Agricultural Regulatory Compliance Checklist

Quarterly compliance review a farm manager runs across pesticide, nutrient, food-safety, worker, and animal-health regulations. Covers FIFRA/WPS, FSMA, NPDES/CAFO, OSHA/MSPA, and VFD recordkeeping for a typical mixed row-crop and livestock operation.

6 sections 23 steps Collects data
1

Pesticide & FIFRA Compliance

  1. Confirm pesticide applicator certifications are current
    • Pull each applicator's private or commercial certification card and verify the expiration date with the state lead agency. Lapsed RUP certification voids legal authority to apply restricted-use products and is a common state-inspection finding.

    Collects file
  2. Update the WPS central posting board
    • Refresh the EPA-required pesticide safety information, application list (product, EPA reg number, REI, location), and emergency contact poster at the central posting site. Workers must be able to view this without entering treated areas.

  3. Check Bulletins Live! Two for ESA limits
    • For each field where you plan applications in the next 6 months, run the address through Bulletins Live! Two and print or save any active endangered-species pesticide-use limitations. Bulletins are valid for the calendar month issued.

  4. Identify whether RUPs will be applied this cycle
    • Review the planned spray program against the EPA RUP list — atrazine, paraquat, dicamba (over-the-top formulations), chlorpyrifos products, and others. RUP use triggers stricter recordkeeping and dealer-purchase reporting.

    Collects list
  5. Pull RUP application and dealer-purchase records
    • Federal rules require RUP application records within 30 days; many states require 14 days and demand additional fields. Match dealer purchase invoices to application records — gaps are the most common audit finding.

2

Nutrient Management & Water Quality

  1. Determine the operation's CAFO classification
    • Count animal units against the EPA CAFO size thresholds (e.g., 1,000+ beef = Large; 700+ mature dairy = Large). Medium CAFOs need a permit only on discharge or pollutant-conveyance findings; Large CAFOs need an NPDES permit regardless.

    Collects list
  2. Verify the NPDES permit and nutrient management plan
    • Confirm the NPDES CAFO permit is current with the state regulator and the comprehensive NMP reflects current herd size, manure volumes, and crop rotations. NMPs that haven't been updated against actual herd numbers are a frequent permit-violation source.

  3. Inspect manure storage against 25-year storm headroom
    • Measure freeboard in lagoons and slurry pits and compare against the 25-year/24-hour storm capacity required by the NMP. Discharges during a design storm are reportable and trigger NRCS engineering review.

  4. Map manure-application setbacks per field
    • Brief each spreader operator on field-specific setbacks from streams, wells, tile inlets, property lines, and public roads. Surface-applied vs. injected manure carry different setback distances under most state NMPs.

3

Food Safety (FSMA & GAP)

  1. Confirm FSMA Produce Safety Rule coverage
    • Run the three-year average produce sales against the FSMA $25K/$500K thresholds and review the rarely-consumed-raw and commercial-processing exemptions. Coverage status determines water-testing frequency, training requirements, and FDA inspection priority.

  2. Schedule agricultural water tests at irrigation sources
    • Book generic E. coli sampling at each pre-harvest water source on the survey-based MWQP cadence. Surface-water sources need more frequent sampling than wells; missing a sampling window is the top GAP-audit non-conformance.

    Collects file
  3. Walk through GAP audit prep against prior non-conformances
    • Pull last year's USDA GAP or Primus audit report and confirm each corrective-action item is closed with evidence. Repeat findings escalate point deductions and can fail the buyer's vendor approval.

4

Worker Safety & Labor

  1. Verify ROPS and PTO guards on every tractor
    • Walk every tractor in service: ROPS installed and seatbelt functional, master PTO shield and implement input-shaft shield in place. Tractor rollovers and PTO entanglement remain the top two sources of farm fatalities under 29 CFR 1928.

  2. Document pesticide-handler training under WPS
    • Each handler needs annual EPA-approved training before they touch product, with the trainer's QR or commercial credentials recorded and the worker signature retained for two years. Worker training is annual as well; the two are separate records.

  3. Confirm whether H-2A workers will be employed
    • Check the season's labor plan against the DOL ETA-790 application timeline. H-2A obligations cascade into housing inspections, AEWR wage compliance, transportation safety, and three-quarters guarantee tracking.

    Collects list
  4. Complete the H-2A housing pre-occupancy inspection
    • State workforce agency or DOL inspector signs off on bunkhouse capacity, sanitation, fire egress, and cooking facilities under 29 CFR 1910.142. Schedule the inspection at least two weeks before worker arrival; a failed inspection delays the entire season's labor.

  5. Stock field-sanitation supplies per MSPA thresholds
    • Operations with 11+ hand-laborers in fields more than three hours owe potable water, single-use cups, toilets within a quarter-mile, and handwashing stations within OSHA 29 CFR 1928.110. Stock supplies before the first hand-harvest crew enters.

5

Animal Health & Veterinary Compliance

  1. Review active VFDs for expiration
    • VFDs covering medically-important antimicrobials in feed expire at six months and must be renewed by the veterinarian of record before the next mill order. Feeding under an expired VFD is an FDA violation and a frequent feed-mill audit finding.

  2. Verify CVIs for upcoming livestock movement
    • Confirm Certificates of Veterinary Inspection for any interstate sale, fair, or auction in the next 30 days. CVIs typically expire 30 days after issue and are checked at scales, sale barns, and state ports of entry.

  3. Track antibiotic withdrawal periods per treated animal
    • Cross-check the treatment log, ear-tag/leg-band marking system, and bulk-tank discard records. A residue violation at the plant flags the producer in the FDA database and dumps the whole tanker — recordkeeping is the only defense.

6

Records & Audit Sign-Off

  1. File the FSA acreage report by the state deadline
    • Submit form FSA-578 with planted, prevented-planted, and failed acreage by the state-specific deadline (commonly July 15 for spring crops). Late filings forfeit ARC/PLC, MPCI claims, and NAP eligibility — there is no second chance.

  2. Compile the compliance binder for state inspection
    • Assemble pesticide application records, WPS training rosters, NMP and manure-application logs, water test results, VFD copies, and CVIs into one binder. State ag-department inspectors arrive unannounced; having one binder ready beats hunting through filing cabinets.

  3. Sign off on the quarterly compliance review
    • Farm owner or operator signs off on the review, captures any open items as next-quarter actions, and files the signed record. The signature is the audit-trail anchor inspectors look for first.

    Collects list Collects paragraph Collects signature

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Sections 6
Steps 23
Category Agriculture
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