Organic Processing and the Use of Pesticides
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While technically cannabis cannot be registered as an organic product, that should not deter a grower from using the organic management practices provided by our current agricultural and regulatory framework. Below is a synopsis of the codes and definitions of some of the organic protocol. Regardless of the information presented, it is up to the individual to follow all applicable local and state guidelines.
Overview by UNIVAR USA:
With many commercial and private operations in the United States interested in producing or processing “organic” quality cannabis, there is increased interest in having a list of pesticides available that would be appropriate to use in an organic facility. This is page is an effort to provide definitions and create a framework 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.
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.
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 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 Allowed – 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.
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 full 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 will 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).
FIFRA definition – “Any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest”. It includes insecticides, herbicides, fungicides, rodenticides, anti-microbials, as well as growth regulators, defoliants, and desiccants.
Processing – cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, freezing, chilling, 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 naturally occurring plant, animal, or mineral sources, except for substances created by naturally occurring biological processes.
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 repellents.
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
Control of the pest with:
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 sufficient
The National List of Allowed Substances: (Partial List)
Below is a list of Pesticide Active Ingredients exempt from EPA Registration under 40 CFR – 152.25 “Minimum Risk Pesticides”. This may be an incomplete list.
Castor Oil • Cedar Oil • Cinnamon and Cinnamon Oil • Citric Acid • Citronella and Citronella oil • Cloves and Clove Oil • Corn Gluten Meal • Corn Oil • Cottonseed Oil • Dried Blood • Eugenol (= clove oil) • Garlic and Garlic Oil • Geraniol • Geranium Oil • Lauryl sulfate • Lemongrass Oil • Linseed Oil • Malic Acid • Mint and Mint Oil • Peppermint and Peppermint Oil • 2-phenethyl propionate • Potassium sorbate • Putrescent whole egg solids • Rosemary and Rosemary oil • Sesame and Sesame oil • Sodium chloride (salt) • Sodium lauryl sulfate • Soybean oil • Thyme and Thyme oil • White pepper