# Who keeps the spray records when a contractor does the work?

URL: https://leafwrit.com/uk/contract-sprayer-records/
Reviewed: 2026-10-23

For **Northern Ireland**, DAERA places the prescribed application record with the contractor as the professional user who does the spraying. The contractor creates and retains the machine-readable original and provides the customer access or copies without undue delay or restrictions. A customer may retain a PDF reference copy while the contractor keeps the compliant original. [^1]

For **Great Britain**, keep the treatment handover connected with the farm's records. The Scottish pesticide code recommends obtaining contractor copies and keeping records accessible at the farm or local office. The Welsh 2026 inspection guide asks for detailed contractor records. These sources describe how customer-held information supports the local workflow. [^2][^4]

## Agree responsibilities before the first job

Use the treatment location to identify the relevant jurisdiction, then assign named contacts for the application record and customer copy. A contractor working in several countries needs to know which set of jobs a request concerns. Keep the customer's business and job reference attached to that location throughout the handover.

The following table is a suggested working agreement. DAERA's NI rules establish the original-record and access responsibilities; the allocation of your own administrative contacts is an organisational choice. [^1]

| Task | Contact to identify in your own agreement |
| --- | --- |
| Supply actual application information | Applicator or the contractor's record keeper |
| Maintain the NI machine-readable original | Contractor as professional user |
| Receive and review the customer copy | Customer's nominated farm or site contact |
| Resolve product, time or quantity questions | Person able to consult the original job note |
| Assemble records for an authority request | Responsible person for the relevant business |
| Communicate an agreed correction | Contact able to update the original and notify recipients |

Keep the agreement short enough to use. Record where documents will be delivered, the reference identifying the job and who follows up an incomplete report. If another administrator takes over, they should be able to retrieve the right record using the agreement and index.

## Understand the Northern Ireland original

DAERA says the professional user is the person who carries out the spraying. Where a contractor works for a business, that contractor is responsible for creating and retaining the record in the required machine-readable format. The contracting business may retain another format for reference, provided the original is maintained correctly. [^1]

This distinction gives each file a clear purpose. The customer's reading copy helps it identify and review an operation, while the structured original preserves the application data in the prescribed form. Save the customer's copy with the contractor and job reference so a later request can be directed to the correct record holder.

DAERA lists CSV, XLSX, XML and JSON as machine-readable examples and excludes PDFs and scanned images for that purpose. A report emailed to a customer is therefore not sufficient evidence of the format in which the contractor maintains its underlying records. Ask for the actual export when assessing the handover procedure. [^1]

## Customer access is part of the NI workflow

The NI guidance requires contractors to give the person or business they work for access to, or copies of, relevant records without undue delay or restrictions. It further says the required machine-readable format must be supplied without undue delay when the customer requests it, including where the records are needed by the Department. [^1]

Agree a practical request route and test it with a completed job. Ask the customer's contact to obtain the record using only the job reference and application period. Confirm that the resulting file covers the requested site and includes the information needed to understand the operation. Retain the request and supplied version in the archive.

If access is through a customer portal, document how the business obtains a saved copy for its own records. If a report is sent as an attachment, keep it with the original communication. These are suggested record-management practices; the actual access requirement comes from DAERA's guidance. [^1]

## Inspect one treatment rather than the invoice total

The existing application information described by DAERA includes product name, application time and dose, treated area and crop. Northern Ireland additionally requires product authorisation number, EPPO crop or land-use code and relevant BBCH stage where the product use is growth-stage restricted. [^1]

Check the supplied report against the actual treatment. Identify the product, place, person and date before reviewing quantities. If the job covers several locations, make the relationship between the entries and the locations understandable. If several products were used, preserve their individual identities. Annex F's treatment-record note expressly says all products should be shown for mixtures. [^5]

An invoice can help identify the service and customer, but use the job record to resolve application details. If the invoice combines multiple visits, retain a correspondence between its reference and the treatment reports. Ask for the particular missing value instead of requesting an entirely new report without explaining the problem.

## Keep units and boundaries intelligible

The official Scottish treatment-sheet example separates dose per hectare, volume per hectare, total product quantity and total area. Those headings describe different quantities. A contractor report needs to retain enough context for the recipient to interpret which figure belongs to which part of the operation. [^5]

Before transcribing a value, establish its unit and meaning. Keep the product quantity distinct from spray water or total application volume. Use the treated extent rather than assuming the property's entire area was covered. Where the customer and contractor use different field names, maintain a mapping in the shared job information.

Preserve the original application note while resolving discrepancies. If a clarified quantity changes the meaning of several exported rows, identify all affected records and keep the reason for the revision. Make the corrected customer copy recognisable so a later reader does not unknowingly use an earlier version.

## Give the customer the restrictions it needs to manage

The Scottish code explains that records help manage harvest intervals, repeat applications and periods excluding workers or livestock. Annex F includes relevant restrictions, ventilation, flowering, notifications to neighbours or beekeepers, warning signs and problems during application among its suggested notes. [^2][^5]

Agree which person will receive the job information needed for subsequent activity at the site. Link restrictions to the specific treated location and product information. Keep an application report accessible to the person scheduling harvest, grazing, maintenance or access. Use the [harvest and access guide](/uk/harvest-interval-spray-records/) to organise that part of the record.

When the job involves an aquatic-buffer decision, retain the assessment or recorded distance alongside the application reference. The [LERAP guide](/uk/lerap-spray-records/) explains the separate record and the distinction between eligible reductions and maintaining a labelled buffer.

## Prepare for a departmental request

DAERA says the professional user must submit records within 10 working days of a request unless the Department specifies an alternative timeframe. Save the actual request and its stated scope before assembling the file set. Coordinate the contractor and customer contacts where records are held in more than one place. [^1]

Use the application period, business and site to select the relevant records. Open the supplied structured file and compare a completed job with the customer reference copy. Confirm that product, crop, location and quantities still correspond. Retain a list of files provided and the version used for the response.

For Welsh inspections, the published guide describes cross-checking sampled treated fields with farm records and checking product use against label crop specifications. A customer needs a usable treatment record to follow that trail, alongside the contractor's underlying archive. [^4]

## Business registration belongs to both sides' administration

Defra's GB professional-user registration guidance includes businesses having PPPs applied by a third party and contractors hired to store or apply products for others. It also says local authorities using or storing products register, while their hired contractors register independently. Treat those as separate business tasks when setting up a service relationship. [^3]

Keep the registration reference in each organisation's administration. Use the [registration guide](/uk/professional-ppp-registration/) for addresses, typical product-use estimates and accepted return formats. The job record remains the place to describe individual treatments; registration is not a seasonal upload of all application entries.

## Review the handover when the service changes

HSE distinguishes professional-user retention of three years from supply-chain records retained for five. DAERA also states at least three years for professional-user application records. Keep the treatment archive accessible when a contract ends, a member of staff changes or a different recording system is adopted. [^6][^1]

Before the change, identify the applications and periods covered by each record holder. Obtain the copies required for the customer's files and test retrieval of older jobs. Record how corrections and authority requests will reach the contractor after the normal service contact changes. Preserve the relevant correspondence with the archive index.

Use a final sample job to rehearse the complete path: original note, structured record, customer copy, supporting restriction and later retrieval. Ask someone unfamiliar with the job to locate each part using the references provided. Improve the references where the process still relies on personal memory.

### Do I need pesticide records if a contractor sprays?

The Scottish code recommends obtaining the contractor’s application record. DAERA requires contractors to give customers access or copies without undue delay or restrictions. [^2][^1]

### Who keeps the pesticide application records in Northern Ireland?

The contractor as the professional user creates and retains the prescribed machine-readable original. The customer may keep a reference copy such as PDF while the compliant original is retained. [^1]

### Can I ask for spray record sheet Excel data?

In Northern Ireland the customer can request records in the required machine-readable format, and DAERA lists XLSX as an acceptable example. [^1]

### How long to keep spray records?

DAERA states at least three years for professional-user records; HSE also distinguishes three-year professional-user records from five-year supply-chain records. [^1][^6]

### Do I need pesticide records and Defra registration?

The GB registration guidance includes customers having professional PPPs applied by third parties as well as contractors hired to apply them. Registration is separate from the records for each application. [^3]

## Sources

- [DAERA — new PPP record-keeping requirements for professional users](https://www.daera-ni.gov.uk/articles/new-requirements-plant-protection-product-ppp-record-keeping-professional-users), read 2026-10-23
- [Scottish Government — pesticide code, Section 6: keeping records (2007)](https://www.gov.scot/publications/pesticides-code-practice-using-plant-protection-products-scotland/pages/9/), read 2026-10-23
- [Defra and HSE: how to register a professional PPP user](https://www.gov.uk/government/publications/professional-plant-protection-products-ppps-register-as-a-user/how-to-register-as-a-user-of-professional-plant-protection-products-ppps-and-adjuvants), read 2026-10-23
- [Welsh Government — Inspections: Sustainable Farming Scheme and Regulatory Baseline (2026), SMR 10](https://www.gov.wales/sites/default/files/publications/2026-04/inspections-sustainable-farming-scheme-and-regulatory-baseline.pdf), read 2026-10-23
- [Scottish Government — pesticide code, Annex F: record sheet for pesticide treatments](https://www.gov.scot/publications/pesticides-code-practice-using-plant-protection-products-scotland/pages/15/), read 2026-10-23
- [HSE — guidance on the Plant Protection Products (Sustainable Use) Regulations 2012](https://www.hse.gov.uk/pesticides/using-pesticides/codes-of-practice/guidance-sustainable-use-ppp-regs-2012.htm), read 2026-10-23
