Requirements for Non-Private Applicators

All Other Certified Applicator Record Requirements

Any certified applicator, other than private applicators, who applies restricted-use pesticides must keep records as required by 40 CFR 171.11(c)(7), which is administered by US EPA. However, most states have put EPA’s and additional recordkeeping regulations in place. Each state uses several different titles for certified applicators, which include, but are not limited to, Commercial Applicator or Operator, Public Operator, and NonCommercial Applicator. Most states’ rules require additional records for any pesticide applied, not only restricted-use products. Hyperlinks below provide state forms. Use of state-specific forms is typically voluntary, but using them ensures you capture the required items.

States generally require more recordkeeping items than the EPA requirements listed below. EPA requires access to these records for inspection and copying by an EPA representative for a period of at least two years from the date of application. Following are the EPA requirements.

EPA Requirements for Commercial Applicator Recordkeeping

Note: most states have several additional requirements

  1. Name and address of the person for whom the pesticide was applied: This may be the customer of a custom applicator/PCO, or the business that employs the applicator who is applying to publicly- or privately-owned non-agricultural ground.
  2. Physical Location of Treated Area: location of the field, forest, nursery, such as section, township, range, mileposts, street numbers
  3. Target Pest: species that you are attempting to control (e.g., Canada thistle, elm aphid, Phytophtora sp.)
  4. Crop, Commodity, Stored Product, or Site: what you made the application to, such as potatoes, elm trees, lawn, pond, lake, stored barley, dairy cows, or indoor cracks and crevices
  5. Date of Application: month, day, year of application
  6. Brand Name/Product Name: name by which the manufacturer sells that product formulation (i.e., Roundup Original or Roundup Ultra, but not glyphosate). If you tank mix products, each restricted-use product name must be listed (i.e., Tordon 22K and Banvel SGF).
  7. EPA Registration Number (EPA Reg. No.): listed just under the active ingredient statement on most product labels. Make sure you write down the EPA Reg. No and not the EPA Establishment Number (EPA Est. No). Look for something similar to EPA Reg. No 3120-280. If an SLN labeled product is applied, record its registration number as well.
  8. Percentage of Active Ingredient per Unit of the Pesticide Used: percent active ingredient per acre, 1,000 square feet, etc. You can record as amount of total product (pounds or gallons) per unit area, such as 20 quarts product over 10 acres.
  9. Pesticide Disposal:type and amount of the pesticide disposed of, method of disposal, date(s) of disposal, and location of the disposal site.

Requirements vary significantly from state to state. Some of the more common state requirements include one or more of the following:

  • record all pesticide applications, not only restricted-use pesticides
  • additional recordkeeping items, such as wind direction, windspeed and air temperature
  • complete the record in a specified time period
  • retain records for greater than 2 years
  • mandatory record reporting.

Authored by Carol Ramsay

Washington State University Extension