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pes·ti·cide: Function: noun Inflected Form(s): -s Etymology: pest + -i- + -cide: an agent (as a chemical) used to destroy a pest : ECONOMIC POISON Source: Webster’s Third New International Dictionary, Unabridged. Merriam-Webster, 2002. http://unabridged.merriam-webster.com (3 Aug. 2010).
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Webster’s definition seems, on the surface, quite satisfactory. A pesticide is an agent–such as, for example, a chemical–that is used to destroy pests. Fine. But that expression “as a chemical” should perk up our ears a little. What is the definition of a chemical, in the first place? And what, besides those kinds of pesticides, are also considered pesticides as well? Let us now go to the fount of knowledge on this subject, namely the U.S. Environmental Protection Agency (EPA).It is, after all, the responsibility of this agency to define terms such as the one we are now examining in sufficient detail that anyone who formulates, packages, distributes, applies, or uses anything that might be a pesticide will know if the definition truly applies to them or not.
According to the EPA, the term “pesticide” applies to any substance or mixture of substances intended for (1) preventing, (2) destroying, (3) repelling, or (4) mitigating any pest. The EPA also points out that though the term pesticide is often misunderstood to refer only to insecticides, it applies to herbicides, fungicides, and various other substances used to control pests as well. Furthermore, under United States law, the term pesticide also refers to any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant.
Read through the EPA definition carefully. Notice, as you do, that some of the terms used in that definition are rather broad. Anything that is intended, that is, purposely used, to prevent pests, for example, fits the definition of “pesticide,” but what exactly does that mean? Anything that is intended to destroy pests is included, too; such things seem rather straight-forward, and is the definition we are most familiar with, but it, too, can include unexpected chemicals, materials, processes, and procedures. Anything intended to be used as pest repellents are pesticides, too, and it is important to recognize that if a material is intended to be used to repel pests of any kind, that material meets the definition of a pesticide and therefore falls under the regulatory scrutiny of the EPA and other agencies, federal, state, or local, that are charged with insuring that pesticides are used safely and properly. But… anything that “mitigates” pests?
mit·i·gate Function: transitive verb Inflected Form(s): -ed/-ing/-s Etymology: Middle English mitigaten, from Latin mitigatus, past participle of mitigare to soften, mitigate, from mitis soft, mild +agere to drive; akin to an Old Irish word for soft, and another OI word for smooth, gentle, Sanskrit mayas enjoyment, pleasure, Lithuanian mielas, mylas dear — more at AGENT. 1 : to cause (as a person) to become more gentle or less hostile. MOLLIFY. 2 : to make less severe, violent, cruel, intense, painful : SOFTEN, ALLEVIATE <used opium to mitigate the horrors to which condemned criminals were subjected — Science> <disasters can be, if not prevented, at least mitigated — K.S.Davis> : TEMPER<in the summer the altitude tempers the heat, and in the winter the latitude mitigates the cold — C.W.DeKiewiet> : LESSEN <a sentence of 20 days solitary confinement may be mitigated to 10 days — Naval Orientation> <tends to increase rather than to mitigate these differences in students —General Education in a Free Society> <mitigate the sincerity of what I said — Mary Austin> synonym: see RELIEVE. Source: Webster’s Third New International Dictionary, Unabridged. Merriam-Webster, 2002. http://unabridged.merriam-webster.com (3 Aug. 2010).
Now, that’s about as broad as you can get. The lesson to be learned here seems to be that–as viewed by the EPA–practically anything that is intended to be used, in any way, to target pests, falls under the definition of “pesticide” and is, therefore, subject to its regulatory authority. Still, although that statement is essentially correct, it happens that common sense clearly leaves certain things — such as soaps and cleansers whose sanitary properties obviously “mitigate” pests in the broadest sense — out of that definition. Every common ordinary household cleansing solution on the market wipes away the grime, dirt, fecal matter, webbing, pheromones, etc., left behind by pests and later used by them and their predators, yet the manufacturers of those household cleansers are not required to register them as pesticides unless they are sold for the express function of preventing, destroying, repelling, or mitigating pests. Furthermore, and perhaps even more telling, the EPA has actually chosen to exempt certain substances from regulation and registration under its authority.
For example, drugs used to control diseases of humans or animals (such as livestock and pets) are not considered pesticides; such drugs are still regulated, but not by the EPA. Instead, they are regulated by the Food and Drug Administration.
Furthermore, fertilizers, nutrients, and other substances used to promote plant survival and health are not considered plant growth regulators and, on that basis alone, are no classified as pesticides.
Also, biological control agents, except for certain microorganisms, are exempted from regulation by EPA. (Biological control agents include beneficial predators such as birds or ladybugs that eat insect pests.)
Perhaps most importantly, products which contain certain low-risk ingredients, such as garlic and mint oil, have been exempted from Federal registration requirements, although State regulatory requirements may still apply. A list of ingredients which may be exempt, and a discussion of allowable label claims for such products, is provided in EPA’s Pesticide Registration Notice 2000-6, “Minimum Risk Pesticides Exempted under FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act) Section 25(b)”
So, what are these minimum risk pesticides? The following list includes the active ingredients which, according to the EPA, may be in minimum risk pesticide products that are exempted under section 25(b) of FIFRA:
1. Castor Oil (U.S.P. or equivalent)
2. Cedar Oil
3. Cinnamon* and Cinnamon Oil *
4. Citric Acid*
5. Citronella and Citronella Oil
6. Cloves* and Clove Oil*
7. Corn Gluten Meal*
8. Corn Oil*
9. Cottonseed Oil*
10. Dried Blood
11. Eugenol
12. Garlic* and Garlic Oil*
13. Geraniol
14. Geranium Oil
15. Lauryl Sulfate
16. Lemon grass Oil*
17. Linseed Oil
18. Malic Acid*
19. Mint* and Mint Oil*
20. Peppermint* and Peppermint Oil*
21. 2-Phenethyl Propionate (2-phenylethyl propionate)
22. Potassium Sorbate
23. Putrescent Whole Egg Solids (See 180.1071)
24. Rosemary * and Rosemary Oil*
25. Sesame* (includes ground Sesame plant stalks) (See 180.1087) and Sesame Oil*
26. Sodium Chloride (common salt)*
27. Sodium Lauryl Sulfate
28. Soybean Oil
29. Thyme* and Thyme Oil*
30. White Pepper*
31. 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).
Almost all of these 31 ingredients are natural materials, and most are essential plant oils, derived from herbs or spices of one kind or another. Dried blood (item 10 in the list), and putrescent whole egg solids (item 23) are obvious exceptions that are derived from animal-based sources. Sodium chloride (item 26) and zinc metal strips (item 31) are obvious exceptions that are derived from minerals and metals. Others, including 2-Phenethyl-propionate (item 21) are easily produced synthetically, though the synthetic form is essentially identical to that found in nature.
It is important to note that, although the items are listed as exempt from EPA regulation under FIFRA 25(b), they may still be subject to state and local regulation and registration. Even though a product, intended to be used as a pesticide, is formulated entirely with materials on this list, the formulator may still have to register that product in the state or local area where it is intended to be sold and used. Furthermore, as long as the formulation is intended to be used as a pesticide, under any of the definitions described above, the label used for that formulation must meet a strict standard prescribed by the EPA. Failure to follow the guidelines established by EPA in this regard can lead to fines and other penalties.