The organic standards require that a progressive approach to facilities pest management be taken by organic growers and handlers. The organic pest control regulations described below can be found at https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205/subpart-C/section-205.271.
(Level A) First, pests must be controlled through management practices like sanitation, removal of pest food sources and habitat, controlling access to pests, and management of the environment (think altering the temperature, light level, humidity, and atmosphere in which pests may thrive).
(Level B) Next, the facility may control pests via the use of traps, lures, and repellents present on the National List.
(Level C) Third, if level (A) and (B) strategies aren’t effective to prevent or control pests, synthetic or non-synthetic items on the National List such as Vitamin D3 baits and botanical insecticides may be used. (Please visit www.OMRI.org for more level C products).
(Level D) Finally, if all of the methods above prove ineffective, then your facility may request the use of level (d) substances. Level (d) substances are not to be used for pest prevention. They are only to be used to control an active infestation that was not otherwise controlled by management, traps/lures, and level (c) substances.
OneCert requires that facilities who seek to use Level (d) substances complete the Level (d) Pest Plan form. You can find the form here: https://onecert.com/resources/#forms. The Level (d) Pest Plan form asks you to explain what pest control methods you’ve already tried and how you determined those methods were ineffective. It also asks you to explain how you will prevent organic equipment, products, ingredients, and packaging from becoming contaminated with the level (d) substance(s) you intend to use to bring a pest infestation under control. This fulfills the terms of part (e) of the organic pest management regulations which states that, “The handler of an organic handling operation who applies a non-synthetic or synthetic substance to prevent or control pests must update the operation’s organic handling plan to reflect the use of such substances and methods of application. The updated organic plan must include a list of all measures taken to prevent contact of the organically produced products or ingredients with the substance used.”
When completing the Level (d) Pest Plan form, remember that if you have skipped over using the methods described in levels (a), (b), or (c), your plan may not be approved. Use of the progressive hierarchy of pest management described here is a requirement of the regulations. If you have questions about whether or not the substance you intend to use is classified as “Level (d),” contact OneCert.