The Custom Applicator, the UAS, and the Customer's Field Records
A licensed commercial applicator is hired by a farmer to apply a restricted-use herbicide using a small unmanned aircraft system (UAS). The farmer signed a service agreement and provided his private applicator license number, though the farmer will not make the application himself. The applicator plans to keep application records in the UAS control software, which logs flight path, time, and location but not product rate or weather. The farmer asks the applicator to email him a summary so the farmer can keep it with his farm records. The applicator says the software log is enough.
1. Who is responsible for the application records in this arrangement, and what must those records contain?
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The commercial applicator making the application is responsible for the application records, even though the farmer is the customer and holds a private license. The farmer's license number is relevant to the restricted-use product transaction, but it does not shift recordkeeping responsibility to the farmer for an application the applicator performs. The records must include product name and EPA registration number, rate and total amount, date and time, location and acreage, applicator name and license number, and weather conditions, in addition to whatever the UAS logs. The UAS flight log alone is insufficient because it lacks product rate and weather, which are core record elements.
2. Is the UAS flight log sufficient documentation? What gaps exist and how should they be closed?
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No. The UAS log documents flight path, time, and location-useful for showing where the aircraft went-but it does not show what product was applied, at what rate, or under what weather conditions. Those are exactly the facts an inspector needs to evaluate label compliance. The applicator should supplement the flight log with a written or electronic application record capturing product, rate, total applied, weather (wind speed/direction, temperature, inversion status), and the applicator's license number. The applicator should also document that the buffer and any label-required conditions were met. The two records together-flight log plus application record-give a complete picture.
3. The farmer wants a copy of the records. Should the applicator provide it, and what should the applicator keep?
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Yes. Providing the customer a summary is good practice and may be required depending on the arrangement; it also helps the farmer maintain his own farm records. The applicator should provide accurate information (product, rate, date, area) and should keep the complete original records-including the UAS log, weather data, and the signed service agreement-for the retention period required by Ohio law. The applicator should not rely on the customer's copy as the applicator's own record. Keeping complete records protects the applicator if the application is later questioned, and it lets the applicator demonstrate that the restricted-use product was applied by a certified applicator under label conditions.