Recordkeeping and Worker Safety

All organic growers must follow the rules set forth by the NOP in order to maintain their organic certification. NOP certification rules apply to ALL aspects of organic crop production, from seed selection to soil management and from pest management to disinfecting equipment. Any input into the system must be recorded and must adhere to the NOP guidelines.

If pesticides are used, growers are also subject to federal and state pesticide laws, including (but not limited to) applicator licensing, legal pesticide use, safety and recordkeeping. Pesticide laws must be observed whenever an application is made to manage a pest.

Recordkeeping for NOP and pesticide applications

Organic growers must maintain records of all their production activities and operations for a minimum of five years. Types of information tracked may include compost production activities, crop rotation records, soil amendments, and fertilizer applications. If you use any pesticides, including disinfectants, 25(b) products, or any other material for pest management, you MUST keep records of these applications for NOP certification.

The USDA requires records of restricted-use pesticides applied by Private Pesticide Applicators (for more information see the next paragraph). Records of pesticide applications may also be required for state pesticide compliance. State pesticide laws vary with respect to pesticide application recordkeeping requirements. In some states, records must be kept on ALL pesticides applied (including 25(b) products and organic-approved pesticides). Pesticide application records must be retained for a certain period of time from the date of application. This may be a different period than that required for NOP records. The exact length of time required varies depending on individual state law; contact your pesticide licensing agency for more information.

Typically, pesticide application records must include information about both the product (such as name and EPA registration number, if applicable) and the application (such as the location and amount applied). Additional information, such as weather conditions at the time of application, is required in some states. Some states provide specific recordkeeping forms, while others use standard federal forms. For more information on pesticide records, see the USDA AMS Pesticide Recordkeeping Program website, as well as the Recordkeeping module of the Pesticide Environmental Stewardship (PES) website.

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Worker safety

When applying ANY pesticides (including those approved for organic use), appropriate personal protective equipment (PPE) must be used and all safety precautions followed. The pesticide label will contain minimum requirements for PPE.

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The Worker Protection Standard (WPS) provides guidelines on safe handling, application, and use of pesticides for agricultural workers and pesticide handlers. The WPS does not apply to all situations, but the guidelines are an excellent basis for safe pesticide handling and worker protection. If the pesticide label has an Agricultural Use Requirements box, WPS rules MUST be followed. To learn more, visit the Worker Protection Standard module of the PES website and these US EPA websites:

•    Worker Protection Standard for Agricultural Pesticides
•    How To Comply With the Worker Protection Standard for Agricultural Pesticides: What Employers Need To Know

Some states have more stringent protection requirements than those in federal law; contact your state Department of Agriculture if you have questions.

 

Initial compilation courtesy of Lenora Jones

Washington State University Extension