The existing regulation for…

The existing regulation for Class 4, specifically Fly Bait products, can be used by the following:
Certified (Qualified) Farmer, Supervised Assistant Farmer, Licensed Exterminator, Technician Trainee, Bee Inspector, Registered Beekeeper, Farmer*

*Farmers who are not certified must present their Farm Business Registration Number or signed self-declaration form to the vendor.

Unfortunately, the new regulation below is NOT aligned with the existing regulation above and needs modification or the addition of “*Farmers who are not certified must present their Farm Business Registration Number or signed self-declaration form to the vendor.” The new regulation below forces the Farmer to be trained and certified which was ONLY a requirement of Class 2 and 3 products due to them being a higher hazard pesticide. This new regulation now groups less hazard pesticides or Class 4 pesticides with higher hazard Class 2 and 3 pesticides which then changes the requirement of a farmer who now MUST have training and certification. There is an economic argument and a potential of impeding fair trade. The farmer (hobbyist etc.) who doesn’t get training and certification is now removed from buying Class 4 less hazard pesticides (Fly Bait specific) which will have a great financial impact on the industry. Allowing the existing group to buy Class 4 pesticides but then eliminating a buying source (not certified farmer) impedes fair trade. If there was no reason for training and certification on Class 4 less hazard pesticides in the past, what is the purpose of it now?

If this was unintentional missed in the new regulation below, I would kindly ask that modification of below occurs in that “not certified farmers” are added, so it aligns with the existing regulation.

New Regulation:
Farmers are currently exempt from licensing requirements to use certain pesticides. Instead, training and certification are required in order to use certain Class 2 and 3 pesticides for farming operations. Training and certification are currently not required to use Class 4 pesticides, which are lower hazard pesticides. As a result of reclassification, Classes 2, 3, and 4 would now become Classes B and C. It is proposed that farmers would continue to be exempt from the need for a licence to use Class B and C pesticides; however, a farmer would be required to be trained and certified to use Class B and C pesticides because these classes include higher hazard pesticides. A farmer with training but no certification would be able to use these pesticides without a licence if used under the supervision of a certified farmer.