Pest Management Professional, September 2010

Inspection monitoring sanitation and structural repair play large roles in organic food plant pest management Pesticide Use Having used the necessary nonchemical methods or having asked your client to make the nonchemical improvements thatll make their facility less attractive to pests assess whether this has taken care of the situation or whether itll be necessary to use a pesticide If not youre cleared to use a pest control material In a written logbook entry document that you tried nonchemical control measures and that they werent sufficient to take care of the problem Decide on a pesticide thatll take care of the problem There are two schools of thought about whether you should choose a so called National List pesticide boric acid horticultural oils and the rest or whether you can go right to a non National List material It has to do with how the organic certifying agency that audits your clients practices defines National List Depending on the clients organic certifying agency school of thought they may prefer a boric acid based material nonsynergized pyrethrins or some other material consistent with the National List before using a material not named on the National List or they may acknowledge because there are no National List materials approved for use in food processing facilities its OK to proceed directly to use of non National List materials If your clients organic certifying agent considers boric acid Vitamin D3 cholecalciferol rodenticides nonsynergized pyrethrins horticultural oils and pheromones to be among the National List materials then you have to look for a material of this type to try before you can use something not named on the National List If your clients organic certifying agent subscribes to the stricter view there arent any National List materials that can be used as pest control materials inside of a food processing or packaging plant then you can apply any material approved for use in food plants according to label directions for food areas If you try a National List material and find neither nonchemical methods nor the use of a National List material was able to prevent or eliminate pests youre clear to apply a material not named on the National List The simplest way to summarize the rules for pesticide use in organic plants is Try nonchemical methods first and document in writing you tried them and if you need to use a pesticide document nonchemical measures werent sufficient to take care of the problem so you chose to use a pest control material Document in writing how you applied the material such that no contact occurred between the pesticide and the organic food or packaging For example you might write I applied product name using a low pressure crack and crevice method to prevent contact with organic product during application Air intake vents were closed and fans were turned off during application of product name to the exterior perimeter as a barrier against ants Organic product and packaging materials were removed from the area during application Documentation By now you probably have the idea what you do in an organic food facility isnt that different from what you would do in any other food plant Inspection monitoring sanitation and structural repair play large roles Written Pest Management Plan To obtain the right to label their products USDA Organic your clients must submit a document called an Organic Handling System Plan This details every step of production from sourcing of ingredients through shipment of finished product It shows how the organic integrity of their product is protected at each step They must show in writing their product and the ingredients that went into it are free of chemical contaminants The written pest management program you submit becomes part of the plants Organic Handling System Plan Your plan along with all other documentation is placed in a folder and submitted to the organic certifying agent for approval It should include A statement explaining how the plan is designed to comply with organic requirements as specified in the National Organic Program A policy statement about Integrated Pest Management practices declaring inspection and monitoring are the primary activity and that pesticides play a secondary role in pest management supplementing nonchemical measures sanitation exclusion physical and mechanical controls but never substituting for them and Full descriptions of all service elements including equipment materials and service frequencies for control of crawling insects flying insects rodents outdoors and indoors stored product pests birds nuisance wildlife and weeds Your written pest management plan must be supported by a logbook that includes all items that should be in any food processing pest management plan Service description this might be the proposal or service agreement continued on next page www mypmp net SEPTEMBER 2010 PEST MANAGEMENT PROFESSIONAL 59