Spray Records Made Simple: What Records Utah and Other States Require
Most drone spray operators would rather be flying than doing paperwork. The trouble is that the application record is the first thing an inspector asks for, and it's the first thing you'll want if a neighbor calls about drift. If the record is missing a field, it doesn't matter how good the job was.
This post covers the fields that drone spray application records need in Utah, Idaho and Washington, what the FAA wants from a Part 137 operator, and a simple routine for logging every load. It focuses on commercial (for-hire) applicators. If you fly your own ground as a private applicator, check your state's private applicator rules.
Two sets of records: the state and the FAA
A drone spray business usually answers to two agencies.
- Your state department of agriculture licenses you as a pesticide applicator and sets the pesticide record rules. These records are about the chemical: what went on, where, how much and when.
- The FAA issues your Part 137 certificate (the agricultural aircraft operator certificate). Its records are about the operation: who you sprayed for, what you dispensed and which pilots were flying.
You need both. A complete DJI flight log won't satisfy the state, and a state record won't cover the FAA. If you haven't sorted out which state office licenses you yet, start with our guide to finding your state's license department.
The federal baseline
The EPA's applicator certification rule (40 CFR 171.303) sets the minimum that state programs must require from commercial applicators who apply restricted use pesticides (RUPs, products only certified applicators can buy and use). Those records must include the customer's name and address, the location and size of the area treated, the crop or site, the date and time, the brand name and EPA registration number, the total amount applied, and the certified applicator's name and certification number. They have to be kept for 2 years.
One note if you've read older guides: the USDA recordkeeping rule for private applicators at 7 CFR Part 110 was rescinded in 2025 (it ended July 11, 2025). Don't cite it as a current requirement. State rules still apply.
Utah: record within 24 hours, keep 2 years
Utah's rule (Utah Admin. Code R68-7-11) requires commercial applicators to record each application within 24 hours. The record must include:
- Customer name and address, plus the application address if it's different
- Total square footage or size of the area treated
- Target site, crop or commodity
- Date (month/day/year) and time
- Brand name, EPA registration number and mix rate
- Total amount applied per location per application (diluted or ready to use)
- Purpose of the application and the target pest
- Name, business address and license number of the certified commercial applicator
Records must be kept at least 2 years and shown to the Utah Department of Agriculture and Food when asked. The department publishes a commercial applicator record form you can copy.
Utah's rule doesn't list wind. Record it anyway. Most labels have wind and drift limits, and a note like "6 mph from the NW, 72°F" written at the field is the best defense you'll have if someone says your spray drifted.
Idaho: wind is required
Idaho (IDAPA 02.03.03.101) requires professional applicators to keep records for 2 years. On top of the usual customer, crop, product, EPA number, amount, size and date fields, Idaho asks for:
- Location by address, township/range/section, or latitude and longitude
- Time of day
- Approximate wind velocity and wind direction
- Full name and license number of the applicator, and the supervisor's name and license number for an apprentice
- Worker Protection Standard information exchange (who you notified at the grower's operation, and when)
For restricted use pesticides, Idaho requires you to give a copy of the record to the customer within 30 days.
Washington: the most detailed list
Washington's rule (WAC 16-228-1320, updated effective January 1, 2026) is the most demanding of the three. Records must be completed the same day as the application and kept for 7 years. Electronic records are accepted. Fields include:
- Start and stop time, not just the date
- Exact location, including a map of the field for agricultural applications of an acre or more, or location by section/township/range, GPS coordinates or irrigation block
- Product name, EPA registration number, total amount, amount per acre and concentration (for example, gallons per acre of spray output)
- Wind direction (the direction it's blowing from) and estimated speed, plus air temperature, measured near the site
- Crop or site and acres treated
- Names of everyone making the application, plus the applicator's license number, address and phone
- The commercial firm's name and address, and the apparatus license plate number
If you work in more than one state, the simple fix is to keep the strictest set of fields on every job. A Washington-ready record will cover Utah and Idaho too. Our post on reciprocal licenses covers the licensing side of working across state lines.
What the FAA wants (14 CFR 137.71)
A Part 137 operator must keep these records at its home base:
- Name and address of each person you provided service to
- Date of the service
- Name and quantity of the material dispensed on each operation
- Name, address and certificate number of each pilot, and the date each pilot met the knowledge and skill requirements of 137.19(e)
These are kept for at least 12 months. Our article on FAA and state compliance for custom applicators explains the rest of the Part 137 side. If you don't have a certificate yet, the FAA Part 137 Package handles that paperwork.
A simple routine that covers every field
You don't need a complicated system. You need the same steps on every load.
- Before you launch, fill in the customer, field location, crop, target pest and product with its EPA registration number. Most of this can be set up the night before from the work order.
- At the field, take a wind and temperature reading with a handheld meter and write down the time. Do it again if conditions change.
- After the job, record the mix rate, total product used, acres covered and stop time. Your drone's flight data helps here. DJI's SmartFarm platform shows flight paths, mission settings and job reports. If you mix with a Drone Cone, calibrating the flow meter keeps your "total amount" numbers honest.
- Same day, finish the record. That meets Washington's rule and Utah's 24-hour deadline, and you won't be trying to remember wind speed a week later.
- Store it where you can pull it up for an inspector or a customer, and keep it for the longest period that applies to you (7 years if you work in Washington).
Where DroneTrax fits
Paper forms work if you fill them out every time. Many operators use software so the record builds itself from the job. DroneTrax is one option built for spray drone businesses. It logs flights automatically, including Part 137 logs, and tracks chemicals, application rates and coverage. It also handles work orders and mapping, integrates with DJI, and syncs to QuickBooks. It can log Drone Cone mixing as well. You'll still want to enter wind and temperature from your meter at the field. There's a 14-day free trial if you want to see whether it fits how you work.
Whatever you use, the test is the same: could you hand an inspector a complete record for any job you flew in the last two years, today?
Need help getting set up?
If you have questions about record keeping, Part 137 or getting a spray drone program started, call us at 1-877-992-8279 (M–F 9–5 MT) or email sales@avarydrone.com.
This article is general information, not legal advice. Rules change, so always check your state's current pesticide rules and the label before you spray.
Sources
- Utah Admin. Code R68-7-11, Licensing and Certification (Cornell LII)
- Utah Department of Agriculture and Food, Commercial Applicator Record form
- Utah Department of Agriculture and Food, Pesticides program
- IDAPA 02.03.03, Rules Governing Pesticide and Chemigation Use and Application (Idaho, current rules)
- WAC 16-228-1320, Records for pesticide applications (Washington State Legislature)
- 40 CFR 171.303, Requirements for certification of commercial applicators (eCFR)
- 14 CFR 137.71, Records and reports (eCFR)
- Federal Register, Rescission of Recordkeeping on Restricted Use Pesticides by Certified Applicators (May 12, 2025)
- DJI Agriculture, SmartFarm platform
- DroneTrax
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