Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Ethylene Glycol (CAS# 107-21-1) 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action 

Guidance Statement 

Other Not list Ethylene Glycol on §205.601 

 

Statement of the Recommendation (Including Recount of Vote): 

 

The recommendation to list Ethylene Glycol on the National List §205.601 

FAILED by a vote of 14 no and 0 yes. Ethylene Glycol was classified as 

synthetic by a vote of 14 yes, and 0 no. 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

 The board found ethylene glycol to be synthetic with many alternative 

materials and practices that may be employed. See attached crops committee 

recommendation. 

 

NOSB Vote: Motion is to consider Ethylene Glycol to be synthetic. Motion 

passed. 

Moved: Jeff Moyer Second: Tina Ellor 

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

Motion is to list Ethylene Glycol on the National List §205.601. Motion Failed. 

Moved: Jeff Moyer Second: Tina Ellor 

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

December 2006

NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: __October 2010________ Substance: __Ethylene Glycol 

Committee: Crops X Livestock  Handling  Petition is for: To add Ethylene Glycol to 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 X N/A 

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

3. Compatibility & Consistency Yes  No X 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: 1,2,3___ Comments: __Material is a synthetic with many alternative materials and 

practices that may be employed and was previously listed on EPA’s list 3 inerts.

Proposed Annotation (if any): ___________________________________________________________________________

Basis for annotation: To meet criteria above: _____ Other regulatory criteria: _________ Citation:______________________

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

Ethylene Glycol be classified as synthetic for crop production______________________________________________________

Classification of the material: Synthetic ____5

D. Recommended Committee Action & Vote (State Actual Motion): _Motion is to add Ethylene Glycol to 

the National List §205.601.

Motion by: _ Jeff Moyer Seconded:_Tina_Ellor_ Yes: __0___ No: __6___ Absent: ___1____ Abstain: _____ 

____ Non- synthetic_____0______ Absent:____2___ Abstain __0__ 

Motion by: ___Keven Englebert____ Seconded:__Tina Ellor_____ 

 

1) Substance voted to be added as “allowed” on National List to § 205. 601 with Annotation (if any) ________________

______________________________________________________________________________________________________

2) Substance to be added as “prohibited” on National List to § 205. 601 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: Material

was rejected for reasons listed above and on the attached forms – alternatives already exist on the national list and practices that 

make this material unnecessary exist._______________________________________________________________________

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:

____Tina Ellor______________ ________July 26, 2010_________________

 Committee Chair Date
Decision Sheets

December 2006

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - _ Ethylene Glycol

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

TR lines 208 – 238 Millions of gallons enter the 

environment through general manufacture and 

use. This includes entry to surface water and 

soil.

3. Is the substance harmful to 

the environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X

TR lines 252 – 299 Lethal to fish, volatilizes 

into the air and is highly mobile in soil.

4. Does the substance contain 

List 1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2]

X

Ethylene glycol is being petitioned as an inert 

and was listed on the EPA list 3.

5. Is there potential for 

detrimental chemical interaction 

with other materials used?

[§6518 m.1]

X

TR lines 303 – 336 Several materials already 

on the national list of allowed synthetics have 

the potential for interaction

6. Are there adverse biological 

and chemical interactions in 

agro-ecosystem? [§6518 m.5]

X

TR lines 341 - 348 Ethylene Glycol has been 

designated an air pollutant and has the ability 

to persist in the environment for several weeks.

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X TR lines 353 – 386 Terrestrial animals are 

most susceptible yet are least likely to be 

exposed. Soil microbes are most likely to be 

exposed but are less susceptible. 

8. Is there a toxic or other 

adverse action of the material or 

its breakdown products?

[§6518 m.2]

X

TR lines 391 – 426 Ethylene Glycol is toxic to 

humans but is not listed as a carcinogen.

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment? [§6518 

m.2]

X

TR lines 431 – 445 Yes, Ethylene Glycol is 

highly mobile in the soil and breaks down at 

various rates depending on temperature and is 

broken down by microorganisms. 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4]

X

TR lines 450 – 468 Toxic to humans

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.
Decision Sheets

December 2006

Category 2. Is the Substance Essential for Organic Production? Substance – Ethylene Glycol

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 TR lines 176 - 189

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

TR lines 195 – 195 There are no natural 

sources of this material

3. Is the substance created 

by naturally occurring 

biological processes? [6502 

(21)]

X X TR lines 200 – 203 While ethylene glycol can 

be released into the soil by naturally occurring 

processes; however there are no natural 

processes that are of commercial use.

4. Is there a natural source of 

the substance? [§205.600 

b.1]

X

5. Is there an organic 

substitute? [§205.600 b.1]

X

6. Is the substance essential 

for handling of organically 

produced agricultural 

products? [§205.600 b.6]

X

 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)]

X TR lines 473 – 482 Both ethyl alcohol and 

isopropyl alcohol, already listed on the national 

list can be used as a substitute for this material.

8. Is the substance used in 

handling, not synthetic, but 

not organically produced? 

[§6517 c (1)(B)(iii)]

X

9. Are there any alternative 

substances? [§6518 m.6]

X TR lines 487 – 512 Many materials are already 

listed.

10. Is there another practice 

that would make the 

substance unnecessary? 

[§6518 m.6]

X TR lines 518 – 547 There are many cultural 

practices such as crop rotations, sanitation, 

mechanical cultivation, flaming, and use of 

materials already on the list to name a few. 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.
Decision Sheets

December 2006

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

Substance - Ethylene Glycol

Question Yes No N/A1 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 synthetic and there are many substitute 

materials and alternative practices that can be 

employed.

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

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.
Decision Sheets

December 2006

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 - _ Ethylene Glycol ________________________

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

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