Updated June 17, 2010 

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Attapulgite

Chair: Tracy Miedema

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X

Guidance Statement

Other

Statement of the Recommendation (Including Recount of Vote): 

To add Attapulgite – allowed as a processing aid in the handling of plant and 

animal oils to section 205.605(a) of the National List with the following annotation, 

“allowed as a processing aid in the handling of plant and animal oils”

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

This material was petitioned to the NOSB for use as a processing aid in the 

production of organic plant and vegetable oils, as a natural substance used to 

bring oils to a marketable condition through removal of impurities such as

undesirable odors, colors, and trace metals, etc. The Handling Committee voted 6 

yes, 0 no, and 1 absent for the listing of this material, with the annotation “allowed 

as a processing aid in the handling of plant and animal oils”, to the National List, 

thereby recommending that it be listed. The full board voted that attapulgite be 

classified as non-synthetic and approved listing it with the annotation above at its

April 2011 meeting.

As described in the attached Handling Committee recommendation, this 

material satisfied all applicable evaluation criteria for consistency with organic 

handling practices. There was no public comment opposing it’s listing in 

response to publication of the Handling Committee’s recommendation prior to 

the full board meeting. 

NOSB Vote

Moved: Steve DeMuri Second: Mac Stone

Yes: 12 No: 1 Abstain: 1 Absent: 0 Recusal: 0
Decision Sheets 

April 2010 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: Spring 2011—Seattle, Washington Substance: Attapulgite 

Committee: Crops  Livestock  Handling X Petition is for: Addition of Attapulgite on the National List § 205.605(a) 

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

1. Impact on Humans and Environment Yes X No  N/A 

2. Essential & Availability Criteria Yes X No  N/A 

3. Compatibility & Consistency Yes X No  N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance Fails Criteria Category: _________ Comments: 

C. Proposed Annotation (if any): Attapulgite--allowed as a processing aid in the handling of plant and animal oils. 

 Basis for annotation: Unrestricted use would include industrial applications not appropriate to food processing. 

D. Recommended Committee Action & Vote, including classification recommendation (State Actual Motion): 

To consider non-chemically processed attapulgite a non-synthetic substance. 

Classification of the material: Synthetic ________ Non- synthetic __X__ Absent:_________ Abstain _________ 

Motion by: John Foster Seconded: Joe Dickson Yes: 6 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Recommended Committee Action & Vote : Add attapulgite to the National List, 7 CFR § 205.605(a) with annotation as noted: 

Attapulgite--allowed as a processing aid in the handling of plant and animal oils. 

 

Motion by: John Foster Seconded: Joe Dickson Yes: 5 No: 1 Absent: 1 Abstain: 0 Recuse: 0 

 

1) Substance voted to be added as “allowed” on National List to § 205.605(a) with Annotation: Allowed as a processing aid in the handling 

of plant and animal oils. 

2) Substance to be added as “prohibited” on National List to § 205. with Annotation (if any) _______________________ 

____________________________________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. _____ Describe why material was rejected:___________ 

4) Substance was recommended to be deferred because _________________________________________________________ 

If follow-up needed, who will follow up _____________________________________________________________________ 

Crops Agricultural Allowed1

 x

Livestock Non-Synthetic x Prohibited2 

Handling x Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

Steve DeMuri 

Committee Chair Date: April 29, 2011
Decision Sheets 

April 2010 

EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST 

Category 1. Adverse impacts on humans or the environment? Substance: Attapulgite 

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Are there adverse effects on environment 

from manufacture, use, or disposal? 

[§205.600 b.2] 

 x Those effects on environment typically encountered with open 

pit mining activities, and environmental protection practices are 

in place to remediate or mitigate earth moving and removal. (Pet 

page 5, TR line 142+, 232+) Mining of attapulgite does not 

include any chemical adjuvants or catalysts (Pet page 5, TR line 

142+, 232+) 

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3] 

 x See above. 

3. Is the substance harmful to the 

environment and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 x Temporary dust hazard during mining. (TR line 232+) 

4. Does the substance contain List 1, 2, or 3 

inerts? [§6517 c (1 ) (B)(ii); 

205.601(m)2] 

 x Attapulgite is not a formulated product and has nothing added to 

it when used as a food processing aid. 

5. Is there potential for detrimental chemical 

interaction with other materials used? 

[§6518 m.1] 

 x Neither petition nor TR note any. 

6. Are there adverse biological and chemical 

interactions in agro-ecosystem? [§6518 

m.5] 

 x Neither petition nor TR note any. 

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5] 

 x Petitioned as a handling material. 

8. Is there a toxic or other adverse action of 

the material or its breakdown products? 

[§6518 m.2] 

 x Neither petition nor TR note any. 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment? 

[§6518 m.2] 

 x Neither petition nor TR note any. 

10. Is there any harmful effect on human 

health? [§6517 c (1)(A) (i) ; 6517 

c(2)(A)I; §6518 m.4] 

 x If handled without the mandated personal protection equipment 

(PPE) then inhalation hazards are noted (TR line 276+) 

11. Is there an adverse effect on human health 

as defined by applicable Federal 

regulations? [205.600 b.3] 

 x See above. 

12. Is the substance GRAS when used 

according to FDA’s good manufacturing 

practices? [§205.600 b.5] 

 Included in FDA’s EAFUS, and considered GRAS under EPA 

(TR line 340+) 

13. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 b.5] 

 x No information found via TR for attapulgite, but for Fuller’s 

Earth from China, some trace heavy metals have been found. 

(TR line 349+) 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

April 2010 

Category 2. Is the Substance Essential for Organic Production? Substance: Attapulgite 

 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; 

other) 

1. Is the substance formulated or manufactured 

by a chemical process? [6502 (21)] 

 x Formed through geologic processes, 

mined, then physically pulverized, 

screened, and packaged. (Pet page 5, TR 

line 142+, 232+) 

2. Is the substance formulated or manufactured 

by a process that chemically changes a 

substance extracted from naturally occurring 

plant, animal, or mineral, sources? [6502 

(21)] 

 x See above. 

3. Is the substance created by naturally 

occurring biological processes? [6502 (21)] 

 x Formed through geologic processes, 

mined, then physically pulverized, 

screened, and packaged. (Pet page 5, TR 

line 142+, 232+) 

4. Is there a natural source of the substance? 

[§205.600 b.1] 

 x This is the natural form of the substance 

5. Is there an organic substitute? [§205.600 b.1] x TR line 214+ 

6. Is the substance essential for handling of 

organically produced agricultural products? 

[§205.600 b.6] 

x In order to bring the oils to marketable 

condition, some clarifying processing 

aid is needed. 

7. Is there a wholly natural substitute product? 

[§6517 c (1)(A)(ii)] 

 x This is a wholly natural product. 

8. Is the substance used in handling, not 

synthetic, but not organically produced? 

[§6517 c (1)(B)(iii)] 

x Formed through geologic processes, 

mined, then physically pulverized, 

screened, and packaged. (Pet page 5, TR 

line 142+, 232+) 

9. Is there any alternative substances? [§6518 

m.6] 

 x TR line 214+ 

10. Is there another practice that would make the 

substance unnecessary? [§6518 m.6] 

 x 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b)are N/A—not applicable. 

 
Decision Sheets 

April 2010 

Category 3. Is the substance compatible with organic production practices? Substance: Attapulgite 

 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; 

other) 

1. Is the substance compatible with 

organic handling? [§205.600 b.2] 

 x This is a natural substance used to bring 

oils to a marketable condition through 

removal of impurities such as undesirable 

odors, colors, trace metals, etc. 

2. Is the substance consistent with organic 

farming and handling, and biodiversity? 

[§6517 c (1)(A)(iii); 6517 c (2)(A)(ii)] 

 x See above. 

3. Is the substance compatible with a system of 

sustainable agriculture? [§6518 m.7] 

 x 

4. Is the nutritional quality of the food 

maintained with the substance? [§205.600 

b.3] 

 x TR line 312+ 

5. Is the primary use as a preservative? 

[§205.600 b.4] 

 x TR line 319+ 

6. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive values 

lost in processing (except when required by 

law, e.g., vitamin D in milk)? [205.600 b.4] 

 x TR 330+ 

7. Is the substance used in production, and does 

it contain an active synthetic ingredient in 

the following categories: 

 x 

a. Copper and sulfur compounds; x 

b. Toxins derived from bacteria; x 

c. Pheromones, soaps, horticultural oils, fish 

emulsions, treated seed, vitamins and 

minerals? 

 x 

d. Livestock parasiticides and medicines? x 

e. Production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleaners? 

 x 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

April 2010 

Category 4. Is the commercial supply of an agricultural substance as 

organic, fragile or potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 

(d), 205.600 (c) 205.2, 205.105 (d), 205.600 (c)] 

 

Substance: Attapulgite

Question Yes No N/A Comments on Information Provided 

(sufficient, plausible, reasonable, 

thorough, complete, unknown) 

1. Is the comparative description provided as 

to why the non-organic form of the 

material /substance is necessary for use in 

organic handling? 

 x 

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate form to fulfill an 

essential function in a system of organic 

handling? 

 x 

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quality to fulfill an 

essential function in a system of organic 

handling? 

 x 

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quantity to fulfill an 

essential function in a system of organic 

handling? 

 x 

5. Does the industry information provided on 

material / substance non-availability as 

organic, include ( but not limited to) the 

following: 

 x 

a. Regions of production (including factors 

such as climate and number of regions); 

 x 

b. Number of suppliers and amount 

produced; 

 

c. Current and historical supplies related to 

weather events such as hurricanes, 

floods, and droughts that may 

temporarily halt production or destroy 

crops or supplies; 

 x 

d. Trade-related issues such as evidence of 

hoarding, war, trade barriers, or civil 

unrest that may temporarily restrict 

supplies; or 

 x 

e. Are there other issues which may present 

a challenge to a consistent supply? 

 x