Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: December 2, 2011

Subject: Docosahexaenoic acid (DHA) algal oil petition 

Chair: Tracy Miedema

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X 

Guidance Statement 

Other 

 

Statement of the Recommendation (Including Recount of Vote): 

1) Classify DHA from Algal Oil as a “nonagricultural/non-synthetic” substance 

appropriate for listing under 7 CFR §205.605(a). 

Vote: 12 Yes, 2 No. Motion carried.

2) List the petitioned substance as “DHA from Algal Oil, not hexane extracted;

other ingredients that are agricultural must be organic” to the National List at

7 CFR, §205.605(a)

Vote: 10 Yes, 4 No. Motion carried.

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

DHA algal oil was petitioned for inclusion on the National List of Approved 

Substances at §205.605, and reviewed at the November 2011 meeting. The 

Handling Committee’s recommendation is attached. 

The Handling Committee requested and reviewed a Technical Report (TR). 

The Handling Committee agreed with the TR’s finding that the substance 

could be considered a nonsynthetic, nonagricultural substance and proposed

that it be listed on the National List in its generic form, “DHA from algal oil.” 

At the November meeting, the Handling Committee presented an addendum 

to their initial proposal, regarding the “other ingredients” contained in the 

formulation. This document was modified slightly during the meeting (attached).

The Handling Committee recommendation, addendum and updated language 

for the actual listing on the National List were considered by the full board at 

the public meeting in Savannah, Georgia. The applicable statutory review 
criteria were discussed, and each of the supplemental review factors that 

guided the Handling Committee’s analysis described in the addendum were

read into the record and extensive testimony and debate was conducted.

The board discussed the findings of the TR and petition. Portions of both 

documents were read into the record as well. After discussion and vote on the 

classification of the material a motion to list the petitioned substance as “DHA 

from Algal Oil, not hexane extracted; other ingredients that are agricultural must 

be organic” was considered.

 

NOSB Votes: 

Motion to classify DHA from Algal Oil as a “nonagricultural/non-synthetic”

substance appropriate for listing under 7 CFR §205.605(a)

Moved: T. Miedema Second: K. Heinze

Yes: 12 No: 2 Abstain: 0 Absent: 0 Recusal: 0

Motion to list the petitioned substance as “DHA from Algal Oil, not hexane 

extracted; other ingredients that are agricultural must be organic” to the 

National List at 7 CFR, §205.605(a)

Moved: J. Foster Second: S. DeMuri

Yes: 10 No: 4 Abstain: 0 Absent: 0 Recusal: 0
Decision Sheets

December 2006

For NOSB Meeting: Fall 2011 Substance: DHA from Algal Oil

Committee: Crops 0 Livestock 0 Handling X Petition is for: inclusion on the National List 7

CFR, §205.605

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

1. Impact on Humans and Environment Yes X No 0 N/A 

2. Essential & Availability Criteria Yes X No 0 N/A 

3. Compatibility & Consistency Yes X No 0 N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes 0 No 0 N/A X

B. Substance Fails Criteria Category: Comments: 

C. Proposed Annotation (if any): _ not hexane extracted; other ingredients that are agricultural must be organic

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

D. Recommended Committee Action & Vote (State Actual Motion): _

Motion is list the material as a non-synthetic, designating the material for §205.605(a)

Motion by: _Tracy MIedema Seconded:_Katrina Heinze Yes: 7 No: _0 

Absent: Abstain: 

Motion is to list the petitioned material, “DHA Algal Oil” on the National List 7 CFR, §205.605(a) as “DHA from Algal

Oil, not hexane extracted; other ingredients that are agricultural must be organic

Motion by: _Tracy MIedema Seconded:_Katrina Heinze Yes: 7 No: _0 

Absent: Abstain: 

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

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

NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

Crops Agricultural Allowed1 x

Livestock Non-Synthetic x Prohibited2

Handling x Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1 Deferred4

Approved by Committee Chair to transmit to NOSB:

Committee Chair: Steve Demuri Date: December 1, 2011
Decision Sheets

December 2006

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - _ DHA from Algal Oil

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Are there adverse effects on 

environment from manufacture, 

use, or disposal? 1

[§205.600 b.2]

x The TR evaluated the petitioned substance and concluded that 

there are no adverse effects under this criterion. See TR lines

409-407 and 430-455; see also Question 2 below (statutory 

form of criterion)

2. Is there environmental

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3]

x The TR concluded that there are no adverse environmental

impacts, noting that the sole solvent used is “recycled.” See 

generally TR lines 430-455 (describing inputs, manufacturing 

process and waste byproducts); (disposal method for biomass 

substrate for algal growth “eliminates” any possibility of 

adverse environmental impact); (noting that algae are grown 

and not wild-harvested so possibility of “excessive harvesting” 

is inapplicable); (no information that algal oil production has 

“adverse impact on biodiversity”); see also lines 407-409 

(noting FDA GRAS notice reported no heavy metals or 

pesticides detected in petitioned substance)

3. Is the substance harmful to the

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i]

x See Question 2 above, citing TR lines 407-409 and 430-455

4. Does the substance contain List

1, 2, or 3 inerts?

[§6517 c (1)(B)(ii); 205.601(m)2]

x This is a substance used as an ingredient in an organic

processed food. It is not used in production and contains no 

listed inerts.

5. Is there potential for detrimental

chemical interaction with other 

materials used?2

[§6518 m.1]

x No detrimental interactions were noted in the TR. See TR

lines 123-151 (discussing combinations with substances)

6. Are there adverse biological and

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

x This is a substance used as an ingredient in an organic

processed food. It is no longer in the agro-ecosystem.

7. Are there detrimental

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

x This is a substance used as an ingredient in an organic

processed food. It is no longer in the agro-ecosystem.

8. Is there a toxic or other adverse

action of the material or its 

breakdown products? 

[§6518 m.2]

x This is a substance used as an ingredient in an organic

processed food. It is no longer in the agro-ecosystem.

9. Is there undesirable persistence

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2]

x This is a substance used as an ingredient in an organic

processed food. It is no longer in the agro-ecosystem.

10. Is there any harmful effect on

human health?

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i;

x The substance is widely added to food products, including

infant formulas, for its healthful benefits. See TR at lines 496-

524 The TR contains a chart at lines 775-776 that lists more

1 The criteria set forth in 7 CFR §205.600(b) are applicable solely to “synthetic substances used as a processing aid 

or adjuvant.” The petitioned substance is not a processing aid or adjuvant. See TR at lines 49-50 The TR 

determined the petitioned substance be a “nonsynthetic.” See TR at line 298 (“the substance should be considered

non-synthetic.”) Accordingly, the criteria listed in §205.600(b) are inapplicable to the petitioned substance. See e.g.

7 CFR §205.600(c)(“Nonsynthetics...will be evaluated using the criteria [in the OFP A].”) However, the TR 

included review of most of these questions so the results are cited out of an abundance of caution. 2 The criterion appearing at 7 U.S.C. §6518(m)(1), applies only to “interactions with other materials used in organic 

farming systems.” Because this substance is petitioned as a handling material, this criterion appears inapplicable.
Decision Sheets

December 2006

§6518 m.4] than 10 countries, including the U.S., E.U., Canada, Japan,

France, Belgium, U.K. etc. that have set reference

 of DHA for optimal health. The chart includes intake 

levels from leading organizations, such as the World Health 

Organization, World Association of Perinatal Medicine, Early 

Nutrition Academy and the Child Health Foundation.

With regard to harmful effects, the TR reported that the 

scientific literature revealed no harmful effects for adults 

except those associated with “Consumption of high levels of 

DHA (in the form of fish oil)...” See TR at lines 463-494

With regard to infant formula, no studies were cited that found 

adverse events reported to FDA have been treated as

minimis and below the threshold of regulatory significance by 

FDA. See TR at lines 463-494; See also #11 below

11. Is there an adverse effect on

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

x The petitioned substance is recognized as GRAS, and thus is

considered safe under federal law, and is defined as a food 

additive that is properly used in foods, beverages and infant 

formula. It has no adverse impact on human health when used 

under normal conditions. The TR notes that specific GRAS 

notices were submitted by Petitioner that described DHA use

levels for certain products, including infant formula and that

“The notices were reviewed by FDA and at the time of 

submission, FDA had no questions about the proposed 

supplementation levels of DHA or the rationale behind adding 

DHA to the specific food products.” See TR at lines 804-06

The TR cites reports of adverse events for adults based on 

excessive consumption via fish oil sources. See TR at lines

457-524. The safety of the substance is also evident in that 

adverse events reported to FDA regarding infant formula that 

contains DHA have been treated as de minimis and below the 

threshold of regulatory significance by the FDA See also #12 

below.

12. Is the substance GRAS when

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5]

x See e.g. TR Line 670 (“DHA Algal Oil is a substance which is

considered GRAS (FDA, 2001)”); TR lines 75-85 (citing FDA 

GRAS Notices No. GRN 000041 and No. GRN 000137) The 

GRAS notices establish that FDA has no objection to the

 DHA Algal Oil under the conditions of use. (FDA, 2001).

In addition to GRAS status, when DHA Algal Oil appears as 

an ingredient in infant formulas, the manufacturers submit 

premarket notification to FDA under section 412 of the

Federal Food, Drug, and Cosmetic Act (FFDCA). Section 412 

of FFDCA describes the more stringent statutory requirements 

that apply to infant formula as compared to the regulation of 

other foods (FDA, 2006).

13. Does the substance contain

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

x The TR concluded the available literature demonstrates no

heavy metal or other harmful residues have been detected in 

the petitioned product. See TR lines 403-424

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.
Category 2. Is the Substance Essential for Organic Production? Substance - DHA from Algal Oil

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 The TR concluded the algal oil is the product of a “naturally

occurring biological process,” line 278, but the DHA 

extraction process is a “chemical process.” See TR at 279

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 See TR line 298 (“the substance should be considered nonsynthetic.”); see also TR lines 288-292 (Applying National

Organic Standards Board (NOSB) Joint Materials and

Handling Committee draft policy: “extraction with a synthetic 

not on the National List would not result in a material being 

classified as synthetic unless either the extraction resulted in 

chemical change or the synthetic remained in the final material 

at a significant level.”)

3. Is the substance created by

naturally occurring biological 

processes? [6502 (21)]

x The TR concluded that the petitioned substance is the product

a biological process. See TR lines 278-279

4. Is there a natural source of the

substance? [§205.600 b.1]

x DHA is found in fish flesh, eggs and marine algae. See TR

lines 327-341 (noting fish, shellfish and egg sources). 

However, DHA must be extracted from the natural materials 

using extraction technologies. See TR lines 330-338 (noting 

extraction methodologies). For example, while fish oil 

appears on 7 CFR §205.606, it is not known if the processing 

necessary to obtain or isolate the DHA from fish oil renders

the final food additive a synthetic or non-agricultural, nonsynthetic under 7 CFR §205.605. See e.g. TR at line 685 

(“DHA and EPA are components of fish oil but are not 

specifically regulated” by the GRAS specifications for fish 

oil)(italics in TR)

5. Is there an organic substitute?

[§205.600 b.1]

x There are no known certified organic sources of algal oil, nor

certified organic sources of algal oil DHA. There are no 

certified organic sources of fish oil or DHA obtained from fish 

oil.

6. Is the substance essential for

handling of organically produced 

agricultural products? [§205.600 

b.6]

x 

DHA Algal Oil is the most widely used source of DHA in

infant formula. Unlike fish oil sources of DHA, DHA from 

algal oil is vegetarian, carries no risk of containing harmful 

environmental contaminants like mercury and does not deplete 

wild fish or algae stocks. See TR at lines 399-419

In addition, DHA is currently widely used in organic foods. 

Consumers, seeing products labeled as both Organic and 

containing DHA have chosen to purchase these products. 

DHA is essential for consumers to continue to have access to 

these organic products.

7. Is there a wholly natural

substitute product? 

[§6517 c (1)(A)(ii)]

x The petitioned substance is plant based non-synthetic, nonagricultural substance. There is no plant-based agricultural 

substitute for the petitioned substance..

8. Is the substance used in

handling, not synthetic, but not 

organically produced?

[§6517 c (1)(B)(iii)]

x The TR concluded the substance is a non-synthetic, nonagricultural substance. See TR line 298 (“the substance should 

be considered non-synthetic.”).

9. Are there “alternatives to using

the substance in terms of practices 

or other available materials”?

x According to the TR, there are no other plant-based sources of

DHA. See TR lines 327-341 (noting fish, shellfish and egg 

sources). Fish sources of DHA require the animals be
[§6518(m)(6)] “cooked, then strained and pressed to extract the oil and other 

liquids.” TR at line 331 The TR noted that several factors 

can cause fish oil additives to “increase fishy off-flavors in 

milk,” see TR at lines 905-907, and that the various types of 

fish oil each behave differently in formulation and several 

types of antioxidants to “prevent oxidation and development

of off-flavors” have been studied. TR at lines 910-917 Lastly, 

unlike animal-based DHA sources that require the animal be 

slaughtered, the TR notes the absence of any findings in the 

scientific literature that the algal source lessens biodiversity. 

See TR at line 455

The breadth of uses for the petitioned substance also suggests 

that another material is unlikely to always be an acceptable 

substitute—“DHA Algal Oil is as an ingredient as a source of 

DHA in foods, beverages, infant formulas, and as a dietary 

supplement. Some of the foods and products the petitioner 

lists as intended or current foods to supplement with DHA 

Algal Oil include: cookies and crackers, breads and rolls, meat 

products, condiments, beverages (including flavored milk and 

milk products, soy milk, other dairy products, and juices), 

pasta, dietary supplements, and infant formula.” See TR at 

lines 49-54.

10. Is there an “alternative[s] to 

using the substance in terms of 

practices” that would make the 

substance unnecessary? [§6518 

(m)(6)]

x The petitioned substance is a food additive and there are no

“practices” that substitute for its presence.

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

Substance - DHA from Algal Oil

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Is the substance compatible 

with organic handling? [§205.600 

b.2] 

x As noted earlier, the criteria set forth in 7 CFR §205.600(b) 

are applicable solely to “synthetic substances used as a 

processing aid or adjuvant.” The petitioned substance is not a 

processing aid or adjuvant. See TR at lines 49-50 The TR 

determined the petitioned substance be a “nonsynthetic.”

For a lengthy description of the manufacturing process of this 

substance, please See TR lines 225-272

2. Is the substance consistent with 

organic farming and handling? 

[§6517 c (1)(A)(iii); 6517 c 

(2)(A)(ii)]

x

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

x

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

x See TR line 49. (“The petitioned use of DHA Algal Oil is as 

an ingredient as a source of DHA in foods, beverages, infant 

formulas, and as a dietary supplement.”)

5. Is the primary use as a 

preservative? [§205.600 b.4]

x See TR line 49. (“The petitioned use of DHA Algal Oil is as 

an ingredient as a source of DHA in foods, beverages, infant 

formulas, and as a dietary supplement.”)

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 See TR line 49. (“The petitioned use of DHA Algal Oil is as

an ingredient as a source of DHA in foods, beverages, infant 

formulas, and as a dietary supplement.”)

7. Is the substance used in 

production, and does it contain an 

active synthetic ingredient in the 

following categories:

a. copper and sulfur compounds;

b. toxins derived from bacteria;

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals?

d. livestock parasiticides and 

medicines?

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment cleaners?

x

x 

x 

x 

x 

The substance is not used in production.

The substance is not used in production. 

The substance is not used in production.

The substance is not used in production. 

The substance is not used in 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.
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)]

Substance DHA from 

Algal Oil

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 The substance is not petitioned for inclusion on 7 CFR

§205.606

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);

b. Number of suppliers and amount

produced;

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;

d. Trade-related issues such as evidence

of hoarding, war, trade barriers, or civil

unrest that may temporarily restrict

supplies; or

e. Are there other issues which 

may present a challenge to a 

consistent supply?

x

x 

x 

x 

x 
Addendum to Handling Committee Recommendation for the Listing of DHA from 

Algal Oil

Addendum to Handling Committee Recommendation for the Listing of 

Arachidonic acid (ARA) from Fungal Oil

Following the posting of the NOSB Handling Committee unanimous 

recommendation to list DHA from algal oil and ARA from fungal oil1 to 

www.regulations.gov on October 18, 2011, and the closing of the public comment period 

on November 13, 2011, the Committee received a “Memorandum to the National 

Organic Standards Board” (“memorandum”) from the National Organic Program (“NOP”) 

dated November 15, 2011. Later the same day, the Handling Committee conducted a 

conference call during which the NOP requested that the Committee revisit its 

recommendations in light of the memorandum and supplement its findings previously 

completed and posted on www.regulations.gov.

Based on to the NOP request, the Committee has reviewed the memorandum 

and the existing record and now issues this addendum to its “Recommendation to List 

“Arachidonic acid (ARA) from fungal oil” and “DHA from algal oil” on 7 C.F.R. 

§205.605(a) This entire document is incorporated into the posted recommendations. 

The NOP memorandum requests the NOSB “develop a policy” regarding the 

“other ingredients” that are found in substances listed on 7 C.F.R. §205.605(a). 

Although the NOP proposes that review of what the memorandum refers to as “other 

ingredients” be conducted “from this point forward,” we do not understand the NOP to be 

suggesting that a policy that is not yet developed can be applied to presently pending 

matters. Nor did the NOP memorandum cite any specific provisions of the OFPA, or 

provide any analysis, that would assist in developing or implementing such evaluative 

criteria. 

The NOP did suggest two possibly relevant questions for future boards to 

consider, which we do not review here because no notice of these questions has 

previously appeared in the public record and minimal fairness and transparency 

principles forbid their consideration or imposition at this time and by this board. 

Instead we consider the NOP direction a request to make explicit that certain 

criteria are already imposed by the OFPA and 7 C.F.R. Part 205 regarding the review of 

“other ingredients” in a compound petitioned substance, and that the results of that 

review are currently only implicit in the currently posted recommendation. “Other 

ingredients” (or components of compound substances that are petitioned) that are 

allowed are those that are authorized for use in food by the following criteria that we 

make explicit here2:

(1) the National List (7 C.F.R. §§’s 205.600-606) or;

(2) mandatory federal requirements (7 U.S.C. §6519(f)) or;

(3) FDA (GRAS) or otherwise (infant formula, food additive, colors etc.) 7 

U.S.C. §6517(c) and 7 U.S.C. §6519(f) or;

 

1 The vote tally on the ARA-related petition was 6 affirmative and one absent.

2 A version of these factors appeared in the comment filed by Martek Biosciences on 

November 13, 2011
(4) EPA (7 U.S.C. §6517(c) and 7 U.S.C. §6519(f) or;

(5) any other federal regulatory agency with primary jurisdiction over that 

substance (7 U.S.C. §6519(f) or;

And any component or ingredient would be disallowed if:

(6) prohibited by federal regulatory action (7 U.S.C. §6517(d)) or;

(7) the direct product of excluded methods under (7 C.F.R. §205.105) or;

(8) contains any toxic heavy metals or toxic residues (7 U.S.C. §6510(a)) 

and; (Petition pgs. 7-8)(metals and impurities not present or removed)

(9) the component or ingredient was not disclosed in the Petition (72 Fed. 

Reg. 2168)

We note that the Petitions, Technical Reviews and our own Checklist review 

revealed that the petitioner’s manufacturing process follows a HAACP protocol, a cGMP 

protocol acceptable to the FDA and that there are no detectable residues of extraction 

solvents, pesticide residues, PCB’s or any heavy metals. Additionally, the record shows 

that, like many other products on the National List, oxidation retardants are used, and 

that the antioxidants perform no antioxidant function in final formulated food products. 

Lastly we note the processing aids identified in the petition are approved generally for 

use in food products and they are not specifically prohibited by any federal regulatory 

action, or the OFPA or 7 CFR Part 205.

In sum, based on the review criteria listed above, the following “other ingredients” 

are allowed in the petitioned substance because they respectively appear on the 

National List, or are allowed by FDA. None are prohibited by regulatory action. None 

are the product of excluded methods. None contain detectable heavy metal residues. 

Each of the “other ingredients,” listed below was fully disclosed in the petitions.

“DHA from Algal Oil”: Tocopherols, Ascorbyl palmitate, rosemary extract, high oleic 

sunflower oil, sunflower lecithin.

“Arachidonic acid (ARA) from fungal oil”: Tocopherols, Ascorbyl palmitate, citric acid, 

rosemary extract, sunflower oil.

Lastly, it is the intent of the Handling Committee that “Arachidonic acid (ARA) 

from fungal oil” and “DHA from algal oil,” upon listing on the National List, authorize 

formulations containing “other ingredients” if and only if the NOSB and NOP are 

provided notice that such materials meet the 9 criteria listed above. 

Motion that "Addendum to Handling Committee Recommendations for the Listing of 

DHA and ARA Nov 19 2011" be appended to each of the published recommendations for 

these materials. Motion made by Tracy Miedema. Seconded by Steve DeMuri Vote 5 

Yes, 1 abstain, 1 absent

.

This document is not intended to set precedent but merely to show the work that 

the Committee completed on these two materials. [statement added December 1, 

2011 and unanimously approved by Handling Committee]