Organic pesticide input approval: National List, product label and certifier

Organic pesticide input approval: National List, label and certifier

Organic farming pesticides pass two separate checks. The product label is legally enforceable and carries the statement "It is a violation of Federal law to use this product in a manner inconsistent with its labeling." Separately, all substances used on organic operations must be approved by the operation's certifying agent before use. The organic system plan lists each substance used as a production input with its composition, source, the location where it will be used and documentation of commercial availability, as applicable. Before you buy anything, send the certifier the full product details and the intended use, and wait for the answer.

Use the crop sections of the National List

The National List has three scopes: crop, livestock and handling. In organic crop production, nonsynthetic (natural) substances are allowed unless specifically prohibited and synthetic substances are prohibited unless specifically allowed (§§ 205.601-205.602). Some entries carry annotations, which are specific requirements for how an organic operation must use the substance; annotated substances are commonly called "restricted" rather than "allowed".

Substances allowed by § 205.601 may only be used when the prevention, mechanical and cultural provisions of § 205.206(a) through (d) prove insufficient to prevent or control the target pest. The exceptions are disinfectants and sanitizers, compost feedstocks, crop or soil amendments, plant growth regulators, floating agents in postharvest handling and production aids.

Check pesticide directions as a separate step

Pesticide labeling specifies where, how, how much and how often a product is used. For the exact product, check the crop section, the rates, the tank-mix directions and the application method on its label; the label guide shows how to read each section.

Connect the proposed use to the correct annotation

Section 205.601 lists allowed synthetic substances by function: algicides, disinfectants and sanitizers, herbicides and weed barriers, insecticides, crop disease control, and crop or soil amendments, among others. Read the whole entry for your use, not just the chemical name you recognize, and check the crop-system limits, the prohibited functions and the deficiency-documentation conditions that go with it.

Copper sulfate (copper sulphate) in organic farming appears under several functions with different conditions. As an algicide in aquatic rice systems it is limited to one application per field during any 24-month period. As tadpole shrimp control in aquatic rice production it carries the same one-application limit. As crop disease control the condition is that the "Substance must be used in a manner that minimizes accumulation of copper in the soil." Fixed coppers (copper hydroxide, copper oxide, copper oxychloride) are listed separately for crop disease control and "shall not be used as herbicides".

For nutrient inputs, magnesium sulfate is "allowed with a documented soil deficiency." Micronutrients may not be used as a defoliant, herbicide or desiccant, those made from nitrates or chlorides are not allowed, and the deficiency must be documented by soil or tissue testing or another documented and verifiable method approved by the certifying agent. Ask the certifier to evaluate your actual material under the entry that matches its purpose; do not assume every sulfate shares one approval condition.

Preventive management comes before any substance

The producer must use management practices to prevent crop pests, weeds and diseases, including crop rotation and soil and crop nutrient management, sanitation measures to remove disease vectors, weed seeds and habitat for pest organisms, and cultural practices that enhance crop health, such as choosing species and varieties suited to the site and resistant to prevalent pests.

Pest problems may be controlled through mechanical or physical methods, including introduced predators or parasites, habitat for natural enemies, and nonsynthetic lures, traps and repellents. Weed problems may be controlled by mulching with fully biodegradable materials, mowing, livestock grazing, hand weeding and mechanical cultivation, or flame, heat or electrical means; plastic or other synthetic mulches are allowed if removed from the field at the end of the growing or harvest season. Disease problems may be controlled by practices that suppress the spread of disease organisms or by nonsynthetic biological, botanical or mineral inputs.

When those practices are insufficient, a biological or botanical substance or a substance on the National List of allowed synthetic substances may be applied, provided the conditions for using the substance are documented in the organic system plan.

How the National List changes and what the Petitioned Substances Index shows

Changes to the National List occur through rulemaking by the National Organic Program in response to a National Organic Standards Board recommendation on a petition, sunset review or other recommendation. The Petitioned Substances Index lists all substances that have been considered for addition, both those added and those that were not, and is non-exhaustive and for reference use only. A substance that appears in the index is not necessarily allowed, so check the current regulation for your material and use.

Insecticides for organic farming: how to check that a pesticide is approved

The National List names allowed substances and their annotations; approval for a specific operation comes from its certifying agent before use. A supplier's list of products "approved for organic farming" is not the certifier's approval. Keep the certifier's answer and any limitations with the input record.

Approved pesticides for organic farms, organic farmers' pesticides and bio pesticides

Approved pesticides for organic farms are the substances named on the National List with the annotation your use needs, and the certifier confirms the product. Organic farmers use pesticides of that kind: for example, in UC IPM's guidance on thrips in nurseries, botanicals including pyrethrins without piperonyl butoxide are acceptable for organic production. Pyrethrin for organic farming is therefore a National List and certifier question for your product, not a general permission. Bio pesticides in organic farming follow the same rule: biopesticides are pesticides derived from natural materials such as animals, plants, bacteria and certain minerals, and each product still needs the certifier's approval.

Chemical fertilizers and pesticides used in agriculture

A product sold as organic must be produced without synthetic substances, except as provided in § 205.601 (or § 205.603 for livestock), and without nonsynthetic substances prohibited in § 205.602. Among the prohibited nonsynthetics, sodium nitrate is barred unless its use is restricted to no more than 20% of the crop's total nitrogen requirement. The producer must not use any fertilizer or composted plant and animal material that contains a synthetic substance not on the list of allowed synthetic substances. For each fertilizer or pesticide, record the actual product and its function, the National List entry and annotation, and the certifier's decision. Check the ingredients of a purchased compost or amendment against the National List before you accept it.

Regenerative organic agriculture

Regenerative Organic Certified product intended for processing must maintain and demonstrate current certification to USDA/NOP Organic (or an approved international equivalent). If a supplier or buyer calls a program "regenerative organic", ask which published standard, certifier and scope it means.

Organic agriculture: farm conversion and production planning

Organic agriculture in the United States follows the USDA organic regulations. The path to certification has five steps: the applicant adopts organic practices, selects a USDA-accredited certifying agent and submits an application and fees; the certifying agent reviews the application to verify that practices comply; an inspector conducts an on-site inspection; the certifying agent reviews the application and the inspector's report; the certifying agent issues the organic certificate.

Choose the certifier early and ask which current application package fits your scope before you copy information into a form.

Certification costs

Certification costs may range from a few hundred to several thousand dollars. Typically there is an application fee, an annual renewal fee, an assessment on annual production or sales, and inspection fees.

Land history of each parcel

Under 7 CFR 205.202, land producing crops represented as organic must have had no prohibited substances applied during the 3 years immediately preceding harvest of the crop.

Annual renewal: fees, plan update and inspection

Organic certification continues through an annual review and inspection process. To continue certification, the operation annually pays the certification fees and submits to the certifying agent a summary of changes made to the organic system plan during the previous year and any additions or deletions planned for the coming year. The certifying agent must conduct an on-site inspection at least once per calendar year. Name one person who answers the certifier and prepares the yearly update; the first certificate is not the end of the work.

The organic system plan

An operation intending to sell products as organic must develop an organic system plan agreed to with an accredited certifying agent. The plan must include:

The Common OSP is optional. Describe how your farm actually works, including how often each practice is done, and ask the certifier to review your boundary and shared-equipment arrangements.

Fertility through the whole rotation

The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical and biological condition of soil and minimize soil erosion, and must manage crop nutrients and soil fertility through rotations, cover crops and the application of plant and animal materials.

Manure and compost intervals

Raw animal manure must be composted unless it is applied to land used for a crop not intended for human consumption, or incorporated into the soil at least 120 days before harvest when the edible portion has direct contact with the soil surface or soil particles, or at least 90 days before harvest when it does not.

Composted plant and animal materials must be produced through a process that established an initial C:N ratio between 25:1 and 40:1 and maintained 131-170 °F for 3 days in an in-vessel or static aerated pile system, or for 15 days in a windrow system with the materials turned at least five times.

Sewage sludge (biosolids) may not be used. Burning as a means of disposal for crop residues is prohibited, except to suppress the spread of disease or stimulate seed germination.

Seed and planting stock exceptions

The producer must use organically grown seeds, annual seedlings and planting stock, with these exceptions:

• Nonorganic untreated seeds and planting stock when an equivalent organically produced variety is not commercially available; organic seed must be used for edible sprouts.
• Nonorganic seeds and planting stock treated with a substance on the National List of allowed synthetic substances, when an equivalent organically produced or untreated variety is not commercially available.
• Nonorganic annual seedlings when a temporary variance has been granted.
• Nonorganic planting stock for a perennial crop, which may be sold as organic only after one year under organic management.
• Seeds, seedlings and planting stock treated with prohibited substances when a Federal or State phytosanitary regulation requires the treatment.

Check which exception applies before you order. An out-of-stock answer from a supplier does not by itself permit every nonorganic or treated substitute; keep the evidence that no equivalent organic variety was available.

Prepare the input-approval request

Start with the complete commercial formulation, not a generic ingredient. Send the certifier the product name, manufacturer, current container label, ingredient information and the intended crop or site, and name any adjuvants separately. Say what the input is for (fertility, crop disease, insect control, sanitation or something else), because one substance can have different annotations for different uses.

For a crop-protection request, describe the actual target and what you have done or plan to do first. Say whether it is a verified infestation, a diagnosed disease or a preventive concern, and give the field or crop context rather than a generic line that the farm practices IPM.

Next step

The certifier receives the input list in the organic system plan and its yearly updates. Current substances and annotations are on the National List page; the plan requirements are on the organic system plan page. For prevention measures see nonchemical crop protection.