# Pesticide storage: inventory, returns and road-transport checks

URL: https://grangebook.com/ie/pesticide-store-stock-records/
Reviewed: 2026-10-29

**Irish professional users must keep three sets of pesticide records: products received, products applied, and products returned or disposed of.** Each record carries the brand name and PCS number, and quantities are in kilograms or litres. An authorised officer can ask to inspect the records.

Stock is the running balance of those three records. The store itself must also meet DAFM's minimum structure, equipment and operating rules.

A shelf count shows only what is there today; the three records explain how the balance got there. Count the physical stock before you look at the calculated balance, so you report what you see rather than what you expect. If a difference is large and unexplained, ask a second responsible person to check the original movements before you enter any correction.

## Pesticide storage: what the store must be

DAFM sets these minimum requirements for the structure of a professional user's pesticide store:

The operator guidance adds that all products stored on a farm must be in a secure, bunded chemical store that is clearly identified. No pesticide use or storage is permitted inside the safeguard zones set around groundwater abstraction points such as wells and boreholes.

Match each original container to its purchase documents by marketed name and PCS number. Record different formulations and concentrations separately, so an active-substance nickname does not merge different products. Count packs by size rather than as one combined number: three sealed 5-litre packs and two sealed 1-litre packs are 17 litres of product (a worked example, not a purchase record). Keep a copy of the stock list where the person managing chemicals can find it, and give relief staff a location for each product group. A photograph of the shelves is not a substitute for the quantities.

Keep two things apart: how many containers are on the shelf and how much product is left. An opened container can stay on the shelf long after most of its contents are used. Note the date and the way you measured, and mark an estimate as an estimate. Do not open or handle a damaged pack just to get an exact-looking number; keep the last reliable quantity and say why the present figure is uncertain.

Keep the unit written on the original document. Kilograms and litres are different quantities, and converting needs product information, not a guess based on water. If you convert, write the conversion down with its source.

## Equipment the store must have

Where appropriate, DAFM requires these facilities to be available and used:

## Operating rules inside the store

Powders are stored separately from or above liquids. Products are stored only in their original containers. An appropriate area is used for measuring and mixing. Only products on the register of plant protection products may be acquired and stored.

Walk through the store with a person who knows it and ask in order: can someone find the entrance, get in and read the pack labels? Are the shelves suitable for what is on them? Is a damaged container visible? Could a leak escape the store? A balanced stock sheet does not show that the building meets DAFM's requirements, so check the building against the DAFM document itself. Never pour unidentified remnants into another container or combine similar-looking products to shorten the list. Record damaged packaging as it is, without moving it during the count, and ask the supplier or the receiving company what to do with unidentified or leaking material.

A user who handles very small quantities and stores them for very brief periods can apply to the Minister for exemption from some or all of the storage and record-keeping requirements.

## What a stock record contains

For products received, record the supplier's name and address, and for each product the brand name, PCS number, pack size or sizes, and the quantity received in kilograms or litres.

When a delivery arrives, compare the label, marketed name, PCS number, pack sizes and quantities with the order and the supplier's paperwork before you put it with existing stock. If the supplier substituted a product or the quantity differs, sort it out with the supplier and keep the supplier's explanation with the original invoice instead of altering the invoice yourself. Keep a disputed item identifiable until it is settled. If the invoice arrives after the delivery, keep the delivery reference so both documents match the same receipt. A credit note changes the account, not the shelf: check what actually moved before changing the stock quantity. Where one delivery serves several holdings, write down which farm received which product.

For each product applied, record the brand name, PCS number, date or dates of application, crop and area treated, quantity applied in kilograms or litres, and the reason for use. Use the [spray-record sheet guide](/ie/spray-record-sheet/) for the application entry.

Take the figures for the stock deduction from the completed job record. Deduct the quantity of product used, not the whole volume of spray liquid with its carrier water. If a contractor supplied the product, establish whose stock was used and keep the contractor's application record and invoice with the job; do not take contractor-supplied product off your own stock only because the work was on your land.

For each product returned or disposed of, record the company it was returned to or the name of the disposal company, the brand name, PCS number, date and quantity. See the [pesticide disposal guide](/ie/pesticide-container-waste-disposal/) for empty containers and waste.

Write a return or disposal as planned until the receiver has accepted and taken the product. Record rejected items separately so they stay in the physical stock, and do not remove an item from the list just because a collection was requested. Give the receiver the real identity and condition of the material before agreeing transport or acceptance.

Since 1 January 2014, professional users must also keep records showing that the principles of Integrated Pest Management are being implemented.

## If the numbers do not match

Compare the opening count, the receipts, the completed uses and the documented returns, all in compatible units, and re-check the pack identity when trade names are similar. Look for an unfiled delivery, an entry against the wrong holding, a duplicate application record or a movement entered before the job was done. Write down the explanation and the correction. Do not force the closing balance by inventing an application quantity. While a difference is unresolved, keep the counted quantity and the calculated balance as two separate figures and name the person looking into it.

## Products that are no longer registered

Existing stocks of products whose registration has recently expired, been withdrawn or been revoked may in some instances continue to be used. DAFM's product pages give the status of each product; see the [withdrawal-date guide](/ie/pesticide-register-ireland/).

An old label, an expired registration and a confirmed last-use date are three different pieces of evidence. Mark stock whose status is unclear as "do not use", ask DAFM, and save the reply with that product. Keep this decision separate from the stock count.

## Pesticide transport: when a dangerous goods safety adviser is needed

An undertaking involved in the consignment or carriage of dangerous goods by road, or in the related packing, loading, filling or unloading, must appoint a vocationally qualified dangerous goods safety adviser (DGSA).

There are exceptions. An undertaking whose dangerous goods are minimal, low risk or infrequently consigned may not need to appoint one, for example where it stays within the ADR 1.1.3.6 small-load limits or ADR 3.4 limited quantities. Even then the rules on correct packaging, labelling and documentation still apply.

A DGSA can be the head of the undertaking, an employee or an external consultant with a current vocational training certificate, and the appointment must be in writing.

To get useful advice from the adviser, prepare the full marketed name and the current supplier safety information for each product. Say whether each item is unused product, a return, residue or waste, how much of it there is and what condition the packaging is in. Name who collects, packs, loads, carries and unloads it, where it comes from and where it goes, and whether another contractor is involved. For damaged or unidentified material, describe the condition before any movement is arranged, and do not repackage or combine products to make the list shorter.

## What the DGSA provides

The DGSA advises on classification of dangerous goods, including hazardous waste, under ADR Chapter 2.2, and provides the undertaking with a written copy of the test results and of how the classification was carried out. For wastes, it may be necessary to test samples to determine the correct classification.

The DGSA gives written advice on suitable containment, covering packaging, tanks, containers and vehicles under ADR Parts 4 and 9. The undertaking holds the packaging type approval certification and conditions of use supplied by the manufacturer or supplier.

The DGSA gives written advice on marking and labelling of packages under ADR 5.2 for each role the undertaking fulfils, such as consignor, packer, loader and unloader.

For exemptions, the DGSA gives clear written guidance on how each applies. Exemptions the HSA lists include empty uncleaned packaging (ADR 1.1.3.5) and small loads or packaged goods in limited or excepted quantities.

Ask for that advice in writing and say which conditions apply to your actual load and journey. State the quantity, packaging and route you assume. Do not copy an exemption number from someone else's fuel or fertiliser journey and assume it covers your pesticides. If you move loads regularly, decide who checks each load against the agreed conditions, and take any case outside them back to the adviser before the vehicle leaves. If the load changes, for example after a store clear-out, send the new list for assessment; advice on one product or pack type does not cover additions.

## Loading and transport documents

Dangerous goods must be secured so that loads do not shift, fall or lead to a loss of containment.

Keep the loading instruction with the person doing the work. Before departure check closures, labels and the condition of the packaging against the transport instruction, show the adviser any leaks, residues or damage, and give the driver the emergency instructions for this load.

The consignor and the carrier each hold the transport documents and other information required by ADR for 3 months.

## Next step

Reconcile counted packs against the receipts, applications and returns above, then confirm the [disposal route for rejected stock](/ie/pesticide-container-waste-disposal/).