United States Agricultural 1400 Independence Avenue, S.W. 

Agricultural Department of Marketing Room 2642-S, Mail Stop 0268

Marketing Agriculture Service Washington, D.C. 20250-0268

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February 29, 2016

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Miles V. McEvoy

Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations (October 2015)

Background

The National Organic Standards Board (NOSB) is a 15-member Federal Advisory Committee 

comprised of organic community and stakeholder representatives. The Board was established by 

the Organic Foods Production Act of 1990 and charged with the following:

• Providing advice to the USDA about whether substances should be allowed or prohibited in 

organic production and/or handling

• Assisting with the development of standards for organic production, and

• Advising the Secretary on other aspects of the implementation of the Organic Foods

Production Act.

The NOSB advises USDA on which substances should be allowed or prohibited in organic 

farming and processing, based on criteria under the Organic Foods Production Act. The NOSB 

must also review each substance on the National List every five years to determine whether it 

continues to meet all required criteria; this is referred to as the “sunset” review. 

This memorandum responds to National Organic Standards Board (NOSB) recommendations as 

a result of the oral comments given via webinar on October 13th and 20th, 2015, as well as at the 

October 26-29, 2015 meeting of the NOSB in Stowe, Vermont. The NOSB provided a series of 

recommendations to USDA at the meeting. All motions by the NOSB require a 2/3 majority to 

pass.

Summary of Recommendations from Fall 2015 NOSB Meeting

1. Petitioned Substances. The NOSB recommended one amendment to the National List of 

Allowed and Prohibited Substances (National List). This section of the USDA organic 

regulations includes synthetic substances allowed in crop and livestock production, nonsynthetic 

substances prohibited in crop and livestock production, and all substances allowed in the 

handling of organic products. 
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 2

 

Substance Section Action Considered by NOSB and 

the NOSB Recommendation

Flavors §205.605(a) The motion to amend the annotation 

passed

2. 2017 Sunset Review: The NOSB completed the 2017 sunset review for 198 substances.

The NOSB considered motions to remove each of these substances from the National List.

Please see Appendix 1 for a complete list of all substances reviewed and those recommended 

for removal.

Upon completing the Sunset 2017 review, the NOSB recommended 11 substances for removal: 

lignin sulfonate, furosemide, magnesium carbonate, chia (Salvia hispanica L.), dillweed oil, 

galangal, inulin-oligofructose enriched, lemongrass, peppers (Chipotle chile), Turkish bay 

leaves, and whey protein concentrate.
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 3

 

Substance Section Action Considered by NOSB

NOSB Recommendation

Lignin sulfonate §205.601(l)(1) The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review

and also acknowledged and supported the 

petition that requested its removal.

Furosemide §205.603(a) The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Magnesium 

carbonate 

§205.605(b) The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Chia (Salvia hispanica 

L.)

§205.606 The motion to remove the following substance 

from the National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Dillweed oil §205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Galangal §205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Inulin-oligofructose

enriched

§205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 4

 

Lemongrass §205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Peppers (Chipotle 

chile)

§205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Turkish bay leaves §205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

Whey protein 

concentrate

§205.606 The motion to remove this substance from the 

National List passed.

The NOSB recommended removal from the 

National List as a result of its sunset review.

3. Other Recommendations

EPA List 4 Inert ingredients

The NOSB passed a recommendation to revise the annotation for inerts at 205.601(m) and 

205.603(e).

Micronutrients for Crop Production, 205.601(j)

The NOSB passed a recommendation to revise the annotation for micronutrients at 205.601(j)(6). 

Reclassification of Alginic acid

The NOSB passed a recommendation to reclassify aliginic acid, which is currently listed on 

206.605(a), as synthetic and move it to section 205.605(b). 

Reclassification of Carnauba wax 

The NOSB passed a recommendation to reclassify carnauba wax, which is currently listed on 

206.605(a), as agricultural and move it to section 205.606.
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 5

 

NOP Discussion and Response

The NOP reviewed the NOSB’s recommendations and will be pursing the following intended 

actions. 

1. Petitioned Substances

Flavors

At the October 2015 meeting, the NOSB recommended to revise the flavors annotation at 

§205.605(a) to read: Non-synthetic flavors may be used when organic flavors are not 

commercially available. All flavors must be derived from organic or nonsynthetic sources only, 

and must not be produced using synthetic solvents and carrier systems or any artificial 

preservative.

Flavors are currently listed at §205.605(a) with the annotation “Flavors, nonsynthetic sources 

only and must not be produced using synthetic solvents and carrier systems or any artificial 

preservative.”

The 2017 Sunset review was also considered at the fall 2015 meeting concurrently with the 

petition to revise the flavor annotation. Flavors are comprised of several types of products, e.g., 

distillates, extracts, isolates, oleoresins, essential oils, compounded flavors, reaction flavors. 

Natural flavors can be produced from plants, animals and microorganisms.

NOP Response: 

The NOP has reviewed the NOSB’s recommendation and plans to move forward with a proposed 

rule for public comment.

2. 2017 Sunset Review

The NOSB completed the sunset review for 198 substances as a part of the Sunset 2017 review 

and recommended the removal of 11 substances: lignin sulfonate, furosemide, magnesium 

carbonate, chai (Salvia hispanica L.), dillweed oil, galangal, inulin-oligofructose, lemongrass, 

peppers (Chipotle chile), Turkish bay leaves, and whey protein concentrate. Please see the end of 

this document for a complete list of all substances reviewed and those recommended for 

removal.

• Lignin sulfonate: The NOSB determined that its use in organic crop production, 

specifically as a floatation agent in post-harvest handling, is no longer essential. The 

NOSB therefore recommended its removal from the National List. 

• Furosemide: Comments were provided from the public on the use of furosemide. Those

in support of relisting stated that furosemide is an important diuretic-saluretic for the 

humane treatment of organic animals. Comments in opposition stated that its use is 

limited and there are other natural alternatives. The NOSB recommended removing
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 6

 

furosemide from the National List based on it not being necessary for organic livestock 

production. 

• Magnesium carbonate: The NOSB determined that this material, which is currently only 

allowed in “made with organic” products, is not essential to organic handling and that 

alternatives exist. The NOSB recommended removing magnesium carbonate from the 

National List.

• Chia (Salvia hispanica L.): The NOSB requested information from the public related to 

commercial demand, commercial availability, alternatives, and necessity and use. Several 

comments from a cross-section of the organic community were received in support of the 

delisting of chia, noting its wide commercial availability in organic form. The NOSB 

determined that based on the commercial availability of organic chia, it should be 

removed from the National List. 

• Dillweed oil: The NOSB requested information from the public related to commercial 

demand, commercial availability, alternatives, and necessity and use. No comments were 

received that supported the relisting of dillweed oil. According to the NOSB Handling 

Subcommittee proposal, dillweed oil also meets the definition of flavors, non-synthetic, 

and dillweed and dillweed oil appear to be commercially available in organic form. The 

NOSB therefore recommended removing it from the National List. 

• Galangal: The NOSB requested information from the public related to commercial 

demand, commercial availability, alternatives, and necessity and use. No comments were 

received that supported the relisting of galangal. According to the NOSB Handling 

Subcommittee proposal, galangal appears to be commercially available in organic form. 

The NOSB therefore recommended removing it from the National List.

• Inulin-oligofructose: The NOSB requested information from the public on commercial 

availability, ancillary substances, current use and demand for inulin-oligofructose, and 

alternatives. Given the comments received concerning the availability of organic inulin, 

the separate listing of fructooligosaccharides, information from certifiers of operations 

switching to organic inulin, and the absence of information on continued commercial 

unavailability of the organic inulin, the NOSB recommended removing it from the 

National List.

• Lemongrass: The NOSB requested information from the public related to commercial 

demand, commercial availability, alternatives, and necessity and use. Comments were 

received from a cross-section of the organic community in support of delisting frozen 

lemongrass noting it is commercially available in organic form. No specific comments 

received supported relisting or addressed commercial unavailability of frozen organic 

lemongrass. The NOSB therefore recommended lemongrass-frozen be removed from the 

National List.
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 7

 

• Peppers (Chipotle chile): The NOSB requested information from the public related to 

commercial demand, commercial availability, alternatives, and necessity and use. Several 

comments from a cross-section of the organic community were received in support of 

delisting chipotle peppers noting its commercial availability in organic form. No specific 

comments received supported relisting or addressed commercial unavailability of organic 

chipotle peppers. The NOSB therefore recommended peppers (Chipotle chile) be 

removed from the National List.

• Turkish bay leaves: The NOSB requested information from the public related to 

commercial demand, commercial availability, alternatives, and necessity and use. 

According to the NOSB, searches of publically available organic sourcing sites found 

organic sources of Turkish bay leaves. The NOSB therefore recommended Turkish bay 

leaves be removed from the National List.

• Whey protein concentrate: The NOSB requested information from the public related to 

ancillary ingredients, commercial demand, commercial availability, alternatives, and 

necessity and use. Information received from the original petitioner stated that they had 

secured a supply of organic whey protein for several years. There was no detailed 

information on whether organic supplies were insufficient. The NOSB therefore 

recommended the removal of whey protein concentrate from the National List on the 

basis that organic whey protein concentrate is available. 

This action completes the NOSB’s responsibility to review substances scheduled for the 2017 

sunset review, according to the Organic Foods Production Act (OFPA) sunset provision (7 

U.S.C. 6517(e)). 

NOP Response:

The NOP accepts the NOSB’s completed 2017 Sunset review. The NOP is reviewing these 

recommendations and plans to move forward with a proposed rule for public comment. AMS 

also intends to publish a notice to renew the other 187 substances, as listed in the relevant tables 

at the end of this document, on the National List for another five years. 

3. Other Recommendations

EPA List 4 Inert ingredients

The NOSB passed a recommendation to revise the annotation for inerts at sections 205.601(m) 

and 205.603(e) of the National List.

The purpose for the annotation change is to remove reference in the regulation to the EPA List 4, 

since it is no longer maintained by the Environmental Protection Agency. In order to thoroughly 

evaluate inerts for compatibility with organic materials, the NOSB plans to work with the EPA 

Safer Choice Program. This recommendation acknowledges the current nomenclature in use by 

the EPA regarding FIFRA 25(b) and 40 CFR 180.1122, while laying a framework for some 

inerts to be reviewed individually. The recommended annotation is as follows:
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 8

 

205.601(m) and 205.603(e) – As synthetic inert ingredients as classified by the Environmental 

Protection Agency (EPA), for use with nonsynthetic substances or synthetic substances listed in 

this section and used as an active pesticide ingredient in accordance with any limitations on the 

use of such substances. 

(i) Substances permitted for use as inerts in minimal risk products exempt from 

pesticide registration under FIFRA section 25(b).1

(ii) Substances included on the EPA’s Safer Chemical Ingredient List.

(iii) Inert ingredients that are exempt from the requirement of a tolerance under 

40 CFR 180.1122 – for use only in passive pheromone dispensers. 

NOP Response: 

The NOP has reviewed the NOSB’s recommendation and plans to collaborate further with 

EPA’s Safer Choice Program to develop a program for inert ingredient review, and to initiate 

notice and comment rulemaking to revise the annotations for inert ingredients at 205.601(m) and 

205.603(e).

Micronutrients on Section 205.601(j)

The NOSB passed a recommendation to revise the annotation for micronutrients for organic crop 

production at 205.601(j)(6). The current listing reads as follows:

205.601 (j) - As a plant or soil amendment. 

(6) Micronutrients - not to be used as a defoliant, herbicide, or desiccant. Those made from 

nitrates or chlorides are not allowed. Soil Deficiency must be documented by testing.

to:

205.601 (j) - As a plant or soil amendment. 

(6) Micronutrients - not to be used as a defoliant, herbicide, or desiccant. Those made from 

nitrates or chlorides are not allowed. Deficiency must be documented.

The NOSB recommended that the annotation be changed because they determined there are a 

number of ways to determine soil and crop deficiencies, including tissue testing, professional 

opinions from agronomists and crop advisors, extension publications, and regional knowledge. 

NOP Response: 

The NOP has reviewed the NOSB’s recommendation and plans to initiate rulemaking for public 

comment to revise the annotation for micronutrients at section 205.601(j)(6). 

 1 http://www.epa.gov/opprd001/inerts/section25b_inerts.pdf. EPA has published a proposed rule at FR 77:76979 to 

codify the list of actives and inerts eligible for minimal risk products, when finalized the NOP reference will cite 

this. 
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 9

 

Reclassification of Alginic Acid 

The NOSB passed a recommendation to reclassify alginic acid, which is currently listed as a 

nonsynthetic substance on 206.605(a), as synthetic and move to section 205.605(b). 

Alginic acid exists naturally in both brown seaweeds and two bacterial genera. However, the 

NOSB determined that the manufacturing process for industrial alginic acid could be considered 

a synthetic process when assessed against Draft Guidance on Classification of Materials (NOP 

Guidance 5033) document and the information presented in the 2015 technical report. 

The NOSB recommended that alginic acid remain on the National List but that the listing is 

changed from section 205.605(a) to section 205.605(b) due to the determination that alginic acid 

would be classified as synthetic under the Draft Classification of Materials document. 

NOP Response: 

The NOP has reviewed the NOSB’s recommendation and plans to initiate rulemaking for public 

comment to revise the listing for alginic acid. If finalized, alginic acid, which is currently listed 

on section 205.605(a), will be classified as synthetic and moved to section 205.605(b). 

Reclassification of Carnauba Wax as Agricultural

The NOSB passed a recommendation to reclassify carnauba, which is currently listed on 

205.605(a), as agricultural and move it to section 205.606. 

Carnauba wax is extracted from palm trees. It is used to coat fruits and vegetables, candies and 

as a base for chewing gum. The NOSB assessed the manufacturing process of carnauba wax

against the Draft Guidance on Classification of Materials (NOP Guidance 5033) document and 

determined it to be agricultural, based on the definition of "agricultural product" at § 205.2 of the 

USDA organic regulations. According to the NOSB, there is also some organically grown 

carnauba on the market.

NOP Response: 

The NOP has reviewed the NOSB’s recommendation and plans to initiate rulemaking for public 

comment to revise the listing for carnauba wax. If finalized, carnauba wax, which is currently 

listed on 205.605(a), will be classified as agricultural and moved to section 205.606. 

4. Summary

The NOP acknowledges and sincerely appreciates the hundreds of hours NOSB members

provided in developing the NOSB October 2015 recommendations, particularly the substantial 

amount of work required due to the large number of 2017 sunset reviews needed. In addition, 

the NOP supports the NOSB’s vital role in representing the diversity of the organic community 

to enhance organic regulatory implementation and ensure organic product integrity.
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 10

 

Appendix 1 – 2017 Sunset Review

Sunset 2017 Review

Action Considered: Motion to Remove | Outcome: Passed 

Final NOSB Recommendation: See Below

Use Area Substance Section NOSB Final Recommendation

Crops Lignin sulfonate 205.601(l)(1) Remove from National List as a floating 

agent in postharvest handling

Livestock Furosemide 205.603(a) Remove from National List

Handling Magnesium 

carbonate

205.605(b) Remove from National List

Handling Chia (Salvia 

hispanica L.)

205.606 Remove from National List

Handling Dillweed oil 205.606 Remove from National List

Handling Galangal 205.606 Remove from National List

Handling Inulin-oligofructose 

enriched

205.606 Remove from National List

Handling Lemongrass 205.606 Remove from National List

Handling Peppers (Chipotle 

chile)

205.606 Remove from National List

Handling Turkish bay leaves 205.606 Remove from National List

Handling Whey protein 

concentrate

205.606 Remove from National List

NOSB Meeting Update: Sunset 2017 Review 

Sunset 2017 Review – Crop Production

Action Considered: Motion to Remove | Outcome: Failed 

Status: Sunset Review Completed

Substance Section Substance Section

Alcohols: Ethanol 205.601(a) Hydrated lime 205.601(i)

Alcohols: Isopropanol 205.601(a) Potassium bicarbonate 205.601(i)

Chlorine Materials: 

Calcium hypochlorite, 

Chlorine dioxide, Sodium 

hypochlorite

205.601(a) Aquatic plant extracts 205.601(j)

Soap-based 

algicide/demossers

205.601(a) Humic acids 205.601(j)

Hydrogen peroxide 205.601(a), 

(i)

Lignin sulfonate (chelating agent) 205.601(j)

Herbicides, soap-based 205.601(b) Magnesium sulfate 205.601(j)

Newspaper or other 

recycled paper

205.601(b), 

(c)

Micronutrients: Soluble Boron 

Products, Sulfates, carbonates, 

oxides, or silicates of zinc, copper, 

205.601(j)
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 11

 

iron, manganese, molybdenum, 

selenium, and cobalt

Plastic mulch and covers 

(petroleum-based other 

than polyvinylchloride 

(PVC))

205.601(b) Liquid fish products 205.601(j)

Soaps, ammonium 205.601(d) Vitamin B1, C, E 205.601(j)

Ammonium carbonate 205.601(e) Ethylene 205.601(k)

Boric acid 205.601(e) Sodium silicate 205.601(l)

Elemental sulfur 205.601(e), 

(i), (j)

EPA List 4 - Inerts of Minimal 

Concern

205.601(m)

Lime sulfur 205.601(e), 

(i)

Microcrystalline cheesewax 205.601(o)

Oils, horticultural 205.601(e), 

(i)

Ash from manure burning 205.602(a)

Soaps, insecticidal 205.601(e) Arsenic 205.602(b)

Sticky traps/barriers 205.601(e) Lead salts 205.602(d)

Sucrose octanoate esters 205.601(e) Potassium chloride 205.602(e)

Pheromones 205.601(f) Sodium fluoaluminate (mined) 205.602(f)

Vitamin D3 205.601(g) Strychnine 205.602(h)

Coppers, fixed 205.601(i) Tobacco dust (nicotine sulfate) 205.602(i)

Copper sulfate 205.601(i)

Sunset Review - Handling

Action Considered: Motion to Remove | Outcome: Failed 

Status: Sunset Review Completed

Substance Section Substance Section

Acid, Alginic 205.605(a) Potassium acid tartrate 205.605(b)

Acid, Citric & lactic 205.605(a) Potassium carbonate 205.605(b)

Attapulgite 205.605(a) Potassium citrate 205.605(b)

Bentonite 205.605(a) Potassium phosphate 205.605(b)

Diatomaceous earth 205.605(a) Sodium citrate 205.605(b)

Kaolin 205.605(a) Sodium hydroxide 205.605(b)

Perlite 205.605(a) Sodium phosphates 205.605(b)

Calcium carbonate 205.605(a) Sulfur dioxide 205.605(b)

Calcium chloride 205.605(a) Tocopherols 205.605(b)

Dairy cultures 205.605(a) Xanthan gum 205.605(b)

Enzymes 205.605(a) Casings 205.606

Flavors 205.605(a) Celery powder 205.606

Magnesium sulfate 205.605(a) Colors: Beet juice extract color 205.606

Nitrogen 205.605(a) Colors: Black currant juice color 205.606

Oxygen 205.605(a) Colors: Pumpkin juice color 205.606

Potassium chloride 205.605(a) Colors: Red cabbage extract color 205.606
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 12

 

Potassium iodide 205.605(a) Colors: Black/Purple carrot juice 

color

205.606

Sodium bicarbonate 205.605(a) Colors: Blueberry juice color 205.606

Sodium carbonate 205.605(a) Colors: Carrot juice color 205.606

Waxes: Carnauba Wax 205.605(a) Colors: Cherry juice color 205.606

Waxes: Wood rosin 205.605(a) Colors: Chokeberry—Aronia juice 

color

205.606

Yeast 205.605(a) Colors: Elderberry juice color 205.606

Acidified sodium chlorite 205.605(b) Colors: Grape juice color 205.606

Alginates 205.605(b) Colors: Grape skin extract color 205.606

Ammonium bicarbonate 205.605(b) Colors: Paprika color 205.606

Ammonium carbonate 205.605(b) Colors: Purple potato juice 205.606

Ascorbic acid 205.605(b) Colors: Red radish extract color 205.606

Calcium citrate 205.605(b) Colors: Saffron extract color 205.606

Calcium hydroxide 205.605(b) Colors: Turmeric extract color 205.606

Calcium phosphates: 

monobasic, dibasic, 

tribasic

205.605(b) Fish oil 205.606

Carbon dioxide 205.605(b) Fructooligosaccharides 205.606

Chlorine Materials: 

Calcium hypochlorite, 

Chlorine dioxide, Sodium 

hypochlorite

205.605(b) Gelatin 205.606

Ethylene 205.605(b) Gums: Arabic, Carob bean, Guar, 

Locust bean

205.606

Ferrous sulfate 205.605(b) Kelp 205.606

Glycerides, mono and di 205.605(b) Konjac flour 205.606

Glycerin 205.605(b) Lecithin—de-oiled 205.606

Hydrogen peroxide 205.605(b) Orange pulp, dried 205.606

Magnesium chloride 205.605(b) Orange Shellac - unbleached 205.606

Magnesium stearate 205.605(b) Pectin (non-amidated forms only) 205.606

Nutrient vitamins and 

minerals

205.605(b) Seaweed, Pacific kombu 205.606

Ozone 205.605(b) Starches, Cornstarch (native), 

Sweet potato 

205.606

Phosphoric acid 205.605(b) Wakame seaweed (Undaria 

pinnatifida)

205.606

Sunset Review - Livestock Production 

Action Considered: Motion to Remove | Outcome: Failed 

Status: Sunset Review Completed

Substance Section Substance Section 
Memorandum to NOSB

Response to NOSB Recommendations October 2015

Page 13

 

Alcohols: Ethanol, 

Isopropanol 

205.603(a) Parasiticides: Moxidectin 205.603(a) 

Aspirin 205.603(a) Peroxyacetic/Peracetic acid 205.603(a) 

Atropine 205.603(a) Phosphoric acid 205.603(a) 

Biologics, Vaccines 205.603(a) Poloxalene 205.603(a) 

Butorphanol 205.603(a) Tolazoline 205.603(a) 

Chlorhexidine 205.603(a) Xylazine 205.603(a) 

Chlorine Materials: 

Calcium hypochlorite, 

Chlorine dioxide, Sodium 

hypochlorite 

205.603(a) Copper sulfate 205.603(b) 

Electrolytes 205.603(a) Formic Acid 205.603(b) 

Flunixin 205.603(a) Lidocaine 205.603(b) 

Glucose 205.603(a) Lime, hydrated 205.603(b) 

Glycerin 205.603(a) Mineral oil 205.603(b) 

Hydrogen peroxide 205.603(a) Procaine 205.603(b) 

Iodine 205.603(a), 

205.603(b), 

Sucrose octanoate esters 205.603(b) 

Magnesium hydroxide 205.603(a) Methionine 205.603(d) 

Magnesium sulfate 205.603(a) Trace minerals 205.603(d) 

Oxytocin 205.603(a) Vitamins 205.603(d) 

Parasiticides: 

Fenbendazole 

205.603(a) Excipients 205.603(f) 

Parasiticides: Ivermectin 205.603(a) Strychnine 205.604(a)