Formal Recommendation 

From: The National Organic Standards Board (NOSB)

To: The National Organic Program (NOP)

Date: October 28, 2022

Subject: Potassium Hydroxide 

NOSB Chair: Nate Powell-Palm

The NOSB hereby recommends to the NOP the following: 

No Action

Statement of the Recommendation: 

The NOSB recommends that potassium hydroxide not be added to the National List as a processing aid 

at § 205.601.

Rationale Supporting Recommendation: 

The NOSB, with the support of a majority of stakeholders, determined that there is no need to add 

another synthetic processing aid to the National List when alternatives to processing fish for fertilizer 

are already available. 

NOSB Vote: 

Classification 

Potassium hydroxide is on the National List, and already classified as synthetic. 

National List Motion 

Motion to add potassium hydroxide to the National List as a processing aid at § 205.601 

Motion by: Rick Greenwood 

Seconded by: Jerry D’Amore 

Yes: 2 No: 13 Abstain: 0 Recuse: 0 Absent: 0 

Motion Failed
National Organic Standards Board

Crops Subcommittee

Petitioned Material Proposal

Potassium Hydroxide as a production aid in the production of

liquid fish products

July 20, 2022

Summary of Petition:

The petition states that the intent is to use potassium hydroxide as a processing aid to facilitate 

emulsion of the invasive carp species to help support extraction of soluble organic compounds from the 

fish by means of alkaline hydrolysis. The petitioner states that the amount of potassium hydroxide used 

should be limited to the amount necessary for emulsion of the fish and once the process is completed 

phosphoric acid will be used to stabilize the product.

Summary of Review:

Potassium hydroxide is already on the National List and is allowed as a processing aid for the extraction 

of aquatic plant extracts (per 7 CFR 205.601(j)(1)) and humic acids (per 7 CFR 205.601(j)(3)). It is also 

allowed for extraction and emulsion of algae and its use has been thoroughly reviewed when it was 

added to the National List. 

Category 1: Classification 

1. For CROP use: Is the substance Non-synthetic or X Synthetic?

 Is the substance formulated or manufactured by a process that chemically changes a substance 

extracted from naturally occurring plant, animal, or mineral sources? [OFPA §6502(21)] If so, 

describe, using NOP 5033-1 as a guide. 

 

Potassium hydroxide is a synthetic substance allowed for use in organic crop production (7 CFR 

205.601).

2. Reference to appropriate OFPA category:

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; toxins derived from 

bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicines and production aids including netting, tree wraps 

and seals, insect traps, sticky barriers, row covers, and equipment cleansers; or (ii) is used in 

production and contains synthetic inert ingredients that are not classified by the Administrator 

of the Environmental Protection Agency as inerts of toxicological concern?

The petitioner is requesting that potassium hydroxide be added to 7 CFR 205.601(j)(4) as a 

synthetic substance allowed for use in organic crop production to be used as a production aid 

for the emulsion of invasive carp to produce a liquid fish product. 

Category 2: Adverse Impacts 

1. What is the potential for the substance to have detrimental chemical interactions with other 

materials used in organic farming systems? [§6518(m)(1)]
Potassium hydroxide is added to a reactor vessel along with fish and water, agitated with heat,

and eventually stabilized (neutralized) with phosphoric acid. The potential for chemical 

interactions with other materials is negligible.

2. What is the toxicity and mode of action of the substance and of its breakdown products or any 

contaminants, and their persistence and areas of concentration in the environment? 

For the petitioned use there will be no environmental contamination since the product will be 

neutralized before it is used in the environment.

 3. Describe the probability of environmental contamination during manufacture, use, misuse, or 

disposal of such substance? [§6518(m)(3)]

The probability that there could be environmental contamination during the manufacture of the 

liquid fish product is minimal because the reaction takes place in an enclosed reaction vessel. 

4. Discuss the effect of the substance on human health. [§6517(c)(1)(A)(i); §6517(c)(2)(A)(i); 

§6518(m)(4)].

Potassium hydroxide is a caustic chemical and can cause skin damage, but in this use there is 

little chance for human exposure except during the manufacturing process. Potassium 

hydroxide has been reviewed by the FDA (21 CFR 184.1631).

5. Discuss any effects the substance may have on biological and chemical interactions in the 

agroecosystem, including the physiological effects of the substance on soil organisms (including 

the salt index and solubility of the soil), crops and livestock. [§6518(m)(5)]

Potassium hydroxide is used to raise the pH as part of the fish emulsion process but is 

neutralized when the liquid fish product is produced so no change in soil pH would be expected. 

Minor amounts of potassium would be added to the soil but in levels that would not be 

expected to change biological or chemical interactions in the soil agroecosystem.

6. Are there any adverse impacts on biodiversity? (§205.200) 

At the rates this substance is applied, no adverse impacts on biodiversity are expected.

Category 3: Alternatives/Compatibility 

1. Are there alternatives to using the substance? Evaluate alternative practices as well as nonsynthetic and synthetic available materials. [§6518(m)(6)]

Potassium hydroxide is the preferred chemical for raising pH and is commonly used in 

agriculture, fertilizer, and food products. It is also listed by OMRI in numerous products. 

Sodium hydroxide could be an alternative but can be harmful to plants because of increased 

sodium levels. Lithium hydroxide could be an alternative but would be harmful to the 

environment due to the toxicity of lithium. 

2. In balancing the responses to the criteria above, is the substance compatible with a system of 

sustainable agriculture? [§6518(m)(7)]

Yes. The end product, fish emulsion (liquid fish products), is widely used by organic farmers and 

has been recognized for years as being a beneficial fertilizer. This process will allow an invasive 

species of fish to be used in a beneficial way for organic agriculture. However, the
Subcommittee had remaining questions about the need to add this to the National List for just 

this specific fish (invasive carp species).

Classification 

Potassium hydroxide is on the National List, and already classified as synthetic.

National List Motion

Motion to add potassium hydroxide to the National List as a processing aid at 205.601 

Motion by: Rick Greenwood

Seconded by: Jerry D’Amore

Yes: 6 No: 1 Abstain: 0 Recuse: 0 Absent: 1