Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday January 5, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Harold Austin (HA); Colehour Bondera 

(CBo); Carmela Beck (CBe); Jean Richardson (JR) - sitting in; Tracy Favre (TF) - sitting in

Absent: none

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016

Substance Contact TR 

request?

Notes Scheduled 

for disc/ 

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA Y Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015

Jan 19 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Scheduled 

for disc/

Vote

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015)

Feb 2 disc 

TR if 

available

TBD

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS to review

Proposal 

Spr 2016

Hypochlorous Acid 

205.605 and 

205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19 Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1/Jan 

19

TBD

Calcium Chloride 

annotation change

205.602

CBe Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16

Jan 19 TBD

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16

Feb 2 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

CBo/FT Report? Mar 15 TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

ZS DD? Feb 2 TBD

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved/

Spr 2016

Newspaper -

annotation change

ZS Will write justification to send to ES and 

NOP.

TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of December 15

• Calcium Chloride (CBe): Discuss 2018 sunset questions

• Ash from Manure Burning (CBe): Discuss petition

• Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR?

• Contamination Issues in Farm Inputs (CBo/FT) - Discuss project

• Squid and Squid Byproducts (CBe) - Discuss TR if available

• Copper sulfate (ZS) - Discuss 2018 sunset questions

• Other items 

• Adjourn 

Discussion

• Crops Subcommittee notes of December 15 approved with a change to the text regarding 

hypochlorous acid.

• Calcium Chloride 208 sunset (CBe). The lead summarized the material, its uses, and previous reviews. 

The lead researched information from two Material Review Organizations (MROs) and noted that there 

are ~30 registered products containing calcium chloride. The draft review will be updated with some 

potential questions and will be finalized for posting for the April 2015 meeting. 

• Calcium Chloride annotation change (CBe). The group discussed the 2015 petition with respect to the 

2005 petition, which was rejected by a previous Board because it failed to meet the OFPA criteria. 

Members discussed the difference(s) between the two petitions and whether or not there was any new 

information. The CS will revisit this on the next call. 

• Ash from Manure Burning (CBe): The lead summarized the changes made since the previous 

discussion, and the CS moved to a vote on this material. 
Motion to annotate ash from manure burning (§205.602, nonsynthetic substances prohibited for 

use in organic crop production) with the following annotation: “except where the combustion 

reaction does not involve the use of synthetic additives and is controlled to separate and preserve 

nutrients.”

Motion by: CBe

Seconded by: CBo

Additional Discussion: none

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

The motion failed, thus the Subcommittee supports retaining the existing prohibition of manure 

ash in organic crop production. 

• Contamination Issues in Farm Inputs (CBo/FT). The CS discussed this project in light of the public 

comment from the last meeting, and the path forward. The lead feels there are emerging issues with 

regard to this and the CS should continue to work on this issue. A member noted that commenters 

mentioned contamination issues related to irrigation water, but pointed out that water is not restricted 

by the regulations as are other inputs , so although the NOSB could address this elsewhere, it is not 

germane to this document. The lead reviewer will co-lead this with one of the new NOSB members and 

will present this to the CS in March. 

• Squid and Squid Byproducts (CBe). Deferred to Feb 2 call. Awaiting TR.

• Copper sulfate - 2018 sunset (ZS). The lead noted that this listing pertains to rice and control of tadpole 

shrimp and algae, and that it is used in a very specific and narrow range of conditions. She added that 

sodium carbonate peroxyhydrate was suggested as an alternative, but research found it was not 

successful. The CS will add a couple of questions for posting, hoping to glean comments from rice 

growers. The lead asked the NOP to add the link to the review of copper from last meeting. 

• Other items - none.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

December 15, 2015

Ozone gas (FT): Discuss 2018 sunset questions

Calcium Chloride (CBe): Discuss 2018 sunset questions

Ash from Manure Burning (CBe): Discuss petition

Hypochlorous Acid (HA): TR sufficiency

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR

1-methylcyclopropene (1-MCP): Assign lead

January 5, 2016

Calcium Chloride (CBe): Discuss 2018 sunset questions

Ash from Manure Burning (CBe): Discuss petition

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR?

Discuss Contamination Issues in Farm Inputs (CBo/FT)

Squid and Squid Byproducts (CBe): Discuss TR if available

Copper sulfate (ZS): Discuss 2018 sunset questions

January 19, 2016. (CBe & ZS may miss call due to conflict with hydroponics task force).

Squid and Squid Byproducts (CBe): Discuss TR if available

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR.

Soy Wax (FT): Discuss proposal

Paracetic Acid (HA): Discuss 2018 sunset questions & TR if available

Hypochlorous Acid - discuss proposal
February 2, 2016

EPA List 3 - Inerts of Unknown Toxicity (ZS) - Discuss 2018 sunset questions & TR if available

Biodegradable Biobased Mulch. Review public comment/memo/original

Squid and Squid Byproducts (CBe)

1-methylcyclopropene (1-MCP) (ZS/HA)

February 16, 2016 

March 1, 2016 

March 15, 2016

Contamination Issues in farm inputs

April 5, 2016 

April 19, 2016

May 3, 2016 

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 4, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment webinars ??

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday January 19, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Harold Austin (HA); Colehour Bondera 

(CBo); Harriet Behar (HB) - sitting in; Emily Oakley (EO) - sitting in; Scott Rice (SR) - sitting in; Tracy Favre 

(TF) - sitting in

Absent: Carmela Beck (CBe); Emily Brown Rosen (EBR)

Staff: Michelle Arsenault (MA), Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA Y Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16

Feb 2 TBD

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS to review

Proposal 

Spr 2016

Hypochlorous Acid 

205.605 and 

205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

TBD

Calcium Chloride 

annotation change

205.602

CBe Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16

Feb 2 TBD

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16

Feb 2 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

CBo/FT Report? Mar 15 TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

ZS DD? Feb 2 TBD

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved

Spr 2016

Newspaper -

annotation change

ZS Will write justification to send to ES and 

NOP.

TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of January 5

• Soy Wax (FT): Discuss proposal

• Peracetic Acid (HA): Discuss 2018 sunset questions & TR if available

• Hypochlorous Acid (HA): Discuss proposal

• Other items 

• Adjourn 

Discussion

• Crops Subcommittee notes of January 5 were approved with no changes.

• Soy Wax (FT). The CS discussed the draft proposal that was circulated to the members prior to the call. 

The members discussed the possible inclusion of an annotation: “must be made from non-GMO 

soybeans.” The lead noted that the petitioner has already addressed this in the petition i.e. that the soy 

wax is made with soy that was not genetically modified. Additionally, this restriction is implied in the 

organic regulations. Members discussed the need to add the language for emphasis, and chose to do 

so. 

Motion to classify Soy Wax as petitioned as synthetic

Motion by: FT

Seconded by: CBo

Additional Discussion: none

Yes: 4 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

Motion to add Soy Wax as petitioned at §205.601(o). As production aids. Soy wax (CAS # 8016-70-4) -

for use in log grown mushroom production. Must be made from non-GMO soybeans.

Motion by: FT

Seconded by: CBo
Additional Discussion: none

Yes: 4 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

• Peracetic Acid (HA). The group discussed the 2018 draft review while waiting for the TR, which is in 

development. The lead asked about a discrepancy in concentration amounts of peracetic acid (5% vs 

6%) between the previous NOSB review and the final rule. The NOP indicated that it was a result of 

comments received during the proposed rule stage. The CS will revisit this topic on the next call, at 

which time the Technical Report should be back. 

• Hypochlorous Acid (HA): The lead presented the material, its uses, and a brief summary of the previous 

public comment. Hypochlorous Acid (electrolyzed water) is used at an anti-microbial and is an 

alternative to several sanitizers, including chlorine. This material was petitioned for use for handling, 

crops and livestock, and all three Subcommittees are reviewing it. The lead noted that the Handling 

Subcommittee voted to add it to the National List. Additionally, the NOP issued a memo asking the 

NOSB to review this material and the process by which it is manufactured. The members discussed the 

sources and manufacturing process and are supportive of hypochlorous acid, as it reduces any potential

human health and environmental concerns. The group discussed adding an annotation limiting 

production of hypochlorous acid to on-site only. The CS will postpone the vote until members can 

review the petition further, and align its proposal with that of the Handling and Livestock 

Subcommittees. The NOP added that if the NOSB intends to allow hypochlorous acid for plant disease 

control that the CS should keep in mind that the National List includes separate paragraphs for for plant 

disease materials (§205.601(i)) and algicides/disinfectants/sanitizers (§205.601(a)). The NOP will 

consider the following before the next call and let the CS know: The need for an annotation; If an 

annotation is included could the CS then remove it at the Spring meeting without it being a substantive 

change; and the alignment of all 3 Subcommittee proposals. 

• Other items

The meeting was adjourned

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

January 5, 2016

Calcium Chloride (CBe): Discuss 2018 sunset questions

Ash from Manure Burning (CBe): Discuss petition

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR?

Discuss Contamination Issues in Farm Inputs (CBo/FT)

Squid and Squid Byproducts (CBe): Discuss TR if available

Copper sulfate (ZS): Discuss 2018 sunset questions

January 19, 2016. (CBe & ZS may miss call due to conflict with hydroponics task force).

Squid and Squid Byproducts (CBe): Discuss TR if available

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR.

Soy Wax (FT): Discuss proposal

Peracetic Acid (HA): Discuss 2018 sunset questions & TR if available

Hypochlorous Acid (HA) - discuss proposal

February 2, 2016

Peracetic Acid (HA) - Discuss 2018 sunset questions & TR if available

Hypochlorous Acid (HA) - Discuss proposal and vote

EPA List 3 - Inerts of Unknown Toxicity (ZS) - Discuss 2018 sunset questions & TR if available

Biodegradable Biobased Mulch (ZS) - Review public comment/memo/original

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR.
February 16, 2016 

March 1, 2016 

March 15, 2016

Contamination Issues in farm inputs

April 5, 2016 

April 19, 2016

May 3, 2016 

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 4, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment webinars ??

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday February 2, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Harold Austin (HA); Carmela Beck (CBe); 

(CBo); Harriet Behar (HB); Jesse Buie (JB); Emily Oakley (EO); Jean Richardson (JR) - sitting in; Scott Rice (SR)

- sitting in; Tracy Favre (TF) - sitting in

Absent: none

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA Y Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16

Feb 16 TBD

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS to review

Proposal 

Spr 2016

Hypochlorous Acid 

205.605 and 

205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16

Feb 16 TBD

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16

Feb 16 TBD

Fatty Alcohols 

(octanol/decanol 

mix)

? Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16

TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting
Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Mar 15 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

ZS DD? Feb 2, Feb 

23

TBD

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16 TR request sent to NOP 

Feb 5

Feb 2

Newspaper -

annotation change

ZS TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of January 19

• Welcome to our new members, brief introductions

• Discuss potential April 19 webinar/Subcommittee meeting rescheduling

• Sunset 2018 first postings

o Peracetic Acid (HA) - Discuss 2018 sunset questions & TR if available

o EPA List 3 - Inerts of Unknown Toxicity (ZS) - attached

• Hypochlorous Acid (HA) - Discuss proposal and vote

• Nonyl Phenol Ethoxylates (NPEs). Discussion document for spring meeting.

• Biodegradable Biobased Mulch (ZS) - Review history and proposal, vote will be Feb.23. 

• Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

• Squid and Squid Byproducts (CBe) - TR sufficiency

• 1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR (no document, just 

discussion)

• Update from Livestock subcommittee on status of Aluminum sulfate petition

• Marine Algae TR questions 

• Other items 

• Adjourn 

Discussion

• Crops Subcommittee notes of January 19 were approved with a minor clarification to the language

under the discussion of soy wax. Regarding the availability of non-GMO soy wax. HB will research 

availability further. 
• Introductions and welcome to new members. 

• Discuss potential April 19 webinar/Subcommittee meeting rescheduling. The group decided the best 

approach would be to leave the conference calls on Tuesday, April 19 and to hold the public comment 

webinar on either Monday or Wednesday, April 18 or 20. The NOP will schedule the webinar 

accordingly. 

• Marine algae and Marine materials (marine algae and extracts). The lead author indicated that there 

are nine materials on the National List that fall into this category. The Subcommittee is seeking 

clarification on the substances, and will include specific questions in the TR request. The HS will also 

focus on the broader areas of conservation and sustainability. The lead asked that members send 

comment to her and the HS chair by Friday, February 3.

• Sunset 2018 first postings

o Peracetic Acid (HA). The lead summarized the review, and based on the conversation in 

Subcommittee, will make suggested edits and recirculate the document. 

o EPA List 3 - Inerts of Unknown Toxicity (ZS). The lead author presented the draft document for 

the members and discussed several specific materials on the list, including pheromones. The CS 

Chair asked that the NOP add the citation for the Oct 2015 recommendation.

• Hypochlorous Acid (HA). Hypochlorous acid is a petitioned material also being reviewed by the LS and 

HS, and the lead authors have worked together to align the proposals. The lead summarized the 

manufacture and use of the material and noted that the end product is found to be safer than some 

alternatives, and there are no by-products. The group discussed the possible inclusion of language 

regarding pH but after some discussion decided that it was not necessary. They also discussed an 

annotation regarding the on-site manufacture of hypochlorous acid, which the lead will revise and add. 

The CS held the vote to classify hypochlorous acid and will defer the motion to add until the next call. 

Motion to classify hypochlorous acid as petitioned as synthetic

Motion by: HA

Seconded by: FT

Additional discussion: none

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

• Nonyl Phenol Ethoxylates (NPEs). The lead summarized the history and previous review of these 

substances and discussed information from the TR regarding safety, for the benefit of the new 

members. The NOSB is collaborating with the EPA Safer Choice Program (SCP) on the List 4 Inerts and 

will proceed with a discussion document, and eventually a proposal, to remove NPE's from organic 

products. The CS is putting forth the discussion document to allow manufacturers enough time to 

reformulate. 

Motion to accept the discussion document on NPEs

Motion by: ZS

Seconded by: HA 

Additional discussion: The NOP suggested adding Chemical Abstracts Service (CAS) numbers. A 

member asked for some clarifying language for ease of reading.

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

• Biodegradable Biobased Mulch (ZS). The lead author summarized the history of the petition, the 

subsequent NOSB proposal, and the NOP response to the NOSB recommendation. The NOP response 

memo (issued in January 2015) effectively rules out any products currently on the market from being 

used because no products qualify due to insufficient bio-based content. The group discussed several 

options for moving forward. The lead asked the members to review the documents so they can vote on 

the February 23 call. 
The remainder of the agenda items were deferred to the next call in the interest of time. 

• Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

• Squid and Squid Byproducts (CBe) - TR sufficiency

• 1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR (no document, just 

discussion)

• Update from Livestock Subcommittee on status of aluminum sulfate petition

• Other items 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

January 19, 2016. (CBe & ZS may miss call due to conflict with hydroponics task force).

Squid and Squid Byproducts (CBe): Discuss TR if available

Calcium Chloride annotation change (CBe): Petition sufficiency, need for TR.

Soy Wax (FT): Discuss proposal

Peracetic Acid (HA): Discuss 2018 sunset questions & TR if available

Hypochlorous Acid (HA) - discuss proposal

February 2, 2016

Peracetic Acid (HA) - Discuss 2018 sunset questions & TR if available

Hypochlorous Acid (HA) - Discuss proposal and vote

EPA List 3 - Inerts of Unknown Toxicity (ZS) - Discuss 2018 sunset questions & TR if available

Biodegradable Biobased Mulch (ZS) - Review public comment/memo/original

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR.

February 16, 2016 

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR (no document, just 

discussion)

Update from Livestock Subcommittee on status of aluminum sulfate petition

March 1, 2016 

March 15, 2016

Contamination Issues in farm inputs

April 5, 2016 

April 19, 2016

May 3, 2016 

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 
November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment webinars ??

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday February 16, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Harold Austin (HA); Carmela Beck (CBe); 

(CBo); Harriet Behar (HB); Jesse Buie (JB); Emily Oakley (EO); Jean Richardson (JR) - sitting in; Tracy Favre 

(TF) - sitting in

Absent: none

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA Y Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016

Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16. TR found sufficient 02 16 16

Feb 16,

Mar 1 

Spr 2016

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS review

Fall 2016

Hypochlorous Acid 

205.605, 205.603,

and 205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe N Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16. CS rejected 

petition based on the lack of new 

substantive info. 

Feb 16 NA

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16

Feb 16,

Mar 1

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16

Mar 1 Fall 2016

Inert Ingredients
Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Mar 15 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, Feb 

23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16 TR request sent to NOP 

Feb 5

Feb 2

Newspaper -

annotation change

ZS TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of February 2

• Hypochlorous acid (HA)

• Squid and Squid Byproducts (CBe) - TR sufficiency review

• Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR, completion date?

• Biodegradeable biobased mulch (ZS) timeline for completion 

• 1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR

• Aluminum sulfate petition update

• New Petition: Fatty Alcohols (octanol and decanol). 

• Upcoming work agenda items

• Adjourn 
Discussion

• Crops Subcommittee notes of February 2 were approved with no changes

• Hypochlorous acid (HA). The lead reviewed the proposal and noted that the HS removed the 

annotation from its proposal and re-voted. The CS will do the same so that all three proposals (HS, CS 

and LS) are aligned. The CS moved to a vote: 

Motion to add Hypochlorous acid as petitioned at §205.601(c)(a) (2)chlorine materials.....(iv)

Motion by: HA

Seconded by: EO 

Additional discussion: none

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

• Squid and squid byproducts (CBe). The TR was found sufficient. The lead summarized the material and 

its uses from the info in the petition and TR. The Crops subcommittee will proceed to a proposal for full 

Board consideration at the fall 2016 meeting. 

• Calcium chloride annotation change (CBe). The lead reviewer summarized the uses of calcium chloride. 

The petitioner is requesting removal of the annotation limiting use as a foliar spray for certain 

disorders. The CS compared the current petition to the previous petition for calcium chloride, and finds 

no new substantive information, therefore the Subcommittee is rejecting this proposal, and will not 

proceed with a review. 

• Biodegradable biobased mulch (ZS). The lead feels that in order to have the new members participate 

fully in this conversation, it would be best to defer this discussion and proposal until the fall 2016

meeting. HB will be the lead author. Members discussed the history of the proposal and subsequent 

NOP memo. 

• New Petition: Fatty Alcohols (octanol and decanol). JB volunteered to be the lead reviewer for this 

material. The first step is to determine petition sufficiency, and then decide whether or not to request a 

TR before moving to the proposal stage. Petition sufficiency and a request for a TR are due March 28.

• 1-methylcyclopropene (1-MCP) (ZS/HA). The CS Chair gave an overview of this substance, which is 

used to keep apples fresher in storage, and delays ripening after harvest. 1-MCP is synthetic and 

although the petition included confidential business information (CBI) the petitioners included the 

patent information.. The patent includes various manufacturing processes, all of which are clearly 

synthetic. The co-lead author noted that this material is used extensively in conventional apple storage, 

and that it does prevent rot/waste and extends the availability of stored fruit. The group discussed the 

appropriate section on the National List for this material, since it is a post-harvest use. The lead noted 

the lack of appropriate category of allowed synthetics in OFPA for this substance, a plant growth 

regulator. The members also discussed alpha-cyclodextrin, an additional substance mentioned in the

petition and will discuss this further on the next call. 

• Aluminum sulfate - Update from Livestock Subcommittee. Aluminum Sulfate will be on the agenda for 

the fall 201 6 meeting, and the LS is awaiting a TR for litter amendments.

• Upcoming work agenda items. The CS Chair asked that members submit ideas for new work agenda 

items so they can discuss them during the March 1 call so they can be discussed on the March 11 Exec 

call.

• Other items - none

• The meeting was adjourned

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

February 2, 2016

Peracetic Acid (HA) - Discuss 2018 sunset questions & TR if available

Hypochlorous Acid (HA) - Discuss proposal and vote
EPA List 3 - Inerts of Unknown Toxicity (ZS) - Discuss 2018 sunset questions & TR if available

Biodegradable Biobased Mulch (ZS) - Review public comment/memo/original

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR.

February 16, 2016 

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR 

Update from Livestock Subcommittee on status of aluminum sulfate petition

March 1, 2016

Discuss potential work agenda items

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR

Squid and Squid Byproducts (CBe)

Fatty Alcohols (octanol/decanol mix) - Petition sufficiency

March 15, 2016

Contamination Issues in farm inputs

April 5, 2016 

April 19, 2016

May 3, 2016 

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Public comment webinars Apr 18, 2016
Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday March 1, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Carmela Beck (CBe); 

(CBo); Jean Richardson (JR) - sitting in; 

Absent: Harriet Behar (HB); Jesse Buie (JB); Emily Oakley (EO); Harold Austin (HA)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA Y Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16. TR found sufficient 02 16 16

Feb 16,

Mar 1

Spr 2016

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS review

Fall 2016

Hypochlorous Acid 

205.605, 205.603,

and 205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe N Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16. CS rejected 

petition based on the lack of new 

substantive info. 

Feb 16 NA

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16

Feb 16,

Mar 15

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16

Mar 15 Fall 2016

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting
Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Mar 15 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16. TR request sent to NOP 

Feb 5

Feb 2

Newspaper -

annotation change

ZS TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of February 16

• Squid and Squid Byproducts (CBe). Discuss proposal/vote

• Discuss potential work agenda items

• 1-methylcyclopropene (1-MCP) (ZS/HA). Petition sufficiency, need for TR

• Fatty Alcohols (octanol/decanol mix). Petition sufficiency 

• Adjourn 

Discussion

• Approval of Crops Subcommittee notes of February 16 were deferred to next call due to lack of 

quorum.

• Squid and Squid Byproducts (CBe). The lead summarized the petition and the uses for this material. 

Members discussed the proposal via email prior to the call as well as during the call. One member had 

questions about whether or not squid required a separate listing or could be added to the current 

listing for liquid fish products. NOP suggested proposing it as a stand-alone item, then NOP will 

determine the best regulatory placement. A member expressed concerns about overfishing, although 

the TR indicates that this material is a byproduct and therefore its addition will not incentivize

overfishing. The members discussed the fact that the FDA definition lists squid as a “fish product” 

although squid are actually mollusks. For clarity, the Subcommittee feels squid should be identified 

separately. The CS opened the vote, and will hold it open until close-of-business Wednesday for email 

voting by absent members. ABS Note: the vote below reflects the votes from the entire Subcommittee, 

tallied after email voting closed.

Motion to classify squid & squid byproducts as synthetic 

Motion by: CBe 

Seconded by: ZS
Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0

Motion to list squid & squid byproducts at §205.601(j) of the National List with the following 

annotation: 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. 

Motion by: CBe 

Seconded by: ZS

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

• Work agenda items. The Crops Chair circulated a draft document suggesting a new work agenda topic: 

Strengthening the Organic Seed Guidance. The CS feels that the NOP guidance regarding commercial 

availability of organic seed issued in March 2013 needs strengthening. Crops would like to reevaluate 

the progress from the last 5 years, and will submit a request to the Executive Committee and then to 

the NOP to add it to its work agenda. The Chair will discuss this topic on the Executive call on March 

11. 

• 1-methylcyclopropene (1-MCP) (ZS/HA). Deferred to next call

• Fatty Alcohols (octanol/decanol mix). Deferred to next call

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

February 16, 2016 

Calcium Chloride annotation change (CBe) - Petition sufficiency, need for TR.

Squid and Squid Byproducts (CBe) - TR sufficiency

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR 

Update from Livestock Subcommittee on status of aluminum sulfate petition

March 1, 2016

Discuss potential work agenda items

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR

Squid and Squid Byproducts (CBe)

Fatty Alcohols (octanol/decanol mix) - Petition sufficiency

March 15, 2016

Approve notes from February 16 and March 1

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR

Fatty Alcohols (octanol/decanol mix) - Petition sufficiency

Contamination Issues in farm inputs

April 5, 2016 

April 19, 2016

May 3, 2016 

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 
November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 8, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 6, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday March 15, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Carmela Beck (CBe); 

(CBo); Jesse Buie (JB); Emily Oakley (EO); Harold Austin (HA); Harriet Behar (HB); Tracy Favre (TF) - sitting 

in; Jean Richardson (JR) - sitting in 

Absent: none

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16. TR found sufficient 02 16 16

Feb 16,

Mar 1

Spr 2016

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS review

Fall 2016

Hypochlorous Acid 

205.605, 205.603,

and 205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe N Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16. CS rejected 

petition based on the lack of new 

substantive info. 

Feb 16 NA

1-

methylcyclopropen

e (1-MCP). 205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR

Feb 16,

Mar 15

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

Mar 15 Fall 2016

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting
Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16 TR request sent to NOP 

Feb 5

Feb 2

Newspaper -

annotation change

ZS TBD

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of February 16 and March 1

• 1-methylcyclopropene (1-MCP) (ZS/HA). Petition sufficiency, need for TR

• Fatty Alcohols (octanol/decanol mix) (JB). Petition sufficiency 

• Contamination Issues in farm inputs (FT/HB)

• Squid follow up

• Peracetic acid - TR sufficiency

• Adjourn 

Discussion

• Crops Subcommittee notes of February 16 were approved with no changes.

• Crops Subcommittee notes of March 1 were approved with no changes.

• 1-methylcyclopropene (1-MCP) (ZS/HA). The CS discussed 1-MCP previously, and the lead summarized 

the material and its uses again for the group. 1-MCP is a plant growth regulator that works as an 

ethylene inhibitor. The petitioned use is post-harvest, where it prolongs storage and firmness. It is 

complexed with alpha cyclodextrin (claimed to be a natural sugar) for stabilization. The sugar is sourced 

from a fermentation process, however the patent indicates that it is synthetic but doesn’t talk about 

the fermentation process. The group discussed asking the petitioner for additional information

regarding classification, and the possibility of seeking a technical report (TR). The lead reviewer 

indicated that 1-MCP is a synthetic chemical and does not see a need for a TR, but the CS will seek 

further information and clarification from the petitioner regarding the fermentation process. The group 

also discussed the location on the National List for such a listing. One member note support of this 

material as it would benefit smaller growers. 

• Fatty Alcohols (octanol/decanol mix) (JB. Fatty alcohols are being petitioned for use as sucker control 

on organic crops. The CS found the petition sufficient and the CS Chair suggested a TR request since this 
is a new material. The group discussed the idea of reviewing the two materials (1-octanol and 1-

decanol) separately since it is a blend, although the EPA considers the blend, and not the individual 

materials, an active pesticide ingredient. The CS Chair will compile a list of questions for the TR 

including a request for information about each of the individual materials. 

• Contamination Issues in farm inputs (FT/HB). Deferred to April 5

• Squid & Squid byproducts proposal. The Chair asked for any follow-up questions or conversation, since 

some members missed the last meeting. One member asked for clarification whether squid can be 

considered a fish product(since an FDA definition includes molluscs as fish products) NOP clarified that 

the FDA definition as human food is not relevant for fertilizer use, and advised it will be better to 

specifically clarify whether stabilized squid products can be allowed as fertilizer. 

• Peracetic acid. The TR was found sufficient and the Chair will notify the NOP of this determination.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

March 1, 2016

Discuss potential work agenda items

1-methylcyclopropene (1-MCP) (ZS/HA) - Petition sufficiency, need for TR

Squid and Squid Byproducts (CBe)

Fatty Alcohols (octanol/decanol mix) - Petition sufficiency

March 15, 2016

1-methylcyclopropene (1-MCP) (ZS/HA). 

Fatty Alcohols (octanol/decanol mix). 

Contamination Issues in farm inputs

April 5, 2016

Contamination Issues in farm inputs (FT/HB)

April 18, 2016

Review comments

May 3, 2016 - cancelled

May 17, 2016

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016
NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 16, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 14, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 11, 2016

Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday April 5, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Carmela Beck (CBe); 

(CBo); Emily Oakley (EO); Harold Austin (HA); Tracy Favre (TF) - sitting in; Jean Richardson (JR) - sitting in; 

Harriet Behar - sitting in

Absent: Jesse Buie (JB)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16. TR found sufficient 02 16 16

Feb 16,

Mar 1

Spr 2016

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS review

Fall 2016

Hypochlorous Acid 

205.605, 205.603,

and 205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe N Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16. CS rejected 

petition based on the lack of new 

substantive info. 

Feb 16 NA

1-

methylcyclopropen

e (1-MCP). 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

Mar 15 Fall 2016

Ammonium 

Glycinate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids

TBD

Ammonium Citrate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015

TBD
Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16 TR request sent to NOP 

Feb 5

Feb 2 TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16 TBD?

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of March 15

• Assign lead for two new petitioned substances: Ammonium citrate and Ammonium glycinate 

• Update on 1-MCP new information from petitioner

• Contamination Issues in farm inputs (FT/HB)

• Adjourn 

Discussion

• Crops Subcommittee notes of March 15 were approved with no changes. 

• Two new petitioned substances: Ammonium citrate and Ammonium glycinate were submitted by the 

same petitioner. A member noted that the wording in both was nearly identically except for the

chemical name. Emily Oakley offered to take the lead for these reviews. The group will determine 
petition sufficiency and need for a TR on the May 17 call. The CS Chair clarified for the new members 

how to determine the need for a TR. 

• 1-MCP (ZS/HA). The CS received the additional information it requested from the petitioner regarding 

the fermentation process. The CS feels a TR is not necessary. The lead will write the proposal using the 

new materials’ review template form, and the Subcommittee will discuss it on May 17.

• Contamination Issues in farm inputs (FT/HB). The Co-leads summarized the draft document they 

circulated to the CS to review. The group discussed various components of the review such as 

categories, thresholds, testing and water/flooding. The members agreed that topics related to water 

and irrigation should be a separate work agenda item. The Crops Chair made some suggestions for next 

steps and asked that the leads develop some ideas for a workplan to be included in the document for 

discussion after the spring meeting. 

• Other items - none

• The meeting was adjourned. 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

March 15, 2016

1-methylcyclopropene (1-MCP) (ZS/HA). 

Fatty Alcohols (octanol/decanol mix). 

Contamination Issues in farm inputs

April 5, 2016

Contamination Issues in farm inputs (FT/HB)

April 18, 2016

Review comments and presentations for spring NOSB meeting.

May 3, 2016 - cancelled

May 17, 2016

Ammonium citrate and Ammonium glycinate. Petition suff/need for TR

1-MCP (ZS/HA). Discuss proposal

June 7, 2016 

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 16, 2016
Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 14, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 18, 2016

Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday April 18, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Carmela Beck (CBe); Harriet Behar (HB); Tracy Favre (TF) - sitting in; Jean Richardson (JR) -

sitting in; Tom Chapman (TC) - sitting in

Absent: Emily Brown Rosen (EBR)

Staff: Michelle Arsenault (MA), Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Discussed/

Reviewed

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jan 5 Spr 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Dec 15 Spr 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jan 19, Feb 2 Spr 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Feb 2 Spr 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jan 5 Spr 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Ash from Manure 

Burning

205.602(a)

CBe Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. To be 

revisited after fall 2015.

Jan 5 Spr 2016
Squid and Squid 

Byproducts

205.601

Petition 

amendment #1

CBe Y Petition sent to CS 05 12 15. Questions or 

request for TR due 07 14 15. HS requested 

TR 07 21 15. Petition amendment sent to 

CS 10 05 15. TR in development (expected 

Dec 2015), TR sent to CS 01 13 16. TR suff 

due 03 14 16. TR found sufficient 02 16 16

Feb 16,

Mar 1

Spr 2016

Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Waiting for 

LS review

Fall 2016

Hypochlorous Acid 

205.605, 205.603,

and 205.601

HA 2015 NOP Policy Memo 14-3: Electrolyzed Water 

(PDF)

Petition sent to HS 06 03 15. 

Response/request for TR due 08 03 15. TR 

request sent to NOP 07 21 15. TR sent to 

HS 08 13 15. TR suff due 10 13 15. TR suff 

discussion scheduled for 12 01 15 in HS

Jan 19,

Feb 2. Feb 

16

Spr 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested

Dec 1,

Jan 19

Spr 2016

Calcium Chloride 

annotation change

205.602

CBe N Petition sent to CS 11 02 15. Petition 

suff/TR Request due 01 04 16. CS rejected 

petition based on the lack of new 

substantive info. 

Feb 16 NA

1-

methylcyclopropen

e (1-MCP). 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

Mar 15 Fall 2016

Ammonium 

Glycinate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids

TBD

Ammonium Citrate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015

TBD
Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics”

TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD DD leading toward annotation change. NOP 

already approved work agenda item

Feb 2 Spr 2016

Marine materials 

(marine algae and 

extracts)

JR DD Pending NOP approval. NOP approved 

request 1-12-16 TR request sent to NOP 

Feb 5

Feb 2 TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16 TBD?

Research Priorities All NA RPs due to MS Aug 2016 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of April 5

• Review Public Comment & discuss presentations

• Preliminary discussion of research priorities.

• Adjourn 

Discussion

• Crops Subcommittee notes of April 5 approved with no changes. 

• Public comment

o Peracetic Acid (2018 sunset): The NOP clarified some information regarding uses of peracetic 

acid. The TR included information about FDA approved sanitizing solutions, a number of which 

contain peracetic acid and other chemicals. This does not impact the NOSB review, as they are 

reviewing peracetic as a single substance, and there is no restriction on manufacture or source.
o Hypochlorous acid: Commenters have raised concerns about sources, although the Board focus

is on electrolyzed water. The NOP supports the addition of “as petitioned” to the proposal to 

clarify. The CS discussed adding the phrase “hypochlorous acid from electrolyzed water as

petitioned.” The NOSB will discuss this at the meeting prior to voting. A member noted that 

according to Robert’s Rules the motion should be made, then amended, then voted upon. 

• Petitioned Items: 

o Squid and squid byproducts. A few commenters noted the language about squid byproducts, 

as opposed to squid and squid byproducts. The lead suggested changing the motion to remove 

the word squid and leave in only squid byproducts.

o Copper sulfate for rice. The petition was specifically for copper for rice. The NOSB received 

some comments from rice growers, but not much information regarding alternatives. Some 

comments discussed copper sulfate for other uses, which is not relevant to this review. 

o Nutrient Vitamins and Minerals (NVM). The Lead reached out to stakeholders to let them 

know that the Board is discussing the implementation timeline, and the CS will clarify the 

timeline at the NOSB meeting.

o Soy wax. The CS received two comments - both in support of listing soy wax. 

• Research priorities (RPs). The group had a brief discussion, and the CS Chair suggested that members

keep the Research Priorities in mind during the NOSB meeting to potentially identify future work 

agenda topics. The CS will review the previous lists to determine which ones are completed and/or still 

relevant. The new priorities will be summarized and shortened so the funding agencies find it more 

useful. 

• Other items. 

o Biodegradable Biobased mulch. The lead asked for some additional information about next 

steps for this topic. The CS Chair suggested reviewing the memo that NOP sent to Crops 

outlining three options for going forward. Members will discuss this further after the spring 

meeting. 

• The meeting was adjourned. 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

April 5, 2016

Contamination Issues in farm inputs (FT/HB)

April 18, 2016

Review comments and presentations for spring NOSB meeting.

May 3, 2016 - cancelled

May 17, 2016

Ammonium citrate and Ammonium glycinate. Petition suff/need for TR

1-MCP (ZS/HA). Discuss proposal

June 7, 2016

 Research Priorities

June 21, 2016

July 5, 2016 

July 19, 2016

August 2, 2016 

August 16, 2016 

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016
December 6, 2016 

December 20, 2016

Spring 2016 Milestones Target date

New NOSB member orientation Feb 29, 2016

NOP - Complete Spring 2016 NOSB meeting tentative agenda Feb 10, 2016

NOSB - Spring 2016 proposals due to NOP Feb 26, 2016

NOP - Post proposals, Publish FRN, Open public comment Mar 16, 2016

Discuss work agendas on ES call Mar 11, 2016

Public comment closes Apr 14, 2016

Work agendas finalized on ES call (last call before fall meeting) Apr 8, 2016

NOP - Send compiled public comments to NOSB Apr 18, 2016

Public comment webinars Apr 19, 2016

Spring 2016 NOSB meeting – Washington, DC Apr 25 - 27, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday May 17, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Carmela Beck (CBe); Harriet Behar (HB); Scott Rice (SR) - observer: Tracy Favre (TF) -

observer

Absent: none

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jun 7 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

205.601(m)

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jun 21 Fall 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting
Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jun 21 Fall 2016

1-

methylcyclopropen

e (1-MCP). 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jun 21

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

TBD TBD

Ammonium 

Glycinate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids

May 17 TBD

Ammonium Citrate

205.601

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015

May 17 TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP

May 17, Jun 

7, Jul 5

TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5, TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics” NOP sent memo 

to board 05 09 16requesting review.

TBD TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 1-12-16 TR request 

sent to NOP Feb 5.

Feb 2, TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16 TBD?

Hydroponics ZS Report due from Task Force ~June. DD or 

proposal? 

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of April 18

• Ammonium citrate and ammonium glycinate (EO). Petition suff/need for TR

• Anaerobic Digestate (ZS) - Petition sufficiency

• Work agenda scheduling

• Adjourn 

Discussion

• Crops Subcommittee notes of April 18 approved with no changes

• April 2016 meeting recap. A member suggested that based on previous discussion and public 

comment, the NOSB should undertake a comprehensive review of sanitizers. The Crops Chair 

recommended delaying this project until the new sunset reorganization proposal is approved, so they 

can determine which materials will be reviewed when. Members also expressed support that the 

Handling Subcommittee take the lead for this project, since most of the sanitizers are listed under 

handling. 

• Ammonium citrate and ammonium glycinate (EO). The lead noted that the two petitions are nearly 

identical, and both substances are being petitioned for use as chelating agents for fertilizers. The CS 

Chair asked if the petition included justification for why Ammonium citrate and Ammonium glycinate 

would be better/preferred over what is already on the list, such as lignin sulfonate. The lead noted that 

the petition did not include much information about why these are necessary. The group discussed 

whether or not to return the petition to the petitioner for justification, or whether to request a TR, and 

chose the former. The CS will include specific questions for the petitioner as to why the current 

chelating agents are not sufficient and will re-evaluate for sufficiency when it is returned. 
• Anaerobic digestate (ZS). Anaerobic digestate was previously petitioned (and subsequently 

withdrawn) but the new petition presents a different process and is asking for removal of the waiting 

period for manure-based anaerobic digestate (90-120 days). Currently the petition is still under review 

for eligibility. Members discussed the lack of information in the petition regarding nutrient content and 

fate and will discuss this further. Additionally, at a future date, they will consider the NOP memo on 

treated manure that was recently issued. With regard to the current petition on anaerobic digestate, 

the lead offered to develop questions for the petitioner.

• Work agenda scheduling. The Crops Subcommittee scheduled discussion times for work agenda items 

(see table above) and added a call on August 30 in case more time is needed.

• Biodegradable biobased mulch (HB). The group discussed the history of the NOSB recommendation for 

biodegradable biobased mulch, and the subsequent memo issued by the NOP. The lead noted that the 

NOSB recommendation took into consideration the biobased content amount, and the NOSB was 

aware that the product would not be 100% bio-based. A Subcommittee member feels that this 

component of the recommendation was misinterpreted by the NOP. A new NOSB member will be 

addressing this work agenda item, and was urged to review the background document that was 

circulated several months ago that included three options for moving forward. 

• Prohibition of NPEs in inerts annotation change. The proposed rule implementing the NOSB 2015 

recommendation on inerts is likely to be released in 2017, and since her term is ending in January 2017, 

the lead would like to transition this project to another NOSB member. Additionally, she asked for 

volunteers for the inerts working group to aid in transition at the end of both current members’ term. 

JB volunteered.

• Hydroponics Task Force report. The NOP indicated that the Task Force may complete its report to the 

Crops Subcommittee by mid-to-late June. Once Crops receives the report, the lead will develop a 

proposal. Going forth, the group will discuss options and conduct a straw poll to get a sense of the 

Subcommittee. 

• The CS added an extra call on August 30

• The meeting was adjourned. 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

April 18, 2016

Review comments and presentations for spring NOSB meeting.

May 3, 2016 - cancelled

May 17, 2016

Ammonium citrate and Ammonium glycinate (EO). Petition suff/need for TR

1-MCP (ZS/HA). Discuss proposal

June 7, 2016

 Research Priorities (All)

 Copper sulfate (ZS) - discuss and vote

EPA List 3 inerts (ZS) - discuss and vote

Anaerobic Digestate (ZS) - discuss

June 21, 2016

Ozone Gas (FT) - discuss and vote

Soy Wax (FT) - discuss and vote

Peracetic acid (HA) - discuss and vote

Calcium chloride (CBe) - discuss and vote

1-MCP (ZS/HA) - discuss and vote

July 5, 2016

Anaerobic Digestate (ZS) - discuss

July 19, 2016

Aluminum sulfate (JR)
Biodegradable Biobased Mulch (HB)

August 2, 2016

August 16, 2016 

August 30, 2016 additional call

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals, Publish FRN, Open public comment June/TBD 

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinars Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday June 7, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Carmela Beck (CBe); Harriet Behar (HB); Tracy Favre (TF) - observer; Lisa de Lima - observer; 

Tom Chapman (TC) - observer

Absent: none

Staff: Michelle Arsenault (MA), Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

a

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jun 21 Fall 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting
Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jun 21 Fall 2016

1-

methylcyclopropen

e (1-MCP). 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum sent to CS 06 13 16

May 17 TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum 

sent to CS 06 13 16

May 17 TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP

May 17,

Jul 5

TBD

Polyoxon D Zinc salt Petition sent to CS 06 16 16. Petition 

suff/TR Request due 08 16 16.

TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?
Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5, TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics” NOP sent memo 

to board 05 09 16requesting review.

TBD TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23, Jul 

19

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 1-12-16 TR request 

sent to NOP Feb 5.

Feb 2,

Aug 2

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16 Aug 2 TBD?

Hydroponics ZS Report due from Task Force ~June. DD or 

proposal? 

Jul 19 Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT Jun 21 Summary 

Spr 17
Chlorine dioxide

205.601(a)

FT Jun 21

Sodium 

hypochlorite 

205.601(a)

FT Jun 21

Herbicides, soapbased 205.601(b)

EO Jun 21

Biodegradable 

biobased mulch 

film 205.601(b)

HB Jun 21

Boric acid 

205.601(e)

HB Jun 21

Sticky 

traps/barriers 

205.601(e)

EO Jun 21

Copper sulfate 

205.601(i)

ZS Jun 21

Coppers, fixed

205.601(i)

ZS Jun 21

Humic acids 

205.601(j)

CBe Jun 21

Soluble boron 

products 

205.601(j)

ZS Jun 21

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS Jun 21

Vitamin B1 

205.601(j)

CBe Jun 21

Vitamin C 

205.601(j)

CBe Jun 21

Vitamin E 

205.601(j)

CBe Jun 21

Lead salts 

205.602(d)

FT Jun 21

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB Jun 21

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of May 17

• Work agenda discussions and scheduling 

• Research Priorities for Crops
• Assign sunset 2019 items to leads for determining TR requests 

• List 3 inerts (ZS) - discuss and vote 

• Adjourn 

Discussion

• Crops Subcommittee notes of May 17 were approved with a minor change under the biodegradable 

biobased mulch section.

• Work agenda discussions and scheduling.

o Hydroponics. The group discussed the timeline and how to structure the subsequent proposal. 

The hydroponics task force has asked for an extension to submit the report and would like to 

submit it July 1. Members discussed how to go forth in light of the timeline and feel that if they 

get the report by July 1, they would have time to develop a proposal for the fall meeting. The 

group discussed the path forward. 

o NOP Guidance on Seed and Planting Stock NOP 5029. The goal of this project is to provide a 

recommendation to strengthen and clarify the requirements for use of organic seed when 

commercially available. The Crops Subcommittee will submit a request to Executive team for a 

guest speaker and would like to invite the Director of Advocacy & Communications at the 

Organic Seed Alliance to speak at the fall meeting. 

• Research Priorities. The group discussed the items on the draft research priorities document that was 

circulated by the lead. Some items are still pertinent and critical, while others were determined to be 

too broad and in need of modification or clarification. The list will be re-prioritized and discussed

further on next call. The CS Chair asked that members bring any new topics to the next Crops call.

• 2019 Sunset Materials. Members volunteered to lead the 2019 sunset materials requests (see table 

above) and will determine the need for TRs on June 21.

• List 3 Inerts (ZS). The group discussed the draft proposal and proceeded to a vote. 

Motion to remove EPA List 3 -Inerts of unknown toxicity - for use only in passive pheromone 

dispensers, from 205.601(m)

Motion by: ZS

Seconded by: FT 

Additional discussion: none

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

• The meeting was adjourned. 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

May 17, 2016

Ammonium citrate and Ammonium glycinate (EO). Petition suff/need for TR

1-MCP (ZS/HA). Discuss proposal

June 7, 2016

 Research Priorities (All)

 EPA List 3 inerts (ZS) - discuss and vote

June 21, 2016

Sunset 2019 TR determinations

Soy Wax (FT) – petitioned material. Discuss and vote

2018 sunset: Ozone Gas (FT) - discuss and vote

2018 sunset: Peracetic acid (HA) - discuss and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote
July 5, 2016

1-MCP (ZS/HA) - discuss and vote

Anaerobic Digestate (ZS) - discuss

Hydroponics task force report - Preliminary discussion of report

July 19, 2016

Hydroponics task force report – Discussion report and proposal

Aluminum sulfate (JR)

Biodegradable Biobased Mulch (HB)

August 2, 2016

Marine materials (marine algae and extracts)

Newspaper annotation change

Strengthening seed guidance.

August 16, 2016 

August 30, 2016 additional call

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals, Publish FRN, Open public comment June/TBD 

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday June 21, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Harriet Behar (HB); Tracy Favre (TF) - observer; Lisa de Lima - observer; Ashely Swaffar (AS) - observer; Jean 

Richardson (JR) - observer.

Absent: Jesse Buie (JB); Carmela Beck (CBe)

Staff: Michelle Arsenault (MA), Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

a

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting
Aluminum sulfate JR Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5 Fall 2016

1-

methylcyclopropen

e (1-MCP). 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum sent to CS 06 13 16

May 17 TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum 

sent to CS 06 13 16

May 17 TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP

May 17,

Jul 5

TBD

Polyoxin D Zinc salt Petition sent to CS 06 16 16. Petition 

suff/TR Request due 08 16 16.

TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?
Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. Reqst for TR or White 

paper. TR rqst sent to NOP 10 06 15. 

Petition withdrawn 10 14 15. CS moved 

project to “other topics” NOP sent memo 

to board 05 09 16requesting review.

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23, Jul 

19

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16

Feb 2,

Aug 2

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16.

Aug 2? TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July.DD or 

proposal? 

Jul 19 Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17
Chlorine dioxide

205.601(a)

FT N Jun 21

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21

Herbicides, soapbased 205.601(b)

EO N Jun 21

Biodegradable

biobased mulch 

film 205.601(b)

HB Y Jun 21

Boric acid 

205.601(e)

HB N Jun 21

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21

Copper sulfate 

205.601(i)

ZS N Jun 21

Coppers, fixed

205.601(i)

ZS N Jun 21

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21

Soluble boron 

products 

205.601(j)

ZS N Jun 21

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21

Vitamin B1 

205.601(j)

CBe N Jun 21

Vitamin C 

205.601(j)

CBe N Jun 21

Vitamin E 

205.601(j)

CBe N Jun 21

Lead salts 

205.602(d)

FT N Jun 21

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of June 7

• Sunset 2019 TR determinations

• Research Priorities - Continue prioritization and be prepared with any additional ones. 
• Soy Wax (FT) - petitioned material. Discuss and vote

• 2018 sunset: Ozone Gas (FT) - discuss and vote

• 2018 sunset: Peracetic acid (HA) - discuss and vote

• 2018 sunset: Calcium chloride (CBe) - discuss and vote

• 2018 sunset: Copper sulfate (ZS) - discuss and vote

• Adjourn 

Discussion

• Crops Subcommittee notes of June 7 were approved with no changes

• Sunset 2019 TR determinations. The group discussed the need for TRs for the 2019 sunset materials. 

See table above and discussion below

o Biodegradable mulch (HB). Members supported the need for a limited scope TR with targeted 

questions. The lead asked for feedback from the members and will report back on a future call. 

o Boric acid (HB). Although the TR is old, the lead feels that a new TR would have limited 

usefulness.

o Sticky traps/barriers. The TAP review is from 1995, however, the group agreed this is a 

relatively benign material and a TR is not needed. 

o Copper sulfate, Coppers, fixed (ZS). These materials are included in the Research Priorities, 

and therefore the group feels a TR is not needed.

o Humic acids (CBe). There is a 1996 TAP and a 2006 TR on file, as well as a 2012 TR for oxidized 

lignite, which addressed other humic acid derivatives. The lead noted, via the CS Chair, that a 

TR likely would not provide new information, however, it could provide updated information 

regarding international regulations and potential environmental contamination from 

manufacture, use, misuse or disposal, if applicable. The CS will not request a new TR. The NOP 

will cross-reference the oxidized lignite TR on the Petitioned Substance Database.

o Lead salts are currently prohibited and the lead feels no TR is necessary.

o Tobacco dust is currently prohibited and the lead feels no TR is necessary.

• Research Priorities. The members discussed the list of research priorities and will continue to prioritize 

the existing ones and discuss any additional topics. In an effort to make the list more concise, the items 

will be divided into two groups: higher priority and lower priority. The group also discussed the criteria 

for determining what belongs on the research priorities list. 

• Soy Wax (FT). The CS briefly discussed the draft proposal and will discuss it further and potentially vote 

on the next call. 

• 2018 sunset: Ozone Gas (FT). The lead briefly summarized ozone, which is currently allowed as an 

irrigation system cleaner; the substance was unanimously relisted twice before. 

Motion to remove ozone gas from the National List at §205.601(a)

Motion by: FT

Seconded by: HA 

Additional discussion: none

Yes: 0 No: 4 Abstain: 1 Absent: 2 Recuse: 0

• 2018 sunset: Peracetic acid (HA). The lead summarized the material and its uses, and noted a 2011 

recommendation to annotate as well as a recently received TR. The CS proceeded to a vote. The lead 

author will forward the proposal to the CS Chair for submission to the NOP. 

Motion to remove peracetic acid from the National List at §205.604(a) and 205.604(i)

Motion by: HA

Seconded by: EO 

Additional discussion: none

Yes: 0 No: 5 Abstain: 0 Absent: 2 Recuse: 0 
• The Chair informed the members that the Hydroponics Task Force was granted an extension to submit 

its report. The final report will be due to the Crops Subcommittee in mid-July, therefore the 

Subcommittee discussion will be moved to the July 19 call. 

• 2018 sunset: Calcium chloride (CBe). Deferred to next call

• 2018 sunset: Copper sulfate (ZS). Deferred to next call

• The meeting was adjourned. 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

June 7, 2016

 Research Priorities (All)

 EPA List 3 inerts (ZS) - discuss and vote

June 21, 2016

Sunset 2019 TR determinations

Soy Wax (FT) - petitioned material. Discuss and vote

2018 sunset: Ozone Gas (FT) - discuss and vote

2018 sunset: Peracetic acid (HA) - discuss and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote

July 5, 2016

Soy Wax (FT) - discuss proposal and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote

1-MCP (ZS/HA) - discuss and vote

Anaerobic Digestate (ZS) - discuss

Hydroponics task force report - preliminary discussion of report

Polyoxin D Zinc salt - assign lead

July 19, 2016

Research Priorities - Discuss and approve list

Hydroponics task force report - Discuss report and proposal

Aluminum sulfate (JR) - Discuss proposal

Biodegradable Biobased Mulch (HB) - Discuss draft discussion document

August 2, 2016

Marine materials (marine algae and extracts) - TR in development

Newspaper annotation change. Waiting for TR 

Strengthening seed guidance - Discuss draft discussion document

August 16, 2016 

August 30, 2016 additional call

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

2:00
Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June/TBD

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals On or before Sept 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday July 5, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Harriet Behar (HB); Jesse Buie (JB); Carmela Beck (CBe); Tracy Favre (TF) - observer; Lisa de Lima - observer; 

Jean Richardson (JR) - observer

Absent: Devon Pattillo (DP)

Staff: Michelle Arsenault (MA); Jessica Walden (JW)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting
Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5 Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum sent to CS 06 13 16. Petition 

found sufficient 07 05 16.

May 17, 

July 5

TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum 

sent to CS 06 13 16. Petition found 

sufficient 07 05 16.

May 17, 

July 5

TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD

Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR Request due 08 16 16.

Aug 2 TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO Petition sent to CS 06 28 16. Petition 

suff/TR Request due 08 30 16.

Jul 19 TBD

Inert Ingredients
Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report? Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Feb 2, 

Feb 23, Jul 

19

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16

Feb 2,

Aug 2

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16.

Aug 2? TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July.DD or 

proposal? 

Jul 19 Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017
Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21

Herbicides, soapbased 205.601(b)

EO N Jun 21

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21

Boric acid 

205.601(e)

HB N Jun 21

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21

Copper sulfate 

205.601(i)

ZS N Jun 21

Coppers, fixed

205.601(i)

ZS N Jun 21

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21

Soluble boron 

products 

205.601(j)

ZS N Jun 21

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21

Vitamin B1 

205.601(j)

CBe N Jun 21

Vitamin C 

205.601(j)

CBe N Jun 21

Vitamin E 

205.601(j)

CBe N Jun 21

Lead salts 

205.602(d)

FT N Jun 21
Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of June 21 

• Research Priorities

• Biodegradable Biobased mulch (HB)

• Potassium cellulose glycolate (Potassium CMC) petition - assign lead

• Polyoxin D Zinc salt - assign lead 

• Ammonium citrate and ammonium glycinate (EO) - schedule petition supplement sufficiency

• Anaerobic Digestate (ZS). 

• Soy Wax (FT) - discuss and vote

• 2018 sunset: Calcium chloride (CBe) - discuss and vote.

• 2018 sunset: Copper sulfate (ZS) - discuss and vote.

• 1-MCP (ZS/HA).

• Adjourn.

Discussion

• Crops Subcommittee notes of June 21 were approved with no changes

• Research Priorities. The group discussed the research priorities draft document, specifically the 

biodegradable biobased mulch topic.

• Biodegradable biobased mulch (HB). The members briefly discussed the research priority topic on

Biodegradable biobased mulch. The CS Chair suggested composing targeted questions for a limited 

scope TR request, which will be submitted to the NOP after the next Crops call. 

• Potassium cellulose glycolate (Potassium CMC) petition. EO volunteered to be the lead reviewer for 

this material. Potassium cellulose glycolate is used in conjunction with fertilizers as a water absorbing 

agent. There was some question among the Subcommittee members as to its use in crop production. 

Members will discuss petition sufficiency on the next call. 

• Polyoxin D Zinc salt. Re-petitioned material. JB volunteered to lead this, with assistance from HA who 

was the previous lead. The CS will discuss petition sufficiency on the August 2 call.

• Ammonium citrate and ammonium glycinate (EO). The lead provided some background information

regarding the definition of chelate vs. chelating agents and the group discussed necessity and 

alternatives. The petitions were found sufficient and the group will move to a discussion and vote on 

the August 2 call. 

• Anaerobic Digestate (ZS). The lead summarized the draft document and the members discussed the 

potential questions to include in the TR request. The TR request will be sent to the NOP

• Soy Wax (FT). The members discussed language for the proposal regarding non-GMO soybeans and 

commercial availability. A member noted that the clause regarding (excluded methods?) does not apply 

to §205.601, so it would be helpful to be explicit here. FT will add some language and resend it to the 

group for review.

Motion to classify soy wax as petitioned as synthetic

Motion by: FT

Seconded by: HA

Additional discussion: none

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

Motion to add soy wax at §205.601(o) as production aids. Soy wax (CAS # 8016-70-4) - for use in log 
grown mushroom production. Must be made from non-GMO soybeans if soy wax from organic 

soybeans is not commercially available.

Motion by: FT

Seconded by: EO

Additional discussion: none

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

• 2018 sunset: Calcium chloride (CBe). Calcium chloride is a non-synthetic substance prohibited for use 

in organic crop production. There is no new information and while there was not much public comment

during the first posting in Spring 2016, commenters were in favor of its continued prohibition.

Motion to remove calcium chloride at §205.602 

Motion by: CBe

Seconded by: HA 

Additional discussion: A member noted that this material is used extensively on apples and cherries 

in the Pacific Northwest. Another member noted that she uses it extensively in California on 

heirloom varieties of apples. . 

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

• 2018 sunset: Copper sulfate (ZS). Copper sulfate is used for two different orders of pests. The lead 

noted that while it is a common material, it is arcane, and the pests are not common. 

Copper is on the Crops list of research priorities, and there is new research on alternatives.

Motion to remove copper sulfate from §205.601(i) based on OFPA criteria of essentiality

Motion by: ZS

Seconded by: HA 

Additional discussion: none

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

• 1-MCP (ZS/HA). Used to slow ripening and retard spoilage in post-harvest storage. The lead indicated 

that 1-MCP does not satisfy criteria 3: compatibility and alternatives. Although there is no direct 

material that is an alternative, there are broader alternative practices, and therefore feels this material 

is not necessary. The lead added that it is synthetic, and not exempt from having to be listed for postharvest use. Another member added that it is used in conventional products, and although it’s used 

post-harvest, there is no detectable residue. 

Motion to classify 1-MCP as petitioned as synthetic 

Motion by: ZS

Seconded by: EO

Additional discussion: none

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

Motion to add 1-MCP as petitioned at §205.601

Motion by: ZS

Seconded by: HA

Additional discussion: none

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

• The meeting was adjourned 
Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

June 21, 2016

Sunset 2019 TR determinations

Soy Wax (FT) - petitioned material. Discuss and vote

2018 sunset: Ozone Gas (FT) - discuss and vote

2018 sunset: Peracetic acid (HA) - discuss and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote

July 5, 2016

Soy Wax (FT) - discuss proposal and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote

1-MCP (ZS/HA) - discuss and vote

Anaerobic Digestate (ZS) - discuss

Hydroponics task force report - preliminary discussion of report – deferred. No report available

Polyoxin D Zinc salt - assign lead

July 19, 2016

Hydroponics task force report - Discuss report and proposal

Aluminum sulfate (FT) - Discuss proposal

Biodegradable Biobased Mulch (HB) - Discuss draft discussion document and TR questions

Potassium cellulose glycolate (EO) - Petition sufficiency.

August 2, 2016

Marine materials (marine algae and extracts) - TR in development

Newspaper annotation change. Waiting for TR 

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D Zinc salt. Petition sufficiency

Ammonium citrate and glycinate (EO) - Petition sufficiency.

August 16, 2016 

August 30, 2016 additional call

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June/TBD

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals On or before Sept 27, 2016

Discuss work agendas on ES call Oct 14, 2016
Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday July 19, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Harriet Behar (HB); Jean Richardson (JR) - observer

Absent: Carmela Beck (CBe)

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016

Petitioned Substances
Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5 Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum sent to CS 06 13 16. Petition 

found sufficient 07 05 16.

May 17, 

July 5

TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum 

sent to CS 06 13 16. Petition found 

sufficient 07 05 16.

May 17, 

July 5

TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD

Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR Request due 08 16 16.

Aug 2 TBD
Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO Petition sent to CS 06 28 16. Petition 

suff/TR Request due 08 30 16.

Jul 19, 

Aug 16

TBD

Allyl Isothiocyanate 

(AITC) Petition 

(2016)

JB Petition sent to CS 07 06 16. Petition 

suff/TR Request due 09 06 16.

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

TBD TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request will be sent to 

NOP in late July

Feb 2, 

Feb 23, Jul 

19

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16

Feb 2,

Aug 2

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

Aug 2? TBD
Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July. DD or 

proposal? 

Aug 2 Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21

Herbicides, soapbased 205.601(b)

EO N Jun 21

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21

Boric acid 

205.601(e)

HB N Jun 21

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21

Copper sulfate 

205.601(i)

ZS N Jun 21

Coppers, fixed

205.601(i)

ZS N Jun 21

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21

Soluble boron 

products 

205.601(j)

ZS N Jun 21
Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21

Vitamin B1 

205.601(j)

CBe N Jun 21

Vitamin C 

205.601(j)

CBe N Jun 21

Vitamin E 

205.601(j)

CBe N Jun 21

Lead salts 

205.602(d)

FT N Jun 21

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of July 5

• Aluminum sulfate (FT) - Discuss proposal

• Biodegradable Biobased Mulch (HB) - Discuss draft discussion document and TR questions

• Potassium cellulose glycolate (EO) - Petition sufficiency

• Hydroponics task force report - Discuss report and proposal

• Allyl Isothiocyanate (AITC) Petition - Assign lead

• Check-in on future call schedule topics

• Adjourn

Discussion

• Crops Subcommittee notes of July 5 were approved with minor changes under Biodegradable Biobased 

Mulch. 

• Aluminum sulfate (FT). The lead circulated a draft document and noted that the Livestock 

Subcommittee (LS) also reviewed this material and voted to not add it. In livestock, aluminum sulfate is 

used as a poultry litter amendment used to reduce ammonia. The LS found there was a non-synthetic 

alternative. For crops, aluminum sulfate has been petitioned to allow application of manure that has 

been treated with aluminum sulfate. Members discussed the role of the substance in mitigating soil 

phosphorous levels, as described by the petition. The CS proceeded to a vote.

Motion to classify aluminum sulfate as petitioned as synthetic 

Motion by: FT

Seconded by: HB 

Additional discussion: 

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

Motion to add aluminum sulfate as petitioned at §205.601.

Motion by: FT

Seconded by: HB
Additional discussion: 

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

• Biodegradable biobased mulch (HB). The group discussed the difference between the document that 

was written for the Research Priorities and the limited scope TR request. Members discussed a draft list 

of questions for the TR and will recirculate these via email before submitting the request to the NOP.

• Potassium cellulose glycolate (EO). The lead summarized the material’s manufacture and use. The CS 

found the petition sufficient and determined a TR is unnecessary. The lead will draft a proposal for 

discussion on the August 16 call. Potassium cellulose glycolate is used for water retention, and the 

petitioner noted benefits of recovering and conserving dripped water. 

• Hydroponics Task Force report has not been received by the Crops Subcommittee. The CS noted that 

time will be limited to develop a proposal by the fall meeting. CS will consider how to proceed once 

they receive the report.

• Allyl isothiocyanate (AITC) petition (2016). JB volunteered to be lead author on this substance. Allyl 

isothiocyanate (AITC) was originally petitioned as a fumigant in 2013 and was subsequently withdrawn 

by the petitioner. This substance is a synthetic version of mustard seed meal, and it is being petitioned 

for use as a nematicide and fungicide. A member asked about the use of a synthetic in light of the fact 

that a natural nonsynthetic alternative exists. The petitioner has claimed there is an inadequate supply 

of the nonsynthetic form. 

• Future call schedule. 

o Contamination issues in farm inputs. Postponed to a future meeting.

o The CS has requested to have a speaker from the Seed Alliance at the fall NOSB meeting and is 

awaiting NOP approval. 

o Inerts update at fall meeting. The Chair asked for an update from the Inerts working group

ingredients (National List) and whether NOP or a member of the Safer Choice program (SCIL) 

could deliver an update at the fall meeting. The NOP will discuss this and report back to the CS 

Chair. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

July 5, 2016

Soy Wax (FT) - discuss proposal and vote

2018 sunset: Calcium chloride (CBe) - discuss and vote

2018 sunset: Copper sulfate (ZS) - discuss and vote

1-MCP (ZS/HA) - discuss and vote

Anaerobic Digestate (ZS) - discuss

Hydroponics task force report - preliminary discussion of report – deferred. No report available

Polyoxin D Zinc salt - assign lead

July 19, 2016

Aluminum sulfate (FT) - Discuss proposal

Biodegradable Biobased Mulch (HB) - Discuss draft discussion document and TR questions

Potassium cellulose glycolate (EO) - Petition sufficiency.

Allyl Isothiocyanate (AITC) Petition (2016) - assign lead?

August 2, 2016

Hydroponics task force report - Discuss report and proposal

Marine materials (marine algae and extracts) - TR in development

Newspaper annotation change - TR in development

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D Zinc salt - Petition sufficiency

Ammonium citrate and glycinate (EO) - Petition sufficiency.
August 16, 2016 

Potassium cellulose glycolate (EO) - discuss proposal

August 30, 2016 additional call

September 6, 2016 

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment June/TBD

NOP - Complete fall 2016 NOSB meeting tentative agenda Sept 8, 2016

NOSB - Fall 2016 proposals due to NOP Sept 14, 2016

NOP - Post proposals On or before Sept 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday August 2, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Harriet Behar (HB); Carmela Beck (CBe); Jean Richardson (JR) - observer; Tracy Favre (TF) -

observer

Absent: none

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance ContactTR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD
Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16.

Aug 2,

Aug 16

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16.

Jul 19, 

Aug 16

TBD

Allyl Isothiocyanate 

(AITC) Petition 

(2016)

JB Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16.

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

TBD TBD

Sodium Citrate, 

2016 

HB Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16.

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Inert Ingredients

Substance ContactTR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Fall 2016

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD
Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16

Feb 2,

Sep 6

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July. DD or 

proposal? 

Aug 16 Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2,

Aug 16

Fall 2016

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21

Herbicides, soapbased 205.601(b)EO N Jun 21

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21

Boric acid 

205.601(e)

HB N Jun 21

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21

Copper sulfate 

205.601(i)

ZS N Jun 21

Coppers, fixed

205.601(i)

ZS N Jun 21

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21
Soluble boron 

products 

205.601(j)

ZS N Jun 21

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21

Vitamin B1 

205.601(j)

CBe N Jun 21

Vitamin C 

205.601(j)

CBe N Jun 21

Vitamin E 

205.601(j)

CBe N Jun 21

Lead salts 

205.602(d)

FT N Jun 21

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of July 19

• Revisit Soy Wax Annotation:

• Polyoxin D Zinc salt (JB) - Petition sufficiency

• Ammonium citrate and glycinate (EO) - discuss issues, please read addition to petition

• New Petition for Sodium citrate (email from Lisa B. on July 27) - assign lead and schedule

• Strengthening Organic Seed Guidance (ZS) - draft will be sent by end of weekend.

• Adjourn

Discussion

• Crops Subcommittee notes of July 19 approved with one correction to the vote for aluminum sulfate.

• Soy Wax Annotation (FT). The NOP suggested that the CS find an alternative to the term “non-GMO” in 

the proposed annotation. The lead suggested new language, and the group proceeded to a vote to 

amend the language. 

Motion to amend the annotation for soy wax as follows: Must be made from soybeans grown without 

the use of excluded methods if soy wax from organic soybeans is not commercially available.

Motion by: FT

Seconded by: HA

Additional discussion: none

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

• Polyoxin D Zinc salt (JB). Petition sufficiency deferred to next call. 
• Ammonium citrate and glycinate (EO). The lead summarized the substances based on the information 

provided in the petition, and the unsolicited addendum sent by the petitioner. The petitioner feels that 

the definition on the National List (NL) for chelating agents is incorrect. A member noted that the 

definition is in the materials guidance and not on the NL. The members discussed the chemistry of 

chelating agents and the role of acids and bases. The NOP acknowledged that the substances could be

incorporated into the existing listing for micronutrients on the NL rather than under their own and 

separate listings. The lead will continue to work on the proposal, with assistance from other 

Subcommittee members and the CS will discuss it on the next call.

• Sodium citrate petition. Members discussed the uses indicated in the petition. HB volunteered to lead 

this project, and will discuss petition sufficiency on a future call, 

• Strengthening Organic Seed Guidance discussion document (ZS). The lead forwarded a link to the 

latest Organic Seed Alliance seed guidance document to the group, as well as the draft discussion 

document, and asked for feedback. She noted that the questions for the discussion document are not 

flushed out yet and asked for suggestions. The Subcommittee will discuss it further on the next call. 

• Additional items. The current CS Chair noted that after the fall meeting, the Subcommittee Chairs will 

be rotating off, and suggested that people consider taking on that role. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

July 19, 2016

Aluminum sulfate (FT) - Discuss proposal

Biodegradable Biobased Mulch (HB) - Discuss draft discussion document and TR questions

Potassium cellulose glycolate (EO) - Petition sufficiency.

Allyl Isothiocyanate (AITC) Petition (2016) - assign lead?

August 2, 2016

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D Zinc salt - Petition sufficiency

Ammonium citrate and glycinate (EO) - Discuss petition & addendum

August 16, 2016 

Polyoxin D Zinc salt - Petition sufficiency

Hydroponics task force report - Discuss report and proposal

Potassium cellulose glycolate (EO) - discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

August 30, 2016 additional call

September 6, 2016

Sodium citrate (HB) Petition sufficiency

Marine materials (marine algae and extracts) - TR in development

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016 - cancelled

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016
NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday August 16, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Harriet Behar (HB); Carmela Beck (CBe); Jean Richardson (JR) - observer; Scott Rice (SR) -

observer, Lisa de Lima (LD - observer, Ashley Swaffar (AS) - observer; Dan Seitz (DS) - observer

Absent: none

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance ContactTR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

Aug 30

TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

Aug 30

TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD
Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

lmt’d scope TR

Aug 2,

Aug 16

Aug 30

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request

Jul 19,

Aug 30

TBD

Allyl Isothiocyanate 

(AITC) Petition 

(2016)

JB Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16.

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

TBD TBD

Sodium Citrate, 

2016 

HB Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16.

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Inert Ingredients

Substance ContactTR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Fall 2016
Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16. TR suff due 10 11 16

Feb 2,

Sep 6

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July. DD or 

proposal?

Aug 16

Aug 30

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2,

Aug 30

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “
Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of August 2

• Polyoxin D zinc salt - Petition sufficiency

• Hydroponics task force report - Discuss report and proposal

• Potassium cellulose glycolate (EO) - Discuss proposal

• Ammonium citrate and glycinate (EO) - Discuss proposal

• Strengthening the Organic Seed Guidance 

• Adjourn

Discussion

• Crops Subcommittee notes of August 2 were approved with no changes.

• Polyoxin D zinc salt. The lead summarized the petition and uses of Polyoxin D zinc salt. The group 

discussed the difference between the current petition and the 2012 petition for the same material. The 

new petition requests a different use pattern than the original, and there is new data in the new 

petition, including a response to 17 points from the previous review. The petition was found sufficient

and the group discussed the potential need for a limited scope TR to answer some lingering questions. 

A member noted that in addition to the 2012 TR, there were two petition addendums that could 

answer some of the questions. For the sake of the new NOSB members, the Chair reminded the group 

that because this is a re-petitioned substance, it is given lower priority, and does not have to be 
completed immediately. The lead reviewer will write a list of questions for a limited scope TR for 

discussion on next call. 

• Hydroponics task force report. The lead summarized the Task Force report and the subsequent draft 

documents she prepared. Due to the complexity of the topic and the report, the lead author proposed 

a multi-part document: One part addressing the core issues of how bioponics (liquid based culture 

methods) fits into OFPA and the current USDA Regulations; one part (a discussion document) on 

container systems and methods; and one part on which bioponic systems satisfy the rule and which do 

not. A key issue is whether the current Board agrees with the 2010 NOSB recommendation that found 

that “... systems of crop production that eliminate soil from the system, such as hydroponics or 

aeroponics, cannot be considered as examples of acceptable organic farming practices.”

Members discussed the draft document and made modifications to some of the language, including the 

motion. The Crops Subcommittee feels that due to the complex nature of the report and the topic, this 

may not be concluded at the fall meeting. The lead asked for feedback (via email) about the 

definitions, and noted that the section on “gaps and grey areas” needs to be flushed out. The group 

discussed the path forward and discussed the merits of bringing forth a proposal(s) versus discussion 

documents. Several members noted that a discussion document would allow them to glean more 

comments from stakeholders before the NOSB had to vote on the document. The CS discussed the 

option of bringing the proposal back to Subcommittee at the fall meeting, if public comment and 

discussion indicates that it is not ready for a vote. 

• Potassium cellulose glycolate (EO) - deferred to next call.

• Ammonium citrate and glycinate (EO) - deferred to next call.

• Strengthening the organic seed guidance - deferred to next call

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

August 2, 2016

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D Zinc salt - Petition sufficiency

Ammonium citrate and glycinate (EO) - Discuss petition & addendum

August 16, 2016 

Polyoxin D Zinc salt - Petition sufficiency

Hydroponics task force report - Discuss report and proposal

Potassium cellulose glycolate (EO) - Discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

August 30, 2016 additional call

 Hydroponics task force report - Discuss proposal/discussion doc

Potassium cellulose glycolate (EO) - Discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D. Discuss questions for potential Lmtd scope TR request

September 6, 2016

Sodium citrate (HB) - Petition sufficiency

Marine materials (marine algae and extracts) - TR in development

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016 - cancelled (NOSB meeting)

December 6, 2016 
December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday August 30, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Jesse Buie (JB); 

Harriet Behar (HB); Carmela Beck (CBe); Jean Richardson (JR) - observer; Dan Seitz (DS) - observer

Absent: Michelle Arsenault (MA); Harold Austin (HA

Staff: Devon Pattillo (DP); Jessica Walden (JW)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

Sep 6

TBD

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16.

May 17, 

July 5, 

Aug 2

Sep 6

TBD

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD
Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

lmt’d scope TR

Aug 2,

Aug 16

Aug 30

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request

Jul 19,

Aug 30

TBD

Allyl Isothiocyanate 

(AITC) Petition 

(2016)

JB Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16.

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

TBD TBD

Sodium Citrate, 

2016 

HB Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16.

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Fall 2016
Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16. TR suff due 10 11 16

Feb 2,

Sep 6

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July. Discussion 

Document

Aug 30

Sep 6

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2,

Sep 6

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)

EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “
Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of August 16

• Hydroponics task force report: Discuss proposal/discussion doc

• Potassium cellulose glycolate (EO): Discuss proposal

• Ammonium citrate and glycinate (EO): Discuss proposal

• Strengthening seed guidance: Discuss draft discussion document

• Polyoxin D: Discuss questions for potential limited scope TR request

• Adjourn

Discussion

• Crops Subcommittee notes of August 16 were approved with a couple minor grammatical changes.

• Hydroponics task force report. Since the last meeting, members participated in a poll and voted on 

whether hydroponics are compatible with the organic regulation. The subcommittee discussed the 

results of that poll and the lead summarized the incorporated changes since the last call to the draft 

document she prepared. Due to the complexity of the topic and the report, the lead author proposed a 

multi-part document: One part addressing the core issues of how bioponics (liquid based culture 

methods) fits into OFPA and the current USDA Regulations; one part (a discussion document) on 

container systems and methods; and one part on which bioponic systems satisfy the rule and which do 

not. Members discussed the draft document and made modifications to some of the language, 

including grammatical corrections, the 2010 NOSB recommendation, and the definition of hydroponics. 
Discussion was also had on bioponic systems, growing media, and how nutrients are delivered to the 

plant. The lead indicated that the Canadians are also working on this issue as well. The idea to invite 

someone from Canada as an expert to discuss at a future meetings was discussed. This document will 

be finalized on the next call

• Potassium cellulose glycolate (EO). The lead discussed the proposal for this substance. 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 filtration aid 

during irrigation and in combination with liquid fertilizers and nutrients. The Subcommittee determined 

that water usage is not a criteria under OFPA, and there was insufficient information justifying the need 

for this material in an organic production system. The subcommittee voted on the proposal.

Motion to classify potassium cellulose glycolate as petitioned as synthetic.

Motion by: EO

Seconded by: HB

Additional discussion: none

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

Motion to add potassium cellulose glycolate to the National List, as petitioned, at § 205.601.

Motion by: EO

Seconded by: HB

Additional discussion: 

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

• Polyoxin D. The lead discussed the petition and posed the question to the subcommittee regarding 

whether there is the need to obtain more information about the substance or the manufacturing 

process. One member of the committee noted that all zinc in the market is by-product of 

manufacturing processes and is synthetic. The subcommittee decided to postpone the discussion until 

one member of the subcommittee is on the call, in order to get his input. Further discussion was 

deferred to the next call. 

• Ammonium citrate and glycinate (EO) - Deferred to next call

• Strengthening seed guidance - Deferred to next call

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

August 16, 2016 

Polyoxin D Zinc salt - Petition sufficiency

Hydroponics task force report - Discuss report and proposal

Potassium cellulose glycolate (EO) - Discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

August 30, 2016 additional call

 Hydroponics task force report - Discuss proposal/discussion doc

Potassium cellulose glycolate (EO) - Discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D. Discuss questions for potential Lmtd scope TR request

September 6, 2016

Ammonium citrate and glycinate (EO) - Discuss proposal

Hydroponics task force report - Discuss discussion doc

Strengthening seed guidance - Discuss draft discussion document
Sodium citrate (HB) - Petition sufficiency

Marine materials (marine algae and extracts) - TR in development

September 20, 2016

October 4, 2016 

October 18, 2016 

November 1, 2016 

November 15, 2016 - cancelled (NOSB meeting)

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday September 6, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Harriet Behar (HB); Carmela Beck (CBe); Lisa de Lima (LD) - observer; Tracy Favre (TF) -

observer; Scott Rice (SR) - observer

Absent: Michelle Arsenault (MA)

Staff: Devon Pattillo (DP); Jessica Walden (JW)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected late Summer 2016.

TBD TBD

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16. CS voted 

09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16. CS voted 09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

TBD
Polyoxin D Zinc salt JB Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

lmt’d scope TR. 

Aug 2,

Aug 16

Aug 30

Sept 6

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request

Jul 19,

Aug 30

TBD

Allyl Isothiocyanate 

(AITC) Petition 

(2016)

JB Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16.

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

TBD TBD

Sodium Citrate, 

2016 

HB Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16.

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Fall 2016

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Fall 2016
Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16. TR suff due 10 11 16

Feb 2,

Oct 4

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics ZS Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Aug 30

Sep 6

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB Originated in MS. Draft DD in development Aug 2,

Aug 30

Sep 6

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)

EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “
Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of August 30

• Ammonium citrate and glycinate (EO) - Discuss proposal

• Hydroponics task force report - Discuss discussion doc

• Potassium cellulose glycolate (EO) - Discuss proposal

• Strengthening seed guidance - Discuss draft discussion document

• Polyoxin D. Discuss questions for potential limited scope TR request

• Sodium citrate (HB) - Petition sufficiency

• Marine materials (marine algae and extracts) 

• Adjourn

Discussion

• Crops Subcommittee notes of August 30 were deferred until the next meeting, as the committee 

received them shortly before the meeting.

• Ammonium citrate and glycinate (EO). The lead discussed these substances and explained that the 

petition does not supply sufficient reason for why these substances should be added when there are 

other substances on the National List that fulfill the same purpose. One proposal with separate motions

for each substance has been finalized. The Subcommittee found that the addendum did not completely 

discuss the question of alternatives. 
Motion to classify ammonium citrate as synthetic.

Motion by: EO

Seconded by: HB

Additional discussion: none

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

Motion to add ammonium citrate, as petitioned, at §205.601

Motion by: EO

Seconded by: HB

Additional discussion: none

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

Motion to classify ammonium glycinate as synthetic.

Motion by: EO

Seconded by: FT

Additional discussion: none

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

Motion to add ammonium glycinate, as petitioned, at §205.601

Motion by: EO

Seconded by: FT

Additional discussion: none

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

• Polyoxin D. The previous lead discussed new information provided by the petitioner, including new 

studies on the efficacy of this material. He recommends they reach out to the TR contractor and ask 

them to assess the validity of those studies. If the facts provided are valid, this could potentially be a 

useful material for organic producers. Inclusion of zinc (for retention purposes) makes this material 

synthetic, and as such does not fit into an OFPA category. Without zinc the material is non-synthetic. 

However, zinc is an allowed micronutrient. Members discussed whether to move forward with a TR,

given that there may not be an OFPA category for this material. A vote was cast regarding the TR (4 in 

favor, 3 opposed). The lead and former lead will draft questions for the TR and circulate them to the 

Subcommittee members for approval. One question will be whether the addition of zinc is necessary.

• Hydroponics task force report. The lead discussed the amendments provided by the other members of 

the Subcommittee to the hydroponics/bioponics draft proposal. The lead clarified that the container 

discussion document will provide guidance on which types of growing practices are allowed. The lead 

discussed the definitions section and the Subcommittee found the changes acceptable.

Motion to allow bioponics in organics. 

Motion by: ZS

Seconded by: EO 

Additional discussion: One member was concerned that there was still confusion over bioponics vs.

container-based systems that might be considered compliant. A discussion was had about the fact that 

this proposal might be sent back to Subcommittee after the fall meeting. 

Yes: 2 No: 5 Abstain: 0 Absent: 0 Recuse: 0
The subcommittee discussed the discussion document for container growing, referring to Canadian 

standards as well as a frame of reference. They considered which questions should be asked in the 

discussion document, with regard to percentages of compost, soil, etc. that are required to address 

specific needs of the plant. 

Motion to accept the discussion document on container-based growing.

Motion by: ZS

Seconded by: HA

Additional discussion: none 

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

• Sodium citrate. The Subcommittee would like to postpone this topic until an October meeting, but will 

check with the Advisory Committee Specialist once she is back from leave.

• Strengthening seed guidance. The lead discussed the discussion document and how she amended it for 

clarity. The Subcommittee agreed with the clarifications and a motion was put forth. 

Motion to adopt the discussion document on strengthening seed guidance

Motion by: ZS

Seconded by: HB

Additional discussion: further discussion was had on needing to go to three sources for certain varieties 

that are not available as organic and contamination issues in organic seed and testing

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

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

August 30, 2016 additional call

 Hydroponics task force report - Discuss proposal/discussion doc

Potassium cellulose glycolate (EO) - Discuss proposal

Ammonium citrate and glycinate (EO) - Discuss proposal

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D. Discuss questions for potential Lmtd scope TR request

September 6, 2016

Ammonium citrate and glycinate (EO) - Discuss proposal

Hydroponics task force report - Discuss discussion doc

Potassium cellulose glycolate (EO) - Discuss proposal

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D. Discuss questions for potential limited scope TR request

Sodium citrate (HB) - Petition sufficiency

Marine materials (marine algae and extracts) - TR sufficiency

September 20, 2016 - cancelled

October 4, 2016 

Allyl Isothiocyanate (AITC) Petition (2016) - petition sufficiency

Polyoxin D. Discuss questions for potential limited scope TR request

Sodium citrate (HB) - Petition sufficiency

Marine materials (marine algae and extracts) - TR sufficiency

October 18, 2016 

November 1, 2016 

November 15, 2016 - cancelled (NOSB meeting)
December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday October 4, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Harold Austin (HA);

Jesse Buie (JB); Harriet Behar (HB); Carmela Beck (CBe); Tracy Favre (TF) - observer; Scott Rice (SR) -

observer. 

Absent: Lisa de Lima (LD) - observer

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected Fall 2016.

TBD Spr 2017

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16. CS voted 

09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16. CS voted 09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

Spr 2017
Polyoxin D Zinc salt

205.601

JB Y Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

Lmt’d scope TR. CS requested Lmt’d scope 

TR 10 04 16

Aug 2,

Aug 16

Aug 30

Sept 6

Oct 4

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request

Jul 19,

Aug 30

Fall 2016

Allyl Isothiocyanate 

(AITC) Petition 

(2016) 205.601

JB Y Lmt’d 

scope

Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16. Petition 

found suff 10 04 16. CS requested Lmt’d 

scope TR 10 04 16

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

Oct 4 TBD

Sodium Citrate 

2016 205.601

HB Y Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16. Petition was 

found sufficient 10 04 16. CS requested a 

TR 10 04 16

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Natamycin HB Petition sent to CS 09 09 16. Petition 

suff/TR request due 11 08 16.

Nov 01 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2017

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Spr 2017

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16.

Feb 2 Spr 2017

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics/biopo

nics 

ZS Proposal Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Aug 30

Sept 6

Fall 2016

Container and 

greenhouse 

production

ZS DD See above Aug 30

Sept 6

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB NA Originated in MS. Draft DD Aug 2,

Aug 30

Sep 6

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting
Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)

EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “

Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda
• Approve Crops Subcommittee notes of August 30

• Approve Crops Subcommittee notes of September 6

• NOP operating plan priorities (from current list)

• Check in on future work agenda for CS

• Allyl Isothiocyanate (AITC) Petition (2016) - petition sufficiency

• Polyoxin D. Discuss questions for potential limited scope TR request

• Sodium citrate (HB) - Petition sufficiency

• Adjourn

Discussion

• Crops Subcommittee notes of August 30 were approved with no changes

• Crops Subcommittee notes of September 6 were approved with no changes

• NOP operating plan priorities (from current list). The NOSB was asked to rank priorities for the NOPs 

2017 operating plan. Each Subcommittee will identify priorities, which will be discussed on the next ES 

call. Crops identified four items for consideration: sodium nitrate, which was the top priority; rotenone; 

EPA List 4 inerts annotation change, and apiculture (which is a Livestock project). Additionally, the 

Crops Subcommittee emphasized the need for the inerts working group to meet and continue work. 

• Future work agenda for CS. The CS Chair requested that members prepare suggestions for additional 

work agenda items for discussion on the next call. Members will continue work on outstanding items, 

some of which will be transitioned to other/new members in January. Outstanding items include: 

contamination issues in farm inputs; anaerobic digestate, for which there is a TR in development;

biodegradable biobased mulch; 2019 sunset substances; prohibition of NPEs; marine materials (EO will 

take the lead on this project, and will collaborate with JR to transition); newspaper, for which there is a 

TR in development; the container production discussion document will likely become a proposal for the 

Spring 2017 meeting; and strengthening and clarifying the requirements for use of organic seed.

• Allyl Isothiocyanate (AITC) petition (2016) (HA). The petition was found sufficient. AITC was originally 

petitioned in 2014 and was subsequently withdrawn. The new petition asks for additional uses, such as 

a fungicide, etc. Members discussed the uses and effects of AITC, which is a synthetic analog of mustard 

seed. The lead suggested the CS request a limited scope TR with targeted questions. 

• Polyoxin D (JB). The lead composed several questions for the limited scope TR request, and the group 

discussed them. The lead will forward the questions to the CS Chair to submit to the NOP. 

• Sodium citrate (HB). Members discussed the draft summary, including the uses of sodium citrate. It is 

being petitioned for use as anticoagulant for blood meal fertilizer. Currently it is an allowed synthetic in 

Handling. The 2015 TR, contracted for the handling review, focused on sodium citrate as a food 

ingredient. The group discussed the substance in relation to the OFPA criteria: human 

health/environmental concerns, and alternatives. Although the petition mentioned alternatives, the 

lead felt it was not entirely clear, so the HS will seek a technical report to address questions about 

alternatives. 

• Natamycin (EO). Natamycin was originally petitioned for use in handling, and the Handling 

Subcommittee classified it as synthetic and voted to not allow it. New information indicates that it may

be non-synthetic, but it is now being petitioned for use in Crops. EO will take the lead on this material 

review. The CS Chair noted that the classification of materials guidance, if published, could help shed 

light on this material. Members discussed whether natamycin is considered an antibiotic, since it may 

affect fungi and mold but not bacteria. The CS may request a TR. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

September 6, 2016

Ammonium citrate and glycinate (EO) - Discuss proposal
Hydroponics task force report - Discuss discussion doc

Potassium cellulose glycolate (EO) - Discuss proposal

Strengthening seed guidance - Discuss draft discussion document

Polyoxin D. Discuss questions for potential limited scope TR request

Sodium citrate (HB) - Petition sufficiency

Marine materials (marine algae and extracts) - TR in development

September 20, 2016 - cancelled

October 4, 2016 

Allyl Isothiocyanate (AITC) Petition (2016) - petition sufficiency

Polyoxin D. Discuss questions for potential limited scope TR request

Sodium citrate (HB) - Petition sufficiency

October 18, 2016

November 1, 2016 

Natamycin - Petition suff and TR request

November 15, 2016 - cancelled (NOSB meeting)

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

 Tuesday October 18, 2016 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Jesse Buie (JB); 

Harriet Behar (HB); Scott Rice (SR) - observer

Absent: Harold Austin (HA); Carmela Beck (CBe)

Staff: Michelle Arsenault (MA); Devon Pattillo (DP)

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP)

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected Fall 2016.

TBD Spr 2017

Ammonium 

Glycinate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16. CS voted 

09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16. CS voted 09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Anaerobic 

Digestate

205.203

ZS New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

Spr 2017
Polyoxin D Zinc salt

205.601

JB Y Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

Lmt’d scope TR. CS requested Lmt’d scope 

TR 10 04 16

Aug 2,

Aug 16

Aug 30

Sept 6

Oct 4

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request

Jul 19,

Aug 30

Fall 2016

Allyl Isothiocyanate 

(AITC) Petition 

(2016) 205.601

JB Y Lmt’d 

scope

Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16. Petition 

found suff 10 04 16. CS requested Lmt’d 

scope TR 10 04 16

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

Oct 4 TBD

Sodium Citrate 

2016 205.601

HB Y Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16. Petition was 

found sufficient 10 04 16. CS requested a 

TR 10 04 16

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Natamycin HB Petition sent to CS 09 09 16. Petition 

suff/TR request due 11 08 16.

Oct 18

Nov 1

TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2017

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Spr 2017

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16.

Feb 2 Spr 2017

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics/biopo

nics 

ZS Proposal Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Aug 30

Sept 6

Fall 2016

Container and 

greenhouse 

production

ZS DD See above Aug 30

Sept 6

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB NA Originated in MS. Draft DD Aug 2,

Aug 30

Sep 6

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting
Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)

EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “

Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion
Agenda

• Approve Crops Subcommittee notes of October 4

• Natamycin - Designate lead

• Fall meeting - Discuss presentations and updates

• Discussion of any public comments received so far 

• Adjourn

Discussion

• Crops Subcommittee notes of October 4 were approved with no changes.

• Natamycin. HB will be the lead author for this substance. The CS will determine petition sufficiency and 

the need for a TR on the November 1 call. 

• Fall meeting - discuss presentations and updates.

o The members discussed the comments regarding hydroponics, noting that there are comments

supporting both sides of the issue. 

o A member described the format for presenting proposals and discussion documents at the fall 

meeting. Presentations should be submitted to the NOP no later than Tuesday, November 15 

at the NOSB administrative meeting. 

o Two NOP staff members sat in on a webinar on hydroponics last week that was hosted by the 

Controlled Environment Agriculture Center (CEAC) of the University of Arizona. Two of the 

Hydroponics Task Force members were part of the panel. The email with the call-in information 

for the next webinar was forwarded to the Crops Subcommittee members. 

• Public comments. The group discussed the open docket and the receipt of comments prior to the 

posting of the proposals. The comment period closes on October 26, and the CS will discuss the 

comments during the next conference call. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

October 4, 2016 

Allyl Isothiocyanate (AITC) Petition (2016) - petition sufficiency

Polyoxin D. Discuss questions for potential limited scope TR request

Sodium citrate (HB) - Petition sufficiency

October 18, 2016

November 1, 2016 

Review public comment

Natamycin - Petition suff and TR request

November 15, 2016 - cancelled (NOSB meeting)

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016
Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

 National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes 

 Tuesday November 1, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Jesse Buie (JB); 

Harriet Behar (HB); Harold Austin (HA); Carmela Beck (CBe); Tracy Favre (TF) - observer; Ashley Swaffar (AS) 

- observer; Scott Rice (SR) - observer

Absent: none

Staff: Michelle Arsenault (MA); Devon Pattillo (DP), Jessica Walden (JW) 

Work Agenda

2018 Sunsets (TR requests)

Summary: Spr 2016 Review: Fall 2016 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed, 

Voted

Meeting

Copper sulfate 

205.601(a) 

205.601(e)

ZS 2015 LS 

TR

Sunset date: 11/3/2018. No new TR 

requested.

Jul 5 Fall 2016

Ozone gas 

205.601(a)

FT N Sunset date: 11/3/2018. No new TR 

requested.

Jun 21 Fall 2016

Peracetic acid 

205.601(a)

205.601(i)

HA 2016 Sunset date: 5/29/2018. HS requested TR 

07 21 15. TR in development as of Nov 

2015. TR sent to CS 03 04 16. Response 

due as soon as possible to facilitate 

posting before Spring 2016 meeting. TR 

found sufficient 03 15 16

Jun 21 Fall 2016

EPA List 3 - Inerts of 

Unknown Toxicity 

ZS Y Sunset date: 11/3/2018. HS requested TR 

07 10 15. Request for TR under review as 

of Nov 2015. TR request on hold.

Jun 7 Fall 2016

Calcium chloride 

205.602(c) 

CBe N Petition for annotation change. Sunset 

date: 11/3/2018. No new TR requested.

Jul 5 Fall 2016
Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Aluminum sulfate FT Y The petitioner requests two related 

allowances on the NL: (1) treatment of 

poultry litter (205.603) and (2) application 

of treated poultry litter to the field 

(205.601). Sent to LS 03 12 14. TR request 

sent to NOP 06 18 14. TR expected Jan 

2015. TRs (2) sent to LS 05 15 15. Suff due 

07 15 15. TR found insufficient 07 21 15. 

Waiting for LS. LS voted on 06 22 16

Jul 19 Fall 2016

Soy Wax FT N Petition sent to CS 10 14 15. Questions or 

request for TR due 12 15 15. Petition found 

suff 12 01 15. No TR requested. Referred 

back to CS at Spr 2016 NOSB

Jul 5, 

Aug 2

Fall 2016

1-

methylcyclopropen

e (1-MCP) 

+ addendum

205.601

ZS/HA N Petition sent to CS 11 30 15. Petition 

suff/TR Request due 02 01 16. CS rqstd 

additional info from petitioner 03 17 16. No 

new TR. Additional info from petitioner 

sent 03 23 16. Suff due ASAP

Feb 16,

Mar 15, 

Jul 5

Fall 2016

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development - 

expected Fall 2016.

TBD Spr 2017

Ammonium 

Glycinate 

205.601

Petition Addendum 

#1

Addendum #2 

EO N Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. 2007 crops 

technical report for amino acids, Found 

insufficient. Sent Qs to petitioner. Petition 

addendum #1 sent to CS 06 13 16. Petition 

found sufficient 07 05 16. Petition 

addendum #2 sent to CS 07 25 16. CS voted 

09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Ammonium Citrate

205.601

Petition Addendum 

#1

Addendum #2 

EO N Petition sent to CS 03 31 16. Petition 

suff/TR Request due 05 31 16. HS TR, Citric 

acid and salts, 2015. Found insufficient. 

Sent Qs to petitioner. Petition addendum

#1 sent to CS 06 13 16. Petition found 

sufficient 07 05 16. Petition addendum #2 

sent to CS 07 25 16. CS voted 09 06 16.

May 17, 

July 5, 

Aug 2

Aug 30

Sept 6

Fall 2016

Anaerobic 

Digestate

205.203

ZS Y New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

Spr 2017
Polyoxin D Zinc salt

205.601

JB Y Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

Lmt’d scope TR. CS requested Lmt’d scope 

TR 10 04 16

Aug 2,

Aug 16

Aug 30

Sept 6

Oct 4 

TBD

Potassium Cellulose 

Glycolate 

(Potassium CMC) 

EO N Petition sent to CS 06 28 16. Petition 

suff/TR request due 08 30 16. Pet found 

sufficient 07 19 16. No TR request 

Jul 19,

Aug 30

Fall 2016

Allyl Isothiocyanate 

(AITC) Petition 

(2016) 205.601

JB Y Lmt’d 

scope

Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16. Petition 

found suff 10 04 16. CS requested Lmt’d 

scope TR 10 04 16

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

Oct 4 TBD

Sodium Citrate 

2016 205.601

HB Y Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16. Petition was 

found sufficient 10 04 16. CS requested a 

TR 10 04 16

TR - Handling, Citric acid and salts (2015)

Sep 6 TBD

Natamycin HB Y Petition sent to CS 09 09 16. Petition 

suff/TR request due 11 08 16. Petition 

found sufficient 11 01 16, and CS requested 

TR 11 01 16

Oct 18

Nov 1 

Spr 2017

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2017

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD
Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above) 

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Spr 2017

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD TBD

Marine materials 

(marine algae and 

extracts)

JR DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16.

Feb 2 Spr 2017

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

TBD TBD

Hydroponics/biopo

nics 

ZS Proposal Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Aug 30

Sept 6

Fall 2016

Container and 

greenhouse 

production

ZS DD See above Aug 30

Sept 6

Fall 2016

Research Priorities All NA RPs due to MS Aug 2016 Jun 7 Fall 2016

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB NA Originated in MS. Draft DD Aug 2,

Aug 30

Sep 6

Fall 2016

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017 

Substance Contact TR 

request?

Notes Scheduled, 

Discussed, 

Voted

Meeting
Calcium 

hypochlorite 

205.601(a)

FT N Jun 21 Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N Jun 21 “

Sodium 

hypochlorite 

205.601(a)

FT N Jun 21 “

Herbicides, soapbased 205.601(b)

EO N Jun 21 “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y Jun 21 “

Boric acid 

205.601(e)

HB N Jun 21 “

Sticky 

traps/barriers 

205.601(e)

EO N Jun 21 “

Copper sulfate 

205.601(i)

ZS N Jun 21 “

Coppers, fixed

205.601(i)

ZS N Jun 21 “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

Jun 21 “

Soluble boron 

products 

205.601(j)

ZS N Jun 21 “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N Jun 21 “

Vitamin B1 

205.601(j)

CBe N Jun 21 “

Vitamin C 

205.601(j)

CBe N Jun 21 “

Vitamin E 

205.601(j)

CBe N Jun 21 “

Lead salts 

205.602(d)

FT N Jun 21 “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N Jun 21 “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion
Agenda

• Approve Crops Subcommittee notes of October 18

• Natamycin - Petition sufficiency and TR request

• Discuss work agenda

• Review public comments 

• Adjourn

Discussion

• Crops Subcommittee notes of October 18 approved with no changes. 

• Natamycin (HB). The lead summarized the material, including its petitioned use. Natamycin was 

petitioned in 2007 and the Board voted to not allow it on the National List at that time. Currently it is 

approved for use in Canada, and is listed by OMRI as non-synthetic. The petition was found sufficient, 

and the CS will seek a TR.

• Work agenda. The Chair recommended that the members, and especially the new members, keep in 

mind items for future work agenda. The new members should be announced at the fall meeting, and 

will be invited to sit in on December calls. 

• Public comments. Members discussed public comments about various materials, including ammonium 

glycinate, ammonium citrate, hydroponics and containers. The chair reviewed the process for 

discussing and voting on proposals for the benefit of the new members. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

October 18, 2016

November 1, 2016 

Review public comment

Natamycin - Petition suff and TR request

November 15, 2016 - cancelled (during NOSB meeting)

December 6, 2016 

December 20, 2016

Fall 2016 Milestones Target dates (tentative)

NOP - Publish FRN, Open public comment Aug 1, 2016

NOP - Complete fall 2016 NOSB meeting tentative agenda Sep 8, 2016

NOSB - Fall 2016 proposals due to NOP Sep 14, 2016

NOP - Post proposals On or before Sep 27, 2016

Discuss work agendas on ES call Oct 14, 2016

Public comment closes Oct 26, 2016

NOP - Send compiled public comments to NOSB Nov 2, 2016

Public comment webinar Nov 3, 2016

Work agendas finalized on ES call (last call before fall meeting) Nov 4, 2016 

Fall 2016 NOSB meeting - St Louis, MO Nov 16-18, 2016
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

 Tuesday December 6, 2016 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS); Francis Thicke, Vice Chair (FT); Emily Oakley (EO); Jesse Buie (JB); 

Harriet Behar (HB); Harold Austin (HA); Carmela Beck (CBe); Dave Mortensen (DM) - observer, Asa Bradman

- observer, Steve Ela - observer

Absent: none

Staff: Michelle Arsenault (MA); Devon Pattillo (DP), Jessica Devon (JW)

Work Agenda

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected Fall 2016.

TBD Spr 2017

Anaerobic 

Digestate

205.203

ZS, EO Y New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

Spr 2017

Polyoxin D Zinc salt

205.601

JB Y Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

Lmt’d scope TR. CS requested Lmt’d scope 

TR 10 04 16

Aug 2,

Aug 16

Aug 30

Sept 6

Oct 4

Fall 2017

Allyl Isothiocyanate 

(AITC) Petition 

(2016) 205.601

JB Y Lmt’d 

scope

Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16. Petition 

found suff 10 04 16. CS requested Lmt’d 

scope TR 10 04 16

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

Oct 4 Fall 2017

Sodium Citrate 

2016 205.601

HB Y Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16. Petition was 

found sufficient 10 04 16. CS requested a 

TR 10 04 16

TR - Handling, Citric acid and salts (2015)

Sep 6 Fall 2017
Natamycin HB Y Petition sent to CS 09 09 16. Petition 

suff/TR request due 11 08 16. Petition 

found sufficient 11 01 16, and CS requested 

TR 11 01 16

Oct 18

Nov 1

Fall 2017

Ammonium 

Nonanoate 

FT Petition sent to CS 11 09 16. Petition 

suff/TR request due 01 09 16. 

Dec 20 TBD

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2017

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16.

Feb 2, 

Feb 23, Jul 

19

Spr 2017

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD TBD

Marine materials 

(marine algae and 

extracts)

JR/EO DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16.

Feb 2 Spr 2017

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development

Jan 3 TBD

Hydroponics/biopo

nics 

ZS, , JB, 

HB, FT 

and EO

Proposal Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Fall 2017
Container and 

greenhouse 

production

ZS Proposal

?

Fall 2017

Research Priorities All NA RPs due to MS Aug 2017 Fall 2017

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB NA Originated in MS Spr 2017

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N “

Sodium 

hypochlorite 

205.601(a)

FT N “

Herbicides, soapbased 205.601(b)

EO N “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y “

Boric acid 

205.601(e)

HB N “

Sticky 

traps/barriers 

205.601(e)

EO N “

Copper sulfate 

205.601(i)

ZS N “

Coppers, fixed

205.601(i)

ZS N “

Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

“

Soluble boron 

products 

205.601(j)

ZS N “
Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N “

Vitamin B1 

205.601(j)

CBe N “

Vitamin C 

205.601(j)

CBe N “

Vitamin E 

205.601(j)

CBe N “

Lead salts 

205.602(d)

FT N “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of November 1

• De-brief from Fall meeting

• New (old) petition for ammonium nonanoate - assign lead 

• Review work agenda (see charts in notes) to make sure leads are assigned, transition happens smoothly 

and everything is being worked on.

• Adjourn

Discussion

• Crops Subcommittee notes of November 1 were accepted with a minor change to the roll call. 

• Fall meeting debrief. 

o The CS Chair praised the members for speaking up and stating their viewpoints at the meeting 

regarding hydroponics. She stressed the importance of having these conversations so 

stakeholders are aware of the differing views. This allows the public to witness the decision 

making process and how difficult it can be for Board members. 

o The Hydroponics proposal was sent back to Subcommittee and will now be led by JB, HB, FT, 

and EO. The current lead offered suggestions about how to proceed. Members discussed 

various considerations for future iterations of the documents on both containers and 

hydroponics, including convening a panel. Some felt that an expert panel would not be helpful 

since the scientific information they are seeking does not exist, and instead, discussed inviting 

various experts to join the Subcommittee calls. 

o Strengthen and clarify the requirements for use of organic seed (NOP 5029). The lead will 

discuss next steps with the NOP and the Crops Subcommittee will discuss this again on Jan 3.

• Ammonium nonanoate. The group discussed the petition and the inclusion of new information, which 

is a requirement for re-petitioned materials. FT volunteered to lead this material, and the CS will 

schedule the discussion for the December 20 call. 

• Work agenda 

o Petitioned Substances: There are several petitioned substances waiting for TRs: Fatty alcohols; 

Anaerobic digestate (EO will eventually take the lead on this); Polyoxin D Zinc salt; AITC; Sodium 
Citrate, and Natamycin. Several of these items were moved from the spring 2017 meeting to 

fall 2017 as the TRs likely won’t be back in time to finish the proposals by the February due 

date.

o Contamination Issues in Farm Inputs. FT and HB will begin work on this project, although it is 

pending until the compost ruling. 

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

November 15, 2016 - cancelled (during NOSB meeting)

December 6, 2016 

December 20, 2016

Ammonium nonanoate (FT). Petition sufficiency/TR request?

Marine materials (EO). Keep on agenda or not?

January 3, 2017

Strengthen and clarify the requirements for use of organic seed (NOP 5029)

Newspaper - annotation change

January 17, 2017

February 7, 2017

February 21, 2017

March 7, 2017

March 21, 2017

April 4, 2017

April 18, 2017

May 2, 2017

May 16, 2017

June 6, 2017

June 20, 2017

July 18, 2017

August 1, 2017

August 15, 2017

September 5, 2017

September 19, 2017

October 3, 2017

October 17, 2017

November 7, 2017

November 21, 2017

December 5, 2017

December 19, 2017

January 2, 2018

January 16, 2018

Spring 2017 Milestones 2017 Target date

New NOSB member orientation Feb 8, 2017

NOP - Complete Spring 2017 NOSB meeting tentative agenda Feb 10, 2017

NOSB - Spring 2017 proposals due to NOP Feb 17, 2017
NOP - Post proposals, Publish FRN, Open public comment Mar 1, 2017

Discuss work agendas on ES call Mar 17, 2017 

Public comment closes Mar 30, 2017

NOP - Send compiled public comments to NOSB Apr 5, 2017

Work agendas finalized on ES call (last call before fall meeting) Apr 7, 2017

Public comment webinar Apr 13, 2017

Spring 2017 NOSB meeting – Denver, CO Apr 19-21, 2017 (W-F)
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

 Tuesday December 20, 2016 2:00 pm ET

Present: Francis Thicke, Chair (FT); Zea Sonnabend (ZS); Emily Oakley (EO); Jesse Buie (JB); Harriet Behar

(HB); Harold Austin (HA); Joelle Mosso (JM) - observer; Tom Chapman - observer

Absent: Carmela Beck (CBe)

Staff: Michelle Arsenault (MA); Jessica Walden (JW)

Work Agenda

Petitioned Substances

Substance Contact

TR 

request?

Notes Discussed,

Voted

Meeting

Fatty Alcohols 

(octanol/decanol 

mix)

JB Y Petition sent to CS 01 27 16. Petition 

suff/TR Request due 03 28 16. Petition 

found sufficient 03 17 16. TR request sent 

to NOP 03 17 16. TR in development -

expected Fall 2016.

TBD Spr 2017

Anaerobic 

Digestate

205.203

ZS, EO Y New petition sent to MS 04 22 16. Under 

review for eligibility at request of NOP. TR 

request sent to NOP 07 05 16

May 17, 

Jul 5

Spr 2017

Polyoxin D Zinc salt

205.601

JB Y Petition sent to CS 06 16 16. Petition 

suff/TR request due 08 16 16. Petition 

found sufficient 08 16 16. Discuss need for 

Lmt’d scope TR. CS requested Lmt’d scope 

TR 10 04 16

Aug 2,

Aug 16

Aug 30

Sept 6

Oct 4

Fall 2017

Allyl Isothiocyanate 

(AITC) Petition 

(2016) 205.601

JB Y Lmt’d 

scope

Petition sent to CS 07 06 16. Petition 

suff/TR request due 09 06 16. Petition 

found suff 10 04 16. CS requested Lmt’d 

scope TR 10 04 16

• AITC Petition (2013) (PDF)

• NOSB Subcommittee Proposal 

(2014) (PDF)

• Technical Evaluation Report (2014) 

(PDF)

Oct 4 Fall 2017

Sodium Citrate 

2016 205.601

HB Y Petition sent to CS 07 27 16. Petition 

suff/TR request due 09 27 16. Petition was 

found sufficient 10 04 16. CS requested a 

TR 10 04 16

TR - Handling, Citric acid and salts (2015)

Sep 6 Fall 2017
Natamycin HB Y Petition sent to CS 09 09 16. Petition 

suff/TR request due 11 08 16. Petition 

found sufficient 11 01 16, and CS requested 

TR 11 01 16

Oct 18

Nov 1

Fall 2017

Ammonium 

Nonanoate 

FT Petition sent to CS 11 09 16. Petition 

suff/TR request due 01 09 16. CS rejected 

petition 12 20 16.

Dec 20 NA

Inert Ingredients

Substance Contact

TR 

rqstd?

Notes* Vote Meeting

EPA List 4 Inerts 

annotation change

ZS N/A Update from IWG NA Spr 2017?

Other Topics

Project ContactDoc type Notes* Disc/Vote Meeting

Contamination 

Issues in Farm 

Inputs 

FT/HB Report. On HOLD pending compost ruling. Apr 5 TBD

Anaerobic 

Digestate - Food 

Waste

205.601(j) and 

other manure 

issues

ZS Petition sent to CS 04 08 15. Questions or 

request for TR due 06 09 15. Petition found 

sufficient 06 02 15. TR rqst sent to NOP 10 

06 15. Petition withdrawn 10 14 15. CS 

moved project to “other topics” NOP 

sent memo to board 05 09 16 requesting 

review. TR request sent to NOP 07 05 16 

(see anaerobic digestate above)

Jul 5 TBD

Biodegradable 

Biobased Mulch

HB DD Limited scope TR request sent to NOP 08 02 

16. TR in development, expected Jan 2017

Feb 2, 

Feb 23, Jul 

19

Spr 2017

Prohibition of NPEs 

in Inerts annotation 

change

ZS DD on hold TBD TBD

Marine materials 

(marine algae and 

extracts)

JR/EO DD NOP approved request 01 12 16. TR 

request sent to NOP 02 05 16. TR sent to 

HS 08 10 16. On hold as Handling develops 

proposal

Feb 2, 2016; 

Dec 20, 

2016

TBD

Newspaper -

annotation change

ZS NOP approved request 01 12 16. TR 

request sent to NOP 06 21 16. TR in 

development. TR expected Dec 2016

Jan 3 TBD
Hydroponics/biopo

nics 

ZS, JB, 

HB, FT

and EO

Proposal Report due from Task Force ~June. 

Deadline extended to mid-July. 2 parts: 

proposal on bioponics and a disc doc on 

container-based growing. 

Jan 3 Spr 2017?

Container and 

greenhouse 

production

ZS Proposal

?

Fall 2017

Research Priorities All NA RPs due to MS Aug 2017 Fall 2017

Strengthen and 

clarify the 

requirements for 

use of organic seed

(NOP 5029)

ZS/HB NA Originated in MS Spr 2017

NOP operating plan 

suggestions

ALL NA NA NA

2019 Sunsets (TR requests)

Summary: Spr 2017 Review: Fall 2017

Substance Contact TR 

request?

Notes Scheduled, 

Discussed,

Voted

Meeting

Calcium 

hypochlorite 

205.601(a)

FT N Summary 

Spr 17

Chlorine dioxide

205.601(a)

FT N “

Sodium 

hypochlorite 

205.601(a)

FT N “

Herbicides, soapbased 205.601(b)

EO N “

Biodegradable 

biobased mulch 

film 205.601(b)

HB Y TR in development, expected Jan 2017 “

Boric acid 

205.601(e)

HB N “

Sticky 

traps/barriers 

205.601(e)

EO N “

Copper sulfate 

205.601(i)

ZS N “

Coppers, fixed

205.601(i)

ZS N “
Humic acids 

205.601(j)

CBe N 2012 TR for oxidized lignite/humic acid 

derivatives

“

Soluble boron 

products 

205.601(j)

ZS N “

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

ZS N “

Vitamin B1 

205.601(j)

CBe N “

Vitamin C 

205.601(j)

CBe N “

Vitamin E 

205.601(j)

CBe N “

Lead salts 

205.602(d)

FT N “

Tobacco dust 

(nicotine sulfate) 

205.602(i)

HB N “

* Yellow highlight indicates Subcommittee action needed *Highlight indicates review completion

Agenda

• Approve Crops Subcommittee notes of December 6

• Ammonium nonanoate (FT). Petition sufficiency/TR request

• Marine materials (EO). Keep on agenda or not 

• Feedback from first planning session of the Crops Hydroponics Sub-Subcommittee (Jesse, Harriet, Emily 

and Francis)

• Other business

• Adjourn

Discussion

• Crops Subcommittee notes of December 6 were approved with the addition of two co-leads to the 

Hydroponics project. JB and FT will join HB and EO.

• Ammonium nonanoate (FT). Originally petitioned in 2009 as an herbicide. This re-petition indicates use 

as an herbicide and desiccant. The lead reviewed the previous NOSB determination, which found that it 

was non-essential and incompatible with organic principles. While the new petition contains 

information about human health, this was not a criterion that was used to reject the 2009 petition. 

Additionally, the new petition did not address concerns the previous Board had identified. Therefore

the CS is rejecting the petition for ammonium nonanoate. The NOP will notify the petitioner. 

• Marine materials (EO). The Handling Subcommittee completed an in-depth discussion just prior to the 

Crops call. The CS discussed various aspects of the draft proposal, including sustainability and overharvesting. After a lengthy discussion the members determined that there is nothing for the Crops 

Subcommittee to work on at this time, but will follow the review in Handling, and decide later if there is 

something they could build on. 
• Crops Hydroponics Sub-Subcommittee. Four members of the Crops Subcommittee are working on the 

hydroponics project as co-leads. The group has had preliminary conversations and is moving forward 

with a draft document based on the strong foundation that was already developed by previous 

members. The group will also look at the regulations to determine if a path forward will involve 

regulatory change and/or rulemaking. The CS hopes to have a document ready for the Spring 2017 

NOSB meeting.

• 2019 Sunset Materials. Several materials will need to be reassigned for presentation at the Spring 2017 

meeting, as current leads are completing their NOSB terms in January. The leads will pass along any 

previous notes and work for the transition. 

• Other business - none

• The meeting was adjourned 

Previous CS Notes

Future Call Schedule (1st and 3rd Tuesdays 2:00 ET)

December 6, 2016

December 20, 2016

Ammonium nonanoate (FT). Petition sufficiency/TR request?

Marine materials (EO). Keep on agenda or not?

January 3, 2017

Strengthen and clarify the requirements for use of organic seed (NOP 5029) (ZS/HB)

Newspaper - annotation change (ZS). Discuss TR if available

Hydroponics discussion document (JB, HB, FT, EO)

Reassign 2019 Sunset Materials/schedule discussion dates

January 17, 2017

January 31, 2017 (rescheduled from Feb 7)

February 21, 2017

March 7, 2017

March 21, 2017

April 4, 2017

April 18, 2017

May 2, 2017

May 16, 2017

June 6, 2017

June 20, 2017

July 18, 2017

August 1, 2017

August 15, 2017

September 5, 2017

September 19, 2017

October 3, 2017

October 17, 2017

November 7, 2017

November 21, 2017

December 5, 2017

December 19, 2017

January 2, 2018

January 16, 2018
Spring 2017 Milestones 2017 Target date

New NOSB member orientation Feb 8, 2017

NOP - Complete Spring 2017 NOSB meeting tentative agenda Feb 10, 2017

NOSB - Spring 2017 proposals due to NOP Feb 17, 2017

NOP - Post proposals, Publish FRN, Open public comment Mar 1, 2017

Discuss work agendas on ES call Mar 17, 2017 

Public comment closes Mar 30, 2017

NOP - Send compiled public comments to NOSB Apr 5, 2017

Work agendas finalized on ES call (last call before fall meeting) Apr 7, 2017

Public comment webinar Apr 13, 2017

Spring 2017 NOSB meeting – Denver, CO Apr 19-21, 2017 (W-F)