The federal pesticide record rule is gone. The one that counts is your state's.

August 9, 2026 · 7 min read

Last summer, with almost no news coverage, the federal government took its pesticide recordkeeping regulation off the books. 7 CFR Part 110, the rule that vendor summaries and old training slides still quote, was rescinded effective July 11, 2025. If you spray for money, the rule that decides what goes in your records was never really federal anyway. It is written by your state, and no two states wrote it the same.

We are building record-keeping software for lawn care operators, which means we have spent this summer reading state pesticide record rules one at a time, from the official code publishers, thirty-nine states so far. This post is what we found: what actually governs your records now, the five questions every state answers differently, and one state read line by line so you can see what these rules really look like.

What actually governs your records

Three layers, smallest first.

The federal statute still exists, but it is narrow. The 1990 farm bill requires certified applicators to keep records of restricted-use pesticide applications: product name, amount, approximate date, and location. Four data points, kept two years. That statute is still on the books. But the regulation that implemented it was rescinded in 2025, and the rescission notice says the program it belonged to had not been funded since 2012. And most of what a lawn business puts down, your pre-emergents, your broadleaf herbicides, your fert, is general-use anyway, which the federal statute never covered.

The label is the law. Under FIFRA, the binding document for any single application is the product label. Some labels carry their own documentation demands on top of anything your state asks. Nothing in this post shrinks that.

Your state writes the record rule. States run applicator licensing, and the record requirement rides along with the license. Your state's department of agriculture wrote a rule that says which applications get recorded, what goes on the record, how fast it has to exist, and how long you keep it. That rule is the one an inspector reads from when there is a drift complaint. It is the one that counts.

One more myth while we are here. There is a list that gets passed around as "the federal record requirements," out of 40 CFR Part 171. We have seen it cited in official state documents. Read the caption on that section and you find it is instructions for states writing their certification plans for EPA approval. It binds state agencies, not applicators. The duty that reaches you is whatever your state then wrote.

Five questions, thirty-nine different answers

Every state record rule we have read answers the same five questions. Almost none of them answer alike.

1. Which applications trigger a record? North Carolina's rule triggers on restricted-use products only. Ohio's covers every pesticide application a commercial applicator makes, general-use included. Both patterns are common in the rules we have read. If you assumed your state only cares about restricted-use, that assumption is worth checking today.

2. What goes on the record? The lists run from a handful of fields to more than a dozen. The core is stable almost everywhere: who applied, where, what product with its EPA registration number, how much, and when. The edges are where states differ: the customer's address as well as the site's, the equipment used, the dilution, the pest you were targeting, start and end times instead of one time.

3. Does weather go on it? Nine of the thirty-nine rules we have read require some weather reading on the record itself. Ohio wants wind direction, velocity, and air temperature. North Carolina asks for no weather at all. If you work near a state line, the two sides of the road can genuinely disagree on this.

4. How fast does the record have to exist? This is the requirement operators are least likely to know about. Ohio says the record is made on the date of application. Six states we have read give you 24 hours. Nebraska gives 48. North Carolina gives 72, and that deadline is new, added to the rule effective November 2024. Minnesota gives five days. Many states set no deadline at all. A stack of stops you plan to write up on Sunday can be a violation in one state and fine in the next.

5. How long do you keep it? Two years in most of the rules we have read. Three years in about a third of them, North Carolina included. Five in a couple. If two periods could apply to the same record, keep it for the longer one. Over-keeping costs you a folder. Under-keeping destroys a record you were required to hold.

The pattern under all five: the record rule is short, specific, and probably not what you were told. The only way to know yours is to read it.

One state, read line by line: North Carolina

Here is what a real record rule looks like when you read the current official text instead of a summary. North Carolina's is 02 NCAC 09L .1402. It covers applications of restricted-use pesticides with ground equipment. Records are kept three years and must be created within 72 hours of the application. Nine items:

1. Name of the licensed applicator or public operator

   The person whose license the work runs under.

2. Name and address of the person you applied for

   The customer, and the customer's address. If they own three properties, this is them, not the lawn.

3. The farm or site treated

   The property itself. Separate from item 2, and the rule wants both.

4. The crop, commodity, or object treated

   Turf, ornamental beds, trees. What the product actually landed on.

5. Approximate acres, size, or number of objects treated

   A number with a unit. A bare "12,500" does not answer this. 12,500 square feet does.

6. Year, month, date, and the specific time of day the application was completed

   Each day of application is its own record. And the time of day matters: software that stores times without handling your time zone puts the wrong date on an evening application. We know because ours did, in testing, and we had to fix it.

7. Brand name and EPA registration number

   Both, together, from the actual jug on the truck.

8. Amount of formulation or active ingredient applied per unit

   The rate. What went down per thousand square feet or per acre.

9. Names of the people who applied it

   Separate from item 1 on purpose. On a crew job, the licensed applicator and the person running the hose can be different people, and the rule wants both names.

Now the part that makes the case for reading the code itself. The state agency's own recordkeeping handout, the one a reasonable person would find first, still reproduces the 2009 version of this rule. The current text was amended effective November 1, 2024, and that amendment is where the 72-hour deadline lives. The agency handout does not mention it, because the handout is fifteen years old. The only place the current rule actually lives is the state's administrative code publisher. If we had trusted the agency's own PDF, we would have missed a deadline that did not exist when that PDF was written.

What no rule we have read asks for: photos

Operators photograph everything, and photos are genuinely useful if a customer dispute comes up. But in thirty-nine state record rules, photos appear as a required field exactly zero times. The trap runs the other way. You can have forty photos of a lawn and still be missing the specific time of day the application was completed, which is a required field. The camera roll feels like recordkeeping. The rule has a list, and the list is what the inspector reads from.

The reverse warning matters just as much. The absence of a requirement is never permission. Your state's rule is the floor, the label can demand more, and rules change, as North Carolina's just did. Nothing here is a promise that a short list is all you will ever need.

California is its own system

California does not fit this post. It runs a full use-reporting program, where pesticide applications are reported to the state, which is a different regime from keeping records for inspection. We have not verified California's requirements yet and TurfDispatcher does not format California chemical records. If you operate in California, the rest of what we are building still works for you, and we would rather say plainly what we have not done than pretend otherwise.

How to read your own state's rule

You do not need a lawyer for this. You need about twenty minutes and three habits.

• Go to the official code, not a summary. Search for your state's administrative code, published by the state itself, and find the pesticide record rule. Not an agency handout, not a vendor's chart, not this post. North Carolina taught us that even the agency's own handout can be fifteen years stale.
• Check the effective date. Every rule carries a history note listing when it was last amended. If the copy you are reading does not show one, you are not reading the code.
• Make sure it is the right rule. Most states keep separate regimes for structural pest control and for lawn and ornamental work. They can carry different fields and different retention periods. Reading the wrong one is how a lawn operator gets told "two years" when the rule that binds them says three.

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