1.4 Records, Annual Use Summaries & Business Registration
Key Takeaways
Connecticut commercial applicators must keep records of every application, not just restricted use applications, for at least five years.
Required commercial record fields are supervisor and operator certification numbers, kind and amount, date and place, pest, and crop or site.
Commercial and private applicators must file annual pesticide use summaries with DEEP on or before January 31 for the prior year.
A pesticide application business registration costs $240, expires each August 31, and is fee-exempt with only one certified applicator.
Business registration numbers must appear on business vehicles, in advertisements, and in written pesticide service contracts.
1.4 Records, Annual Use Summaries & Business Registration
Connecticut separates recordkeeping into layers: the individual commercial applicator's records (CGS § 22a-58(d)), the private applicator's restricted use records (§ 22a-58(c)), and the pesticide application business's records and registration (CGS §§ 22a-66b to 22a-66j). Exam questions test the retention period, the required fields, the January 31 reporting date, and the business registration rules. Several of the "ten required record fields" sometimes repeated online, such as weather readings and start and finish times, are not in Connecticut law. Learn the statutory lists below.
Commercial Applicator Records — CGS § 22a-58(d)
Commercial applicators must keep records of their use and supervision of use of pesticides for not less than five years after the date of application. The records must include at least:
- The name and certification number of the commercial supervisor and the commercial operator.
- The kind and amount of pesticide used.
- The date and place of application.
- The pest treated for.
- The crop or site treated.
These requirements cover all commercial applications, general-use products included, not just restricted use pesticides. By comparison, federal law (7 U.S.C. § 136i-1) requires restricted use pesticide records to be kept for 2 years where a state has no comparable requirement, so Connecticut's five-year commercial rule is both longer and broader.
The annual use summary
A summary of items (1) and (2) — who applied or supervised, and the kind and amount of pesticide — must be submitted to DEEP on or before January 31 for the preceding calendar year, on DEEP's form. DEEP now requires electronic submission through elicense.ct.gov (the Annual Pesticide Use Summary Report).
Consequences of not filing:
- DEEP may refuse to renew the certification of an applicator who fails to submit the report.
- CGS § 22a-66e(c): a new certificate or a renewal shall not be issued to a commercial applicator unless the summary for the previous calendar year has been submitted.
- Failing to submit required records is a listed ground for denial, suspension, or revocation (§ 22a-61(f)(1)(M)). Refusing to keep records or allow their inspection is a prohibited act (§ 22a-61(b)(2)).
Other records that become part of the file
- Written instructions given to operators must be retained as part of the § 22a-58(d) records (RCSA § 22a-66-5(i)(5)).
- For each neighbor notification or attempted notification, the business must record the date, the name of the person notified, and the method (RCSA § 22a-66a-2(d)(3)), as part of its § 22a-66g business records.
- A copy of every request for notification received by the business is also kept with the business records (RCSA § 22a-66a-2(b)).
Private Applicator Records — CGS § 22a-58(c)
Private applicators keep a record of each use of a restricted use pesticide, including:
- The name of the applicator.
- The kind and amount of pesticide used.
- The date and place of application.
- The crop or site treated and the acreage treated.
A copy goes to DEEP on or before January 31 for the preceding calendar year, as the Private Applicator Restricted Use Pesticide Summary Report, uploaded through elicense.ct.gov. A private applicator renewing must have submitted all annual summaries for the past five years.
Under § 22a-58(e), any commercial applicator, or any private applicator using restricted pesticides, must let a DEEP officer access and copy these records at reasonable times on request.
Pesticide Application Businesses — CGS §§ 22a-66b to 22a-66j
Who must register
A pesticide application business is any business that wholly or partly holds itself out for hire to apply or recommend the application of a pesticide, or that for compensation applies or recommends pesticide use (§ 22a-66b). No person may operate one without a certificate of registration from DEEP (§ 22a-66c).
| Rule | Requirement |
|---|---|
| Expiration | August 31 following issuance |
| Separate registrations | Each place of business and each business name registers and pays separately |
| Fee | $240 per registration; exempt if the business employs not more than one certified applicator; initial renewal fee may be waived for certificates issued in the 3 months before expiration |
| Changes | Notify DEEP in writing within 30 days of any change in the application information or business status |
| Registration number display | On the body of every motor vehicle used in the business, in newspaper, billboard, and telephone-directory advertisements, and in every written contract for pesticide services |
| Supervisor staffing | At each place of business, at least one certified supervisor in each category or subcategory the business applies in (§ 22a-66f) |
A place of business is any location where the business's functional operations regularly occur (financial transactions, contracts, work assignment, recordkeeping). It does not include buildings used only for equipment or supply storage, or telephone answering services.
Business records — CGS § 22a-66g
A registered business keeps records for not less than five years from the date the record is made or amended, whichever is later. The records must show:
- For each application: supervisor and operator names and certification numbers; kind and amount of pesticide, and acreage treated if applicable; date and place; pest; crop or site.
- A list of the names and EPA registration numbers of the pesticides the business applies. This may be kept separately, or each application record may include the full product name and EPA registration number.
- The name and certification number of each certified applicator employed or acting as an agent, and the types of applications each performs.
The records are kept at the registrant's place of business. If that place of business is outside Connecticut, the records must be made available at a location in the state within 10 days of DEEP's request. On written request, the business must give a customer a copy of the record of the application made for that customer.
Denial, revocation, and penalties
- DEEP issues or denies registration after reviewing a complete application. A denial goes by certified mail, and the applicant may request a hearing within 30 days (§ 22a-66d).
- Grounds for denial, revocation, or suspension (§ 22a-66e) include violations of the chapter; false information or failure to report changes; false records or failure to keep them; label-inconsistent use; ineffective or improper pesticides; faulty or unsafe equipment; careless or negligent application; aiding evasion of the law; false statements during an investigation; working in a category without certification; and, considered case by case, felony convictions.
- Violating §§ 22a-66b to 22a-66j means forfeiting up to $5,000 per day of violation (§ 22a-66h). The acts of any officer, agent, or employee are deemed acts of the business (§ 22a-66i).
Records at Schools, Day Care Centers, and State Agencies
| Setting | Record kept | Retention |
|---|---|---|
| Schools (CGS §§ 10-231c(f), 10-231d(e)) | Copy of each application record, with the § 22a-66a information, kept at the school | 5 years |
| Day care centers (CGS § 19a-79a(e)) | Copy of each application record kept at the center | 5 years |
| Municipal playgrounds (CGS § 22a-66m(d)) | Copy of each public notice, kept by the controlling authority and available to the public | 5 years |
| State agencies (RCSA § 22a-66l-1(e)) | IPM methods used, reasons if none, purpose, supervisor and operator, kind, amount and rate, date and place, manufacturer and EPA registration number, pest | 5 years |
Note
The five-year figure recurs throughout Connecticut law: commercial records, business records, school and day care copies, playground notices, and state agency records. The 30-day figure covers change notices, hearing requests, and the wait between exam attempts.
How long must a Connecticut commercial applicator keep records of a general-use herbicide application made for a customer?
Not less than five years after the date of application
One year after the end of the calendar year
Until the customer pays the invoice
Two years, because only restricted use pesticide records are regulated
A lawn care company has an office in Hartford and a second office in New Haven operating under the same name. What does CGS § 22a-66c require?
Registration only for the office where restricted use pesticides are stored
A separate certificate of registration and fee for each place of business, each expiring August 31
One registration for the company, because both offices use the same business name
No registration if every technician holds an operator certificate
Which deadline applies to the annual pesticide use summary that Connecticut commercial applicators must submit to DEEP?
By August 31, together with the business registration renewal
Within 30 days of each application
Only at the five-year certification renewal
On or before January 31 for the preceding calendar year
Sections you finish are checked off in the contents.