**Petition for Amending the National List of the USDA's**

**National Organic Program**

**[DL- Methionine, ML-Methionine Hydroxy analog, and
DL-Methionine-hydroxy analog calcium-for use only in organic poultry
production]{.underline}**

**A Synthesized Essential Amino Acid**

**Submitted December 17, 2007 by:**

**Dave Martinelli, on behalf of the Methionine Task Force**

*(Please refer to the first attachment to this petition for a list of
Task Force representatives.)*

**Introduction:**

**The Methionine Task Force requests that 7 CFR §205.603(d)(1) be
amended, by removing the reference/annotation date of "October 8, 2008",
and therefore submitting DL-Methionine to the standard process for
sunset review of allowed substances on the National List.**

**Petitioners are required to provide the following information as
applicable:**

**Category for inclusion on the National List:**

-   *This request is to remove the annotation date currently listed on
    synthetic methionine \[MET\] in Section 205.603 of the National List
    as a synthetic substances allowed for use in organic livestock
    production thereby submitting MET to the standard sunset process for
    review of materials on the National List.*

**Common name:**

-   *The three names in the title of this document are the most widely
    used common names. They are however the common names associated with
    specific manufacturers. Throughout this petition the term
    "Methionine" will be used to refer to the natural form of the amino
    acid and the term MET will be used to refer to any synthetic
    analog.*

**Chemical Structure:**

-   *The formula for Methionine is H~2~NCH~3~SCH~2~CH~2~COOH.\
    Other Chemical Structures;\
    DL-Methionine   CH3-S-CH2-CH2-CH(NH2)-COOH\
    Methionine Hydroxy Analog       CH3-S-CH2-CH2-CH(OH)-COOH*

**Manufacturers name, address and telephone number**

-   *There are three major manufacturers of MET world wide:\
    ***Adisseo**\
    3480 Preston Ridge Road, Suite 375. Alpharetta, GA  30005 Phone 
    678-339-1513

**Degussa Feed Additives**\
        1701 Barrett Lakes Blvd., Suite 340 Kennesaw, GA  30144 Phone 
800-955-3114

**Novus International, Inc.\
**        530 Maryville Centre Drive St. Louis, MO 63141 888-906-6887

**List of uses, rates and applications for crops and livestock uses,
mode of action for handling uses:**

-   *Typically added to poultry feed rations at the following rates:*

-   *Laying Hens: 0.001% (1-3 lbs per ton of feed)*

-   *Broilers: 0.0025% (5 lbs per ton of feed)*

-   *Turkeys: 0.0025% (5 lbs per ton of feed)*

**Sources and detailed description of manufacturing procedures:**

*The following text is taken from the May 21, 2001 Methionine Livestock
TAP Review:*

Methionine may be isolated from naturally occurring sources, produced
from genetically engineered organisms, or entirely synthesized by a wide
number of processes. While methionine has been produced by fermentation
in laboratory conditions, racemic mixtures of D- and L- methionine
(DL-Methionine) are usually produced entirely by chemical methods (Araki
and Ozeki, 1991). Methionine can be produced from the reaction of
acrolein with methyl mercaptan in the presence of a catalyst (Fong, et
al., 1981). Another method uses propylene, hydrogen sulfide, methane,
and ammonia to make the intermediates acrolein, methylthiol, and
hydrocyanic acid (Degussa). The Strecker synthesis can be used with
〈-methylthiopropionaldehyde as the aldehyde (Fong, et al., 1981). A
recently patented process reacts 3-methylmercaptopropionaldehyde,
ammonia, hydrogen cyanide, and carbon dioxide in the presence of water
in three reaction steps (Geiger et al., 1998). Other methods are
discussed in the 1999 Crops Amino Acid TAP review. DL-methionine hydroxy
analog calcium and DL-methionine hydroxy analog forms are considered to
be alpha-keto acid analogues in which the amine group has been replaced
by a hydroxy (OH) group. These forms are converted to the amino form in
the bird by transamination in the liver, using non-essential amino acids
such as glutamic acid (Cheeke 1999; Leeson 1991). These forms are
produced by reacting hydrogen cyanide with an aldehyde that has been
treated with a sulfite source to form a cyanohydrin. The aldehydes used
are prepared from either hydrogen sulfide or an alkyl mercaptan with an
aldeyhde such as acrolein and are then hydrolyzed using sulfuric or
hydrochloric acid (USPO 1956).

**Regulatory status with EPA, FDA or state authorities:**

*The following text is taken from the May 21, 2001 Methionine Livestock
TAP Review:\
*

Regulated as a nutrient / dietary supplement by FDA (21 CFR 582.5475).
The Association of American Feed

Control Officials (AAFCO) set the standard of identity for DL-methionine
as containing a minimum of 99%

racemic 2-amino-4-methylthiobutyric acid (AAFCO, 2001). The AAFCO model
regulation states that "the term Methionine Supplement may be used in
the ingredient list on a feed tag to indicate the addition of
DL-Methionine" (AAFCO, 2001). AAFCO also lists a feed definition for
DL-Methionine hydroxy analogue calcium (min. 97% racemic
2-amino-4-methylthiobutyric acid, 21 CFR 582.5477) and DL-Methionine
hdyroxy analogue, (min. 88% racemic 2-amino-4-methylthiobutyric acid, 21
CFR 582.5477).*\
*

**Chemical Abstract Service (CAS) number or other product number,
samples of labels:**

*The following text is taken from the May 21, 2001 Methionine Livestock
TAP Review:*

**Chemical Names:**

2-amino-4-methylthiobutyric acid and

〈-amino--methylmercaptobutyric acid

**Other Names:**

DL-methionine, D-methionine, L-methionine,

Met, Acimethin

**CAS Numbers:**

59-51-8 (DL-methionine)

63-68-3 (L-methionine)

348-67-4 (D-methionine)

**Other Codes:**

International Feed Names (IFN):

DL-methionine: 5-03-86

DL-methionine hydroxy analog

calcium: 5-03-87

DL-methionine hydroxy analog: 5-30-28

**Physical properties of the substance and chemical mode of action:
including environmental impacts, interactions with other materials,
toxicity and persistence, effects on human health, effects of soil
organisms, crops or livestock:**

*The following text is taken from the May 21, 2001 Methionine Livestock
TAP.*

**Properties:**

L-Methionine: Colorless or white lustrous plates, or a white crystalline
powder. Has a slight, characteristic odor. Soluble in water, alkali
solutions, and mineral acids. Slightly soluble in alcohol, insoluble in
ether. MP 280-82°C. It is assymetric, forming both an L- and a D-
enantiomer. Methionine hydroxy analog (MHA) is available in liquid form.

**Action:**

Amino acids form protein. Of the 22 amino acids found in body proteins,
the National Research Council lists 13 as essential in poultry diets,
and these must be consumed in feed. These 13 are: arginine, glycine,
histidine, isoleucine, leucine, lysine, methionine, cystine,
phenylalanine, proline, threonine, tryptophan, and valine (NRC 1994).
Five that are deemed critical in poultry rations are methionine,
cystine, lysine, tryptophan, and arginine (North, 1990).

Animals convert dietary protein into tissue protein through digestive
processes. Proteins are metabolized by animals through two phases:
catabolism (degradation from body tissue to the free amino acid pool)
and anabolism (synthesis into body tissue). Amino acids utilized as
proteins are primary constituents of structural and protective tissues,
including skin, feathers, bone, ligaments, as well as muscles and
organs.

**Combinations:**

Amino acids are combined in feed rations of grains, beans, oilseeds, and
other meals with antioxidants, vitamins, minerals, antibiotics, and
hormones (Pond, Church, and Pond, 1995). Methionine is a precursor in
the diet to cystine, and the amount needed in the diet depends on the
amount of cystine also present. Requirements for methionine are
frequently cited in terms of methionine plus cystine, because methionine
converts to cystine as needed.

**OFPA 2119(m) Criteria:**

*(1) The potential of such substances for detrimental chemical
interactions with other materials used in organic farming systems.*

The primary chemical interaction is the dietary intake by animals. While
many of the interactions may be regarded as beneficial, excess
methionine in a diet may cause deficiencies in other amino acids and
induce toxicity (D'Mello, 1994). Methionine, while often one of the most
limiting amino acids, is also one that readily goes to toxic excess.
Small excesses of methionine can be deleterious (Buttery and D'Mello,
1994). Errors in feed formulation or excess supplemental methionine can
actually depress growth and development at levels of

40 g/kg (4.0%) (Baker, 1989, NRC 1994). Excess methionine exacerbates
deficiencies of vitamin B-6, which results in depressed growth and feed
intake (Scherer, 2000). Growth depressions resulting from excess
supplemental amino acids include lesions in tissues and organs (D'Mello,
1994). Methionine is "well established as being among the most toxic of
all amino acids when fed at excess levels in a diet" (Edmonds and Baker,
1987 cited in Scherer, 2000).

*(2) The toxicity and mode of action of the substance and of its
breakdown products or any contaminants, and their persistence and areas
of concentration in the environment.*

While it is nutritionally essential, methionine excesses are far more
toxic to poultry than similar excesses of tryptophan, lysine, and
threonine (National Research Council, 1994). Force feeding methionine to
excess can result in death to chicks (National Research Council, 1994).
However, NRC acknowledges that such toxicities are unlikely in practical
circumstances for poultry, in that an amino acid toxicity requires a
particularly high level of an amino acid relative to all others.
Supplemental levels fed to poultry are usually fed at lower levels,
ranging from 0.3 - 0.5% of the diet. Susceptiblity of an animal to
imbalances and excesses is influenced by the overall protein supply, and
animals that are fed relatively high levels of protein are more tolerant
(Buttery and D'Mello,

1994).

A dosage of 2 g / mature cat / day (20 to 30 g / kg dry diet) for 20
days induces anorexia, ataxia, cyanosis,

methemoglobinemia and Heinz body formation resulting in hemolytic anemia
(Maede, 1985). Rat studies of methionine is significantly toxic in
excess (Regina, et al., 1993). High levels of methionine were found to
be toxic to hepatic cells and liver function of the rat models. The
results of this study indicated that the Biochemical reason for the
extreme sensitivity of mammals to excess dietary methionine is thought
to be due to the accumulation of toxic catabolites, most notably,
S-adenosylmethione, resulting in liver dysfunction. L-methionine has an
acute LD50 of 4,328 mg/kg (rat) (NIEHS, 1999b). NIEHS carcinogenicity
and teratogenicity are not available, but reports positive mutagenicity
(NIEHS, 1999b). Methionine is stable in crystalline form at standard
temperature and pressure.

\(3\) *The probability of environmental contamination during
manufacture, use, misuse or disposal of such substance.*

Synthetic production of DL-methionine involves a number of toxic source
chemicals and intermediates. Each of the several manufacturing processes
used to produce DL-methionine was rated as either "moderately heavy" to
"extreme" (Fong, et al., 1981). Newer processes have not replaced many
of the feedstocks. Several of the

feedstocks are likely to result in ruptured storage tanks, leaking
chemicals, and releases into the environment.

The methionine production process is listed by EPA as a hazardous air
pollutant (40 CFR 63.184).

Methyl mercaptan can react with water, steam, or acids to produce
flammable and toxic vapors (Sax, 1984). The EPA rates methyl mercaptan
fires as highly hazardous and can cause death by respiratory paralysis
(EPA, 1987). Acrolein has a toxicity rating of 5 (on a scale of 1 to 6
with 6 being most toxic) (Gosselin, 1984) and it is also an aquatic
herbicide (Meister, 1999). The acrolein process involves several steps
that render it synthetic as well (1994). Acrolein itself is an extreme
irritant.

Hydrogen cyanide is produced by further processing of methane and
ammonia. Hydrogen cyanide is a gas that is highly toxic. Hydrogen
cyanide has a toxicity rating of 6 and is one of the fastest acting
poisons known to man (Gosselin, 1984). Exposure causes paralysis,
unconsciousness, convulsions, and respiratory arrest. Death usually
results from exposure at 300 ppm concentrations for a few minutes.
Manufacture of hydrogen cyanide is a significant source of atmospheric
release of cyanide (Midwest Research Institute, 1993). Ammonia is a
corrosive agent. Methane is a central nervous system depressant
(Gosselin, 1984).

*(4) The effect of the substance on human health.*

Methionine is essential in small amounts in the human diet, and is sold
over-the-counter as a dietary supplement. The L- form of methionine is
used extensively in human medicine for a variety of therapeutic
purposes, including pH and electrolyte balancing, parenteral nutrition,
pharmaceutical adjuvant, and other applications. It is in fact one of
the top 800 drugs in human medicine (Mosby, 1997). Methionine may cause
nausea, vomiting, dizziness, and irritability and should be used with
caution in patients with severe liver disease (Reynolds, 1996).

The D- form of methionine is not well utilized by humans (Lewis and
Baker, 1995). Individuals may have allergic reactions to the D- isomers
or a racemic mixture of DL-methionine. While a number of amino acids are
considered GRAS for human consumption and as feed supplements,
DL-methionine is not (see 21 CFR 172, 21 CFR 184, and 21 CFR 570.35).
DL-methionine is unique among amino acids cleared for food use in that
it is the only one listed that explicitly says it is not for use in
infant feed formulas (21 CFR 173.320). When heated to decomposition,
methionine emits dangerous and highly toxic fumes (NIEHS, 1999).

*(5) The effects of the substance on biological and chemical
interactions in the agroecosystem, including the physiological effects
of the substance on soil organisms (including the salt index and
solubility of the soil), crops and livestock.*

[Interactions and Imbalances]{.underline}

Protein is required for body development in all growing birds, and
layers also need a good proportion since eggs consist of 13-14% protein.
Broilers also need high energy diets as they are commericially raised to
grow rapidly to reach about 4.4 lbs in 8 week at a desired food
conversion rate of 1.8 (consuming less than 8 lbs of feed total)
(Sainsbury, 2000). This is a 50-55 fold increase inbody weight by 6
weeks after hatching, which leads to a high amino acid requirement to
meet the need for active growth (NRC 1994). The dietary requirement for
protein is actually a requirement for the amino acids contained in the
dietary protein. Protein quality is related to the proper balance of
essential amino acids in the diet. The presence of nonessential amino
acids in the diet also reduces the necessity of synthesizing them from
the essential amino acids (NRC 1994).

Amino acids in the body are constantly in flux between three states:
stored in tissue, oxidized from tissue to free amino acids, and digested
and excreted as uric acid. If some nonessential amino acids are low,
they may be synthesized from others in the free amino acid pool, or
degraded from those stored in tissue. Deficiencies or excesses of a
particular amino acids can cause problems in availability of other amino
acids (Buttery and D'Mello 1994; Baker 1989). Intact proteins (as in
natural grains) are more slowly available in the digestive system, while
pure sources of amino acids are more bioavailable than intact-protein
sources (Baker, 1989). Excesses of some amino acids in an unbalanced
source of crude protein can reduce feed intake and depress amino acid
utilization (Pack, 1995). Depressed feed intake and growth at excess
intake levels of protein has recently been attributed to insufficient
supply of vitamin B-6 which is required to metabolize the sulfur amino
acids (Scherer and Baker 2000).

The requirement for sulfur containing amino acids of methionine,
cystine, and cysteine can be misjudged due to inaccurate accounting for
the availability of cystine in the diet (NRC, 1994).

Other cases have shown significantly higher weights and faster gains
from amino acid (lys+met) supplementation (Slominski et al, 1999). Also,
the digestibility of practical ingredients, such as corn and soybeans,
appears to be on the order of 85% or more (NRC, 1994).

Amino acid requirements may be affected by environmental temperature
extremes, basically because of the effect on feed intake, but amino acid
supplementation will only affect weight gain if it improves feed intake
(Baker 1989; NRC 1994). Interactions between deficiencies of methionine
and several vitamins and minerals have also been documented, and suggest
that other dietary factors in addition to total protein have an effect
on the efficency of amino acid utilization (Baker, D.H. et.al, 1999).

[Environmental Impact]{.underline}

Managing the nitrogen cycle is seen as a challenge to livestock
producers (Tamminga and Verstegen, 1992; Tamminga, 1992; Morse, no
date). Poultry layer operations are experiencing increased costs and
regulations for manure management (Sloan, et al., 1995). Supplementation
with amino acids may allow dietary protein and excretory nitrogen levels
to be reduced with a minimum reduction in egg output and no loss in
weight gain in broilers (Summers, 1993; Sloan et al., 1995, Ferguson,
et.al 1998). Excess ammonia build up in poultry houses can be a hazard
to workers and birds if not properly ventilated (Ferguson, 1998).

Feeding systems that reduce levels of protein fed using amino acid
supplementation are not the only means identified to reduce nitrogen
pollution from animal manure. Other potential solutions include lower
animal densities; more frequent rotations; better manure storage,
handling, and application techniques; use of enzymes; improved
processing of the feed; and selection of more appropriate land and
locations to graze and shelter animals (Archer and Nicholson, 1992;
Tamminga, 1992; Tamminga and Verstegen, 1992). Increased digestiblilty
of protein in feeds suplemented with microbial phytase provided better
availabilty of most of the amino acids other than lysine and methionine
and allowed for reduced P and Ca levels in feed, a goal in reducing
phosphorus overload from poultry manure (Sebastian 1997). Another study
found that reduced crude protein and energy content were needed in
enzyme supplemented broiler diets, although availability of individual
amino acids were not improved equally and were still deemed to need
balancing (Zanella, et al 1999).

One grower reported success with innovative housing design that allows
twice daily cleanout of manure, combined with a commercial composting
operation (La Flamme, 2001). Manure from organic operations has
potential added value to organic crop farmers seeking to avoid manure
from conventional operations. Some markets in the EU require that
imported crops are documented to be grown free of "factory farm" manure,
requiring additional verification from U.S. certifiers (McElroy, 2001).

[Impacts on Bird Health]{.underline}

A number of reports cite a benefit of methionine supplementation on
reduced immunologic stress (Klasing, 1988; Tsiagbe et al, 1986).
Immunologic stress is considered to be a response to microbial
challenges, in these experiments due to injections of E. coli and
Salmonella and other pathogens. This causes decreased feed rates and
lower rates of growth. Chicks that received deficient levels of
methionine were more subject to an impaired immune response. These
experiments seem to be more applicable to a high density confinement
system or high density production system in terms of bird treatment, and
may not be very relevant to an organic system approach.

A problem exacerbated by excess methionine is hepatic lipidosis, a
condition of excessive fat in the liver commonly associated with caged
birds and is related to the fact that wild diets are much lower in fat
than seed diets fed to captive species (Aiello, 1998). This can be
mangaged by a well balanced diet, and is reportedly not a problem in
free range birds in organic systems (Krengel, 2001). Enteritis is a
disease frequently observed in poultry that do not have access to the
soil and green growing plants (Titus, 1942). Well managed pasture would
prevent this cause of the disease.

Reduced feathering has been reportedly linked to lack of methionine and
cystine (Elliott, no date). Many other factors are also involved,
including deficiencies of other amino acids, vitamins, zinc, feather
pecking in cage systems, and cannibalism (Elliot, NRC 1994). Increased
protein level is correlated with reduced feather loss and cannibalism
(Ambrosen, 1997).

*(6) The alternatives to using the substance in terms of practices or
other available materials.*

Birds raised on pasture with access to insects and worms historically
did not need supplementation (Morrison, 1951), and smaller scale
pastured operations have success without the need for synthetic
supplements (Salatin, 1993). Pasture quality will vary according to
field conditions and the season. However, free range poultry on well
managed pasture are able to supplement their diets with insects,
annelids, and fresh green forage (Smith and Daniel, 1982). The two most
limiting amino acids, methionine and lysine, are found in richest
sources in proteins of animal origin. Common natural sources of these
amino acids have traditionally been fish meal and meat meal, especially
for starter chicks and broilers (Sainsbury, 2000). The USDA organic
program final rules do not allow the use of meat meal as feed for
poultry or mammals and may or may not allow fish or crab meal (7CFR
205).

Diets can be formulated without supplemented synthetic acids to meet the
objective of adequate methionine percentages, but this usually requires
an increase in crude protein level of the diet (Hadorn, 2000). Many
studies have been done to identify a cost effective method of lowering
protein content by supplementing with methionine and lysine. Often the
control treatments are non-supplement grain based diets. A comparison
study using supplemented and non-supplemented diets found that adequate
dietary methionine can be attained, at a cost of higher intake of
protein and less protein efficicy ratio (Emmert 2000). Another study fed
a control diet using only corn and soy to satisfy amino acid levels
compared to reduced protein supplemented with methionine and lysine, and
these treatments were considered successful because performance was not
lowered in 4-5 experiments (Harms, 1998).

Rice and casein offer potential novel available sources of methionine
(Lewis and Bayley, 1995). Yeast protein has long been known as a rich
protein source relatively high in methionine+cystine (Erbersdobler,
1973; National Research Council, 1994), as well as phosphorous and
B-complex vitamins (Morrison, 1951). As a natural feed supplement, NOSB
should advise whether yeast is considered agricultural and required from
organic sources or permitted as a natural substance. Other potential
sources of available methionine for poultry appear to be sunflower meal
and canola meal (Waibel et al., 1998). These natural sources are all
currently of limited availability in organic forms. Alfalfa meal is
reported to be a good additional protein source, though difficult to
blend in commercial formulations. Optimally balancing these nutrients
may be challenging to feed processors and livestock producers.

Feed sources with high percentages of methionine are bloodmeal, fish
meal, crab meal, corn gluten meal, and sunflower seed meal (National
Research Council, 1994). If fish meal were permitted, there is a lack of
supply that does not contain ethoxyquin, a synthetic antioxidant not
permitted under the final rules. A limited supply of fish meal preserved
with natural tocophorols has gone mostly into the pet food market
(Mattocks, 2001). Corn gluten and sunflower seed meal are not currently
very available in organic form, and feed formulators and nutritionists
have reported difficulty in meeting NRC requirements for methionine
based on currently available organic plant protein sources (Mattocks,
Morrisson, Simmons, 2001). One feed mill operator feels he can meet even
broiler needs with a combination of crab meal (at 75 lbs/ton or 3.75%)
and organic corn gluten (Martens, 2001). Crab meal is a by-product of
crab processing and not treated with preservatives but has limitations
due to salt content. Another certified feed mill produces layer and
range broiler rations without synthetic amino acids based only on plant
products, including corn, soy, barley, oats, wheat, field peas, and
flaxmeal. These products are labeled at a minimum of 0.3% met and 0.6%
lysine, but reportedly achieve good results (White 2001, VOG).

NRC requirements for amino acids and protein are designed to support
maximimum growth and production. The recommended levels for methionine
in poultry depend on species, stage, and level of feed consumption. For
chickens, recommendations for layers range from 0.25% to 0.38% and for
broilers 0.32 - 0.50%. NRC notes that maximum growth and production may
not always ensure maximum economic returns when protein prices are high,
and that if decreased performance can be tolerated, dietary
concentrations of amino acids may be reduced somewhat to maximize
economic returns (NRC, 1994). Methionine is known to have a direct
effect on egg weight (size) and rate of lay, and is used by some
producers to manipulate egg production to meet market needs, such as to
increase egg size in younger birds, reduce it in older birds, or produce
more eggs in off peak market periods (NRC 1994; Harms 1998; Simmons
2001). A reduction in rate of gain in broilers (longer time to finish)
would be an outcome of lower than optimal methionine levels. Unless the
diet contained other forms of sulfur containing amino acids (cystine or
cysteine), problems with inadequate feathering might be encountered
(Simmons, 2001).

Temporarily confined poultry can be fed a practical organic corn /
soybean ration. Depending on market conditions and on how other parts of
the standards evolve, novel organic products can be developed as
supplements. Among the potential alternative sources include organic
dairy products such as casein (National Research Council, 1982 and
1994).

Macroorganisms commonly found in healthy pasture soils cannot be
discounted as a source of nutrient cycling in free-range poultry
systems. Given the natural feeding habits of poultry and other birds,
the use of earthworms is a logical source of protein in chicken feed
(Fisher, 1988). Earthworm populations in a pasture depends on a number
of factors (Curry, 1998). The amino acid content of earthworms will vary
depending on species and food source. However, earthworms have been
found to accumulate and concentrate methionine found in the ecosystem in
proportions greater than for other amino acids (Pokarzhevskii, et al.,
1997). As a feed supplement, earthworms have been found to equal or
surpass fish meal and meat meal as an animal protein source for poultry
(Harwood and Sabine, 1978; Toboga, 1980; Mekada et al., 1979; and
Jin-you et al., 1982 all cited in Edwards, 1998).

Earthworms can play a role in moderating nitrogen losses as well. Enzyme
treatment of feedstuffs can improve amino acid availability and also
reduce nitrogen pollution (Tamminga and Verstegen, 1992), as can changes
in stocking density, rotations, and manure handling.

*(7) Its compatibility with a system of sustainable agriculture.*

In 1994 the NOSB recommended that feed and feed supplements be produced
organically. When considering the review of feed additive vitamins and
minerals, an NOSB statement of principles advised that non-synthetic
viamins and mineral sources are preferable when available. The NOSB also
advised that a farm plan should reflect attempts to decrease or
eliminate use of feed additives when possible (NOSB, 1995).

A constraint to optimal production in modern organic systems that are
not able to utilize pasture based systems appears to be adequate organic
sources of the first limiting amino acid, methionine. The allowance of
isolated amino acids facilitates the use of the lowest cost, non-diverse
corn-soy ration. It is the basis of conventional confinement animal
production systems which may be considered as antithetical to the
principals of organic livestock production. The source and method of
production of synthetic amino from non-renewable fossil fuels and toxic
chemicals is also questionable in compatibility with system of
sustainable agriculture.

The use of synthetic amino acids increases animal production by
increased efficiency of protein conversion, which lowers feeding costs
and reduces nitrogen content of the waste output. While this is not by
itself unsustainable, synthetic amino acids discourage the integration
of a whole-systems approach to cycling nutrients, particularly nitrogen,
as part of an integrated crop-livestock production system. Allowance of
synthetic sources of amino acids may discourage market development of
organic plant sources, such as seed meals.

Increased efficiency of protein conversion reduces the amount of
nitrogen excreted (Summers, 1993; deLange, 1993). The cycling of
nutrients from animals is part of an integrated farming system, and the
environmental effects of manure management requires looking at the big
picture (Archer and Nicholson, 1992). What is viewed as a liability in
confinement animal systems---nitrogen production---is seen in cropping
systems as a limiting factor resource. Reduction of nitrogen pollution
may require improved range or pasture management, and with that either
more frequent rotations or lower stocking rates

**Safety information, including a MSDS (Material Safety Data Sheet) and
report from National Institute of Environmental Health Studies
(NIEHS):**

*A MSDS for DL Methionine is attached to this petition. A search of the
National Institute of Environmental Health Sciences (NEIHS) website for
Methionine and DL Methionine yielded no Substance Reports.*

**Petition justification statement which states why the synthetic
substance is necessary, alternatives that could be used, beneficial
effects to the environment, etc:**

**[Overview / History]{.underline}**

In 2001, synthetic methionine \[hereafter referred to as MET\] was
approved for use in organic poultry production for use until October
2005. Three Technical Advisory Panel reviews were conducted prior to
this approval. In 2005, there was a petition to extend the deadline to
October 2008. This petition was approved unanimously by both the
Livestock Committee and the NOSB. This approval allowed for the
continued use of MET since the US organic poultry industry has
historically used MET.

For the past six years, organic poultry producers have worked to
reformulate feed rations without MET. Although methionine is the primary
limiting amino acid in poultry, the industry collectively believed that
we would be able to reformulate organic feed without it. For example, in
conventional poultry production, synthetic lysine (the second limiting
amino acid for poultry) is routinely added to the diet. And yet, organic
poultry producers have been able to successfully formulate feed without
lysine. However, our methionine reformulation efforts have not been
successful and the organic poultry industry still remains dependant upon
synthetic MET as a supplement.

As will be discussed in more detail below, the 2001 TAP Review
referenced a number of potential feed ingredients that could be used in
lieu of synthetic MET. Unfortunately, while some of these alternatives
have more methionine content than the typical ingredients in a poultry
diet, none of the alternatives are particularly rich in methionine.
Therefore, reformulation with these ingredients has not yet proved
successful.

During this same time, university research has been conducted on
alternative breeds to determine whether heritage or slower growing
breeds would have a lower methionine demand than the widely used
commercial breeds. However, Prof. Anne Fanatico's work at the University
of Arkansas has demonstrated that heritage and slow growing breeds have
the same methionine demand as commercial breeds.

At this point in time, neither the industry's feed reformulation efforts
nor the breed research has resulted in viable alternative to the use of
MET.

The Methionine Task Force \[hereafter referred to as MTF\], consists of
US organic poultry producers, many of whom were raising chickens
organically even prior to the national standards. The MTF has existed
since the first MET petition was approved and has continuously conducted
and sponsored research into alternatives to MET. The MTF has evaluated
an array of alternatives to MET and in turn has solicited voluntary
contributions from its members to fund research on these alternatives.
The results of these efforts are discussed in this petition.

**[Why MET is Necessary]{.underline}**

The primary benefit to MET use is animal health and welfare. As
referenced in the TAP review from May 21, 2001:

> A number of reports cite a benefit of methionine supplementation on
> reduced immunologic stress (Klasing, 1988; Tsiagbe et al, 1986).
> Immunologic stress is considered to be a response to microbial
> challenges, in these experiments due to injections of E. coli and
> Salmonella and other pathogens. This causes decreased feed rates and
> lower rates of growth. Chicks that received deficient levels of
> methionine were more subject to an impaired immune response.

The TAP review goes on to postulate that the impaired immune response is
a result of high density confinement, which if true, would not be as
relevant in an organic system. However, the trials conducted by the MTF
reflect lower growth rates when MET is reduced or eliminated, even in a
less densely populated organic environment.

The TAP review also notes that "reduced feathering has been reportedly
linked to lack of methionine and cystine (Elliott, no date)." The TAP
reviewer appropriately notes that there may be other factors involved,
including the deficiencies of other amino acids. Nonetheless, it needs
to be restated that organic poultry producers have eliminated all other
synthetic amino acids from the feed ration. Therefore, supplying
sufficient balances of the other amino acids is continually challenging,
and occasionally is not achieved. Consequently, the use of synthetic MET
is even more critical in organic poultry production since one of the
typical solutions (supplementation with other synthetic amino acids) is
not available.

The traditional signs of methionine deficiency (feather picking,
cannibalization, incomplete feather development, excessive mortality)
have been well documented in scientific literature. All of these
symptoms raise questions about animal health and welfare in the absence
of methionine.

To help the MTF better understand the implications of attempting to
raise chickens without MET, a number of ranch trials have been
conducted. Additional trials are either underway or currently being
designed for implementation in 2008.

A layer trial is underway at the University of Minnesota, sponsored by
Organic Valley/CROPP Cooperative. This trial is evaluating the
performance of a control group (standard organic diet) against a diet
excluding MET, but using high methionine corn in the place of standard
organic corn. The trial is not yet concluded, but preliminary results
show good performance on both groups, suggesting that a diet with high
methionine corn may be adequate to eliminate the use of MET. However, it
will take a substantial amount of time to confirm these results, and if
successful to implement growing high methionine corn on a commercial
scale necessary to substitute for MET.

The Methionine Task Force has also sponsored several broiler farm trials
in the past year. The broiler trials consisted of 4 groups:

1.  Standard organic diet (control group)

2.  Standard diet, but without MET

3.  Standard diet, excluding MET, but including Betaine\*

4.  Standard diet, excluding MET, but including Betaine and Corn Gluten
    Meal

*\*Betaine is an alkaloid commonly used in poultry diets. It is a methyl
donor which spares methionine in the bird. It is currently approved for
use in organic production.*

In all cases, the control groups performed the best, followed by group 4
(Betaine & Corn Gluten Meal). Field observers could readily pick out the
non MET groups, particularly group 2. These birds were smaller and less
developed. All of the non MET groups had unfavorable feed conversions
and meat yields relative to the control group.

In the broiler trials, the traditional signs of a methionine deficiency
were not seen in any of the groups without MET. Although these findings
are encouraging, it needs to be pointed out that the trials consisted of
small lots of birds raised in test housing. We recognize that most
organic producers grow chickens in a commercial setting with a higher
level of basic challenges (e.g. disease, rodents, housing quality).
Chickens given low levels of methionine may perform acceptably in an
ideal setting, but the same birds may exhibit the traditional signs of
methionine deficiency in a commercial setting.

Health through good nutrition is the fundamental key to successful
organic livestock production. Unlike conventional production, there is
little recourse available to a producer once disease manifests. MET is
considered a "Maintenance Nutrient" added to organic poultry rations
only in amounts necessary to achieve the basic nutritional level
necessary to maintain good health and avoid disease. In trial settings,
with optimal housing, MET deficiencies may not have tipped the balance
towards disease outbreaks and corresponding performance breakdowns. But
MTF members are very concerned that on the practical scale of commercial
poultry production, different results may be experienced. Additional
trials on a larger scale will be attempted in 2008 to address this
point.

The higher feed conversions seen in the "no methionine" trials have
other implications. Higher feed conversions mean that more organic
grains need to be produced and fed. From a whole systems perspective,
this does not appear to be a prudent utilization of resources and our
limited organic acreage.

Synthetic MET is a relatively modern material, only available to poultry
producers since the early 1950's. So the obvious question becomes, if
methionine is so critical to bird health and welfare, how were chickens
raised prior to the availability of MET? The answer has several
elements:

-   Prior to the inclusion of MET in the feed ration, diets were
    typically supplemented with meat and bone meal to add incremental
    methionine to the diet. Attached are sample rations from the 1940's
    which indicate how farmers met the nutritional needs of the birds
    before the advent of synthetics. Under NOP standards, meat and bone
    meal are not acceptable feed ingredients for livestock.

-   When going back to the pre-MET era, eggs and birds were typically
    much smaller. For example, prior to 1955, broilers averaged less
    than 3.3 lbs live weight. Flocks also experienced much higher levels
    of mortality and poorer feed conversion. A chart illustrating US
    Broiler Historical Bird Performance over time is attached for
    reference.

-   We feel that raising undersized chickens, with higher mortality and
    higher feed conversions, is unacceptable from an animal welfare and
    good poultry husbandry perspective.

**[Discussion of Alternatives]{.underline}**

The Methionine Task Force has commissioned a Literature Review to
identify the methionine needs of poultry, summarize the organic
livestock standards nationally and internationally, and discuss the
viability of potential alternatives. This review as conducted by Dr.
Bonny Burns-Whitmore at the California State Polytechnic University in
Pomona, CA. A summary of this report is attached.

The TAP review identified several potential feed ration alternatives.
One of the important findings in this Literature Review is that while
all of these alternatives carry "more" methionine than the traditional
Corn and Soybean Meal poultry diet, they do not carry "sufficient"
methionine to meet the bird's methionine demand unless included at very
high rates (resulting in other nutritional imbalances).

In addition, many of the alternatives cited in the TAP review are either
not available in organic form, or are only available in organic form in
a very small quantity (i.e. not commercially available). A Table
entitled SUMMARY OF METHIONINE SOURCES is attached for reference.

**[Status of Most Viable Alternatives]{.underline}**

1.  **Alternative Feed Ingredients**

**High Methionine Corn**

As evidenced by the University of Minnesota / Organic Valley trials
(ongoing), high methionine corn is one alternative feed ingredient with
considerable promise. Much of the work to develop these hybrids has been
done by Dr. Walter Goldstein of the Michael Fields Agricultural
Institute.

Methionine levels with these hybrids are typically are two times the
levels of standard organic corn. Per the ongoing University of Minnesota
/ Organic Valley trial, this level of methionine may be sufficient for
laying hens. But with turkeys and broilers, even though corn is a large
part of the organic poultry diet (60% or more), this higher level of
methionine alone is not sufficient to eliminate the need to use
synthetic MET.

Nonetheless, this alternative still looks promising in that:

-   Although presently still in the Research and Development phase, high
    methionine corn could be ready on a commercial scale within five
    years.

-   When used in conjunction with other feed ration additives (e.g.
    Betaine), this corn may eliminate the need to use MET.

-   The Methionine Task Force has committed funding for seed trials
    going on now in Chile and Hawaii. These trials are enabling the
    Michael Fields Agricultural Institute to accelerate the rate of
    hybrid experimentation, expand the stock of seed supply, and
    increase the number of planted acres in the US in 2008.

The significant challenges encountered with this alternative thus far
include:

-   **Agronomic viability**

> Farmers continue to express concerns about higher moisture levels and
> poorer yields in the first round of hybrids. Balancing the poultry
> producers demand for high methionine with the organic farmers demand
> for high yields has proven difficult.

-   **Time constraints**

> Significant research needs to be done in both corn production trials
> and poultry trials with new high methionine corn diets. Even with the
> multiple crop cycles offered by utilizing Chile and Hawaii, it will be
> years before the commercial viability of this alternative is tested
> and known.

-   **Economic consequences**

> Significant capital is required to continue the research and bring
> high methionine corn to a commercial scale. In addition, farmers will
> need to be financially incented to grow high methionine corn, rather
> than standard organic corn hybrids. As a result, high methionine corn
> will need to carry a price premium over standard organic corn. The
> level of premium, and therefore the economic impact to the US organic
> poultry producers, is completely unknown.

**Corn Gluten Meal**

As referenced earlier, the best bird performance in the broiler trials
resulted when corn gluten meal was included in the feed ration. In Dr.
Bonny Burns-Whitmore's report, several feed producers indicate that
organic corn gluten meal is available. ***However, no member of the Task
Force has ever been able to source this product in organic form.*** As
the MTF understands it, the problem is two fold:

-   **Process**

> The corn gluten meal manufacturing process appears to be inherently in
> conflict with organic principles. Unless an alternative processing
> technology were to be used, the manufacturing process is unlikely to
> meet the organic criteria. For example, sulphurous acid is used in the
> fermentation and steeping process. The current production standards
> and technologies will have to change to resolve this issue.

-   **Inputs**

> The current corn gluten plants are all "conventional" operations which
> do not segregate their input sources (organic vs. non-organic). The
> plants are large and require huge input volumes to maintain their
> productivity. No current plant in the US is appropriately sized or
> economically incented to segregate out organic inputs.

MTF members continue to hear that there may be some interest in
developing organic processing materials (e.g. high fructose corn syrup)
which in turn might lead to the production of organic corn gluten meal
(as a by-product). The MTF members would be very interested in this
product if developed, as a potential nutritional balancer for poultry
rations.

**Insect Meal**

At the NOSB Meeting in November 2007, the MTF became aware of a company
(Neptune Industries) that is working on a project to develop organic
insect meal for the aquaculture producers. According to company
literature, this product is high in methionine and offers great
potential for the US organic poultry industry as well. Much information
(protein percentage, methionine levels, availability, etc.) still needs
to be gathered and flock trials will need to be performed. Nonetheless,
this alternative offers potential as a long term solution.

2.  **Naturally Produced MET**

The MTF is most intrigued by the development of methionine produced
naturally through fermentation methods. To poultry producers, this
represents the most effective and likely economically viable
alternative. Unfortunately, to date the science in this area is
contradictory. Dr. Billy Hargis from the University of Arkansas is on
record with the MTF indicating that "...I am sorry that it does not look
like the simple idea of selecting for high methionine content producing
natural flora has a probability of success."

Nonetheless, the MTF has initiated discussions with Dr. Steve Ricke,
Food Safety Endowed Chair and Director of the Center for Food Safety,
University of Arkansas. Dr. Ricke has committed to reviewing this
possibility further with the intention of developing a method to produce
methionine naturally.

In addition, the MTF continues to take inquiries from private firms who
believe that development of this product is possible. The MTF envisions
that it will continue to work with any and all parties on developing
such a product.

3.  **Genetic Selection**

At the time of the last petition in 2005, it was felt that part of the
solution to eliminating MET from organic poultry production lay in
finding suitable alternative or heritage breeds as well as commercial
hatcheries willing to produce sufficient quantities for the organic
market. This area of research was being pursued by Prof. Anne Fanatico
at the University of Arkansas. Subsequently, this research has been
completed, with the surprising finding that heritage and/or commercial
slow growing breeds have the same methionine demand as the more widely
used, faster growing commercial breeds.

Within the commercial breeds, however, there may be sufficient
variability to select for those birds with lower methionine needs. For
example, the broiler farm trails conducted to date by the MTF indicate
that there is a wide range of performance within the "No Methionine"
groups. Even without MET being added to the diet, some of the birds in
these groups performed remarkably well---similar to the standard diet
control groups. The wide range of performance variability suggests that
even within the commercial breeds there is the potential to genetically
select for birds that perform acceptably even with lower levels of
methionine.

This selection process will take time and it is unknown what other
unintended traits may manifest themselves. While genetic selection
through selective breeding offers potential for broilers, no such
results with layers have been observed. This is clearly a very long term
solution requiring significant additional research before it could be
considered truly viable.

**Conclusion:**

Methionine is the first limiting amino acid in poultry. Sufficient
levels of methionine must be found in a poultry diet, balanced
appropriately with the other feed ingredients. Without supplemental
methionine and a nutritionally balanced diet, bird health and growth
performance suffer.

Poultry growing has advanced tremendously in the last fifty years. Prior
to the advent of synthetics, farmers supplemented the diet with
ingredients that are not allowed in organic production (e.g. bone meal,
meat meal, meat scraps). Chicken mortalities were higher and feed
conversions poorer, indicating that overall raising standards and animal
husbandry were well below current standards.

The MTF members are united in the belief that MET can eventually be
eliminated from organic production.

However, with less than one year before the current annotation expires,
several things are apparent:

1.  The US organic poultry industry is not currently able to eliminate
    MET from organic poultry rations

2.  Although the MTF has identified several viable alternatives to MET,
    none of them are currently commercially available

3.  The ongoing cycle of annotations and petitions every three years has
    become problematic for the NOSB, the NOP, and organic poultry
    farmers

**Consequently, we now petition for the removal of the date of October
1, 2008 from the listing of synthetic methionine \[MET\] in Section
205.603 of the National List as a synthetic substance allowed for use in
organic livestock production as a feed additive for poultry, and submit
MET to the standard sunset review process.**

In this petition, we have gathered a significant amount of information
in order to substantiate our case. We have presented it here as openly,
honestly and transparently as possible in the hopes of stimulating an
open, honest and transparent discussion among the NOSB, the NOP and the
organic community. We look forward to this discussion and offer our
further services in order to clarify, elaborate or in any other way
assist the process.

Final Note: this petition focuses on chicken since the MTF members have
the greatest expertise in chicken, but MET is currently allowed in all
organic poultry production. Consideration needs to be given to the
potential impact of MET to other organic poultry such as turkeys, ducks,
geese, game birds, and ratites.

**Commercial Confidential Information Statement - describing information
that is considered to be confidential business or commercial
information:**

-   *None of the information submitted in this report is considered
    confidential.*

**LIST OF ATTACHMENTS AND STATUS**

Current as of December 14, 2007

-   **Methionine Task Force Members** *--attached*

-   **MSDS Sheet for DL Methionine** *--attached*

-   **Poultry Diets from the 1940's** *--attached*

-   **US Broiler Historical Bird Performance** *--attached*

[]{.mark}

-   **A Review of Recent Scientific Research of Methionine**
    *--attached\
    *

-   **Summary of Methionine Sources** *--attached***\
    \
    **

[]{.mark}

**[Methionine Task Force Members]{.underline}**

  ----------------------------------- -----------------------------------
  ***Company Name***                  ***Representatives***

  Eberly Poultry                      Bob Eberly

  Kreamer Feed                        Bob Schwartz, Steve Smelter

  Heritage Poultry                    Chris Pierce, Mel Gehman

  Organic Valley / CROPP Cooperative  David Bruce, Jim Pierce

  Chino Valley Ranchers               David Will, Steve Nichols

  Free Bird Chicken / Hain Celestial  Joe DePippo, Hank Correll

  Organics Unlimited                  Ken Rice

  Foster Farms                        Sun Kim, Norm Ramos

  Coleman Natural Foods               Dave Martinelli, Mike Leventini

  Hidden Villa Ranch                  Mike Sencer

  Pete and Gerry's Organic Eggs       Jesse Laflamme

  SonCrest Eggs                       Randy Boone
  ----------------------------------- -----------------------------------

**[Material Safety Data Sheet (MSDS) for DL Methionine]{.underline}**

![](media/image1.png){width="5.997222222222222in"
height="8.69513888888889in"}

![](media/image2.png){width="5.920833333333333in"
height="8.994444444444444in"}

![](media/image3.png){width="5.842361111111111in"
height="8.998611111111112in"}

![](media/image4.png){width="5.993055555555555in"
height="8.960416666666667in"}

**[US Broiler Historical Growth Performance]{.underline}**

Source: Poultry USA, Watt Publications, February 2002

![](media/image5.png){width="5.427083333333333in"
height="3.1666666666666665in"}

**[Poultry Diets from the 1940's]{.underline}**

![](media/image6.png){width="5.992361111111111in"
height="8.847916666666666in"}![](media/image7.png){width="5.821527777777778in"
height="8.991666666666667in"}

**[SUMMARY OF METHIONINE SOURCES]{.underline}**

+-----------+-------+------+-----+-----+--------+---------------------+
| **Alte    | *     | *    | **  | **  | **     | **Other Comments**  |
| rnative** | *Appr | *Syn | Nat | Org | Commer |                     |
|           | ox.** | thet | ura | ani | cially |                     |
|           |       | ic** | l** | c** | Avail  |                     |
|           | **    |      |     |     | able** |                     |
|           | Methi |      |     |     |        |                     |
|           | onine |      |     |     |        |                     |
|           | %**   |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Dl        | 99.00 | Yes  |     |     |        | Included as         |
| M         |       |      |     |     |        | 0.001-0.0025% of    |
| ethionine |       |      |     |     |        | ration              |
+-----------+-------+------+-----+-----+--------+---------------------+
| Corn      | 0.18  |      |     | Yes | Yes    | *Currently in       |
|           |       |      |     |     |        | Poultry Ration*     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Hi        | 0.36  |      |     | Yes | No     | In R&D Phase        |
| M         |       |      |     |     |        |                     |
| ethionine |       |      |     |     |        |                     |
| Corn      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Soybean   | 0.60  |      |     | Yes | Yes    | *Currently in       |
| Meal      |       |      |     |     |        | Poultry Ration*     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Sesame    | 1.26  |      |     | Yes | No     | Deficient in Lysine |
| Meal      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Sunflower | 0.72  |      |     | Yes | No     | Relatively Low      |
| Meal      |       |      |     |     |        | Methionine          |
+-----------+-------+------+-----+-----+--------+---------------------+
| Canola    | 0.75  |      |     | Yes | No     | Relatively Low      |
| Meal      |       |      |     |     |        | Methionine          |
+-----------+-------+------+-----+-----+--------+---------------------+
| Alfalfa   | 0.20  |      |     | Yes | No     | Very Low Methionine |
| Meal      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Corn      | 1.50  |      | Yes |     |        | Not available in    |
| Gluten    |       |      |     |     |        | organic form        |
| Meal      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Flax Meal | 0.50  |      |     | Yes | No     | Relatively Low      |
|           |       |      |     |     |        | Methionine          |
+-----------+-------+------+-----+-----+--------+---------------------+
| Blood     | 1.00  |      |     | No  |        | Not allowed: Animal |
| Meal      |       |      |     |     |        | By Product          |
+-----------+-------+------+-----+-----+--------+---------------------+
| Insects   | Un    |      |     |     | No     | Pilot project under |
|           | known |      |     |     |        | development         |
+-----------+-------+------+-----+-----+--------+---------------------+
| Earthworm | 1.60  |      |     |     | No     | Not being produced  |
| Meal      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Crab Meal | 0.50  |      |     |     |        | Not available in    |
|           |       |      |     |     |        | organic form        |
+-----------+-------+------+-----+-----+--------+---------------------+
| Meat Meal | 0.81  |      |     |     |        | Not allowed: Animal |
|           |       |      |     |     |        | By Product          |
+-----------+-------+------+-----+-----+--------+---------------------+
| Rice      | 0.22  |      |     | Yes | No     | Very Low Methionine |
+-----------+-------+------+-----+-----+--------+---------------------+
| Casein    | 2.56  |      |     | Yes | No     | Ratio of methionine |
|           |       |      |     |     |        | to cystine is poor  |
+-----------+-------+------+-----+-----+--------+---------------------+
| Milk      | 0.79  |      |     | Yes | Yes    | Relatively Low      |
| Powder,   |       |      |     |     |        | Methionine          |
| Skim      |       |      |     |     |        |                     |
+-----------+-------+------+-----+-----+--------+---------------------+
| Potato    | 1.60  |      | Yes |     | No     | Not available in    |
| Protein   |       |      |     |     |        | organic form        |
+-----------+-------+------+-----+-----+--------+---------------------+
| Fish Meal | 1.68  |      | Yes | ??  |        | Not available in    |
|           |       |      |     |     |        | organic form, ratio |
|           |       |      |     |     |        | of methionine to    |
|           |       |      |     |     |        | cystine is poor     |
+-----------+-------+------+-----+-----+--------+---------------------+