Pesticide record requirements in Queensland

Queensland requires a record of every pest management activity, made as soon as practicable and no later than 24 hours after the activity, retained for five years, and kept in a tamper-evident form. The obligation is section 46 of the Medicines and Poisons (Pest Management Activities) Regulation 2021, administered by Queensland Health.

Queensland is the strictest jurisdiction in the country on both ends of the record's life. The 24-hour deadline is half what New South Wales allows and a quarter of Western Australia's two business days; the five-year retention is two years longer than any other state.

The record also sits inside a wider set of obligations that no other state imposes in the same form: advice to the occupier before the treatment, a notice to the occupier after it, a risk plan for sensitive places, and a clearance certificate for fumigation.

The section 46 record identifies the activity, the place, the customer, the technician and the product in enough detail to reconstruct exactly what was applied and at what strength. Queensland asks for the active constituents and the strength of the product, which goes further than a trade name alone.

The technician's licence number is a required field. As in Victoria, this means the record itself evidences that licensed work was performed by a licensed person.

The record must be made as soon as practicable after the activity, and in any case within 24 hours. "As soon as practicable" is the primary obligation; the 24 hours is the backstop, not an entitlement to wait.

In practice a 24-hour deadline rules out any weekly write-up process and most end-of-day ones, because a job finished at 4pm on Friday needs a record by 4pm Saturday. Capturing the record on site is the only workflow that reliably meets it.

Records must be kept for five years. If you operate across state lines, five years is the number to standardise on, because it is the longest retention period in the country and satisfies every other state's minimum.

Queensland requires records to be kept so they cannot be altered or deleted without the alteration or deletion being detectable. This is a requirement about the system, not about the technician's diligence — a spreadsheet fails it, because any cell can be overwritten and nothing shows that it was.

Append-only amendment is the design that satisfies it. The original record is locked once it is made; a correction is recorded as a new, timestamped, attributed entry that references the original, and the history of both remains visible. Nothing is ever overwritten or removed.

This has a real operational consequence: technicians must be able to correct a mistake without deleting anything, and the office must be able to show a regulator both what was recorded first and what it was changed to. A system that simply refuses edits is compliant but unusable, and one that allows silent edits is usable but not compliant.

Queensland requires you to give the occupier advice before the treatment and a notice after it. These are occupier-facing documents, separate from the section 46 record that you keep.

The pre-treatment advice covers the business's contact details, the date of the proposed activity, a statement about APVMA approval of the products, the precautions to be taken, and any warranties and limitations that apply to the work.

The post-treatment notice must be given before leaving an occupied place, or within 24 hours where the place is unoccupied. It covers the technician's licence number, the names and constituents of the pesticides used, where they were applied and when.

Because the two notices and the record all draw on the same underlying job data, they are best generated from one source. Re-keying product names into three documents is how a business ends up with a record and a notice that disagree.

Fumigation in Queensland carries its own document chain: a notice before the fumigation, and a clearance certificate afterwards recording the type and concentration of the fumigant, the times of introduction and release, and the method used to verify that the space is clear.

An Activity Risk Management Plan (ARMP) is required for high-risk activities and for work at sensitive places — schools, childcare centres and hospitals among them — and for all fumigation. The ARMP is a planning document produced before the work, not a record made after it.

Businesses also carry obligations around trainee logs, employee records and incident reports. These are separate retention obligations from the section 46 record and should be tracked as their own document class.

A termite management certificate issued under AS 3660 is deemed to satisfy the section 46 record for that activity. That is a genuine simplification — the certificate you already produce for the installation does double duty as the statutory use record.

It also means the certificate inherits the section 46 retention period. Termite management certificates in Queensland need to be held for five years and be as tamper-evident as any other record, which is a higher bar than most businesses apply to a document they think of as a customer deliverable.

Termite management that constitutes building work also requires a QBCC licence — the chemical or physical termite management classes — on top of the Queensland Health pest management technician licence, along with professional indemnity insurance. Two regulators, two licences, and the pest management licence alone does not cover you.

This guide is general information about pesticide record-keeping in Queensland. It is not legal advice, the Medicines and Poisons (Pest Management Activities) Regulation 2021 may be amended, and you should confirm your current obligations with Queensland Health and, for termite building work, the QBCC.