Recordkeeping
for Restricted Use Pesticide
Applications in Hawaiʻi
June 2019
FOR PERSONS SEEKING CERTIFICATION
BY THE STATE OF HAWAIʻI DEPARTMENT OF AGRICULTURE
TO BUY, USE, OR SUPERVISE THE USE
OF RESTRICTED USE PESTICIDES
This study guide was developed in cooperation with staff of the Hawaii Department of Agriculture's Pesticides Branch. Please direct any question or comment about this guide to the coordinator for the Pesticide Risk Reduction Education program of the College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa. Contact the coordinator by email cynagami@hawaii.edu, or telephone: (808) 956-6007.
About This Study Guide
Purpose
This booklet is a study guide for the Hawaii Department of Agriculture’s examination to qualify for certification to buy, use, or supervise the use of restricted use pesticides in Hawaii. It will not tell you everything you need to know about owning, handling, or using pesticides correctly.
Scope
This guide discusses only selected information about several sets of laws and regulations for regulating pesticide distributors and applicators. It does not explain everything about owning, storing, using or disposing pesticides legally. For example, it does not explain some pesticides' labeling requirements for recording and keeping information other than what is covered in this study guide. So you should check the labeling for your pesticides for any recordkeeping requirements that are not discussed in this guide.
Updates and changes
The date of this study guide is “June 2019.” It could be out-of-date by the time you read it because we may have changed important parts or because laws or regulations may have changed. Refresh your browser to be sure you have the latest version.
Other Study Guides
You can get the other study guide for the exams by following the links beginning at this webpage:
https://cms.ctahr.hawaii.edu/epp/Education/StudyGuidePackets.aspx
or by contacting the coordinator for the Pesticide Risk Reduction Education program of the College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa. Contact the coordinator by email, cynagami@hawaii.edu or telephone, 808-956-6007.
Table of Contents
- Introduction
- Two Kinds of Restricted Use Pesticides
- Responsible Persons
- Recording Information
- Maintaining Records
- Making Records Available for Inspectors
- Requirements for Specific Products
Introduction
This study guide is about the Hawaii Department of Agriculture’s rules for making and keeping records of applications of restricted use pesticides in Hawaii.
Two Kinds of Restricted Use Pesticides
The Department’s rules apply to the two kinds of restricted use pesticides in Hawaii:
Federal restricted use pesticides--These products have labels that bear a restricted use pesticide statement in a box near the top of the label’s front panel (Figure 1). The U.S. Environmental Protection Agency or EPA classified each of these products for restricted use because of its chemical properties, toxicity to humans or wildlife, history of use and accidents, complexity of using it correctly, or some combination of these factors. The EPA’s reason for that classification is stated in the same box directly beneath the phrase “RESTRICTED USE PESTICIDE”. These products are considered restricted use pesticides throughout the U.S.
State restricted use pesticides--These products have labels without the restricted use pesticide statement. Even so, they are considered restricted use pesticides in Hawaii.
Responsible Persons
As a Hawaii-certified applicator, you are responsible for recording certain information, maintaining the record, and, when requested, making it available for inspection and copying, as explained below in the sections Maintaining Records and Making Records Available to Inspectors, in this study guide.
Maintaining Records
You must maintain each record for two years at the principle place of business.
Recording Information
The Hawaii rules do not require you to use any specific form. You may record and keep information on paper, computer, or other media.
Computer programs for recordkeeping are available. They can be useful for managing large numbers of records. However, use caution when choosing a recordkeeping program. If it was made for another state or for other purposes, it may not lead you to record all of the information required by the State of Hawaii's pesticide rules.
The sample form on the next page has spaces for all of the required information. Examples and notes for each information item are in the next section, INFORMATION TO RECORD.
Information to Record
The recordkeeping rules make you, the certified applicator, responsible for ensuring that someone records the following 16 items of information for each application of a restricted use pesticide that you bought or otherwise acquired. The record may be on paper, a computer, or other media. The rules do not require a record to be on any specific form.
1. Brand name or common name of the pesticide
Search the product label for this information. The brand name is the name of the product. It’s printed in big bold letters near the top of the label’s front panel. The common name is the simplified name of an active ingredient in the product.
EXAMPLES:
Diazinon 4E Sprayable Insecticide
(That is an example of a brand name.)
Diazinon
(That is an example of a common name.)
2. EPA registration number of the pesticide
Search the product label for the EPA Registration Number or EPA Reg. No. It’s usually located on the label’s front panel (Figure 2). Each product has its own unique number.
EXAMPLES:
4-678
123-9876
123-9876-456
Figure 2. The EPA Registration Number or EPA Reg. No. is usually located on the label's front panel
3. Type of formulation of the pesticide
Determine the formulation by looking at the product when you use it or by searching its labeling or safety data sheet (SDS) for this information. The formulation’s name may be part of the product’s brand name, as in “Ocifate 75% Soluble Powder” and “Turf Patrol WP Herbicide”. Sometimes the formulation is specified in the part the label that gives general or introductory information about the product. On the product’s SDS, look in "Section 9 Physical and Chemical Properties" for the words “appearance” or “physical state” instead of “formulation”.
EXAMPLES:
Powder
Wettable powder or W or WP
Water-soluble powder
Liquid
Emulsifiable concentrate or E or EC
Flowable or F
Aqueous suspension
Water-soluble liquid
Liquefied gas
Gel
Granular or G
Water-dispersible granules or WDG
Dry flowable or DF
Pellets
Tablets
Bait blocks
4. Per cent active ingredient of the pesticide
Search the product label for this information. It’s in the list of ingredients on the front panel. If a product contains two or more active ingredients, record each percentage.
EXAMPLES:
Mevinphos 23%
1,3‑dichloropropene 60.8% + chloropicrin 33.3%
5. Scientific or common name of target pest
The target pest is the microorganism, weed or plant, insect, rat or other animal you planned to control with your pesticide treatment.
EXAMPLES:
Cyperus rotundus
(That is an example of a scientific name.)
Purple nutsedge
Drywood termite
Burrowing nematode
Slugs
Black rat
(Those are examples of a common name.)
6. Dilution rate
EXAMPLES:
1½ cups per 20 gallons water
3 fluid ounce per 1 gallon diesel/water mix
1.25 pounds per 42 gallons water
1% mix with kerosene
Not diluted
7. Total amount of the pesticide used for the application
EXAMPLES:
3 cups
4½ gallons
15 pounds
2 packets (2 oz.)
3 tubes (13 grams)
8. Total area covered
EXAMPLES:
2350 square feet
2.375 acres
98 linear feet
9. Time and date of application
Record both the date and time that you finished the treatment.
10. Address or location of the treated site
Record enough detail so that you could point out the treated site to an inspector two years later. If the location could be confused with nearby sites treated at different times, give distinguishing details in a note, sketch, map, GPS coordinates or some combination of these.
EXAMPLES:
Residence at 12-345 Puakea Rd. Kaneohe 96744
Greenhouse #4 benches 1–9
Pasture between Quarry Rd & Hwy 120
11. Name and certification number of certified applicator
The certification number is on the wallet-sized card that you get from the Hawaii Department of Agriculture when you become a certified “private” or a “commercial” applicator.
EXAMPLE:
A12345
12. Crop, commodity, stored product, or other site treated
EXAMPLES:
Banana orchard
Poinsettias
Grass seed
Lumber
Pasture
Ditchbank
Animal cages
Sewer line
13. Restricted entry interval or waiting period before re-entering
Search the pesticide’s labeling for this information.If the product is for treating an agricultural crop, look for the restricted entry interval or REI, which is a number of hours or days. It may be in the specific instructions for that crop or in the box of statements beginning with the phrase “AGRICULTURAL USE REQUIREMENTS.”
EXAMPLE:
"Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 12 hours."
If the product is for fumigating soil, search the labeling for the number of hours or days listed as the entry restricted period.
SIMPLIFIED EXAMPLE:
‘Entry by any person is PROHIBITED from the start of the application until 5 days (120 hours) after the application is complete for untarped applications."
If the product is for fumigating commodities in sealed containers or buildings, search the labeling for a specific number of hours of ventilation or a specific “ppm” of the remaining fumigant gas, or a combination of both.
SIMPLIFIED EXAMPLE:
‘…[fumigant name] 3 ppm or less, after 6 hours ventilated with fans …’
If the product is for treating outdoor sites that are not for agriculture, carefully read the labeling for something less specific, like ‘…until spray has dried’ or ‘…until the dust has settled’.
EXAMPLE
"Do not enter or allow others (including children or pets) to enter treated areas until sprays have dried."
14. Whether posting and oral notification are required
EXAMPLES
No
Yes
Record “Yes” if the product’s labeling has a statement like this: "Notify workers of the application by warning them orally and by posting warning signs at entrances to treated areas."
That kind of statement is called a double-notification requirement because it calls for two actions: giving an oral warning to the workers and posting warning signs (Figure 3).
Figure 3. A warning sign posted at a farm
pesticideresources.org/wps/guide/posting.html
15. Any other information that the head of the Hawaii Department of Agriculture deems to be necessary
The head of the Hawaii Department of Agriculture did not require any other information, as of March 31, 2018.
Making Records Available to Inspectors
The Hawaii Department of Agriculture’s pesticides inspectors may request and inspect your records during reasonable working hours. If a pesticides inspector from the Hawaii Department of Agriculture requests, you must make your records available for inspection and copying during reasonable working hours. (The inspectors must show their government identification at the start of an inspection.)
Requirements for Specific Products
Some pesticide products have labeling that require the users to record and keep information that is not discussed in this study guide. Examples are the pesticides made for fumigating soil, commodities in chambers or shipping containers, or structures such as buildings. Users of those fumigants must write and keep a "fumigation management plan" or "FMP." Another set of examples are the agricultural pesticides used at plant-growing operations such as forests to be harvested, farms, greenhouses, and nurseries. Employers of people who do certain types of work at these operations must keep records of employee training and documents such as safety data sheets for the pesticide products used in the operations, as required by a federal regulation known as the “Worker Protection Standard” or “WPS.”
References
Hawaii Pesticides Law, Hawaii Revised Statutes, Chapter 149A.
https://www.capitol.hawaii.gov/hrscurrent/Vol03_Ch0121-0200D/HRS0149A/ (as viewed on 8/8/18).
Hawaii Administrative Rules, Title 4, Chapter 66, as adopted in October 2006.
https://hdoa.hawaii.gov/pi/files/2013/01/AR-66.pdf (as viewed on 4/9/19)
Acknowledgements
The author gratefully acknowledges the comments offered by staff of the Pesticides Branch of the Hawaii Department of Agriculture: Greg Takeyama, Esther Medrano, and Adam Yamamoto.
Disclaimers
This study guide will not tell you everything you need to know about handling and using pesticides correctly.Where trade names are used, no endorsement is intended nor is criticism implied of similar suitable products not named.The underlining of words and phrases is only to make this study guide easier understand and not to imply that those words or phrases are more important or significant than others.
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