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. 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). 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.