NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: Fall 2012, Savannah, GA Substance: Odorized propane

Committee: Crops X Livestock  Handling  Petition is for: addition of odorized propane on the National List 

§ 205.601.

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  No x 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: 2 Comments: Majority of CC members believe adequate alternatives exist and questioned 

the materials efficacy.

C. Proposed Annotation (if any): _________________________________________________________________________ 

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

D. Recommended Committee Action & Vote (State Actual Motion): To amend the National List, Synthetic substances allowed 

for use in organic crop production, § 205.601(g)(3) – Rodenticides, to include odorized propane as petitioned.

Motion by: John Foster Seconded: Tina Ellor Yes: 3 No: 4 Absent: _______ Abstain: _____ 

 

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 § 205.601. Describe why material was rejected: Majority of 

 CC members believe adequate alternatives exist and did not believe the material to be effective.

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 x

No restriction Commercially UnAvailable as Organic1

 

Deferred4

E. Approved by Committee Chair to transmit to NOSB:

John Foster 10/7/11

Committee Chair Date
EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance: Odorized Propane

Question Yes No N/A

1

Documentation

(TAP; petition; regulatory agency; other)

1. Are there adverse effects on environment 

from manufacture, use, or disposal? 

[§205.600 b.2] 

x

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3] 

x x Long term no, short term yes, and then 

when misused or mishandled. 

TR 250

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

x See #2 above.

4. Does the substance contain List 1, 2, or 3 

inerts? [§6517 c (1 ) (B)(ii); 

205.601(m)2] 

x Given the EPA’s reclassification of inerts.

5. Is there potential for detrimental chemical 

interaction with other materials used? 

[§6518 m.1] 

x TR 265. Other than flammability with 

oxygen, no interactions between propane 

and other common substances used in 

agriculture were identified.

6. Are there adverse biological and chemical 

interactions in agro- ecosystem? [§6518 

m.5] 

x TR 276. These are highly localized and 

not persistent.

7. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518 m.5] 

x TR 276. These are highly localized and 

not persistent.

8. Is there a toxic or other adverse action of 

the material or its breakdown products? 

[§6518 m.2] 

x TR 276. These are highly localized and 

not persistent.

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

x TR 276. These are highly localized and 

not persistent.

10. Is there any harmful effect on human 

health? [§6517 c (1)(A) (i) ; 6517 

c(2)(A)I; §6518 m.4] 

x Not when used as directed. TR 276. 

These are highly localized and not 

persistent. 

11. Is there an adverse effect on human 

health as defined by applicable Federal 

regulations? [205.600 b.3] 

x

12. Is the substance GRAS when used 

according to FDA’s good manufacturing 

practices? [§205.600 b.5] 

x

13. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 

b.5]

x

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 Odorized propane

Question Yes No N/A

1

Documentation

(TAP; petition; regulatory agency; other)

1. Is there a natural source of 

the substance? 

[§205.600 b.1] 

X

2. Is there an organic 

substitute? [§205.600 b.1] 

X

3. Is the substance essential for 

handling of organically 

produced agricultural 

products? [§205.600 b.6] 

X

4. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

x

5. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

x

6. Is there any alternative 

substances? [§6518 m.6] 

x However none of them have acceptable 

availability, applicability, functionality or efficacy. 

TR 316

Pet. pg. 7

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

x Tillage, flooding, long-term fallow, smoke bombs, 

biological controls, removal of food, CO2, 

anticoagulants, trapping

TR 312, 338

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)]

x See #5 above

9. Is there any alternative 

substances? [§6518 m.6]

x See #6 above

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6]

x See #7 above

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 Odorized propane

Question Yes No N/A

1

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 It is a physical control, consistent with preferred pest 

control methodologies; propane is currently in use as 

vertebrate deterrent and fuel for thermal weed control. 

The material was allowed by the majority of private 

certification standards pre-NOP and was allowed 

under the NOP until 2007, when the substance was 

summarily prohibited pending successful petition and 

inclusion on the National List. (Petition+TR)

3. Is the substance compatible with 

a system of sustainable 

agriculture? [§6518 m.7] 

x See above.

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

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: Odorized propane

Question Yes No N/A

1

Documentation

(TAP; petition; regulatory agency; other)

1. Is the comparative description 

provided as to why the nonorganic 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 

non-availability 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
National Organic Standards Board

Crops Committee 

Proposed Recommendation

Odorized Propane

October 7, 2011

List: § 205.601 Synthetic substances allowed for use in organic crop production

(g) As rodenticides.

California Certified Organic Farmers, Inc. (CCOF) is petitioning to have odorized propane used 

in devices for control of burrowing pest animals added to the National List § 205.601, 

Synthetics for use in crop production.

In its pure form, (C3H8) propane is an odorless gas, but may also be compressed into a liquid

(often called LPG). It is a constituent of natural gas and of crude petroleum, is isolated from 

these sources by a “stabilization process” using fractional distillation under pressure, and is 

highly flammable. It is readily available for home, transportation, farm, commercial, and 

industrial uses. Propane is not currently listed as an allowed substance for organic crop 

production under 7 CFR § 205.601. However, heat methods (fueled with propane) are allowed 

to control weeds and propane is used to create above ground explosions to deter birds and 

other vertebrate pests from orchards, vineyards, and berry farms previous to and through 

harvest. It is a physical control, consistent with preferred pest control methodologies. Prior to 

NOP implementation, the substance was allowed by multiple private certification standards

and was allowed under the NOP until 2007, when the substance was summarily prohibited 

unless and until successfully petitioned and included on the National List.

The propane is mixed with oxygen and is exploded underground, causing a rapid expansion of 

gases that leads to concussive force that kills burrowing pest animals, with accompanying 

suffocation from consuming all the oxygen in the tunnel. The mixture is approximately 2%

propane to 98% compressed oxygen, and the mixture is injected into the burrow for up to one 

minute before it is ignited. The Crops Committee has received a new Technical Report on this 

material and this has been posted by the Program for the Crops Committee, NOSB, and public 

review. 

The Committee discussed the placement of this material on § 205.601, noting this is somewhat 

atypical given that the material’s efficacy is accomplished by physical action, either as an 

agent of concussive force or as an agent of oxygen displacement, either of which are physical 

control methods in common IPM parlance. The Committee discussed the possibility of creating 

a new subsection, § 205.601(o) – Pest control production aids, consistent with an option 

identified in the TR, line 171. The intent with that listing would be to provide a place on the 

National List for synthetic substances which are used up in their application and not present 

after the fact, somewhat analogous to processing aids used on food handling. While propane 

itself as applied is not a rodenticide, the Committee discussed the merits of classifying it under 

§ 205.601(g) - Rodenticides. One Committee member felt strongly that propane should not be 

identified as a rodenticide per se, but ultimately agreed in framing the recommendation to 

place the material under § 205.601(g) in the interests of collaboration and consensus and 
Page 2 of 3

Odorized Propane on §205.601

October 7, 2011

recognized that in fact the intended use was to control, in the main, rodents. Standards in 

Canada, EU and Japan either a) allow or b) do not prohibit the use of propane in organic 

production systems.

The Committee noted there are legitimate concerns over collateral damage from this method 

on endangered species. The Crops Committee wishes to make it clear to all concerned that 

use of the propane in a manner that violates the Endangered Species Act is a federal crime; 

the presumably provides adequate disincentive for such misuse.

In discussions, some members thought that this material was preferable to chemical controls 

currently allowed for use in organic production since it leaves no residue and complies with the 

mandates of § 205.206 which require that physical or mechanical controls be attempted prior 

to use of chemical controls. Other members felt that its use was unnecessary given the

alternatives available for use, with discussion as to the applicability, efficacy, and functionality 

of those alternative methods. Allowed alternative methods discussed included flooding with 

water, a vacuum, CO2, vitamin D3 baits, smoke bombs, and several cultural practices listed 

under § 205.206(a). Some members also questioned the efficacy of propane for the petitioned 

use. There was again discussion about the utility of these practices across the wide range of 

crops, conditions and environments where propane had been used under pre-NOP private 

certification standards and under the NOP, until 2007 and whether that was an appropriate 

criterion on which to base a decision.

Another relevant discussion item was that propane is currently allowed in organic production 

as a physical control agent to kill weeds by heat and flame and is presently and widely used in 

many crops and conditions in that capacity. It is also used for fuel in so called “propane 

cannons” to generate loud explosions that deter wildlife from crops around harvest time, 

generally in and around perennial crops such as orchards, vineyards and cane berries. The 

Committee understands that both uses are allowed under the NOP as they are considered 

physical pest control methods.

The Committee recognized that if this material is included on the National List, an organic 

operator would still have to demonstrate that cultural practices (repellants, rotations, irrigation 

management, etc.) and non-synthetic physical practices (trapping, etc.) have been determined 

to be inadequate prior to using this management method on organic farms. In other words, the 

inclusion of propane on the National List would not affect the obligation to abide by § 205.206.

With those discussions had, the majority of the Crops Committee voted not to recommend 

odorized propane be included on the National List.

Committee Recommendation

The Crops Committee voted on the recommendation for propane to be added to the National 

List. The motion was as follows: To amend the National List, Synthetic substances allowed for 

use in organic crop production, § 205.601(g)(3) – Rodenticides, to include odorized propane 

as petitioned.
Page 3 of 3

Odorized Propane on §205.601

October 7, 2011

Committee Vote

Motion: John Foster Second: Tina Ellor

Yes: 3 No: 4 Abstain: 0 Absent: 0