FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: ___November 30, 2007_____

Subject: __Sunset- EPA List 3 inerts used in passive pheromone dispensers__ 

Chair: _Andrea M. Caroe_______________ 

 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ____X___

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

Renewal of the following substances in this use category: §205.601(m)(2)(ii) 

(m)- As synthetic inert ingredients as classified by the Environmental Protection Agency(EPA), 

for use with nonsynthetic or synthetic substances listed in this section and used as an active 

pesticide ingredient in accordance with any limitations on the use of such substances. 

(2)- EPA List 3, Inerts of unknown toxicity 

(ii)- Inerts used in passive pheromone dispensers 

NOSB Vote: Motion: T. Miedema Second: R. Delgado 

Board vote: Yes - 13 No- 0 Abstain- 2 Absent - 0 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Substances widely used in organic production. No new information presented to warrant removal 

from the list. 

Sunset Material Vote 

Response by the NOP:
Crops Committee Recommendation for §205.601 September 12, 2007 

 

I. List: 205.601 Synthetic substances allowed for use in organic crop production 

Specifically, this recommendation refers to EPA “List 3” inerts used in passive pheromone dispensers only, and 

referred to in 7CFR § 205.601 (m) (2) (ii) 

II. Category Use 

(m) As synthetic inert ingredients as classified by the Environmental Protection Agency (EPA), for use with 

nonsynthetic substances or synthetic substances listed in this section and used as an active pesticide ingredient in 

accordance with any limitations on the use of such substances. 

III. Committee Summary 

The Crops Committee supports the renewal of “List 3” inerts whose classification has not been revoked by EPA and 

are permitted for use by EPA as “other ingredients” in the formulation of pest management materials for use only in 

passive pheromone dispensers. 

So-called “List 3” inerts, when used in passive pheromone dispensers, do not negatively impact humans or the 

environment. They are essential for organic production and are compatible with organic production practices. 

The EPA system of categorizing inerts into “Lists” is in the process of changing. Only those inert ingredients 

identified by EPA “List 3” inerts as of Oct 9, 2007 are included in this particular Sunset recommendation. Those inert 

ingredients used for organic crop production on the National List can be found in the following: 

http://www.ams.usda.gov/nop/NoticesPolicies/NOP5008ReassessedInertIngredients09-06-07.pdf 

Future petitions to add, remove or renew an inert ingredient to the National List will need to reference a specific inert 

ingredient. A petition may be submitted to the NOSB using the National List petition procedures. Individually 

petitioned substances must be recommended by the NOSB and added to the National List through notice and comment 

rulemaking before use in organic agriculture. 

IV. Committee Recommendation 

The Crops Committee recommends the renewal of the following substances in this use category: § 205.601 (m) (2) (ii) 

(m) – As synthetic inert ingredients as classified by the Environmental Protection Agency (EPA), for use 

with nonsynthetic substances or synthetic substances listed in this section and used as an active pesticide 

ingredient in accordance with any limitations on the use of such substances. 

(2) – EPA List 3, Inerts of unknown toxicity 

(ii) – Inerts used in passive pheromone dispensers 

Moved: Tracy Miedema Second: Rigo Delgado 

Committee vote: Yes: 6 No: 0 Absent: 0 Abstain: 0 

Board vote: