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Update

Inerts Working Group

National Organic Standards Board MeeApril 26, 2011Seattle, Washington
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Inert ingredients in pesticides

Any substance ... other than an active ingredient which is intentionally includany pesticide product. [§ 205.2]Examples: substances to prevent cakinfoaming, preservatives, spreaders, sticUV inhibitor, solvents, diluents 
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Background• OFPA permits synthetic inerts that are “not classed b

as inerts of toxicological concern”

• Synthetic inert ingredients, classified as List 4 by EPA

allowed in pesticides for organic use.

• List 3 inerts are allowed in passive pheromone dispe
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Background

• EPA revised system of assessment in 2006, no longer 

List 1-4 

• NOP is operating with obsolete list of inerts, dated Au

2004

• Manufacturers are petitioning for use of inerts that d

appear on the old Lists
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NOSB recommendation: April 2010

• NOP should create a MOU with EPA to assist in evalua

former List 3s-4s. May need a task force.

• NOSB and/or task force to review former List 4s to id

that may be non-synthetic; these should be first choipesticide formulations

• Ask manufacturers to provide information on all rema

synthetic inerts in current use, to be reviewed individpetitions

• Prioritize review of inerts, establish timelines for refo• Result may be individual listing of inerts, or EPA mana
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NOP Actions since April 2010

• Drafted MOU that has been shared w• Initial meeting with EPA staff – Oct. • Follow up meeting with EPA staff – D• Initial Work Group meeting Feb 2, 20• Data gathering and assessment
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Inerts Working Group

• NOP: Emily Brown Rosen, Lisa Brines

Punzi

• EPA: Chris Pfeifer (BPPD), Kerry Leife

(Inerts)

• NOSB: Jay Feldman, Tracy Meidema

Moyer (ex officio)
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Initial findings

• EPA is very willing to assist in assessm

but does not have authority or resoudevelop or maintain a special list of organic-compliant inerts

• Goal: to develop a new policy that ca

finalized no later than 2017, next sundate for List 4
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Initial findings

• 2004 EPA List 4a & 4b = 879 substance• EPA currently lists all inerts used on foo

either as exempt from tolerance, or witspecific tolerances for residues

• Listed at 40 CFR 180.910-180.960• EPA also classes some inerts as permitt

use in Minimal Risk products– FIFRA 25
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Some options discussed

• Review all synthetic inerts individual

– Develop screening criteria that can be a

• Identify subgroups of inerts under EP

180 that might be compatible

– e.g. 25(b) list 

• Evaluate currently used inerts for any 

patterns or groupings, focus on know
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Data collection

• OMRI and WSDA have shared lists of 

in current use

• Comparing this to EPA’s 25(b) list and 

old List 4 to see where overlap and gexist

• Identifying nonsynthetic substances
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Data collection

• OMRI list includes 251 inerts

– Of these, approx. 157 are synthetic

• WSDA list overlaps, plus includes 22 

additional synthetic inerts

• Total 179 synthetic inerts in these pr
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Next steps

• Review data, analyze further

– Compare to EPA 25b list (291 substances)– Compare to other EPA tolerance exempt c– See which if any existing categories can be 

referenced

– Develop criteria for screening any materia

do not fall in those categories
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Next steps

• Report back to the Board• Questions?• Suggestions?