Formal Recommendation 

From: National Organic Standards Board (NOSB)

To: the National Organic Program (NOP)

Date: April 2015

Subject: Petition to add 3-decene-2-one at §205.601

NOSB Chair: Jean Richardson

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: 

Guidance Statement:

Other: X 

Statement of the Recommendation (Motion #1): 

Motion to classify 3-decene-2-one as synthetic, passed. 

Statement of the Recommendation (Motion #2): 

Motion to list 3-decene-2-one at §205.601, as a synthetic substance allowed for use in organic 

crop production, failed.

 

Rationale Supporting Recommendation (including consistency with OFPA and Organic 

Regulations): 

Although not as effective as 3-decen-2-one, clove oil is listed as an alternative to the use of this 

synthetic. In addition, proper harvest, handling and cold storage techniques (to maintain 

optimal temperature, humidity, and ventilation) can also be used to help delay dormancy 

break. Therefore the NOSB found that this material does not meet the essentiality or 

compatibility criteria in OFPA. 

Committee Vote: 

Motion to classify 3-decene-2-one as synthetic

Moved: Carmela Beck

Second: Colehour Bondera

Yes: 14 No: 0 Abstain: 0 Absent: 1 Recusal: 0

Motion passed

Motion to list 3-decene-2-one at §205.601, as a synthetic substance allowed for use in organic 

crop production

Moved: Carmela Beck

Second: Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 1 Recusal: 0

Motion failed
National Organic Standards Board

 Crops Subcommittee

Petitioned Material Checklist – 3-decen-2-one

January 27, 2015

Summary of Proposed Action:

The National Organic Standards Board’s (NOSB) Crops Subcommittee received a petition from 

AMVAC Chemical Corporation to add 3-decen-2-one to the National List of Approved Substances at 

§205.601 for use as a plant growth regulator. Specifically, the petition requests approval for the use of 

the substance on potatoes as a sprout inhibitor. 3-decen-2-one is a synthetic substance used in postharvest handling of raw agricultural products. The material is manufactured using n-heptaldehyde 

(produced from castor oil) and acetone and is applied through thermal fogging in a post-harvest closed 

system storage facility.

Background:

The NOSB Crops Subcommittee found the petition submitted by AMVAC Chemical Company to be 

complete and did not request a technical report (TR). In the petition, the primary argument for listing the 

material under §205.601 is that it extends the potato shelf life, which is particularly advantageous for 

the export market. The use of 3-decen-2-one does not negatively impact the potato or the potato

processing quality, nor does it reduce sugar levels. 

Although not as effective as 3-decen-2-one, clove oil is listed as an alternative to the use of this 

synthetic. In addition, proper harvest, handling and cold storage techniques (to maintain optimal 

temperature, humidity, and ventilation) can also be used to help delay dormancy break.

Due to the availability of non-synthetic alternatives on the market, the Crops Subcommittee is in 

agreement that the material fails the essentiality, compatibility and consistency criteria and should not 

be allowed for use in organic production.

Evaluation Criteria (see attached checklist for criteria in each category)

 Criteria Satisfied? 

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

2. Essential & Availability Criteria ☐ Yes ☒ No ☐ N/A

3. Compatibility & Consistency ☐ Yes ☒ No ☐ N/A 

Substance Fails Criteria Category: 2, 3 

Subcommittee Action & Vote

Classification Motion: Move to classify 3-decene-2-one (CAS # 10519-33-2) as petitioned as 

synthetic

Motion by: Carmela Beck 

Seconded by: Colehour Bondera

Yes: 5 No: 0 Abstain: 0 Absent: 1 Recuse: 0

Listing Motion: Move to list 3-decen-2-one on section §205.601 of the National List 

Motion by: Carmela Beck 

Seconded by: Harold Austin

Yes: No: 5 Abstain: 0 Absent: 1 Recuse: 0

 
Proposed Annotation (if any): none

Approved by, Zea Sonnabend, Subcommittee Chair, to transmit to NOSB January 27, 2015

NOSB Evaluation Criteria for Substances Added To the National List - Crops 

Category 1. Adverse impacts on humans or the environment? Substance: 3-decen-2-one

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during, use or misuse? 

[§6518(m)(3)]

X Proposed indoor use only on potatoes in 

post-harvest storage. Applied by fogging, 

so environmental contamination is likely 

when fumigation chamber is opened.

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X Use according to label instructions.

Raw material acetone: extremely 

flammable and explosive. Toxic through 

inhalation, ingestion, dermal exposure to 

eye, skin, respiratory system, central 

nervous system.1 Raw material 

heptaldehyde: volatile, flammable, 

causes serious eye damage, and is 

irritating to skin and respiratory system. 

Must be treated as hazardous waste. 

Very toxic to aquatic system, with long 

term effects.2

3. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

X

4. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X Material will be used for post-harvest 

storage of potatoes; the material is not 

expected to be utilized alongside other 

materials (Petition; page 9).

5. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X No data available about most impacts. 

Toxic to aquatic life.3 May be irritating to 

skin and eyes.4

6. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X According to petition, it volatilizes.

1 http://mfc.engr.arizona.edu/safety/MSDS%20FOLDER/Acetone.pdf 2 http://img1.guidechem.com/msdspdf/111-71-7.pdf 3

http://www.sigmaaldrich.com/MSDS/MSDS/DisplayMSDSPage.do?country=US&language=en&productNumber=W353205

&brand=ALDRICH&PageToGoToURL=http%3A%2F%2Fwww.sigmaaldrich.com%2Fcatalog%2Fproduct%2Faldrich%2F

W353205%3Flang%3Den 4 http://www.bedoukian.com/product_images/mxts/613.txt 
7. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

X 3-decen-2-one is found in many common 

foods such as yogurt & tuna; the 

chemically synthesized form is approved 

as a direct food additive by the FDA & 

has been determined to be GRAS by 

FEMA (Petition; page 11) Label: Causes 

skin irritation and substantial but 

temporary eye injury. Harmful if inhaled.

8. Are there adverse biological and 

chemical interactions in the agroecosystem, including biodiversity? 

[§6518(m)(5)]

X EPA did not evaluate impacts on nontarget organisms because of the use 

pattern. Toxic to aquatic life with long 

lasting effects.5

9. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X Data not available. Exhibit I (Petition; 

page 78) pertains to human toxicology.

Category 2. Is the Substance Essential for Organic Production? Substance: 3-decen-2-one 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X

3. 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 Acetone and heptaldehyde are reactants.

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X It occurs in small quantities in some fruits 

and yogurt.

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X Not a practical one.

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X Essential oils including: clove, mint and 

caraway seed; Shortcomings include:

residual activity of oils is very short (2-3 

weeks); does not control sprouts longer 

5

http://www.sigmaaldrich.com/MSDS/MSDS/DisplayMSDSPage.do?country=US&language=en&productNumber=W353205

&brand=ALDRICH&PageToGoToURL=http%3A%2F%2Fwww.sigmaaldrich.com%2Fcatalog%2Fproduct%2Faldrich%2F

W353205%3Flang%3Den 
than .5 cm; clove oil supply recently 

erratic; potato taste can be compromised; 

multiple applications required (Petition; 

page 12); sugars spike with multiple 

applications and can turn the potato chip 

an undesirable color (Petition; page 209).

8. Are there any alternative substances? 

[§6518(m)(6)]

X Herbs, essential oils.

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X Proper harvest, handling, and storage.

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

decen-2-one

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

[§6517(c)(1)(A)(iii); 6517(c)(2)(A)(ii)]

X Synthetic preservative. Organic 

emphasizes “management practices in 

preference to the use of off-farm inputs;” 

uses “cultural, biological, and mechanical 

methods, as opposed to using synthetic 

materials.”6

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X Prevents use of potatoes for seed.

3. If used in livestock feed or pet food, is 

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X

4. If used in livestock feed or pet food, is 

the primary use as a preservative? 

[§205.600(b)(4)]

X

5. If used in livestock feed or pet food, is 

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

X

6. 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

X

toxins derived from bacteria X

6 NOSB Principles of Organic Production and Handling. October 17, 2001.
pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X

livestock parasiticides and medicines X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X