Formal Recommendation 

From: National Organic Standards Board (NOSB)

To: National Organic Program (NOP)

Date: October 26, 2018

Subject: Sodium citrate - petitioned

NOSB Chair: Tom Chapman

The NOSB hereby recommends to the NOP the following:

Rulemaking Action: X

Statement of the Recommendation: The NOSB received a petition to approve sodium citrate 

as an aid used to prevent coagulation of blood in the manufacture of dried blood meal. The 

NOSB determined sodium citrate to be synthetic. The Board voted to allow this annotated use 

of sodium citrate and place it on the National List of approved synthetics for crop production.

Rationale Supporting Recommendation 

The attached recommendation is made with some reticence by the Board, since it has not 

previously reviewed and approved synthetic materials for placement on the National List that 

are used in the processing of a generic crop production material, such as blood meal. The 

Board was compelled to complete its review of the petition, despite the fact that there is no 

place on the National List for “processing aids” for crop production materials. There is concern 

that in reviewing this material it could create the assumption that every input into any 

previously approved crop production material will also have to be reviewed. Finally, the NOSB 

does not wish to create uncertainty in the classification of commonly accepted natural 

materials if it is found there might be a synthetic sub-ingredient used as a processing aid.

The NOSB would like the NOP to review sodium citrate and decide if a material, used in this 

manner to process a crop production material, needs to be placed on the National List or not. 

The Board does not consider the use of sodium citrate in the manufacture of blood meal an 

issue, and therefore unanimously approved this material. However, there is concern that there 

may be other synthetic aids used in the production of approved natural or synthetic materials. 

There is concern that listing sodium citrate may cause unwanted consequences, such as 

Materials Review Organizations ceasing approval of currently allowed materials, until these 

other synthetic production aids are placed on the National List, as well as the ambiguity of 

where this material should be listed.

NOSB Vote: 

Classification Motion: Motion to classify sodium citrate as a synthetic substance.

Motion by: Harriet Behar 

Seconded by: Emily Oakley

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recuse: 0
Listing Motion: Motion to add sodium citrate at §205.601 with the annotation “For use as an 

anticoagulant in the production of blood meal.”

Motion by: Harriet Behar 

Seconded by: Steve Ela

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recuse:0

 

Outcome: Motion Passed
National Organic Standards Board

Crops Subcommittee Petitioned Material Proposal

Sodium Citrate

June 19, 2018

Summary of Petition:

A petition was received in July 2016 for the use of sodium citrate as an anticoagulant when drying blood into 

blood meal which is then used as a crop fertility input in organic production. The petition specifically 

describes the sodium citrate as a processing aid in the production of dried blood meal. 

Summary of Review:

Sodium citrate, a salt derivative of citric acid, currently appears on the National List of approved 

synthetic substances at §205.605(b), allowed as an ingredient in or on processed products labeled as 

organic or made with organic. There is no restrictive annotation for its use in organic handling. It is 

produced microbially typically from a molasses fermentation process and then neutralized with sodium 

hydroxide and crystallized into sodium citrate. It can also be produced microbiologically directly from 

the culture of a specific strain of yeast.

To date, the NOSB has not routinely been asked to review processing aids used in the production of crop 

fertility inputs. To our knowledge (according to a spring 2017 OMRI newsletter), sodium citrate is 

currently being used to produce blood meal used in organic production (i.e., the products are OMRI 

listed). 

It is unclear if listing this material will instigate review and NOSB approval of more crop input processing 

aids. Would some materials currently in use and present on the National List no longer be allowed due 

to the presence of non-approved processing aids? In its spring 2017 newsletter, OMRI (a materials 

review organization which aids organic producers in determining allowed and prohibited materials in 

organic production) noted that if sodium citrate is approved as an anticoagulant processing aid for blood 

meal, they may feel compelled to review other anticoagulants. If other synthetic anticoagulants not 

present on the National List are used, OMRI may decide to not approve those brand name blood meal 

products as OMRI listed. It is unclear if the approval of sodium citrate as a processing aid in the drying of 

blood into blood meal as a crop fertility input would result in more processing aids being brought forth 

or disrupt the availability of other crop inputs due to the use of processing aids that are not present on 

the National List.

In discussions with the National Organic Program staff, it is still unclear where this material would 

specifically be listed on the National List, since there is no dedicated section for crop input processing 

aids and the term processing aid is not defined in the context of crop input production. It is also unclear 

if the use of sodium citrate, a synthetic, as a processing aid in the production of blood meal, would 

change blood meal from its current status as a nonsynthetic substance to a synthetic one, and therefore

blood meal (made using sodium citrate) should be placed on the National List (similar to liquid fish 

products pH adjusted with synthetic acids). The NOSB Crops Subcommittee is bringing the sodium 

citrate proposal forward for full NOSB discussion, review, and vote, and will continue to work with the 

NOP to address the issues listed above.

Specific Uses of the Substance:
Sodium citrate is routinely used to aid in the processing of blood meal to prevent coagulation. Blood will 

begin to clot soon after slaughter, making the drying of the blood into blood meal difficult to impossible. 

Keeping the blood chilled and continually agitated are mechanical methods used to slow or prevent the 

rapid clotting of the blood, but this is impractical in a commercial sense when spray drying liquid blood 

into blood meal. Canada, Codex, the European Union, Japan and IFOAM allow sodium citrate in use of 

organic processed foods, but do not specifically approve its use in organic crop production as a crop 

input manufacturing processing aid.

Approved Legal Uses of the Substance:

Sodium citrate is present on the EPA Safer Chemical Ingredient list (SCIL) and described in the Technical 

Report as a material of low concern. Sodium citrate is not currently allowed as a synthetic in organic 

crop production as a stand-alone material, and the Crops Subcommittee is presenting this proposal to 

limit its use in organic crop production to use as an anticoagulant in the production of blood meal. It is 

currently allowed as an ingredient in organic foods, typically used as a pH control, buffering agent, and 

stabilizer. Sodium citrate is present on the National List as an approved synthetic in organic processed 

foods, with no restrictions.

Action of the Substance: 

Sodium citrate acts as a chelation agent that removes the available calcium present in the blood. The 

naturally present calcium acts to allow the fibrinogen in freshly harvested blood to convert to fibrin 

which causes clotting or coagulation. Even with the use of this anticoagulant, blood must be dried fairly 

quickly after harvest. The sodium citrate is added directly to blood as it is collected in the meat 

slaughtering facility.

Manufacture:

Sodium citrate, the sodium salt derivative of citric acid, is a crystalline white powder with a melting 

point of >300o

C. Its molecular formulae are: anhydrous: C6H5O7Na3; hydrated: C6H5O7Na3·nH2O (n = 2 

or 5) or C6H5Na3O7 or C6H5O7. 3Na. It has a molecular weight of 258.08 grams/mole. A two-dimensional 

structure of sodium citrate is provided in Figure 1. Previous technical reviews for citric acid and sodium 

citrate are available on the NOP website (NOP, 2015). Sodium citrate is the sodium salt of citric acid. It is 

prepared by neutralizing citric acid with sodium hydroxide or sodium carbonate and subsequent 

crystallization. It is most commonly in the anhydrous or dihydrate forms.

Figure 1 2D Sodium Citrate Structure

(PubChem, 2017)
Category 1: Classification 

1. For CROP use: Is the substance _____ Non-synthetic or __x__ Synthetic? 

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

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

describe, using NOP 5033-1 as a guide.

Sodium citrate is produced through a chemical process, introducing sodium hydroxide or other 

synthetics to a naturally fermented citric acid. 

2. For CROPS: Reference to appropriate OFPA category:

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

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

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

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

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

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

the Environmental Protection Agency as inerts of toxicological concern?

Sodium citrate may fall within the OFPA production aid category. Sodium citrate is not a 

synthetic inert ingredient of toxicological concern.

Category 2: Adverse Impacts 

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

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

The technical report (TR) does not identify any detrimental chemical interactions with other 

materials used in organic farming systems. It is currently approved for use with no restrictions 

as an ingredient in organic foods. 

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

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

[§6518(m)(2)]

The TR states “Sodium citrate is of low acute toxicity to freshwater fish, daphnia, algae and 

marine species. Similarly, sodium citrate has no obvious toxic potential against protozoans and 

many species or strains of bacteria including activated sludge micro-organisms (EPA, 1992; 

OECD, 2001).“

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

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

The production of sodium citrate (biological fermentation process) results in waste byproducts. The agricultural byproducts can be composted, and the acidic wastewater can be 

treated through a variety of wastewater treatment systems. No toxic environmental 

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

§6518(m)(4)].

As petitioned, there are no effects expected on human health, the TR states any remainder of 

the sodium citrate in the blood meal is expected to become a metabolite of soil bacteria. 

Organic farmers or consumers would not be in contact with sodium citrate. Workers in

processing facilities might experience irritation to the eyes and skin when handling sodium 

citrate.

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

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

(including the salt index and solubility of the soil), crops and livestock. [§6518(m)(5)] 

The TR did not note any negative effects associated with the low concentration of sodium 

citrate found in blood meal used as a fertility input in organic production. The many benefits of 

blood meal as a crop fertilizer were noted.

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

The TR states citric acid is found naturally in soil and water, and sodium citrate readily degrades 

when in contact with soil microorganisms. There is low toxicity to aquatic environments, and no 

negative effects upon terrestrial ecosystems and animals.

Category 3: Alternatives/Compatibility 

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

The Crops Subcommittee asked for further detail to explore alternatives to the use of this

 synthetic in the production of blood meal. The TR notes that none of the mechanical methods 

were practical for spray drying since this process involves spraying a fine, uniform mist and any 

coagulation interferes with the process. However, there are blood meal products that do not use

sodium citrate, but they may not have the same uniformity or other beneficial characteristics of 

products that are spray dried.

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

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

The Crops Subcommittee discussed this issue in detail and found sodium citrate to be compatible 

with a system of sustainable agriculture. It is currently approved for use with no restrictions as 

an ingredient in organic foods. The TR states citric acid is found naturally in soil and water, and 

sodium citrate readily degrades when in contact with soil microorganisms. The TR did not note 

any negative effects associated with the low concentration of sodium citrate found in blood meal 

used as a fertility input in organic production. The many benefits of blood meal as a crop 

fertilizer were noted and sodium citrate is an important aid in the manufacture of blood meal.
Classification Motion:

Motion to classify sodium citrate as a synthetic substance.

Motion by: Harriet Behar

Seconded by: Emily Oakley

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

National List Motion:

Motion to add sodium citrate to §205.601 with the annotation “For use as an anticoagulant in the 

production of blood meal.”

Motion by: Harriet Behar

Seconded by: Emily Oakley

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

Approved by Steve Ela, Crops Subcommittee Chair, to transmit to NOP August 22, 2018