The Licence That Wasn't Issued Yet

1. Unlicensed application. An exterminator licence is personal. Passing the certification exams is a prerequisite, not a substitute for the issued licence. If the regulation permits an unlicensed assistant to work at all, it is only under the direct supervision of a licensed exterminator who is present and accountable. Sending the hire out alone is the core failure: it exposes the hire, the licence holder and the company to offences, and it can void liability insurance.

2. Restricted-class product. Restricted-class pesticides carry conditions beyond an ordinary licence. The hire should have confirmed both his licence class and the product's classification before opening the container. He cannot.

3. Perimeter work near a drain. Ontario law prohibits discharging pesticides to water, and labels commonly restrict application where runoff can enter drains, sewers or watercourses. A 200 m run to a creek, an asphalt lot and unknown grade mean runoff must be assessed (grade, forecast rain, buffer distance) before application. A blanket band along the foundation is also hard to defend as IPM.

4. The cosmetic ban. The ban targets aesthetic uses on lawns, gardens and hard surfaces. Controlling a structural pest to protect a building and public health generally falls outside it - but only where there is documented pest evidence, a least-risk product and label-compliant targeted placement. 'Tidying the perimeter' would be cosmetic; treating entry points for a real infestation is not. He must be able to prove which this was.

Before dispatch:

• Verify the hire's licence status in writing with MECP; if not issued, schedule him as a supervised assistant with a licensed exterminator on site.
• Match the licence class and any restricted-class conditions to the specific products.
• Obtain the service request, do a site assessment (species, harbourage, access, occupants, sensitive neighbours), and set a threshold for treatment.
• Check the label for use sites, rate, method and re-entry interval; check forecast and drainage for the exterior work.
• Give him a spill kit, PPE from the label, and a written emergency contact list.

Documentation for each visit: date and time; applicator name and licence number; species identified and evidence (specimens, photos, monitor counts); product name and PCP registration number; dilution, total volume and area treated; method and placement locations; re-entry information given; name of the person notified; calibration record; any deviation and why. Records must be retained for the period the regulation specifies and produced on request to an inspector - the inspector's first question will be 'who applied this and under what authority?'

'Everyone does it' is not a lawful basis, and the comparison to cosmetic weed control actually cuts the other way: cosmetic use on hard surfaces is restricted, so the work only survives if it is genuinely structural pest management.

Make it defensible by showing the chain of reasoning:

1. Evidence - what pest, where, how many, and what damage or entry risk? Photographs and monitor data, not a hunch.
2. Entry points, not area - treat cracks, expansion joints, utility penetrations and thresholds where the pest actually crosses, rather than a continuous band.
3. Least-risk product - a formulation and rate justified by the label, not by habit; document why a non-chemical option (sealing, sanitation, drainage repair) alone was insufficient.
4. Runoff control - no application before rain, on sloping asphalt toward the drain, or within any label buffer; consider granular or bait placements that cannot wash.
5. Notice and records - inform the plaza operator, note the re-entry time, and file the assessment with the application record.

If the manager wants an annual prophylactic band regardless of pest activity, the honest answer is that this is not structural pest management and the technician should decline and escalate to the licence holder.