Inert Allowance

Is hydrogenated corn oil allowed as a pesticide inert?

By Katherine Rola

Both organic and conventional agricultural practices utilize pesticides to prevent damage and losses due to pests. Due to the restrictions imposed by the Organic Foods Production Act and enforced by the National Organic Program (NOP), many pesticides on the market do not meet the criteria necessary for use in organic production. Pesticide restrictions for organic production relate to the designated function of ingredients in the product, and the ways in which the ingredients are manufactured. OMRI uses the guidelines and allowances for synthetic and nonsynthetic materials provided by the NOP—as well as other regulatory authorities, such as the Environmental Protection Agency (EPA)—to determine if the ingredients are allowed for use in pesticides intended for organic production.

A basic understanding of pesticide products centers on the two types of ingredients they are composed of: active and inert. As defined by the EPA, the term “active” identifies the ingredient whose function it is to mitigate pests, and the term “inert” identifies all other ingredients that impact the product’s performance. Per the NOP regulations, active and inert components in pesticide products are subject to different rules, depending on whether they are considered synthetic or nonsynthetic substances. In 1987, the EPA issued the first Categorized List of Inert Ingredients, which subdivided synthetic inert ingredients into categories of toxicological concern from 1 (toxicological concern) to 4 (minimal concern). Although the EPA no longer updates the list, the NOP still utilizes it and the material identification by name, CAS number, and List number (category of concern). For synthetic inert components, the restrictions are outlined at §205.601(m), indicating that synthetic inert components are allowed as long as they are classified by the EPA as either EPA List 4, or EPA List 3 for use in passive pheromone dispensers only.

In 2002, a new section was added to the Code of Federal Regulations titled “Tolerance exemptions for minimal risk active and inert ingredients” (40 CFR 180.950). It outlined the specific circumstances under which a) commonly consumed food commodities, b) animal feed items, and c) edible fats and oils would qualify as minimal risk active and inert ingredients in pesticide chemical formulations. The 2004 EPA List of Inerts included references for materials conforming to 40 CFR 180.950(a), 40 CFR 180.950(b) and 40 CFR 180.950(c), all three of which are identified as List 4A.

As an example, when evaluating the use of hydrogenated corn oil as an inert, one must consider the process by which it was created. The hydrogenation process uses pressure and a catalyst to force a hydrogen to bond with the fatty acid chains; this process renders the material synthetic. The synthetic status means the inert must be allowed under §205.601(m) if it is to be used in organic production. Given that corn oil is identified by the EPA as a commonly consumed oil, and the EPA List of Inerts specifically includes products derived from hydrogenation, hydrogenated corn oil would indeed be considered allowed as a pesticide inert.

This article was originally published in the winter 2022 edition of the OMRI Materials Review Newsletter.