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Issue

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1

Aims

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

2

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.

3

Normative framework

EU Regulation:

Annex III, General Provisions 8: " For the storage of products, areas must be managed in order to … avoid any mixing with or contamination by products and/or substances not in compliance with this Regulation."

Besides this paragraph focussing on storage rooms, no specific provisions for processing facilities are included in the EU-regulation on organic farming. Therefore, a common understanding is, that all pest control products and methods allowed for food processing in general are also allowed for processing of organic food.

German Law on Plant Protection:

According to this law, "plant protection" involves not only the protection of crops on the field, but also simple processing steps, like e.g. drying, freezing, milling, etc. According to this rationale, in establishments, which perform this kind of processing, only those substances could be used for pest control, which are listed in Annex II of Regulation (EEC) 2092/91, besides being reg­istered for post-harvest treatments (which would be a very reduced number of products).

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.

JAS

Notification 60, Art. 4: The manufactured or processed organic agricultural product …shall be controlled not to be polluted by the agricultural chemicals, detergentes, disinfectant, and other drugs.

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Terms, clarifi­cations, abbreviations

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

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Policy

5.1

Basic consid­erations

•     The EU-regulation is vague concerning facility pest management. There is a certain contradiction between the EU-regulation and national legislation of EU member states, mainly due to different definitions of what is considered as "plant protection" (see 3). This leaves space for a wide range of interpretations, which is not satisfactory for us.

•     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 NOP and EU certification, we apply the following require­ments:

5.2

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 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).

•     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.

•     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.

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Related documents

None.