Microsoft word - organic pesticides.doc

Organic Processing and the Use of Pesticides

Univar USA
Professional Products and Services
Overview
CFR Title 40 – page 2
The OMRI – page 2
The NOP – page 2
The National List of Allowed and Prohibited Substances – page 4
Potential pesticide products allowed in Organic facilities – page 6


Overview:

With many commercial and private operations in the United States interested in producing or processing “organic” food
products, there is increased interest in having a list of pesticides available that would be appropriate to use in an
organic facility. This is an effort to create that list for customers of Univar USA, with respect to products for use in
professional pest management.
This is a very difficult topic. While the “guidelines” are established by government agencies to define what may be
permissible in organic facilities, these agencies may shy away from creating lists of specific active ingredients, and
even more so from naming specific product trade names.
There also is a trend toward establishing “Green” buildings and facilities, which brand themselves as environmentally
concerned with this designation. This also can be difficult with respect to recommending specific pest control products,
and the term “green” seems to be defined in varying ways by various entities.
DO NOT CONFUSE “GREEN” WITH “ORGANIC” !
DO NOT CONFUSE “NATURAL” WITH “ORGANIC” !
There are very specific al owances and prohibitions with respect to organic pest management, whereas green and
natural are much more subjective.

The Agencies That Regulate / Oversee Organic Facilities & Production:

The EPA – CFR Title 40 – Protection of the Environment – via the federal EPA OMRI – the Organic Materials Review Institute NOP – the National Organic Programs CFR Title 40 – EPA and Protection of the Environment:
The Code of Federal Regulations (CFR), Title 40, Subchapter E – deals with “Pesticide Programs” in Parts 150 to 189.
Within these regulations Part 152 deals with “Pesticide Registration and Classification Procedures”, and section
152.25 is entitled “Exemptions for pesticides of a character not requiring FIFRA regulation”. Many of these products
are now found sold as pesticide active ingredients, most botanical in origin, and thus do not require EPA Registration.
A list of Exempt products wil be found on Page 4 of this document.
40 CFR 152.25 – also provides an extensive list of “inert” ingredients that may be in pesticide formulations that are
allowed as “exempt” materials. Those considered Exempt must be listed in the most current List 4A. Some inert
ingredients of interest will be discussed on page 5 of this document.

The OMRI:

The Organic Materials Review Institute – OMRI – a private organization which reviews products and trade names and
determines whether or not they are NOP compliant.
Their website – www.omri.org – provides some lists of trade names of pesticides approved for organic use. Their
complete listing of trade names can be found at http://www.omri.org/OMRI_products_list.html .
Please Note – OMRI is a private organization. Pesticide products may be appropriate for use in Organic facilities
without being listed on the OMRI list.
The OMRI applies codes to the products they list:
A = Allowed – indicates no restrictions on the use of the product R = Restricted – indicates certain use restrictions exist in order to be in compliance with NOP standards. The R status is assigned to the generic ingredient and thus pertains to each trade name product. N = Not Al owed – a designation that may be used on other lists, such as state lists, but does not exist on the OMRI lists. The OMRI only lists products that are allowed, and products NOT allowed simply do not show.
The NOP:
NOP = National Organic Programs compliant – the NOP is affiliated with the USDA (United States Department of
Agriculture), and lists the standards that must be met to be organic-approved. It lists basic ingredients that may or may
not be included in organic products.
Guidelines for the NOP are in The Act – the Organic Foods Production Act of 1990. The ful text of their regulations in
The Act can be found on the internet at http://www.ams.usda.gov/nop/NOP/standards/FullRegTextOnly.html . This text
begins with extensive definitions, and for the sake of simplifying this resource on PestWeb we wil include only a few
terms which are important to pest management. The definitions are not word for word, but are summaries of those
found in The Act.
Buffer zone – an area located between an organic operation and adjacent non-organic operations, sufficient
to prevent the possibility of unintended contact of prohibited substances from the non-organic operation onto the organic lands. Co-mingling – physical contact between unpackaged organic and non-organic products during production,
processing, storage, transportation, or handling. Feed – edible materials consumed by livestock for their nutritional value.
Fertilizer – a single or blended substance containing one or more recognized plant nutrients.
Handling Operation – any operation that receives or otherwise acquires agricultural products, and
processes, packages, or stores such products. Inert Ingredient – any substance other than the active ingredient which is included in any pesticide product.
National List – a list of allowed and prohibited substances as provided for in The Act.
Natural / Non-synthetic – synonymous terms meaning a substance derived from mineral, plant, or animal
matter that does not undergo any synthetic process. Non-toxic – not known to cause any adverse physiological effects in animals, plants, humans, or the
Organic – refers to an agricultural product produced in accordance with The Act and its regulations.
Organic Matter – the remains, waste products, or residues of any organism.
Pesticide – any substance which alone, in chemical combination, or in any formulation with one or more
substances is defined as a “pesticide” by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). o FIFRA definition – “Any substance or mixture of substances intended for preventing, destroying,
o It includes insecticides, herbicides, fungicides, rodenticides, anti-microbials, as wel as growth Processing – cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting,
slaughtering, cutting, fermenting, distil ing, eviscerating, preserving, dehydrating, freezing, chil ing, or otherwise manufacturing – and includes the packaging, canning, jarring, or otherwise enclosing food in a container. State Organic Program – a state program that meets the requirements of the NOP or may be more
restrictive, subject to approval by USDA. Synthetic – a substance that is manufactured by a process that chemically changes a substance extracted
from natural y occurring plant, animal, or mineral sources, except for substances created by natural y occurring biological processes.
What must be Certified? –
Each operation that produces or handles crops, livestock, or other agricultural products that wil be sold or represented as “100% organic”, “organic”, or “made with organic ingredients”.
Exempt from Certification? –
Any retail food establishment that handles or sel s organic products, but which does not process them.
Organic Production includes the use of “Cultural Practices”, including mechanical and physical methods of pest
management, including:
Use of predators and parasites Non-synthetic controls such as lures, traps, and repel ents. Weed control using mowing, mulching, flame or heat. Plant disease control using non-synthetic biological, botanical, or mineral substances.
Facility Pest Management standards – the organic operation MUST use practices such as:
Removal of pest habitats, food sources, and breeding areas. Exclusion to prevent access to the operations and handling areas. Management of cultural factors, such as temperature, lighting, humidity, air circulation, to prevent the pest o Mechanical or physical controls – traps, light, sound o Lures and repellents with substances consistent with The National List o A pesticide consistent with The National List only if the other non-chemical steps are not effective or
The National List of Allowed and Prohibited Substances:

Pesticide Active Ingredients exempt from EPA Registration under 40 CFR – 152.25 “Minimum Risk Pesticides”.
Castor Oil

Synthetic substances specifically allowed as organic:

Synthetic substances may be permissible for organic production IF they have been evaluated using the criteria set
forth in The Act. Those synthetic substances specifically allowed in organic crop production, under certain guidelines,
are:
As algaecides, disinfectants, or sanitizers – o alcohols such as ethanol and isopropanol o chlorine materials o copper sulfate – with restrictions o soap-based algaecides and de-mossing agents o Soap-based agents o Mulch or coverings – paper, without glossy or colored ink o Plastic sheeting or mulch o Soaps or ammonia – no soil contact, no contact with edible parts of crops As insect or other arthropod control – o Ammonium carbonate – only as a bait in insect traps, no soil or crop contact o Boric acid – for structural pest control – no direct contact with organic crops/foods o Copper sulfate – tadpole shrimp control in rice production only o Elemental sulfur and lime sulfur o Horticultural oils – dormant and summer oils, suffocating oils o Insecticidal soaps o Sticky traps and barriers o Sulfur dioxide – underground rodent control only – smoke bombs o Vitamin D3 As mol usk control – slugs and snails – o Listed as “no options/none” o Sluggo? – iron phosphate? As plant disease / pathogen control – o Fixed coppers – copper hydroxide, copper oxide, copper oxychloride, and those EPA-exempted for o Copper sulfate – minimizing soil contact o Hydrated lime, lime sulfur o Horticultural oils – dormant, summer, suffocating oils o Potassium bicarbonate o Elemental sulfur o Streptomycin and Tetracycline – for fire blight control For use in livestock production – synthetic products - o Ivermectin – emergency treatments for parasites when approved methods are not otherwise o Copper sulfate – topical treatment for parasites The “inert” ingredients in pesticide formulations are a major concern. EPA has created 4 Lists of synthetic inert
ingredients for use with non-synthetic substances/ingredients –
o EPA List 4 – “Inerts of Minimal Concern” o EPA List 3 – Inerts of Unknown Toxicity  Piperonyl butoxide – the most common additive/synergist in pyrethrum products is on List o EPA List 2 – potentially toxic inerts, with a high priority for testing o EPA List 1 – inert ingredients of toxicological concern o EPA Lists of Inert Ingredients can be found on the internet at http://www.epa.gov/opprd001/inerts/lists.html
Natural substances that are specifically prohibited:

Some Natural / Non-synthetic substances are specifically prohibited for use in organic production –
Arsenic Calcium chloride – one exception Strychnine Nicotine sulfate – tobacco dust Diatomaceous Earth – allowed for use only as a food filtering aid for direct contact with organic foods. Pest Management in an Organic Facility – or, the basic steps you need to know:

The Organic facility must have in place a FPMS – Facility Pest Management Standard – that the pest management
company should be involved in developing. This FPMS is part of their overal Organic Handling System Plan, and any
facility claiming to be organic wil be inspected periodical y by an Organic Certifying Agent from one of several
organizations that they contract with.
Guidelines for the PMP:
Every recommendation you make must be in WRITING IPM is MANDATORY, meaning the PMP is required to perform pest management in this order: o Inspection – to determine al the contributing conditions that make the facility “friendly” to any pest, o Sanitation o Exclusion o Physical controls – lighting, storage, moisture control, traps, vacuum, steam, heat o Use of NOP listed pesticides – this is al owed ONLY if the non-chemical steps failed to control the o Use of NON-listed pesticides – allowed ONLY if the non-chemical steps and the listed pesticides did For “Split Operations” where part of the facility is Organic and part is not – the PMP must document exactly the steps taken to ensure the Organic area has not been exposed to pesticides. o Example – exterior rodent baiting to maintain the bait on the exterior o Example – a grocery store with a separated Organic Produce section o The PMP must document in detail exactly what was applied, where it was applied, and the steps taken to ensure no cross contamination with the organic area of that facility
Proposed list of pesticides and pest management products that may be appropriate in
Organic facilities:

Based on the various qualifying criteria above, fol owing is a growing and evolving list of products sold by Univar USA.
DO NOT consider this to be absolute fact, but use your own judgment as well before recommending a product to a
customer.
Specifically PROHIBITED substances of interest:

Isopropyl alcohol – (Ethanol and Methanol are permitted)
Moth balls and Moth crystals – naphthalene and para-dichlorobenzene (PDB)
Methyl bromide
Nicotine – a botanical, due to high toxicity
Petroleum solvents – considered health hazards
Piperonyl butoxide – most common synergist in pyrethrin products – originally a plant-derived product, but it
goes through significant molecular changes in extraction and processing. Synthetic pyrethroids – prohibited as a group Sulfur dioxide – cannot be used as a fumigant Anti-coagulant rodent baits – all are prohibited, whether or not in bait stations

Approved Products:

Biological products – micro-organisms – cannot be genetically engineered organisms:
Bacil us thuringiensis – B.t. and B.t.i. – only when used without synthetic additives or inert ingredients o Dipel o Teknar o Mosquito Dunks, Mosquito Bits o Gnatrol – liquid and WDG o Vectobac Bacil us sphaericus – byproduct of fermentation of a soil bacterium Steinernema carpocapsae – nematodes for insect larva control
Biological cleaners for fly breeding site reduction and other surface cleaners:
DrainGel and DrainGel IBD – bacteria based drain cleaner DrainFoam – microbe-based cleaner for drains, corners, crevices Micro-Foam – microbe-based, but specific ingredients not disclosed Bio-Gel – bacteria-based for drains and general surfaces Bio-Mop – bacteria based surface cleaner DrainForce – bacteria based drain cleaner DF-5000 – bacteria and enzyme based drain cleaner Clean Kil – Ionic silver plus citric acid – surface cleaner and disinfectant Invade Bio Drain – microbe-based drain cleaner – gel formula Invade Bio-Cleaner – microbial formulation with citrus oil for surface cleaning Invade Bio Remediation – microbe based for waste digestion and citrus oil for odor control – concentrated Invade Bio Zap – microbe based for waste digestion and citrus oil for odor control Invade Bio Foam – microbe based for waste digestion and citrus oil for odor control – liquid formulation Invade Bio Foam Hot Spot – microbe based for waste digestion and citrus oil for odor control – aerosol
Rodent and other Vertebrate Control:
o Detex blox – non-toxic food grade – monitoring only o Rode-trol – Corn Oil Concentrate o Quintox – cholecalciferol – calcium derivative o Terad3 / Terad3 AG Blox – cholecalciferol Glue traps for rodents and insects – all glue products without other pesticide additives are okay Repel ents – must be derived from a natural source without synthetic additives Mole Out Granules, Whole Control – Castor oil Mole Med Repellent – Castor oil Dr T’s Deer / Rabbit repel ent – putrescent whole egg solids / mint / garlic oil Defence Granules for dogs / cats – natural essential oils Mosquito and Gnat Repel ing Granules – natural essential oils Snake-Out Snake Repel ent – combines oils of cinnamon, clove, and cedar – inert ingredients of sulfur, water, and Ful er’s Earth (see description below for Ful er’s Earth) Rat-Out Rodent Repel ent – contains Garlic Oil, White Pepper, White Mineral Oil, Silicon Dioxide Detour For Rodents – contains Garlic Oil, White Pepper, White Mineral Oil Detour Roadblocks – contains White Oil, Fumed Silica, White Pepper Chase Granular Mole Repel ent – castor oil on ground corn cob Chase Liquid Mole Repel ent – contains castor oil, sodium lauryl sulfate Critter Ridder repel ents – Oil of Black Pepper, Piperine (from Oleoresin of Black Pepper), Capsaicin and related Capsaicinoids (from Oleoresin of Capsaicum) – OMRI listed per manufacturer Deer Scram Professional – blood meal, garlic, red pepper, cloves
Mole Scram Professional – castor oil, citronel a oil, garlic oil
Rabbit Scram Professional – dried blood, white pepper, garlic, cloves, meat meal
Iguana Rid – sodium lauryl sulfate, garlic oil, cinnamon oil
Mosquito Barrier – garlic juice with citric acid, potassium sorbate – EPA Exempt

Botanicals:
 Mosquito Barrier – garlic juice with citric acid, potassium sorbate – EPA Exempt
o Victor Poison Free Ant & Roach aerosol o Victor Poison Free Flying Insect Kil er o Dust  EcoPCO D-X – hexa-hydroxyl + pyrethrins  EcoExempt D – hexa-hydroxyl + clove oil  TechDust (TyraTech) – thyme oil + calcium silicate, calcium carbonate, sodium  EcoExempt G – clove oil + thyme oil  Essentria Granular – eugenol + thyme oil – 25(b) exempt
 EcoExempt IC2 – hexa-hydroxyl + rosemary oil + peppermint oil  EcoExempt IC – hexa-hydroxyl + rosemary oil  EcoExempt MC – a.i. is oils of rosemary, cinnamon, lemongrass Inerts are wintergreen oil, isopropyl myristate, lecithin  EcoPCO EC – NOT NOP-compliant – contains PBO synergist
 TyraTech Naturals Crawling Insect Spray – thyme oil with other inerts
 Essentria IC3 – Envincio (replaces EcoExempt IC-2) – rosemary oil, geraniol, peppermint  Essentria Broadcast Insecticide – Envincio – hexahyroxyl, rosemary oil, peppermint oil – EPA Exempt
 Essentria Bed Bug Repel ent Travel – Envincio – hexahydroxyl, geraniol, rosemary oil, peppermint oil – EPA Exempt
 Essentria General Household Insect Spray – Envincio – geraniol, rosemary oil, peppermint oil – EPA Exempt
 EcoPCO AR-X - hexa-hydroxyl + pyrethrins  EcoExempt Jet Wasp & Hornet – hexa-hydroxyl + rosemary oil  ExoPCO Jet-X Wasp & Hornet – NOT NOP-compliant – contains PBO synergist
 EcoExempt KO – hexa-hydroxyl + clove oil
 Bioganic Flying Insect Kil er – eugenol (clove oil) + sesame oil  Bioganic Crawling Insect Kil er – rosemary oil  Topia Insecticide – Geraniol / Cedar Oil / Sodium lauryl sulphate – FMC  ExoExempt HC – hexa-hydroxyl + clove oil Pyrethrums – without synergists – piperonyl butoxide is a prohibited substance Evergreen Pyrethrum Concentrate (= Pyganic Pro) – with restrictions R MotherEarth 2% Py Contact – pyrethrum only with no PBO Evergreen Pyrethrum Dust (= Pyganic dust) – 1% pyrethrins only with no PBO Azadirachtin – also called Neem oil – from seed kernels of Neem Fruit Tree – acts as an IGR o Azatrol EC – o Ecozin Plus 1.2% ME – Amvac Sesame Oil – Organocide – combination of sesame oil + fish oil Soybean and vegetable oils – Natur’l Oil – Stol er o A wide range of retail products from CedarCide Industries o Topia Insecticide – aerosol – Cedar Oil / Geraniol / Sodium Lauryl Sulphate o Topia Insecticide – aerosol – Cedar Oil / Geraniol / Sodium Lauryl Sulphate Pro-citra DL – with restrictions R- contains petroleum distil ates MotherEarth ProCitra-DL – with restrictions R- contains petroleum distil ates Orange Guard – with restrictions R Orange Guard Ornamental Plants Concentrate Power Plant XT-2000 MotherEarth Wasp/Hornet Jet Spray o EcoExempt MC – a.i. is oils of rosemary, cinnamon, lemongrass Sabadil a – from ground seeds of sabadil a lily – stomach poison Rotenone – from roots of tropical legumes – inhibits cellular processes, depriving insects of oxygen in cell Strychnine – allowed for rodent control only. Must not be left on ground surface. o Wilco Gopher Getter Type 1 Bait o Wilco Gopher Getter Bait AG
Soap – insecticidal soap = sodium/potassium salts + fatty acid

Inorganic products – “mined products” shal not have been heated to change molecular structure, nor combined with
any synthetic or other prohibited substances:
Boric Acid / Orthoboric Acid – cannot be used in direct contact with food or in soils  Borid and Borid Turbo – Waterbury  Nibor and Boracide – Nisus (Boracide discontinued 2011)  Boric Acid Dust – Eaton  BorActin Insecticide Powder – Rockwel Labs  Armor Guard  Victor Roach Powder – Victor Woodstream  Borid Turbo – Waterbury  Perma-dust – Whitmire-Microgen  Terro PCO  Drax Gel – Waterbury  Niban Granular – Nisus  Niban FG granules – Nisus  Intice Ant Granules – Rockwel Labs  Intice Sweet Ant Gel – Rockwel Labs  Intice Perimeter Bait – Rockwel Labs  Intice Granular Bait – Rockwel Labs  Intice Roach Bait – Rockwel Labs  Green Zone Granular Bait – Rockwel Labs  Green Dragon Roach Bait – Green Dragon Pest Solutions Disodium Octaborate Tetrahydrate / Sodium Tetraborate Decahydrate (Borax):  Gourmet Ant Bait – liquid or gel  Uncle Albert’s Super Smart Ant Bait – gel  Intice Ant Bait – Rockwel Labs  Intice Ant Gel – Rockwel Labs  Intice Gelanimo Ant Bait – Rockwel Labs  Intice Rover Ant Bait – Rockwel Labs  Bora-Care  Borrada LP  BoraSol Liquid  Jecta Diffusible Boracide – gel in syringe o Dry Formula Concentrates and solid forms: Ful er’s Earth – inert ingredient listed on EPA List 4A – “Minimal Risk Inerts” – this is clay, combining alumina + silica + iron oxides + lime + magnesia Silica gel / silicon dioxide / amorphous silica dioxide: o Drione and Tri-Die not al owed – they contain Piperonyl Butoxide which is prohibited
o Diatect II - NOT NOP-compliant – contains PBO synergist
o Diatect III – NOT NOP-compliant – contains PBO synergist
o Diatect V – silicon dioxide + pyrethrins – with R restrictions
o NIC Pro dust – 1 and 10 lb containers Diatomaceous earth – non-heated forms only, without synthetic additives  MotherEarth D – WMMG – freshwater-derived – 100% DE  Eaton Kil s Bedbugs Powder – 85% DE, 10% other oxides, 5% “moisture”  Insecto – saltwater-derived – with R restrictions  Concern DE – Woodstream Corp. – 85% DE, 10% other oxides, 5% “moisture” o MotherEarth Exempt Granules – 25 lb – freshwater derived DE o MotherEarth Granular Bait – 4 lb and 40 lb – freshwater derived DE Potassium bicarbonate (= baking soda) – used as fungicide on ornamentals, often combined with oils - may create conditions fungi cannot survive on Copper products – includes Fixed Copper, Copper Sulfate, Copper Hydroxide – generally grouped as o Copper Count-M – metal ic copper o Copper Sulfate – copper sulfate pentahydrate o Kocide DF – fixed coppers o Kocide 2000 – fixed coppers Iron sulfate, Zinc sulfate – used as fertilizers or soil amendments Petroleum Oil derivatives - Horticultural oils – smothering effect – may be either synthetic or natural – o Mosquito Larvacide Oil – mineral oil o Saf-T-Side Spray Oil – petroleum oil – OMRI listed o Loveland 415 Oil – mineral oil o Purespray Green (WMMG) – paraffinic oils – OMRI Certified o Damoil Dormant & Summer Spray Oil – petroleum oil
Odor Control:

Growth Regulators
Prohibited – any synthetic products such as IBA and NAA Allowed: o natural growth regulators such as IAA o insect juvenile hormones – recommend natural y derived, but synthetic mimics okay  methoprene – Altosid, Precor IGR, Extinguish Pro Fire Ant Bait  hydroprene – Gentrol aerosol, IGR Concentrate, and Point Source  Nylar (Pyriproxyfen) – Archer, Pyri-Shield EC, IG Regulator, Nyguard IGR, Distance IGR
Insect Monitoring:
Insect pheromones are permitted for use in monitoring traps Mating Disrupters – these make the label statement that they “Control” the insect pests, and therefore must o Allure MD – for Indian Meal Moth – BASF/WMMG o CideTrak IMM Mating Disrupter – Trece

Source: http://pestweb.ca/assets/files/pestweb/businesstools/OrganicPesticides.pdf