2.6 Application Records Under 8 CCR 1203-2 Part 6
Key Takeaways
- C.R.S. § 35-10-111 requires commercial, registered limited commercial, and registered public applicators to retain records three years from the date of application; private applicators retain them two years.
- Part 6.03 lists eleven required elements, including the EPA registration number, dilution rate, application rate, carrier if other than water, and the time of application accurate to within one-half hour.
- The record must state whether a noted time is the start or the stop of the application; an entry reading only "A.M." or "P.M." expressly fails the rule.
- When an applicator technician applies a restricted use pesticide, the record must name both the technician and the responsible on-site qualified supervisor.
- Private applicator records follow USDA 7 CFR Part 110 rather than Part 6.03, and the Endangered Species Protection Bulletin must be retained only when the label makes one applicable to that county and month.
2.6 Application Records Under 8 CCR 1203-2 Part 6
Why records dominate inspections: A CDA investigator cannot re-create an application after the fact. The record is the evidence — of the product used, the rate, the site, the timing, and who was responsible. That is why an incomplete record is a stand-alone violation even when the application itself was flawless.
1. Who Keeps Records, Where, and For How Long
| Applicator | Retention | Records kept at |
|---|---|---|
| Commercial applicator | 3 years from the date of the application | The address specified in the application for the commercial applicator's business license |
| Registered limited commercial applicator | 3 years | The address specified in the registry authorized by § 35-10-109 |
| Registered public applicator | 3 years | The address specified in that same registry |
| Licensed private applicator | 2 years | The address of record on file with the Commissioner |
Both the retention periods and the storage addresses come from C.R.S. § 35-10-111. Commercial applicators must maintain "accurate and legible office records of each application of pesticides made for hire"; registered limited commercial and registered public applicators keep office records of each application, whether or not it was for hire.
2. The Eleven Required Elements (Part 6.03)
| # | Element | What the rule actually demands |
|---|---|---|
| 1 | Name and address of the person for whom the application was made | — |
| 2 | Location where the application was made, if different from element 1 | A field should be fully described. For roadside weed control, give the county or state road number and describe the portion treated by mileage markers or prominent geological features such as intersections or river crossings |
| 3 | Target pest | The specific pest. A general term such as "broadleaf weeds" is acceptable only if the label specifically refers to that exact term |
| 4 | Site, crop, commodity, or structure treated | — |
| 5 | Specific pesticide applied | Recorded by EPA registration number. The brand name and the manufacturer's name and address may also be included, but do not replace the registration number |
| 6 | Dilution rate | Amount of formulated product or active material per unit volume of carrier. For a product applied out of the container without mixing, enter "no dilution," "aerosol," or "RTU" |
| 7 | Application rate | Total gallons or pounds of the final tank mix applied per unit of area or volume. Enter "crack and crevice" for that kind of structural treatment; enter "dip" or "spray" for a livestock application; for a "spray until wet" or "spray to runoff" label, describe the application in language consistent with the label |
| 8 | Carrier, if other than water | — |
| 9 | Date and time of application | The time must be accurate to within at least one-half hour, and records must be kept consistently and clearly enough to determine whether a noted time is the beginning or the end of the application. "An entry merely stating 'A.M.' or 'P.M.' is not sufficient to comply with this Rule." |
| 10 | Name and license number of the person who made or supervised the application | Technician, certified operator, or qualified supervisor. If a restricted use pesticide application is performed by an applicator technician, the record must include the names of both the technician and the responsible on-site qualified supervisor |
| 11 | Endangered Species Protection Bulletin | For the county and month of the application, for any product whose label requires it. If no active bulletin use limitation exists for that county and month, no bulletin need be kept. A single bulletin record may cover multiple applications subject to that bulletin |
┌─────────────────────────────────────────────────────────────────────────────┐
│ FOUR ENTRIES THAT FAIL AN AUDIT │
├─────────────────────────────────────────────────────────────────────────────┤
│ ✗ "Applied in the morning" → no half-hour accuracy, no start/stop │
│ ✗ "10:00 A.M." → does not say start or stop │
│ ✗ "Roundup Pro" → brand name with no EPA Reg. No. │
│ ✗ "Weeds" → general term not used on that label │
│ │
│ ✓ "Start 08:15; Stop 09:40, 06/14/2026" │
│ ✓ "EPA Reg. No. 524-537 (Roundup PowerMAX)" │
│ ✓ "Field bindweed" or "broadleaf weeds" IF the label uses that term │
└─────────────────────────────────────────────────────────────────────────────┘
Commercial applicators using devices rather than pesticides keep records under Part 15.07 instead of Part 6.03.
3. Extra Records for Wood-Destroying Organism Work (Part 6.04)
Any applicator performing wood-destroying insect control for termites keeps a supplemental file on top of the eleven elements.
Pre-construction treatments: square footage treated per application site, the flow rate of the application equipment, and the start and stop time for the treatment. If a physical barrier is used, record the barrier's square footage and provide a diagram describing the installation.
Post-construction liquid and bait treatments: a diagram, blueprint, or building plat plus a description of the structure, including approximate measurements as accurately as practical; areas of known current termite activity; areas of known previous activity; areas of conditions conducive to termite activity; and the areas to be treated and by what means (slab injection, trenching). The file must also hold a copy of the signed customer contract and any warranty information including job-specific exclusions, limitations, or amendments; an original or legible copy of the original label for any pesticide used; and the signature of approval on the proposed treatment diagram by a qualified supervisor licensed in the wood destroying organism category who is employed by or associated with the applicator making the proposal.
Termite baiting programs additionally require the number and locations of baiting and monitoring stations to be installed, and all service inspections of bait stations must be kept as part of that customer's service record, with service frequency performed as the manufacturer's label recommends.
4. Private Applicator Records (Part 6.05)
Colorado does not apply the eleven-element list to private applicators. Instead, Part 6.05 incorporates the USDA federal pesticide recordkeeping requirements at 7 CFR Part 110 for each restricted use pesticide application, and § 35-10-111 sets the retention at two years from the date of application.
The federal rule requires the record within 14 days of the application and covers the brand or product name and EPA registration number, total amount applied, size of the area treated, crop or commodity and location, and the date and the certified applicator's name and certification number.
[!IMPORTANT] Do not mix up the two federal recordkeeping rules. Private applicator RUP records live in 7 CFR Part 110, a USDA rule. 40 CFR Part 171 is the EPA certification rule, and the WPS application-information posting duty sits in 40 CFR Part 170. A commercial applicator in Colorado owes Part 6.03 records to CDA and, on an agricultural establishment, WPS application information to the establishment's central posting location.
5. Reading a Record Backward
The practical test of a record is whether a stranger could reconstruct the job from it. Work through this entry:
| Field | Entry |
|---|---|
| Customer | Foothills HOA, 1400 Meadow Ln., Longmont CO |
| Location | Common-area turf, north of clubhouse, approx. 0.6 acre |
| Target pest | Dandelion, white clover |
| Site | Managed Kentucky bluegrass turf |
| Pesticide | EPA Reg. No. 228-317 |
| Dilution | 1.5 fl oz product per 1,000 sq ft in 2 gal water per 1,000 sq ft |
| Application rate | 2 gal finished spray per 1,000 sq ft |
| Carrier | Water |
| Date / time | 06/14/2026, Start 08:15, Stop 09:40 |
| Applicator | J. Alvarez, Technician #T-4412, supervised on site by M. Chen, QS #QS-2087 |
| ESA bulletin | No active Boulder County bulletin limitation for June 2026 |
Every element is present, the time states start and stop, the product is identified by registration number, and because a technician performed the work the responsible on-site qualified supervisor is named. Note the carrier is listed even though it is water — recording it is harmless, and omitting it when the carrier is not water is a violation.
Which time entry satisfies 8 CCR 1203-2 Part 6.03(i) for a commercial pesticide application?
A Colorado grower applies a restricted use herbicide to her own wheat under a private applicator license. Which recordkeeping regime and retention period apply?
A pre-construction termite treatment is performed on a new slab. Beyond the standard Part 6.03 elements, what must the licensee record under Part 6.04(a)?
When must a Colorado commercial applicator retain an Endangered Species Protection Bulletin as part of the application record?