Skip to content

EPA List 3 Inerts (2023 Sunset Crops)

Sunset Survey

This survey is administered by the Organic Trade Association to assess the necessity/essentiality of substances used in organic production and processing that are undergoing NOSB Sunset Review. The information collected will be passed along to NOSB via the Organic Trade Association’s comments. Please do not include any confidential businesses information. For more information please visit OTA.com/NOSB.

This survey is for the substance EPA LIST 3 INERTS (for passive pheromone dispensers)
Allowed for use only in passive pheromone dispensers used for insect management, either to trap and monitor insect populations or to control a pest through pheromone mating disruption. §205.601(m)
1.Is your operation certified organic?
2.Are Passive Pheromone Dispensers containing EPA List 3 Inerts included in your organic system plan?
3.Which types of organic products do you produce using Passive Pheromone Dispensers containing EPA List 3 Inerts ? (e.g., fruit trees)
4.What function does Passive Pheromone Dispensers containing EPA List 3 Inerts provide and why is it necessary? (e.g., to control a specific pest or disease, etc.)
5.With what frequency does your operation use Passive Pheromone Dispensers containing EPA List 3 Inerts? (e.g., seldom, as needed when a certain condition arises, routinely, etc.)
6.Have you tried using any other substances as an alternative to List 3 inerts in Passive Pheromone Dispensers? (e.g., other substances that are on the National List and/or other natural substances)
7.Are there any other management practices that would eliminate the need for Passive Pheromone Dispensers containing EPA List 3 Inerts ? (e.g., mechanical or physical practices; alternative harvest or storage practices).
8.How would your organic production be impacted if Passive Pheromone Dispensers containing EPA List 3 Inerts were no longer allowed? (describe the agronomic, environmental or human health effects, product quality, economic effects)
9.On a scale from 1 to 5 stars, rate the overall necessity of Passive Pheromone Dispensers containing EPA List 3 Inerts  for your organic operation:
Unnecessary (don’t need it at all)
Neutral (nice to have but could live without it)
Critical (would leave organic without it)
10.You are strongly encouraged to submit your own comments by Sept 30th directly to the NOSB via Regulations.gov.

If you would like assistance or guidance in submitting comments to NOSB, please contact Johanna Mirenda at jmirenda@ota.com or provide your contact information below and OTA will contact you directly.