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Citrus Industry Magazine CEU 2013 Articles Test Series: Article #3

Pesticide recordkeeping

CEU CentralBy Stephen H. Futch

Posted Aug. 1, 2013
(expires Jul. 31, 2014)

Ifas Extension

PESTICIDE CLASSIFICATION

Pesticides are classified according to their potential hazards under the situations in which they will be used. The two classifications are unclassified use and restricted use.

Unclassified pesticides are also referred to as general-use pesticides. Normally they are less toxic than restricted-use pesticides. General-use pesticides can be purchased by anyone regardless of whether they have a pesticide license or not.

Restricted-use pesticides (RUPs) pose a greater adverse risk to human health and/or the environment than general-use pesticides. RUPs can only be sold to and used by certified applicators or people working under their direct supervision. It is the licensed applicator's responsibility to make sure each pesticide is used according to label directions.

In addition to other requirements, the license holder must be licensed in a category which reflects the work that he or she actually performs. For example, an applicator who works directly for an individual grove owner or who owns the grove himself or herself is considered a Private Applicator. An applicator who works for a company which maintains groves for many grove owners must be licensed as a Commercial Applicator in the category of Agricultural Tree Crop.

RECORDKEEPING FOR PESTICIDES

All certified applicators of RUPs are required to keep records related to the application of RUPs under both federal and state rules. In Florida, the Florida Department of Agriculture and Consumer Services (FDACS) has the local responsibility and authority to verify that records are properly maintained and available for inspection. These recordkeeping requirements are in addition to those required under the Worker Protection Standard (WPS). WPS requires that information be available to pesticide handlers and agricultural workers about where and when pesticides (both unclassified and RUPs) have been applied in agricultural farms, forests, nurseries and greenhouses.

Recordkeeping is necessary to ensure the safety of agricultural workers and pesticide handlers, protect the environment, maintain food safety and preserve agrichemicals for future use in controlling agricultural pests.

RECORDKEEPING BENEFITS

Agricultural producers who keep accurate records of pesticide use are able to evaluate and analyze seasonal performance and management decisions throughout the production cycle. This evaluation process can enhance profitability over the long term by allowing producers to better understand events that may have impacted the pest control process or crop quality.

The producer can use these records to determine the effectiveness of past pesticide applications and determine if the choice of pesticide effectively managed the pest problem. These records will also provide documentation to aid in pre- and post-harvest decisions.

Proper pesticide records aid integrated pest management decisions by ensuring that the best products are used for specific problems. Records also aid in pesticide rotation, thereby minimizing potential pest resistance issues. These records should include not only the product selected, but also the application rate and application method, weather and environmental conditions, and time of application to understand product failures, if they were to occur.

Recordkeeping provides the documentation needed to ensure a safe food supply for the general public. Records may be useful for future certification processes for selected markets or where the produce buyer requires such records. These records could also be used to protect the producer in the event of accusations of improper application, drift issues, personal injury or a host of other potential liability issues.

REQUIRED INFORMATION

Florida law requires 10 elements to be recorded for each RUP application:

  1. The name and the pesticide applicator's license number of the person responsible for the pesticide application
  2. The name of the person who actually applied the pesticide, if different than the licensee
  3. The date, the start and ending time of the pesticide application
  4. The location of the treatment site, which may be recorded using the legal description of the property or some other format that clearly identifies the location, allowing it to be distinguished from other sites
  5. The crop, commodity or type of target site treated
  6. The total size (acres, square feet, number of animals treated or other appropriate units) for the treatment site
  7. The brand name and EPA registration number of the pesticide product applied
  8. The total amount (pounds, gallons, etc.) of formulated products applied
  9. The application method
  10. The name of the person requesting or authorizing the application, or a statement of authority to make the application, if it was made to property not owned or leased by the licensee

Within 30 days of the application of a restricted-use pesticide, commercial applicators must provide a copy of the application record to the person for whom the application was made.

The required information shall be recorded no later than two working days after the application date and may be incorporated into other business records. All records must be retained for a period of two years, and must be maintained in a method that is accessible to authorized representatives.

This recordkeeping can utilize any format as long as the required information is properly recorded in a timely manner. This will allow producers some flexibility.

ACCESS TO RECORDS

Upon receiving a written request from FDACS, a licensed applicator must make available records of RUPs used during the last two years. The authorized representative may copy or photograph the records. Original records are kept by the licensed applicator.

Additionally, the licensed applicator must promptly make application records and label information available to licensed health-care professionals or their designated representative, if the information is necessary to provide medical treatment or first aid to an individual who may have been exposed to a pesticide. Information must be made available immediately following application in cases of medical emergencies. If necessary to prevent further injury or illness, the attending health-care professional may release the record or forward information to appropriate federal or state agencies that deal with pesticide use or any health issues related to the use of pesticides.

VIOLATIONS

For a first offense, a certified applicator who violates any provision of the law will be asked to correct his or her violation(s) and be subject to a civil penalty of not more than $500. For subsequent offenses, an applicator may be subject to a greater civil penalty. Any violators who are penalized will be served with a signed, written notice of violation and will have 21 days to request a hearing or respond to the charges.

CONTACT INFORMATION

If you need more information regarding recordkeeping, contact FDACS Bureau of Compliance Monitoring, 3125 Conner Blvd., MD-1, Tallahassee, FL 32399-1650 or by phone at (850) 617-7870.

Sources of information for this article: "Applying Pesticides Correctly." Frederick Fishel, UF IFAS Extension, SM-1 "Pesticide Recordkeeping." Michael Aerts, O. Norman Nesheim and Frederick Fishel. UF Extension IFAS, PI-20. "Restricted-Use Pesticides." Frederick Fishel, UF IFAS Extension, PI-36 "Surviving the FDACS Bureau of Compliance Monitoring Inspection: Walking through an inspection." Frederick Fishel, UF IFAS, PI-158

Stephen H. Futch is an Extension agent at the Citrus Research & Education Center, Lake Alfred, FL.


 

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