Have you ever performed a pesticide treatment and had it fail? Ever had a customer or client ask what you did months ago, but now you can’t remember? Have you ever said the phrase “those who don’t learn from history are doomed to repeat it”? Worse yet, if you don’t keep a history, there is little to learn from. Today we will discuss pesticide record keeping and how having a “history” of what you have done is oftentimes a requirement, but also why it can be helpful.
Certain pesticides and certain circumstances make pesticide record keeping a requirement. Requirements include, but are not limited to:
- Any use of a Restricted Use Pesticide (RUP)
- Anytime Worker Protection Standard would apply
- Any use of Organo Auxins falling under the Organo Auxin rule
- Certified Tree Farm Program Particpants
- Anybody performing preventative termite treatments
- Anybody using structural fumigants
That is not a short list. This captures many of the pesticide treatments in Florida, but certainly not ALL treatments. This means you might not need to keep pesticide records, but hopefully this blog can show you why you should keep pesticide records.
If you are going to keep records, what kind of information should you gather? There is no end to what you can capture, but for most records at a minimum you need to gather:
- Date and time
- Name of applicator (if a license was needed who had a license)
- Location of treatment and What was treated
- Size of the treatment
- Pesticide used (brand name, active ingredient, EPA registration number)
- Total amount of product used
- Pesticide rate
- Equipment or method of application
- Any restrictions (re-entry, irrigation, etc…)
The Florida Department of Agriculture and Consumer Services (FDACS) has a handy form that lays all this out and even specifies what is required for RUP pesticides and what is needed for WPS applications https://www.fdacs.gov/content/download/2990/file/SPR.pdf (copy and paste into browser, link will NOT take you to site)
In Florida FDACS requires a bit more information when falling under the Organo Auxin Rule (https://www.flrules.org/gateway/ruleno.asp?id=5E-2.033) and has its own record keeping form to help stay compliant (https://forms.fdacs.gov/13328.pdf). In addition to RUP rules, WPS, and Organo Auxin, local governments and other certifying bodies might have requirements as well. Regardless of legal requirements, maintaining records is a good practice to keep.
Maintain pesticide records for two years (with a few requirements going longer) and they must be readily accessible during an inspection or if requested. Ensuring that you maintain records will help to make sure you are protected from any unjustified liability claims or false accusations. The only way to keep transparent and show your work is profession is to maintain pesticide records.
Beyond meeting legal requirements, keeping pesticide records is useful for lots of other reasons. Keeping track of what you have done with treatments in the past can help to avoid things like pesticide resistance, label violations by applying too many times in a year, and general efficacy checks. Some pesticides take a long time to work, or are supposed to last for years, and without records there is no way to confirm what works and what doesn’t. Keeping a history of what you have used and how much can also be good for inventory management and bulk ordering for a season’s worth of chemicals.
Record keeping does not need to be burdensome or simply “another box to check”. RUP pesticides require record keeping, and many agricultural settings do to, but keeping records is always a good idea.
Records are a history of what was done, and history can be a powerful tool for those willing to learn from it.