An applicant for a license as a groom must satisfy the Commission that he possesses the necessary qualifications, both mental and physical, to perform the duties required. Elements to be considered, among others, shall be character, reputation, temperament, experience, knowledge of the rules of racing and of the duties of a groom. Applicants between the ages of 16 and 18 years of age must submit Pennsylvania State working papers or an "Educational Certificate" together with their application. No license shall be issued to applicants under 16 years of age.
58 Pa. Code § 183.254