Record Keeping of Agricultural Spraying Information
I wish I could remember what I used to get rid of the blight on my watermelons two years ago……or how we controlled whitefly in our eggplant the year before. Whenever this happens I find myself going back through old storage boxes looking for the scraps of paper that I wrote the sprayer tank mixes down on.
Looking back now, how I wish I had kept more formal and detailed records of my sprays. Never seemed to have time or the inclination to really make a detailed history of what we did and why we did it.
Well, I have to, now. With FIFRA being modified by the 1992 Farm Bill and its revisions, now requiring us to keep formal spray records and make them available to our employees (Worker Protection Standard of 1992 and parts of the Right-to-Know Act).
Not only that, but we must keep files on the labels and “MSDS” (Material Safety Data Sheet - that fine-printed sheet that was always delivered with the chemical and we didn’t know what to do with it, nor had time to read it…. so we threw it away) of every labeled spray material we use.
Plus, since the vendors have to supply us with that documentation, we should now file it in binders and not have it knocking around on the floor of our truck.
Many of you have set up record keeping systems and are working with them. What I want to do is give you a check list to go over, and make sure that you are doing everything that is required. And for those of you that haven’t gotten around to it, this could be your guide to get yourselves in line with the Law.
Your friendly extension agent, chemical supplier or safety equipment vendor can also provide this information.
RIGHT TO KNOW:
First of all, remember that the basic application information must be made available to your employees and must be posted wherever you post other employee notices at least for the 30 days after the application. Remember, that according to WPS you must have a bulletin board in a central location for this and other notice purposes.
Many growers just tack a copy of the spray record sheet to the bulletin board, over the previous sheet. You can also put up a clipboard and just go adding the sheets to it as you go along, (remember to remove the old ones).
Your employees can certainly make the effort to leaf through the records if they actually want to look something up, and this way you don’t eat up valuable bulletin board space.
If you do want to post something in the chemical storage room, then put up copies of the WPS Poster, location and telephone of nearest first aid facility ( in metropolitan areas, 911 will do), personal protection equipment requirements and clean-up instructions. But remember that most of these posters must also be tacked onto the main bulletin board in the central location (next to the time clock or where the generally employees congregate.
There are several record keeping systems on the market both manual and computerized. I have found that due to the many things that we have to do and keep track of daily in this growing business, that best systems are the simple systems.
Generally, and this is not a knock, the systems being sold are complicated because those who have devised them, (generally not growers) want to give you as much as possible for your money. Sort of a justification to what they’re doing. (Most of the record keeping programs for computers that I have tried and looked at can do all sorts of things for you and, if you have the time, they could be great fun!).
But since this is not a question of fun, what I am going to do to-day is take you through the basic requirements and, if you want to get more sophisticated or try record keeping on the computer, go for it!
APPLICATION RECORDS
I have found that the best way to get this going is to draw up a form that will ask the questions required for complete recording (as far as the law is concerned) of the applications, so that when we fill it out we are putting everything down that has to be saved. (fig 1.) This form must be kept handy for at least two years and the most practical way is to keep it in a three ring binder in the office. A copy of this form can be used for employee posting.
The three ring binder should have all of your applicator’s names, license numbers and expiration dates posted on the inside of the front cover. I have also found that if you post a list of all the chemicals with their EPA Registration numbers also inside that cover, you will not have to repeat the EPA numbers every time you fill out the form.
This does not hold true for the Active Ingredient. You will have to write down the Active Ingredient every time on the form. (hopefully this will change in the future, and is one compelling reason to look at a computer program, as all that repetitious information is stored and printed out when you type the name of the chemical). And make sure that the EPA Registration Number is on the copy of the form that you post for your employees.
Remember to keep the listing of applicators and EPA numbers current. The latter is especially important if you have an emergency as medical first aid information is being indexed to EPA numbers as well as active ingredients. EPA numbers may change as products are reformulated and re-registered so be sure to read the labels on every new shipment as there may be important changes that you may have to record.
THE FORM
As you will see on the sample form the following are the records required.
- Date - Location - Area Treated (acres or sq. ft)
- Brand Names of Products Applied - EPA Registration Number**
- Active Ingredient of products applied
- Rate per 100 gallons of water
- Total gallons of mixed product used
- Applicator name - Method of application ( boom, broadcast, air, hand spray, etc.)
- REI (Restricted Entry Interval) REI expiration date and time
** EPA number is optional if it is already listed in the front of the binder. Do not confuse this with the EPA establishment number, also listed on the label. That is the factory number and not the Registration Number. The number you want is also shown as EPA Reg. No.
There are other items on the form that are purely informational.
POSTING
As a rule of thumb, you should post all records of spray applications in the central location, for your employees to have access to the information. If you are spraying pesticides with REI (Restricted Entry Interval), the records should be posted before the application begins and kept on the board for 30 days after the REI. (if the REI is 48 hours, then the records cannot be removed for 32 days).
The minimum information required for this posting is: Area to be sprayed - Brand Name of Pesticide (s) - EPA Registration number - Date and time of application - REI (hours of restricted entry: 4, 12, 24, etc.) There is no filing requirement on these particular sheets.
LABELS:
Keep a file of all the labels you are using and have used. If a label changes, be sure to add it to your file and write the date you started to use the material across the label. Also write the same date on the old label indicating that is the time that you replaced it with the newer version. It is best to keep the labels also in a three ring binder for easy reference.
Again, I must insist the you keep your eyes open when receiving new shipments of chemicals to catch changes in the label contents. These can cover re-entry periods, signal words, PPE (Personal Protection Equipment), mixing and loading restrictions and application instructions. So consequently you and your applicators have to be advised of this. Remember to brief your applicators of all changes to label content.
WPS RECORDS
You should also have a record of the training that your personnel has received in Worker Protection Standard. The applicators should have been trained in the Mixing and Loading protocol known as Handler Training.
You should have sheets on file showing their names, Social Security Numbers, type of training, date, place, trainer Id., and EPA card number, if such was issued by the trainer.
Your workers should have been given the WPS Worker Training and you should have sheets on file showing their names, social security numbers, type of training, date, place, trainer Id and EPA Card number, if such was issued by the trainer.
If you do not have those records, contact the person that trained your personnel to issue them. You must have them on file at your place of business.
If you have not trained your employees in WPS, you must do so immediately to avoid sanctions and fines. Remember, EPA training must be repeated every five years. If you trained your people back in 1993, you will have to train them again this year.
CHEMICAL STORAGE
Although not directly related to Record Keeping, I want to just go over a couple of points which will help you comply with the storage rules.
1. Keep everything off the floor in the storage room.
What you have on the floor can be put up on pallets and, as long as it is not indirect contact with the floors, will be acceptable. Another way is to get some concrete blocks and use them as bases for planks that will make shelves holding the materials.
2. Do not store fertilizers and other nutrients in the chemical storage room together with pesticides.
Remove all fertilizers and nutritionals to another ventilated and protected storage area. Also be sure to keep them off the floor.
3. Make sure all bags and containers are closed when mixing and loading is not taking place.
You can get clamps for the paper bags and make sure you keep the stoppers and caps on the bottles.
4. The chemical room must be well ventilated and yet lockable.
5. Keep the room clean and free of spills.
If you have broken or leaking containers, transfer contents into good containers. Make sure you label them properly and clearly.
6. Check all the labeling on the packages and containers in the chemical room.
Make sure they are all legible. If any need replacing, relabel them clearly and with an indelible pen.
Hopefully I have been able to refresh you on some points of record keeping. I know it is not the most attractive task in the world, but it is very necessary and, who knows, in a couple of years you’ll be able to instantly look up what you did to get rid of the aphids before they gave your citrus trees the “Tristeza”.
