Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: 2,4,7,9-Tetramethyl-5-decyne-4,7-diol (CAS# 126-86-3) 

Chair: Daniel G. Giacomini 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action 

Guidance Statement 

Other Not to list 2,4,7,9-Tetramethyl-5-decyne-4,7-diol CAS# 

126-86-3) determined to be synthetic on the National 

List §205.601. 

 

Statement of the Recommendation (Including Recount of Vote): 

 

The recommendation is to consider 2,4,7,9-Tetramethyl-5-decyne-4,7-diol 

(CAS# 126-86-3) synthetic. The motion passed 14 yes, 0 no, no abstentions, 

no absences, and no conflicts of interest. 

The recommendation is to list 2,4,7,9-Tetramethyl-5-decyne-4,7-diol (CAS# 

126-86-3) on the National List 205.601 for use in organic agriculture. The 

motion was defeated 14 no, 0 yes, no abstentions, no absences, and no 

conflicts of interest. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

 Substance fails criteria 1 (impact on humans and environment), 2 (essential & 

availability criteria), and 3 (compatibility & consistency). Please see attached 

Crops Committee recommendation. 

 

NOSB Vote: 

To classify 2,4,7,9-Tetramethyl-5-decyne-4,7-diol (CAS# 126-86-3) as synthetic 

Moved: Barry Flamm Second: Jeff Moyer 

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

NOSB Vote: 

To add 2,4,7,9-Tetramethyl-5-decyne-4,7-diol (CAS# 126-86-3) to § 205.601 on 

the National List. 

Moved: Barry Flamm Second: Jeff Moyer 

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

 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: Fall 2010__ Substance: 2,4,7,9-Tetramethyl–5–decyne -4,7-diol__ 

Committee: Crops  Livestock  Handling  Petition is for: adding 2,4,7,9-Teramethyl -5-decyne-4,7-diol__ 

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  No  N/A 

2. Essential & Availability Criteria Yes  No  N/A 

3. Compatibility & Consistency Yes  No  N/A 

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

B. Substance Fails Criteria Category: 1, 2, 3 Comments: According to the TR material is not allowed for use in organic crop production 

by either 

EU. or Codex. See following evaluation.____________________________________________________________ 

___________________________________________________________________________________________________

C. Proposed Annotation (if any): _________________________________________________________________________ 

____________________________________________________________________________________________________ 

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

D. Recommended Committee Action & Vote, including classification recommendation (State Actual Motion): 

 To aprove 2,4,7,9-Teramethyl-decyne-4,7-diol to 205.601(m) of the National List 

Classification of the material: Synthetic ____X____ Non- synthetic_____________ Absent:_________ Abstain _____ 

Motion by: Jeff Moyer Seconded: Tina Ellor Yes: __1___ No: _5____ Absent: _1______ 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: Adverse effects 

on humans and the environment, not compatable with organic production and alternatives are available._____________________ 

___________________________________________________________________________________________________ 

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: 

______________________________________ _________________________ 

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

Category 1. Adverse impacts on humans or the environment? Substance: Tetramethyl decyne diol 

 

Question Ye

s

N

o 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 TAP lines 133-149: Trace amounts appear 

to be released to the environment via air 

and water. Potential concern from run off 

from fields after treatment. 

3. Is the substance harmful to the 

environment and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X TAP lines 169-172: slightly toxic to fish and 

aquatic invertebrates and moderately toxic 

to aquatic plants. Has long half lives. Lines 

184-5: Has ability to persist in the 

environment and interact with other 

chemicals and organic substances. Line 

204: may have detrimental physiological 

effects on soil, organisms, crops or 

livestock. 

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

inerts? [§6517 c (1 ) (B)(ii); 

205.601(m)2] 

X List 3 Inerts of unknown toxicity. List 3 now 

obsolete. 

5. Is there potential for detrimental chemical 

interaction with other materials used? 

[§6518 m.1] 

X See 3 above. Also TAP lines 198-99, if 

solubilized in an organic solvent, there may 

be additional concerns about adverse 

effects on the agro ecosystem. 

6. Are there adverse biological and chemical 

interactions in agro- ecosystem? [§6518 

m.5] 

X See 5 above. 

7. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518 m.5] 

X TAP line 204 

8. Is there a toxic or other adverse action of 

the material or its breakdown products? 

 [§6518 m.2] 

X TAP lines 204-297 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X TAP lines 184-185 

10. Is there any harmful effect on human 

health? [§6517 c (1)(A) (i) ; 6517 

c(2)(A)I; §6518 m.4] 

X TAP lines 312-329: severely irritating to 

eyes, mildly irritating to skin, inhalation may 

cause headache, drowsiness, or other 

effects to the central nervous system. 

11. Is there an adverse effect on human 

health as defined by applicable Federal 

regulations? [205.600 b.3] 

X X TAP lines 72-82, Petition: Has 3 EPA 

exemptions from the requirement of a 

tolerance when not more than 2.5% of the 

pesticide formulation. 

12. Is the substance GRAS when used 

according to FDA’s good manufacturing 

practices? [§205.600 b.5] 

 X Not approved by FDA as a food additive. 

13. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 

b.5] 

 X TAP, Petition 

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: Tetramethyl 

 

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 TAP lines 122-123,128. 

2. Is there an organic 

substitute? [§205.600 b.1] 

 X TAP 332-340: There are non-synthetic sapponins and 

microbial wetting agents on OMRI list. 

3. Is the substance essential 

for handling of organically 

produced agricultural 

products? [§205.600 b.6] 

 X TAP 332-340, 342-371: alternatives are available. 

4. Is there a wholly natural 

substitute product? 

 [§6517 c (1)(A)(ii)] 

 X Possibly. See TAP lines 332-340 

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 TAP lines 345-371: could use synethics already listed in 

205.601 

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

 X TAP lines 376-405: alternative practices such as bio 

controls, cultural measures( crop rotation, cover crops, 

sanitation,mowing,weeding,flame, pruning, mulches, 

others) natural substances, resistent varieties. 

8. Is the substance used in 

handling, not synthetic, but 

not organically produced? 

[§6517 c (1)(B)(iii)] 

 Duplicate question 

9. Is there any alternative 

substances? [§6518 m.6] 

 Duplicate question 

10. Is there another practice 

that would make the 

substance unnecessary? 

[§6518 m.6] 

 Duplicate question 

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: Tetramethyl 

 

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, and biodiversity? 

[§6517 c (1)(A)(iii); 6517 c 

(2)(A)(ii)] 

 X TAP: Wide range of known and potential adverse 

effects to biodiversity and agro ecosystem. 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

 X TAP line 184: Material is not readily biodegradable with 

ability to persist in the environment thus is not 

compatible with sustainable agriculture. 

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 - ______________________________________ 

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? 

 

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? 

 

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? 

 

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? 

 

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); 

 

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?