[Pest Management] Pest Management in Organic Facilities

Do you remember the days when “organic” food stores were the province of sandal-shod bohemians clad in bell-bottom Levis and unbleached linen tunics? These folks occupied tiny storefronts in college towns and quaint urban neighborhoods. In their stores (called co-ops), you’d find organically grown brown rice; whole-grain breads; soy milk and tofu; maybe a free-range chicken or two; and the latest edition of Mother Jones magazine.
Fast-forward to the present, and you’ll find that the whole-foods co-ops have modernized, ditched the Che Guevara posters, gotten bigger, and moved into upscale suburbs. Even more striking is that the organic foods department in your local Safeway, Winn-Dixie, or Kroger gets bigger and better-stocked every month. Organic food production has definitely gone mainstream, and larger food producers and distributors are beginning to claim their share of this promising market.
Perhaps you have a client in the food processing or storage sector who has announced they’d like to “go organic,” and has asked you to submit an Organic pest management plan. What do you do next? Read on!

HISTORICAL PERSPECTIVE. Organic food production traces its origins to the whole-earth movement of the late 1960s and early 1970s. Doing things the natural way was seen as important, and this involved rejection of the chemical additives, preservatives, and pesticides that were necessary for large-scale production and storage of food. Corporate farms and large food processors were seen as being all about maximizing profit, and chemicals were a necessary part of their efficiency. The producers of organic foods sought to get “back to nature,” offering their customers a purer product free of synthetic inputs such as preservatives and pesticides.
Many small farms began raising organic crops, as well as Organic dairy cows, layer hens, and animals for slaughter. Organic food processors and packagers completed the cycle from farm to table by conducting processing, packing and storage operations under conditions that met a definition of “organic” that was, for many years, somewhat vague.
Early on, there was little standardization as to what exactly was meant by “organic,” a term that was used interchangeably with “natural” and other words and phrases that were supposed to convey a sense of Earth-friendly, sustainable, and otherwise ecologically responsible practices. There was a vague notion that “organic,” as far as pest control was concerned, meant “no pesticides.”
Organic inspection agencies appeared, and their job was to provide guidance to growers, producers and packagers of organic foods about how to maintain the organic integrity of their products. Ultimately, they were responsible for Certification of the Organic status of products being marketed to consumers. Eventually, these agencies (among them the Organic Crop Improvement Association, Organic Growers & Buyers Association, and many others) petitioned Congress for some kind of standardization of organic rules.
The result was the Organic Food Production Act, which was passed in 1990 but was not fully supported by an actual government program until October of 2002. That was when the National Organic Program, under the aegis of the United States Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS), became law.

COMMON MISCONCEPTIONS. Pest management professionals who are called upon to offer service to Organic food producing or packaging establishments often fall victim to one of several misunderstandings. The origin of these misunderstandings may stem from the “old days” of organic certification under many different sets of rules; or they may be based on a faulty interpretation of the new National Organic Program (NOP) rules.
 The most common fallacy is that in Organic facilities no pesticides can be used. The second most common misconception is that the only pest control products that can be applied in Organic facilities are non-synergized pyrethrins, boric acid, Vitamin D3 (cholecalciferol), insecticidal soaps and oils, diatomaceous earth, and elemental sulfur (the so-called “National List” pesticides).
The real truth about what pest management professionals can and cannot do in Organic facilities lies in a careful reading of the rules; in adopting a commitment to the intent and spirit in which the rules were conceived; and in carefully following the rules as they are written.
THE RULES. The rules of the National Organic Program (NOP) pertaining to pest management in and around food processing and storage facilities (this includes manufacturers’ warehouses, but does not include grocery distribution centers, grocery stores, restaurants or food processing plants with annual sales under $5,000.00) are summarized in the Facility Pest Management Standard, which is part of the NOP regulatory text. Taking a few liberties with language for the sake of brevity, the rules are as follows (see the sidebar on page 106 for the full text of the NOP Facility Pest Management Standard):
1. Food processors must rely on responsible non-chemical practices as a first line of defense against pests. Most of the task of pest prevention and management is to be accomplished through effective pest exclusion and sanitation. Additionally, mechanical controls (e.g., traps) and physical practices (lighting design, temperature and humidity management, etc.) must be employed where appropriate to prevent and/or control pests.
2. In the event that non-chemical practices are found inadequate to prevent or control pests, then it is permissible to use a pesticide named on the National List. (The National List, which is part of the regulatory text of the NOP, gives the names of synthetic and non-synthetic substances that are, and are not, allowed as inputs in organic production.
It is important to keep in mind that, just by virtue of being named on the National List, a pesticide cannot be applied at will in an organic food plant. Management and the pest management professional must first exhaust their non-chemical options as outlined previously. The National List is somewhat limited in what it permits as far as pest control materials are concerned: non-synergized pyrethrins (most pyrethrin products on the market contain synergists such as piperonyl butoxide), boric acid, insecticidal soaps and oils, and Vitamin D3 (cholecalciferol) are among those found on the National List. Fortunately, many ant control products and some cockroach control products, as well as all-purpose insecticide dusts, contain boric acid as an active ingredient. Recently, several pesticide manufacturers have begun marketing space treatment and contact insecticides containing non-synergized pyrethrins, with organic and “green” pest management consumers specifically in mind. A growing number of residual and non-residual insecticides containing essential oils as active ingredients are also now available. And rodenticides containing Vitamin D3 have been commercially available for many years.
Thus, we have some materials in our toolbox that conform to this important aspect of the NOP rules — the National List. Pest management professionals should check with their suppliers for pest management products that fit the National List.
3. In the event that a material named on the National List is found to be inadequate to prevent or control pests, a material not named on the National List may be used. Two important provisions apply to the use of materials not named on the National List:
• Management must amend their written Organic Handling System Plan (this is the master document, including not only pest control but also many other details of plant operation, describing how their products will be made, packaged, and stored in such a way that their organic integrity is safeguarded) to reflect the fact that pest control materials not named on the National List will be used under certain circumstances.
• The materials must be applied in such a way that no contact occurs between the material applied and any organic product that might be present.
This third point of the NOP Facility Pest Management Standard is the point that is least understood by pest management professionals. It tells us, in effect, that we are permitted to apply pest control materials that are not named on the National List, as long as we take steps to ensure that our pest control materials do not contaminate organic product or processes.

WHAT TO DO AND HOW TO DO IT. Once your client decides to become an organic processor, packager or food storage facility under the rules of the National Organic Program, they must submit an Organic Handling System Plan to their Organic Certifying Agent. (The Organic Certifying Agent may be one of the Organic certifying agencies that existed prior to NOP, or it might be a more recently formed entity.) Organic Certifying Agents answer to USDA, and their responsibility is to verify compliance of food processing and storage facilities with the requirements of the National Organic Program rules, and to accredit those facilities that fulfill the criteria of the NOP. Facilities that fully comply with the rules of the NOP are permitted to display the USDA Organic logo on their packaging. (Actually, there are rules that dictate whether the producer is permitted to display the logo plus the words “100% organic,” or some lesser verbiage indicating partial compliance. In the interest of brevity, those rules will not be covered in this article.)
Part of the Organic Handling System Plan that food producers, packagers and warehouse operators wishing to market their products as “USDA Organic” must submit to the Organic Certifying Agent will be a formal, written pest management program that you must prepare for them. This will be very much like the service description that you prepare for all of your clients, but it will be worded in such a way that it demonstrates understanding of, and compliance with, the rules of the NOP.
1. First, prepare an introductory statement indicating your commitment to responsible Integrated Pest Management and the protection of the Organic integrity of your client’s products, processes and facilities.
2. Second, design an approved pesticides list, showing:
• Brand name, manufacturer name and EPA registration number of each material proposed for use
• For each material, whether it is intended for use indoors or outdoors, and for what specific purpose it is intended
• For each material, how it will be applied (examples: low-pressure crack and crevice in process areas; in tamper-resistant bait stations around exterior perimeter)
• For each material, what non-chemical measures will be employed prior to our resorting to use of the material — in other words, what non-chemical strategies will be employed in order not to need this material in most cases (examples: mowing weeds around the perimeter to reduce the need for rodenticide baits; inspection and detail cleaning of processing machinery so as not to need residual insecticides in many cases)
• For each material, what measures will be taken when it becomes necessary to use the material, in order to ensure that no contact occurs between the material and any organic product or processes (examples: liquid residual insecticides applied under low pressure, and using a crack and crevice tip, and at times when product is not exposed; cockroach baits applied in retrievable bait stations to ensure that, following their retrieval, the only bait left behind is in the stomachs of dead cockroaches)

EXECUTION. Once the written program is designed and your client submits it (along with the rest of their Organic Handling System Plan) to the Organic Certifying Agent, it all comes down to perfect execution.
All of those non-chemical prevention and control strategies that have always been so important in the performance of Integrated Pest Management become doubly important in organic programs, because you don’t have the luxury of relying on pesticides as a first line of defense against pests. The client cooperation you always needed in order to do excellent IPM becomes twice as important under an organic program. Your requests for sanitation improvements, structural repairs, and proper personnel practices become twice as urgent. Organic pest management programs cannot succeed without the full cooperation of the client, and that cooperation must exist at all levels of the operation, from top management on down.
The pest control log book is central to the two-way communication that is the cornerstone of organic pest management. In the log book, the technician servicing an organic account should inform his or her client of significant findings, especially as this pertains to pest activity noted, or to conditions that might be conducive to pests and that might need correction.
Remember that any action that is taken — whether a recommendation to clean a clogged drain, or an application of ant bait in a floor crack, or the use of a granular insecticide outside to control crickets — must be tied to the rules of the NOP, and you must describe each action you take in writing, and then reference it to the stated rule. For example, your log report from a particular service visit might indicate that you found saw-toothed grain beetles under a piece of equipment because it was poorly cleaned. On that visit, you might write a note in the pest control log book, asking your client to clean up the equipment and suggesting that they amend their Master Cleaning Schedule to ensure that the needed level of cleaning is done in the future. Perhaps, on a follow-up inspection of the same area a week later, there was still some beetle activity. You might apply a non-synergized pyrethrin product consistent with the National List into cracks and crevices, to knock down the remaining beetles. You’d then make a note in the log book, indicating that simple sanitation didn’t get the job done, so you used a material consistent with the National List. Now, let’s say that you came back to check on things a week later, and there were still some beetles present. You might be justified at this point to apply a residual insecticide into cracks and crevices near where the activity is occurring. But it would be important to point out, in writing, that you employed this strategy only after sanitation and the use of a material consistent with the National List had failed.
It is important to have a paper trail that shows compliance with the rules of the National Organic Program. And you will have this paper trail if your log book:
• Acknowledges, and pledges to support, the principles of the National Organic Program.
• Names all pest control materials you might want to use, in an approved materials list. This list must describe, for each material, what non-chemical measures will be employed prior to resorting to use of that material; and must describe what measures will be taken when using that product in order to ensure that organic products or processes will not be contaminated by the material used.
• Describes all action taken (recommendations for sanitation or structural improvements; other non-chemical strategies; application of pesticides consistent with the National List; and application of pesticides not named in the National List), and shows — in writing — how our actions are in compliance with the letter and spirit of the NOP’s rules.
If all of the preceding gives the impression that doing pest management in organic facilities is not that different from any well-designed food processing Integrated Pest Management program, that impression is exactly right. As an industry, we as pest management professionals are well qualified, by way of our long experience with Integrated Pest Management, to serve the organic food processing and storage industry.

The author is technical director at Plunkett’s Pest Control, Fridley, Minn. He can be reached at jbruesch@giemedia.com.