National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sunset 2016 Review 

NOSB Final Review

Crops Substances

April 2015

As part of the National List Sunset Review process, the NOSB has evaluated the need for the continued 

allowance for or prohibition of the following substances for use in organic crop production.

Ferric phosphate

Reference: 7 CFR 205.601 As a synthetic substance allowed for use in organic crop production 

(h) As slug or snail bait. Ferric phosphate (CAS # 10045 - 86 - 0). 

Technical Report: 07/2004; 6/2010; 07/2012 supplemental TR

Petition(s): 05/2003; 07/2009 petition to remove

Past NOSB Actions: 03/2005 - NOSB review and recommendation for addition to the National List; 

04/2010 - Recommendation to renew; 10/2012 - NOSB recommendation on petition to remove.

Recent Regulatory Background: Added to National List effective 09/12/06 71 FR 53299; Sunset renewal 

notice published 08/03/2011 76 FR 46595

Sunset Date: 9/12/2016

Subcommittee Review

NOSB Review 

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing (voting no on removal) pointed out that the substance itself has 

not been found to be harmful to human health or the environment, is the only effective control for 

mollusks, and should be reviewed on its own merits regardless of what other ingredients are formulated 

with it. Those in favor of removal brought out that the inert ingredient EDTA is not safe in their opinion, 

and that there are alternative cultural practices and control measures. The majority of the NOSB 

concluded that it meets the Criteria in the OFPA and should be renewed.

Motion to remove Ferric Phosphate (CAS # 10045–86–0) from 205.601(h) 

Motion by: Carmela Beck 

Seconded by: Colehour Bondera

Yes: 3 No: 11 Abstain: 0 Recuse: 0 Absent: 1

Outcome: Motion failed. NOSB completed its sunset review. 

Hydrogen chloride

Reference: 7 CFR 205.601 As a synthetic substance allowed for use in organic crop production 

(n) Seed preparations. Hydrogen chloride (CAS # 7647 – 01 - 0) - for delinting cotton seed for planting.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Technical Report: 2003 TAP: 5/2014 Limited Scope TR

Petition(s): 10/2002

Past NOSB Actions: 05/2004 - NOSB review and recommendation for addition to the National 

List; 11/2009 - Recommendation to renew

Regulatory Background: Added to National List effective 09/12/06 71 FR 53299; Sunset renewal notice 

published 08/03/2011 76 FR 46595

Sunset Date: 9/12/2016

Subcommittee Review

NOSB Review 

There are very few sources of cotton seed available to organic cotton farmers and all of them use an 

acid de-linting process to provide clean seed for planting. This issue also has a significant impact on 

cotton producers in other countries where there are also limited sources of seed. While there is 

continuing concern over having a very corrosive acid on the National List, it was acknowledged that an 

alternative mechanical de-linting process is not available yet and so the NOSB recommends renewing 

this on the National List because it is essential to the production of organic cotton.

Motion to remove Hydrogen Chloride, CAS # 7647-01-0, from §205.601(n) 

Motion by: Francis Thicke

Seconded by: Harold Austin

Yes: 1 No: 13 Abstain: 0 Recuse: 0 Absent: 1

Outcome: Motion failed. NOSB completed its sunset review.