Pesticide Recordkeeping for Private Applicators: The Basics and More

1. Pesticide Recordkeeping for Private Applicators: The Basics and More

2. Why keep good records? • State and Federal regulations require it! • Liability Protection • Application Efficacy – how well the product(s) worked • Pest Management Decisions

3. Recordkeeping Requirements for Private Applicators • 1990 Farm Bill requires that private applicators keep records for all Federally restricted use pesticides. • Keep for 2 years. • State regulations requires records for 2,4-D and MCPA herbicides. • Keep 2,4-D/MCPA records for 3 years.

4. Records required for Federally restricted use pesticides • Brand name and registration # of pesticide • Total amount applied • Date (mm/dd/yyyy) • Detailed location or i.d. of crop/field • Crop, commodity, or site • Size of area treated • Name of applicator • License number of applicator • Must be retained for 2 years

5. Name and address of crop owner *Detailed location of crop *Date with starting and ending times Wind speed and direction (with type of instrument and where it was located) *Brand name and registration # *Crop and # of acres Type of equipment used Distance from, and direction to, susceptible crops in 1 mile radius of treated crop *Name of applicator Must be retained for 3 years. For 2,4-D and MCPA (Class F) products, records required are: * Records in common with the Federal RUP requirements.

6. Recordkeeping Requirements for Private Applicators • The Worker Protection Standard requires records for ALL pesticide applications • Keep for 2 years. • All records must be furnished to the Arkansas State Plant Board upon request.

7. Worker Protection Standard (WPS) Records(Federal requirement for ALL pesticides applied to farms, forests, nurseries and greenhouses) • Date and time of application • Field or site identification/location • Full brand name for the product • EPA registration number • Restricted Entry Interval (REI) • Keep for 2 years (post for 30 days after REI) • Must be made available to regulatory agencies or health care professionals upon request.

8. Recordkeeping Form • No specific form is required for any of these records. • The Extension Service has a single form that covers all the different requirements: • http://www.aragriculture.org/pesticides

9. http://www.aragriculture.org/pesticides

10. Details worth noting • Spray tank concentration • Record the amount of product and the total spray volume mixed. • For example, 8 pints in 100 gallons water; • Surfactants and other Adjuvants • Note the product name and spray mix rate of any adjuvants (buffers, surfactants, spreaders, etc). • Use this information to assess efficacy and possible damage. • Consider the impact of reducing your gallons per acre volume on the surfactant load of the mix.

11. Wind • Wind speed during the application taken in the area of the application • Purchase a quality wind meter to measure wind speed. There are several in the market ranging from $40-$120. • Take readings several times during the application if possible and record the range, for example, 4.5-5.8 mph. • Do not simply report calm or gusty.

12. Wind direction during the application, taken in the area of the application • Try to avoid words or letters for wind direction (ex., south, NW) • When you apply in areas with concerns for off-target movement, use a compass reading ex., a range of 80-95 degrees from the east. • Radio and TV reports are not sufficient.

13. Temperature • Air temperature should be taken during and in the area of the application. • Take readings several times during the application and note the time of these readings. • Do not rely on weather stations that are not directly associated with the field. • Some products have restrictions on air temperatures (ex., upper limit of 90o for 2,4 -D products applied in Arkansas).

14. Equipment • Nozzle manufacturer, make and size • Document that your equipment is set up to deliver label-specified droplet size or spray volume • Many herbicide labels require a Medium or Coarse droplet.

15. Details • Document crop variety you are spraying and any that are downwind from your application. • With all the GMO crops being grown it is important to know the variety of your target crop AND the varieties of any crops in the potential drift zone. • Consider using “Flag the Technology” program to identify your crops.

16. Details • Sensitive areas downwind of treatment area • Note any sensitive site that you took steps to protect in your records. These could include, but are not limited to homes, sensitive plants, wildlife management areas, etc. • Pest timing • Record the pest stage when application was made. • Herbicide example – seedling, true leaf, V1, 2 nodes, flowering, etc. • Insecticide example – egg, first/second instar, third/fourth instar, adult

17. Reasons for delaying an application • Ex., “Due to the sensitive crop that sits just north of the field, I waited until June 12 to make this application when there was a 5 mph wind (350 – 360 degrees).” • Reasons for halting an application • Ex., “Stopped application when the school bus approached at 3:35 and waited until 3:40 when the bus had passed my field.”

18. Benefits of Recordkeeping • Liability Protection • Documents proper use (rates, volumes, timing, protective measures) • Verifies your professionalism (due care and concern) • Good records have stopped compliance investigations immediately • Each missing record item can be a violation