                           WHATS BUGGING YOU?
       How to kill, destroy, expunge, obliterate houseplant pests
                              Diane Martin
                 Harrowsmith Country Life, December 1993

     Most Garneners realize that all manner of bugs are a fundamental part
of nature--as pollinators, recyclers and sources of food for other
animals--and strive for a mutually beneficial coexistence with them. Yet
many of today's safe pest-management practices aren't suited for the indoor
garden. Few of us are eager to introduce a swarm of green lacewings into
our living rooms or to cover our African violets with lloating row covers.
Indoors, we need to kill pests dead (to borrow the slogan created by the
poet e.e. cummings for Raid pesticides). But we also want to get rid ofthem
without harming ourselves, our pets, our plants or the environment.
     Fortunately, there are better and safer ways than using pesticides,
synthetic or natural, to eliminate bugs on indoor plants (see the charts
on pages 74 and 75). Although climatic conditions are ideal, food is
abundant and there are no natural enemies, indoor bugs are at a
disadvantage if you know what you're doing and, just as important, you know
what they're doing. The earlier you notice bugs on your plants and take
care of them, the better your chances of never being tempted to resort to
chemical warfare.
     What to look for? Foliage wilt and yellowing, leaf drop and stunted
growth (which can also indicate improper environmental conditions) are
indicators of pest-infected plants. Other signals of insect problems are
sticky foliage and foliage that is flecked, blotched, stippled or covered
with bumps. Check carefully, for sooner or later everyone encounters one
or more of the five most common houseplant pests: mealybugs, whiteflies,
scale, aphids and spider mites.

MEALYBUGS
     Mealybugs, which prefer to feast on soft-stemmed or succulent plants
and thrive in warmth and humidity, are easy to identify. Their round,
white, furry bodies are about the size of a dill seed and are covered with
a fine granular excretion, or wax, that makes them look as if they were
dusted with flour. They can be found at rest or crawling along stems, on
upper as well as lower leaf surfaces (especially along the veins) and in
the axils, where leaves and stems meet. They also hide in the tips of new
shoots and often cluster together. The citrus mealybug (Plarlococcus citri)
is the most common indoor pest, but there are hundreds of types. Because
mealybugs are soft-bodied insects, they are highly sensitive to temperature
and humidity.
     Females lay between 300 and 600 eggs in conspicuous cottony masses in
protected spots, such as in the angles of stems or midribs of leaves. The
eggs hatch in a week's time, and the emerging nymphs begin feeding almost
immediately on plant sap. Male nymphs pass through a cocoon stage and
emerge with wings and no mouth, dying soon after they mate. After molting
several times, females reach maturity, lay eggs for a week or two and then
die.
     It is the nymphs and adult females that cause most damage to plants,
by piercing leaves, sucking sap and excreting honeydew (a sticky substance
that coats leaves and nourishes black sooty mold, a fungus). Nymphs and
adult females are also the most vulnerable, since in these stages they are
slow-moving and visible.
     Likely victims: African violets, aralias, begonias, cacti and other
succulents, dieffenbachias, dracaenas, ferns, gardenias, grape ivies, jade
plants, philodendrons, pothos.

WHITEFLIES
     Adult whiteiflies, which are unrelated to houseflies, are about the
size of a celery seed, have four broadly rounded wings and are covered with
a snow-white waxy powder that causes them to resemble tiny moths. They
congregate on the undersides of leaves and, when disturbed, fly short
distances, creating small, agitated white clouds. The subtropical
greenhouse whitelly (Trialeurodes vaporariorum) is the most common indoor
variety. Like the mealybug, it is a sucking insect.
     Most whiteflies are primarily parthenogenetic, which means they can
produce off spring without mating. Females lay between 200 and 400 pale
green eggs during their lifetime, leaving them in circular clusters on the
undersides of leaves. Minute six-legged crawlers--flat and colored light
green--hatch in about 10 days. The crawlers attach themselves to the leaves
and begin sucking sap and excreting honeydew, which can foster sooty mold.
They will remain attached to the foliage while they pass through several
scalelike stages from which they emerge as winged adults.
     Adults, which are easily visible, tend to cluster at the tops of
plants and on new growth, especially on shoots that are yellow-green, a
color that attracts the insect.
     Likely victims: Begonias, coleus, fuchsias, hibiscus, peace lilies,
pelargoniums, primulas, poinsettias.
     
SCALE
     There are more than 2,000 species of scale insects; those that attack
houseplants are classified either as soft (Coccidae) or armored
(Diaspididae) scales. Among soft scales are the types most commonly found
on houseplants: hemispherical scale (Saissetia coffeae), black scale (S.
oleae) and brown soft scale (Coccus hesperidum). These foes, which are
recognizable by their hard, turtlelike, gray-brown shells, are oval shaped
and measure between 1/5 and l/4 inch long. Looking like dark bumps on
leaves and stems, soft scales are sucking insects. They secrete honeydew
and flourish and multiply best in warm, hurnid conditions.
     Females lay 500 to 1,000 eggs under their shells. When the eggs hatch,
the young feed on the mother's body until they are ready to venture out and
begin sucking sap from the plant.
     Female offspring shed their shells twice on their way to maturity,
keeping the same form, but males undergo metamorphosls, turning into small,
mouthless, flylike bugs. The males live only three or four days--long
enough to mate--while females can live for almost four months.
     Armored scale species are also covered with hard protective shells,
which are separate from their bodies, but they rarely produce honeydew.
Oysterlike or volcanic in shape, they blend in color with their host plant.
Determining whether your poinsettia is covered with a soft or armored scale
is important only if you're using biological controls. Deciding whether you
have scales or simply bumps on the leaves is more important. Scrape the
spot in question with a knife: if it is a scale, it will lift easily.
     Likely victims: Citrus, cyclamens, ivies, palms, philodendrons,
poinsettias, schefleras, weeping figs.


APHIDS
     Sometimes called plant lice or green flies, aphids are a huge
genus--about 4,000 species--though they are more common in greenhouses than
in living rooms. Even better, only a small percentage of aphids,
approximately 10 percent, attack many different plants; most aphids feed
only on a particular species.
     Still, there are plenty of aphids to torment the indoor gardener: fern
aphids (Idiopterus nephrolepdis) attack ferns; melon aphids (Aphis
gossypii) attack dioscorea and schefflera; mottled arum aphids (Macrosiphum
circumflexum) attack amaryllis, arums, begonias, caladiums and cyclamen.
The type most commonly encountered on houseplants is the green peach aphid
(Myzus persicae), which is also a threat to many agricultural crops.
     Aphids' soft, delicate, pear-shaped bodies are about the size of
sesame seeds and are colored pink, white or yellowish green. Equipped with
long legs, antennae and a set of tailpipelike projections off their backs,
most aphids are wingless and slow moving indoors. They feed on succulent
growth, causing wilting and deformed leaves and buds, and they secrete
honeydew; its shine may be one of the first signs that your plants are
infested.
     Although aphid reproduction is a complicated affair--some females lay
eggs, some give birth to live young, some do both--indoors, aphids usuallv
reproduce parthenogenetically and give birth to live young rather than
laying eggs. That's one reason why they can turn up so quickly on a leaf
that appeared to be aphid-free the day before. Because the offspring stay
close to their mothers, aphids are found in clusters on new growth, flower
buds and the undersides of leaves. Each unfertilized female produces about
50 daughters that mature in approximately a week, ready to become mothers
themselves.
     Likely victims: African violets, arrowhead vines, begonias, caladiums,
cinerarias, chrysanthemums, cyclamens, ferns, gardenias, hibiscus, ivies.

SPIDER MITES
     The first sign of spider mites is usually stippled, yellowing leaves,
the result of the tiny punctures these pests make in order to suck sap from
the plant. Spider mites also spin irregular webs that, in time, can encase
an entire plant. Although related, these are not the beneficial predatory
mites that eat other insects; these mites eat your plants. The two-spotted
spider mite (Tetranychus bimaculatus) is the species found most commonly
on indoor plants. Similarly troublesome, especially on cyclamens, begonias,
grape ivies and African violets, are broad or cyclamen mites
(Steneotarsonemus pallidus), which are much smaller than spider mites,
about one-fourth their size. Citrus red mites, false spider mites and
European red mites also ravage houseplants.
     With a 10-power hand lens, you can identify spider mites: greenish,
pinkish or yellowish elliptical forms with eight legs and two large
blotches on either side of their backs. The female lays between two and six
round, shiny, cream-colored eggs each day. The six-legged baby mites feed
for a daY or two after hatching, then
     begin a series of molts until they reach maturity (8 to 20 days).
Outdoors, twospotted spider mites go through diapause, a resting phase
somewhat like hibernation, but indoors they are active throughout the year.
     True spider mites live in colonies, clustering on mature leaves, and
they prefer dry, warm conditions, exactly the environment provided by many
houses. Misting plants daily or hosing frequently with a jet of water will
break up webs, wash away eggs and suppress their development.
     Likely victims: Aralias, aspidistras, crotons, dracaenas, ferns,
ficus, hibiscus, ivies, palms, scheffleras.

     Diane Martin lives in upstate New York. This article was adaptedfrom
Kill Bugs Dead: An Indoor Gardener's Guide to Eliminating Insects on House
Plants Without Using Harrnful Pesticides (The Scriptorium Press, 1992).

                               THE WEAPONS

     OIL-DETERGENTSOLUTION

     1 cup vegetable oil
     1 Tbsp. dishwashing detergent
     Mix well.
To use, dilute as follows: 1 to 2 l/2 tsp. oil-detergent solution
1 cup warm water. Spray plant thoroughly and let sit for 1 to 2 hours, then
rinse with clear, warm water.

TOBACCO TEA

     1 cigarette or 1 cigar butt or 1 tsp. pipe tobacco 
     1 cup warm water 
     1/4 tsp. olive oil 
     1/4 tsp. liquid soap

Soak tobacco in water for 24 hours.Strain and discard tobacco. Combine
tobacco water, olive oil and soap, and mix well . To use, spray on affected
area of plant and let sit for several hours. Rinse with warm water.

INSECTICIDAL SOAPS

     Insecticidal soaps are commercial preparations based on soaps made
from fatty acids. They are effective only when wet and in direct contact
with the bug. Relatively harmless, they still should be used in careful
compliance with label instructions.
                            HOMEMADE GARDEN SPRAYS




    These 2 recipes are from an episode of The Weekend Gardener TV show. The
first is assumed to be a homemade liquid fertilizer of some kind. The show in-
dicated its use when weather has been particularly hot, if plants are under
stress due to other factors affecting their general health, or as a mid or
late season nutrient boost. The second was offered as a set spray for tomatoes,
which were said not to form blossoms above 90 - 95 degrees F. Whether or not it
would be effective in cooler temperatures or on other types of plants was not
mentioned. It is supposed to interrupt the nitrogen cycle, so the plant will
set blossoms.


GARDEN TONIC

5 gal. bucket
Water
3 pkgs. Unflavored Gelatin
2 c. epsom salts
1 t. Borax (boron)
1/4 c. dishwasher soap (made with vegetable oils, NOT animal fats)

Put gelatin & epsom salts in bucket as you fill it with water, so they will get
dissolved properly. Add borax and stor. Put soap in last (to keep down suds).
Mix well. Use about 2 cups of formula per plant or group of plants. May be
poured directly over foliage and allowed to soak in ground. In 2 - 3 days,
plants and foliage should "perk up".


TOMATO SET SPRAY

1 gal. Water
1 t. sugar

Mix well and spray on plants.
Ä [20] Survnet: SURVIVAL_ORIENTED TOPICS (9:2500/0) ÄÄÄÄÄÄÄÄ SURVIVAL_ORIENTED Ä
 Msg  : 92 of 98                                                                
 From : Brian Sorensen                      9:1992/195      Fri 10 Dec 93 17:04 
 To   : All                                                                     
 Subj : Homemade Garden Sprays                                                  
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Greetings,
  Found this on a Agriculture BBS here in DC.

--------------------------------------------------------------

                            HOMEMADE GARDEN SPRAYS




    These 2 recipes are from an episode of The Weekend Gardener TV show. The
first is asumed to be a homemade liquid fertilizer of some kind. The show in-
dicated its use when weather has been particularly hot, if plants are under
stress due to other factors affecting their general health, or as a mid or
late season nutrient boost. The second was offered as a set spray for tomatoes,
which were said not to form blossoms above 90 - 95 degrees F. Whether or not it
would be effective in cooler temperatures or on other types of plants was not
mentioned. It is supposed to interrupt the nitrogen cycle, so the plant will
set blossoms.


GARDEN TONIC

5 gal. bucket
Water
3 pkgs. Unflavored Gelatin
2 c. epsom salts
1 t. Borax (boron)
1/4 c. dishwasher soap (made with vegetable oils, NOT animal fats)

Put gelatin & epsom salts in bucket as you fill it with water, so they will get
dissolved properly. Add borax and stor. Put soap in last (to keep down suds).
Mix well. Use about 2 cups of formula per plant or group of plants. May be
poured directly over foliage and allowed to soak in ground. In 2 - 3 days,
plants and foliage should "perk up".


TOMATO SET SPRAY

1 gal. Water
1 t. sugar

Mix well and spray on plants.


--- Blue Wave/RA v2.10 [NR]
 * Origin: SurvNet - Powderhorn BBS 202-562-8239 (9:1992/195)

RE:  NOSB COMMENTS ON PESTICIDE RESIDUES IN ORGANIC PRODUCTION.
===============================================================

The following comments were submitted by the Agricultural
Resorces Center (ARC, Carrboro, NC, and several other
organizations to the National Organic Standards Board (NOSB),
created by the 1990 Farm bill to develop national standards for
organic agriculture. Among the questions to be decided are how to
control pesticides that are in the environment but not applied
directly by the organic farmer. The NOSB is considering draft
policies on Emergency Spraying of Pesticides, Pesticide Drift, and
Irrigation Water Quality. The document expresses concern
about the direction that the draft policies seem to be going and
suggests that stronger incentives for avoiding contamination of
organic production with pesticides used in conventional
agriculture or elsewhere is essential for maintaining the
integrity of organic production, protection of the environment,
and confidence of consumers. It is apparent that there are
strong differences of opinion even within the organic community
about what standards are appropriate. Some of them are
philosophical, some are regional, and some are practical. We
welcome responses which support or question the views below as
these standards are developed.


ARC can be reached the following ways:

1) By mail or phone at the following address:

   AGRICULTURAL RESOURCES CENTER
   PESTicide EDucation Project
   15 West Main Street
   Carrboro, North Carolina, 27510
   1-919/967-1886

2) Through Internet E-Mail at following address:
   Allen.Spalt@bbs.oit.unc.edu

3) FidoNet netmail (e-mail) at:
   Allen Spalt, 1:151/502 (EARTH*Net BBS, 1-932-3115)

4) Post a message to Allen Spalt in the FidoNet
   Sustainable Agriculture echo (SUST_AG, Host system: 151/502)




September 11, 1992
Dr. Harold Ricker

National Organic Standards Program
USDA/AMS/TMD
Room 2510-South Building
P.O. Box 96456 Washington, DC  20090-6456


Dear Dr. Ricker:

Please accept these comments concerning proposed
policies on Emergency Spray Exemptions, Pesticide Drift, and
Irrigation Water Quality to the National Organic Standards Board
and its Crops Committee for the meeting on September 17, 1992.
The drafts considered were adopted by the Crops Committee in
August, 1992.   These comments are submitted on behalf of the
Agricultural Resources Center (ARC), Kansans for Safe Pest
Control, the Hazardous Materials Committee of the National Sierra
Club, and the National Coalition Against the Misuse of Pesticides
(NCAMP).  ARC is a private, non-profit, public interest
organization which conducts research and public education on food,
agriculture, and natural resources and, through its Pesticide
Education Project (PESTed), has a special interest in preventing
the misuse of pesticides and promoting least toxic, sustainable
alternatives to chemical pesticides.  Kansans for Safe Pest
Control is a non-profit organization in Kansas devoted to
promoting safe alternatives to hazardous pesticides.  The
Hazardous Materials Committee of the National Sierra Club is
charged with providing expert commentary and policy development on
issues relative to pesticides, hazardous waste, and other toxic
materials.  NCAMP is a national coalition of grassroots groups
concerned with the health and environmental consequences of
pesticides and promoting safer alternatives.  All have long been
involved in supporting organic agriculture and welcome this
opportunity to comment on important matters before the NOSB.


I. GENERAL COMMENTS.

Developing a comprehensive system of organic crop certification
as mandated by Title XXI of the Food
and Agriculture Act of 1990, the Organic Foods Production Act
(OFPA), is an important task.  Defining and implementing "organic"
may be difficult, but it is vital that the regulations reflect the
popular conception that it means no synthetic pesticides or
fertilizers.  Confidence of consumers, producers, sellers, and
regulators in the new national organic label depends on the
overall thrust as well as the fine print.  We believe it is
important that what is controlled in the major provisions not be
undermined by unwarranted exemptions.  If not carefully crafted,
emergency spray, drift, and irrigation water exemptions could
provide major loopholes in an otherwise worthy program.   We
support the comments by Jay Feldman, Executive Director of the
National Coalition Against the Misuse of Pesticides, to the NOSB
at its meeting on July 8, 1992, in Fort Collins, Colorado.
NCAMP's critique of the federal pesticide regulatory system are
particularly important.  The analysis supports the assumptions
which underlie our joint comments on the particular policies in
question here.  NCAMP's conclusion is particularly important.  We
believe that:  "...organic agriculture is of vital importance to
the future of agriculture, the public's health and environmental
protection.  It should be fostered and encouraged.  At the same
time, we feel that it is important that in our desire to support
organic agriculture, we not institutionalize practices that do not
establish the ultimate protections we are seeking....   "The
Organic Foods Production Act provides for an opportunity and a
challenge....[T]here is the challenge of building and maintaining
agricultural systems that are true to a new standard of
environmentalism and safe food--not embodied in previously
established EPA risk standards that are plagued by uncertainties
and miscalculation.  The organic standards established under the
act must be borne out of a non-contamination standard, not simply
a lower toxicity model of production and acceptable pesticide
residues.*  It is the goal, we believe, to encourage through this
act agricultural systems that do not add elements of health risk
to our diet and environmental risk to our planet under any formula
of acceptable risk.  The goal is to define systems of organic
production, rather than accept existing production problems as
unresolvable.  [Jay Feldman, Statement to NOSB, July 8, 1992.  *
Emphasis added.]   We believe the standard of contamination
by prohibited substances which is most appropriate is already
embodied in the Act, in Section 2112(c)(2)(B).  It is the standard
for removal of the organic label if prohibited substances are
present at levels greater than "unavoidable residual environmental
contamination."  We understand this term as it has typically been
used indicates levels similar to EPA's requirement to establish
action levels for residues of banned pesticides, such as
organochlorines.  These levels are unavoidable in the sense of
long-term background rather than those resulting from incompatible
current conventional practices, which should be treated as
chemical trespass.  Deviation from this standard in the context of
organic production should be minimal, rare, accidental,
unintentional, and involuntary.  Any other standard, such as "best
available" or "x percent" of some established legal value
including EPA tolerance levels, perpetuate the conventional
approach of "acceptable" risk, albeit at a lower level of risk,
rather than seizing the opportunity to further a viable, lasting,
organic alternative.


II. COMMENTS ON SPECIFIC POLICIES.


A. Emergency Spray Exemptions (Draft Recommendation #3, August 1992):

The OFPA provides under the section "Discretionary
Requirements" that the the organic certification program "may"
provide "for reasonable exemptions" from requirements if organic
farms are "subject to a Federal or State emergency pest or disease
treatment program".  [2117(b)(2)].  It further provides that the
NOSB "shall" advise the Secretary of Agriculture on rules for
exemptions for farms subject to such spraying.  [2119(k)(6)].
Provisions in the Act for emergency spray
exemptions, therefore, are narrow and permissive.  No specific
exemptions are required, and the Board could recommend that there
be no exemptions.  We believe exemptions should be very limited.
Other mechanisms, such as provisions for "transitional", or
"limited treatment" categories, should be considered as
alternatives to expanded exemptions.   The draft Emergency Spray
policy, however, is too broad and does not propose an evaluative
process consistent with organic methods.  It properly removes
certification from produce which has been sprayed with a
prohibited substance in an emergency.  But it does not adequately
deal with the field where such produce was grown.  Instead, it
proposes an exemption from the requirement that a field exposed to
a prohibited substance cannot be certified for three years.  It
provides that the field "shall not loose its organic
certification" regardless of how serious the exposure may be.  It
allows residue testing "if deemed necessary" and sets a standard
of acceptable contamination of ten percent of EPA or FDA levels.

This policy is flawed for several reasons.

1) No Blanket Exemption.
There should be no blanket exemption from the loss of
certification.  Some exposures from emergency spray treatments may
be so serious an insult to organic production that loss of
certification is warranted.  Providing only for residue testing
during subsequent years is not adequate.

2)  Qualitative Evaluation Needed.
A qualitative evaluation of the emergency
exposure is needed to help determine whether or not certification
of the site should be continued, provisionally continued, or lost.
Evaluation of emergency spray treatments should include
the frequency, duration, and extent of emergency treatments to
which a particular site may be subjected with the recognition that
locations which are repeatedly subjected to emergency pesticide
treatments are not suitable for organic
certification.   For example, limited exposure to emergency
use of a known non-systemic and non-persistent pesticide may not
be sufficient to withdraw certification of the field for
subsequent years.  However, if the emergency spray is with
persistent or systemic poisons or, as is most often the case, if
the health and environmental effects of the pesticides are not
adequately known, then loss of certification is justified, however
harsh.  The policy should not automatically rule out loss of
certification.

3)  Health Based Standard Needed.
A health-based standard appropriate to organic production is needed
for residues.  Ten percent of the EPA or FDA legal limits is an
arbitrary standard that does not provide protection consistent
with the demands of organic agriculture.  In many, if not most
cases, the agency-set standards are an inadequate basis for making
health or environmental judgements as to cleanliness or safety,
are not protective of the most vulnerable parts of the population,
and are not appropriate as a measure for organic certification.
Tolerances are commonly set at residue levels which are expected
after legal applications, a standard that has no relation to
organic production.  It follows that ten percent of an arbitrary
standard is still arbitrary.  It should not be used unless the
produce is labeled, for example, ten percent organic, low spray,
or transition.     A better standard for certification of
subsequent year's produce would be no residue, or no residue above
"unavoidable residual environmental contamination", as discussed
above, of the emergency spray pesticide. That is what consumers expect.

4) Involuntary Treatments Only.
The policy should be explicit that it applies only to emergency
treatments to which the organic grower is required to submit by
Federal or State authorities; there should be no special exemption
for optional or voluntary emergency spray programs.

5) Limited to Treated Areas.
The policy should apply only to emergency spray treatments
on the certified fields themselves.  Drift from nearby emergency
applications should be treated as any other spray drift is
treated.  See comments below on proposed Pesticide Drift policy.

6) Limited to Certain Eradication Programs.
The policy should explicitly state that it covers only Federal and
State eradication programs that also meet FIFRA Section 18
emergency requirements.  Meeting either alone is not sufficient as
not all eradication programs are emergencies and Section 18
registrations are widely used as backdoor loopholes to allow the
use of unregistered pesticides under conditions that do not
constitute actual pest emergencies, no less under conditions
compatible with organic production.



B. Pesticide Drift Policy (Position Paper #4, August 1992):

Many of the comments on the above draft Emergency Spray Exemptions
policy apply to the proposed Pesticide Drift policy.
While a step in the right direction, the proposal does not adequately
protect the integrity of organic production and certification.

1)  Recognize All Sources of Drift.
The draft policy recognizes only nearby  "conventional fields" as
potential sources of pesticide drift.  In fact, pesticides are widely
used on rights of way, forests, parks, golf courses, lawns, areas
subject to emergency spray programs,
and other areas which my be near or adjacent to certified sites.
All potential sources of drift should be recognized.
Notification, as required for conventional fields, should be
required for all reasonably expected sources of drift.

2) No Blanket Exemption from Decertification.
There should be no blanket exemption from the loss of certification.
Some exposures from drift may be so serious an insult to organic
production that loss of certification is warranted.
Providing only for residue testing during subsequent years is not
adequate.

3) Qualitative Evaluation Needed.
A qualitative evaluation of each exposure to drift is needed to
help determine whether or not certification of the site should be
continued or lost. Evaluation of drift should include the frequency,
duration, and extent to which a particular site may be subjected.
As with areas subject to emergency treatments, the Pesticide Drift
policy should recognize that not all sites are suitable for
organic certification.

4) Residue Testing Inadequate:
The proposed "Multi-residue Screen" is inadequate and outdated.
If testing for unknown pesticides is included, it should also
include organophosphates, pyrethroids, phenoxies and others.  Some
pesticides cannot be detected by commonly available screening
tests.  We believe it is inappropriate for unknown pesticide drift
to be accepted as part of an organic certification program.

5) Health Based Standard Needed.  Comments above on the use of EPA
and FDA tolerance standards apply to pesticide drift.  No level of
known drift of prohibited substances above "unavoidable residual
environmental contamination" should be tolerated as "organic".



C. Irrigation Water Quality (Position Paper #5, August, 1992):

The current draft Irrigation Water Quality paper does not
adequately address the question of the use of water contaminated
with prohibited substances and should be substantially revised
before adoption.

1)  Contaminated Irrigation Water Must Not Be Used.
The draft policy calls for organic farmers to "avoid"
the use of polluted water "unless no other source is available".
Such language is weak and difficult to enforce.  The policy should
recognize that not all sites are suitable for organic
certification.  If clean water is not available, a site should not
be certified for organic production.

2)  Qualitative Evaluation of Available Water Supply Needed.
The policy fails to make a distinction between occasional and
involuntary use of water that may be slightly contaminated
and the routine use of "run-off from conventional farms".
A qualitative evaluation of the nature of any contamination
is essential to determine the extent of possible insult
to organic production.  Routine use of water
contaminated  beyond levels of "unavoidable residual environmental
contamination" is not consistent with organic agriculture and
should not be allowed.

3) Difficulty of Enforcement.
Sanctioning the use of contaminated irrigation water as a part of
organic production renders unenforceable controls over use of
prohibited substances.  It increases the difficulty of preventing
chemigation, for example, and raises questions about the source of
any residues found.  It also reduces incentives to clean up
contaminated sources or to find uncontaminated alternative
supplies

4)  Organic Production Not For Waste Disposal.
While a goal of organic production to improve the quality of life
and the environment in particular, it cannot, in the short run,
solve conventional agriculture's disposal problems.  The argument
in the draft proposal that "[a]pplication of nutrient-containing
irrigation water to the organic farm's biologically active soil is
the best way to recapture these nutrients and prevent further
contamination of groundwater by synthetic fertilizers" is faulty.
"Run-off from conventional farms" is commonly also contaminated
with pesticides, which will not help the "biologically active
soil", as well as nutrients.   The draft policy also proposes
applying the same strategy to "irrigation water containing
pesticide residues" because the soil "may" break them down and
"cleanse the irrigation water".  It may in some cases, but
breakdown products of pesticides may be more as well as less toxic
than the parent compounds.  Allowing use of pesticide contaminated
water on the assumption that organic fields will clean it is
unwise, unscientific, and inconsistent with organic
production.   The draft Irrigation Water Quality proposal works
against the goal of the OFPA to promote and certify organic
production.  Rather it is more consistent with EPA policy that the
best way to "get rid of" left over stocks of cancelled pesticides
is to use them up, that is, to spread them around in the
environment.  Or to apply sewage sludge to fields to disperse
pollution.  Organic agriculture cannot at this time solve the
runoff problems of conventional agriculture, but it can be an
example of how to avoid creating additional toxic runoff.  We
think it is inappropriate that the use of contaminated water be
rationalized as "cleansing".

5)  Health Based Standard Needed.
Comments above on the use of EPA and FDA tolerance standards apply
to the draft policy on contaminated irrigation water.  No level of
known prohibited substances above "unavoidable residual
environmental contamination" in irrigation water should be allowed
as "organic".



III.  CONCLUSION.

All three proposed policies have in common an apparent unwillingness
to face the hard fact that contamination of organic production should
result in loss of organic status and that mechanistic testing to confirm
certification is not adequate.  Organic agriculture is not just
"residue free" or residue limited.  Organic is a process, a
systemic, holistic, thoughtful, qualitative, sustainable, and
humane process.  Insults to the system must be evaluated in a
similar thoughtful, qualitative way.  While residue tests may
confirm contamination, they can not confirm
"organic".   Thus, insults in the form of contamination with
prohibited substances including pesticides by emergency spray,
drift, contaminated irrigation water, or other means should be
evaluated by a qualitative process that is both more difficult and
more appropriate than just testing or measurement against an
arbitrary standard.  The evaluation must include a willingness to
withdraw certification when necessary.  And, it must recognize
that not all places are suitable for certification.  An area
subject to repeated, significant exposures to prohibited
substances, for example, may not be able to produce
organically.   Organic certification is an economically valuable
commodity.  If it is damaged or destroyed, the organic producer
should be able--even encouraged--to seek restitution from
responsible parties.  Diluting certification requirements to
include contamination from emergency applications, drift,
irrigation water, or other sources reduces the economic value of
certification and does a disservice to responsible organic
growers.  Rather than accept contamination from conventional
agriculture as inevitable, national standards should provide
incentives for changing practices that promote chemical trespass
and for empowering producers to protect their property.  The NOSB
must be an advocate for effective drift control practices and
regulations and for the rights of organic producers.   People
don't want to buy organic produce only to find it has been treated
only in an "emergency", sprayed only by "drift", or nourished with
contaminated water.  They want to get what they think they are
getting.  As the organic sector grows from specialty status, where
trust in organic practices is reinforced by personal
relationships, to a larger, more impersonal marketplace, keeping
that trust is difficult but essential.  Vigilance, sound polices,
and full disclosure, not exceptions which allow "acceptable"
levels of contamination, are required.   Insistence on a
clean, healthy, non-polluting standard is both philosophical and
practical.  We believe it is right for organic certification.  We
also believe the public will be far more forgiving to learn that
transition to organic production may take longer than expected
than to find it has been tricked into thinking organic means
"clean" only to find it is something else.  If contamination is
unavoidable, label it as such.  People can take that--as
transition or as step in the right direction.  Let's not call
contamination something else.     The Board should recommend
high standards for organic certification.  It may also want to
establish interim, transitional, or low spray standards for those
unable or unwilling to meet full organic criteria.  It may be that
some locations, because of emergency pesticide use, spray drift,
irrigation water quality, or other problems, will always fall into
a lesser category.  We believe, however, that this is much better
than bringing organic standards down to a lowest common
denominator.

Thank you for your attention to these comments as the Board carries
on its important task of establishing national organic standards.

Sincerely,


Allen Spalt
Director, Agricultural Resources Center & Pesticide Education Project

Terry Shistar
Director, Kansans for Safe Pest Control Pest Management
Coordinator, Sierra Club Hazardous Materials Committee

Jay Feldman
Executive Director, National Coalition Against the Misuse of Pesticides

                        NATURAL PEST REPELLENTS



These recipes were taken from the June, 1987 issue of Country Journal magazine 
(p. 42-45).


TOMATO

Tomato leaves, pureed *
4 - 5 pints of water
1 T. each cornstarch & Ivory Soap flakes

Mix together, let stand for a couple of hours. Strain. Spray on roses to prevent 
black spot. Refrigerate any leftover liquid.


GARLIC

3 - 4 ounces chopped garlic bulbs
2 T. mineral oil
1 pint water
1 t. fish emulsion

Soak garlic in mineral oil for 24 hours. Dissolve fish emulsion in water & mix 
with garlic-mineral oil. Stir well and strain. Store in glass jar (it reacts 
with metal). Dilute as follows: 1 part mixture to 20 parts water. Use on plants 
with large insect infestation. DO NOT USE on peas, beans, or sage. Also repels 
rabbits.


CHIVE TEA

5 T. chopped chives
10 c. boiling water
1 T. Ivory Soap flakes

Pour boiling water over chives. Let stand until cool. Strain and add soap. Spray 
on cucumbers to prevent or discourage powdery mildew.


NASTURTIUMS

Nasturtium leaves, pureed *
4 - 5 pints of water
1 T. each cornstarch & Ivory Soap flakes

Mix leaves, water, and cornstarch. Let stand for a couple of hours. Strain and 
mix with soap. Spray on squash to deter squash bugs. Also, use on broccoli to 
control aphids.



                                                                  OVER
HOT PEPPER

5 Pepper pods
2 medium onions
1 Garlic bulb
Water *

Mash pods, onions, & garlic together. Cover with water and let stand for 24 
hours. Strain. Add enough water to make a gallon of spray. Use on roses, 
azaleas, chrysanthemums, & beans.



*  No specific amounts were given in the article.-------------------------------
---------
|      HERBAL SPRAY FOR ROSES          |
|                                      |
|      USING DRY HERBS,MIX TOGETHER:   |
|                                      |
|      7 OZ. NETTLE                    |
|      6 OZ. LEMON BALM                |
|      3 1/2 OZ. CRUSHED HOT CHILI     |
|      PEPPERS,WITH SEEDS.             |
|      2 OZ. LOBELIA                   |
|                                      |
|      BREW AS WITH ORDINARY TEA,      |
|      USING 2 TBSP. DRY HERBS PER     |
|      1 PINT WATER.ALLOW TO STEEP     |
|      IN A WARM PLACE FOR 3 DAYS.     |
|      STRAIN AND SPRAY ROSES TO       |
|      PREVENT APHIDS AND ENHANCE      |
|      GROWTH.                         |
|                                      |
|                                      |
|                                      |
|                                      |
|                                      |
----------------------------------------
                SPRAYING FACTS FOR THE GARDEN

     An effective spray program can mean the difference between a
garden that thrives and one that dies on the vine.  And whether
you're a veteran or a novice, organic or generalist, there are
some basic spraying facts every gardener should keep in mind.
     You should mix spray material as recommended, according to
David Robson, Extension Educator, Horticulture with the
Springfield Extension Center.
     Start with the proper spray material.  Then follow all
directions and precautions on the label of pesticide.  A common
misconception is that if one tablespoon of pesticide is
recommended, two tablespoons will be twice as effective.  
     Effectiveness will not be increased by doubling the amount
of chemical.  In fact, higher concentrations of pesticide can
harm plants, and is against Federal law.
     Use proper measuring utensils.  Don't guess at amounts. 
Measure the pesticides carefully, and mix only the amount needed
for a job.  Keep measuring utensil separate from cooking
utensils.  Never use pesticide measures for food.
     When you spray, remember that "how you spray does make a
difference".  Spray on target (pest), especially under leaves
where insects settle and many plant disease begins.  A haphazard
application will not curb an infestation of insects or stop the
spread of plant disease.
     Spray just to the point of run-off, never drench the plants. 
You may think more spray is better, but over spraying can injure
plants.  And excess run-off may hit non-target plants.
     "On-target" spray applications require equipment which gives
you control over the spray, so use proper equipment, adds Robson.
     Use a sprayer with "control" features such as an adjustable
nozzle for various spraying jobs, a positive on-off valve for
precise application, and a long spray extension for easy reach
under leaves.  This can be a pressure sprayer or a hose sprayer. 
Dusters can be used for dust applications.
     Watch the weather and spray before the heat of the day and
always avoid spraying when temperatures are high.  High
temperatures cause some pesticides to evaporate and decompose
quickly.  Rain or watering after application will reduce
effectiveness by washing the spray material off plant leaves. 
But most formulations can withstand one-half to one inch of
rainfall.
     Spray when it's calm as on a calm day.  Pesticide "drift",
the movement of spray from the place of release, should be
avoided.  Drift can also be minimized by spraying at a lower
pressure and using the largest practical nozzle opening.
     Wind speeds should be below 5 miles per hour.  Early morning
and early evening are relatively calm periods.

                              -30-

Source:        David Robson
               Horticulture Educator
               Springfield Extension Center
               217/782-6515


5/24/93
KILL DATE:  January 1, 1994
          Ä [20] Survnet: SURVIVAL_ORIENTED TOPICS (9:2500/0) ÄÄÄÄÄÄÄÄ 
SURVIVAL_ORIENTED Ä
 Msg  : 88 of 97                                                                
 From : Brian Sorensen                      9:1992/195      Fri 10 Dec 93 17:04 
 To   : All                                                                     
 Subj : Natural Pest Replellants                                                
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
For your library, from DC ;).

---------------------------------------
                        NATURAL PEST REPELLENTS



These recipes were taken from the June, 1987 issue of Country Journal magazine
(p. 42-45).


TOMATO

Tomato leaves, pureed *
4 - 5 pints of water
1 T. each cornstarch & Ivory Soap flakes

Mix together, let stand for a couple of hours. Strain. Spray on roses to prevent
black spot. Refrigerate any leftover lquid.


GARLIC

3 - 4 ounces chopped garlic bulbs
2 T. mineral oil
1 pint water
1 t. fish emulsion

Soak garlic in mineral oil for 24 hours. Dissolve fish emulsion in water & mix
with garlic-mineral oil. Stir well and strain. Store in glass jar (it reacts
with metal). Dilute as follows: 1 part mixture to 20 parts water. Use on plants
with large insect infestation. DO NOT USE on peas, beans, or sage. Also repels
rabbits.


CHIVE TEA

5 T. chopped chives
10 c. boiling water
1 T. Ivory Soap flakes

Pour boiling water over chives. Let stand until cool. Strain and add soap. Spray
on cucumbers to prevent or discourage powdery mildew.


NASTURTIUMS

Nasturtium leaves, pureed *
4 - 5 pints of water
1 T. each cornstarch & Ivory Soap flakes

Mix leaves, water, and cornstarch. Let stand for a couple of hours. Strain and
mix with soap. Spray on squash to deter squash bugs. Also, use on broccoli to
control aphids.



                                                                  OVER
HOT PEPPER

5 Pepper pods
2 medium onions
1 Garlic bulb
Water *

Mash pods, onions, & garlic together. Cover with water and let stand for 24
hours. Strain. Add enough water to make a gallon of spray. Use on roses,
azaleas, chrysanthemums, & beans.



*  No specific amounts were given in the article.

--- Blue Wave/RA v2.10 [NR]
 * Origin: SurvNet - Powderhorn BBS 202-562-8239 (9:1992/195)

 
