Formal Recommendation

From: National Organic Standards Board (NOSB)

To: National Organic Program (NOP)

Date: November 18, 2016

Subject: Petitioned Material Proposal Potassium Cellulose Glycolate

NOSB Chair: Tracy Favre

The NOSB hereby recommends to the NOP the following:

Rule Making Action: 

Guidance Statement: 

Other: X

Statement of the Recommendation:

The Board determined that water usage is not a criterion under OFPA, and there was insufficient 

information justifying the need for this material in an organic production system. Soil organic matter 

serves to naturally increase water holding capacity and retention. Managing for and fostering soil 

organic matter is a key element in a good organic system plan.

Rationale Supporting Recommendation (including consistency with OFPA and Organic

Regulations):

Conservative tillage and no-till practices increase soil organic matter, decrease compaction, minimize 

water evaporation, and increase rain and irrigation water retention and infiltration. Plant, mulch, and 

cover crop residues can increase water retention by preventing crusting and conserving water. 

Incorporated residues and compost improve soil fauna, whose activity increases aeration, opens pores, 

and decreases compaction. In turn, these attributes increase water penetration.

Synthetic water retention and filtration materials are incompatible with a system of sustainable 

agriculture. Natural alternatives and good soil management practices exist, and water use is not an 

OFPA criteria. 

NOSB Vote: 

Classification Motion: Move to classify potassium cellulose glycolate as synthetic

Motion by: Emily Oakley

Seconded by: Harriet Behar

Yes: 14 No: 0 Abstain: 0 Absent: 1 Recuse: 0 
List Motion: Move to list potassium cellulose glycolate as petitioned at 205.601 

Motion by: Emily Oakley

Seconded by: Harriet Behar

Yes: 0 No: 14 Abstain: 0 Absent: 1 Recuse: 0

 Motion Failed
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National Organic Standards Board

Crops Subcommittee

Petitioned Material Proposal

Potassium Cellulose Glycolate

August 16, 2016

Summary of Petition:

Lamberti USA, Incorporated has petitioned for the inclusion of potassium cellulose glycolate on the 

National List at 205.601 (synthetic substances allowed for use in organic crop production) as a synthetic 

inert ingredient. 

Potassium cellulose glycolate, or potassium carboxymethylcelluose (CMC), is a chemically modified 

polymer derived from natural cellulose. The petition proposes to utilize Potassium CMC as a water 

retention aid during irrigation and in combination with liquid fertilizers and nutrients.

Potassium CMC is manufactured from naturally occurring cellulose by replacing one or more reactive 

hydroxyl groups with carboxymethyl groups through etherification. This is achieved by treating cellulose 

with caustic soda to attain the alkali-cellulose complex. This is further reacted with mono chloroacetic 

acid (MCA), and the result is CMC and sodium chloride. Sodium glycolate is formed through a side 

reaction by the caustic soda on MCA. Pure grade CMC is obtained by removing impurities with an 

aqueous solvent treatment. 

Potassium CMC is being petitioned for its water holding properties, delivering water more effectively to 

the plant’s root zone. The petition claims that the material increases drip irrigation efficiency by 

approximately 30-40%.

Summary of Review:

The Subcommittee determined that water usage is not a criterion under OFPA, and there was 

insufficient information justifying the need for this material in an organic production system. Soil 

organic matter serves to naturally increase water holding capacity and retention. Managing for and 

fostering soil organic matter is a key element in a good organic system plan.

The Subcommittee did not request a technical review after deciding that the petitioned material was 

not necessary for organic production. The Subcommittee determined that the petitioned substance fails 

to meet the OFPA criteria and therefore should not be added to the National List.

Category 1: Classification 

1. For CROP use: Is the substance _______ Non-synthetic or ____X___ Synthetic?

 Is the substance formulated or manufactured by a process that chemically changes a substance 

extracted from naturally occurring plant, animal, or mineral sources? [OFPA §6502(21)] If so, 

describe, using NOP 5033-1 as a guide.

Potassium CMC is manufactured from naturally occurring cellulose and undergoes a synthetic 

chemical change.
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2. Reference to appropriate OFPA category:

Is the substance used in production, and does it contain an active synthetic ingredient in the 

following categories: [§6517(c)(1)(B)(i)]; copper and sulfur compounds; toxins derived from 

bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicines and production aids including netting, tree wraps 

and seals, insect traps, sticky barriers, row covers, and equipment cleansers; or (ii) is used in 

production and contains synthetic inert ingredients that are not classified by the Administrator 

of the Environmental Protection Agency as inerts of toxicological concern?

Potassium CMC is a List 4 Inert approved for food and nonfood uses. It is a low-risk polymer (40 

CFR 723.250) and is exempted from a requirement of tolerance under FFDCA section 408 when 

used in according with good agricultural practices.

Category 2: Adverse Impacts 

1. What is the potential for the substance to have detrimental chemical interactions with other 

materials used in organic farming systems? [§6518(m)(1)]

The petition states that potassium salt is petitioned to avoid increasing soil sodium content. As 

a component of plants, cellulose would not be expected to have detrimental interactions with 

other materials used in organic farming systems 

2. What is the toxicity and mode of action of the substance and of its breakdown products or any 

contaminants, and their persistence and areas of concentration in the environment? 

[§6518(m)(2)]

The petition relied on test results of carboxymethylcelluose, sodium salt (structurally identical to 

Potassium CMC except for the cation of the salt) as there are no test results available for the 

petitioned material. Average biodegradation rates were above 73%.

3. Describe the probability of environmental contamination during manufacture, use, misuse or 

disposal of such substance? [§6518(m)(3)]

The petition presented results from EcoToxicological studies on fish and crustacean toxicity for 

carboxymethylcelluose, sodium salt with no toxicity detected.

4. Discuss the effect of the substance on human health. [§6517(c)(1)(A)(i); §6517(c)(2)(A)(i); 

§6518(m)(4)].

Results from acute toxicity tests on rats, short-terms studies on rats, guinea pigs, rabbits, and 

dogs, and long-terms and teratogenicity studies on mice and rats for carboxymethylcelluose, 

sodium salt were shown with minimal or no effects found. The safety data sheet supplied in the 

petition lists no hazard or precautionary statements but does note a European Union special 

provision that the substance may produce an allergic reaction.

5. Discuss any effects the substance may have on biological and chemical interactions in the 

agroecosystem, including the physiological effects of the substance on soil organisms (including 

the salt index and solubility of the soil), crops and livestock. [§6518(m)(5)] 
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The petition presents results from terrestrial toxicity studies measuring bean and corn seed 

exposure to applications carboxymethylcelluose, sodium salt in natural soil media with no 

reported effects.

6. Are there any adverse impacts on biodiversity? (§205.200)

None known.

Category 3: Alternatives/Compatibility

1. Are there alternatives to using the substance? Evaluate alternative practices as well as nonsynthetic and synthetic available materials. [§6518(m)(6)]

A primary goal of an organic system plan is maintaining or improving soil organic matter content 

through strategic management practices. Conservative tillage and no-till practices increase soil 

organic matter, decrease compaction, minimize water evaporation, and increase rain and 

irrigation water retention and infiltration. Plant, mulch, and cover crop residues can increase 

water retention by preventing crusting and conserving water. Incorporated residues and 

compost improve soil fauna, whose activity increases aeration, opens pores, and decreases 

compaction. In turn, these attributes increase water penetration.

2. In balancing the responses to the criteria above, is the substance compatible with a system of 

sustainable agriculture? [§6518(m)(7)]

Synthetic water retention and filtration materials are incompatible with a system of sustainable 

agriculture. Natural alternatives and good soil management practices exist, and water use is not 

an OFPA criteria. The subcommittee does not recommend adding this substance to the National 

List.

Classification Motion: 

Motion to classify potassium cellulose glycolate as synthetic

Motion by: Emily Oakley

Seconded by: Harriet Behar

Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

National List Motion:

Motion to add potassium cellulose glycolate as petitioned at §205.601 

Motion by: Emily Oakley

Seconded by: Harriet Behar

Yes: 0 No: 6 Abstain: 0 Absent: 1 Recuse: 0