Controlled environment agriculture (CEA) is experiencing tremendous growth, largely due to innovations in production environments, lighting and nutrition, as well as an increased concern toward food quality. Fortunately, as traditional pest control strategies have become limited due to regulations and chemical resistance concerns, there has been a number of new, softer pesticide products entering the market to fill the gap. The regular use of bioinsecticides and biofungicides has become standard practice, and several other naturally derived products have proven useful when growing CEA edible and cannabis crops.
Recent developments in formulation of minimum risk pesticides, commonly known as “25b” products, have given growers another reliable alternative that can provide both pathogen and insect control using food-safe ingredients.
What is a minimum risk, 25b pesticide?
25b products do not require an EPA registration and do not have a pesticide registration number. Because EPA has determined that certain minimum risk pesticides pose little to no risk to human health or the environment, EPA has exempted them from the requirement of being registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Enacted in 1947, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is the Federal statute that governs the registration, distribution, sale, and use of pesticides in the United States. With certain exceptions, a pesticide is any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, desiccant, or any nitrogen stabilizer.
The certain exceptions from above are used to formulate 25b products. They must meet six conditions to be labeled as a minimum risk pesticide (source – https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides):
1. The active ingredients must be listed in the EPA Active Ingredients for Minimum Risk Pesticide Products
(Active Ingredients Allowed in Minimum Risk Pesticide Products | US EPA)
2. The inert ingredients must be on the EPA Inert Ingredients for Minimum Risk Pesticide Products list
(Inert Ingredients Approved for Use in Minimum Risk Pesticide Products | US EPA)
3. All ingredients and percent concentration must be on the label for transparency
4. The labeling cannot make health-related claims
5. Company name and contact information must be provided on the label
6. The label cannot include any false or misleading statements
How do minimum risk products fit into our pest control programs?
They are made from ingredients that are relatively safe for workers, allowing a zero-hour restricted entry interval (REI) and zero-day pre-harvest interval (PHI). There are no restrictions on the number of applications per growing cycle or limits on the number of consecutive applications, making them very useful as a rotational partner for both microbials and conventional chemistry.
25b pesticides are labeled for all edible crops and approved for use on cannabis crops in some states. Initially, many states allowed only 25b products on cannabis and hemp crops, and some still retain that restriction. Currently, several states have an “allowed” or approved list for crop protection products on cannabis, or have a list of requirements that include state registration and specific labeling, including crop, and PHI to help determine approval for use on cannabis – “it is the grower’s responsibility to determine what they can and cannot use in their state”
It is important to understand that most 25b products contain botanical oils, and many formulations also include alcohols, soaps, surfactants, acids and other ingredients that can contribute to phytotoxicity. Differences in formulations and refining processes also impact efficacy and tendency to burn foliage. Griffin Greenhouse Supplies carefully evaluates 25b products for efficacy and plant safety concerns. Applications should be made in low to moderate light conditions, when temperatures are below 85°F and humidity is below 85% to ensure that the oils dry quickly (preferably within 1-2 hours of application) with minimal stress on the plants. Plants should never be under drought or heat stress when any sort of pesticide is applied.
As these products become more sophisticated, they are beginning to join biopesticides and biofungicides in spray rotations for edible crops and cannabis as part of a robust IPM program. Utilizing softer chemistry like these minimal risk pesticides along with microbial products as a preventative measure when pest pressure is low can save conventional chemistry for curative, or “rescue” applications when necessary.
*Reach out to your local Griffin Sales Representative for additional product and accessory options.
Note: Not all products are registered in all states. Some pesticides are restricted use in some states or regions and not others. It is the responsibility of the applicator to read and follow all label directions, remembering that labels may change. Other products may be safe and effective. Rates, application methods, and edible status are detailed in our GGSPro Insecticide & Fungicide Guides. Griffin also offers the 6th Edition GGSPro Technical Reference Guide. This valuable resource outlines a wide range of pest control options and information on pollinator safety, BCA’s, scouting, weed management, plant lighting, nutrition, water quality and more!
Recent developments in formulation of minimum risk pesticides, commonly known as “25b” products, have given growers another reliable alternative that can provide both pathogen and insect control using food-safe ingredients.
What is a minimum risk, 25b pesticide?
25b products do not require an EPA registration and do not have a pesticide registration number. Because EPA has determined that certain minimum risk pesticides pose little to no risk to human health or the environment, EPA has exempted them from the requirement of being registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Enacted in 1947, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is the Federal statute that governs the registration, distribution, sale, and use of pesticides in the United States. With certain exceptions, a pesticide is any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest, or intended for use as a plant regulator, defoliant, desiccant, or any nitrogen stabilizer.
The certain exceptions from above are used to formulate 25b products. They must meet six conditions to be labeled as a minimum risk pesticide (source – https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides):
1. The active ingredients must be listed in the EPA Active Ingredients for Minimum Risk Pesticide Products
(Active Ingredients Allowed in Minimum Risk Pesticide Products | US EPA)
2. The inert ingredients must be on the EPA Inert Ingredients for Minimum Risk Pesticide Products list
(Inert Ingredients Approved for Use in Minimum Risk Pesticide Products | US EPA)
3. All ingredients and percent concentration must be on the label for transparency
4. The labeling cannot make health-related claims
5. Company name and contact information must be provided on the label
6. The label cannot include any false or misleading statements
How do minimum risk products fit into our pest control programs?
They are made from ingredients that are relatively safe for workers, allowing a zero-hour restricted entry interval (REI) and zero-day pre-harvest interval (PHI). There are no restrictions on the number of applications per growing cycle or limits on the number of consecutive applications, making them very useful as a rotational partner for both microbials and conventional chemistry.
25b pesticides are labeled for all edible crops and approved for use on cannabis crops in some states. Initially, many states allowed only 25b products on cannabis and hemp crops, and some still retain that restriction. Currently, several states have an “allowed” or approved list for crop protection products on cannabis, or have a list of requirements that include state registration and specific labeling, including crop, and PHI to help determine approval for use on cannabis – “it is the grower’s responsibility to determine what they can and cannot use in their state”
It is important to understand that most 25b products contain botanical oils, and many formulations also include alcohols, soaps, surfactants, acids and other ingredients that can contribute to phytotoxicity. Differences in formulations and refining processes also impact efficacy and tendency to burn foliage. Griffin Greenhouse Supplies carefully evaluates 25b products for efficacy and plant safety concerns. Applications should be made in low to moderate light conditions, when temperatures are below 85°F and humidity is below 85% to ensure that the oils dry quickly (preferably within 1-2 hours of application) with minimal stress on the plants. Plants should never be under drought or heat stress when any sort of pesticide is applied.
As these products become more sophisticated, they are beginning to join biopesticides and biofungicides in spray rotations for edible crops and cannabis as part of a robust IPM program. Utilizing softer chemistry like these minimal risk pesticides along with microbial products as a preventative measure when pest pressure is low can save conventional chemistry for curative, or “rescue” applications when necessary.
| Product | Item # | OMRI | Active Ingredients (A.I.) |
| Ecotec Plus | 70-1507; 2.5 gal | Yes | Rosemary oil, Peppermint oil, & Geraniol. |
| EpiShield | 70-1545; 36 oz 70-1548; 2.5 gal |
No | Peppermint oil, Clove oil, Sodium Lauryl Sulfate. |
| Mildew Cure | 16-11005; 2.5 gal | Yes | Cottonseed, Corn, and Garlic oils. |
| Pest Out | 16-11011; 2.5 gal | Yes | Cottonseed, Clove, and Garlic oils. |
Note: Not all products are registered in all states. Some pesticides are restricted use in some states or regions and not others. It is the responsibility of the applicator to read and follow all label directions, remembering that labels may change. Other products may be safe and effective. Rates, application methods, and edible status are detailed in our GGSPro Insecticide & Fungicide Guides. Griffin also offers the 6th Edition GGSPro Technical Reference Guide. This valuable resource outlines a wide range of pest control options and information on pollinator safety, BCA’s, scouting, weed management, plant lighting, nutrition, water quality and more!
