Adulticides and The Federal Pesticide Recordkeeping Program
Since there is discussion of registrants voluntarily relabeling their mosquito adulticide products as restricted use, it may be of interest to review the U.S. laws regarding recordkeeping of these products. The USDA's Agricultural Marketing
Service administers the Federal Pesticide Recordkeeping Program, which requires all certified private applicators to keep records of their use of federally restricted use pesticides for a period of 2 years. The Federal Pesticide Recordkeeping Program was authorized by the Food, Agriculture, Conservation, and Trade Act of 1990, commonly referred to as the 1990 Farm Bill. Under this law, all certified private pesticide applicators who have no requirement through state regulations to maintain records must comply with the federal pesticide recordkeeping regulations. Certified private pesticide applicators who are required to maintain records of pesticide applications under state regulations will continue to keep their records as required. The pesticide recordkeeping regulations require the certified private pesticide applicator to record the following for each application, within 14 days of the application: the brand/product name, the EPA registration number, the total quantity of the pesticide applied in common units of measure, and the date of the pesticide application, including month, day, and year.
The location of the restricted use pesticide application, not the address of the farm or business, can be reported by four options:
a. county, range, township, or section,
b. identification system established by USDA, such as plat IDs used by the Farm Service Agency or the Natural Resource Conservation Service,
c. legal property description, as listed on the deed of trust or county/city records, or
d. an applicator generated identification system that accurately identifies the location of the application.
Other information includes crop commodity, stored product, or site being treated, size of area treated, the name of the private applicator performing and/or supervising the application, and the certification number (if applicable) of the private applicator. If the name of the private applicator and the certification number are kept together, this information only has to be listed once.
Although there is a spot spray section of the federal law, greenhouse and nursery applicators are required to keep all data elements as listed. Attending licensed health care professionals or those acting under their direction, USDA representatives, and state regulatory representatives have legal access to the records. No standard federal form is required, so that pesticide recordkeeping can be integrated into the applicator's current recordkeeping schemes. All certified commercial pesticide applicators will continue to maintain the records they currently keep under state, tribal, or federal regulations. The federal pesticide recordkeeping regulations require all commercial applicators, both agricultural and non-agricultural, to furnish a copy of the data elements required by this regulation or their state, to the customer within 30 days of the restricted use pesticide application.
The State of Florida’s rules differ somewhat. Applications must be recorded within two days rather than 14, the time of application needs to be recorded, and there is no spot spray section (i.e., all applications need to be recorded). There is also a requirement for the commercial applicator to state who requested the application. For more information, see: http://edis.ifas.ufl.edu/PI012 (USDA, 3/10/03).
