WSDA Guidance on Complete Wood Destroying Organism Inspections
The Department regulates structural pest inspectors under RCW 15.58 and WAC 16-228. This
memorandum sets out the Department’s legal positions on several issues related to structural pest
inspectors and wood destroying organism (WDO) inspections.
RCW 15.58.445 states in part:
It is unlawful for any business to conduct complete wood destroying organism
inspections without having obtained a company license from the director [of agriculture].
RCW 15.58.030(4) defines a complete WDO inspection as being:
[F]or the purpose of determining evidence of infestation, damage, or conducive
conditions as part of the transfer, exchange, or refinancing of any structure in Washington
The question has arisen as to when a WDO inspection is “part of the transfer, exchange, or
refinancing” of a structure thus requiring that the business be licensed.
The Department’s position is that an inspection is “part of the transfer, exchange, or refinancing”
if the inspection report is used by the owner, buyer, seller, or other party in any manner in the
course of the transfer, exchange, or refinance. Such use may be a formal use where the report is
actually cited in real estate documents, or may be a more informal use for other purposes (e.g., a
homeowner determining what needs to be repaired prior to putting a house on the market).
Whether an inspection is “part of the transfer, exchange, or refinancing” does not depend on
when the inspection is performed. What matters is how the report is ultimately used. Thus, even
if the inspection is called a “pre-sale” inspection, it may be “part of a transfer, exchange, or
refinance” if the property ultimately is transferred, sold, or refinanced and the report is used
without a new complete WDO inspection having been performed.
In the Department’s experience, nearly all complete WDO inspections fall into the transfer-
exchange-refinancing category. Any other