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Inspection Requirements for Commercial Applicators

Below is a list of common things that your inspector will be looking at during their routine inspection. Your annual inspection is a good time to ask questions. If your inspector doesn’t know the answer they will find out for you.
  • Is everyone making pesticide applications for your business licensed?
  • Are you licensed for the specific type of work you do (structural, O&T, Right of Way)?
  • Ask the inspector if they want all your operators present. They may need to inspect all vehicles and equipment.
  • Is your pesticide storage area secure and signed?
    Pesticide intended for use by commercial pesticide applicators shall be stored in enclosed, secured areas and shall be posted with warning signs in English and Spanish.
  • Are all containers in good condition? Are all labels present and legible?
  • Are you in possession of old, unregistered products? If you have questions about products, ask your inspector.
  • Have empty containers been triple rinsed, rendered unusable, and disposed of correctly?
  • Are your bait boxes labeled with your business name, pesticide name, EPA reg. no., and the NM Poison Control number (1-800-222-1222)?
  • Do all your service vehicles have the right information correctly displayed?
    Service vehicles used by commercial applicators and operators must be prominently marked with the name of the firm and the commercial applicator’s license number. All letters and numerals shall be of bold lettering at least one and one-half (1-1/2) inches high with a contrasting color as background. Markings shall be visible on both the right and left side of the service vehicle.
  • Can you secure pesticides and application equipment so it is inaccessible to unauthorized persons?
  • Is your application equipment in good working order and clean with good hoses and nozzles that don’t leak? Do you have backflow prevention where appropriate?
  • Do you and your operators all have the personal protective equipment (PPE) required by the labels of pesticides you use? Is it clean and stored away from the pesticides?
  • Have all your application records for the last two years available. Do your records include everything the law requires? Are they legible?
  • The customer’s name
  • The date, time, and location of the application
  • The name and EPA registration number of the pesticide or pesticides used
  • The concentration or rate applied
  • The target pest and site (name of crop or specific site)
  • If the application is made outdoors, the wind direction and speed and the temperature at the time of the application
  • The total volume of mixed pesticide (use-dilution preparation) applied, whenever the pest control category is agricultural, forest, ornamental, aquatic, right-of-way, public health, or wood destroying pest control
  • The name and license number of the individual who applied the pesticide.

Below are some helpful templates for record keeping:

O&T Application Record Template

Structural Application Record Template

  • Check the products you have in storage and on your vehicles. Do the EPA registration numbers on the products agree with the numbers on your records? These numbers can change even if the product name is the same.
  • Is your insurance valid, adequate, and up to date?

Brad Lewis, AES Division Director