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Questions and Answers Regarding New York State Pesticides Management Program

Introduction:

Welcome to the Pesticides Program's series of Questions and Answers (Q&A). This Q&A series is designed to provide information on Pesticide Program subjects of interest to the public and the regulated community. The Q&A cover a range of subjects, such as pesticide product labels, commercial lawn applications, certified applicators, and many more topics.

The subjects covered in our Q&A are listed below in alphabetical order under "Topics". Please click on topics of interest to you to gain information on those subject areas. We plan to regularly expand this Q&A series to address additional questions in those and other subject areas.

cover of NYSDEC regulations and policies booklet

Regulatory and Statutory Citations in the Q&A:

The answers provided in the Q&A often reference NYSDEC regulations and policies or NYS statutes. Click here to view the text of the cited regulations, statutes, and policies.

Additional Questions You May Have:

If you have a pesticides-related question which is not answered on our website, please contact the Pesticides Compliance Section at 518-402-8727 and PesticideCompliance@dec.ny.gov, or the pesticides program in the NYSDEC Regional Office nearest you. Telephone numbers can be found at Regional Offices.

Topics Covered in Pesticides Program Q&A

Please click on any of the topics below to link to our Q&A on that subject:

image of someone using pesidices, with mask

Certification and Certified Applicators

Q. What are the appropriate categories of pesticide applicator certification for the control of adult mosquitos, including non-residual fogging and residual barrier or perimeter delivery?

A. Pursuant to 6 NYCRR 325.16, Categories 3, 7A, 7F, and 8 may apply in whole or in part, as explained below:

Category 3 - Applicators certified in:

  • Commercial Subcategory 3A (Ornamentals and Turf) may conduct a residual barrier or perimeter delivery of mosquito adulticide, where the target of application is to grounds, trees or shrubs.
  • Commercial Subcategory 3B (Turf) would be authorized to conduct a residual application of mosquito adulticide to turf.
  • Commercial Subcategory 3C (Interior Plant Maintenance) would be authorized to conduct a residual application of mosquito adulticide to indoor plant foliage.

The residual barrier or perimeter delivery of mosquito adulticide, to grounds, trees or shrubs, under Category 3, would be considered a commercial lawn application (CLA). For CLAs, the applicator must meet the:

  • CLA requirements of Environmental Conservation Law (ECL) Sections 33-1001 and 1003 and Part 325.40, regarding CLA contracts and visual notification markers.
  • neighbor notification requirements, if in a county/municipality with a local neighbor notification law, in 6 NYCRR Part 325.41 and the local law which parallels ECL Section 33-1004.

Category 8 - The ultra-low volume (ULV) aerosol or fog delivery of mosquito adulticide (using ground or aerial equipment) would only be allowed under Category 8 (Public Health). The ULV aerosol or fog delivery of mosquito adulticide does not constitute a residual barrier or perimeter delivery of mosquito adulticide, because the pesticide is not applied to ground, trees or shrubs. Such applications are intended to control adult mosquitoes in flight in the target zone or in the areas around vegetation (not applied to or on vegetation). Therefore, the ULV aerosol or fog delivery of mosquito adulticide will not be allowed under Category 3, and would not be a CLA.

Category 8 applicators may also conduct residual barrier or perimeter applications of mosquito adulticide to grounds, trees or shrubs and the applicator must meet the:

  • CLA requirements of ECL Sections 33-1001 and 1003 and Part 325.40, regarding CLA contracts and visual notification markers.
  • neighbor notification requirements, if in a county/municipality with a local neighbor notification law, in 6 NYCRR Part 325.41 and the local law which parallels ECL Section 33-1004.

Categories 7A and 7F - Applicators certified in Categories 7A (Structural) and 7F (Food Processing) may conduct an outdoor residual barrier treatment of mosquito adulticide for the purposes of indoor pest control. The only permitted outdoor sites of application for these barrier treatments include the foundation and outside surface of the structure, and the vegetation immediately surrounding the structure, according to compliance measure II.A. in NYSDEC Program Policy DSH-PES-05-11. The outdoor residual barrier of mosquito adulticide under Category 7 to grounds, trees or shrubs, for the purposes of indoor pest control, is not CLA.

Q. Can an uncertified person (e.g., spouse, farmhand) working for a certified applicator pickup/possess restricted use pesticides, on behalf of the certified applicator responsible for purchasing the restricted use pesticides?

A. No, an uncertified person cannot pickup/possess restricted use pesticides on behalf of a certified applicator. ECL 33-1301(7) makes it unlawful for any person to purchase or possess, or use any restricted use pesticide without a purchase permit issued by the commissioner or without being a certified applicator. Under ECL section 33-0901(5), commercial permit holders must maintain records, including "...the permit numbers or certification identification card numbers of all purchasers...." In addition, a form letter used by the NYSDEC Bureau of Pesticides Management, Pesticide Product Registration Section to advise the registrant that their product will be classified as restricted by New York State contains information pertinent to the answer to this question. That letter states (among other things): "...As such, each product is restricted in its purchase, distribution, sale, use and possession in New York State. Furthermore, each product may only be purchased and used by a certified applicator in New York State."

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drawing of different products in containers

Containers for products for experimental use or research and alternative service nontainers

Q. What type of labeling is needed on containers holding pesticides for experimental use and/or research?

A. The United States Environmental Protection Agency (USEPA) advised of several items needed on containers holding pesticides used with an Experimental Use Permit. Per USEPA, Section 40 CFR 172.6 states that pesticides used under an Experimental Use Permit must have the following information on the label:

  • The prominent statement, "For Experimental Use Only'';
  • The Experimental Use Permit number;
  • The statement, "Not for sale to any person other than a participant or cooperator of the EPA-approved Experimental Use Program'';
  • The name, brand, or trademark;
  • The name and address of the permittee, producer, or registrant;
  • The net contents;
  • An ingredient statement;
  • Warning or caution statements;
  • Any appropriate limitations on entry of persons into treated areas;
  • The establishment registration number, except in those cases where application of the pesticide is made solely by the producer; and
  • The directions for use, except that the Administrator may approve the use of the experimental program as labeling provided that such program is to be distributed with the product.

In the case where the pesticide is registered, the administrator of USEPA can permit this pesticide to be used under a supplemental label that is approved by USEPA.

If the experimental use is small enough that it falls into the exemptions to an Experimental Use Permit, under 40 CFR 172.3(b), the above labeling requirements do not apply. USEPA advised that although there are no specific federal requirements for labeling of pesticides for this type of research or experimental use, they recommend that the container be labeled with enough information to be able to identify the product and supply precautionary language that may be necessary to safely deal with a potential spill.

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From the New York State perspective, Environmental Conservation Law (ECL) sections 33-1301(1)(b) and 33-1301(1)( c) apply to situations in which the experimental use is small enough that it falls into the exemptions from obtaining an Experimental Use Permit, since they are the manufacturer containers. Under ECL 33-1301(1)(b), the following information should be on the label:

  • The name and address of the manufacturer, registrant, or person for whom manufactured;
  • The name, brand or trademark under which said article is sold; and
  • The net weight or measure of the content; subject, however, to such reasonable variations as the commissioner may permit.

The NYSDEC Bureau of Pesticides Management recognizes that the net weight or measure of the content would vary every time pesticide product is used from the container. This would result in the need to frequently revise the label to reflect the ever-changing net weight. For practical purposes, it is recommended that the label indicate the maximum volume or weight that the pesticide container can hold when full.

Under 33-1301(1)( c), if the pesticide is highly toxic, the container must also bear:

  • The skull and crossbones;
  • The word "POISON" prominently, in red, on a background of distinctly contrasting color; and
  • A statement of antidote for the pesticide.

The NYSDEC Bureau of Pesticides Management recommends and encourages that the labels of containers used to hold pesticides for experimental use or research, and the labels of alternative pesticide containers also contain the USEPA product registration number. Under New York State's regulatory scheme for pesticides, it is impossible to fully identify a pesticide product without the USEPA product registration number. Therefore, to fully identify the specific pesticide, the applicator should indicate the product registration number on the label.

Since all of the information required in ECL Sections 33-1301(1)(b) and ( c) is contained on the pesticide product label, the applicator may directly and securely affix a copy of the registered product label of the pesticide to the container or application device. If, as recommended above, the maximum weight or volume that the container can hold is to be indicated, it should be marked separately from the product label if the actual label is affixed to the container.

*NOTE: The requirements and NYSDEC recommendations in the bolded text above apply to alternative pesticide containers as well as containers used to hold pesticides for experimental use. Alternative pesticide containers are also addressed in the Q&A in this section regarding that subject.
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Q. What is required to be on the label of alternative pesticide containers? ("Alternative pesticide containers" are also known as "service containers" in trade terminology)

A. Alternative pesticide containers are identified in ECL Sections 33-1301(1)(b) and 33-0303(3)(e). It is the Department's position that any container would be considered an alternative pesticide container, except the manufacturer's immediate container used to transport or store pesticides. This includes all application equipment used at any time other than in conjunction with actual on-site application.

Therefore, any pesticide applicator utilizing an alternative pesticide container must comply with ECL Section 33-1301(1)(b) and ( c), and must ensure that the container bears the specified information or must directly affix to such container a label bearing that information. The required information is listed in the bolded text in the answer to Q&A regarding experimental use containers.

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Exempt Products

Q. How do I know if a pesticide product is "exempt" from registration?

A. New York State does not exempt pesticide products from registration. The Federal Government exempts some products from registration. There is no single source that lists all federally exempt pesticide products by name. One definite characteristic of a product that is not exempt is the USEPA Pesticide Product Registration Number. If an applicator finds a USEPA registration number on the product, then it is not exempt.

Nationwide, pesticide products are subject to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA requires, among other things, the registration (by USEPA) of pesticide products. Under FIFRA Section 25b (Exemption of Pesticides), "exempt" pesticides are "25b minimum risk pesticides." To qualify for a USEPA exemption as a minimum risk pesticide, there are a number of requirements in FIFRA and related federal regulation (40 CFR 152.25). These requirements are in regard to active and inert ingredients, label appearance, etc. Summary information on 25b pesticides and links to details are contained at the EPA's website. (link leaves DEC's website).

If, after reviewing the available information, the applicator is unable to determine whether the product is exempt under FIFRA 25b, they should contact the NYSDEC Product Registration Section at 518-402-8768. (NOTE: From the NYSDEC perspective, since 25b products are not required to be registered with the USEPA and do not bear a USEPA Registration Number, the Department does not require the registration of these products in New York State and does not review and/or approve their labeling.)

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houses next to each other

Neighbor Notification Law (NNL)

NNL - Counties Involved

Q. Which counties in New York State have opted into the NNL?

A. Neighbor notification requirements regarding certain pesticides applications are in effect in some local governments in the State which have enacted local NNLs. Under ECL Section 33-1004.1, "...any county not contained entirely within a city, and any city with a population of one million or more, may, after public hearing, adopt a local law..." to enact neighbor notification requirements effective in that county or city. Under ECL 33-1004.2, the county or city that enacts a local NNL has "...concurrent authority to enforce..." that local law, provided the related specific requirements of the ECL are met. Additional general Information on the NNL is available on our website.

As of January 1, 2008, the following counties had adopted local NNLs:

  • Albany
  • Erie
  • Monroe
  • Nassau
  • Rockland
  • Suffolk
  • Tompkins
  • Ulster
  • Westchester
  • New York City (one local law covers all five counties that comprise New York City).

NOTE: Over time, the above list of local governments, which have enacted NNLs, may not be all-inclusive. Additional local NNLs may be enacted by counties after this list is included on the website. To confirm whether a NNL law is in place in your area, please contact your local government. (General county government information can be accessed online at the New York State home page, under "governments".) Questions regarding local NNL laws listed above should be directed to the specific local government.

NNL - Commercial Application

Q. Do applicators need to notify people who live next to a golf course?

A. Under ECL 33-0101.46(e), the application of pesticides on golf courses is not considered to be a "Commercial lawn application." Therefore, the applicator treating the golf course with pesticides would not need to meet neighbor notification requirements under ECL Section 33-1004. This means they would not need to notify neighbors, such as those in a single family dwelling or other premises within 150' of the site of application.

Separate from neighbor notification and commercial lawn application requirements, however, are the requirements under Environmental Conservation Law (ECL) Sections 33-0905.5(a) and (b). There is no exemption under these Subdivisions, for either golf courses or certified applicators performing applications on golf courses, from the requirements to supply certain entities, prior to pesticide application, with written copies of information contained on the label(s) of the pesticide products to be applied.

That section requires, among other things, that every certified applicator, prior to pesticide application, provide information from pesticide product labels to dwelling occupants, or to the property owner or agent, depending upon specific conditions described in the ECL.

NOTE: See the Q&A, under "PESTICIDE PRODUCT LABELS," for information on specific requirements of ECL Section 33-0905. That Section was amended in 2007. For information on specific requirements, see the Q&A which begins "What does the New York State law (enacted in 2007) regarding electronic pesticide product labels, mean for pesticide applicators, dwelling occupants, or owners or owners agents?"

Under Section 33-0905.5(a), every certified applicator must, prior to application of pesticides within or on the premises of a dwelling, provide to the occupants a written copy of the information on the pesticide product label and, under Section 33-0905.5(b), the applicator must provide the owner, owner's agent or person of authority with a written copy of the label information. Therefore, if, under circumstances such as those of a pre-existing agreement (such as an easement), the golf course applicator applies pesticides within or on the premises of dwellings and/or multiple dwellings, buildings, or structures other than dwellings, the requirements regarding supplying label information must be met.

Q. If a neighbor declines future prior notification of the commercial lawn application of pesticides, is the applicator still required to notify?

A. If a neighbor, who is the occupant/person of authority at the neighboring dwelling, declines future notification of commercial lawn application of pesticides, the applicator would not be required to supply notification to that particular neighbor, provided that the applicator meets the requirements of 6 NYCRR Part 325.41(f). Under that section, a person or business making commercial lawn applications may provide one or more options to occupants of dwellings to decline further notices of commercial lawn applications to abutting property for the dwelling unit in which the occupant resides. Any such person or business must retain a record of each declination received and make all such records available for inspection upon request. The applicator must provide a reasonable mechanism for any occupant who issues such a declination to rescind the declination. Such rescission shall be effective no later than five business days following receipt by such person or business making commercial lawn applications.

NOTE: Any such declination applies to an occupant of a dwelling and not the address of the dwelling; it is the applicator's responsibility to provide notice to future occupants. There is no corresponding provision for occupants of multiple dwellings, since the 48-hour notice must be provided to the owners or owner's agent of the multiple dwelling or other person in a position of authority over the multiple dwelling. Owners of a multiple dwelling cannot decline notification for the occupants of the multiple dwelling. Occupants of multiple dwellings may make arrangements for declination with the owner or owner's agent or person of authority.

Q. If an applicator supplies one notification post card to each "neighbor," with all seasonal application dates indicated on it, will that fulfill the requirement for notification under the NNL?

A. Under Section 33-1004.1(b)(i) of the Environmental Conservation Law, written notice must be provided at least 48 hours prior to any commercial lawn application of a pesticide. Therefore, a single notification, meeting all necessary requirements, of all seasonal applications could be provided, as long as it is provided at least 48 hours in advance of the first application. However, if any application date(s) on that single notice change, then another notice, with the correct date(s), must be provided at least 48 hours prior to application on the changed date(s).

Q. What neighbor notification requirements must a pesticide applicator meet when making a commercial lawn spot application?

A. Neighbor notification requirements relating to certain commercial lawn pesticide applications are contained in 6 NYCRR Parts 325.41(b), (c), and (d). Under 6 NYCRR 325.41(e)(1) through (12), certain types of commercial lawn applications are exempt from neighbor notification requirements. Under 6 NYCRR Part 325.41(e)(10), spot applications of pesticides are exempt when both of the following requirements are met:

  • the application of pesticides is made in a manually pressurized or non-pressurized container of thirty-two ounces or less and
  • the application is made to an area of ground less than nine square feet.

The full text of Part 325 can be accessed at Pesticide Regulations. If it is not clear whether an exemption would be allowed, please contact our regional pesticides program staff whose telephone numbers can be accessed at Regional Offices.

NNL - Residential Application

Q. Some businesses sell markers to the public for use in meeting the NNL requirement for posting notices of residential lawn applications of pesticides on property the resident owns or leases, if they reside in a county which has enacted a local neighbor notification law. Can such markers include, on the front of the marker, information on the business selling the markers to the public?

A. The regulations, in 6 NYCRR Part 325.41(g), specify that all neighbor notification markers for residential lawn applications must include, on the front of the marker, certain language advising of the pesticide application and when it occurred, and not to enter the treated area for 24 hours. Other language placed on the front of the marker, beyond that required in regulation, would deter from the intent of the pesticide warning; therefore, any additional language should be placed on the back of the marker.

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picture of a label

Pesticide Product Labels

Q. What does the New York State law (enacted in 2007), regarding electronic pesticide product labels, mean for pesticide applicators, dwelling occupants, or owners or owners agents? What is the current language of the law?

A. The law referred to in the question is Chapter (Ch.) 216 of the New York State Laws of 2007, which was signed into law on July 3, 2007. That law amends Section 33-0905.5(a) and (b) of the Environmental Conservation Law (ECL). That section requires, among other things, that every certified applicator, prior to pesticide application, provide information from pesticide product labels to dwelling occupants, or to the property owner or agent, depending upon specific conditions described in the ECL (see "specific language" below).

  • The amendments made through Chapter 216 give the occupants, owner, or his or her agent, the option of requesting the required label information from the certified pest applicator in either written, digital or electronic format. Before changes were made to the law, applicators were required to supply a written copy of the label information and there was no other format option available.
  • The amendments also include a statutory requirement for certified applicators to have a written copy of the label information in his or her possession. (Note: A regulatory requirement also exists at 6 NYCRR Part 325.2(d), regarding applicators, technicians and apprentices having "...in their custody a copy of the label....")

The new law took effect on July 3, 2007; applicators must meet the amended requirements of ECL 33-0905.5(a) and (b).

What is the specific language of the Law?
Under ECL Section 33-0905.5(a):
"Every certified applicator shall, prior to the application of a pesticide within or on the premises of a dwelling, supply the occupants therein with a copy of the information, including any warnings, contained on the label of the pesticide to be applied. Such information shall be supplied in either a written, digital or electronic format which shall be determined by the occupants of such dwelling, provided however that the certified applicator must also have a written copy of such information in his/her possession."

Under ECL Section 33-0905.5(b):
"Except as provided in paragraph c of this subdivision, every certified applicator shall, prior to the application of a pesticide within or on the premises of a multiple dwelling, building, or structure other than a dwelling supply the owner or his agent, with a copy of the information, including all warnings, contained on the label of the pesticide to be applied. Such information shall be supplied in either a written, digital or electronic format which shall be determined by the
owner or his or her agent, provided however that the certified applicator must also have a written copy of such information in his or her possession. Such owner or agent shall make available upon request at reasonable times such information in written or electronic form if available to the occupants or residents of such multiple dwelling, building, or structure."

The ECL can be viewed on the Article 33 and Portions of Articles 15 and 71 of the ECL page.
Chapter 216 of the Laws of 2007 can be viewed through the New York State Legislature webpage. (link leaves DEC's website) Search for Chapter No. 216, 2007.

Q. Does the applicator have to provide pesticide product labels annually to the customer?

A. Under ECL 33-0905.5, the applicator is required to provide the label "prior to application." There is not a statutory time frame for "prior to," to stipulate how far in advance of application the label must be provided. The Department encourages the applicator to provide the labels annually, in general, but this may not be required if certain conditions are met.

There are, however, certain circumstances under which a label would need to be provided more than once.
• If the product or the product label changes since being provided to the customer, then the new label must be provided prior to any application.
• If a CLA is involved, the applicator must meet the requirements of ECL 33-1001 and 6 NYCRR Part 325.40. Under 325.40.1(a)(4), a CLA contract must include certain product and label information in 12-point type. Under 325.40.1(a)(7), the contract must be amended, if any of the contract elements under 325.40.1(a)(1)-(6) change. If a contract is amended due to different pesticide products being used, then the 12-point information for the changed products must be provided. If the product and label information was provided by supplying the full label with the contract, then the label must be provided anew, including 12-point information. For multiyear CLA contracts, DEC Program Policy #DSH-PES-05-11, item II.F. includes a compliance measure whereby the applicator may provide label information for the contract in several ways, such as a full label or label packet. That label or packet would need to be provided to the customer again, if a new contract is provided from year to year, if the contract is amended regarding products, or if the product label changes. (With any method used for providing product information under a CLA contract, the required 12-point product and label information under 325.40(a)(4) must be provided.)

Q. While making any pesticide application, can the applicator keep the label of the pesticide product being applied in his/her vehicle, or must it be on the applicator's person?

A. It is the applicator's responsibility to keep the pesticide product label immediately available as they move about the site of application. The most prudent approach would be for the applicator to keep the label with them, when they are at the location where the product is applied and during the entire application process.

Q. How can pesticide product labels be accessed on the Internet?

pesticide products

A. Labels for pesticide products currently approved for use in New York State (NYS) can be accessed on the New York State Pesticide Administration Database (NYSPAD) site, which is maintained by the NYSDEC. Pesticide labels and other product information can be viewed by following these general steps:

  • Search in NYSPAD for a product using one of the listed parameters (e.g. EPA registration number, active ingredient). [NOTE: Generally, searching by EPA Registration Number is often the easiest search parameter to use.]
  • Click on the "More" button on the Product Search Results page to see product information and labels for a particular pesticide
  • Click on the "Label/Document No." on the page with the New York State Label/Document ID Search Results, with the most recent "Accepted Date" to view and/or print the most recently accepted labels (in PDF format).

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Pesticide Recordkeeping and Reporting for Commercial Applications

Q. What are the recordkeeping and reporting items required for the commercial application of pesticides?

A. Records of ALL of the items below are required to be maintained by the applicator, with the exception of county code. Records are required to be compiled prior to leaving the address of application and made available for inspection by the Department.

Reporting - The first seven items below must be reported annually to the Department, including county code.

Reports must be filed by February 1.

Electronic reporting options can be found at the NYS PRL website.

1) USEPA Registration Number (EPA Reg. No.) - Enter the EPA Reg. No. as it appears on the product label. Be sure to include the dashes and use the EPA Reg. No. and NOT the EPA Establishment Number. EPA Reg. Numbers do change on occasion for various reasons, so it would be advisable to check the EPA Reg. No. on the pesticide product label prior to application and the completion of records.

2) Product name - Enter the product name as stated on the container. The name of the active ingredient should not be listed unless it is the same as the product name.

3) Quantity of each pesticide used - Enter the amount of the product used from the manufacturer's container. The quantity should be expressed as a decimal and not a fraction. For example: 1.5 Fl is an acceptable method of reporting, while 1½ Fl is not. The amount of diluted product (after the pesticide is mixed) must NOT be recorded in your records or on your Pesticide Reporting Law reports. It is acceptable for the amount of diluted product to be recorded while at the application site, but when records and reports are finalized the quantity must be the undiluted amount and your Pesticide Reporting Law reports must indicate the undiluted amount.
For example- If you diluted 0.5 fluid ounces per gallon of a pesticide product and applied 1,000 gallons, you need to report that 500 fluid ounces was applied, not 1,000 gallons.

4) Units of measurement- enter the units associated with the quantity used. For example: these units would be gallons-GL, quarts-QT, fluid ounces-FL, pounds-LB, milligrams-MG, dry ounces-OZ, liters-L, milliliters-ML, kilograms-KG, Grams-GM. The units must match the units in the directions for the pesticide that is being recorded and must be placed in the designated column on the reporting form, if the form is used.

5) Date of application - Enter the month, day, and year of the application. If the year is entered on the top of the Department's reporting form, it is not necessary to enter it for every entry.

6) County Code - The county code can be found on the Department's website. Do not use other sources of county codes!

7) Location of application by address (including five-digit zip code) - Enter the street address and zip code where the pesticide was applied. When pesticides are applied to locations where a street address cannot be associated with a particular location (such as right-of-ways, transmission lines, stream tributaries, community wide applications, etc.), the applications are to be reported as precisely as possible, but at a minimum must include county, municipality, and individual 5 digit zip code. If there are any identifiable features of the application site they must be used to report the application. These features may include: mile markers, intersections, entrance ramps and exit ramps, utility pole numbers, etc. If it is discovered that a specific street address does exist for the application site and it is not recorded in the records or reported to the Department, you could be found in violation of the requirements to keep records and reports. The county tax maps available on-line may be a good source of information to find the address for a particular parcel of property.

In addition, applications made to telephone poles and areas around fire hydrants, etc. that are located within specific property boundaries must be reported using that specific address as the location of application. If a single pole or hydrant being treated in the right-of-way between the sidewalk and roadway in front of 100 Main Street, then the address of the application may be reported as 100 Main Street. If the application is associated with multiple locations along a right-of-way then it should be reported in the manner described above for locations where a street address cannot be associated with a particular location.

The place of application for recordkeeping and reporting purposes is not the location of application by address. There may be several places of application at one particular address. For example several farm fields at one address or different rooms in a house. In this case you record the amount of product for the entire address and not each place of application, although all of the individual places of application must be listed in the record for that address. In all cases the recordkeeping must be completed prior to leaving the application address. For more information on "Place of Application" see # 11.

8) Dosage Rate - Enter the mixing or application rate of the product used either as area or volume based on the pesticide label. This may be in oz/sq ft or pts/acre, or some products may be labeled as fl oz/gal or a 0.06% solution. If the pesticide is a ready-to-use (RTU) product, enter the rate as indicated in the label directions, which may be labeled as: to drip, linear feet/sec, etc. If there is no rate indicated in the label directions, enter RTU.

9) Method of Application - Enter the method or the equipment used to apply the product, as indicated in the label directions (broadcast spreader, hand placement, aerial, air-blast sprayer, bulb duster, etc.).

10) Target Organism - Enter the name of the targeted pest(s). The targeted pest or organism must be listed on the pesticide label. In some instances labels may be general and list "weeds" as a target organism. If "weeds" are listed on the label then "weeds" would be an acceptable target pest for recordkeeping purposes. If the label contains, and you are targeting, a specific weed, for example, a dandelion, then dandelions must be recorded.

11) Place of Application - Enter the exact place (field #, right of way marker #s, room, area on property, items treated, etc.) where the pesticide was applied. Information on "place" maintained by commercial applicators must be sufficient to accurately and precisely provide Department staff with a complete description about each pesticide application and enable an individual to return to a site and identify the exact place of the application.

Map or Diagram: If the place of application is difficult to describe, use of a map or diagram may be appropriate. If a map or diagram is used, the records must indicate "see map" or "see diagram" and there must be an adequate description of the place on the map or in the corresponding records.

GPS Coordinates: For large area outdoor applications, which may include farm fields, community wide applications, or utility right-of-ways, GPS coordinates (Latitude and Longitude) are an acceptable method to describe the place of application. A short description of the place of application will be needed in addition to the GPS coordinates. For example "entire field" or "entire guide rail". For large scale applications that may span a long distance, for example guide rails, two sets of GPS coordinates will be necessary to show the beginning and end-point of the application, if this option is used. In order to provide enough detail, the Latitude and Longitude will need to be a minimum of 8 digits. This record keeping option is only acceptable for large scale pesticide applications and is not adequate to document more specific places of application as described in the next paragraph.

Specific or Detailed Places: For applications that would not be considered large area outdoor applications, for example: an indoor or outdoor application at a residence, apartment building, or place of business. In these instances, the place of application would be specific to the application, such as "kitchen baseboards", "all grass in front yard", or "flower beds" and must be descriptive enough to precisely describe the place of application.

An example of properly completed Records and Reports for various types of pest control can be viewed in our recordkeeping and reporting requirements document (PDF, 27KB)

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