FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: 5/22/08 

Subject: Cheesewax 

Chair: Rigoberto Delgado 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: XXX 

Guidance Statement: 

Other: 

Statement of the Recommendation (including Recount of Vote):

The Board recommends to include microcrystalline cheesewax (CAS #’s 64742-42-3, 8009-03-

08, and 8002-74-2) on The National List §205.601(o) as a production aid in log grown mushroom 

culture made without either ethylene-propylene co-polymer or synthetic colors. 

NOSB Vote 

Motion: to include microcrystalline cheesewax (CAS #’s 64742-42-3, 8009-03-08, and 8002-74-

2) on The National List §205.601(o) as a production aid in log grown mushroom 

culture made without either ethylene-propylene co-polymer or synthetic colors. 

Moved by: Gerald Davis Second by: Jeffrey Moyer

Board vote: Yes - 12 No- 0 Abstain- 1 Absent - 1 

Result: The ayes have it and the motion is agreed to. 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

The material composed of a blend of the three CAS #’s listed above was determined to meet the 

OFPA and NOP evaluation criteria for minimal human and environmental impact, essentiality, 

Compatibility and consistency with organic farming regulations. 

Response by the NOP:
National Organic Standards Board 

Final Recommendation for 

Date: 6/16/2008 

I. List: (where in FR rule example 205.606) 

The National List §205.601(o) as a production aid in log grown mushroom culture made 

without either ethylene-propylene co-polymer or synthetic colors. 

II. Committee Summary: 

The material composed of a blend of the three CAS #’s listed above was determined to meet 

the OFPA and NOP evaluation criteria for minimal human and environmental impact, 

essentiality, Compatibility and consistency with organic farming regulations. 

III. Board Recommendation 

The Board recommends to include microcrystalline cheesewax (CAS #’s 64742-42-3, 

8009-03-08, and 8002-74-2) on The National List §205.601(o) as a production aid in 

log grown mushroom culture made without either ethylene-propylene co-polymer or 

synthetic colors. 

Board vote: 

Moved: Gerald Davis Second: Jeffrey Moyer 

Board vote: Yes- 12 No- 0 Absent- 1 Abstain- 1 Recuse- 0
Decision Sheets 

December 2006 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __May 2008_____ Substance: Microcrystalline_Cheese Wax_ 

Committee: Crops X Livestock  Handling  Petition is for:_ To include microcrystalline cheesewax (CAS#’s 

64742-42-3, 8009-03-08, and 8002-74-2)” on the National List §205.601(o) as a production aid in log grown mushroom 

culture made without either ethylene-propylene co-polymer or synthetic colors. 

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

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

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

3. Compatibility & Consistency Yes X No  N/A 

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

B. Substance Fails Criteria Category: None__ Comments: ___________________________________________________ 

________________________________________________________________________________________________________ 

C. Proposed Annotation (if any): _ as a production aid in log grown mushroom culture made without either ethylenepropylene co-polymer or synthetic colors ___________________________________________________________________ 

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:______________________ 

D. Recommended Committee Action & Vote (State Actual Motion): _ To include microcrystalline cheesewax (CAS#’s 

64742-42-3, 8009-03-08, and 8002-74-2)” on the National List §205.601(o) as production aid in log grown mushroom 

culture made without either ethylene-propylene co-polymer or synthetic colors. 

Motion by: JM Seconded:___BF_______ Yes: ___6__ No: __0___ Absent: ___0____ Abstain:__0___ 

 

 

1) Substance voted to be added as “allowed” on National List to § 205. with Annotation (if any) ______________________

________________________________________________________________________________________________________ 

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

________________________________________________________________________________________________________ 

Describe why a prohibited substance:__________________________________________________________________________

________________________________________________________________________________________________________ 

 

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

________________________________________________________________________________________________________ 

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops X Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

__Gerald Davis_______________________________ May 21, 2008 _________________________ 

 Committee Chair Date
Decision Sheets 

December 2006 

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Microcrystalline_Cheese Wax

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Are there adverse effects on 

environment from manufacture, use, or 

disposal? 

[§205.600 b.2] 

X According to the petition, the 3 components of cheesewax are 

byproducts of oil refining. It is recovered from crude oil through a 

series of filtration, solidifying, and solvent extraction steps. All of the 

solvent is recovered and none remains in the final product. Petition 

pages 16-18. 

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3] 

X Petition pages 16-18. The petition does not mention what kind of 

solvent is used in the separation of wax from oil, but does say that all 

of the solvent is recovered during the process. 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X Microcrystalline wax: petition pages 44-101 

Paraffin: petition pages 102-157 

Petrolatum: petition pages 158-182 

Blended wax: petition pages 183-212 

4. Does the substance contain List 1, 2, 

or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2] 

X CAS#’s 64742-42-3, 8009-03-08, and 9010-79-1 are all on EPA list 

‘Inert Ingredients Permitted for Use in Nonfood Use Pesticide 

Products: Last Updated January 7, 2008’. CAS# 8002-74-2 on EPA 

list 4A. CAS# 6231-60-7 does not appear on any EPA list. 

5. Is there potential for detrimental 

chemical interaction with other 

materials used? 

[§6518 m.1] 

X Not with materials used in Shiitake mushroom culture. 

6. Are there adverse biological and 

chemical interactions in agroecosystem? [§6518 m.5] 

X Microcrystalline wax: petition pages 44-101 

Paraffin: petition pages 102-157 

Petrolatum: petition pages 158-182 

Blended wax: petition pages 183-212 

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5] 

X Microcrystalline wax: petition pages 44-101 

Paraffin: petition pages 102-157 

Petrolatum: petition pages 158-182 

Blended wax: petition pages 183-212 

8. Is there a toxic or other adverse 

action of the material or its breakdown 

products? 

[§6518 m.2] 

X Microcrystalline wax: petition pages 44-101 

Paraffin: petition pages 102-157 

Petrolatum: petition pages 158-182 

Blended wax: petition pages 183-212 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X Microcrystalline wax: petition pages 44-101 

Paraffin: petition pages 102-157 

Petrolatum: petition pages 158-182 

Blended wax: petition pages 183-212 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

X Petition page 189: Fumes from molten material may cause mild 

respiratory irritation according to the MSDS. 

11. Is there an adverse effect on human 

health as defined by applicable Federal 

regulations? [205.600 b.3] 

X Petition page 40: ‘wax meets FDA requirements in 21 CFR 178.3710 

for use in non-food articles in contact with food and in 21 CFR 

172.886 for use in food.’ 

12. Is the substance GRAS when used 

according to FDA’s good 

manufacturing practices? [§205.600 

b.5] 

X Not listed on GRAS lists found in 21CFR Part 182, Part 184, or Part 

186. 

13. Does the substance contain residues 

of heavy metals or other contaminants 

in excess of FDA tolerances? 

[§205.600 b.5] 

X Petition pages 16-17, 167 

1

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

December 2006 

Category 2. Is the Substance Essential for Organic Production? _ Microcrystalline_Cheese Wax 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance formulated or 

manufactured by a chemical 

process? [6502 (21)] 

X 

Petroleum wax is derived from crude oil. The cracking process 

of crude oil refining is considered synthetic. Also, one of the 

components listed for one cheesewax product with CAS# 

9010-79-1 is listed with the EPA as ethylene-propylene copolymer which means that it is made by polymerizing 

ethylene. Also petition page 7 lists this component as 

synthetic. Formulations of cheesewax listed in petition do not 

contain this component or any colors, but do contain BHT, a 

synthetic antioxidant preservative. 

2. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring 

plant, animal, or mineral, sources? 

[6502 (21)] 

X Components CAS#’s 6472-42-3, 8009-03-08, 8002-74-2 are 

separated out of crude oil by means of solvent extraction and 

filtration. 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

X 

4. Is there a natural source of the 

substance? [§205.600 b.1] 

X 

5. Is there an organic substitute? 

[§205.600 b.1] 

X 

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 

b.6] 

X 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

X Petition page 3 says that beeswaxes are not approved by the 

FDA for use in and around food. Beeswax is vulnerable to 

removal by bees, rodents, and other insects and melts in the 

heat. 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

X . 

9. Are there any alternative 

substances? [§6518 m.6] 

 X Styrofoam plugs. 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X Not for ‘log grown’ Shiitake production. 

1

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

December 2006 

Category 3. Is the substance compatible with organic production practices? Microcrystalline Cheese Wax

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance compatible 

with organic handling? [§205.600 

b.2] 

 X 

2. Is the substance consistent with 

organic farming and handling? 

[§6517 c (1)(A)(iii); 6517 c 

(2)(A)(ii)] 

X Cheese wax is permitted on organic cheese, yet this use will 

not contact food at all. It breaks down readily in the 

environment, shows little or no harmful effects to humans and 

animals, is not toxic to soil flora and fauna, does not dissolve 

readily in water and is the best alternative of materials 

available for this use. 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

X This material makes possible a system of utilizing low value 

and culled timber to produce high quality mushrooms directly 

from trees with very little material and energy inputs 

compared to indoor sawdust-based mushroom production 

systems currently certified organic. It is an important part of 

integrated and sustainable forest management practices 

systems. 

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3] 

X 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 X 

6. Is the primary use to recreate or 

improve flavors, colors, textures, 

or nutritive values lost in 

processing (except when required 

by law, e.g., vitamin D in milk)? 

[205.600 b.4] 

 X 

7. Is the substance used in 

production, and does it contain an 

active synthetic ingredient in the 

following categories: 

a. copper and sulfur compounds; 

X 

b. toxins derived from bacteria; X 

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals? 

X 

d. livestock parasiticides and 

medicines? 

X 

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment cleaners? 

X May be considered a production aid as it is used as a sealant to 

hold in moisture and to physically hold the spawn in place. 

1

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

December 2006 

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or potentially 

unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 205.600 (c)] 

Microcrystalline Cheese Wax

Question Yes No N/A Comments on Information Provided (sufficient, 

plausible, reasonable, thorough, complete, unknown) 

1. Is the comparative description

provided as to why the non-organic 

form of the material /substance is 

necessary for use in organic handling? 

 X 

2. Does the current and historical 

industry information, research, or 

evidence provided explain how or why 

the material /substance cannot be 

obtained organically in the appropriate 

form to fulfill an essential function in 

a system of organic handling? 

X 

3. Does the current and historical 

industry information, research, or 

evidence provided explain how or why 

the material /substance cannot be 

obtained organically in the appropriate 

quality to fulfill an essential function 

in a system of organic handling? 

X 

4. Does the current and historical 

industry information, research, or 

evidence provided explain how or why 

the material /substance cannot be 

obtained organically in the appropriate 

quantity to fulfill an essential 

function in a system of organic 

handling? 

X 

5. Does the industry information 

provided on material / substance nonavailability as organic, include ( but 

not limited to) the following: 

a. Regions of production (including 

factors such as climate and number of 

regions); 

X 

b. Number of suppliers and amount 

produced; 

X 

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts that 

may temporarily halt production or 

destroy crops or supplies; 

X 

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or 

X 

e. Are there other issues which may 

present a challenge to a consistent 

supply? 

X