Pesticide Recordkeeping

Recordkeeping Index

1. What are pesticides?
   
2. Restricted Use Pesticides
   
3. Benefits of Keeping Records
   
4. PIP-42 Pesticide Recordkeeping Requirements for Private Applicators In South Carolina, all private pesticide applicators are required to maintain records or display information on their pesticide applications under three different regulations.
   
5. PIP-43 Pesticide Recordkeeping Requirements for Commercial & Non-commercial Applicators - In South Carolina, commercial and non-commercial pesticide applicators may be required to maintain records on their pesticide applications under more than one regulation.
   
6. PIP-44 Pesticide Application Information Disclosure Requirements - In South Carolina, all pesticide applicators are required to maintain records or display information on their pesticide applications, and often, under more than one regulation.
   
7. Summary of Pesticide Recordkeeping Regulations - Which pesticide uses and which applicators are covered?
   • EPA's Worker Protection Standard
   • South Carolina Pesticide Control Act
   • South Carolina Chemigation Act - SCCA
   • USDA Federal Pesticide Recordkeeping Requirement
   
8. Food, Agriculture, Conservation and Trade Act (FACT) - otherwise known as the "1990 Farm Bill", pesticide recordkeeping requirements for Private applicators
   
9. Pesticide recordkeeping tips
   
10. Time burden of keeping pesticide records
    
11. USDA Powerpoint presentation on pesticide applicator recordkeeping requirements
    
12. Outline and instructions for using the 2003 USDA/Virginia Tech Interactive CD entitled Recordkeeping Regulations for Private Applicators.
    
13. Selected Recordkeeping web sites and publications
    
14. Selected Recordkeeping software web sites

Summary of Pesticide Recordkeeping Requirements

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Robert G. Bellinger, Extension Pesticide Coordinator

What are pesticides?

          Yes, herbicides are pesticides. Unfortunately, the term "pesticide" is often used interchangeably with "insecticide" and thus we frequently see and hear the phrase "pesticides and herbicides". However, herbicides are pesticides under FIFRA and are regulated as such.

          All pesticides are categorized into two (2) groups for regulatory purposes by the EPA. These are Unclassified Pesticides (General Use), and Restricted Use Pesticides (RUPs). Restricted Use Pesticides may only be purchased and used (used in the broad sense to include opening the container, mixing, loading, applying, and rinsing empty containers) by Certified Applicators, or persons under their direct supervision. In South Carolina Certified Applicators include Certified Private, Commercial and Noncommercial Applicators.

          For more information, such as additional materials that are and are not pesticides, see EPA's What is a pesticide? You can return to this page using the "Back" button on your browser.

Benefits of Keeping Records

          The records you keep on pesticide use are not only required by the law, they will also help you improve your farming operation.

• Records help you evaluate how well a chemical worked, particularly if you have used reduced rates or alternative application techniques.
• Records help you figure out how much pesticide you will need in a future year, so that you will not have to store or dispose of extra chemicals.
• Records help to prevent carry-over injury and improve rotation decisions.
• Records may protect you from legal action if you are accused of improper pesticide use.
• Food processors may require pesticide records to evaluate the potential for residues.
• Lenders and land developers often require records to evaluate potential evironmental liability before lending money or buying land.
• Records provide data to respond to surveys conducted by Federal agencies and universities that can impact future availability of some pesticides through re-registration. They may also be used to respond to the public's concern regarding pesticide use.
• Records can save money by helping a farmer determine the best pesticide management program. Records are the key to a successful integrated pest management program.

Summary of Pesticide Recordkeeping Regulations - Which pesticide uses and which applicators are covered?

          In South Carolina, pesticide applicators may be required to maintain records or display information on their pesticide applications under at least four different regulations. All of these regulations require that information or records be made on a per application basis. A given application may be affected by more than one of these regulations. The following information is provided as a brief summary of the recordkeeping requirements of these regulations. You must consult the regulations and individual pesticide labels for complete information.

EPA's Worker Protection Standard - WPS

• The WPS covers ALL pesticides (RUPs and general use) used in the production of agricultural plants. (See the WPS and individual pesticide labels for additional information.) Pesticide and application information to be provided or displayed to WPS employees should be provided for all appropriate pesticides, regardless of whether or not the pesticides are RUPs.
  
• The WPS affects agricultural employers (agriculture plant production, nurseries, greenhouses, and forestry operations). It does not matter if the ag employer is or isn't a Certified Applicator.

South Carolina Pesticide Control Act - SCPCA

• The SCPCA covers the sale and use all pesticides registered in South Carolina.
  
• SCPCA recordkeeping requirement:
  1. Records must be maintained by each company or firm employing licensed commercial or noncommercial pesticide applicators, each licensed commercial applicator if self-employed, and by the employer of each licensed noncommercial applicator, of all pesticides (herbicides, insecticides, etc.) used.
     
  2. The record must include the quantity of each pesticide used, received, or purchased, the common chemical name of the active ingredient(s) (not the product name), the pest or purpose for which the pesticide was applied, and the date and place of application. It is not necessary to list the pests involved for general household insect control or for general insect control measures in commercial and industrial establishments. In these cases the record may indicate merely "household pests" or "general insect control."
     
  3. Records of pesticide applications must be maintained by the company, firm, or licensed commercial or noncommercial applicator as detailed below:
     1. For pre-construction termite-control treatments ("pretreats"), including the installation of bait systems and baits containing active ingredients, records of termiticide application must be maintained for a period of five (5) years or as long as a continuing warranty or contract exists, whichever is longer, and must be made available to the Director or his designee for review and duplication upon request at the expense of the Department.
     2. For post-construction termite control treatments, including the installation of bait systems and baits containing active ingredients, records of termiticide application must be maintained for a period of two (2) years from the date of application or as long as a continuing warranty or contract exists, whichever is longer, and must be made available to the Director or his designee for review and duplication upon request at the expense of the Department.
     3. Records of pesticide applications other than termiticides must be maintained for a period of two (2) years from the date of the application.
     
     
  4. The Director may request records of all pesticides used by any applicator. This includes application records as well as any records of or related to pesticides purchased or otherwise received by the applicator. The expense of copying or duplicating those records shall be paid by the Department.
  
  
• Commercial Applicators must provide copies of application records to clients who are Certified Private Applicators within 30 days of an application of an RUP.

South Carolina Chemigation Act - SCCA

• The SCCA affects ALL chemicals (fertilizers, plant growth regulators, pesticides (both general use and RUPs), etc.), applied to agricultural crops, nurseries, turf, golf courses, greenhouse sites, or land through irrigation equipment. This includes overhead irrigation, trickle irrigation, etc.
  
• The ability to use pesticides in chemigation is on the individual product label.
  
• The SCCA affects any chemigator, whether or not the individual is a Certified Applicator.
  
• When the water supply used in chemigation is a public water supply, the SCDHEC's State Safe Drinking Water Act must be complied with.

USDA Federal Pesticide Recordkeeping Requirement

• The Federal pesticide recordkeeping requirement covers RUPs ONLY.
  
• It affects both Certified Private and Commercial Applicators in states with no recordkeeping requirements.
  
• In South Carolina, Certified Commercial Applicators were already required to keep records of their RUP applications by the SCPCA (above). This federal regulation now requires that Certified Private Applicators also keep records of their RUP applications.

Pesticide Recordkeeping Tips

          Under the SC Pesticide Control Act, the SC Chemigation Act, and the USDA Federal pesticide recordkeeping requirement, records must be maintained for two (2) years from the date of the application. Again, the WPS does not require application records to be maintained after the required display period.

          Whenever you are recording information on any of your pesticide applications, identify the pesticide(s) with three (3) identifiers:

1. The BRAND (Trade) or PRODUCT name,
2. The COMMON CHEMICAL name (active ingredient name), and
3. the EPA Registration No.

          Each of the recordkeeping regulations above vary in which of the identifiers they require. Because you may be required to display information or keep pesticide application records under more than one regulation, use all three identifiers any time you record application information so you don't have to worry about which regulation you are keeping records for.

A tip: Sometimes the pesticide label does not have the common chemical name of the active ingredient on it, rather, the full chemical name. You can often find the common chemical name on the Material Safety Data Sheet MSDS.

An example: A pesticide product called "FURY 1.5 EC INSECTICIDE" lists the active ingredient name on its label as: S-Cyano (3-phenoxyphenyl)methyl (+,-) cis/trans 3-(2,2-dichloroethenyl)-2,2 dimethylcyclopropane carboxylate. The MSDS provides, in addition to the chemical nomenclature, the common chemical name, in this case, zeta-cypermethrin.

          Records for the various regulations do not have to be kept individually; you can keep a single, comprehensive set of application records, provided that you keep all required data elements. The records can be on paper, or in a computer file, or both.

          The Clemson University Cooperative Extension Service encourages ALL pesticide applicators to keep good records of ALL their pesticide applications. Good application records not only meet regulatory requirements, but provides information the grower/applicator can use to trouble-shoot application/control problems, or to duplicate control successes. You should keep any additional information in your records that would be useful to YOU, such as weather information, nozzle sizes, spray pressures, rates, ground speed, etc.

          Recordkeeping regulations for Private Pesticide Applicators are found in the Federal Food, Agriculture, Conservation and Trade Act (FACT), administered by the USDA Agricultural Marketing Service (AMS). More detailed information on pesticide recordkeeping is available from your County Extension Pesticide Training Coordinator, or the SC Department of Pesticide Regulation.

Some Statistics on the Time Burden for Certified Pesticide Applicators to Comply with the Federal Pesticide Recordkeeping Requirement

The USDA Agricultural Marketing Service, in a Notice of Request for Extension and Revision of the Federal Pesticide Recordkeeping Requirement information collection in the Federal Register provides the data below. These numbers are based on a national average of over 705,000 Certified Private Applicators keeping records on their Restricted Use Pesticide (RUP) applications. (Source: Federal Register. Vol. 64, No. 25. February 8, 1999.)

In complying with the Federal pesticide recordkeeping requirement:

• On the average, there is a total annual time burden of 0.35 hours per record keeper (Certified Private Applicator).
  
• On the average, for each of those Certified Private Applicators who are selected annually for recordkeeping inspections, there is an annual time burden of 0.85 hours. (Each year 188 Ceritified Private Applicators are selected for pesticide recordkeeping inspections in South Carolina.)
  
• The USDA/AMS estimates that Certified Private Applicators (recordkeepers), record an average of 5 Restricted Use Pesticide (RUP) applications annually.
  
• Commercial applicators provide 616 copies of Restricted Use Pesticide records to their clients annually. The USDA/AMS reports nationally there are over 308,500 commercial applicators who are required to provide copies of RUP applications to their clients.
  

USDA PowerPoint® presentation on pesticide applicator recordkeeping requirements

The following are links to important Recordkeeping web sites and publications:

• USDA AMS Federal Pesticide. Recordkeeping Program
  
• Federal Restricted-Use Pesticide Recordkeeping Inspection.
  
• Federal Pesticide Recordkeeping For Certified Applicators - PowerPoint slide show of the Federal Pesticide Recordkeeping for Certified Applicators from the USDA/AMS. (If you don't have PowerPoint® 97 or greater on your computer you can download a PowerPoint® Viewer 2003 free from Microsoft.)
  
• Department of Pesticide Regulation - South Carolina's pesticide regulatory agency.
  

The following are links to Pesticide Recordkeeping software web sites:

• Agrosoft Systems^© - PestCalc dB^©, the pesticide rate calculation software; and the Record Keeper^©, a pesticide application record tracker.
  
• ChemTrak^TM
  
• eSpray Spray Management System
  
• KAHILTNA Agricultural Record Keeping and Data Analysis Software - Kahiltna Pesticide Application Record Keeping Database.
  
• LadyBug Chemical Application Program - a chemical application, tracking and reporting program
  
• Orange Software's Tiger Jill
  
• Pesticide Recordkeeping Software Sites - University of Nebraska Pesticide Education Resources provides a listing for you.
• sprayMapper Software - to maintain required spray reports and daily logs, map and print your spray locations, or export them to GIS shape files for inclusion in a GIS system. If your state requires electronic reporting, sprayMapper can automatically submit your reporting information.
  
• University of Tennessee Pesticide Recordkeeping Program - this program may be downloaded from this site
  
• Farm Assist crop management software program - Includes pesticide and fertilizer application recordkeeping.