Pesticide Recordkeeping Requirements

Although most applicators keep pesticide records because it makes good agronomic and horticultural sense to do so, there are legal reasons as well to keep these records. The purpose of this article is to sift through the gossip and guessing about the recordkeeping 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 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 follows.) and maintained for 2 years.

• Certified applicator’s name and certification number
• Date of application (M/D/Y)
• Pesticide product name and its U.S. EPA registration number
• Amount of chemical concentrate applied (for example, pints, quarts, gallons, pounds)
• Crop, commodity, stored product, or site treated
• Size of the area treated (acres, bushels, animals, etc.)
• Location of application (any system that accurately identifies the location of the application). For a spot application, simply enter “spot application” and a short description of the location. Greenhouses and nurseries must still give complete descriptions for spot applications (for example, 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 two 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 follows.)

• Pesticide product name and its U.S. EPA registration number
• Amount of chemical concentrate applied per unit (for example, pounds or ounces per acre)
• Date of application (M/D/Y)
• Use site(s).

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

• Purchaser’s name, address, and certification number and type of certification if appropriate
• Quantity and kind of pesticide sold
• Date of sale.

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

• Certified applicator’s name and certification number
• Time and date the pesticide is scheduled to be applied and when it is safe to reenter the site (for example, listing the pesticide’s restricted-entry interval, or REI).
• Pesticide product name, active ingredient(s), and its U.S. EPA registration number
• Amount of chemical concentration applied (for example, pints, quarts, gallons, pounds)
• Crop, commodity, stored product, or site treated
• Size of the area treated (acres, bushels, animals, etc.)
• Location of application (any system that accurately identifies the location of the application). For a spot application, simply enter “spot application” and a short description of the location. Greenhouses and nurseries still must give complete descriptions for spot applications (for example, which bench, row, block, plant).

Other key items for WPS employers:

• To protect WPS employees (farmworkers, scouts, and applicators) who might enter treated areas, it is critical that all WPS employers communicate information about planned pesticide applications and those already made. Decide beforehand how such messages will be delivered (for example, by phone, a note in mailbox). 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 hrs).
• 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 recordkeeping!

Because no standard forms are required for any of the records listed here, 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, suppliers of personal protective equipment, and other organizations offer recordkeeping sheets or notebooks. In addition, many companies offer software (some free) for computerized record-keeping. The University of Nebraska lists several software packages on their website (http://ianrwww.unl.edu/ianr/pat/pestbkmk.htm). Again, regardless of how you keep records, just be sure you meet the requirements as outlined here.

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 (www.aces.uiuc.edu/~pse).

Bruce Paulsrud (5/00)
University of Illinois Extension