2.5 PA Recordkeeping & Recertification Requirements
Key Takeaways
- 7 Pa. Code § 128.35 requires a pesticide application business to record 8 specific items for every application - general use and restricted use alike - and to complete the record within 24 hours of the application date.
- Application records must be kept at least 3 years and made immediately available to the Department on request; the same 24-hour and 3-year rules apply to private applicator restricted use records under § 128.65 and to technician records under § 128.53.
- Target pest and weather data are professional best practice and are often required by the label or by a customer contract, but they are not among the 8 items § 128.35 itself lists.
- Recertification runs at 3-year intervals under § 128.45: 6 core credits for every applicator, plus PDA-set category credits that range from about 4 to 10 per category held.
- If a certification expires during a triennial recertification year, § 128.44(d) lets the applicator cure the shortfall by completing delinquent credits; re-examination is required only if the delinquent credits are not completed within one year.
2.5 PA Recordkeeping & Recertification Requirements
Records and continuing education are the two compliance obligations a Pennsylvania applicator carries every single year. Records give PDA the audit trail it needs when a drift complaint, a fish kill, or a worker exposure is investigated; recertification credits keep the certificate alive. Both are tested heavily on the Core exam, and both are surrounded by widely repeated misinformation, so work from the regulation text.
Who Must Keep Records, and of What
| Who | Regulation | What must be recorded |
|---|---|---|
| Pesticide application business (the firm employing commercial applicators) | 7 Pa. Code § 128.35 | Every application of a pesticide - general use and restricted use alike |
| Pesticide application technician | 7 Pa. Code § 128.53 | Every application the technician makes |
| Private applicator | 7 Pa. Code § 128.65 | Each application of a restricted use pesticide |
| Pesticide dealer | 7 Pa. Code § 128.11 | Restricted use pesticide sales |
| Pest management consultant | 7 Pa. Code § 128.24 | Recommendations made |
| Businesses making notified applications | 7 Pa. Code § 128.88 | Prior-notification records |
Key contrast: federal law obliges a private applicator to record only restricted use applications. Pennsylvania goes further for the commercial side - a pesticide application business must record every application it makes, including general use products on a residential lawn.
The Eight Required Items - 7 Pa. Code § 128.35
Section 128.35 lists exactly eight items. Memorize the list as written; do not pad it.
| # | Required item | Detail |
|---|---|---|
| 1 | Date of application | Including the hour if the pesticide has a reentry time |
| 2 | Customer and site | Name and address of the customer, and the address and location of the application site |
| 3 | Brand name | The brand name of each pesticide used |
| 4 | EPA product registration number | Exactly as printed on the label (for example EPA Reg. No. 100-1098) |
| 5 | Total amount used | Of every pesticide, in pounds, ounces, gallons, or liters |
| 6 | Dosage or rate of application | For every pesticide used |
| 7 | Applicator identity | The names and the certification number or technician registration number of each person making or supervising the application |
| 8 | Application site identification | Including the specific field or land area, the crop, and the size of the area treated |
Timing and Retention
- The record must be completed in written or printable form no later than 24 hours after the application date, and must be made immediately available to the Department upon request.
- A record kept under § 128.35 must be maintained for at least 3 years.
- The identical 24-hour completion rule and 3-year retention period apply to private applicator restricted use records under § 128.65, which also requires that pesticide information be made immediately accessible to medical personnel during an emergency.
- Electronic records are acceptable provided they can be printed or displayed immediately during an inspection.
Best practice beyond the minimum: experienced applicators also log the target pest, wind speed and direction, temperature, equipment and nozzle setup, and the applicator's own observations. None of these is one of the eight items in § 128.35, but the label frequently makes wind-speed limits or buffer distances mandatory, and complete weather notes are the strongest defense an applicator has in a drift complaint. Know the difference between what the regulation compels and what good practice adds.
Where Records Live
Keep records at the principal place of business or the applicator's residence, organized so any single application can be produced on demand. An inspector who asks for "the record for 14 Maple Street on June 3" and receives an unsorted box is looking at an avoidable violation.
Recertification: 7 Pa. Code § 128.45
The 3-Year Interval
"At intervals of 3 years, a certified commercial or public applicator shall provide evidence of having received current update training in technology relating to pesticides in the specific categories in which the applicator is certified." The certificate itself is renewed on the September 30 certification year (§ 128.44(b)); the credits are counted over the 3-year recertification interval.
Credits Required
| Credit type | Amount | Content |
|---|---|---|
| Core | 6 credits for every certified applicator | Safety and health, labeling, environmental protection, equipment use, protective clothing, equipment maintenance, transportation/storage/disposal, and applicable laws |
| Category | Set by PDA per category, ranging from about 4 to 10 credits | Pest identification, control measures, and integrated pest management for that category |
| Private applicator | 6 core plus 6 category credits from categories 1-9 and 22 | For a fumigation-certified private applicator, 2 of the 6 category credits must address fumigation |
Representative category totals per cycle: Category 07 Lawn and turf - 10; Category 06 Ornamental and shade trees - 10; Category 11 Household and health related - 10; Category 10 Right-of-way and weeds - 8; Category 05 Forest pest control - 8; Category 13 Structural fumigation - 6; Category 24 Swimming pools - 4. Because these numbers are set administratively and can change, verify your own totals on the yearly credit statement PDA sends to each certified applicator under § 128.45.
How Credits Are Earned
- Credits are approved at the rate of 1 credit per 30 minutes of applicable instruction.
- Credit is granted for attendance at PDA-approved courses and training, which the Department evaluates and assigns credits to.
- PDA maintains the training records and mails each certified commercial or public applicator a yearly statement describing credits obtained and credits still due.
- Falsifying attendance or credit records may result in a warning, a fine, or suspension or revocation of the applicator's certification.
Falling Short - The Delinquent-Credit Cure
This is where most study aids overstate the consequence. The actual rule in 7 Pa. Code § 128.44 is:
- § 128.44(d): if a certification expires during a triennial recertification year, the person must complete the delinquent recertification credits required by § 128.45 and satisfy the eligibility requirements.
- § 128.44(e): only if the person fails to complete the delinquent credits within one year, or fails to renew the certification, must the person re-establish eligibility by meeting the fee and competency requirements of §§ 128.3 and 128.43 - that is, pay again and pass the exams again.
- § 128.44(c): in the meantime, "once a certification has expired, no further use of pesticides as allowed by the certification will be permitted." An expired applicator may not apply restricted use pesticides or make commercial applications, even while curing the credit shortfall.
Exam framing: an expired certification is not instantly unrecoverable. There is a one-year window to complete delinquent credits. What is immediate is the loss of authority to apply - the moment the certificate expires, the work must stop.
Business License vs. Individual Certification
These two renewals run on different calendars and candidates routinely confuse them:
| Credential | Fee | Cycle | Expires |
|---|---|---|---|
| Pesticide application business license | $35 | Annual | December 31 |
| Commercial applicator certificate | $40 | Annual | September 30 |
| Public applicator certificate | $10 | Triennial | September 30 |
| Private applicator permit | $10 | Triennial | March 31 |
| Technician registration | $30 / $20 | Annual | February 28 |
A business license does not certify any individual, and an individual certification does not authorize a firm to offer pesticide applications for hire. A commercial operation needs both, plus the financial responsibility coverage required by § 128.34.
How soon after an application must a Pennsylvania pesticide application business complete its application record, and how long must the record be kept?
Which item is NOT one of the data items that 7 Pa. Code § 128.35 requires on a Pennsylvania pesticide application record?
How many core recertification credits must a certified Pennsylvania commercial applicator earn during each 3-year recertification interval, and how are category credits determined?
A commercial applicator's certification expires during a triennial recertification year because the required credits were not earned. What does 7 Pa. Code § 128.44 provide?