What You'll Learn
- Requirements for pest control in an organic facility.
- Recognize practices for preventing pests in storage areas
- How product flow and WIP management relate to organic integrity
- The importance of prevention and how it can be approached.
- What certifiers need for review and approval of pest control plans and how to work with your certifier on review.
- Your responsibilities when working with a third party pest management provider.
Introduction
This article will guide you through facility pest management requirements for organic handlers, and provide examples of management strategies and materials, as well as the information your certifier needs to review and approve your practices.
Organic pest control prioritizes prevention and monitoring before using pesticides, and requires certifier approval of pest control methods and inputs. Newly-certified organic handlers who are accustomed to conventional processing often need to adapt their pest management practices when transitioning to USDA organic requirements. In this article you’ll learn:
How to think about pests in organic
The organic approach to food production is to focus on promoting systems that prevent problems. This prevention-first approach is key to organic pest management.
Many handlers are familiar with Integrated Pest Management (IPM) principles, a framework that sees management techniques as either preventative or or curative. Organic pest control requirements share things in common with IPM principles. IPM and organic pest control both prioritize the prevention and monitoring of pests prior to control.1
The pest management approach for organic handlers
The organic regulations give clear instructions for pest management in handling facilities.2 In organic pest control you can’t jump straight to using a pesticide, instead you progress through steps, and at each step you aim to have prevented or stopped the pest problem so that harsher materials are not needed. The regulations describe these steps with letters A through D.
Whether you use a material that is on the National List or off the National List – you will need to record it on your organic system plan. Your updated organic system plan must include a list of the measures taken to prevent contact of your organically produced products or ingredients with the substance used.7
Also, your certifier needs to agree on the substance, method of application, and measures taken to prevent contact between the pest control substance and organically produced products or ingredients before you use them. Even for materials allowed on the National List, it is your certifier who interprets how any restrictions for materials on the National List apply to your operation.
However, if Federal, State, or local laws require the use of certain pesticides, you can use these but must take measures to prevent contact between the substance and organically produced products or ingredients.
Step A: Prevention First
The organic regulations require that organic handlers prevent pests.2 It is much easier to prevent pests from moving-in rather than dealing with them once they’ve arrived. And the fewer pest interventions needed, the less potential for contamination from pest management products. When you understand your target pests, you can identify where they might create problems in your facility. You can then manage them through preventative techniques.
There is a lot you can do through facility design to prevent pests. Below are some routine pest prevention tactics for organic facilities.
Identify your target pests
You can’t monitor or prevent what you aren’t looking for. Speak with other handlers or a pest consultant to identify the likely pests that will be an issue at your facility. Then learn about the habitat and food sources that these pests prefer. Knowledge is power – the more you know about your target pests, the better you can avoid the conditions that attract them.
Removing habitat
Remove food sources. By cleaning up spills of ingredients promptly, keeping employee food in sealed containers, evaluating how and where food waste products are stored.
In storage areas, keep items like pallets and bins at least 12 inches from the walls, and set rodent traps along the walls.
Consider the outside of your facility and whether you are creating habitat for problem pests – through storage of food waste products and any building or plant habitat that could harbor rodents, birds, or other target pests.
Preventing access
Screen windows that remain open.
Make sure doors close properly and are kept closed to prevent pest access (this could include door sweeps to ensure doors seal completely).
For doorways that must remain open, consider air curtains that blow air down within an open doorway to prevent flying insect access from one area to another.
Fix cracks in the building foundation and consider the sealing on your floors.
Inspect incoming goods for pests.
Managing your facility’s environment
Identify the humidity and temperature levels your target pests prefer – and avoid them.
Don’t allow standing water in your facility.
Make sure gutter downspouts are functional and move water away from your facility.
Good air flow can keep pests on the move, making it hard for them to congregate and breed.
Dumpsters
Are dumpsters located near your loading dock? Is your loading dock door open for longer periods of time? If so, you might be inviting pests into your facility.
Step B: Physical Control
Physical control means keeping your facility pest free using devices like sounds or lights, setting out preventative traps to catch the first arrivals, using chemical repellents to keep pests away, or lures to attract them to a single spot. BUT, any chemical lures or repellents that you use must be consistent with the National List.
Organic handlers have several devices they can use to deter pests and trap them for monitoring. Common examples are:
Traps for rodents or insects
Tin Cats are non-lethal rodent traps that mice can enter but not leave.
Snap Traps baited with food can target rodents in tight areas. Be careful about the bait you choose – chemical baits will need to be carefully reviewed by your certifier prior to use.
Glue Boards can catch rodents or certain insects in high traffic areas.
Fly tape or strips are a common trap for flying insects.
Lights
Insect Light Traps (ILT) attract flying insects with light and then trap them on glue boards.
Bug Zappers that kill flying insects with electricity.
Sounds
Hawk recordings can deter roosting birds.
Ultrasonic devices use high frequency sounds to repel pests, such as mice.
Lures and Repellents
These are allowed at this step but the chemicals in them must be consistent with the National List.
Ammonium carbonate may be used as bait in insect traps only.
Pheromone lures can be used to monitor, trap, and disrupt the mating of certain insects.
Essential oils (nonsynthetics) may be used as repellents.
Step C: Pest control substances on the National List
Only if the management practices in steps A and B are not effective can an organic handler use a pest control substance that is nonsynthetic or on the National List (other than a lure or repellent).
There are just a few pest control substances that are on the National List (other than lures or repellents). Common materials are Vitamin D3 as a rodenticide, and Boric acid for insect control. As always, confirm with your certifier that they will approve of your using these, even though they are on the National List.
Step D: Synthetic Substances not on the National List
If prevention and pesticides on the National List are not effective, only then can you proceed to using a synthetic substance not on the National List – as a last resort.
Your certifier needs to agree on the substance, method of application, and measures to be taken to prevent contact between the pest control substance and organically produced products or ingredients before use. This applies only to pest control inputs used in the areas of the facility where organic handling occurs, not the facility exterior or non-handling areas like break rooms or bathrooms. Examples include most pesticides, such as synthetic rodent baits and most insecticides.
Communicating with your certifier about pest management
Your OSP
Your organic system plan (OSP) is the living constitution of your organic certification. It is living because you are always updating it. The regulations say that your OSP must describe all practices that you use in your handling of organic products, including pest management practices.4 Your certifier will review your OSP to confirm it complies with the organic regulations.
You must prevent any pest control materials that your facility uses (such as lures, pesticides) from contaminating organic products or packaging.5 Your inspector will review your pest control records to see if your OSP and the list of inputs you submitted to your certifier matches what you are actually doing on site.6 You can learn more details about recordkeeping requirements in the article “Recordkeeping for Pest Control and Sanitation”.
Materials
You’ll need to submit a list of all pest control products to your certifier, including where and how they will be used. You will also submit the product label and other documents needed to determine the material’s source and composition. Your certifier will review this supporting documents to determine if, where, and how you may use the pest control substance. The National List does include certain synthetic pesticides, but they have restrictions on their use. So even if a product is allowed, you must first check with your certifier to determine how the restrictions apply to you.3
Risk Management
The organic facility pest management regulations provide specific requirements, but many of these rely on your certifier applying reason to assure that your pest management measures do not contaminate your organic ingredients or products.2 This is all about managing risk.
The method of application, or how, when, and where you plan to use the substance, makes a big difference in the level of risk for contamination. Here are some examples of how your certifier sees the risk of contamination with different pest control methods:
- Bait stations: If the bait stations are anchored and locked to prevent access by non-target animals, and the bait is secured on rods inside the bait station, then the pest control substance should be stationary, and risk of contamination from the bait is lower. Location is also important – your plan for preventing contact of the pesticide with organic products may also include strategically NOT placing the bait stations near organic products. At some organic facilities, for example, bait stations are only placed around the exterior perimeter.
- Backpack sprayer: If a pest control substance is sprayed, like a crack and crevice spray for insects, there is inherently a higher risk of the product traveling farther than if it were contained inside a bait station. Where will the spray be used and where will organic ingredients and products be stored? This will need to be considered prior to application to avoid contamination.
- Fogging: Fogging sprays a fine mist of pesticide throughout an area. If fogging is needed, all organic ingredients, products, packaging, etc. will need to be moved out of the area. You may need to consider cleaning methods after fogging, before any organic products or ingredients could be moved back into the space, to prevent contamination.
- Packaging: Contamination can occur if packaging material, like a bag or container, comes in contact with a prohibited substance and then touches organic products. But cleaning many types of packaging is difficult and impractical – always consider and prevent contamination to your packaging when managing pests.5
- Location: Where you plan to use pest control materials will have an impact on how your certifier sees contamination risk. Interior or exterior? Production areas, storage areas, break rooms, or outside around the dumpster – all have varying levels of risk for contamination.
Monitoring for pests
Monitoring is not included in steps A-D, and that’s because it happens first. Your organic system plan must include, “a description of the monitoring practices and procedures to be performed”4 In addition to being required in your OSP, monitoring for pest activity is also critical in organic pest management. You want to intervene early to avoid a pest outbreak, especially since you have more limited options in organic control. Think of monitoring like having eyes and ears for pests – you want to be actively looking for them, so that you know right away when a pest is threatening your facility and products.
Routine pest monitoring activities for organic handlers include regular walk throughs of your facility. Look for pest activity, such as chewed containers, pests caught in monitoring traps. Check for pest attractants like spilled ingredients, leftover employee lunch, pallets pushed next to walls, or standing water. Non-production areas can provide pest habitat, too. These are places like your employee break room, restrooms, or dumpster areas.
Monitoring traps are an excellent way to gauge pest activity early. Placing glue boards, Insect Light Traps (ILTs), and rodent monitoring traps at key locations provides you with early warning of pest incursions into the facility.
The placement of these tools and the frequency that you check them will influence how effective they are as monitoring tools. You will also record all your monitoring activities, since keeping records of monitoring activities is essential to identify any increase in pest activity, and because records are also required by the organic standards.6
Staff training
Everyone who will interact with pest monitoring and control should understand your pest control procedures, and that certifiers need to review and approve any changes to procedures or inputs used. They should also understand their role in keeping pest management records.
Working with third party pest control providers
Many organic handlers prefer to contract with pest control companies. If you do, your company is ultimately responsible for what the pest control provider does. If they keep poor records or use a prohibited substance, even if you told them not to, your organic certification would still be at risk.
Most organic handlers prefer to work with companies that already understand organic pest control requirements, or are at least willing to learn. Pest contractors need to know that they cannot use new pest products before you obtain approval from your certifier. It is particularly important that your contractor understand that for step D products your certifier needs to approve the product, the method of application, and the method for preventing contact with organic products and ingredients. Your pest control provider cannot provide approval for the use of any product, even if another organic client of theirs uses it – only your certifier can give approval.
You are required to provide records of all pest control activities, including those conducted by a third party contractor. If your pest control provider creates these records, you will be responsible for having the records available during your on-site inspection. Your inspector will review the records for completeness and to confirm the inputs and application methods used match the pest control plan in your OSP.
Your Next Steps
- Monitor the pest activity in your facility and determine the pests you need to target with control.
- Design a pest management protocol that targets those pests and complies with the hierarchy of pest management strategies in the USDA organic regulations.
- Document your pest management plan and submit it to your certifier for approval.
- Check in with any third party contractors that you use and ensure they understand the requirements of working in an organic facility.
- Train your staff to follow pest management protocols and recordkeeping.