Sunset 2019 

Meeting 2 - Review

Crops Substances

November 2017 

Note: With the exception of biodegradable biobased mulch film, the materials included in this list are 

undergoing early sunset review as part of November 18, 2016 NOSB recommendation on efficient 

workload re-organization. 

As part of the National List sunset review process, the NOSB Crops Subcommittee 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.

Chlorine materials: calcium hypochlorite, chlorine dioxide, sodium hypochlorite

Herbicides, soap-based

Biodegradable biobased mulch film

Boric acid

Sticky traps/barriers

Coppers, fixed

Copper sulfate

Humic acids

Micronutrients: soluble boron products

Micronutrients: sulfates, carbonates, oxides, or silicates of zinc, copper, iron, manganese, molybdenum, 

selenium, and cobalt

Vitamins B1, C, E

205.602 Nonsynthetic substances prohibited for use in organic crop production

Lead salts

Tobacco dust (nicotine sulfate)

NOSB October 2017 proposals and discussion documents 17/175
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; 04/2006 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022

Subcommittee Review: 

Calcium hypochlorite is an EPA registered pesticide (OPP No. 014701) that is used in controlling bacteria, 

fungi, and slime-forming algae (2011 TR lines 86-87). In water and soil, calcium hypochlorite separates 

into calcium, hypochlorite ions (OCl-), and hypochlorous acid (HOCl) molecules. The hypochlorous acid 

molecules diffuse through cell walls of microorganisms, changing the oxidation-reduction potential of 

the cell and inactivating triosephosphate dehydrogenase, an enzyme essential of the digestion of 

glucose, destroying the microorganism’s ability to function (2011 TR lines 122-133).

Calcium hypochlorite is produced by passing chlorine gas over slaked lime. It is then separated from the 

coproduct, calcium chloride, and air dried or vacuumed (TR lines 194-195).

Calcium hypochlorite is highly caustic and is a concern for occupational exposure. Acute exposure to 

high concentrations can cause eye and skin injury. Ingestion can cause gastrointestinal irritation and 

corrosive injuries to the mouth, throat, esophagus and stomach (2011 TR lines 411-418).

Public comments were received during the 2019 review indicating that chlorine materials are necessary 

in organic crop production, and that chlorine sanitizers have a wide range of uses, including sanitation of 

equipment and work surfaces, maintaining functioning irrigation systems, preventing the spread of 

disease, and controlling pathogens detrimental to human health. Some commenters said it was 

important to have several types of sanitizers available for use in case resistance develops to any of 

them.

 

Some public commenters expressed concerns that chlorine sanitizers can be harmful to human health 

and the environment, and that alternatives should be used when possible. Commenters also suggested 

that chlorine sanitizers, and all sanitizers, should be reviewed as a group to identify if all sanitizers 

currently on the National List are needed, and if the use of chlorine sanitizers could be limited to use 

only where other sanitizers that are less harmful to human health and the environment are not 

adequate.

Subcommittee vote:

Motion to remove calcium hypochlorite from §205.601(a) based on the following criteria in the Organic 

NOSB October 2017 proposals and discussion documents 18/175
Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Francis Thicke

Seconded by: Emily Oakley

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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; 04/2006 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

EPA has registered the liquid form of chlorine dioxide for use as a disinfectant and sanitizer. The Agency 

also has registered chlorine dioxide gas as a sterilant. Chlorine dioxide is added to drinking water as a 

disinfectant in some municipal water-treatment systems in the United States. EPA has set a maximum 

contaminant level (MCL) of 0.8 mg/L for chlorine dioxide in drinking water and 1 mg/L for chlorite 

(chlorine dioxide’s oxidation product) (2011 TR lines 104-110).

Chlorine dioxide kills microorganisms directly by disrupting transport of nutrients across the cell wall. 

Chlorine dioxide is an effective disinfectant at a pH of between 5 and 10 (2011 TR lines 149-157).

To form chlorine dioxide, sodium chlorate (NaClO3) and sulfuric acid (H2SO4) are reacted with sulfur 

dioxide (SO2), or chloric acid is reacted with methanol (CH3OH). Alternatively, chlorine dioxide can be 

formed with chlorine (Cl2) and sodium chlorite; sodium hypochlorite with hydrochloric acid; potassium 

chlorate with sulfuric acid; or by passing nitrogen dioxide through a column of sodium chlorate (2011 TR 

lines 206-210).

Chlorine dioxide is a severe respiratory and eye irritant. The reaction products of chlorine dioxide 

(chlorite and chlorate) can cause oxidative damage to red blood cells and mild neurobehavioral effects 

(2011 TR lines 433-436). 

Public comments were received during the 2019 review indicating that chlorine materials are necessary 

in organic crop production, and that chlorine sanitizers have a wide range of uses, including sanitation of 

equipment and work surfaces, maintaining functioning irrigation systems, preventing the spread of 

disease, and controlling pathogens detrimental to human health. Some commenters said it was 

important to have several types of sanitizers available for use in case resistance develops to any of 

them. 

NOSB October 2017 proposals and discussion documents 19/175
Some public commenters expressed concerns that chlorine sanitizers can be harmful to human health 

and the environment, and that alternatives should be used when possible. Commenters also suggested 

that chlorine sanitizers, and all sanitizers, should be reviewed as a group to identify if all sanitizers 

currently on the National List are needed, and if the use of chlorine sanitizers could be limited to use 

only where other sanitizers that are less harmful to human health and the environment are not 

adequate.

Subcommittee vote:

Motion to remove chlorine dioxide from §205.601(a) based on the following criteria in the Organic 

Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Francis Thicke

Seconded by: Emily Oakley

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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; 04/2006 NOSB sunset recommendation; 04/2011 

NOSB sunset recommendation; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022

Subcommittee Review: 

Sodium hypochlorite is an EPA registered pesticide (OPP No. 014703) that is used in controlling bacteria, 

fungi, and slime-forming algae (2011 TR lines 86-87). In water and soil, sodium hypochlorite separates 

into sodium, hypochlorite ions (OCl-), and hypochlorous acid (HOCl) molecules. The hypochlorous acid 

molecules diffuse through cell walls of microorganisms, changing the oxidation-reduction potential of 

the cell and inactivating triosephosphate dehydrogenase, an enzyme essential of the digestion of 

glucose, destroying the microorganism’s ability to function. (2011 TR lines 122-133).

Sodium hypochlorite is highly caustic and is a concern for occupational exposure. Acute exposure to 

high concentrations can cause eye and skin injury. Ingestion can cause gastrointestinal irritation and 

corrosive injuries to the mouth, throat, esophagus and stomach (2011 TR lines 411-418).

Generally, sodium hypochlorite is produced by reacting chlorine with a solution of sodium hydroxide 

(NaOH, also called lye or caustic soda). This method is used for most commercial productions of sodium 

hypochlorite. A more active, but less stable formulation of sodium hypochlorite can be produced by 

NOSB October 2017 proposals and discussion documents 20/175
chlorinating a solution of soda ash (Na2CO3) (TR lines 199-202).

Public comments were received during the 2019 review indicating that chlorine materials are necessary 

in organic crop production, and that chlorine sanitizers have a wide range of uses, including sanitation of 

equipment and work surfaces, maintaining functioning irrigation systems, preventing the spread of 

disease, and controlling pathogens detrimental to human health. Some commenters said it was 

important to have several types of sanitizers available for use in case resistance develops to any of 

them. 

Some public commenters expressed concerns that chlorine sanitizers can be harmful to human health 

and the environment, and that alternatives should be used when possible. Commenters also suggested 

that chlorine sanitizers, and all sanitizers, should be reviewed as a group to identify if all sanitizers 

currently on the National List are needed, and if the use of chlorine sanitizers could be limited to use 

only where other sanitizers that are less harmful to human health and the environment are not 

adequate.

Subcommittee vote:

Motion to remove sodium hypochlorite from §205.601(a) based on the following criteria in the Organic 

Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: NA

Motion by: Francis Thicke

Seconded by: Emily Oakley

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review

Soap-based herbicides generally are comprised of a fatty acid component with carbon, hydrogen and 

oxygen atoms with potassium or ammonium counterions. Potassium salts of fatty acids include 

individual soap salts such as potassium laurate, potassium myristate, potassium oleate and potassium 

ricinoleate). Potassium salts of fatty acids are produced through a process known as saponification, 

whereby aqueous potassium hydroxide (KOH) is added to fatty acids commonly found in animal fats and 

plant oils (NPIC, 2001; Nora, 2010). Alternatively, ammonium salts of fatty acids, such as ammonium 

nonanoate, are produced through the room temperature reaction of aqueous ammonia (NH3) or 

ammonium hydroxide (NH4OH) with fatty acids (Reiling, 1962; Dunn, 2010). Commercially available 

soap salt products are used as acaricides, algicides, herbicides, insecticides and animal repellents, 

controlling a variety of insects, mosses, algae, lichens, liverworts and other weeds. 

NOSB October 2017 proposals and discussion documents 21/175
Technical Review Evaluation Report, Soap-Based Herbicides, February 27, 2015: 

Potential Human Health Impact Concerns: The US Food and Drug Administration (FDA) classifies “salts 

of fatty acids” as Generally Recognized As Safe (GRAS) when used in food and in the manufacture of 

food components (7 CFR 172.863). Ammonium salts of fatty acids are not included in the FDA’s 

description of GRAS fatty acid salts. Despite the lack of systemic toxicity associated with soap salts, both 

potassium and ammonium salts of fatty acids can lead to various forms of irritation. 

Potassium soaps are classified as corrosive to the skin, side effects include skin redness, cracking and 

fissuring of skin. Even though potassium soaps are only moderately irritating to the skin, they are 

corrosive to the eyes and may cause permanent eye damage in extreme exposure scenarios (US EPA, 

2012). 

Reproductive issues, weight loss, and failure to maintain pregnancies were observed in laboratory 

animals administered soap salts at high doses. However, the incidences of fetal loss, malformations, 

visceral or skeletal anomalies and skeletal variants were within the historical control range for young 

mice in the 500 mg/kg-day dose group. The International Agency for Research on Cancer (IARC) has not 

listed potassium or ammonium soaps as carcinogens (IARC, 2014).

Potential aquatic organisms impact concerns: The technical review (TR) states that the acute and 

chronic toxicity of soap salts is markedly different for land- and water-dwelling organisms. Terrestrial 

animals—including mammals, birds, and insects—are largely unaffected by exposure to even high doses 

of potassium and ammonium salts of fatty acids; however, aquatic animals are moderately (fish) to 

highly (crustaceans) sensitive to these substances (Thurston County, 2009a; Thurston County, 2009b). 

Studies submitted to US EPA for registration of potassium and ammonium salts of fatty acids indicate 

that potassium salts are generally more toxic to aquatic organisms than their ammonium counterparts. 

The TR also states that they may harm many soil-dwelling organisms including insects, earthworms, and 

nematodes that are supportive of organic production. 

International Standards, Soap-Based Herbicides: Organic standards for COR, EU, Codex Alimentarius 

Commission, MAFF, and IFOAM allow fatty acid potassium salts for differing uses in organic production. 

COR specifically does not allow ammonium soaps to be in direct contact with soil or edible portion of 

crops production. 

The Crops Subcommittee supports relisting soap-based herbicides at §205.601(b).

Subcommittee vote:

Motion to remove soap based herbicides from §205.601(b) based on the following criteria in the 

Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Sue Baird

Seconded by: Jesse Buie

Yes: 0 No: 5 Abstain: 2 Absent: 2 Recuse: 0

NOSB October 2017 proposals and discussion documents 22/175
Biodegradable biobased mulch film

Reference: 205.601(b) As herbicides, weed barriers, as applicable (2) Mulches (iii) Biodegradable 

biobased mulch film as defined in §205.2. Must be produced without organisms or feedstock derived 

from excluded methods.

Technical Report: 2012 TR; 2015 Report; NOP Policy Memorandum 15-1; Supplemental Technical 

Evaluation Report 2016

Petition(s): 2012

Past NOSB Actions: Actions: 10/2012 NOSB Recommendation

Recent Regulatory Background: Added to National List effective 10/30/14 (79 FR 58655) 

Sunset Date: 10/30/19 

Subcommittee Review:

Biodegradable biobased mulch films were approved for placement on the National List of approved 

synthetics without detailed information about the how much non-biobased content would be allowed. 

The vast majority of mulch films in this category contain 20% or less of biobased materials, with the 

remainder consisting of polymers, colorings, and other synthetic materials. There are some products 

that might meet the biobased aspect of this material’s definition on §205.2, but are either not 

biodegradable or are not used widely in production due to brittleness or other production issues. 

In January 2015, the National Organic Program issued Policy Memorandum 15-1, clarifying that 

biodegradable biobased mulch film must not contain any synthetic polymer feedstocks. The NOSB 

requested a limited scope technical review (TR) in 2016. This TR focused upon biobased biodegradable 

mulches that contain polymers and the soil and crop health effects they may have as they biodegrade. 

This supplemental TR was inconclusive, since research on these materials is currently limited. 

There have been numerous public comments requesting the NOSB work with the NOP to allow a 

biodegradable biobased mulch that contains these unique polymers. Some noted that having a 

degradable plastic mulch is more environmentally friendly than using landfills for the non-degradable 

plastic mulches. Commenters also acknowledged that there are currently very few options (other than 

difficult to use paper mulch), for 100% biobased mulch, but felt the listing should remain. This could 

encourage development of mulch that would meet the NOP regulations, or solicit information that 

could change the directive in the policy memo. The fact this product is derived from petroleum, led to 

negative comments asking for its removal from the National List of approved synthetics.

There are studies now in progress that could provide more information in the future, which could result 

in a proposed annotation change or other mechanism to allow the use of a mulch containing some 

percentage of these synthetic polymers. The research may also support the current NOP regulations 

and policy memo that no synthetic polymers are allowed in degradable mulch. Our current 

understanding of the unique synthetic polymers used in these biodegradable mulches is they are 

recognized by the soil biological life as food, and readily consumed and degraded when incorporated 

into the soil. However, there are fossil fuel-based fertilizers, used in nonorganic agriculture, that also 

break down in the soil and provide nutrients for plants as well, but they are not allowed. The Crops 

Subcommittee will keep biodegradable, biobased mulch film on our work agenda. We will revisit it again 

once we have more information and can determine if the polymers used in these biodegradable mulch 

films are compatible with the approved synthetic materials criteria in the Organic Foods Production Act.

NOSB October 2017 proposals and discussion documents 23/175
The Crops Subcommittee favors keeping biodegradable biobased mulch film on the National List at 

205.601(b).

Subcommittee vote:

Motion to remove biodegradable biobased mulch film as defined in §205.2 - Must be produced without 

organisms or feedstock derived from excluded methods.

Motion by: Harriet Behar

Seconded by: Emily Oakley 

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

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

Boric acid, derived from the mineral borax, is a weak acid that has long been considered a “least-toxic” 

pesticide because it is non-volatile when placed in bait or gel formulations and therefore eliminates risk 

of direct exposure. However, when used as a dust for structural pest control, exposure can occur, 

causing hazards for exposed populations. 

Boric acid is a reproductive toxicant, a suspected endocrine disruptor, and toxic to plants and animals if 

misused. Boric acid has a low toxicity to mammals and humans (1995 TAP). Borax mining causes 

environmental damage. Boric acid raises challenging issues of health and environmental/mining 

impacts, and there are alternative materials and practices that may be less harmful. Of the alternative 

choices of pest control products, boric acid is considered to be among the least toxic, as noted in the 

sources used for this review. 

The following question was put forth by the NOSB to the public in 2015: “Are there situations in which 

boric acid is the only, or safest, means of controlling the pest?”, and some response was received. It 

was stated that it is good to have as a means for control and as a back-up with insect problems. 

Comment was received that natural alternatives do exist, and that management changes rather than a 

material application is the best if problems do occur. 

At the Fall 2015 NOSB meeting, the Crops Subcommittee proposed a vote to remove boric acid from 

§205.601(e) on the basis of not fully meeting all sub-components of OFPA criteria in regards to: criteria 

NOSB October 2017 proposals and discussion documents 24/175
of Impacts on Humans and the Environment, Essentiality, and Compatibility & Consistency. The motion 

to remove failed after receiving 1 “Yes” and 134 “No” votes. While boric acid does not fully meet the 

OFPA criteria of Impacts on Humans and the Environment, Essentiality, and Compatibility & Consistency, 

the alternatives often have equally challenging issues. 

This material is often used in packing sheds and other facilities. Many times it is used as a powder 

introduced into cracks and crevices, and is essential for controlling ants and roaches. A number of 

members of the public did comment regarding the listing of boric acid, and the majority supported relisting. Numerous distributors, food processing businesses, certifiers and farmers recommended 

relisting, as a necessary tool for control of ants and roaches in packing houses and food handling 

facilities. One certifier noted it was not used by any of their certified operations. A few organizations 

recommended changing the annotation to read: “For use only as bait in traps or in gel formulations”. 

The CS would consider a petition requesting an annotation change.

Subcommittee vote:

Motion to remove boric acid - As insecticides (including acaricides or mite control) (3) Boric acidstructural pest control, no direct contact with organic food or crops from 205.601(e) based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

none

Motion by: Harriet Behar

Seconded by: Francis Thicke

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

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

This listing covers a wide range of traps and coatings made with a number of different materials, 

including coated paper, coated plastic, and brushed on sticky chemicals applied directly to plants. They 

are typically used for pest control and monitoring in limited quantities and in confined areas, such as 

tree trunks. As noted in the 1995 TAP review, these products are of low toxicity, and while persistent, 

they are unlikely to contaminate the surrounding environment. Coated plastic sticky traps produce a 

small amount of plastic waste. The sticky coating may contain petroleum distillates, and the traps may 

contain volatile attractants; however, as they do not come in direct contact with crops, there is minimal 

concern for human health effects. Some are non-specific and can trap non-targeted beneficial insects, 

spiders, mites, reptiles, and amphibians, although they do not attract non-targeted insects or animals. 

One 1995 TAP reviewer suggested the traps are compatible with organic production only in processing 

NOSB October 2017 proposals and discussion documents 25/175
plants. Another suggested they should be used only for monitoring, mass trapping, or barriers. Over 

twenty years later, more traps are now available, including targeted lures to attract only pest insects, 

and there is significant experience with their use in organic farming without negative consequences or 

problems.

During the 2017 sunset review (completed in 2015), public feedback was solicited on the following 

questions: 1) should the wide range of products covered by this listing be categorized by use and 

materials, and 2) are some uses of sticky traps incompatible with organic production? There was 

support for the continued listing of sticky traps/barriers as a permitted synthetic given both product 

availability and effective insect control. 

During this sunset review, no additional information was requested. As in the previous review, there 

was broad support for relisting sticky traps/barriers from farmers, certifiers, and trade organizations. 

There was some concern that non-target animals can get caught, with a suggested annotation stating 

that traps and barriers must be used in a way that prevents non-target trapping.

Subcommittee vote:

Motion to remove sticky traps from §205.601(e) based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Emily Oakley

Seconded by: Sue Baird

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review: 

Coppers, fixed, and copper sulfate were reviewed and approved for continued use during the October 

2015 NOSB meeting. Coppers continue to be an important tool for organic producers as part of a 

comprehensive approach to disease management in many crops. For example, copper products became 

an integrated part of fire blight control in pome fruits after antibiotics were removed from the national 

list. While some copper minerals and compounds occur in nature, products for agriculture are made 

from by-products of processing copper ores and are considered synthetic. Copper is on the list of 

exemptions for synthetic materials in OFPA at § 6517(c)(1)(B)(i). This review applies to both the listing 

for Coppers, fixed and the listing for Copper Sulfate on the National List 205.601. 

NOSB October 2017 proposals and discussion documents 26/175
The last technical report (TR) was completed in 2011 at which time the EPA had recently completed a 

re-assessment of copper products. The potential adverse impacts are well known and were discussed in 

the TR. The main concern with copper materials is their potential to accumulate to toxic levels in the 

environment. The TR notes the many factors that can affect copper accumulation (2011 TR lines 465 to 

549). To address this concern, the copper listings on the National List have the annotation "That, 

copper-based materials must be used in a manner that minimizes accumulation in the soil..." 

To put copper use patterns into perspective, we consulted the Materials Fact Sheet Copper Products 

from the Organic Resource Guide, 2nd edition (2013): 

http://web.pppmb.cals.cornell.edu/resourceguide/pdf/resource-guide-for-organic-insect-and-diseasemanagement.pdf 

"In New York, maximum soil concentration rates for copper have been recommended based on soil 

type; rates range from 40 ppm in sandy soils, to 60 ppm in silt loam, to 100 ppm in clay soils. These rates 

have been suggested in order to protect against phytotoxicity and negative impacts on soil life (Harrison 

et al. 1999). Typically, each spray with a copper-based fungicide results in an application of 1 to 4 lb. of 

copper per acre, raising the topsoil concentration from 0.5 to 2 ppm; often several copper sprays are 

made per season. Under a heavy copper spray program, toxic topsoil levels could be reached in a matter 

of decades." 

The effects on human health from agricultural copper were addressed in the TR as follows: 

"In "III Summary of Coppers Risk Assessments" of RED-Cu (2009), human health risk, after aggregate or 

combined exposure to copper compounds, was adequately assessed. The basic considerations are that 

copper is naturally-occurring, ubiquitous in environment, copper itself is a nutrient, copper deficiency is 

more of a problem than copper over-exposure, the active assimilation of copper through routes of food, 

drink, air, non-occupational sources, and other exposure is efficiently modulated, excessively available 

copper is not assimilated but instead is actively excreted, and no systematic and carcinogenic effects are 

observed/confirmed. The overall conclusion is that copper, when used as pesticide following the label, 

would not cause toxic effects." (2011 TR lines 933 - 940) 

The effects of copper on the agro-ecosystem (including on biodiversity) were also discussed in the TR: 

The 2011 TR (lines 647 - 761) is quite extensive and evaluates many studies on soil microorganisms, 

earthworms, and crops. The conclusions in all instances is that it depends on the soil composition, soil 

pH, concentration of copper, species being studied, and crop species being grown. 

And: 

Copper can have a significant diminishing effect on biodiversity in an aquatic environment such as 

wetlands. However it is not prone to leaching or runoff in all but the sandiest of soils and is not likely to 

end up in the sensitive environments if used according to label restrictions. In contrast, copper can be 

used to control invasive aquatic plants that out-compete native plants in some ecosystems and this 

would have a positive effect on biodiversity. (2011 TR lines 870 - 874) 

The TR closes with a quote from the "Reregistration Eligibility Decision (RED) for Coppers – Revised May 

2009":

"U.S. EPA recognized the advantages of using copper pesticides (RED-Cu, 2009): "Through extensive 

outreach to the public as well as additional comments and refined information provided by the user 

community, the Agency has determined that there are many benefits that support the significance and 

continued agricultural uses of copper pesticides. A significant benefit is that copper exposure from all 

sources, including use as a pesticide in agricultural settings, does not pose any human health concerns. 

Although there is still potential for ecological effects to non-target organisms, there are many benefits 

to retain agricultural uses of copper pesticides" (from the 2011 TR lines 988-996, p.20) 

The high variability in copper use patterns and organic farming situations led the NOSB to conclude in 

October 2015 that the annotation in place for this substance is appropriate since certifiers can assess 

NOSB October 2017 proposals and discussion documents 27/175
copper accumulation in the context of a specific farming operation. However, to make sure that this is 

true, public comment was requested from growers on the importance of this material, and the ways of 

monitoring accumulation. Input from certifiers was sought on whether testing was being required for 

monitoring and whether there have been non-compliances issued for enforcement of this annotation. 

Comments from certifiers indicated that they require either a testing protocol or an overall copper 

monitoring plan for growers who include copper on their OSPs. None of the certifiers who wrote 

comments had issued a non-compliance for accumulation of copper, but several had done so for not 

having a monitoring plan in place. 

In the review of copper materials in Spring 2017, several public comments expressed concern about the 

overuse of copper, particularly near harvest time, when copper residues could still be seen on harvested 

produce. There was a question of whether an additional annotation should be added that no visible 

residues of copper be present at harvest. Several certifiers commented that this would be very difficult 

to enforce since it would require an inspection visit during the actual harvest. In general, comments 

during the Spring 2017 Review supported relisting of copper materials and that the current annotation 

is adequate.

Given the extensive use and documented need for copper sprays, the Crops Subcommittee thinks these 

materials should be renewed. 

Subcommittee vote:

Motion to remove coppers, fixed from §205.601(i) based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Steve Ela

Seconded by: Emily Oakley

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

Coppers, fixed, and copper sulfate were reviewed and approved for continued use during the October 

2015 NOSB meeting. Coppers continue to be an important tool for organic producers as part of a 

comprehensive approach to disease management in many crops. For example, copper products became 

an integrated part of fire blight control in pome fruits after antibiotics were removed from the national 

NOSB October 2017 proposals and discussion documents 28/175
list. While some copper minerals and compounds occur in nature, products for agriculture are made 

from by-products of processing copper ores and are considered synthetic. Copper is on the list of 

exemptions for synthetic materials in OFPA at § 6517(c)(1)(B)(i). This review applies to both the listing 

for Coppers, fixed and the listing for Copper Sulfate on the National List 205.601. 

The last technical report (TR) was completed in 2011 at which time the EPA had recently completed a 

re-assessment of copper products. The potential adverse impacts are well known and were discussed in 

the TR. The main concern with copper materials is their potential to accumulate to toxic levels in the 

environment. The TR notes the many factors that can affect copper accumulation (2011 TR lines 465 to 

549). To address this concern, the copper listings on the National List have the annotation "That, 

copper-based materials must be used in a manner that minimizes accumulation in the soil..." 

To put copper use patterns into perspective, we consulted the Materials Fact Sheet Copper Products 

from the Organic Resource Guide, 2nd edition (2013): 

http://web.pppmb.cals.cornell.edu/resourceguide/pdf/resource-guide-for-organic-insect-and-diseasemanagement.pdf 

"In New York, maximum soil concentration rates for copper have been recommended based on soil 

type; rates range from 40 ppm in sandy soils, to 60 ppm in silt loam, to 100 ppm in clay soils. These rates 

have been suggested in order to protect against phytotoxicity and negative impacts on soil life (Harrison 

et al. 1999). Typically, each spray with a copper-based fungicide results in an application of 1 to 4 lb. of 

copper per acre, raising the topsoil concentration from 0.5 to 2 ppm; often several copper sprays are 

made per season. Under a heavy copper spray program, toxic topsoil levels could be reached in a matter 

of decades." 

The effects on human health from agricultural copper were addressed in the TR as follows: 

"In "III Summary of Coppers Risk Assessments" of RED-Cu (2009), human health risk, after aggregate or 

combined exposure to copper compounds, was adequately assessed. The basic considerations are that 

copper is naturally-occurring, ubiquitous in environment, copper itself is a nutrient, copper deficiency is 

more of a problem than copper over-exposure, the active assimilation of copper through routes of food, 

drink, air, non-occupational sources, and other exposure is efficiently modulated, excessively available 

copper is not assimilated but instead is actively excreted, and no systematic and carcinogenic effects are 

observed/confirmed. The overall conclusion is that copper, when used as pesticide following the label, 

would not cause toxic effects." (2011 TR lines 933 - 940) 

The effects of copper on the agro-ecosystem (including on biodiversity) were also discussed in the TR: 

The 2011 TR (lines 647 - 761) is quite extensive and evaluates many studies on soil microorganisms, 

earthworms, and crops. The conclusions in all instances is that it depends on the soil composition, soil 

pH, concentration of copper, species being studied, and crop species being grown. 

And: 

Copper can have a significant diminishing effect on biodiversity in an aquatic environment such as 

wetlands. However it is not prone to leaching or runoff in all but the sandiest of soils and is not likely to 

end up in the sensitive environments if used according to label restrictions. In contrast, copper can be 

used to control invasive aquatic plants that out-compete native plants in some ecosystems and this 

would have a positive effect on biodiversity. (2011 TR lines 870 - 874) 

The TR closes with a quote from the "Reregistration Eligibility Decision (RED) for Coppers – Revised May 

2009":

"U.S. EPA recognized the advantages of using copper pesticides (RED-Cu, 2009): "Through extensive 

outreach to the public as well as additional comments and refined information provided by the user 

community, the Agency has determined that there are many benefits that support the significance and 

continued agricultural uses of copper pesticides. A significant benefit is that copper exposure from all 

sources, including use as a pesticide in agricultural settings, does not pose any human health concerns. 

NOSB October 2017 proposals and discussion documents 29/175
Although there is still potential for ecological effects to non-target organisms, there are many benefits 

to retain agricultural uses of copper pesticides" (from the 2011 TR lines 988-996, p.20) 

The high variability in copper use patterns and organic farming situations led the NOSB to conclude in 

October 2015 that the annotation in place for this substance is appropriate since certifiers can assess 

copper accumulation in the context of a specific farming operation. However, to make sure that this is 

true, public comment was requested from growers on the importance of this material, and the ways of 

monitoring accumulation. Input from certifiers was sought on whether testing was being required for 

monitoring and whether there have been non-compliances issued for enforcement of this annotation. 

Comments from certifiers indicated that they require either a testing protocol or an overall copper 

monitoring plan for growers who include copper on their OSPs. None of the certifiers who wrote 

comments had issued a non-compliance for accumulation of copper, but several had done so for not 

having a monitoring plan in place. 

In the review of copper materials in Spring 2017, several public comments expressed concern about the 

overuse of copper, particularly near harvest time, when copper residues could still be seen on harvested 

produce. There was a question of whether an additional annotation should be added that no visible 

residues of copper be present at harvest. Several certifiers commented that this would be very difficult 

to enforce since it would require an inspection visit during the actual harvest. In general, comments 

during the Spring 2017 Review supported relisting of copper materials and that the current annotation 

is adequate.

Given the extensive use and documented need for copper sprays, the Crops Subcommittee thinks these 

materials should be renewed. 

Subcommittee vote:

Motion to remove copper sulfate from §205.601(i) based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Steve Ela

Seconded by: Francis Thicke

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

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: 2012 TR for oxidized lignite/humic acid derivatives

Petition(s): N/A

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

sunset recommendation; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

Humic acids, which naturally exist in soils, can be supplemented by manufactured humic acids from 

oxidized lignite. Humic acids are used as a component of traditional fertilizers, and do not provide

NOSB October 2017 proposals and discussion documents 30/175
additional nutrients to plants, but rather affect soil fertility by making micronutrients more readily 

available to plants. “Humic acids are applied as a soil conditioner to increase cation exchange capacity, 

enhance mineral availability, improve soil structure, stimulate soil microorganisms, and provide broad 

spectrum trace elements.” Commercially available humic acids are derived from leonardite and lignite.

Extracts from nonsynthetic humates by hydrolysis using synthetic or nonsynthetic alkaline materials are

permitted, including the use of potassium hydroxide and ammonium hydroxide. Humic acid derivatives 

are on the National List with the following annotation: naturally occurring deposits, water and alkali 

extracts only.” [7 CFR 205.601(j)(3)].

In 2015 the majority of comments were in favor of keeping humic acids on the National List. At the Spring 

2017 NOSB meeting the majority of commenters were also in favor of keeping humic acids. Several 

objections focused on environmental concerns related to humic acids as fertility tools manufactured, in 

some cases, from low grade coal (lignite).

However, as reiterated in public comment, humic acids are viewed as a critical and necessary element of 

nutrient management in organic farming. Concerns were raised that removal from the National List would

negatively impact many growers. 

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. 

Subcommittee vote:

Motion to remove humic acids from 205.601(j) based on the following criteria in the Organic Foods

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: NA

Motion by: Ashley Swaffar

Seconded by: Dave Mortensen

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

Micronutrients: Soluble boron products.

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. 

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; 10/2015 sunset recommendation; 10/2015 micronutrient annotation 

change

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

 

Subcommittee Review:

Micronutrients, including soluble boron, are essential for plant health and are typically applied in very 

small quantities. While producers can choose to rely on the natural presence of micronutrients in their 

soil, many find deficiencies of some or all of these micronutrients on the National List. The lack of these 

micronutrients can be a limiting factor in water and macro-nutrient uptake, and can result in limiting 

growth and vitality of crops.

NOSB October 2017 proposals and discussion documents 31/175
At the October 29, 2015 NOSB meeting, the Board voted to change the Micronutrients annotation from:

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.

As of January 17, 2017, this annotation change has not yet been implemented by the NOP or printed in 

the Federal Register. The NOSB crops supports this annotation change.

 

All public commenters were supportive of relisting this micronutrient, calling it essential. Certifiers, 

distributors, food processing businesses, and many individual growers stated their need for this material 

and that it is very commonly used. One commenter felt that there should be a way to address overaccumulation of all micronutrients used by organic growers. Others felt that if testing must be done 

before micronutrients are used, the application may be too late to save the crop or perennial plant.

The Subcommittee supports the proposed annotation change recommended by the NOSB in October 

2015. Removing the requirement that there be soil testing before allowing application is problematic 

for both perennial and annual crop producers. There are numerous ways of documenting a deficiency, 

other than soil testing. By the time the deficiency is noted through soil testing, it may be too late to 

save the perennial plant or crop. This is an essential micronutrient, used across all types of crop 

production.

The Crops Subcommittee supports relisting micronutrients: soluble boron products at §205.601(j)(6).

Subcommittee vote:

Motion to remove micronutrients: soluble boron products from §205.601(j) based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Harriet Behar

Seconded by: Jesse Buie

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

Micronutrients: sulfates, carbonates, oxides, or silicates of zinc, copper, iron, manganese, 

molybdenum, selenium, and cobalt

Reference: 205.601(j)(6) - As plant or soil amendments. 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. (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; 10/2015 annotation change recommendation; 10/2015 sunset 

NOSB October 2017 proposals and discussion documents 32/175
recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review: 

Micronutrients are essential for plant health and are typically applied in very small quantities. While 

producers can choose to rely on the natural presence of micronutrients in their soil, many find 

deficiencies of some or all of the micronutrients on the National List. The lack of these micronutrients 

can be a limiting factor in water and macro-nutrient uptake, and can result in limiting growth and vitality 

of crops.

At the October 29, 2015 NOSB meeting, the Board voted to change the micronutrients annotation from:

205.601 (j) -As plant or soil amendments. 

(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 plant or soil amendments. 

(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.

As of January 17, 2017, this annotation change has not been published in the Federal Register.

 

All public commenters were supportive of relisting these micronutrients, calling them essential in a 

variety of cropping systems. Certifiers, distributors, food processing businesses, and many individual 

growers stated their need for these materials and one or more of them are commonly used. One 

commenter felt that there should be a way to address over-accumulation of all micronutrients used by 

organic growers. Others felt that if testing must be done before micronutrients are used, the 

application may be too late to save the crop or perennial plant.

The Crops Subcommittee supports renewing micronutrients with the proposed annotation change 

recommended by the NOSB in October 2015. The requirement that there be soil testing before allowing 

application is problematic for both perennial and annual crop producers. There are numerous ways of 

documenting a deficiency, other than soil testing. By the time the deficiency is noted through soil 

testing, it may be too late to save the perennial plant or crop. Many of these are essential 

micronutrients, used across all types of crop production.

Subcommittee vote:

Motion to remove micronutrients: sulfates, carbonates, oxides, or silicates of zinc, copper, iron, 

manganese, molybdenum, selenium, and cobalt at §205.601 (j) based on the following criteria in the 

Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none 

Motion by: Harriet Behar

Seconded by: Steve Ela 

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

NOSB October 2017 proposals and discussion documents 33/175
Vitamins B1, C, E

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

Technical Report(s): 1995 TAP; 2015 TR

Petition(s): N/A

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

sunset recommendation; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

Vitamins, including synthetically derived vitamins B1 (thiamine), C (ascorbic acid) and E (tocopherols), 

are generally considered non-toxic essential nutrients for terrestrial and aquatic organisms. 

Nonsynthetic sources of all vitamins and synthetic sources of vitamins B1, C, and E may be used in 

certified organic crop production. Vitamin B1 is an ingredient in many commercial root stimulator 

products helping to establish nursery-grown planting stock once transplanted. As noted in the 2015 

technical review, the available literature does not support the premise that foliar and soil applications of 

vitamin B1 are responsible for root stimulation in transplanted crops. Vitamins C and E are used to 

promote both growth and yields and to protect plants from oxidative stress due to salinity. However, 

practical information regarding their use was unavailable; therefore the TR relied on peer-reviewed 

scientific literature. 

An OMRI (Organic Materials Review Institute) product search for each of the three vitamins resulted in 

zero entries. An OMRI generic materials database search indicated that nonsynthetic plant hormones 

such as gibberellic acid, indole acetic acid (IAA), and cytokinins might be applied to organic crops as 

plant growth regulators. Additionally, there are several naturally derived, OMRI-listed substances 

marketed to stimulate root growth.

During the 2017 sunset review, there was some public comment in support of relisting these materials 

for the purpose intended. Commenters indicated that vitamins B1, C, and E are rarely used individually 

but are included as ingredients in some of the products reviewed for crop fertility. To supplement the 

1995 TAP review, the Crops Subcommittee requested a technical review.

The 2015 TR indicated that the root growth claims associated with vitamin B1 are largely 

unsubstantiated. Alternative practices include encouraging the growth and productivity of beneficial 

soil microorganisms to help produce vitamin B1, reduce fertilizer use, refrain from applying fertilizer at 

the time of planting, and proper irrigation of the root ball and surrounding soil. There was no use 

information for vitamins C and E on agriculture extension websites.

During the 2019 sunset review, additional information was requested on the efficacy and use of vitamin 

B1, given that the 2015 TR stated that it is not generally effective at reducing transplant shock or 

stimulating new root growth outside of a laboratory setting. Public comments were solicited as to 

whether vitamin B1 should be removed or if there are there other benefits attributed to it that 

necessitates its continued listing as a plant or soil amendment. Specific information was invited 

regarding its use in the tree fruit industry and if there is a need for vitamin B1 to assist in transplant 

shock or replant disease issues.

NOSB October 2017 proposals and discussion documents 34/175
Public comments were received from certifiers, material reviewers, organizations, and farmers 

supporting the continued listing of the vitamins. In response to the questions posed, stakeholders again 

noted that there are products in use containing multiple vitamins, particularly in blended fertilizers. 

There was some concern that the vitamins could be made from excluded methods; however, there are 

vitamins available from non-GMO sources, and material reviewers can obtain affidavits attesting to that. 

There was very limited feedback regarding the efficacy and use of vitamin B1, particularly in relation to 

the tree fruit industry.

The 2015 TR reveals that it is the auxins indole butyric acid (IBA) and naphthylacetic acid (NAA) that 

“contribute to root regeneration of transplanted trees by suppressing crown growth to effectively 

redirect resources to developing roots”, rather than vitamin B1 (TR lines 102-111). Additionally, 

multiple studies of vegetable transplants, trees, and flowers concluded that vitamin B1 had no impact 

on seedling vigor, size, color, or root development (TR lines 111-117). The TR was unable to describe a 

mode of action for the substance “in the absence of significant in vivo results correlating vitamin B1 

applications with enhanced root growth” (TR lines 212-219). The TR provides broad reference to 

alternative substances for Vitamin B1 (TR lines 643-692). There are no OMRI approved brand name 

crop inputs containing Vitamin B1 in the final product.

The Crops Subcommittee chose to separate the vitamins for voting purposes, as indicated below.

Subcommittee votes:

Motion to remove vitamin B1 from §205.601(j) based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: incompatible with a system of sustainable 

agriculture due to its unproven efficacy or need and a lack of essentiality.

Motion by: Emily Oakley

Seconded by: Steve Ela

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

Motion to remove Vitamins C and E from §205.601(j) based on the following criteria in the Organic 

Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Emily Oakley

Seconded by: Harriet Behar

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

Lead salts

Reference: 205.602 The following nonsynthetic substances may not be used in organic crop production: 

(d) Lead salts.

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022

NOSB October 2017 proposals and discussion documents 35/175
Subcommittee Review:

Lead poisoning can cause a number of adverse human health effects but is particularly detrimental to 

the neurological development of children. Lead accumulates in soils, so it is important to avoid soil 

applications of materials containing lead, whether the lead is in synthetic materials or naturally 

occurring (nonsynthetic) lead salts.

Public comments received were in favor of keeping lead salts on the list of nonsynthetic substances 

prohibited for use in organic crop production. 

The NOSB recommends keeping lead salts in its prohibited status on the National List. 

Subcommittee vote: 

Motion to remove lead salts from §205.602 based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Francis Thicke

Seconded by: Emily Oakley

Yes: 0 No: 7 Abstain: 0 Absent: 2 Recuse: 0

Tobacco dust (nicotine sulfate)

Reference: 205.602 The following nonsynthetic substances may not be used in organic crop production: 

(i) Tobacco dust (nicotine sulfate)

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; 10/2015 sunset recommendation

Recent Regulatory Background: Sunset renewal notice 2017 (82 FR 14420)

Sunset Date: 03/15/2022 

Subcommittee Review:

Tobacco dust, nicotine sulfate, has been present on the National List as a prohibited substance since the 

inception of the USDA organic regulations. This natural product can be used as a pesticide and as a fertility 

input. Due to the negative human health effects caused by this material, it has been relisted as a 

prohibited nonsynthetic on the National List at every sunset with no objections from the public or from the 

NOSB. It is present on the Hazardous Substance list and regulated by OSHA and the EPA as well as other 

agencies.

Public comments indicated that certifiers, businesses and public interest organizations agree that this 

product should remain listed as a prohibited nonsynthetic. It was noted by two certifiers and OMRI that 

this is currently allowed as a natural agricultural product to be incorporated into the soil, while tobacco 

dust, tea and smoke are prohibited by USDA organic regulations. Clarification had been requested to better 

NOSB October 2017 proposals and discussion documents 36/175
draw the line between where it is allowed and where it is prohibited. It was noted that this product is no 

longer commercially available as a crop pest control product, however it could still be homemade.

The Subcommittee recognizes there are questions as to where to draw the line in respect to the use of 

tobacco, tobacco dust, smoke, and tea. The Subcommittee is researching the use of various tobacco 

products as soil amendments, compost feedstocks, etc. in organic agriculture as well as future actions 

needed, if any, to clarify these allowed or prohibited uses.

The Crops Subcommittee supports keeping tobacco dust on the National List at §205.602.

Subcommittee vote:

Motion to remove tobacco dust from §205.602 based on the following criteria in the Organic Foods 

Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none

Motion by: Harriet Behar

Seconded by: Joelle Mosso

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

NOSB October 2017 proposals and discussion documents 37/175