Pesticide use records in Queensland: the 24 hour rule

Queensland's Medicines and Poisons (Pest Management Activities) Regulation 2021 asks for a short list of facts about every treatment, and gives the person who carried it out 24 hours to write them down. Most businesses have a job sheet that collects some of the list. The part that goes wrong more often is what happens to pesticide use records after the technician makes them.

What pesticide use records must state

A qualified person must make a record stating each of the following matters for each pest management activity carried out by the person: (a) the date of the activity; (b) the address and a description of the place where the activity was carried out;

The rest of section 46(1) adds these:

• Paragraph (c): where the activity was requested by a customer, "the contact details of the customer".
• Paragraph (d): where the person is a licensed technician, or was supervised by one, "the technician's licence number".
• Paragraph (e)(i): "the name by which the fumigant or pesticide is marketed or sold".
• Paragraph (e)(ii): "each active constituent of the fumigant or pesticide and the strength and amount of each active constituent".
• Paragraph (e)(iii): for a fumigant or pesticide used for timber pests, "the rate of application for the fumigant or pesticide".

Paragraph (e) is where most job sheets fall short. A field for the product name does not collect the strength and amount of each active constituent. Neither does a note saying "perimeter spray, as per label".

Section 40 defines the qualified person as a person authorised under the Medicines and Poisons Act 2019 "to carry out a pest management activity with a fumigant or pesticide". In practice, that is whoever did the treatment.

Twenty four hours, not the end of the week

The qualified person must make the record as soon as practicable, but no later than 24 hours, after the pest management activity is carried out.

A technician who writes up Thursday's jobs on Saturday morning has missed it for every one of them. The practical fix is to make the record part of finishing the job, before the van leaves the driveway, when the amount mixed is still on the tank.

The technician makes it, the business keeps it

The qualified person must: (a) if the person is carrying out the pest management activity for another person who is a business operator, give the record, or a copy of the record, to the operator; or (b) otherwise: keep the record.

The dictionary in schedule 3 defines a business operator as "a licensed technician who operates a pest management business", or a person who operates one and "employs a licensed technician or pest management trainee to carry out pest management activities for the business".

Section 59(2) then puts two duties on the operator: to "take all reasonable steps to ensure the employee complies with the requirement", and to "keep any record given to the operator in compliance with the requirement".

So a treatment record kept in a technician's own notebook, or on their own phone, is not finished until the business has a copy. When that technician leaves, the notebook leaves with them, and the operator is left to show what reasonable steps it took.

Five years, retrievable, and not quietly editable

The person must take all reasonable steps to ensure the record: (a) is readily retrievable; and (b) can not be altered, obliterated, deleted or removed without detection; and (c) is kept for 5 years after the day it is recorded.

The maximum penalty stated for section 62(2) is 20 penalty units. Section 61(2) adds that written information must be "written in English" and, if recorded in hard copy, "marked legibly in ink". A pencilled job sheet fails that. A shared spreadsheet anyone can overwrite, with no history of what changed, is hard to square with section 62(2)(b).

Termite work already has its record

A termite management certificate issued for a pest management activity is taken to be a record complying with subsection (1).

Section 46(5) defines that certificate as "a certificate of installation, or certificate of termite treatment, issued under a termite management standard". File the certificate as the record rather than writing the same treatment up twice.

Setting it up so it happens every job

1. Give the job sheet one field for each item in section 46(1), and do not let a job be closed with any of them empty.
2. Keep a product list with each product's active constituents and strength already filled in from the label, so the technician only enters the amount used.
3. Each morning, check that every job completed yesterday has a record. That is the 24 hour rule, checked while it can still be met.
4. When a technician leaves, confirm the business holds every record they made before their access is removed.
5. Store records by year, so the ones older than five years can be found and the rest are not touched.

This article is general information about the Medicines and Poisons (Pest Management Activities) Regulation 2021 (Qld), not legal advice. Other states set different rules. It does not cover pre-treatment or post-treatment pest control advice, or fumigation clearance certificates. Where the regulation introduces a list with a dash, the quotes above show a colon. It quotes the regulation as current at 5 December 2025, the version on the Queensland legislation website when checked, and is current as at 14 September 2026.