Brad Fresenburg
Coordinator of Pesticide Programs

Melissa May
Missouri Department of Agriculture

The 1990 farm bill requires private certified pesticide applicators to keep records of all applications of federally restricted-use pesticides (RUP). The U.S. Department of Agriculture's (USDA) Agricultural Marketing Service (AMS) administers the Federal Pesticide Recordkeeping Program.

Although applicators have 14 days to record information about an RUP application, it is best do so immediately after each application to ensure accurate and detailed records. These records must be maintained for two years.

There is no required federal form on which to maintain your records; however, MU Extension publication MP693, Restricted-Use Pesticide Record-Keeping Form, can be downloaded, reproduced and used to be in compliance with the regulation.

What the records must contain

• The certified applicator's name and certification number.
  If the application was made by someone who is not certified, then record the name and number of the certified applicator who supervised the application.
• The month, day and year of the application
• The crop, commodity or site to which the pesticide was applied.
  This section of the record includes stored products, such as grain held in bins. Refer to the pesticide label for guidance to record this information.
• The brand or product name of the federally restricted-use pesticide and the product's EPA registration number.
  The brand or product name and EPA registration number for many restricted-use pesticides registered in Missouri are included in Table 1. If you use a restricted-use pesticide that is not listed, add the product name and registration number to the table for future use.
• The total amount applied. Record the amount used of the actual product — not the amount after water or other substances were added. Amount does not refer to percent of active ingredient. Use the pesticide label for reference, and record the amount in similar language. For example, if the label states the pesticide is to be measured in pints or ounces, then record the amount in pints or ounces.
• The size of the area treated.
  Record the size of the area treated in the appropriate unit of measure (such as acres, linear feet, bushels, cubic feet, number of animals, etc.), which is normally expressed on the label in reference to the application being made. For example, if an 80-acre grove is treated using the alternate middle approach, the entire 80 acres would be recorded as the size of area treated.
• The location of the application.
  Record the specific location of the application, not the address of the farm or business. Your goal is to be able to identify the exact area of the application two years later if requested. The law allows any of the following designations:
  • ID system using maps and/or a written description
  • County, range, township and section (although not required, subsection is acceptable)
  • A USDA identification system, which involves maps and a numbering system to identify field locations
  • The legal property description

How to record spot treatments

Spot treatments are especially useful in the control of noxious weeds. If you apply restricted-use pesticides on the same day in a total area of less than a tenth of an acre, you are required to record all of the following information:

• Brand or product name, EPA registration number
• Total amount applied
• Location of treatment designated as spot application, followed by a description (for example, the location could be recorded as "spot application," followed by "treated for noxious weeds on Field A, C and all pastures")
• Month, day and year of the application

Note
Greenhouse and nursery treatments do not qualify as spot treatments.

Access to the record information

Only the following people have the right to access your restricted-use pesticide records:

• USDA-authorized representatives who present identification
• State-authorized representatives who present identification
• Attending licensed health care professionals, or those acting under their direction, when treating individuals who may have been exposed to restricted-use pesticides

Commercial applicator requirements

All commercial applicators will continue to maintain the records they currently keep under Missouri or federal regulations. The new federal pesticide record-keeping regulations require all commercial applicators, both agricultural and nonagricultural, to furnish a copy of the application record to the customer within 30 days of the restricted-use pesticide application.

Civil penalties

The AMS administrator of USDA is responsible for the enforcement actions taken against violators of this standard.

Any private applicator who violates any provision of the regulations will be subject to the following civil penalties:

• A fine of not more than $750 for the first offense
• A fine of not less than $1,100 for each subsequent offense

Benefits of pesticide record keeping

Maintenance of pesticide application records helps farmers to:

• Evaluate how well a chemical worked
• Determine the amount of pesticide needed annually, avoiding the purchase and storage of excess product
• Prevent carry-over injury and improve rotation decisions
• Protect themselves from legal action if accused of improper pesticide use
• Save money by determining the best pesticide management program, which is key to a successful integrated pest management (IPM) program

Also, USDA's National Agricultural Statistics Service (NASS) conducts surveys on pesticide use for agricultural production. The information gathered from these surveys is used to maintain a database on the use of pesticides by agriculture. Various public and private organizations use the data when making decisions about or studying such issues as the safety of the nation's food supply, the quality of our water, and the impact of IPM.

Record-keeping information for the EPA Worker Protection Standard

The Environmental Protection Agency's (EPA) Worker Protection Standard (WPS) is a federal regulation intended to reduce the risk of pesticide poisoning and injury among agricultural workers. Private applicators hiring pesticide handlers or workers must display application information to all employees in an accessible area of the workplace before a pesticide is applied. This display is not limited to restricted-use pesticides, but is required when the label of any pesticide being used ­has an Agricultural Use Requirements section.

Additional record-keeping information is also required to meet federal WPS regulations:

• Time of day the application was made
• Active ingredient
• Restricted entry interval (REI)

The previously mentioned MU Extension record-keeping form, MP693, provides space to record the necessary information for both RUP and WPS records.

Restricted-use pesticides registered in Missouri

The brand or product name and EPA registration number for most restricted-use agricultural pesticides registered in Missouri are listed in the following table. If you use a restricted-use pesticide that is not listed, add the brand or product name and registration number to the table. This information is obtained from the pesticide label.

This list of products was accurate as of the date of publication of this guide. For an updated list of registered RUPs, contact the Missouri Department of Agriculture's Bureau of Pesticide Control at 573-751-5504.

Table 1
Agricultural restricted-use pesticides for Missouri.

Original authors
Fred Fishel and Joe Francka