Certified private applicators, as defined by federal law, are private property owners or their employees who apply restricted-use pesticides to their own properties, or properties they rent, for the purposes of producing an agricultural commodity. This encompasses farms, ranches, forests, greenhouses, and nurseries. The 1990 Farm Bill, also known as the Food, Agriculture, Conservation, and Trade Act, is administered by the USDA Agricultural Marketing Service (USDA-AMS), and requires private applicators to keep records on all applications of federally “restricted-use” pesticides, even spot-spray applications. These records must be recorded within 14 days of the application, and retained for a minimum of 2 years. (Note: The USDA-AMS Pesticide Recordkeeping Program operations ended in September 2013 due to the elimination of program funding. However, their website is still viable.)
Some states require records for any pesticide applied. State compliance officers conduct enforcement. Requirements vary significantly from state to state; some examples follow:
- record all pesticide applications, not only restricted-use pesticides
- additional recordkeeping items, including wind direction, wind speed, and air temperature
- complete the record in a specified time period that is less than 14 days
- retain records for greater than 2 years
- mandatory record reporting
Use of a state’s form may be voluntary, but it captures the required items. To determine the requirements in your state, contact your state pesticide regulatory agency, or see the Recordkeeping Resources page.
Worker Protection Standard Records
Farm, forest, nursery, or greenhouse businesses, who employ pesticide handlers or agricultural workers and have their employees entering treated areas within 30 days of a pesticide application, must comply with the federal The Worker Protection Standard (WPS) and its corresponding recordkeeping/application information requirements. WPS requirements are for any agricultural pesticide application. These records ensure that employees of agricultural establishments have access to information about what has been applied and all restricted-entry intervals. Several states have combined WPS and application record requirements on one form; a good example is North Carolina State University’s Private Applicator Form (see “One-page Recordkeeping Form for the Worker Protection Standard and the USDA Restricted-Use Pesticide Regulation (on farms)”.
Below is a list of USDA and WPS requirement descriptions for each recordkeeping item. For several of these items you must refer to the pesticide label.
Private Applicator Recordkeeping Items and Detailed Descriptions
- USDA denotes requirements for restricted-use pesticide applications
- WPS denotes requirements for worker safety information
| USDA | Name of Certified Private Applicator: certified applicator who did the application or supervised a non-certified person |
| USDA | Private Applicator Certification (applicator license) Number: state certification (applicator license) number |
| USDA& WPS | Date of Application: month, day, year of application |
| USDA& WPS | Brand Name/Product Name: name by which the manufacturer sells that product formulation (i.e., Roundup Original or Roundup Ultra, but not the active ingredient glyphosate). If you tank mix products, each restricted-use product name must be listed. (i.e., Tordon 22K and Banvel SGF) |
| USDA& WPS | 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 xxx-xxx-xx. If an SLN labeled product is applied, record its registration number as well. |
| USDA | Total Amount of Undiluted Pesticide Applied or Used: this is the amount of pesticide product only applied to the entire application area; rate of product times the area covered. For example, 2 pints per acre times 40 acres is equal to 80 pints total amount applied. This is not the amount of spray batch applied which includes water, nor is it the percent active ingredient in the product. |
| USDA | Crop, Commodity, Stored Product, or Site: what you made the application to, such as potatoes, elm trees, stored barley, dairy cows |
| USDA | Physical Location of Treated Area: location of the field, forest, nursery, such as section, township, range. It can include maps or written descriptions or a USDA identification system such as those used by the Farm Service Agency or Natural Resources Conservation Service which involves maps and a numbering system to identify field locations. It can also be the legal property description, as listed on the deed of trust or county/city records, or an applicator generated identification system that accurately identifies the location of the application. If location is a greenhouse or nursery, identify it by a name and location. |
| USDA | Size of Treated Area (area or volume): Record this information in the unit of measure, such as acres, linear feet, bushels, cubic feet, number of animals, etc. Use the unit expressed on the label for the product you applied. For example, 450 acres, spot treatment, 100 head of cattle, 1,000 potted ornamental plants, 40 linear feet, 250 bushels, 1,000 cubic feet, 50 trees. |
| WPS | Time of Application: Record both the start and stop times. This determines the start and end of a restricted-entry interval |
| WPS | Active Ingredients: common name of the active ingredients is found in the ingredient statement. For example, glyphosate is listed in the active ingredient statement of the formulated product Roundup Ultra. If the label does not list the common name of the active ingredient, find it on the Material Safety Data Sheet. |
| WPS | Restricted-Entry Interval: all agricultural labels have a restricted-entry interval, usually found in the Agricultural Use Requirements box. Ranches are exempt from WPS. |
Recording spot treatments
Spot treatments are useful in certain situations, particularly for noxious weed control. In this case, a spot treatment is defined as a single-day use of a restricted-use product where the total area treated is less than 1/10 of an acre. This could be 1/10 of an acre of weeds within a 5-acre pasture. Spot treatments require the following records.
Date of application including month, day and year; Brand or product name and the EPA registration number; Total amount of pesticide applied; Location of the pesticide application designated as “spot application” followed by a description. For example, “spot treatment–treated for noxious weeds in Fields A and C”, or “spot treatment along road to grain bins”
A workbook that was initially developed by North Carolina State University for USDA-AMS Private Applicator Recordkeeping is available at this website.
Failure to comply with recordkeeping requirements may result in fines and/or civil penalties according to a state’s civil penalty matrix.
References Cited
Fishel, F.M. 2019. The Importance of Keeping Pesticide Records. Pesticide Information Office, University of Florida. PI-246.
USDA Agricultural Marketing Service web site for private applicator recordkeeping.
Initial content authored by Carol Black
