“Low Impact Pesticide”: by definition in the School IPM Act of New Jersey specifically include:
- Certain formulation types: any gel; paste; or bait;
- Antimicrobial agents such as a disinfectant used as a cleaning product; Specific active ingredients: boric acid; disodium octoborate tetrahydrate; silica gels and diatomaceous earth; Microbe-based insecticides such as Bacillus thuringiensis; Botanical insecticides, not including synthetic pyrethroids, without toxic synergists;Biological, living control agents; and
- EPA FIFRA-exempt active ingredients and/or inerts (see below)
FIFRA-exempt Active Ingredients
In 1996, EPA exempted certain minimum risk pesticides from FIFRA requirements if they satisfy certain conditions. EPA exempted the products described in 40 CFR section 152.25(g) (PDF), and summarized the exempt materials into 2 appendices in an EPA guidance document titled‘Pesticide Registration Notice 2000-6; Subject: Minimum Risk Pesticides Exempted under FIFRA Section 25(b); Clarification of Issues.
The first appendix is Appendix A: Active Ingredients Which May Be in Minimum Risk Pesticide Products Exempted under section 25(b) of FIFRA. To qualify for an exemption as a minimum risk pesticide, each active ingredient in the pesticide product must be listed in 40 CFR 152.25(g)(1). Appendix A (below) is a list of these exempt ingredients.
PR Notice 2000-6
Active Ingredients Which May Be in Minimum Risk Pesticide Products Exempted under section 25(b) of FIFRA
- Castor Oil (U.S.P. or equivalent)
- Cedar Oil
- Cinnamon* and Cinnamon Oil *
- Citric Acid*
- Citronella and Citronella Oil
- Cloves* and Clove Oil*
- Corn Gluten Meal*
- Corn Oil*
- Cottonseed Oil*
- Dried Blood
- Eugenol (oil of cloves)
- Garlic* and Garlic Oil*
- Geranium Oil
- Lauryl Sulfate (sodium lauryl sulfate)
- Lemon grass Oil*
- Linseed Oil
- Malic Acid*
- Mint* and Mint Oil*
- Peppermint* and Peppermint Oil*
- 2-Phenethyl Propionate (2-phenylethyl propionate)
- Potassium Sorbate
- Putrescent Whole Egg Solids (See 180.1071)
- Rosemary* andRosemary Oil*
- Sesame* and Sesame Oil*(includes ground Sesame plant stalks) (See 180.1087)
- Sodium Chloride (common salt)*
- Sodium Lauryl Sulfate
- Soybean Oil
- Thyme* and Thyme Oil*
- White Pepper*
- Zinc Metal Strips (consisting solely of zinc metal and impurities
* These active ingredients are exempt for use on all food commodities from the requirement of a tolerance on all raw agricultural commodities at 40 CFR 180.1164(d).
FIFRA-exempt Inert Ingredients
40 CFR 152.25(g)(2) provides that in order for a pesticide product to be classified as ‘minimal risk’, they may only contain minimal risk inert ingredients listed in the most current of an EPA list called ‘List 4A Minimal Risk Inerts‘. EPA has updated its’ list of the inert ingredients that are eligible for inclusion in pesticide products under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)’s Section 25(b). These minimal risk inert ingredients are referred to as “4A” under Pesticide Registration.
In 2000, this list was published in the EPA Pesticide Registration Notice 2000-6 as Appendix B: List 4A Minimal Risk Inerts.
Later, EPA’s PR Notice 2000-6 was updated with the statement in yellow highlights: “List 4A,” Minimal Risk Inerts” (Appendix B of this notice) is updated on a continuing basis…”IMPORTANT: The 4A List posted by EPA to this link is dated 12/2002. This is an outdated list and has been significantly revised by EPA.
The most current list of minimal risk inerts is available at www.epa.gov/opprd001/inerts/section25b_inerts.pdf. See also EPA’s webpage on minimum risk pesticides at www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm
In addition to these lists, it is EPA’s policy that “commonly consumed foods” are considered List 4A inerts of minimal concern, even if they are not already included on the list of minimal risk inerts.