Aim :

Establish clear rules for pest control practices in post-harvest facilities, where organic food is processed or stored.

Background :

Facility pest management can be even more complex than plant protection in the field. Solutions have to be found, which meet consumers’ expectation of non-polluted organic food, but can at the same time be implemented by the companies with realistic efforts.

Normative framework :

NPOP:

3.4.2 Pest and Disease Control

General Principles:

Pests should be avoided by good manufacturing practices. This includes general cleanliness and hygiene.

Treatments with pest regulating agents must thus be regarded as the last resort.

Recommendations:

Recommended treatments are physical barriers, sound, ultra-sound, light, and UV-light, traps (incl. pheromone traps and static bait traps), temperature control, controlled atmosphere and diatomaceous earth.

A plan for pest prevention and pest control should be developed.

NOP:

§ 205.271 Facility pest management practice standard

(a) The producer or handler of an organic facility must use management practices to prevent pests, including, but not limited to:

1. Removal of pest habitat, food sources, and breeding areas;
2. Prevention of access to handling facilities; or
3. Management of environmental factors, such as temperature, light, humidity, atmosphere, and air circulation to prevent pest reproduction.

(b) Pests may be controlled through:

1. Augmentation or introduction of predators or parasites for the pest species;
2. Mechanical or physical controls including, but not limited to, traps, light, or sound; or
3. Nontoxic, nonsynthetic controls, such as lures and repellents.

(c) If the practices provided for in paragraphs (a) and (b) of this section are not effective to prevent or control facility pests, a nonsynthetic biological or botanical substance or a synthetic substance may be applied to prevent, suppress, or control pests …

(d) The handler of an organic handling operation who applies a nonsynthetic biological or botanical substance or a synthetic substance for the prevention or control of a pest must include in the organic handling plan a list of all measures taken or intended to be taken to prevent contact between the substance and any ingredient or finished product …

(e) …must include in the organic handling plan an evaluation of the effects of repetitive use of the same or similar materials on pest resistance and shifts in pest types.

COS:

8.4.1 Good manufacturing practices shall be adopted to prevent pests. Pest management practices shall first involve the removal of pest habitat and food; second, the prevention of access and environmental management (light, temperature and atmosphere) to prevent pest intrusion and reproduction; and third, mechanical and physical methods (traps), lures and repellents listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists.

8.4.2 If the practices given in par. 8.4.1 are ineffective, the operator may use pest control substances listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists. The operator shall record the use and disposition of all such substances.

8.4.3 If the practices given in par. 8.4.1 and 8.4.2 are ineffective, the operator may use pest control substances not listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists. In situations in which pest control substances not listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists, are used indoors, the operator shall ensure that no organic products or packaging materials for those products are present. Documentation shall be maintained showing the movement of organic products in order to avoid contact with these substances and to record the use and disposition of all such substances.

8.4.4 Organic products shall be exposed only to pesticides or pest control substances listed in CAN/CGSB-32.311, Organic Production Systems — Permitted Substances Lists, during any stage of production, transit, storage or border crossing.

Terms, Clarifi-cations, abbreviations :

Pest control, pest management: Refers to prevention and control of harmful insects, mites, mammals, etc.

Policy :

Basic considerations:

• We agree with the NOP approach, which gives priority to preventive measures, but allows use of non-synthetic and synthetic pesticides under certain conditions.
• Thus, both for NPOP and NOP certification, we apply the following requirements:

Requirements:

• Before using any synthetic substance for pest control or pest prevention, the operator has to implement all possible measures of prevention and non-synthetic control, as listed above in NOP § 205.271. Measures for preventing pests in food industry, are also listed in good manufacturing practice (GMP) standards (e.g. http://www.saafost.org.za/Food-GMP.htm)
• Both synthetic and non-synthetic pest control substances must be applied in a way, which excludes pollution of organic food (see above NOP § 205.271, see also different GMP standards for pesticide application).
• Organic food must be removed from storage or processing rooms, before synthetic pesticides are applied. Covering with plastic sheets, or similar, is not sufficient.
• After application of synthetic pesticides, the waiting time, before organic food is re-introduced into the respective room, has to be doubled, as compared to the time established by the pesticide manufacturer. In case of doubts, ADITI will require residue testing, to make sure, that facility pest control is not a source of contamination of organic food.
• Surfaces, which enter in contact with food, have to be washed with adequate soaps, and then rinsed with clear water, after pesticide use.
• Rodenticides can be used only in closed devices, which’s location must be identified in a drawing accessible to all staff. If possible, a specialised company should place them on safe sites outside the facility.
• The staff in charge of facility pest management is responsible for safeguarding the innocuousness of all measures, which are taken.