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Pesticide Record-Keeping Requirements

June 8, 2001
Although most applicators keep pesticide application records because it makes good agronomic sense to do so, there are legal reasons to keep these records as well. The purpose of this article is to sift through the gossip and guessing about the record-keeping requirements and get to the facts. As you will see, the type of information you are legally required to keep depends on your type of business and the type of pesticide you use. Many folks view their pesticide records as "a good insurance policy" against false accusations. Although it is not required in Illinois, it is a good idea to record (on-site) wind direction and speed during the application should you find yourself in the middle of a drift complaint.

Private Applicators

According to the 1990 Farm Bill, all private applicators (those who apply pesticides to their own land) must maintain records of restricted-use pesticide (RUP) applications. The following information must be recorded within 14 days of the RUP application (Note: WPS exception below) and maintained for 2 years.

1. Certified applicator's name and certification number

2. Date of application (M/D/Y)

3. Pesticide product name and its U.S. EPA registration number

4. Amount of chemical concentrate applied (e.g., pints, quarts, gallons, pounds)

5. Crop, commodity, stored product, or site treated

6. Size of the area treated (acres, bushels, animals, etc.)

7. Location of application (any identification system that accurately identifies the location of the application). For spot applications, simply enter "spot application" and a short description of the location. Greenhouses and nurseries must still give complete descriptions for spot applications (e.g., which bench, row, block, plant).

Commercial Applicators

According to the Illinois Pesticide Act, all commercial applicators must maintain records of RUP applications they make. The following information must be recorded and retained for 2 years from the date of application. In addition, federal regulations require all commercial applicators to furnish a copy of either the state or federally required records to the customer within 30 days of the RUP application (Note: WPS exception below).

1. Pesticide product name and its U.S. EPA registration number

2. Amount of chemical concentrate applied per unit (e.g., pounds or ounces per acre)

3. Date of application (M/D/Y)

4. Use site(s)

Pesticide Dealers

According to the Illinois Pesticide Act, pesticide dealers must retain a record of each individual RUP sale for 2 years. The record must include the following information:

1. Purchaser's name, address, and certification number and type of certification if appropriate

2. Quantity and kind of pesticide sold

3. Date of sale

What About WPS Record Keeping?

For producers who must comply with the Worker Protection Standards (WPS), the record-keeping requirements are a bit different. Following is a combined list of information required by the WPS and the private RUP record-keeping laws. The information preceded by an asterisk (*) is only required when a RUP is used. Keep in mind, however, that there is nothing wrong with keeping more detailed records than is required by law!

1. *Certified applicator's name and certification number

2. Time and date the pesticide is scheduled to be applied and when it is safe to reenter the site (e.g., list the pesticide's restricted-entry interval, or REI)

3. Pesticide product name, active ingredient(s), and its U.S. EPA registration number

4. *Amount of chemical concentration applied (e.g., pints, quarts, gallons, pounds)

5. *Crop, commodity, stored product, or site treated

6. *Size of the area treated (acres, bushels, animals, etc.)

7. Location of application (any identification system that accurately identifies the location of the application). For spot applications, simply enter "spot application" and a short description of the location. Greenhouses and nurseries must still give complete descriptions for spot applications (e.g., which bench, row, block, plant).

Other Key Items for WPS Employers

· To protect WPS employees (farm workers, scouts, and applicators) who might enter treated areas, it is critical that all WPS employers communicate information about planned pesticide applications and those that have already been made. Decide beforehand how such messages will be delivered (e.g., by phone, a note in mail box). When a custom application will not be, or was not, applied as scheduled, the producer must be informed of the corrected time and date before the application takes place or as soon as practicable thereafter (within 24 hours).

· Records for all pesticide applications (including general-use pesticides) must remain available to employees for 30 days beyond the REI.

· The WPS requires more than just record keeping!

Since there are no standard forms required for any of these records, you can use any system you like, as long as the required information is included and it is legible and accessible to those who have a legal right to see it. Many pesticide companies, personal protection equipment suppliers, and other organizations offer record-keeping sheets or notebooks. In addition, there are many companies offering software (some are free) for computerized record keeping. The University of Nebraska lists several software packages on their website (http://pested.unl.edu/pestbkmk.htm, under "Laws & Regs" section). Again, regardless of how you keep records, just be sure you meet the requirements as outlined.

For more information about any of these laws, contact the Illinois Department of Agriculture at (217)785-2427, or your local University of Illinois Extension office. In addition, you can find a good deal of information about these laws at our Pesticide Safety Education website (http://www.pesticidesafety.uiuc.edu).--Bruce Paulsrud

Author: Bruce Paulsrud


The Pest Management and Crop Development Bulletin
Executive Editor: Kevin Steffey, Extension Entomologist

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