Record keeping for pest controllers

Pest control operators (PCOs) must keep records for every pesticide application for every job. This is a requirement under r. 69(1) of the Public Health and Wellbeing Regulations 2019 and s. 108 of the Public Health and Wellbeing Act 2008 (PHW Act).

It is an offence to fail to keep the prescribed records for the prescribed period or create false records.

Pesticides – records to be kept

The PCO that applies the pesticide must record the following details for every pesticide application:

• trade name of pesticide
• batch number of pesticide
• specific precautions to be observed including the re-entry period
• date of application
• start and finish times of application the pests treated
• location of the pesticide application (including street address of property, if applicable)
• specific location of the pesticide application within the property (i.e areas within a property where the product was applied)
• pests treated
• method of application (spray or bait)
• quantity of pesticide applied
• rate of application or sufficient information to allow the rate of pesticide application to be determined (as expressed on the product label)
• if applied outdoors, the ambient temperature, wind direction and speed at the time of application (and any other relevant weather conditions)
• name and licence number of the person supervising the application (if applicable - for example, where the pesticide is applied by a trainee licence holder)
• trading name, address and phone number of the business employing, engaging or owned by the person applying the pesticide
• name, phone number and address of the person for whom the application was carried out
• signature of the person completing the record.

All records must be kept at the business address for a minimum of 3 years. They should be accurate, up to date, clear, consistent and in English.

Pesticide application record template

You can download a template of a pesticide application record sheet, and use or adapt for your purposes. If a pest control business already has a record sheet it uses, PCOs must make sure it contains all the sections that are covered by the template, for each pesticide used.

Record keeping – weather conditions and spray drift

Under the PHW Act, it is an offence to cause a nuisance. Nuisances are defined as a state, condition or activity that is, or is liable to be, dangerous to health or noxious, annoying or injurious to personal comfort. The PHW Act requires municipal councils to remedy as far as is reasonably possible all nuisances in its municipality.

Council is required to investigate any notice of a nuisance and either take action to abate nuisances or advise the notifier of any available methods for settling the matter privately.

Under the Agricultural and Veterinary Chemicals (Control of Use) Act 1992, a person must not carry out agricultural spraying that:

• affects or causes injury to:
  • any plants or stock outside the target area
  • any land outside the target area so that growing plants or keeping stock on that land can be reasonably expected to result in the contamination of the stock, or agricultural produce derived from the plants or stock
• contaminates any stock or agricultural produce outside the target area.

Off-target application of chemical products that creates a hazard that is likely to adversely affect a person’s health or the environment comes within the offence of pollution created by the Environment Protection Act 1970.

WorkSafe Victoria may also become involved if the spray drift incident involves the activities of a workplace that effects the health and safety of employees at that workplace and of others (being persons other than the employer’s employees).

The Department of Jobs, Precincts and Regions (DJPR) investigates reports of alleged misuse of chemical products. DJPR also cooperates with the department and Environmental Protection Authority when pursuing alleged incidents involving off-target application of agricultural chemical products.

Spray drift – how to reduce

The department receives a considerable number of complaints from the public with regard to spray drift. Spray drift raises issues with occupational and public health, such as:

• specific physical health problems
• drinking water contamination
• smell and air pollution concerns
• general uncertainty and anxiety caused by the drift
• concern about pet animal health
• environment concerns, such as contamination of water sources, land, plants and animal feed.

Spray and particulate drift include drift of chemical pesticides in granular, powder, dust or spray form. Some chemicals should also be used with caution if they emit vapour drift.

Those at greatest risk of health problems associated with spray drift are the PCOs themselves.

The atomiser and spray settings (such as pressure, flow rate, nozzle spray angle) influence the droplet size of the chemical being sprayed. Producing pesticide droplets smaller than 50–100 µm is not recommended, as these droplets are most likely to evaporate or drift.

You should perform a site risk assessment before starting every job. If you need to apply pesticides outdoors, monitoring wind speed, wind direction and temperature should be a part of the risk assessment procedure.

In place of a wind-measuring instrument, PCOs can use the Beaufort Scale as a guide to assess the suitability of the weather conditions for spraying.

Remember to assess all aspects of the weather (for example, temperature, humidity and wind direction) when deciding if it is safe to spray pesticides.

If you use the Beaufort Scale to estimate the wind force, you should record this. You can present the data like ‘Beaufort Scale: Force 2, light breeze from the NE’.

You should ALWAYS read and follow the pesticide label instructions, and remember:

• If the environmental conditions change significantly during application, note the time and nature of the changes.
• Pesticides should not be applied if you notice drift occurring due to wind.
• If you notice wind blowing toward sensitive areas, postpone pesticide application until the wind stabilises and changes direction.
• High temperature and low humidity leads to faster evaporation of the spray droplet, increasing chances for drift. Loss of pesticide through evaporation and drift can reduce the effectiveness from that originally calculated.

Beaufort wind scale for pesticide spraying

The Beaufort scale is measure that relates wind speed to observed conditions at sea or on land.

Pest control operators need to be aware of wind conditions, as some conditions are not ideal for spraying pesticides.

Table 1 outlines different wind speeds and their corresponding Beaufort number, and how these conditions relate to pesticide spray application.

Table 1: Beaufort scale and pesticide spraying conditions

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