> Edna -- Your county agent was wrong. Federal pesticide law,
> FIFRA, prohibits a company from selling/labelling a product for pest
> control purposes -- i.e. a product whose packaging makes any
> pesticidal claim -- unless the product is first registered by the
> EPA. It is not a crime, nor any business of the EPA, if a master
> gardener or a beginning gardener were to cook up at home any number
> of natural controls. Soaps, baking soda, gasoline, cyanide, ground
> up mealy bugs -- whatever -- if the chemical or ingredient does not
> come in a containiner that makes pesticidal claims, the EPA has not
> jurisdiction over what individuals do in the privacy of their own
> gardens. So do not let them use that excuse.
I'm guessing you have insights as to how pesticide regulations
work that others of us do not. It would be great to get some
real clarity on this issue.
Having spent countless hours searching through scientific literature
and databases and catalogs and magazines on alternatives to
pesticides -- in respone to queries from growers seeking information
on organic production methods -- I can tell you that the question
raised about the legality of home-made pest controls on commercial
crops is very real and pertinent.
When news that Cornell University research showed that baking
soda had fungicidal properties against mildews, the manufacturer of
Arm & Hammer baking soda (Church & Dwight Co. Inc., of Princeton,
New Jersey) issued a statement in Greenhouse Manager (Feb. 1993) to
the effect that since baking soda is not labeled as a pesticide, it
cannot be legally used as a fungicide in commercial agriculture.
Nowadays, I believe there are bicarbonate products registered for use
and sold through regular pesticide suppliers. But what about the
growers using baking soda, hydrogen peroxide, cinnamon oils, citrus
oils, and other items found in the kitchen cabinet for pest control?
A few years back a co-worker found there may be circumstances where
common products such as baking soda and hydrogen peroxide may be
legally applied as a fungicide under the terms of the federal
In the Consolidated Federal Regulations, 40CFR-Chapter 1,
Part 172.3, it stated that experimental materials used on less than
10 acres are exempt from an EPA Experimental Use Permit, provided
that it is a non-food crop, or that if applied to a food crop it is a
material exempt from tolerance standards (no residue limits have been
Can anybody shed light on this subject? What is the real
deal? What restrictions and what liberties apply to this
When the Russian economy went sour and fertilizer and pesticide
supplies to Cuba dried up, the farmers there became adept at figuring
out organic farming solutions. Dozens of biocontrol centers were
established to raise beneficial insects and culture microbial
biopesticides. Worm compost sheds were built to turn organic wastes
into a valuable soil amendment biofertilizer.
They say that necessity is the mother of invention.
It is obvious that farmers are inventing stuff all the time.
Just think of the brain power churning and clicking everytime
a farmer looks at a field of vegetables and wonders how to get
effective organic or least-toxic control of something so sinister as
blister beetles (yuck!, curse!, spit!) on green beans and tomatoes,
or squash bugs on zucchinis, or corn earworm in sweet corn, or plum
curculio in apples (ack!). "Hmm," the farmer, pausing and
resting chin on handle end of hoe, thinks, "I wonder what will happen
if I mix up a bottle of green kitchen-cabinet-gook and spray it on
I can also assure you that chemical-use farmers are very curious
about these limits too. When organic farmers are charging
higher prices and making claims for superior safety and
food quality, it is simple human nature that the chemical-use
farmers want reassurance that the home-made and
new-invention pesticides are OK to use from a legal
Again, any clarity will be appreciated.
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