National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

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Sunset 2017 

NOSB Final Review

Crops Substances

October 2015

As part of the National List Sunset Review process, the NOSB has evaluated the need for the continued 

allowance for or prohibition of the following substances for use in organic crop production.

Reference: 7 CFR §205.601 Synthetic substances allowed for use in organic crop production.

Alcohol: Ethanol

Alcohol: Isopropanol

Chlorine Materials: Calcium hypochlorite, 

Chlorine dioxide, Sodium hypochlorite

Hydrogen peroxide

Soap-based algicide/demossers

Herbicides, soap-based

Newspaper or other recycled paper

Plastic mulch and covers

Soaps, ammonium

Ammonium carbonate

Boric acid

Elemental sulfur

Lime sulfur

Oils, horticultural

Soaps, insecticidal

Sticky traps/barriers

Sucrose octanoate esters

Pheromones

Vitamin D3

Coppers, fixed

Copper sulfate

Hydrated lime

Potassium bicarbonate

Aquatic plant extracts

Humic acids

Lignin sulfonate(j)4

Lignin sulfonate(l)1

Magnesium sulfate

Micronutrients: Soluble boron products, 

Sulfates, carbonates, oxides, or silicates of zinc, 

copper, iron, manganese, molybdenum, 

selenium, and cobalt

Liquid fish products

Vitamin B1, C, E

Ethylene

Sodium silicate

EPA List 4 - Inerts of Minimal Concern

Microcrystalline cheesewax

205.602 Prohibited nonsynthetic substances

Ash from manure burning

Arsenic

Lead salts

Potassium chloride

Sodium fluoaluminate

Strychnine

Tobacco dust (nicotine sulfate)

Links to additional references and supporting materials for each substance can be found on the 

NOP website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned
Alcohols - ethanol 

Reference: 205.601(a)(1)

 (i) Ethanol. As algicide, disinfectants, and sanitizer, including irrigation system cleaning systems.

Technical Report(s): 1995 TAP; 01/2014 TR - Ethanol

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/2017 

Subcommittee Review

NOSB Review:

There was strong public support for continued use of ethanol as an algicide, disinfectant, and sanitizer, 

including irrigation cleaning systems. Based on the Subcommittee review and public comment, the 

NOSB finds Alcohols - ethanol compliant with OFPA criteria, and does not recommend removal from the 

National List. 

Vote

Motion to remove ethanol from §205.601(a)(1)

Motion by: Francis Thicke

Seconded by: Harold Austin

Yes: 0 No: 13 Abstain: 0 Absent: 1 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Alcohols - isopropanol

Reference: 205.601(a)(1)

 (ii) Isopropanol. As algicide, disinfectants, and sanitizer, including irrigation system cleaning systems.

Technical Report(s): 1995 TAP; 02/2014 TR - Isopropanol

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/2017 

Subcommittee Review
NOSB Review:

There was wide public support for continued listing of isopropanol as algicide, disinfectants, and 

sanitizer, including irrigation system cleaning systems. Based on the Subcommittee review and public 

comment, the NOSB finds Alcohols – isopropanol compliant with OFPA criteria, and does not 

recommend removal from the National List.

Vote 

Motion to remove isopropanol from §205.601(a)(1)

Motion by: Francis Thicke

Seconded by: Harold Austin 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Chlorine materials - Calcium Hypochlorite

Reference: 205.601(a) - As algicide, disinfectants, and sanitizer, including irrigation system cleaning 

systems. (2) Chlorine materials -For pre-harvest use, residual chlorine levels in the water in direct crop 

contact or as water from cleaning irrigation systems applied to soil must not exceed the maximum 

residual disinfectant limit under the Safe Drinking Water Act, except that chlorine products may be used 

in edible sprout production according to EPA label directions.

 (i) Calcium hypochlorite

Technical Report(s): 1995 TAP; 2006 TR; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/27/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was significant public support for continued allowance of the use of chlorine materials in crop 

production, as well as in livestock production and handling. However, there was also concern expressed 

in public comments that chlorine materials are highly caustic, a concern for occupational exposure, and 

detrimental to the environment, and that organic production should be as chlorine-free as possible. It 

was suggested that in the future the NOSB should do an in-depth analysis of how widely chlorine 

sanitizing materials are used, where chlorine use is required by law, and where more benign sanitizers 
could be substituted. Based on the Subcommittee review and public comment, the NOSB finds calcium 

hypochlorite compliant with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Calcium hypochlorite from §205.601(a)

Motion by: Francis Thicke

Seconded by: Colehour Bondera

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Chlorine materials - Chlorine Dioxide

Reference: 205.601(a) - As algicide, disinfectants, and sanitizer, including irrigation system cleaning 

systems. (2) Chlorine materials - For pre-harvest use, residual chlorine levels in the water in direct crop 

contact or as water from cleaning irrigation systems applied to soil must not exceed the maximum 

residual disinfectant limit under the Safe Drinking Water Act, except that chlorine products may be used 

in edible sprout production according to EPA label directions.

 (ii) Chlorine dioxide

Technical Report(s): 1995 TAP; 2006 TR; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/27/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was a lot of public support for continued allowance of the use of chlorine materials in crop 

production, as well as in livestock production and handling. However, there was also concern expressed 

in public comments that chlorine materials are highly caustic, a concern for occupational exposure, and 

detrimental to the environment, and that organic production should be as chlorine-free as possible. It 

was suggested that in the future the NOSB should do an in-depth analysis of how widely chlorine 

sanitizing materials are used, where chlorine use is required by law, and where more benign sanitizers 

could be substituted.

Based on the Subcommittee review and public comment, the NOSB finds chlorine dioxide compliant 

with OFPA criteria, and does not recommend removal from the National List.
Vote 

Motion to remove Chlorine dioxide from §205.601(a) 

Motion by: Francis Thicke

Seconded by: Carmela Beck

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Chlorine materials - Sodium Hypochlorite

Reference: 205.601(a) - As algicide, disinfectants, and sanitizer, including irrigation system cleaning 

systems. (2) Chlorine materials -For pre-harvest use, residual chlorine levels in the water in direct crop 

contact or as water from cleaning irrigation systems applied to soil must not exceed the maximum 

residual disinfectant limit under the Safe Drinking Water Act, except that chlorine products may be used 

in edible sprout production according to EPA label directions.

 (iii) Sodium hypochlorite

Technical Report(s): 1995 TAP; 2006 TR; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/27/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was a lot of public support for continued allowance of the use of chlorine materials in crop 

production, as well as in livestock production and handling. However, there was also concern expressed 

in public comments that chlorine materials are highly caustic, a concern for occupational exposure, and 

detrimental to the environment, and that organic production should be as chlorine-free as possible. It 

was suggested that in the future the NOSB should do an in-depth analysis of how widely chlorine 

sanitizing materials are used, where chlorine use is required by law, and where more benign sanitizers 

could be substituted.

Based on the Subcommittee review and public comment, the NOSB finds sodium hypochlorite

compliant with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Sodium hypochlorite §205.601(a) 

Motion by: Francis Thicke
Seconded by: Colehour Bondera

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Hydrogen peroxide

Reference: 205.601(a)(4) - As algicide, disinfectants, and sanitizer, including irrigation system cleaning 

systems. 

Reference 205.601(i)(5) - As plant disease control.

Technical Report(s): 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation -

deferred; 06/2006 sunset recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The NOSB found the material to meet OFPA criteria and has no objection to continued listing. No 

significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds hydrogen peroxide compliant with OFPA criteria, and does not recommend 

removal from the National List.

Vote 

Motion to remove hydrogen peroxide from §205.601(a) and §205.601(i)

Motion by: Zea Sonnabend

Seconded by: Carmela Beck/Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Soap-based algicide/demossers

Reference: 205.601(a)(7) - As algicide, disinfectants, and sanitizer, including irrigation system cleaning 

systems.

Technical Report(s): 1996 TAP; 2015 TR
Petition(s): N/A

Past NOSB Actions: Actions: 09/1996 NOSB recommendation; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee voted to delist soap-based algicide/demossers because it was thought that 

they were no longer used in organic crop production, and therefore it was not necessary to keep soapbased algicide/demossers on the National List. However, some public comments indicated that these 

materials were still being used by some producers. 

Based on the public comment, the NOSB finds soap-based algicide/demossers compliant with OFPA 

criteria, and does not recommend removal from the National List. 

Vote 

Motion to remove Soap-based algicide/demossers from §205.601(a)(7)

Motion by: Francis Thicke

Seconded by: Carmela Beck

Yes: 8 No: 5 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Herbicides, soap-based/ (Soaps, herbicidal)

Reference: 205.601(b) As herbicides, weed barriers, as applicable (1) herbicides soap-based—for use in 

farmstead maintenance (roadways, ditches, right of ways, building perimeters) and ornamental crops.

Technical Report: 1996 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: Actions: 1996 recommendation; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:
Public comments favored keeping soap-based herbicides on the National List. Comments indicated that 

though soap-based herbicides are sometimes only marginally effective, they are a safe alternative, and 

some farmers rely on them for weed control on farmstead, roadways, and other places they are 

approved for use. 

Based on the Subcommittee review and public comment, the NOSB finds soap-based herbicides

compliant with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Herbicides, soap-based from §205.601(b)

Motion by: Francis Thicke

Seconded by: Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Newspaper or other recycled paper

Reference: 205.601(b) As herbicides, weed barriers, as applicable. (2) Mulches. (i) newspapers or other 

recycled paper, without glossy or colored inks. 

Reference: 205.601(c) - As compost feedstocks - Newspapers or other recycled paper, without glossy or 

 colored inks. 

Technical Report: 1995 TAP; 2006 TAP 

Petition(s): N/A 

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

Several questions were raised during the NOSB review from members and the public that indicated that 

a Technical Report (TR) would be worthwhile for review of this material. While no substantiated issues 

of concern were raised regarding the OFPA criteria, not enough is known about the ingredients in 

newspaper and their fate in the environment. The full board voted to renew this listing, but will be 

discussing requesting a TR. The NOSB finds newspaper or other recycled paper compliant with OFPA 

criteria, and does not recommend removal from the National List.
Vote 

Motion to remove newspaper or other recycled paper from §205.601(b) and §205.601(c)

Motion by: Harold Austin

Seconded by: Carmela Beck

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Plastic mulch and covers

Reference: 205.601(b) As herbicides, weed barriers, as applicable. (2) Mulches. (ii) Plastic mulch and 

covers (petroleum-based other than polyvinyl chloride (PVC)). 

Technical Report: 1995 TAP 

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

No significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds plastic mulch and covers compliant with OFPA criteria, and does not 

recommend removal from the National List.

Vote 

Motion to remove plastic mulch and covers from §205.601(j)

Motion by: Harold Austin

Seconded by: Francis Thicke

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Soaps, ammonium

Reference: 205.601(d) As animal repellents—Soaps, ammonium—for use as a large animal repellant 

only, no contact with soil or edible portion of crop. 

Technical Report: 1999 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There were few public comments on ammonium soaps, but they favored allowing continued use of 

ammonium soaps as a large animal repellent, though comments also questioned the efficacy of this 

material as a repellent. The NOSB finds ammonium soaps compliant with OFPA criteria, and does not 

recommend removal from the National List.

Vote 

Motion to remove Soaps, ammonium from §205.601(d)

Motion by: Zea Sonnabend

Seconded by: Carmela Beck 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ammonium carbonate

Reference: 205.601(e) As insecticides (including acaricides or mite control). (1) ammonium carbonate —

for use as bait in insect traps only, no direct contact with crop or soil. 

Technical Report: 1995 TAP

Petition(s): N/A 

Past NOSB Actions: 10/1995 NOSB minutes and vote ; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/2017 

Subcommittee Review
NOSB Review:

No significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds ammonium carbonate compliant with OFPA criteria, and does not 

recommend removal from the National List.

Vote 

Motion to remove Ammonium carbonate from §205.601(i) 

Motion by: Harold Austin

Seconded by: Carmela Beck

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Boric acid

Reference: 205.601(e) As insecticides (including acaricides or mite control). (3)Boric acid - structural 

pest control, no direct contact with organic food or crops.

Technical Report: 1995 TAP 

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17

Subcommittee Review

NOSB Review:

No significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds boric acid compliant with OFPA criteria, and does not recommend removal 

from the National List.

Vote 

Motion to remove Boric Acid from §205.601(e)

Motion by: Colehour Bondera

Seconded by: Carmela Beck

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Elemental sulfur

Reference: 205.601(e)(5) - As insecticides (including acaricides or mite control).

Reference: 205.601(i)(10) - As plant disease control.

Reference: 205.601(j)(2) - As plant or soil amendments.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 

04/2010 sunset recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The full NOSB after its review and hearing public comments (written and oral) received from both the 

spring and fall meetings, as well as oral comments provided both in person at each meeting, plus during 

the two webinars for oral comments, has completed this Sunset Review cycle. There was over-whelming 

support for the continued listing of this material. Organic stakeholders provided a clear message to the 

full NOSB that this material still remains a necessary tool in organic crop production. There was no new 

information provided or concerns raised that would show cause for this material not to continue to be 

allowed on the National List for use in organic crop production.

Based on the Subcommittee review and public comment, the NOSB finds elemental sulfur compliant 

with OFPA criteria, and does not recommend removal from the National List.

Vote

Motion to remove Elemental Sulfur from the National List at §205.601 (e)(5), §205.601 (i)(10), and 

§205.601 (j)(2).

Motion by: Harold V. Austin IV

Seconded by: Carmela Beck 

Yes: 1 No: 13 Abstain: 0 Recuse: 0 Absent : 0

Outcome: Motion failed. NOSB completed its sunset review.

Lime sulfur

Reference: 205.601(e)(6) - As insecticides (including acaricides or mite control).

Reference: 205.601(i)(6) - As plant disease control.

Technical Report: 1995 TAP; 2014 TR
Petition(s): N/A

Past NOSB Actions: Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 

10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was a Limited Scope Technical Review provided to the Subcommittee that provided specific 

details on possible alternative materials and alternative practices. Public comments provided details as 

to why Lime sulfur still remains a necessary material in organic crop production and that while there 

may be alternative materials available, they do not always provide the same level of control under 

varying conditions. One critical factor that was pointed out is that the use of lime sulfur has actually 

increased with the loss of the two antibiotics previously allowed to control fire blight, as a partial 

replacement material. There was over-whelming support for the continued listing of this material. While 

a concern was raised over possible impact on non-target organisms or insects, discussions suggested 

that these concerns would be mitigated if proper label use instructions were followed. 

Based on discussion, review, and extensive public comments the NOSB feels that there were no 

concerns raised that would show cause for this material not to continue to be allowed on the National 

List for use in organic crop production. The NOSB finds lime sulfur compliant with OFPA criteria, and 

does not recommend removal from the National List.

Vote 

Motion to Remove lime sulfur from §205.601 (e)(6) as insecticides (including acaricides or mite control) 

and §205.601 (j)(6) 

Motion by: Harold V. Austin IV

Seconded by: Carmela Beck

Yes: 1 No: 13 Abstain: 0 Recuse: 0 Absent: 0

Outcome: Motion failed. NOSB completed its sunset review.

Oils, horticultural

Reference: 205.601(e)(7) - As insecticides (including acaricides or mite control). —narrow range oils as 

dormant, suffocating, and summer oils.

Reference: 205.601(i)(7) As plant disease control. - narrow range oils as dormant, suffocating, and 

summer oils.

Technical Report: 1995 TAP
Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 NOSB 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was over-whelming support for the continued listing of this material. Organic stakeholders 

provided a clear message to the full NOSB that this material remains a necessary tool in organic crop 

production and in fact has increased in use due to the recent growth of organic production. Public 

comments help to explain how these materials are used and why. It was also pointed out during public 

comment that these oils are allowed for use world-wide by most organic certifying bodies for use in 

organic crop production. 

Based on the Subcommittee review and public comment, the NOSB finds horticultural oils compliant 

with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Horticultural Oil from §205.601(e) and §205.601(i)

Motion by: Harold V. Austin IV

Seconded by: Francis Thicke

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Soaps, insecticidal

Reference: 205.601(e)(8) - As insecticides (including acaricides or mite control). 

Technical Report: 1994 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review
NOSB Review:

Public comments indicated that some organic producers use insecticidal soaps regularly, and some 

rated insecticidal soaps as critical to the success of their operation. Insecticidal soaps are considered to 

be a relatively nontoxic insecticide alternative. Based on the Subcommittee review and public comment, 

the NOSB finds insecticidal soaps compliant with OFPA criteria, and does not recommend removal from 

the National List.

Vote 

Motion to remove Insecticidal soaps from §205.601(e)(8)

Motion by: Francis Thicke

Seconded by: Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sticky traps/barriers

Reference: §205.601(e) As insecticides (including acaricides or mite control). 

 (9) Sticky traps/barriers.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)Sunset Date: 

6/27/17

Subcommittee Review

NOSB Review:

No significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds sticky traps/barriers compliant with OFPA criteria, and does not recommend 

removal from the National List.

Vote 

Motion to remove sticky traps from §205.601(e)

Motion by: Francis Thicke

Seconded by: Carmela Beck
Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sucrose octanoate esters

Reference: 7 CFR 205.601(e), 205.603(b)

Technical Report: Livestock 2005 Technical Report; Crops 2005 Technical Report

Petition(s): 2004 Sucrose Octanoate Esters; Amendment #1; Amendment #2

Past NOSB Actions: 08/2005 NOSB recommendation for addition to NL; 10/2010 NOSB sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

Minimal public input was received on this material, but the comments received favored its continued 

listing for control of soft-bodied insects. This material is registered with the EPA as a biopesticide with 

no persistence in the environment and no known risks to the environment. 

Based on the Subcommittee review and public comment, the NOSB finds sucrose octanoate esters

compliant with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Sucrose octanoate esters from §205.601(e)

Motion by: Paula Daniels

Seconded by: Harold Austin

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Pheromones

Reference: 205.601(f) - as insect management. 

Technical Report: 1995 TAP; 2012 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 
Subcommittee Review

NOSB Review:

After reviewing both historic and current information, review of written public comments, and listening 

to oral testimony given both in person at the spring and fall meetings, as well as during the two oral 

comment webinars, the NOSB has completed its review of this material for this current Sunset Review 

cycle. There was over-whelming support from organic stakeholders for the continued listing of this 

material. While there have been some concerns raised over the inerts used in the passive pheromone 

dispensers, that is a separate issue covered in the inerts listing of the National List and does not pertain 

specifically to this material discussion. 

Organic crop producers provided clear messaging that pheromones help to provide the foundation for a 

safe and effective control of numerous pests that pose a risk in a variety of crops produced. 

There was no new information provided or concerns raised that would show cause for this material not 

to continue to be allowed on the National List for use in organic crop production.

Based on the Subcommittee review and public comment, the NOSB finds this material compliant with 

OFPA criteria, and does not recommend removal from the National List.

Vote in Crops Subcommittee

Motion to remove Pheromones from §205.601(f)

Motion by: Harold V. Austin IV

Seconded by: Carmela Beck 

Yes: 1 No: 13 Abstain: 0 Absent: Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vitamin D3

Reference: 205.601(g) - as rodenticides.

Technical Report: 1995 TAP; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review
NOSB Review:

No significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds Vitamin D3 compliant with OFPA criteria, and does not recommend removal 

from the National List.

Vote 

Motion to remove vitamin D from §205.601(g)

Motion by: Paula Daniels

Seconded by: Harold Austin 

Yes: 3 No: 11 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Coppers, fixed

Reference: 205.601(i) As plant disease control. (2) Coppers, fixed —copper hydroxide, copper oxide, 

copper oxychloride, includes products exempted from EPA tolerance, Provided, That, copper-based 

materials must be used in a manner that minimizes accumulation in the soil and shall not be used as 

herbicides.

Technical Report: 1995 TAP; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB meeting minutes and vote; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for copper hydroxide, copper oxide, and copper oxychloride. 

The NOSB review of this material acknowledges that copper is both harmful in the environment when 

misused and absolutely necessary to grow many crops to protect against disease. The public made many 

suggestions for further annotations that would be more specific about avoiding hazards of copper. 

However the board did not feel that any of them were workable as annotation language at this time, or 

would be best covered under applicator safety regulations or instructions to certifiers. The NOSB urged 

the NOP to provide clear guidance to ACAs on enforcement of the existing annotation. Additionally, 

study of the uses of copper and their alternatives has been added to the NOSB Research Priorities for 

2015 so that additional research can be underway by the time of the next sunset review. 

Based on the Subcommittee review and public comment, the NOSB finds these materials compliant with 

OFPA criteria, and does not recommend removal from the National List.
Vote 

Motion to remove Coppers, fixed from §205.601(i)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 2 No: 12 Abstain: 0 Absent: Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Copper sulfate

Reference: 205.601(i) As plant disease control. (3) Copper sulfate —Substance must be used in a 

manner that minimizes accumulation of copper in the soil.

Technical Report: 1995 TAP; 2011 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB meeting minutes and vote; 11/2005 NOSB sunset recommendation; 

04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review 

See Coppers, fixed.

Subcommittee Review

NOSB Review:

See Coppers, fixed

Vote 

Motion to remove Copper Sulfate from §205.601(i): 

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Hydrated lime

Reference: 205.601(i)(4) - As plant disease control.

Technical Report: 1995 TAP; 2001 TAP; 2002 TR for Calcium Hydroxide

Petition(s): N/A
Past NOSB Actions: 04/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 NOSB 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for hydrated lime. No significant new issues were raised by the 

public. Based on the Subcommittee review and public comment, the NOSB finds this material compliant 

with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Hydrated Lime from §205.601(i)(4)

Motion by: Zea Sonnabend

Seconded by: Francis Thicke

Yes: 0 No: 13 Abstain: 0 Absent: 1 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Potassium bicarbonate

Reference: 205.601(i)(9) - As plant disease control.

Technical Report:1999 TAP; 2015 TR 

Petition(s): N/A

Past NOSB Actions: 10/1999 NOSB meeting minutes and vote; 11/2005 NOSB sunset recommendation; 

10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

NOSB Review: 

There was a limited scope Technical Review (TR) provided to the subcommittee during this current 

review process. While the new TR provided possible alternative materials or practices that might 

replace this material further clarification was sought from the actual organic stakeholders that relied 

upon this material to help explain under what conditions or scenarios these might apply. Organic 

producers responded that while there are alternative materials and/or practices, that potassium 

bicarbonate was still very necessary to their crop production practices. They provided comments stating 

that it was still important as part of their powdery mildew resistance management process. Also, 

because of its unique mode of action it helped to control not only powdery mildew but other diseases 

under certain conditions or scenarios better than the alternative materials or practices.
There was overwhelming support for the continued listing of this material. There was one concern 

raised that this material actually did not fit into any of the categories listed under §6517(c)(1)(B)(i) of 

OFPA. That concern was answered during the fall meeting and is duly recorded into the minutes of said 

meeting. Thus, there was no new information provided or concerns raised that would show cause for 

this material not to continue to be allowed on the National List for use in organic crop production.

Based on the Subcommittee review and extensive public comment (both written and oral public 

comments provided at the spring and fall meetings, as well as during two webinars for oral testimony, 

and open discussion during the meeting), the NOSB finds potassium bicarbonate compliant with OFPA 

criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Potassium Bicarbonate from §205.601(i)(9)

Motion by: Harold V. Austin IV

Seconded by: Carmela Beck

Yes: 1 No: 12 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Aquatic plant extracts

Reference: 205.601 (j) As plant or soil amendments. (1) Aquatic plant extracts (other than hydrolyzed) –

Extraction process is limited to the use of potassium hydroxide or sodium hydroxide; solvent amount is 

limited to that amount necessary for extraction.

Technical Report: 2006 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 NOSB 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was public comment support in favor of relisting Aquatic Plant Extracts. It is in active use by the 

trade and continues to be considered necessary to the production of fruit and vegetables. In our 

proposal, the Subcommittee identified concern about potential seaweed overharvesting. Extensive 

written public comment was received on this issue but was very regional in nature. The Board will 

prioritize review of this topic to determine if a Technical Report (TR) should be requested across 

subcommittees on all the marine plants to help inform potential future Board action on this topic. Based 

on the Subcommittee review and public comment, the NOSB finds aquatic plant extracts compliant with 
OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Aquatic plant extracts from §205.601(j) 

Motion by: Carmela Beck

Seconded by: Harold Austin 

Yes: 5 No: 6 Abstain: 3 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Humic acids

Reference: 205.601(j) As plant or soil amendments. 3) Humic acids - naturally occurring deposits, water 

and alkali extracts only.

Technical Report: 1996 TAP; 2006 TR

Petition(s): N/A

Past NOSB Actions: 09/1996 meeting minutes and vote; 04/2006 sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was substantial public comment support in favor of relisting humic acids. Humic acids are in active 

use by the trade and continue to be considered necessary to the production of fruit and vegetables. No 

significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds humic acids compliant with OFPA criteria, and does not recommend removal 

from the National List.

Vote 

Motion to remove Humic Acids from §205.601(j)3

Motion by: Carmela Beck

Seconded by: Harold Austin 

Yes: 4 No: 10 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Lignin sulfonate

Reference: 205.601(j) As plant or soil amendments. (4) Lignin sulfonate —chelating agent, dust 

suppressant.

Technical Report: 2011 TR; 1995 TAP

Petition(s): N/A, 2014 Petition to remove as floating agent

Past NOSB Actions: 10/1995 NOSB Minutes and vote; 04/2006 Sunset Rec; 04/2011 NOSB Rec to 

amend, 04/2011 NOSB Sunset Rec

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17

Subcommittee Review

NOSB Review:

There was public comment support in favor of relisting Lignin Sulfonate as a chelating agent and dust 

suppressant. Lignin sulfonates are in active use by the trade and continue to be considered “necessary”, 

both for dust suppression and as the chelating agent for many micronutrient formulations. The NOSB 

found the material to meet OFPA criteria and has voted for continued listing. No significant new issues 

were raised by the public.

Vote 

Motion to remove lignin sulfonate from §205.601(j)(4) as chelating agent and dust suppressant.

Motion by: Carmela Beck

Seconded by: Harold Austin 

Yes: 7 No: 7 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Lignin sulfonate

Reference: 205.601(l)(1) - As floating agents in postharvest handling.

Technical Report: 2011 TR; 1995 TAP

Petition(s): N/A, 2014 Petition to remove as floating agent

Past NOSB Actions: 10/1995 NOSB Minutes and vote; 04/2006 Sunset Rec; 04/2011 NOSB Rec to 

amend, 04/2011 NOSB Sunset Rec

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for lignin sulfonate. There was 100% public support in favor of 

removing Lignin Sulfonate for use as a floating agent from the National List. Lignin sulfonate for use as a 
floating agent is no longer in use by the trade and is therefore no longer considered to be “necessary”.

Based on the Subcommittee review, the petition to remove, and public comment, the NOSB 

recommends removal of this material from the National List.

Vote 

Motion to remove Lignin Sulfonate from section §205.601(l)(1) of the National List for use as a floating

agent in postharvest handling, and to acknowledge support for the petition received on this removal.

Motion by: Zea Sonnabend

Seconded by: Colehour Bondera

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of lignin 

sulfonate

Magnesium Sulfate

Reference: 205.601 (j)(5) - As a plant or soil amendment. Magnesium sulfate—allowed with a 

documented soil deficiency.

Technical Report: 1995 TAP; 2011 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 04/2011 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was substantial public comment support in favor of relisting magnesium sulfate. It is in active use 

by the trade and continues to be considered necessary to the production of fruit and vegetables. No 

significant new issues were raised by the public. Based on the Subcommittee review and public 

comment, the NOSB finds magnesium sulfate compliant with OFPA criteria, and does not recommend 

removal from the National List.

Vote 

Motion to remove Magnesium Sulfate from §205.601(j) as a plant and soil amendment

Motion by: Carmela Beck

Seconded by: Harold Austin

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Micronutrients

Reference: 205.601 (j)(6) - As a plant or soil amendment. 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. (i) Soluble boron products. (ii) Sulfates, carbonates, oxides, or silicates of zinc, 

copper, iron, manganese, molybdenum, selenium, and cobalt. 

Technical Report: 2010 TR Micronutrients

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was substantial public comment support in favor of relisting micronutrients. Micronutrients are in 

active use by the trade and they continue to be considered necessary to the production of fruit and 

vegetables. The Board approved an annotation change to read “deficiency must be documented;” 

please refer to the Formal Micronutrient Annotation Change Recommendation for additional 

information. No significant new issues were raised by the public.

Based on the Subcommittee review and public comment, the NOSB finds micronutrients compliant with 

OFPA criteria, and does not recommend removal from the National List.

Vote

Motion to remove Micronutrients from §205.601(j) as plant and soil amendment

Motion by: Carmela Beck

Seconded by: Harold Austin

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Liquid fish products

Reference: 205.601 (j) As plant or soil amendments. (7) Liquid Fish Products – can be pH adjusted with 

sulfuric, citric or phosphoric acid. The amount of acid used shall not exceed the minimum needed to 

lower the pH to 3.5. 

Technical Report: 1995 TAP; 2006 TR
Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

There was substantial public comment support in favor of relisting Liquid Fish Products. Liquid Fish 

Products are in active use by the trade and continue to be considered necessary to the production of 

fruit and vegetables. Some concerns were raised by the public about potential overharvesting of fish to 

make these fertilizer products. This will be discussed by the subcommittee in the future to see if a 

change of annotation is to be pursued. However the majority of the NOSB voted to renew this listing.

Based on the Subcommittee review and public comment, the NOSB finds liquid fish products compliant 

with OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Liquid Fish products from §205.601(j) as a plant and soil amendment

Motion by: Carmela Beck

Seconded by: Harold Austin 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vitamin B1, C, E

Reference: 205.601 (j)(8) - As plant or soil amendment. Vitamins B1, C, and E

Technical Report(s): 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 minutes and vote, 11/2005 NOSB sunset recommendation; 10/2010 NOSB 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR33290)

Sunset Date: 6/27/17

Subcommittee Review

NOSB Review:
The NOSB completed the sunset review for Vitamins B1, C and E. There was some public comment 

support in favor of relisting these vitamins. Vitamins B1, C and E are in active use by the trade and 

continues to be considered “necessary” to the production of fruit and vegetables. No significant new 

issues were raised by the public.

Based on the Subcommittee review and public comment, the NOSB finds these materials compliant with 

OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Vitamin B1, Vitamin C, Vitamin E, from §205.601(j)(8)

Motion by: Carmela Beck

Seconded by: Harold Austin 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ethylene gas

Reference: 205.601(k) - As plant growth regulators. Ethylene gas - for regulation of pineapple flowering.

Technical Report: 02/2000 Supplemental TAP; 2007 TAP; 2011 Supplemental TR

Petition(s): N/A

Past NOSB Actions: 11/1995 NOSB recommendation; 10/2001 recommendation; 11/2005 NOSB sunset 

recommendation; 04/2011 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

This material was reviewed at both the Spring and Fall NOSB meetings. Public comments were provided 

for both meetings in writing and oral presentation. The fall meeting also provided an opportunity for 

oral public testimony via two webinars provided by the NOP.

The NOSB was concerned about the lack of comments from pineapple producers for the spring meeting, 

so they included another request to hear from stakeholders in the proposal for the fall meeting. There 

was an out-pouring of both written and oral testimony presented to the full NOSB by organic pineapple 

producers, from Costa Rica primarily. These comments along with historic information, previous Sunset 

Reviews and discussions, along with open discussions at the fall meeting helped to provide the full NOSB 

with significant information about this material, how it is used by all size operations of pineapple 

producers, and the significance it plays in their crop production. Previous discussions have made it 

appear that this is a material primarily used only by larger size operations, the grower comments helped 
to provide information showing that this material, in fact, is actually used by organic pineapple growers 

of all size operations.

Discussion and public testimony helped frame the importance of this material to organic pineapple 

production and the impact it would have on not just the growers, but also wholesalers, retailers, 

processors, and ultimately the organic consumers. The over-all messaging from the crop producers was 

that the fact is the level of organic pineapple production that currently exists would cease without this 

material being available for use in organic pineapple production.

There were no new issues of human health or environmental concerns that were raised that have not 

been appropriately and completely answered in the previous review cycles. Therefore, there is no 

rational as to why this material should not continue to be allowed on the National List for use in organic 

crop production.

Based on the Subcommittee review and public comment, the NOSB finds ethylene gas compliant with 

OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Ethylene from §205.601(k)

Motion by: Harold V. Austin IV

Seconded by: Colehour Bondera 

Yes: 3 No: 9 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sodium silicate

Reference: 205.601 (l) As floating agents in postharvest handling. (2) Sodium silicate—for tree fruit and 

fiber processing.

Technical Report: 1995 TAP; 2006 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Subcommittee proposed to delist Sodium Silicate as a floating agent in postharvest handling for tree 

fruit and fiber processing primarily because there was no public comment received in favor of this 
material during our Spring, 2015 meeting. Additionally it was noted that float less mechanized systems 

are an available alternative. 

However, at the Fall, 2015 meeting the Subcommittee did receive two comments discussing Sodium 

Silicate. One commenter supports relisting for use as a pear float – the commenter stated that removal

could prevent small businesses from converting to organic packing due to the high costs of equipment 

to do it without. Also an industry trade organization conducted direct outreach to suppliers of sodium 

silicate for pear floating agents. They state that it appears as though the material is still in use by some 

smaller conventional pear packing facilities in the Pacific Northwest. These facilities have switched to 

sodium silicate due to increased regulation on the use of Lignin Sulfonate. Removing sodium silicate at 

this time would eliminate the possibility of these smaller facilities, with older style packing lines, in 

engaging in the organic industry. 

Faced with this new information the Board needed to take into consideration the potential impacts on 

smaller packing facilities, should both Lignin Sulfonate & Sodium Silicate be removed from the National 

List for use as a pear floating agent. The motion to remove lignin sulfonate was approved and the Board 

determined that this material could still be in use by the trade and therefore continues to be considered 

“necessary”.

Based on the Subcommittee review and public comment, the NOSB finds sodium silicate compliant with 

OFPA criteria, and does not recommend removal from the National List.

Vote 

Motion to remove Sodium silicate from §205.601(j)

Motion by: Carmela Beck

Seconded by: Colehour Bondera 

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

EPA List 4 - Inerts of Minimal Concern

Reference: 205.601(m) 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. 

(1) EPA List 4 – Inerts of Minimal Concern.

Technical Report: 2015 Limited Scope TR: Nonylphenol ethoxylates (NPEs)

Petition(s): N/A

Past NOSB Actions: 02/1999 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 04/2010 

recommendation, 10/2010 NOSB sunset recommendation; 10/ 2012 NOSB recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/17 
Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for EPA List 4 – Inerts of Minimal Concern. This listing is out of 

date as discussed in the proposal from the subcommittee. An annotation change to remove the 

reference to EPA List 4 and replace it with the current regulation structure for inerts was considered and 

passed during the same meeting as this was reviewed. This listing needed to be renewed in the 

meantime in case the rulemaking for the annotation change takes longer than the sunset expiration 

date. Please see the Proposal for an annotation change for EPA List 4 inerts for more information.

Vote 

Motion to remove EPA List 4 inerts from §205.601(m) based on compatibility with organic principles 

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Microcrystalline cheesewax

Reference: 205.601(o) - As production aids. Microcrystalline cheesewax (CAS #'s 64742-42-3, 8009-03-

08, and 8002-74-2)-for use in log grown mushroom production. Must be made without either ethylenepropylene co-polymer or synthetic colors.

Technical Report: none

Petition(s): 2007 Petition; 2008 Petitioner response to questions

Past NOSB Actions: 2008 NOSB recommendation

Recent Regulatory Background: Federal Register rule amendment published 02/14/12 (77 FR 8089)

Sunset Date: 3/15/17

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for microcrystalline cheesewax. The NOSB found the material to 

meet OFPA criteria and has voted for continued listing. The public raised the issue that there was a 

better alternative available made of soy wax but it was acknowledged that this would still need to be 

petitioned, recommended by the NOSB, and included on the National List. Therefore this material will 

remain on the list for now.

Based on the Subcommittee review and public comment, the NOSB finds this material compliant with 

OFPA criteria, and does not recommend removal from the National List.
Vote 

Motion to remove Microcrystalline cheesewax from §205.601(o)

Motion by: Colehour Bondera

Seconded by: Francis Thicke

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review. M

Ash from manure burning

Reference: 205.602(a)

Technical Report: none

Petition(s): 2014

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee believes that ash from manure burning does not meet the OFPA criteria and 

saw no reason to remove it from its prohibited status on the National List. Both the Crops 

Subcommittee and the full NOSB voted to not remove ash from manure burning from §205.602, 

nonsynthetic substances prohibited for use in organic crop production.

Vote 

Motion to remove Ash from manure burning from §205.602(a)

Motion by: Francis Thicke

Seconded by: Zea Sonnabend

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Arsenic

Reference: 205.602(b)

Technical Report: none
Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee believes that arsenic does not meet the OFPA criteria and saw no reason to 

remove arsenic from its prohibited status on the National List. Both the Crops Subcommittee and the 

full NOSB voted to not remove arsenic from §205.602, nonsynthetic substances prohibited for use in 

organic crop production.

Vote 

Motion to remove Arsenic from §205.602(b)

Motion by: Francis Thicke

Seconded by: Zea Sonnabend

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Lead salts

Reference: 205.602(d)

Technical Report: none

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee believes that lead salts do not meet the OFPA criteria and saw no reason to 

remove it from its prohibited status on the National List. Both the Crops Subcommittee and the full 

NOSB voted to not remove lead salts from §205.602, nonsynthetic substances prohibited for use in 

organic crop production.
Vote 

Motion to remove lead salts from §205.602(d)

Motion by: Francis Thicke

Seconded by: Zea Sonnabend

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Potassium chloride

Reference: 205.602(e) - unless derived from a mined source and applied in a manner that minimizes 

chloride accumulation in the soil. 

Technical Report: 1995

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee found no reason to remove it from its prohibited status on the National List. 

Both the Crops Subcommittee and the full NOSB voted to not remove potassium chloride from 

§205.602, nonsynthetic substances prohibited for use in organic crop production.

Vote 

Motion to remove potassium chloride from §205.602(e)

Motion by: Zea Sonnabend

Seconded by: Francis Thicke

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.
Sodium fluoaluminate (mined)

Reference: 205.602(f)

Technical Report: none

Petition(s): N/A

Past NOSB Actions: 1996 NOSB meeting minutes and vote; 11/2005 sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee believes that sodium fluoaluminate does not meet the OFPA criteria and saw 

no reason to remove it from its prohibited status on the National List. Both the Crops Subcommittee and 

the full NOSB voted to not remove sodium fluoaluminate from §205.602, nonsynthetic substances 

prohibited for use in organic crop production.

Vote 

Motion to remove sodium fluoaluminate from §205.602(f)

Motion by: Zea Sonnabend

Seconded by: Francis Thicke

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Strychnine

Reference: 205.602(h)

Technical Report: none

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17 

Subcommittee Review

NOSB Review:

The Crops Subcommittee believes that strychnine does not meet the OFPA criteria and saw no reason to 

remove it from its prohibited status on the National List. Both the Crops Subcommittee and the full 
NOSB voted to not remove strychnine from §205.602, nonsynthetic substances prohibited for use in 

organic crop production.

Vote 

Motion to remove strychnine from §205.602(h)

Motion by: Zea Sonnabend

Seconded by: Francis Thicke

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Tobacco dust (nicotine sulfate)

Reference: 205.602(i)

Technical Report: none

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 NOSB sunset recommendation; 10/2010 

NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/17

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for tobacco dust. The Crops Subcommittee believes that this 

material does not meet the OFPA criteria and saw no reason to remove it from its prohibited status on 

the National List. Both the Crops Subcommittee and the full NOSB voted to not remove tobacco dust

from §205.602, nonsynthetic substances prohibited for use in organic crop production.

Vote 

Motion to remove tobacco dust (nicotine sulfate) from §205.602(i)

Motion by: Francis Thicke

Seconded by: Zea Sonnabend

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.