Pesticides include herbicides, fungicides, insecticides, rodenticides, and any other product that claims to control or repel a pest organism.
Why Keep Records?
Federal and state laws require you to keep application records for restricted-use pesticides, or in some cases for all pesticide applications made by a certified applicator. Application records demonstrate applicator professionalism by documenting legal use, and the safety, care, and concern taken when making the application. Records serve to refresh applicators’ memories of procedures, timing, and implemented precautions. They are also extremely important business tools that are useful in tracking inventories, informing the workforce of pesticide applications, and when used in conjunction with pest monitoring records, they allow the applicator to evaluate the effectiveness of the applications.
When an application is investigated, records along with other data are used by both the applicator and the regulatory agency to reconstruct the application. Thorough records paint a clear picture of job performance and precautions taken. Without complete records, it is difficult to portray the pesticide applicator as a competent individual when legal actions occur months or years after the application in question. Also, records are crucial to providing compliance officers with the best information known at the time of the application about the conditions under which the pesticide was applied.
Recordkeeping Requirements under USDA or US EPA regulations depend on the type of certification you have: Private Applicator or All Other Certified Applicators. In addition, many states have incorporated USDA or EPA requirements into their state regulations and added other recordkeeping items. However, a prudent applicator always records significantly more information than the minimum requirements.
Consider which format is easy for you to maintain while keeping in mind who needs access to the information. Records are typically handwritten on individual forms or note cards. There are recordkeeping books that contain a year’s worth of forms. Other records may simply be the invoice. Some businesses and people have purchased computer recordkeeping software or designed their own computer templates. A few states require records to be maintained or submitted on a particular state form. No matter what format you choose, make sure the form has all the necessary information.
Keeping records on the computer is becoming quite common, but poses some concerns. First, will you be able to access files four to six years later after the initial record was created, and will the software still be usable? Secondly, how will you provide computer records to state/federal regulators or health agencies, if requested; does the software produce an easy-to-read printable version of your records.
What to Record?
The legal requirements are fairly straightforward, though rarely does enforcement staff find flawless records – errors and omissions are a violation of state or federal law. Consider the importance of recording each detail that describes the materials applied, how they were applied, how the equipment was set up, and any special circumstances that occurred before, during, and after the application. Don’t forget to record the times you chose to reschedule or abort an application, and why.
Who has Access?
Think about who has access to review your records and what they look for in those records. Custom applicators are required to supply their customers with a record of each application.
Janssen, C. and F. Whitford. 2001. The Why’s and How’s of Pesticide Recordkeeping, Purdue University, Illinois. PPP #54
Ramsay, C.A. and C.R. Foss. 2004. Use of a Survey as an Educational Tool for Recordkeeping. Journal of Pesticide Safety Education. 6:1-14.
Weaver, M.J. 2003. Recordkeeping Regulations for Private Applicators – Interactive CD. Virginia Tech Pesticide Programs and USDA Agricultural Marketing Service. (copies available through USDA-Agricultural Marketing Service at firstname.lastname@example.org
Authored by Carol Ramsay