# Iowa commercial pesticide records after the 2026 rule change

URL: https://leafwrit.com/us/iowa-pesticide-recordkeeping-2026/
Reviewed: 2026-10-23

Iowa's commercial application record requirements changed effective January 1, 2026 under adopted ARC 9145C. The current field list identifies EPA registration, treatment size, application beginning and ending times, certified-applicator identity, and noncertified applicators where applicable. Review the full list against the worksheet actually used by your business, particularly if that worksheet predates the rule change. [^1]

## Use the commercial application provision

Rule 21—45.26 distinguishes dealer transactions from commercial application activities. Commercial applicators make, or cause to be made, office records of all application activities for each pesticide applied. The rule requires records to be maintained for three years from the application date and supplied to the secretary on written request. [^1]

When work involves more than one licensed commercial applicator, or is billed through a licensed pesticide dealer, each licensee maintains the application records. Identify the parties involved before assigning the only copy to one office. A billing arrangement does not replace this allocation of record responsibility. [^1]

For organization, create a job reference shared by the field note, the commercial record, and the invoice. Retain the identity of the licensee responsible for each record set. If an outside applicator supplies a completed sheet, reconcile it with your location and customer references rather than assuming the billing document contains all application fields.

## Review the 2026 field list

| Field group | Information in 45.26(3) |
| --- | --- |
| Licensee and customer | Licensee name/license number; landowner or customer name/address |
| Place and date | Address of RUP application; pesticide application date |
| Pesticide | Trade name and EPA registration number |
| Quantities | Product quantity, concentration or application rate, treatment-area size |
| Outdoor conditions | Temperature, wind direction, and estimated velocity when applicable |
| RUP site | Crop, commodity, stored product, or site |
| Timing | Beginning and ending times |
| People | Certified applicator making or supervising; applicable noncertified users |

These groups summarize the adopted commercial provision. Keep them separate enough that an export does not hide several values under one general notes column. The precise field descriptions remain tied to the rule. [^1]

The EPA registration number accompanies the trade name. Treatment size accompanies product quantity and concentration or rate. The record also identifies the certified applicator's name and certification number, whether that person made or supervised the application. When a noncertified person applies under the cited direct-supervision provision, that person's name is recorded as applicable. [^1]

## Distinguish people, credentials, and licensees

Use a directory with separate entries for the business licensee, the certified applicator, and the actual noncertified user where applicable. Preserve which identifier belongs to which role. A record listing only the company name does not express the rule's separate certified-applicator identity field. [^1]

IDALS describes the 2026 changes as requiring more rigorous supervision and recordkeeping where certified applicators supervise noncertified people applying RUPs. Its overview identifies qualification and training routes for those people. Keep supervision documentation connected to the person and the period of work it supports. [^2]

The department's update also distinguishes an initial 21-day employment period for noncertified applicators working under direct supervision and a family-farm route for immediate family members aged 16 or older under a certified private applicator. These are specific supervision categories, rather than a reason to remove actual-user identities from commercial application records. [^2]

## Weather and daily timing need their own headings

The commercial record includes application beginning and ending times and, when applicable, outdoor temperature, wind direction, and estimated velocity. Prepare the field note so those observations can be transcribed into the correct treatment. Keep a work interruption or continuation intelligible in the supporting notes. [^1]

During a review exercise, have the applicator explain the timing notation and the unit used for wind speed. Resolve ambiguous shorthand at the source. Distinguish weather observed during the application from a general forecast saved during planning. These suggestions organize the rule's data; they do not specify permitted weather or product-use conditions.

## Check an older PSEP 0061 worksheet

Iowa State Extension's Commercial Pesticide Application Record Keeping form page offers a single-applicator form and a multiple-applicator form. It says there is no official recordkeeping form and displays a publication date of August 2021. That date makes a field-by-field comparison with the adopted 2026 provision a practical preparation task. [^3][^1]

Use a comparison sheet with the current rule field on the left, the old worksheet's matching heading in the middle, and the revised location in your business's record on the right. Include EPA registration number, treatment size, certified identity and number, noncertified people where applicable, and beginning/ending times. Do not interpret an older optional-section label as removing a requirement added by the later rule. [^1][^3]

Keep a dated copy of the worksheet specification you approve internally. When staff use printed sheets, collect outdated blank copies from the preparation area so the next application begins with the revised headings. Preserve completed historical records as records of their period rather than rewriting their appearance to resemble the new layout.

## Keep dealer sales distinct from applications

The same rule contains separate requirements for retail dealer sales. For sales to an uncertified person for use by a certified applicator, it identifies the uncertified recipient, the certified user, certification details, product and registration information, quantity, and transaction date. The transaction records in that subsection are retained for 36 months after the transaction. [^1]

This is a different event from applying a pesticide. Preserve the link from purchased product to the actual treatment, but do not populate an application date from the invoice date or assume a purchased quantity equals the amount applied. Label the two document types clearly when collecting evidence from a dealer and an applicator.

## Prepare the office record for retrieval

The three-year application retention provision starts from the application date. A workable archive index can include the customer, treatment location, application date, licensee, applicator, and the filename of supporting notes. Keep a legend explaining the field and crop abbreviations used during that season. [^1]

Before accepting an exported report, ask a reviewer to locate one treatment involving a supervised applicator and another involving multiple licensees. Have them identify who actually applied, who supervised, which credential belongs to each named role, and where each licensee's copy is kept. Preserve any clarification with the application reference so a later request does not depend on the original office team's memory.

## Close the worksheet update with a concrete comparison

Use a completed application to test the new layout. Compare every reported number with its meaning: formulated product, concentration or rate, and treated size. Check the customer and treatment-place fields independently. Confirm that start and end refer to the application and that the people listed match the actual work.

Document the result as a short acceptance note identifying the worksheet revision and any correction made. Share the field dictionary with both the person collecting application notes and the person transcribing them. This is an editorial implementation method for the adopted fields; it does not establish an additional reporting deadline or change the rule's retention period.

## Keep qualification evidence connected to the supervised person

IDALS defines direct supervision in its update as physical presence at the application site within sight or hearing distance of the noncertified applicator. The update identifies qualification routes before supervised RUP use, including certification in another category or jurisdiction, an IDALS-approved training program, or EPA WPS handler training. Keep the qualification evidence distinct from the name appearing on the application record. [^2]

Prepare a personnel attachment index recording the named individual, qualification document, issuing program, and the job references it supports. Have a supervisor explain which document establishes the route used rather than relying on an unlabeled card image. Preserve the original credential or training reference when transcribing an identifier into a company directory.

When handing the revised worksheet to a seasonal office assistant, walk through a case involving a certified supervisor and another person applying. Ask the assistant to locate the licensee, identify the certified credential, distinguish the actual user, and retrieve the supporting qualification evidence. Document any ambiguity in the headings before staff begin using the form routinely. This exercise proposes an implementation check for the separate identity and supervision information; it does not establish a new training category or extend the qualification periods.

Keep the new worksheet revision recognizable in printed binders, shared drives, and incoming attachments. Retire unused obsolete blanks while preserving completed historical evidence.

### What must Iowa pesticide application records include?

The adopted commercial provision includes licensee/customer, location/date, product/EPA number, quantities and treatment size, applicable weather and RUP site, beginning/end times, and applicator identities. [^1]

### Did Iowa pesticide recordkeeping change in 2026?

ARC 9145C took effect January 1, 2026. Compare your commercial worksheet against the amended 45.26(3) field list. [^1]

### Is PSEP 0061 the required Iowa pesticide application record form?

Iowa State offers single- and multiple-applicator worksheets and says there is no official recordkeeping form. Its page is dated August 2021, so compare the fields with the 2026 rule. [^3][^1]

### How long must Iowa commercial pesticide application records be kept?

Three years from the application date; copies are furnished to the secretary on written request. [^1]

## Sources

- [Iowa ARC 9145C — adopted certification and recordkeeping rules](https://rules.iowa.gov/Notice/Details/9145C), read 2026-10-23
- [IDALS — updates to pesticide applicator rules](https://iowaagriculture.gov/news/announces-updates-pesticide-applicator-rules), read 2026-10-23
- [Iowa State Extension — PSEP 0061 recordkeeping forms](https://shop.iastate.edu/extension/farm-environment/farm-and-business-management/pest-management/psep61.html), read 2026-10-23