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GroundKprs
01-25-2005, 12:40 PM
This topic was brought up in another thread, and should really have a heading all its own. In a discussion of what pesticides can be used without regulation, both in the formulation and use of such products, muddstopper introduced the FIFRA 25b list at: http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm. This is a list of products that the EPA has exempted from requiring registration to sell as pesticides.

So the EPA allows these to be produced as pesticides, with minimal regulation on how the products can be labeled.

But then comes the question: Can you use these products in the sale of a lawn care program? The answer, of course, depends on your own state pesticide regulatory authority. Besides obtaining an EPA registration number or exemption, pesticides must be approved by each state for use within their borders. In addition, each state regulates the commercial applicators of pesticides.

In Indiana, the state regulator is the Office of the Indiana State Chemist, OISC (http://www.isco.purdue.edu/pesticide/index_pest1.html). This is the take on 25b:
3) Do State governments regulate these exempted pesticide products?
Yes, Indiana and many other states continue to regulate these products. The FIFRA section 25(b) exemption is for Federal registration only. (emphasis was used on the department notice (http://www.isco.purdue.edu/pesticide/fifra_section_25b_products.html)).

I searched the Indiana pesticide database (14,050 products) for the first 5 on the 25b list. The only one registered in IN was citronella, and of the 23 products, only 4 did not have EPA numbers. They are used for repelling insects, and are general merchandise, not items marketed to commercial applicators.

Also of concern, what does your state regulatory office say on use of unregistered products by commercial applicators? Remember, states regulate people using pesticides, not just registered pesticides. An operator using boiling water to control fire ants was fined and put out of business; the water was being used as a pesticide, and he was not licensed to apply pesticides.

It just appears that 25b is a recourse to allow product to be available to fringe organics enthusiasts. And these products are marketed for personal use, not for commercial use. Where is the commercial direction that is supposed to be the basis of this forum?

So, again, I learn a lot, but I learn nothing to help me sell an organic lawn care program. Can someone please reveal what organic pesticides he uses legally in his organic lawn care program? Please forget CGM, because use of CGM at the recommended dosage is culturally abominable in my cool season turf area.

muddstopper
01-26-2005, 01:01 AM
At the risk of getting into a peeing contest.
I would think that if you had a pesticide license then any of the 30 or so organics listed in 25b could be used in a legal pesticide business. Even in Indiana. The main thing is that you cant misrepresent the products.

Criteria 4: The product must not make public health claims. For example, the label may refer to controlling ticks or mosquitoes, but may not in any way refer to or claim to prevent any specific disease carried by those pests, such as Lyme disease, encephalitis, or West Nile Virus.

These products are manufactored and packaged for commercial use. The exemption has been applied for and recieved, thats why they are on the list.

4. Can other substances be added to the active ingredient list?
It is possible, but the U.S. EPA would require information adequate to demonstrate minimal toxicity and risk, which the Agency could review and evaluate. Also, since these minimal risk active ingredients are in the Code of Federal Regulations, the Agency would have to undertake a rule-making process requiring public notice and comment to amend 40 CFR to add new substances

It just appears that 25b is a recourse to allow product to be available to fringe organics enthusiasts. And these products are marketed for personal use, not for commercial use. Where is the commercial direction that is supposed to be the basis of this forum?

Last time I looked at Wally world, most of the chemicals you use in a commercial business could also be purchased for personal use by the "fringe chemical enthusiasts".

You ask where is the commercial direction in this forum. Well everytime a commercial person gets on this forum they are automaticly attacked and ridiculed by the chemical operators. They try to give information and someone starts cutting them down with insults and crys of snakeoils. Now just how long would you stay at a forum if everyone here started attacking every word you posted. I am not a lawn care business, I dont do chemicals or organics. I am greatly interested in the organics which is why I visit this forum. I have also searched a lot of other sites and think the organics will soon be the big money maker in lawn care. But its not going to work the same way the chemical lawn care does. I think that scares a lot of chemical operators. Those that dont want to change the way they do business.

trying 2b organic
01-26-2005, 05:26 AM
Great news. I just signed 2 HOA contracts because they heard that I used alternatives to traditional pesticides. In the hardscapes I will be using horticultural vinegar. For the lawns I will focus on cultural methods incl organic fert, aeration and overseeding. They have adjusted their pest threshold level for the lawns accordinly and are happy to pay extra for my knowledge and ability to help them. They are old and worried about their pets and visiting grandkids based on what various levels of governments here are telling them about traditional pesticides.

Canadian law states: vinegar is on the exempted list so u dont need a licence to apply it. ( i am in fact licenced) and 2. you cant use the no-name brand horticultural vinegar (my supplier has it) It has to be Ecoclear horticultural vinegar because only this has been listed as an approved pest control product. It has been studied, the company has paid for the study and govt approval proccess.

Similarly, I get no name Corn Gluten Meal from a supplier. I can only sell this as organic fertlizer with side effects. (the side effects are it may inhibit growth of annual weeds. If I buy Turfmaize brand C.G.M. I can sell it as organic weed and feed since again, the company has paid for the study and the registration as a herbicide.

our exempted list has been updated and includes these and others. dormant oil, BTK, and others.

timturf
01-26-2005, 08:17 AM
Although my knowledge of pesticide laws is some what limited, I was UNDER the impression a license pesticide appliactor MUST obey the label, and follow all instructions.

timturf
01-26-2005, 08:23 AM
This topic was brought up in another thread, and should really have a heading all its own. In a discussion of what pesticides can be used without regulation, both in the formulation and use of such products, muddstopper introduced the FIFRA 25b list at: http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm. This is a list of products that the EPA has exempted from requiring registration to sell as pesticides.

So the EPA allows these to be produced as pesticides, with minimal regulation on how the products can be labeled.

But then comes the question: Can you use these products in the sale of a lawn care program? The answer, of course, depends on your own state pesticide regulatory authority. Besides obtaining an EPA registration number or exemption, pesticides must be approved by each state for use within their borders. In addition, each state regulates the commercial applicators of pesticides.

In Indiana, the state regulator is the Office of the Indiana State Chemist, OISC (http://www.isco.purdue.edu/pesticide/index_pest1.html). This is the take on 25b:
3) Do State governments regulate these exempted pesticide products?
Yes, Indiana and many other states continue to regulate these products. The FIFRA section 25(b) exemption is for Federal registration only. (emphasis was used on the department notice (http://www.isco.purdue.edu/pesticide/fifra_section_25b_products.html)).

I searched the Indiana pesticide database (14,050 products) for the first 5 on the 25b list. The only one registered in IN was citronella, and of the 23 products, only 4 did not have EPA numbers. They are used for repelling insects, and are general merchandise, not items marketed to commercial applicators.

Also of concern, what does your state regulatory office say on use of unregistered products by commercial applicators? Remember, states regulate people using pesticides, not just registered pesticides. An operator using boiling water to control fire ants was fined and put out of business; the water was being used as a pesticide, and he was not licensed to apply pesticides.

It just appears that 25b is a recourse to allow product to be available to fringe organics enthusiasts. And these products are marketed for personal use, not for commercial use. Where is the commercial direction that is supposed to be the basis of this forum?

So, again, I learn a lot, but I learn nothing to help me sell an organic lawn care program. Can someone please reveal what organic pesticides he uses legally in his organic lawn care program? Please forget CGM, because use of CGM at the recommended dosage is culturally abominable in my cool season turf area.

Very good points jim, and I fully agree!

Again, we're talking about HOW a license pesticide applicatorcan use an organic program! The discuss really isn't if it will work, but is it legal, econmical, and provide the results clients expect!

GroundKprs
01-26-2005, 08:34 AM
If someone doesn't want a peeing contest, then keep it in your pants and provide some positive answers. We don't need anyone else "thinking" about how laws are applied in each state.

Read the last paragraph of my post ,and the same on timturf's post. And give a positive answer or go argue on another thread.

Note from T2BO's post that Canadian companies have produced properly registered and labeled products to be used in commercial applications. Where are similar legal products here in the USA today?

woodycrest
01-26-2005, 10:19 AM
Isnt the root of an organic program to not use (or reduce the use of)pesticides?
whether they be organic or synthetic or registered or legal.

Pardon me for my persistence , but an organic program is all about producing a healthy, thick stand of turf, that is resistant to disease, and a healthy thick stand of turf will choke out weeds without the need for pesticides.

In the real world, application of pesticides may be required from time to time to control weeds or insect problem or whatever... in that case a certified applicator could apply his pesticide of choice. So logically it would follow that he would use a legal,registered pesticide that he would normally use in a non-organic(or mainstream) situation.

Now, that wouldnt make a 100%organic program...so what!!! Life goes on.
I really doubt that there is a 100% organic commercial program out there in the market place.

So, the LCO could advertise an 'organic' program with a footnote that application of pesticides may be required from time to time to control outbreaks of weeds or insects or disease problems.

So.... this would satisfy what Tim said..."Again, we're talking about HOW a license pesticide applicatorcan use an organic program! The discuss really isn't if it will work, but is it legal, econmical, and provide the results clients expect!''

So if we assume an organic program works...and that the 'as required' use of pesticides(which are legal and registered)was required to meet the clients expectations. THis eliminates the problem of using high priced 'questionable' , 'not necessarily effective' organic 'pesticides' ,and all the legal ramifications that goes along with them.

So the term 'bridge' program would apply here.

timturf
01-26-2005, 11:32 AM
woodycrest]Isnt the root of an organic program to not use (or reduce the use of)pesticides?[/COLOR]
whether they be organic or synthetic or registered or legal.

Pardon me for my persistence , but an organic program is all about producing a healthy, thick stand of turf, that is resistant to disease, and a healthy thick stand of turf will choke out weeds without the need for pesticides.

In the real world, application of pesticides may be required from time to time to control weeds or insect problem or whatever... in that case a certified applicator could apply his pesticide of choice. So logically it would follow that he would use a legal,registered pesticide that he would normally use in a non-organic(or mainstream) situation.

Now, that wouldnt make a 100%organic program...so what!!! Life goes on.
I really doubt that there is a 100% organic commercial program out there in the market place.

So, the LCO could advertise an 'organic' program with a footnote that application of pesticides may be required from time to time to control outbreaks of weeds or insects or disease problems.

So.... this would satisfy what Tim said..."Again, we're talking about HOW a license pesticide applicatorcan use an organic program! The discuss really isn't if it will work, but is it legal, econmical, and provide the results clients expect!''

So if we assume an organic program works...and that the 'as required' use of pesticides(which are legal and registered)was required to meet the clients expectations. THis eliminates the problem of using high priced 'questionable' , 'not necessarily effective' organic 'pesticides' ,and all the legal ramifications that goes along with them.

So the term 'bridge' program would apply here.

I normally consider bridged or fortified in reference to a organic fertilizer which has a synthetic fert, or maybe even a natural fertilizer added!

So, are you saying use the best of both worlds! Organic and synthetic?

woodycrest
01-26-2005, 12:31 PM
Yes, Tim, it only makes sense.

I understand that bridged refers to the fertilizer, but i couldnt think of a better term.

you put it right though..''the best of both worlds''. :)

Suppose a customer doesnt want pesticides, so he doesnt get them. And he may have weed, insect and disease, that is his choice. Maybe 'organic to him means just having a green yard and getting his grass cut.

I maintain that simple basic cultural practices is what makes an organic program...so fertilizing(your fertilizer of choice),proper mowing,proper watering and NO PESTICIDES (''exempt'' or otherwise). THere will be weeds and maybe the turf wont be the greenest on the block, but that is the nature of an organic lawn.

GroundKprs
01-26-2005, 01:26 PM
Woody, you are suffering from a severe case of common sense!!

The problem is that organic enthusiasts equate pesticides and chemical fertilizers with poisons. I have seen it so many times here, and other places, that it is stated, "Pesticides kill the microbes" and "Chemicals (including chemical fertilizers) poison the soil." While some chemicals do have some negative effect on soil life forms, not all have the same effect. But the arguement is always that chemicals and pesticides should be abolished. Common sense is apparently not a part of the organic equation.

All I am asking is how to operate 100% organically and legally. Seems the only real organic answers are to operate outside the law or deceive the client that you are not using "pesticides" or "chemicals."

woodycrest
01-26-2005, 02:14 PM
naw..must be the wind chill...my brain is going numb. :)

timturf
01-26-2005, 04:07 PM
naw..must be the wind chill...my brain is going numb. :)

I knew it was too good to be true!

muddstopper
01-26-2005, 06:31 PM
If someone doesn't want a peeing contest, then keep it in your pants and provide some positive answers. We don't need anyone else "thinking" about how laws are applied in each state.

Read the last paragraph of my post ,and the same on timturf's post. And give a positive answer or go argue on another thread.

Note from T2BO's post that Canadian companies have produced properly registered and labeled products to be used in commercial applications. Where are similar legal products here in the USA today?

Maybe you shoud go back and re-read my post and re-read t2bo's post again. The organics are being properly labled in the US as well as Canada. The problem is that everyone is looking for a cheaper product. In a lot of cases the same feed that is bought for cattle is the same material that is being labled. The high price of the label is the only difference it the two products. That is why they are looking at cattle feed and such to use for pest control. When using feeds they probably wouldnt be legal but using the labeled organics they would be. Why dont you try calling the phone number that is listed in the other thread and ask them.

And the way you replied to my post is exactly the reason why the organic commerial people are not posting at this site. So put yours back in your pants.

GroundKprs
01-26-2005, 07:25 PM
Maybe you shoud go back and re-read my post and re-read t2bo's post again. The organics are being properly labled in the US as well as Canada. The problem is that everyone is looking for a cheaper product. In a lot of cases the same feed that is bought for cattle is the same material that is being labled. The high price of the label is the only difference it the two products. That is why they are looking at cattle feed and such to use for pest control. When using feeds they probably wouldnt be legal but using the labeled organics they would be.

Most of the thoughts above about cheap and different labeling is again just doublespeak to cloud the issues.

But, I'll try to ask this simply and non-confrontationally. Please name the USA organic pesticides that are registered and labeled like the ones in Canada mentioned by T2BO. He was not discussing exempt items, but organic items duly researched and registered as pesticides. Note he has to use certain brands that have gone thru the approval process, if he is using them as herbicides.


Just name them. Don't need a bunch of verbiage, excuses, explanations or arguement. Just names of registered organic products.

woodycrest
01-27-2005, 11:57 PM
Woody, you are suffering from a severe case of common sense!!

The problem is that organic enthusiasts equate pesticides and chemical fertilizers with poisons. I have seen it so many times here, and other places, that it is stated, "Pesticides kill the microbes" and "Chemicals (including chemical fertilizers) poison the soil." While some chemicals do have some negative effect on soil life forms, not all have the same effect. But the arguement is always that chemicals and pesticides should be abolished. Common sense is apparently not a part of the organic equation.

All I am asking is how to operate 100% organically and legally. Seems the only real organic answers are to operate outside the law or deceive the client that you are not using "pesticides" or "chemicals."

You got me thinkin' here...

THe way to operate legally ,and100%organically would be as i suggested, basic cultural practices.

So the program would go something like this....topdressing(with compost.. cant get much more' 'organic'than that) and overseeding, aerating,mulch mowing, proper watering, and amending the soil(aka 'fertilizing'). Simply eliminate 'chemicals' from the equation.

I wonder too if a rural market would be more tolerant of not having the 'perfect' weed free lawn, than an urban or commercial situation.

oh yeah and for the extreme organut customers.. only push reel mowers...no power equipment allowed... :p

trying 2b organic
01-28-2005, 03:58 AM
Ill be honest, i havnt read every word. Just a quick point, it is very complicated but the organic pesticides I mentioned are on the provincial exempted list. I can never get into it enough to care to prove stuff, Ill just tell you what I know. (no way im going through the 3 levels of Canadian govt websites to dig out the various pieces of legislation)

So what does that mean? The Canadian govt had tried to respond to the fact that many large cities in Canada have banned pesticides. (technically its restricted cosmetic use but lets not get technical, for our purposes its a ban) The have fast tracked registraion of "alternatives" and put these alternatives on exempted lists so we can use them without a licence. Legally, as part of a service or business.

Now, as noted above, its not a free for all. All the products I use have to be registered, even the organic fert I use (Sustain is one) has to have the analysis on it and be a product manufactured and sold as a lawn fertilizer. Its just standard stuff to keep people from b.s'ing folks. Otherwise I could go to the feed store and use rabit food as once suggested on this site. (its alfalpha but all sorts of additives could be in it)

I now have a licence and operate an IPM company. I could however, and may in the future operate and organic lawn care company without a pesticide applicators licence using. Ecoclear (non-selective broadleaf) Topgun (same but fatty acid not vinegar) Turfmaize (corn gluten meal, organic weed and feed). Thats pretty much it for legal, registered, no lincence req. pesticides for turf.

quick edit, of course I dont use non-selectives in turf. I tried using a weed stick and brushing it on the leaf only but it still killed a yellow spot of grass around the weed and looked bad.

Norm Al
01-30-2005, 10:58 AM
a 25b product has to be "labeled as to its use" and registered with the particular state as to its use!

a jar of sesame oil would not be labeled and registered as a pesticide,,,,so for a licensed applicator you would be illegally using a product for a pesticide use!


just because the epa doesnt make a company register a particular prduct because it has deemed it as not worthy/needed of their efforts,,,,,you still have to meet requirements as outlined by them and the state for that product to qualify for use by professionals!

YardPro
01-30-2005, 11:24 AM
lol
i get a big kick out of these arguments.

the problem with the organic alternative is better, is that some of the most poisonous chemicals are organic.

vinigar was one example used above. it is merely acetic acid.
why not just get some acetic acid, or hydrochloric acid for that matter . it will be alot cheaper.

also use any acit on hardscapes for a while and you'll have discoloration in those areas .
here's a quote from the MSDS of acetic acid

"This material is strongly corrosive and causes serious burns. Very harmful if swallowed. Lachrymator."

it is more harmful than roundup.

Grassmechanic
01-30-2005, 02:42 PM
lol
i get a big kick out of these arguments.

the problem with the organic alternative is better, is that some of the most poisonous chemicals are organic.

.

Pyrethrin and rotenone come to mind, not to forget nicotine :dizzy:

jmkr02
02-14-2005, 02:50 PM
Spreading “organics” such as manure in some places is coming under regulation because of water quality concerns and should be.

Then again what is organic about manure from livestock fed hormones and genetically manipulated materials?

Dchall_San_Antonio
02-21-2005, 12:23 AM
I wish manure was banned as a legal material to spread. If not officially banned, at least ban it in the minds of the participants in this forum. The ONLY valid use for manure that I see is as an ingredient for compost. And after it is composted it must pass at least a smell test to see if it is still manure. Manure stinks and will kill your chances of gaining clientèle.

Here are some organic pesticides from the Green Light company (http://www.greenlightco.com/).
1. Bioganic® Organic Insect Control Concentrate
2. Fire Ant Control with Conserve®
3. Cedarcide® Insect Repellent

Bioganic is a mix of three oils. It is non selective so I don't like it. Conserve (TM) is spinosad, a nerve agent, that kills insects and decomposes very easily. It is created by actinomycetes, a specialized bacterium that is also an indicator in finished compost. Cedarcide is ground up cedar chips from juniper trees in East Texas. I have no opinion on that one.

But I really like the beneficial nematodes under the name Guardian/Lawn Patrol at this website (http://www.hydro-gardens.com/guardian_lawn_patrol_nematodes.htm). These guys work on 250 different pests without hurting the beneficials. These things are raised on pest species as hosts and carry a disease that is very deadly to them. It is a good idea to spray these guys a month before you need them. I sprayed today for next summer's fleas. I used them last year and never had one flea on my dog. This is a first for me. I used to give my dogs the spot treatments and don't have to now. And for reference to adjust seasonality from my area to yours, it is early spring down here. Some trees are budded out and blooming, crickets are chirping, grass is starting to grow on the organic lawns, birds chirping, etc. - all that spring stuff is going on. Wild flowers are just around the corner.

timturf
02-21-2005, 08:05 AM
I wish manure was banned as a legal material to spread. If not officially banned, at least ban it in the minds of the participants in this forum. The ONLY valid use for manure that I see is as an ingredient for compost. And after it is composted it must pass at least a smell test to see if it is still manure. Manure stinks and will kill your chances of gaining clientèle.

Here are some organic pesticides from the Green Light company (http://www.greenlightco.com/).
1. Bioganic® Organic Insect Control Concentrate
2. Fire Ant Control with Conserve®
3. Cedarcide® Insect Repellent

Bioganic is a mix of three oils. It is non selective so I don't like it. Conserve (TM) is spinosad, a nerve agent, that kills insects and decomposes very easily. It is created by actinomycetes, a specialized bacterium that is also an indicator in finished compost. Cedarcide is ground up cedar chips from juniper trees in East Texas. I have no opinion on that one.

But I really like the beneficial nematodes under the name Guardian/Lawn Patrol at this website (http://www.hydro-gardens.com/guardian_lawn_patrol_nematodes.htm). These guys work on 250 different pests without hurting the beneficials. These things are raised on pest species as hosts and carry a disease that is very deadly to them. It is a good idea to spray these guys a month before you need them. I sprayed today for next summer's fleas. I used them last year and never had one flea on my dog. This is a first for me. I used to give my dogs the spot treatments and don't have to now. And for reference to adjust seasonality from my area to yours, it is early spring down here. Some trees are budded out and blooming, crickets are chirping, grass is starting to grow on the organic lawns, birds chirping, etc. - all that spring stuff is going on. Wild flowers are just around the corner.

David,
How do you know that those lawns where fert with organic's?
Lawns will green up earlier if fert with certain sythetic fert, that don't require as much microbes to make nitrogen available to plant! Ex. amm. sulfate (yea, high salt index)

NAT
02-21-2005, 10:31 AM
I can say David that the neemoil is good from greenlight,works good on mites and some fungal plant problems. I want to find corn gluten/organic fert combo for spring .If you know of any in tidewater va Tim let me know.I really ready for somthing new, the barr,dem,prem in the last few years havn't been to great with the amount of rain.The chesepeke bay in my area have dead rivers from the amount of nitrogen run off from farms and companys like chlawn and other landscapers with quick release ferts.bridge products are better than norm products and practicing IPM is the way to go. :D

timturf
02-21-2005, 02:28 PM
I can say David that the neemoil is good from greenlight,works good on mites and some fungal plant problems. I want to find corn gluten/organic fert combo for spring .If you know of any in tidewater va Tim let me know.I really ready for somthing new, the barr,dem,prem in the last few years havn't been to great with the amount of rain.The chesepeke bay in my area have dead rivers from the amount of nitrogen run off from farms and companys like chlawn and other landscapers with quick release ferts.bridge products are better than norm products and practicing IPM is the way to go. :D

Corn gluten, does a poor job on crab, and supplies too much nitrogen for cool season turf in the spring!

Many studies done on run off pollution on turfgrass, results are very little, the problem with the bay is farmers, raw sewge dumping into streams, (bad in DC), and poor sewage plants, many on the bay need upgrades

NAT
02-23-2005, 07:29 AM
I wanted to use something a little different this year ,corn-gluten has some good results .Its bad here ! I work around allot wetland areas and sandy soils and it depletes very fast and thats why slow release works so well and the blanket weed feeds wash away. I work in hoa and clean the ponds which full of excessive trash weeds and then go straight to the bay.What are you using this year for a prem tim?

green_mark
05-28-2005, 10:28 AM
This topic was brought up in another thread, and should really have a heading all its own. In a discussion of what pesticides can be used without regulation, both in the formulation and use of such products, muddstopper introduced the FIFRA 25b list at: http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm. This is a list of products that the EPA has exempted from requiring registration to sell as pesticides.

So the EPA allows these to be produced as pesticides, with minimal regulation on how the products can be labeled.

But then comes the question: Can you use these products in the sale of a lawn care program? The answer, of course, depends on your own state pesticide regulatory authority. Besides obtaining an EPA registration number or exemption, pesticides must be approved by each state for use within their borders. In addition, each state regulates the commercial applicators of pesticides.

In Indiana, the state regulator is the Office of the Indiana State Chemist, OISC (http://www.isco.purdue.edu/pesticide/index_pest1.html). This is the take on 25b:
3) Do State governments regulate these exempted pesticide products?
Yes, Indiana and many other states continue to regulate these products. The FIFRA section 25(b) exemption is for Federal registration only. (emphasis was used on the department notice (http://www.isco.purdue.edu/pesticide/fifra_section_25b_products.html)).

I searched the Indiana pesticide database (14,050 products) for the first 5 on the 25b list. The only one registered in IN was citronella, and of the 23 products, only 4 did not have EPA numbers. They are used for repelling insects, and are general merchandise, not items marketed to commercial applicators.

Also of concern, what does your state regulatory office say on use of unregistered products by commercial applicators? Remember, states regulate people using pesticides, not just registered pesticides. An operator using boiling water to control fire ants was fined and put out of business; the water was being used as a pesticide, and he was not licensed to apply pesticides.

It just appears that 25b is a recourse to allow product to be available to fringe organics enthusiasts. And these products are marketed for personal use, not for commercial use. Where is the commercial direction that is supposed to be the basis of this forum?

So, again, I learn a lot, but I learn nothing to help me sell an organic lawn care program. Can someone please reveal what organic pesticides he uses legally in his organic lawn care program? Please forget CGM, because use of CGM at the recommended dosage is culturally abominable in my cool season turf area.

Your grasp of this subject matter is tremendous! I have been fighting this battle with the EPA for years.

After butting heads for many years we ended up in a Federal Court. In my opinion they used the FIFRA Act sec (25b) as a bait to find small companies with potential and then destroy them. I was right.

It was not their desire to end up in a Federal Court. I was told by them that appealing to an outside court was not a option and that I was to sign a confession, pay my fine and they would then decide how long I should be imprisoned.

For other examples of people being imprisoned by the EPA join the National Federation of Independent Businessmen www.nfib.org They fight for all of us. Here is an example of what has happened to other businessmen. http://www.mybusinessmag.com/fullstory.php3?sid=1091

I studied the EPA law on the cornel web site and learned my rights. I prepared the case and had my lawyer present it. At the end the law clearly turned out to be a trap for small companies to be "weeded" out and destroyed before being able to make a place for themselves in the marketplace.

Over the 20 years I have been constantly attacked on both the State and Federal levels for what they considered to be crimes committed against the "People". I use this word because it is how they phrased it. Ask yourself, what other form of government uses that phase, and then look around.

Yes, we are not in the land of the free. We are not in a democracy. We have two parties that we vote for and fight for. We watch them throw stones at each other and we take sides and continue the fight. All the while those who truly run this government sit back and laugh. (Now you think, I must be a lunatic) Maybe so. I have been fighting with the "real" government for years. This hidden party is called the "Bureaucrats". They are not elected. No party has control over them. They don't answer to anyone.

I involved family friends in both parties. Senators, State Representatives and the like to defend me. When the meetings finished where I was trying to get justice the ones truly in charge took me aside a few days later in what they called an effort to mend fences and they informed me that I had made a serious mistake. The statements that followed made things very clear. "We are here for life. They are only here until the next election. We get paid everyday to lobby for our cause and we get both parties to give us powers, one at a time, slowly. No one even knows what we are doing. We are patient."

Last fall I was issued an "Administrative" search warrant. This warrant had my name spelled incorrectly, business name was wrong, address was wrong. It stated that they were here to search for "Possible crimes that may have been committed!" Interesting. I told them of the errors in the service and that the last time I checked we still flew the "stars and stripes" They said it does not apply to them. That they actually are above the constitution and it no longer applies to them.

They investigated all day and found nothing. They then said we are coming back to me the next day with a new search warrant for my house. I asked why and they said it was because they knew I had to have hidden the documents proving the crimes they were looking for there. I then lost my temper and told them lets not wait for tomorrow lets go now! Because if I was doing something I would have destroyed what they were looking for by morning.

Upon seeing my reaction they apologized and said we are only the pawns and to calm down. After that we had a nice conversation about who was really running things at the department. I then told them that when (a specific person) grew a pair of balls he could muster the courage to show up himself as long as I could have the media present to ask him a few questions.

That was the end of that! It has been 8 months since that date and now I have unprecedented cooperation from both the EPA and the State. This was due to the success with Federal Court case and my resolve with the state to bring in the media if this continued. (interesting comment I got from the dept head. He said "there is no need to get nasty here")

We now enjoy a new relationship that is blossoming into something good that will and is starting to spread across the industry.

When you are in contact with these people be very careful and respectful while they are doing what they want. Get a personal small recorder and place it on yourself. Make sure they know they are being recorded. Make sure they know it is for your lawyers use to aid him in understanding what exactly is occurring here.

When we have done that they leave, immediately! Make sure to be respectful and not lose your temper as I did. Mine was well placed and valid and I quickly calmed down and told them I did not hold them responsible for what they were being forced to do by their superiors.

Is this a bit mellow dramatic? From an outsiders point of view? Absolutely! From my staff's point of view who has seen this up close? No!

If you desire to use the FIFRA ACT'S exemption classification status don't be making products out of the back of your garage. Make your labels, submit them to your local state Dept of Ag and make sure they sign off on it.

Once this is done are you protected? No! The federal EPA can look at what the state told you and fine and/or jail you.

This is part and parcel of the "set up". Once you have written, not verbal approval then email them to go to the EPA and have them provide you with their approval. Once you have this keep all the correspondence in a safe off site. Preferably in a bank.


These documents are the only thing between you and fines and/or jail. If you get into these problems let me know ASAP! I will do what I can to guide you to the right people for help. I am not a lawyer and cannot represent you but I can help you as "free advice".

I have 5 products that have this trail of written acceptance from the EPA and State departments. We don't want a war but we do have our ducks in a row and are poised and ready for any trouble.

Sorry about the extensive detail. I just don’t want anyone else to go through what I have

naturesdesign
08-10-2005, 09:36 AM
I dont know if this helps but in Canada I tried to find out the same as you are. I was nicely informed that there is nothing organic on the market that kills weeds completely. The weeds are put in a dormant state and if you stop using what your using they will come back. So organically from what I understand there is nothing available.

naturesdesign
08-10-2005, 10:29 AM
I read you comments about vinegar and the Canadian Law. I live in Ontario and according to M of E you need a licence to apply Vinegar. Maybe not in BC. Abit of misdirection there I believe. Also in Ontariio if you are in the business of weed/pest control organic or not you need a licence.

Soil Humic
10-03-2005, 01:53 PM
An opinion on Organic versus In-Organic, Pyrethrums, rotenone and nicotine from a PhD Physiologist.

Well I know it’s a huge leap in faith for all you boys that have been using chemicals as part of your business all these years, to switch to an organic program. And it does not help that some companies making so called Microbial Soil Conditioners, Chicken poop fertilizers etc., are so unprofessional in their methodology, science and so forth. But consider this: I own two company’s in New Mexico, one involved with growing trees for urban horticulture and the other a Pharmaceutical lab/manufacture of Organic Soil Restoration products; In addition to being a Dr. of Physiology and Bio-Chemistry. With my Tree Farm, we are and have been for 20 years, totally organic. Our farm is the only nursery/farm in all of New Mexico, Arizona, Colorado, Texas, Oklahoma and Utah, that can ship trees to any western state without needing a chemical drench of the root ball to prevent accidental transport of exotic insects such as Japanese Beetle or Fire Aunts. We have exceeded all the JB Harmonizing agreement for the cooperating Western States and we have done so without ever using any chemical that is neither USDA NOP or OMRI approved on certified organic farms. We never use In-Organic NPK fertilizers, using only Soil Secrets Products for Soil Restoration, Microbial Inoculation and Plant Nutrition. We produce Oaks from seed to 3 inch caliper in a three year growing cycle and do so without pushing with excess nitrogen.

Second point: The human body has not and never will adapt to the chemical deluge that we expose it to with all these agricultural chemicals you are using. Cancer rates are sky rocking along with Autoimmune disorders and Learning Disabilities. Do you choose to expose you and your family’s health and risk for cancer because of your occupation? I don’t! And I can tell you with absolute certainty that these chemicals you have so much faith in, will haunt you in at some point in the future. Did you know that one of the highest risk professions for cancer is the Golf Course Supers and Workers? Guess why!

Third point: Certainly Pyrethrums and other organic approved chemicals can also be dangerous, but the half life or natural decay of these chemicals is short. They don’t persist in compost, soils or your body’s fat like the In-Organic chemicals you typically see being used. And they don’t show up in Bio-magnification in the food chain, which the other chemicals will do.

In conclusion, we have a moral and ethical obligation to our clients, family members and ourselves to change. Time is wasting!

Michael Martin Melendrez- Owner
Soil Secrets and Trees That Please
(505) 550-3246

Grassmechanic
10-04-2005, 10:50 AM
:dizzy: :dizzy: :dizzy: :dizzy: :dizzy: talk about an unbiased rant... :rolleyes: :rolleyes: :rolleyes:

ALVW
10-05-2005, 03:17 PM
From an article dated 10/4/2005

Overall, cancer mortality fell 1.5 percent per year from 1993 to 2002 in men, and by 0.8 percent in women during roughly the same time frame, the report found. Death rates declined for 12 of the top 15 cancers striking men, and nine of the top 15 cancers in women.


Lung cancer remains the leading cancer killer for both sexes, according to the Annual Report to the Nation, a collaborative effort by the National Cancer Institute (NCI), the U.S. Centers for Disease Control and Prevention, the American Cancer Society and the North American Association of Central Cancer Registries.


"We are seeing a sustained and continued decline in deaths due to cancer," said report co-author Brenda K. Edwards, an associate director for the surveillance research program at NCI. "The rates for both men and women [overall] continue to go down."


The report appears in the Oct. 5 issue of the Journal of the National Cancer Institute.

NattyLawn
10-05-2005, 05:45 PM
Your blurb mentions nothing about the number of cases, only that people are living longer with cancer.

Grassmechanic
10-06-2005, 08:34 AM
Alright, enough already. This is an excellent thread and it's being trashed like so many others. Start a new thread and we'll gladly debate this topic. As Ric would say "take it to the Orgasmic forum".

LupineLandscaping
01-22-2007, 11:30 PM
In Colorado, if it kills a weed, it's a pesticide. This definately makes things difficult for an lco to operate an oraganic program. I am working on the applicator license currently, but finding an organic product that is licensed in in CO can be another story. I do suggest researching The Green Guardian. They are nice folks there and are confident their products will pass state registration.

I believe we will be forced to go in this direction sooner or later.

Cheers,
Steve

Norm Al
02-04-2007, 10:59 AM
An operator using boiling water to control fire ants was fined and put out of business; the water was being used as a pesticide, and he was not licensed to apply pesticides

i would love to see some proof of this statement. i am pretty sure this is a made up statement!

green_mark
02-06-2007, 09:17 AM
This statement while it has no company name is overall a TRUE statement.

Any product claiming to control, mitigate or repel is a pesticide no matter what product is being used.

The EPA has no interest in the harmless nature of the product. If it is not listed under the exemption clause of the FIFRA ACT SEC 25 (b) as an active ingredient it requires registration.

The use of vinegar...is illegal unless properly labeled. Vinegar is not an allowed active ingredient. Anyone using vinegar to control anything is illegal and can literally destroy your business.

The EPA has no approval process for Exempted products. However, they do have a punitive process once they catch you. Another ideal government agency serving their own existence.