Ok guys. I've read and re-read the Texas Laws and Regulations. From what I can gather, the Texas Department of Agriculture doesn't have much say so in the use of non-restrcited use or state limited use pesticides. The only restricted use pesticide I would ever need to apply is 2,4-D. Or I can use Confront and get the same results. Confront is a little more expensive, but if it keeps me from having to maintain a separate set of records, I think I'd rather not apply any restricted use pesticides. From what I understand, if I apply a restricted use pesticide, I have to keep records on all applications separate from my general billing records. But I don't have to do this for pesticides that I apply that aren't restrcited use or state limited use. Am I understanding these laws and regulations correctly? Thanks, DFW Area Landscaper
No. There's no loophole. I know a guy . . . (ahem) . . . who asked the same question to the TDA when I . . . uh . . . I mean he . . . read what you're read in the laws and regs 2 yrs ago. Just spend the money and get the license. You'll find out "the secret".
DFW, no, there is no "loophole" on the records requirement. I have spent a great deal of time with the legal counsel at TDA trying to get this one straight and was told the following: No license through TDA needed for non restricted use pesticides, however, Structural Pest Control Board demands a license if you are spraying anywhere where people can come into contact with the chemicals. No records maintained = mandatory reporting and investigation by both TDA and SPCB, despite not requiring a license. I do know that TDA mandates a calibration/certification inspection on spray systems, from a one gallon handheld all the way to nurse tank set ups. The inspectors I have met and become familiar with, all say if they do not see a TDA number on the set-up, they stop and inspect. Part of this process is a demand for records. The best way I can illustrate this is, as I was told by TDA, a large, supposedly 9 truck operation around Dallas, was reported to TDA for general apps of glyosphate. Onwer/representative states no records necessary due to no restricted use apps, TDA responds got a SPCB license? Onwer, nope - TDA, it is inspection and probable fine time.
Guys, I don't want you jumping to the wrong conclusions. I am licensed by the TDA and I am insured. I just don't want to have to maintain a separate set of records outside of my billing records. It's enough of a pain the azz to just bill a customer for an app, let alone maintain a second set of records. So every night when I get done with all my work for the day, I enter that information into Quickbooks. If I spray a little bermuda in a customers bed with glyphosphate that day, am I required to record that application in a system separate from my billing records? Thanks, DFW Area Landscaper
We have to keep copies of all apps up here also. This is what I do: I have a 2 part carbonless statement. If I do a little spot spraying, I'll indicate that on the statement. 1 copy goes to client, 1 copy goes in my records.
Yes, you have to maintain seperate records on applications. I do not provide a copy of the TDA p/w unless I am asked for one by the customer. Usually, I indicate on the invoice what I sprayed, and I haven't had anyone ask for more info. In the cab of my truck is where I maintain the TDA p/w, in a seperate folder. I actually found that if I take the two minutes to fill out the app summary, it doesn't affect my productivity. I simply added the cost of the p/w into the app price. Additonally, I never hought you did not have a license. I have had the same question about restricted use that you did-that is why I called TDA and spoke with their legal counsel. If you want that info with regards as to whom I spoke and a phone number, PM me and I will respond.
I am trying to adopt similar methods as SWD. Paperwork is a pain when you are sweating and spraying. Consider using a printout that already has all the chemical data on it since most apps are similar per round where all you have to do is plug in location, time, and weather. TDA even has some sample forms on their website. I print off mailing labels with app data on it to stick to the customer invoice to speed things up on the job(besides my writing is horrible).
