Restricted-use Pesticide Recordkeeping
Rules for Certified Private Applicators
The Federal Pesticide Recordkeeping • The crop, commodity, stored • county, range, township, and
Program was authorized by the Food, product, or site to which the section;
Agriculture, Conservation, and pesticide was applied.
Trade Act of 1990, commonly • an identification system using
referred to as the 1990 Farm Bill.1 • The month, day, and year on maps and/or written descriptions
These rules apply to both certified which the restricted-use pesticide that accurately identify the location;
private and commercial applicators. application occurred.
The Iowa Pesticide Act already • an identification system
requires commercial applicators to • The name and certification number established by a USDA agency, such
keep records of all pesticide of the certified applicator who as the Farm Service Agency (FSA) or
applications for 3 years. The new applied the restricted-use pesticide. the Natural Resources Conservation
rules for private pesticide applicators Service (NRCS), that uses maps and
require records for all restricted use The following frequently asked a numbering system to identify field
be kept for 2 years. questions and their answers may locations; or
help you understand the
The federal regulations require recordkeeping regulations. • the legal property description.
private pesticide applicators to
record the following information What do I include in the total What can I record as the
within 14 days2 of the restricted-use amount of the restricted-use size of area treated?
pesticide application: pesticide applied? Match the terms used in the
Record the total quantity of pesticide directions for use section of the
• The brand or product name and product used, listing each restricted- product label. For example, use
the Environmental Protection use pesticide separately. Do not acres for field crops, linear feet for
Agency (EPA) registration number record the percentage of active fencerows and rights of way, square
of the restricted-use pesticide that ingredient or the amount of water feet for greenhouses and nurseries,
was applied. Note: The registration used as a carrying agent. or whatever designation was used on
number is not the same as the EPA the label of the product you used.
Establishment Number, which is also How should I record the location For livestock and poultry records,
on the label. of the pesticide application? enter the number of animals treated.
Record the actual location where the
• The total amount of the restricted- application of restricted-use pesticide
use pesticide applied. was made. The United States
Department of Agriculture (USDA) 1
Officially known as section 1491 of the
• The location of the application. allows several options for recording
Food, Agriculture, Conservation, and
the field “location,” including the Trade (FACT) Act of 1990.
• The size of the area treated. following: 2
However, whether or not the written record
has been completed, the certified applicator
shall provide the record information for
medical treatment or first aid.
PAT 11 Revised September 2000
How do I record spot How long must I keep restricted- pesticide. By law, the commercial
applications? use pesticide records? applicator must provide these
If you apply restricted-use pesticides Records of restricted-use pesticide records to the client within 30 days
in a total area of less than 1/10 of an applications by private applicators of the restricted-use pesticide
acre on the same day, you must must be retained for 2 years from application. Commercial pesticide
record the brand or product name, the date of application. The Iowa applicators can choose to provide
EPA registration number, total Pesticide Act requires commercial either a copy of the application
amount applied, the location of applicators to keep restricted-use records required for the Iowa
treatment designated as spot pesticide records for 3 years. Pesticide Act or the records required
application, description of the area under the 1990 Farm Bill.
treated, and the month, day, and Does the regulation for private
year of the application. Your record applicators apply to all pesticide Is a federal form required to
also must include a concise applications? maintain the record(s)?
description of location of treatment. No. The regulations only require No. Applicators may fit the record-
For example, if you applied a recordkeeping for applications of keeping requirements into their
herbicide for noxious weed control, federally restricted-use pesticides. current recordkeeping scheme. An
you could record the location of example of a form that may be used
treatment as a spot application, What is the difference between a for recordkeeping is an insert to this
followed by an explanation such as certified commercial applicator publication. Request PAT 11A or
“treated Canada thistle throughout and a certified private applicator? visit the ISU Extension website at
field number 8.” This provision Certified private pesticide www.extension.iastate.edu to print
excludes greenhouse and nursery applicators are persons, or their out copies.
applicators, who are required to employees, who are certified by the
keep their records as described on state to apply restricted-use Which federal and/or state
page 1. pesticides in the production of an agencies can request my
agricultural commodity on property restricted-use pesticide records?
What is meant by crop, owned or rented by the applicator or Under the Federal Insecticide,
commodity, stored product, or the applicator’s employer. In Fungicide, and Rodenticide Act
site to which a restricted-use addition, individuals who apply a (FIFRA) and the Iowa Pesticide Act,
pesticide was applied? restricted-use pesticide without the Iowa Department of Agriculture
This includes general references compensation, other than trading and Land Stewardship has access to
such as corn, soybean, or alfalfa, not personal services between producers all commercial pesticide applicator
specific scientific or variety names. of agricultural commodities, on the records for 3 years after the date of
Commodity also includes stored property of another person are application. Under the 1990 Farm
products such as grain, apples, or considered private pesticide Bill, private pesticide applicators are
other agricultural products to which applicators. Certified commercial required to provide access to their
a restricted-use pesticide may be pesticide applicators are certified to restricted-use pesticide records to
applied, whereas site includes apply general or restricted-use authorized representatives of the
fencerow, livestock, and poultry. pesticides on the property of another USDA and the Iowa Department of
person for compensation. Agriculture and Land Stewardship.
When do I have to record
the restricted-use pesticide How does the law affect certified Who else has access to my
application information? commercial applicators? restricted-use pesticide records?
You must record the required Commercial pesticide applicators are Licensed health care professionals,
information within 14 days follow- required to provide a copy of the or those acting under their direction,
ing the pesticide application. required records to individuals who may access your records when
hire them to apply a restricted-use treating individuals who may have
been exposed to restricted-use information, maintained in a data Are there any penalties for
pesticides. A licensed health care base on agricultural pesticide violation of the federal pesticide
professional is defined as a use, provides annual reports to recordkeeping requirements?
physician, nurse, emergency medical Congress, which can be valuable Yes. A certified pesticide applicator
technician, or other qualified in policy discussions involving who violates any provision of the act
individual, licensed or certified pesticide use. will be subject to a fine of not more
by the state to provide medical than $550 for the first violation. For
treatment. Who is responsible for surveying subsequent violations, the penalties
the nonagricultural uses of will be not less than $1,100 for each
Will the records be surveyed? restricted-use pesticides? violation, unless the administrator of
USDA’s National Agricultural EPA surveys commercial pesticide the USDA Agricultural Marketing
Statistics Service (NASS) conducts applicators who apply restricted-use Service, or his or her designee,
surveys on pesticide use for agri- pesticides to nonagricultural sites determines that the certified
cultural production. The survey such as turf and roadsides. applicator made a good faith effort
Recordkeeping Pocket Guide Available
Iowa State University Extension has numbers for commonly used such as fertilizer use, manure
developed a recordkeeping pocket restricted-use pesticides. The applications, and variety planted.
guide to help farmers comply with pesticide applicator’s name and Not all of this general information is
the restricted-use pesticide rules. certification number, and the total required under law, but producers
The pocket guide is an effective tool amount of pesticide applied per field should find the records useful.
for farmers to use to be in should be recorded in the tables Pocket guides are available
compliance. It includes space for provided in the pocket guide. at county extension offices. Ask for
each of the items to be recorded on a ICM 1, Field Records for Integrated
field-by-field basis and contains a In addition, the pocket guide has Crop Management, Restricted-Use
directory of EPA registration space to enter general field records, Pesticide Applications and Manure
Prepared by Joyce Hornstein and Rich Pope, extension program specialists, and edited by Julie Todd, extension program specialist,
Department of Entomology.
This project has been funded by the Iowa Department of Agriculture and Land Stewardship through a grant
from the U.S. Department of Agriculture.
File: Pest Management 1 11/01
. . . and justice for all Issued in furtherance of Cooperative Extension work, Acts of May 8 and June
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programs and activities on the basis of race, color, national origin, gender, Johnson, director, Cooperative Extension Service, Iowa State University of
religion, age, disability, political beliefs, sexual orientation, and marital or family Science and Technology, Ames, Iowa.
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made available in alternative formats for ADA clients. To file a complaint of
discrimination, write USDA, Office of Civil Rights, Room 326-W, Whitten
Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or