Pesticides are regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA defines a pesticide as any substance or mixture of substances intended to prevent, destroy, control, repel, or mitigate any pest. That’s ANY substance and ANY pest, whether it’s an insect, weed, rodent, snail, slug, fungus, or plant-pathogenic bacteria or virus. This means that any product used to manage any pest problem IS A PESTICIDE. All pesticides, including those approved for organic production, must be used in compliance with all federal, state, and local pesticide laws.
The NOP maintains a national list of approved and prohibited materials, including pesticides, for organic production. The NOP offers further information on their website (About the National List). Because NOP materials lists can be cumbersome and difficult to navigate, you may find that specific, brand-name lists are more useful. Two organizations that maintain specific lists are the Organic Materials Review Institute (OMRI) and the Washington State Department of Agriculture (WSDA). WSDA is an approved certifying agent for the NOP; therefore, the WSDA list is applicable throughout the United States, not just in Washington. The entire pesticide formulation (active and inert ingredients) must meet organic standards. Even though the active (pesticide) ingredient may be allowed for organic production, some products and some formulations containing that active ingredient may not be allowed. If a product is not listed by OMRI or WSDA, the grower or certifier must have a disclosure from the manufacturer that all ingredients, including the inerts, meet NOP requirements.
The Environmental Protection Agency (EPA) also reviews registered pesticides for NOP compliance if requested by the pesticide registrant. Pesticides approved for organic use by the EPA will have the EPA’s three-leaf organic emblem and the words “for organic production” or “for organic gardening” on the label.
However, not all NOP-approved products will have a label with a statement indicating that they can be used in organic production.
In general, synthetic substances are prohibited in organic production and non-synthetic (natural) materials are allowed. Synthetic substances are prohibited for use in organic production unless they are specifically approved on the national list. For example, acetic acid (vinegar) is a synthetic material that has been approved for certain uses in organic production. Sulfur is an allowed synthetic: much of it is produced from a chemical reaction in the scrubbers on the smokestacks of petroleum and natural gas refineries. Sulfur and copper are the first- and second-most-applied fungicides on organic farms, with 40% and 34% of responding farmers reporting their use, respectively. Sulfur and copper are important fungicides in conventional production as well. Another example of a manufactured product approved for organic use is spinosad which comes from the soil bacterium, Saccharopolyspora spinosa. Natural substances can be used in organic production unless they are specifically prohibited on the national list. Nicotine is a natural material that is prohibited due to its toxicity to humans. The national list may also place restrictions on the use of approved materials. There may also be specific conditions of use, depending on the substance, crop, pest, etc., specific conditions of manufacture, and expiration dates. For example:
- copper-containing products must be used in a way that does not allow soil accumulation
- the antibiotics streptomycin and tetracycline are only allowed for fire blight control
- passive pheromone dispensers are permitted to use inert ingredients of unknown toxicity because they are mostly not in contact with the edible portions of crops.
Obtaining organic approval for pesticides
Not all available pesticide products have been assessed for their compliance with organic standards. You may choose to use products for pest management that have not been previously approved for organic use. If you choose to use an unapproved material, you assume the burden of proof for that material’s organic suitability. You risk losing organic certification if the material does not comply with the requirements of the NOP per your certifying agent. OMRI and WSDA, as well as some other NOP-approved certifying agencies, provide services to evaluate the suitability of materials for organic use.
A short note about biopesticides and 25(b) products
Biopesticides, or biological pesticides, are derived from natural materials, such as plants, animals, microorganisms, or certain minerals. Because they are natural in origin, many are approved for use in organic production. Plant-incorporated protectants (PIPs) are the result of genetic modification of plants (or animals). PIPs are classified as biopesticides; however, they are NOT acceptable for use in organic farming. If you are unsure if a product is acceptable for organic use, contact your NOP certifier for assistance.
FIFRA Section 25(b)
Other materials commonly used for organic pest management are minimum-risk pesticides. While they are still pesticides, these materials are exempt from federal registration under FIFRA’s Section 25(b) rule because they pose a minimal risk to the user, the crop, and the environment (all other pesticide laws still apply). These products can be used on any labeled crop for any target pest. However, because of their special status, there may not be a traditional, or full-length, pesticide label. To qualify as a 25(b) material, ALL ACTIVE AND INERT ingredients must meet the risk requirements set forth in FIFRA. Visit the EPA website for more information about Section 25(b)’s allowed inert and active ingredients. Not all 25(b) materials are approved for organic production.
Please note that 25(b) products MAY BE registered as pesticides in your state even though they are exempt from EPA registration requirements. Even though they are considered minimum risk products,you must use appropriate personal protection and read and follow all label instructions when handling or applying 25(b) materials. Contact your state Department of Agriculture or local Extension office if you have questions. Keep in mind that 25(b) products must still be reported as part of the requirements of organic certification, and they should also be recorded as pesticide applications per your state laws.
Initial compilation courtesy of Lenora Jones