IPM – Written Plans and Record-Keeping

golf course maintenance

In order to be sold or distributed in Florida, all pesticide products must undergo registration by both the U.S. Environmental Protection Agency (EPA) and the Florida Department of Agriculture and Consumers Services (FDACS). The FDACS carries out pesticide registration, enforcement, evaluation, and analysis programs to ensure proper use and disposal. Moreover, proper pesticide regulation involves using legally registered pesticides, following manufacturer recommendations, and acquiring licenses and continuing education for pesticide use in golf course maintenance.

The active ingredient in a commercial pesticide product is the component that controls or kills the targeted pest, while the product may also contain additional inert ingredients such as solvents, surfactants, and carriers. However, not all inert ingredients are harmless, and they may be regulated due to environmental or health concerns. The EPA regulates the use of pesticide products based on their active ingredients, but also monitors and limits the use of inert ingredients based on their toxicity.

Regulation

Pesticide use and disposal in the United States are regulated by the EPA, as mandated by the U.S. Congress. The EPA’s Office of Pesticide Programs oversees pesticide use and disposal through two federal statutes, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA).

FIFRA, last amended by Congress in 1988, governs the licensing or registration of pesticide products. Under FIFRA, the EPA and state regulatory agencies can enter into cooperative enforcement agreements. In 1978, FIFRA was amended to give state governments primary enforcement responsibility, with EPA oversight, for pesticide-use violations.

Under the Federal Food, Drug, and Cosmetic Act (FFDCA), the EPA has the authority to establish tolerances for pesticide residues in raw and processed foods, which are monitored and enforced by the Food and Drug Administration (FDA) of the U.S. Department of Health and Human Services.

The EPA allows state regulatory agencies to establish local standards, but these standards must be as strict or stricter than those set by the EPA. Due to the unique environmental conditions in Florida, the state has implemented regulations that are more stringent than the federal guidelines for certain pesticides. The Florida Department of Agriculture and Consumers Services (FDACS) is the primary state agency responsible for ensuring that pesticides are registered, used, and disposed of properly in cooperation with the EPA. Additionally, FDACS analyzes soil and water samples from the field to determine if pesticide residues are at acceptable levels in the environment.

Four primary programs within FDACS carry out these responsibilities: pesticide registration, pesticide enforcement, scientific evaluation, and laboratory analysis.

The EPA requires registrants of pesticides to provide a series of environmental fate and toxicity studies depending on the specific use of the pesticide. Private laboratories carry out these studies, adhering to strict good laboratory practices (GLPs) and QA/QC measures. After the registrant meets all EPA guidelines and the risk assessment is complete, the pesticide product can receive federal registration.

In some states, including Florida, an additional review is required before a pesticide can be sold and distributed. Scientists at FDACS analyze the behavior of the pesticide under Florida’s unique environmental conditions, such as high annual rainfall, year-round cropping, Karst topography, and sandy soils. The goal is to evaluate the pesticide’s risk to surface water and groundwater quality, threatened and endangered species, and Florida citizens.

The Pesticide Registration and Evaluation Committee (PREC), which comprises members from various Florida agencies, reviews all new pesticides for registration. If unreasonable risks are suspected, the manufacturer may be required to provide additional data, perform field tests under Florida-specific conditions, and/or impose risk mitigation measures.

All pesticides registered for use in Florida are required to carry a label that specifies maximum allowed application rates, approved application methods and times, crops, sites, and pests, as well as directions for safe and effective use. Federal and state laws mandate the use and disposal of pesticides in accordance with the label.

Pesticide Regulation Best Management Practices

To ensure proper pesticide regulation, it is important to follow the best management practices outlined below:

1. Use only pesticides that are legally registered at all levels of jurisdiction.

2. Use only pesticides that have been registered for use on the facility in compliance with the law. Avoid using pesticides labeled for agricultural purposes, even if they have the same active ingredient.

3. Apply pesticides according to the manufacturer’s recommendations as specified on the label.

Requirements for Licensing Pesticide Use in Golf Course Maintenance

Federal and state regulations require that individuals involved in the manufacturing, formulation, marketing, or use of any pesticide must comply with certain laws. Those who use restricted use pesticides (RUPs) for golf course maintenance must obtain an RUP applicator license from the Florida Department of Agriculture and Consumer Services (FDACS).

A licensed applicator can supervise up to 15 unlicensed pesticide handlers. Training and exams are provided by County Cooperative Extension Service offices throughout the state. Exam study manuals can be purchased from the UF/IFAS Extension Bookstore at a nominal cost.

To find the exam schedule for a specific County Cooperative Extension Service office, contact that office directly. The FDACS Bureau of Licensing and Enforcement can provide more information at (850) 617-7870.

Continuing Education and Applicator Training

To renew their license, applicants must either earn continuing education units (CEUs) or retake the exams. The Florida Department of Agriculture and Consumer Services (FDACS) mandates that Ornamental and Turfgrass Pest Control category holders must acquire 16 CEUs in total, with 4 being in core and 12 in the category.

The University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) and industry associations like the Florida Golf Course Superintendents Association and the Florida Turfgrass Association provide numerous training opportunities annually. These events equip learners with practical knowledge about pesticide safety, scouting, cultural practices and integrated pest management (IPM), equipment calibration and maintenance, and record-keeping. Proper applicator training is crucial for safe and effective pesticide use.

Record Keeping 

Maintaining accurate records of pesticide applications is a legal responsibility of certified applicators in Florida. According to state regulations, applicators must record information on restricted use pesticides (RUPs) within two working days of application and maintain the records for two years from the application date. These records must be available for inspection by FDACS representatives, USDA authorized representatives, and licensed health care professionals upon request.

To comply with the RUP recordkeeping requirement, Florida law requires that the following items be recorded:

  • Brand or product name

  • EPA registration number

  • Total amount applied

  • Location of application site

  • Size of area treated

  • Crop/variety/target site

  • Month/day/year and start and end times of application

  • Name and license number of applicator (or name and license number of supervisor if applicator is not licensed)

  • Method of application

  • Name of the person authorizing the application, if the licensed applicator does not own or lease the property.

Thus, pesticide products in Florida must be registered by the EPA and the Florida Department of Agriculture and Consumers Services (FDACS), with regulations focused on both active and inert ingredients. The EPA regulates active ingredients based on their control of pests and monitors inert ingredients for toxicity.

Florida has implemented stricter regulations due to its unique environmental conditions. FDACS is responsible for pesticide registration, enforcement, evaluation, and analysis. Pesticides must undergo environmental fate and toxicity studies, and Florida-specific reviews are conducted. All registered pesticides must have a label specifying approved application rates, methods, and directions.

Proper pesticide regulation involves using legally registered pesticides, following manufacturer’s recommendations, and obtaining licenses for restricted use pesticides. Continuing education and record-keeping are essential for license renewal and compliance with Florida regulations.