# Michigan commercial records: one year, three years, and customer information

URL: https://leafwrit.com/us/michigan-pesticide-records/
Reviewed: 2026-10-23

Michigan Regulation 636 Rule 15 requires commercial applicators to preserve verifiable RUP application records for at least three years after application and general-use records for at least one year. The record field lists cover product identity, concentration, end-use dilution amount, purpose or crop site, date, location, method, and rate. Customer information is addressed separately by Regulation 637 Rule 12, reproduced in MDARD's review checklist. [^1][^2]

## Choose the retention category first

The one-year and three-year periods apply to the two pesticide-use classes in the commercial-applicator rule. Keep the application date and the product classification together in the archive index. If a service combines more than one product, preserve the individual product identities so a mixed record can be interpreted without guessing which classification was involved. [^1]

Rule 15 makes the employer responsible for maintaining the verifiable record at the place of business and requires availability to an authorized representative of the director during normal business hours. Assign the archive owner in your operating instructions, including a backup contact for an absent office manager. [^1]

MDARD's current laws page distinguishes Regulation 636's applicator and recordkeeping subjects from Regulation 637's communication and documentation requirements. Use that distinction when reviewing a file: the internal application record and information provided to a customer are related tasks with different content. [^3]

## The commercial application record

| Field | What to preserve |
| --- | --- |
| Product | Name and EPA registration number of the product actually applied |
| Concentration | Pesticide and carrier relationship used to make the end-use dilution |
| End-use amount | Actual dilution or packaged material applied, with units |
| Purpose | Target pest, purpose, or crop site |
| Event | Application date and address or location |
| Method and rate | How application occurred and its recorded rate |

Rule 15 provides the field list; MDARD's checklist explains several common recording distinctions. Keep those explanations alongside the worksheet so the person collecting data and the person transcribing it interpret the quantities consistently. [^1][^2]

MDARD says only products actually applied are listed. When a preprinted record names several possible pesticides, the applicator circles or otherwise notes which were used. Do not let a standard product list become an assertion that every listed product was applied at each visit. [^2]

For minimum-risk 25(b) products, the checklist notes the absence of an EPA registration number and recommends a 25B notation. Preserve the product identity and the reason for the notation in your product directory; do not manufacture a registration number to fill an empty box. [^2]

## Concentration, amount, and rate are separate

Regulation 636 defines concentration as the volume of pesticide formulation and carrier used to create the end-use dilution. The checklist explains that a standard measurement unit is included. It says a concentration is not required for ready-to-use, prepackaged, or unmixed products and recommends an RTU notation for those products. [^1][^2]

The end-use-dilution amount is the actual amount applied, with a unit. MDARD says an application rate is not an acceptable substitute for that amount. It also says amounts are recorded for each field or location rather than as one total for all locations served from the tank load. [^2]

This distinction matters when reviewing a multi-site job. Prepare separate spaces for concentration, the actual end-use quantity at the location, and application rate. Compare each value with its source note. If a worksheet contains only a tank capacity, ask what amount was actually applied at the particular location and preserve the applicator's clarification.

The method and rate field remains separate. MDARD's checklist says rates reflect the label format and include units for both product and area. Use a field dictionary spelling out the quantities and units your business records instead of relying on a single heading such as dosage. [^2]

## Customer information has its own contents

MDARD's reproduced Rule 12 identifies firm name, address, and telephone number; full applicator name; general target-pest description; pesticides applied including common active-ingredient names; application time and date; and applicable label precautions or reentry restrictions. Review a customer document against those contents separately from the internal record. [^2]

For the ordinary written-information route, the information is provided no later than the application. Electronic provision within 48 hours is permitted with the customer's or authorized agent's written approval obtained before application. Keep the approval and delivery reference connected to the service document when using that route. [^2]

The rule also addresses written risk-and-benefit information at or before the initial application and specifies its topics, including how pesticides work, why they are used, general toxicity and exposure information, precautions, and environmental fate. Preserve which information was supplied at the start of the service arrangement. [^2]

## Agricultural and aerial work has a stated alternative

Rule 12(5), as reproduced by MDARD, allows a commercial agricultural or aerial applicator to provide oral instructions on labeled reentry and preharvest requirements before application and a copy of the risk-and-benefit information sheet or pertinent label section instead of the information specified in subrules (2) and (3). Keep this alternative attached to the categories and requirements it actually addresses. [^2]

For an agricultural job, organize the communication note beside the application record and identify the person who received the instructions. Preserve the supplied sheet or label section with the service reference. This is an editorial handover method for the alternative route; it does not remove the separate commercial application-record requirement in Rule 15. [^1][^2]

## Prepare the service agreement and requested documents

The reproduced rule describes an oral or written agreement before application specifying customer consent, firm contact details, and the approximate schedule, frequency, and duration of anticipated services. It also addresses continuation beyond twelve months through the stated notification or definite-term written-contract conditions. Keep the agreement version with the customer record so a later visit can be tied to the arrangement that covered it. [^2]

On customer request, the rule identifies product labels, safety data sheets, EPA fact sheets when available, and a document specifying active-ingredient application rates among the supplied documents. Prepare an attachment index for those materials rather than assuming that an internal spray row answers every communication request. [^2]

## Use the checklist as a review aid

The MDARD document is a review checklist with element-present columns and reproduced provisions. It is useful for comparing internal records and customer information; its presence in a folder does not mean an application entry has been completed. Start the review with an actual service record and mark where each relevant element is found. [^2]

A practical comparison exercise is to select a multi-location job, a ready-to-use product application, and an agricultural service using the communication alternative. For each, identify the product actually applied, quantity meaning, classification and retention category, responsible file owner, and customer-information route. Record a specific correction where the supporting document and the register disagree.

## Preserve a readable record after staff changes

Keep the location directory, unit dictionary, document index, and application register together when moving the archive. Retain a readable export with complete column names and enough context to distinguish the firm record from a customer receipt. Ask an unfamiliar colleague to locate a past service, explain its measurements, and find the supplied information without accessing the original preparer's inbox.

Use the review findings to improve the next worksheet revision. Preserve the original supporting note when correcting a transcription and write the reason for the change. These are proposed organization practices; the cited Michigan provisions determine the content, communication alternatives, and retention duties.

## Explain ready-to-use and multi-location entries during review

Use a worksheet acceptance exercise with two contrasting document situations. In the first, the supporting note identifies an unmixed ready-to-use material. Locate the product identity, recorded end-use amount, and the notation explaining why a mixture concentration is absent. In the second, a tank serves several locations. Ask the preparer to show each location's actual quantity and the reference connecting it to the tank's concentration information. MDARD's checklist supplies the RTU and per-location distinctions used in this review. [^2]

Do not manufacture application measurements for the exercise. Use an actual completed record with personal details handled according to your own document practices, or use blank headings and describe what supporting information would be needed. Keep the product amount, diluted amount, and application rate terminology consistent between the field sheet and office register.

For the customer packet, identify the applicable communication route and retrieve the copy or instructions associated with that service. Preserve the approval for electronic delivery when using that route, or the relevant agricultural/aerial communication reference when using the specified alternative. Record who resolved a mismatch between the packet and internal entry. This suggested exercise focuses the review on Michigan's quantity and communication distinctions.

For an electronic receipt, retain the customer approval alongside the dispatch reference. Name the attachment descriptively so its purpose survives forwarding.

### How long must Michigan pesticide application records be kept?

Regulation 636 Rule 15 requires commercial RUP records for at least three years and commercial general-use records for at least one year after application. [^1]

### What must a Michigan pesticide application record include?

Product identity, concentration, actual end-use amount, pest/purpose or crop site, date, location, method, and rate are the commercial Rule 15 fields. [^1]

### Is the Michigan customer receipt the pesticide application record?

The internal record and customer information have separate provisions. MDARD reviews both; agricultural and aerial services have a specified communication alternative. [^2]

### Can I send Michigan pesticide customer information electronically?

The ordinary Rule 12 route permits electronic provision within 48 hours when written customer or agent approval was obtained before application. [^2]

## Sources

- [Michigan Regulation 636: pesticide applicators](https://ars.apps.lara.state.mi.us/AdminCode/DownloadAdminCodeFile?FileName=R+285.636.1+to+R+285.636.17.pdf&ReturnHTML=True), read 2026-10-23
- [MDARD — Pesticide Application Business Record & Customer Information Review Checklist](https://www.michigan.gov/-/media/Project/Websites/mdard/documents/pesticide-plant-pest/pesticide/customer_receipt_and_recordkeeping_for_clients.pdf?rev=4f4a0862b3e8439899f4df3991d7462e), read 2026-10-23
- [MDARD: pesticide laws, regulations, and orders](https://www.michigan.gov/mdard/plant-pest/pesticides/pesticide-laws-regs), read 2026-10-23