Are You a Pro?

Whether or not to keep a record when you treat a property with pesticides is not your decision. The Environmental Protection Agency (EPA) requires that certified applicators applying restricted-use pesticides for hire keep records of that application. Individual state regulators administer this EPA rule and often add recordkeeping requirements of their own that cover all pesticide applications.

JUST BUSYWORK? Accurate, complete records are your protection from any challenge to your professionalism. Should you ever need to recall that particular treatment, even years later, for a regulator or in a legal case, your thorough records will refresh your memory, may be used in evidence and may save the day! No records or sloppy, partial records can mean trouble down the road.

Good records can make you a better technician. Look at earlier records with a critical eye and evaluate the effectiveness of procedures used, effectiveness of pesticides at rates applied, and look for signs of pest resistance to the product. Records of pesticide application amounts can help your company keep track of product inventory.

Look at it this way: Keeping accurate and detailed records of your work protects you and your company and makes you both look more competent and professional.

WHAT TO REPORT? EPA requires that you report certain details when you apply a pesticide, especially a restricted-use pesticide. Your state may have more or different requirements, so be sure you’re in compliance. Generally, you will need to record the applicator’s name, the pest treated, the pesticide products used with the EPA registration number, the percentage of active ingredient applied, total amount of pesticide used, application equipment used, weather conditions for outdoor treatments and perhaps pesticide disposal information.

A thorough applicator will record even more information than is required. On an unusual job or one that could have repercussions, record circumstances beyond the basics. Report sanitation levels, or if you have to reschedule or cancel an application, and why. And don’t be shy about reporting any precautions and safety measures taken on the job — these could prove important later.

Your records need to be good enough to dispute a claim that a property was inadequately treated/inspected or that your service was improper or dangerous. Your company probably has a standard form that you fill out at the jobsite. Unfortunately, here is where the system often breaks down. Technicians get lazy or take shortcuts in filling out their application records. Are you guilty of any of these common paperwork or electronic record shortcomings?

• Unreadable handwriting.
• Leaving spaces blank or just using ditto (") marks rather than making individual entries (difficult to defend in court and often an issue with regulators).
• Wrong dates and missing addresses (no apartment numbers).
• Not including the things that your state’s regulations require such as product names, concentrations, amount used, EPA Reg. No., etc.

WHO SEES? First off, you must supply your customer with a record of each pesticide application. You also may be asked to provide access to your application records in any of the following circumstances: (1) routine or random inspections by state regulators, or EPA or USDA inspectors; (2) in situations involving suspected pesticide poisoning or related medical emergency; and (3) to determine compliance when an alleged pesticide incident becomes a regulatory or legal case.

EPA requires access to application records for inspection and copying by an EPA representative (including inspectors and state regulators) for at least two years from the date of application. States may require more; it’s wise to keep records for even longer. Whenever a pesticide application is investigated, application records and any other data are used by regulators to reconstruct the application and reach a decision as to whether proper procedures were followed. A detailed paper trail or “electronic” record trail is your best defense.

The authors are well-known industry consultants and owners of Pinto & Associates, publishers of Techletter.