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Your resource for international organic trade
Bringing the US organic industry to
developing markets around the world and
creating new opportunities for organic
products through international promotions,
exporter education, business to business
connections, and trade negotiations.
the organic regulation at Section 205.105(b) and the EPA
regulations at 40 CFR 180.1017(a). Certifiers accept this
practice as compliant with the NOP regulations.
Natural pyrethrum, an extract of chrysanthemum flowers, and viable spores of Bacillus thuringiensis (Bt) are two
nonsynthetic substances not prohibited in organic crop production that can prevent Indian meal moth larvae infestation when used for post-harvest treatment of harvested
grain. EPA established a tolerance of 1.0 ppm for residues
of the insecticide pyrethrins in or on milled fractions derived from grain and in or on cereal when present as a result of its use in cereal grain mills and in storage areas for
milled cereal grain products [40 CFR 180.128(a)( 2)]. EPA
has exempted viable Bacillus thuringiensis spores from the requirement of a tolerance [40 CFR 180.1011].
According to the interpretation of some certifiers, the
organic regulations do not allow the post-harvest use of
nonsynthetic pyrethrum, because it is not allowed as a non-synthetic ingredient in processed organic food. An additional concern is that the inert ingredients used in pesticide
formulations are not included on Section 205.605. Both of
these post-harvest treatments of grains seem to be allowed
at Sections 205.105(b), 205.206(e) and 205.271(c).
Increasing the CO2 level also can prevent insect
development. Effective fumigation may require ten or more
days of CO2 exposure in a sealed bin. EPA regulations permit this use in 40 CFR 180.1049. Regarding NOP, CO2 is a
synthetic substance permitted for processing at Section
205.605(b) but is not an allowed synthetic in organic crop
production at Section 205.601. Application of a nonsynthetic or synthetic substance for facility pest management is
permitted at Section 205.271(c) if the substance is consistent with the National List. CO2 is the only fumigant for unprocessed grain in a bin or a silo that some certifiers
consider consistent with the organic regulations because it
is allowed for processing. CO2 was originally added to the
National List for “handling” and its use as a fumigant of
herbs and spices is mentioned in the 1995 TAP review.
Poultry Egg Washing
Dust, mud, feces, feathers and the contents of broken
eggs may soil as many as a third of the eggs in an organic
production system, so egg washing is important. FDA regulates antimicrobial agents that are used on raw agricultural
commodities, such as shell eggs, wherever food is prepared,
packaged or held for commercial purposes. The EPA regulates antimicrobial agents that are applied in the field, at
treatment facilities where raw commodities are the only
food treated and the treatment does not change the status
of the food as a raw agricultural commodity and during
transportation between the field and such a facility. Sanitiz-
