The Inspector’s Notebook #16
Don’t bug me

Jim’s three-tiered approach to pest management should keep insects at bay

By Jim Riddle

Editor’s NOTE:

Certified organic farmers do an odd thing – they pay people to visit their farms with a critical eye to assure they are adhering to every aspect of the USDA’s national organic standard.

The farmers should already be trying to produce, harvest and market their organic crops, livestock and related products by these rules. The on-farm review of fields, facilities and records by an approved inspector sent by the farmer’s accredited organic certifier is the critical point in confirming that the farmer and the farm meet the organic standards – and can prove it to anyone who needs to know.

The visits are pivotal for applying farmers to become certified, and for certified farmers to keep that certification. For the good of organics, we want to help build the foundation for effective inspection visits. We’ve asked Jim Riddle to provide an inspector’s inside view to help farmers understand an inspector’s role, responsibilities and limitations.

In the months ahead, Riddle will elaborate on many items to help farmers understand regulations that apply to them, and how to document their compliance.

Jim Riddle has been on hundreds of farms in the inspector role, and he’s been inspected himself during his time as a farmer. His leadership in bringing professional training to inspectors helped to earn greater acceptance of organic farming in the U.S. He serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations. He has been an organic farmer, gardener, inspector, educator, policy analyst, author, and consumer.

Jim Riddle serves as vice-chair of the USDA’s National Organic Standards Board and organic policy advisor for He was the founding chair of the Independent Organic Inspectors Association (IOIA).

October 13, 2005: Organic farmers can’t turn to chemicals to eradicate a pest problem that may develop in their fields but that doesn’t mean they are without options. There are many tools in the organic farmer’s arsenal--trap crops, pheromones, beneficial insects. Let’s start by reviewing the NOP requirements.

According to section 205.206 of the rule, farmers, in order to be certified organic, must prevent pest problems by implementing crop rotations, fertility management systems and sanitation measures, such as removing habitat for pests.

Organic farmers are also required to use cultural practices that enhance crop health. This means using a selection of plant species and varieties that are well-adapted to site-specific conditions and resistant to prevalent pests. As inspectors assess the health of crops in the field, they will check seed tags to see that these species and varieties are being grown.

If pests are still a problem once the preventative strategies described above are in place, pests may be controlled through mechanical or physical methods including:

  1. Augmentation or introduction of predators or parasites of the pest species;
  2. Development of habitat for natural enemies of pests; and
  3. Nonsynthetic controls such as lures, traps, and repellents.

As an inspector, I always find it interesting to see the innovative lures, traps, and repellants that farmers use.

Organic pesticides

Despite our best efforts sometimes prevention is not enough. In these cases, a biological or botanical substance or a substance included on the National List may be used. The National List consists of all synthetic substances allowed for use in organic crop production.
Insecticides on the National List are:

  1. Ammonium carbonate—for use as bait in insect traps only, no direct contact with crop or soil;
  2. Boric acid—structural pest control, no direct contact with organic food or crops;
  3. Copper sulfate—for use as tadpole shrimp control in rice production, is limited to one application per field during any 24-month period. Application rates are limited to levels which do not increase baseline soil test values for copper over a timeframe agreed upon by the producer and accredited certifying agent;
  4. Elemental sulfur;
  5. Lime sulfur—including calcium polysulfide;
  6. Horticultural oils — narrow range oils such as dormant, suffocating and summer oils;
  7. Insecticidal soaps;
  8. Sticky traps/barriers; and
  9. Pheromones.

If you plan to use a botanical or biological pesticide or a synthetic pesticide on the National List, make sure that the formulated (brand name) product you intend to use is approved by your certifier prior to applying it to your crop or land. Keep in mind that most insecticides contain inert ingredients as carriers and/or fillers. Synthetic inert ingredients that are classified on the Environmental Protection Agency’s List 4 “Inerts of Minimal Concern” may be used. Inert ingredients on EPA’s List 3 “Inerts of Unknown Toxicity” may only be used in passive pheromone dispensers.

If you are unsure about a product’s inert ingredients, check with the manufacturer or supplier, and make sure that the product is approved by your certifying agent.

Passing inspection

As an inspector, I am looking not only to see that the measures outlined in the rule are in place, but that they have been used properly. For example, when reviewing a farmer’s field history sheets during an inspection, I look to see that soil building crops are included in the rotation and that crops in the same families were not planted in the same fields year after year.

For More Information...
ATTRA has some excellent publications on approved pest control strategies, such as Bug Vacuums For Organic Crop Protection; Colorado Potato Beetle: Organic Control Options; Flea Beetle: Organic Control Options; and Organic Control of Squash Vine Borer. These can be downloaded at

Any substance used must be fully documented in your organic system plan including name and condition for use. The inspector will review the organic plan to make sure that all pest control inputs being used or intended for use are listed. Farmers often forget to write down all of the pesticides they use, or start using new pesticides after the organic plan was submitted. Inspectors also examine product labels, usage records and receipts for all pest control inputs used.

Without an assortment of chemicals at his or her disposal the organic farmer must rely on a multi-tiered approach to controlling insect populations but if you keep these guidelines in mind as you map out your pest management plan insects - and your inspector - shouldn’t bug you too much!

This material was developed with the support of the U.S. Department of Agriculture through the Risk Management Agency, under Agreement No. 031E08310147