# Must pesticide application records be kept for at least two years? URL: https://leafwrit.com/us/pesticide-application-records-two-years/ Reviewed: 2026-10-26 **“Pesticide application records must be kept for at least two years” needs a record category and a starting event.** The current [WPS rule, 40 CFR 170.311(b)(6)](https://www.ecfr.gov/current/title-40/chapter-I/subchapter-E/part-170/subpart-D/section-170.311), requires covered pesticide application and hazard information to be retained for two years **after the applicable restricted-entry interval expires**. USDA's separate 7 CFR Part 110 was removed effective July 11, 2025. The underlying pesticide-recordkeeping statute still contains a conditional two-year provision where there is no state record requirement. These are separate legal texts. ## Is the two-year statement true or false? As an unqualified statement about every US spray record, it is incomplete. For covered WPS application and hazard information, two years is the specified retention period, measured after REI expiration. For the no-state-requirement situation described in 7 USC 136i–1(a)(1), the statute specifies a two-year period after use. For Ohio private application records, the current state rule specifies three years from application. | Text or record category | What the cited source establishes | Event to identify | | --- | --- | --- | | Current WPS application and hazard information | Two years on the agricultural establishment | Expiration of the applicable REI | | 7 USC 136i–1(a)(1), when there is no state record requirement | Two-year period in the statutory text | Use of the restricted-use pesticide | | Former USDA 7 CFR Part 110 | Removed effective July 11, 2025 | Historical rule, not a current archive instruction | | Ohio private-applicator application record | Three years under OAC 901:5-11-10(E)(3) | Application date | Read each row with its condition. A workbook labeled “federal pesticide records” does not establish which row governs the information inside it. A private application record and an employer's WPS information package can concern the same treatment while serving different purposes. For a broader comparison of jurisdictions and record categories, use [how long pesticide application records must be kept](/us/how-long-must-pesticide-application-records-be-kept/). This page focuses on interpreting and correcting the specific two-year statement, especially in old worksheets, training notes and archive settings. ## What changed when USDA removed Part 110? The May 12, 2025 Federal Register final rule directs removal of all of Part 110 and gives July 11, 2025 as its effective date. It explains that USDA's recordkeeping program had previously been defunded and closed. A saved USDA page describing the former regulation is therefore not sufficient evidence of a current obligation under that regulation. That removal did not erase the separate text of 7 USC 136i–1. The Office of the Law Revision Counsel's published statutory text still contains the conditional record clause for certified restricted-use pesticide applicators where a state has no record requirement. It names product, amount, approximate application date and application location, with a two-year period after use. Keep this provision distinct from the removed regulatory scheme. When correcting a worksheet, replace a sentence that attributes a current duty to Part 110 with the actual applicable source. Preserve a historical version if it explains how older records were prepared. Mark the revised instructions clearly, identify the change and keep the earlier entry dates intact. Updating an instruction is different from changing the facts of a completed application. Do not infer that all recordkeeping ended, or that every record now has the same period. Identify the state category and any covered employer information separately. Ohio's private-applicator rule, for example, contains its own timing and retention provisions. ## The WPS clock starts at REI expiration For information covered by 40 CFR 170.311(b), paragraph (6) sets retention at two years after the applicable restricted-entry interval expires. An application date alone does not identify that starting event. The same section requires the application start and end dates and times and the duration of the labeling-specified REI within the application information. **Invented timeline example:** imagine an application ends on June 10 and its applicable REI expires on June 11 of the same invented year. The WPS archive reference is that June 11 expiration, followed by the rule's two-year period. The dates are invented to distinguish the events; they supply no pesticide interval or treatment recommendation. Use the actual application and labeling information for a real record. In an archive worksheet, give application completion and REI expiration separate headings. Preserve the source used for the interval and the meaning of the timestamps. If an imported file contains an undifferentiated date column, resolve its meaning with the original preparer before assigning an archive end date. For an establishment with several treatment entries, keep the event relationship on each entry. Avoid replacing a particular treatment's REI expiration with a general season-closing date. Record the calculation basis next to the information it concerns so a replacement administrator can understand the retention decision without reopening the old software. ## Keep the information package, including the SDS The WPS list includes a safety data sheet; pesticide name, EPA registration number and active ingredients; the crop or site and treated-area description; application dates and start/end times; and the applicable labeling-specified REI. The retention provision refers to the application and hazard information described in that list. An application row alone can therefore leave part of the information package missing. Use an attachment inventory to connect the sheet to the treatment. Record the filename and product identifier and open the saved document independently of the supplier's website. Keep the document readable, including its identifying pages, rather than retaining only a photograph of an unreadable thumbnail. If a product name appears in several files, identify which document belongs to the particular treatment. Preserve the original attachment name when adding a clearer archive filename. These are suggested document-management steps for the cited information package, not additional legal fields or a prescribed electronic format. ## Display and retention answer different questions Section 170.311(b) treats display and retention separately. The display duration has a rule tied to the last applicable REI and the presence of workers or handlers, while the archive provision uses its own two-year period. Finishing the display task does not itself complete retention. Give the display copy and archive copy clear roles in office instructions. When removing an expired display, identify where its retained information can be retrieved. Keep the supporting document relationships intact; moving a sheet from a display board should not break the connection between its product, treatment and archived SDS. The EPA's WPS overview distinguishes the agricultural worker and pesticide-handler protections and explains that its coverage concerns agricultural establishments producing plants. Use the WPS category where it applies, rather than labeling every customer invoice or every pesticide use as a WPS record merely because the subject involves spraying. For practical record preparation, the [spray log sheet guide](/us/spray-log-sheet/) helps separate a working application row from the surrounding documents. Keep the legal basis attached to the specific record purpose when adapting a blank worksheet. ## A state rule can require a longer archive Ohio's private rule requires the applicator or employer, where applicable, to retain the records for three years from application and make them available to the director. It also requires application-day entries and, where applicable, an employer copy that day. This is a current state example showing why “two years” cannot replace a jurisdiction-specific instruction. Use the [Ohio private applicator recordkeeping guide](/us/ohio-private-pesticide-records/) for the full state field list and work-arrangement distinctions. For Wisconsin atrazine work, keep the [separate atrazine record guide](/us/wisconsin-atrazine-records/) as its own subject rather than renaming that article to answer a general national retention question. In a shared archive, identify each record's purpose and jurisdiction in the index. Keep application records, worker information, customer documents and supporting maps connected, while recording the relevant retention basis for each. If you choose to retain a complete job folder longer for your own administration, label that choice as an internal policy rather than presenting it as a universal legal minimum. ## Correct a legacy worksheet without losing its history Start by collecting the instructions that staff actually use: the printed binder cover, spreadsheet notes, procedure document, training slide and software setting. Search those documents for the exact phrase about at least two years, and for references to USDA Part 110. Keep a list of where the wording appears so updating the office copy does not leave an older field worksheet in circulation. For every occurrence, identify the record described. Is it the private applicator's application entry, the employer's hazard information, a contractor handover or an internal invoice file? Put the applicable source beside that purpose. The decision should come from the relevant provision, not from the date when someone last edited the spreadsheet. Use a revision log with the document name, earlier wording, replacement instruction, source URL, review date and person completing the change. Retain enough context to explain why an older season followed different instructions. Avoid overwriting application dates, amounts or locations when the change concerns only the archive procedure. Then check copies used outside the office. Ask a field supervisor to open the saved worksheet on the device normally used for records, and have another person retrieve the printable version. Replace an obsolete instruction in both places. Keep a short note identifying which version staff should use for the next completed treatment. ## Before deleting records, review the whole folder Choose an older application and retrieve its source note, final entry, product attachment, location key and any handover correspondence. Identify which dates support the archive decision. If a filename gives a different year from the entry, resolve the discrepancy against the documents rather than assuming the folder label is authoritative. Check that the archive contains readable evidence. Look for cropped scans, broken attachment paths, unexplained abbreviations and quantity headings lost during spreadsheet conversion. Ask a colleague who did not prepare the entry to locate the treated area using the retained map key. Correct a retrieval failure before retiring the system that still contains the usable copy. Keep an exception list for files whose purpose or starting event has not been resolved. Record the specific question, supporting documents and person assigned to resolve it. This is an editorial review method; it does not create an additional statutory retention period or authorize destruction after the shortest period in a comparison table. ## Questions to put beside the two-year sentence When you encounter the statement in a training handout, first identify its citation. A reference to removed Part 110 calls for a different correction from a reference to the current WPS archive provision. Preserve the distinction between a repealed regulation and a statute that remains in the published Code. Next identify the starting event. “After use” and “after REI expiration” describe different anchors in the sources above. Finally, identify the state and applicator category; the Ohio example demonstrates a longer state period. A useful instruction states those conditions with the retention period instead of leaving a bare number for staff to interpret. Keep the resulting explanation concise enough to fit beside the worksheet's archive setting. Link the source, record its review date and preserve the revision note. The objective is a traceable decision about an identifiable information package, not a memorized answer detached from the work and jurisdiction it describes. ## Make an archive portable before changing software Create a small transfer inventory before closing an old account. Name the register export, scanned pages, SDS attachments, field dictionary and procedure revisions. Record where each item will live after migration. A successful spreadsheet import does not show whether a linked photograph or document survived the transfer. For a practical acceptance exercise, choose a record with a corrected quantity, another with a renamed block and another whose attachment arrived by email. Open them from the destination archive using a replacement employee's ordinary access route. Inspect accents, punctuation, decimal separators and column widths. Confirm that a truncated cell has not hidden a product identifier or a timestamp suffix. Preserve the import mapping and any conversion notes. If one system used separate date and time fields while another combined them, explain the transformation. Document how attachment references were renamed, and retain the correspondence that resolves an ambiguous abbreviation. These are suggested continuity checks for an archive move; they are not a government-mandated file specification. ## Prepare a paper-file handover For paper records, label the binder spine and prepare a contents sheet identifying the seasons, locations and document categories inside. Keep a legible map legend with the pages that use it. If a folded plan or loose sheet belongs to a particular application, identify that connection before sending the binder to storage. During a staff departure, ask the outgoing administrator to describe the filing convention in writing. Identify the cabinet, electronic directory, backup location and person responsible for retrieval. Arrange an ordinary handover exercise in which the successor retrieves a document without using the departing employee's personal inbox. If the business scans the paper file, compare the scan with the original for missing reverse sides, faint handwriting, cut-off margins and page sequence. Keep the resulting index understandable to someone who has never visited the farm. A readable archive needs context as well as a date: the retention comparison above addresses duration, while these suggested handover steps address whether the retained information can still be interpreted. ### Must pesticide application records be kept for at least two years? The answer depends on the record category and jurisdiction. WPS application and hazard information has an REI-based two-year period; Ohio private application records have a three-year state period. ### Was the USDA pesticide recordkeeping rule removed? Yes. The final rule removed 7 CFR Part 110 effective July 11, 2025. The separate statute still contains its conditional two-year record clause. ### Does the WPS two-year period start on the application date? The application and hazard information provision starts that period after expiration of the applicable restricted-entry interval. ### Does a safety data sheet belong with WPS application information? Yes. A copy of the safety data sheet is included in the information list referenced by the retention provision.