Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Wednesday January 9, 2013 2:00 pm EST 

Present: Jay Feldman (Chair) (JFe), Nick Maravell (NM) (Vice Chair), Zea Sonnabend (ZS), Carmela Beck (CBe), John Foster 

(JFo), Colehour Bondera (CBo), Mac Stone (MS), 

Absent: Harold Austin (HA), Barry Flamm (BF)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Begin review fall 2013 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS? 8/2006 TR

No new 

TR

Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Petitioned Substances – Current status of review process

Name Conta

ct

TR

requested

?

Vote 

Date

Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

Proposal. List at §205.601

HA/ZS Yes

9/2012 TR

Petition sent to CS on 3/19. Request 

for TR 4/3/12. Draft TR sent to CS 

07/13. Add’l questions sent from CS 8-

15-12. TR deemed sufficient 11 20 12.

Spr 2013

Name Conta

ct

TR

requested

?

Date of 

vote

Notes* Meeting
Petitioned Substances – Current status of review process

Vinasse - proposal. List at

§205.601

NM Yes. 

Quick, 

modified 

TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. Delayed TR

- will move to fall. 

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

HA/ZS No

4/2011 TR

Sent to CS on 06 19 11; Needs petition 

sufficiency review. TR deemed 

sufficient

Spr 2013

Antibiotics (Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back again 

for incompleteness. 

Spr 

2013?/Fall 

2013

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will rqst 

modification from petitioner (for use 

pattern). Updated petition was deemed 

sufficient. TR deemed unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. Petition 

sufficiency response due 08 08 12? CS 

sent request to NL Mgr 12 04 for 

additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 TR Petition sent to CS on 07 03 12. Petition 

Sufficiency Response due 09 04 12. CS 

sent request to NL Mgr 12 04 for 

additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 12. Petition 

Sufficiency Response due 08 06 12. 

Petition deemed insufficient 12 04 12. 

N/A

Indole-3-butyric acid (IBA)

2012. List at §205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 TR

No new 

TR rqstd

12/2011 Final Recomm. Petition sent to 

CS on 11 02 12. Petition found 

sufficient 12 18 12. No TR rqst

Spr 2013

Inert Ingredients

Inerts update JFe/ZS Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013
Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On 

hold

Waiting to comment on rulemaking

Food safety On 

hold

On hold

Fire blight (Tree fruit) HA On 

hold

On hold

GMO - seed purity ZS Disc doc 

10/2012

Joint with GMO ad hoc Subcommittee Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS Joint with GMO ad hoc Subcommittee Spr 2013

* Yellow highlight indicates committee action needed

Crops Subcommittee work assignments for spring 2013 NOSB meeting:

HA: Polyoxin D Zinc Salt; tetracycline petition (with ZS); streptomycin petition –sent back to petitioner by NOP with 

questions, waiting (with ZS) 

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid – Sunset 2015 material at 601(j)

JFe: Inerts (with ZS); aqueous potassium silicate – Sunset 2015; 3. Seed Purity –in conjunction with Ad hoc GMO subcmte 

(with ZS, CBo); Plant Breeding –in conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate; indole-3-butyric acid (IBA) petition for reconsideration

NM: Vinasse; Carbon Monoxide/Exhaust Gas

ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate – Sunset 2015; tetracycline petition (with HA); streptomycin 

petition –sent back to petitioner by NOP with questions, waiting (with HA)

Agenda 
• Approve agenda 

• Approve December 18, 2012 subcommittee meeting notes

• Tetracycline petition (HA and ZS) – review checklist

• IBA recap and vote

• Check-Ins/Recap/TR response time?

o Polyoxin D Zinc, petitioner response? (HA)

Vinasse (NM)

Carbon Monoxide/Exhaust Gas (NM)

Inerts (JFe, ZS)

Aquaculture Vitamins (B1, B12, and H) (CBe)

Aquaculture: CO2 (CBo and ZS)

• Do leads for sunset materials believe an updated TR is needed to conduct review? (Take questions by email as 

follow up): (i) Aqueous potassium silicate – Sunset 2015 (JFe) – see attached questions in checklist format, (ii) 

Sodium carbonate peroxyhydrate – Sunset 2015 (ZS), (iii) Sulfurous Acid – Sunset 2015 material (CBo)

• (If time allows) Aquaculture thoughts after policy briefing and what CS would like to see as follow up

• Next Meeting

• Adjourn 

Discussion

• The agenda was approved with no changes except ZS noted she is not ready to discuss Aquaculture - CO2.

• December 18, 2012 subcommittee meeting notes were approved with no changes

• Tetracycline petition (HA and ZS). The intent of the proposal is to recap the history of the substance and the 

original review and to look at the more recent research available and fill in any gaps. The group discussed 

proposing an extended phase-out on the expiration date of 2017 and an annotation to require growers to use 

alternatives. The proposal and annotation are not written yet, as the members are still gathering info. SJK added 

that an annotation may not be necessary, as it could be part of the preamble or guidance, but ZS noted that the

preference is to have it in the annotation at the outset, for the purpose of enforceability. ZS and HA plan to have 

an annotation written for the next meeting. The consensus is that tetracycline needs to be phased out but the 

Board is cognizant of consumers and growers, and would advocate for a longer phase out period. A member

asked about alternatives, and how this situation was different than what was already in the regulation. ZS 

replied that they would like to specify amounts instead of only including vague language about “trying to use 

alternatives” with the intent of preparing growers for the elimination of antibiotics by 2017. A member 

cautioned the group about the difference between an accreditation problem versus the regulation at § 605.206, 

when the regulation is adequate. JFe asked if JFo would be willing to write some language summarizing this for 

inclusion in the checklist. Another member in support of not adding lengthy annotations noted that this notion is 

similar to the pasture rule, whereby there were unseen implications of becoming too prescriptive. JFe asked 

that the group continue the discussion via email if there is a need to discuss further. ZS asked that people help 

contribute to the annotation. Additional info is requested by Monday afternoon, Jan 14

• Members discussed aquaculture and the path forward for preparing their review. JFe will work on questions, 

and MS suggested talking with Max Mayeaux of the USDA to clarify some topics. The group is hoping to have a 

series of seminars to elucidate some of the points that were not addressed on the aquaculture call last week. JFe

asked about TR requests for the aquaculture materials and if the group felt they could be ready in the next 30 

days. SJK asked about sending Max Mayeaux an example of a TR and Supplemental TR so he can evaluate how 

the questions may need to be altered in the context of an aquaculture production system, so the Subcommittee 
can determine if they are asking the right questions. ZS asked how aquatic plants are different from 

hydroponics, and suggested that this needs to reevaluated for consistency. 

• Aqueous potassium silicate: The chair asked if the group felt that they should go forward with a TR. A checklist 

was circulated for review with the agenda.

• Sulfurous acid: The lead person recommended a TR request for this material

• Sodium carbonate peroxyhydrate: The lead person noted that they have adequate information for the review 

and would not recommend requesting a new TR. JFe asked if the checklist could be ready for the Jan 15 meeting.

• IBA. There is new information in the petition, but it was difficult to find, so JFo will re-circulate the checklist with 

the hope that the group can vote on this during the next meeting (Jan 15)

• Adjourned

• ABS note: The table above was altered to reflect the new target meeting date for the aquaculture petitions.

Future Call Schedule:

January 9, 2013 2:00 EST

Vote on IBA - postponed until next meeting

Determine Sunset TRs

January 15, 2013 2:00 EST

Vote on IBA 

Discuss/vote Tetracycline proposal and checklist

Discuss checklist for sodium carbonate peroxyhydrate 

February 5, 2013 2:00 EST

February 19, 2013 2:00 EST

March 5, 2013 2:00 EST

March 19, 2013 2:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Wednesday January 15, 2013 2:00 pm EST 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Carmela Beck (CBe), John Foster (JFo), Colehour Bondera (CBo),

Harold Austin (HA), Barry Flamm (BF)

Absent: Mac Stone (MS), Nick Maravell (NM) (Vice Chair)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Begin review fall 2013 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS? 8/2006 TR

No new 

TR

Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Petitioned Substances – Current status of review process

Name Conta

ct

TR

requested

?

Vote 

Date

Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

Proposal. List at §205.601

HA/ZS Yes

9/2012 TR

Petition sent to CS on 3/19. Request 

for TR 4/3/12. Draft TR sent to CS 

07/13. Add’l questions sent from CS 8-

15-12. TR deemed sufficient 11 20 12.

Spr 2013

Name Conta

ct

TR

requested

?

Date of 

vote

Notes* Meeting
Petitioned Substances – Current status of review process

Vinasse - proposal. List at

§205.601

NM Yes. 

Quick, 

modified 

TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. Delayed TR

- will move to fall. 

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

HA/ZS No

4/2011 TR

Straw 

poll 01 

15 13

Sent to CS on 06 19 11; Needs petition 

sufficiency review. TR deemed 

sufficient

Spr 2013

Antibiotics (Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back again 

for incompleteness. 

Spr 

2013?/Fall 

2013

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will rqst 

modification from petitioner (for use 

pattern). Updated petition was deemed 

sufficient. TR deemed unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. Petition 

sufficiency response due 08 08 12? CS 

sent request to NL Mgr 12 04 for 

additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 TR Petition sent to CS on 07 03 12. Petition 

Sufficiency Response due 09 04 12. CS 

sent request to NL Mgr 12 04 for 

additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 12. Petition 

Sufficiency Response due 08 06 12. 

Petition deemed insufficient 12 04 12. 

N/A

Indole-3-butyric acid (IBA)

2012. List at §205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 TR

No new 

TR rqstd

12/2011 Final Recomm. Petition sent to 

CS on 11 02 12. Petition found 

sufficient 12 18 12. No TR rqst

Spr 2013

Inert Ingredients

Inerts update JFe/ZS Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013
Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On 

hold

Waiting to comment on rulemaking

Food safety On 

hold

On hold

Fire blight (Tree fruit) HA On 

hold

On hold

GMO - seed purity ZS Disc doc 

10/2012

Joint with GMO ad hoc Subcommittee Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS Joint with GMO ad hoc Subcommittee Spr 2013

* Yellow highlight indicates committee action needed

Crops Subcommittee

Work Assignments, Draft Agenda (January 15, 2013/2:00pmEST meeting), Action Items

Crops Subcommittee work assignments for Spring 2013 NOSB meeting:

HA: Polyoxin D Zinc Salt; tetracycline petition (with ZS); streptomycin petition –sent back to petitioner by NOP with 

questions, waiting (with ZS) 

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid – Sunset 2015 material at 601(j)

JFe: Inerts (with ZS); Aqueous potassium silicate – Sunset 2015; 3. Seed Purity –in conjunction with Ad hoc GMO 

subcmte (with ZS, CBo); Plant Breeding –in conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate; indole-3-butyric acid (IBA) petition for reconsideration

NM: Vinasse; Carbon Monoxide/Exhaust Gas (sent back to petitioner)

ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate – Sunset 2015; tetracycline petition (with HA); streptomycin 
petition –sent back to petitioner by NOP with questions, waiting (with HA)

Agenda 

• Approve agenda

• Approve January 9, 2013 subcommittee meeting notes

• Tetracycline petition (HA and ZS) – review checklist and vote

• IBA (JFo) – additional thoughts and vote

• Polyoxin D Zinc (HA) – update and next steps

• Sodium carbonate peroxyhydrate – Sunset 2015 (ZS) – TR necessary?

• Next Meeting

• Adjourn

Discussion

• The agenda was approved with no changes 

• January 9, 2013 Subcommittee meeting notes were approved with a note to the ABS that one of the links in the 

workplan table above was not working.

• HA summarized the Tetracycline petition and proposal and the group discussed various aspects. There were 

several changes made to the document since the last call, including the separation of the discussions of apples 

(expiring in 2017) and pears (remove expiration date). Since the organic pear industry is much more vulnerable 

than that of apples (if tetracycline is prohibited, virtually the entire organic pear industry will disappear from the 

market), the group felt this was the best way to discuss/review them. The default motion would be to include 

the 2017 expiration date for both apples and pears. Topics that were discussed include: annotations, which a 

member thought might be redundant (i.e. pest control and alternatives); the intention of the proposal and if it 

would be required to label pears as antibiotic free, which was not something that was considered when writing 

the proposal; and the historical context from past Board deliberations. ZS indicated that the current Board is in a 

better position to make an informed decision The NOP asked about the way forward for a grower if all of the 

alternatives are exhausted, to which a member replied that this scenario would not occur because there are 

many variables that can be adjusted from year to year. The NOP asked for clarification about the motions that 

would be included in the proposal, and asked that the members consider how things would proceed for voting. 

The chair indicated that he would like to take a straw vote today and continue to work on the document before 

taking an official vote. A member asked for clarification of the motion, since it is complicated. For example, are 

there implications from removal of the expiration date?

 

 Straw vote tetracycline for pears: Yes: HA, CBe, JFo, ZS No: CBo, BF, JFe, NM

Straw vote: tetracycline for apples: Yes: HA, CBe, JFo, ZS, No: CBo, BF, JFe, NM

ZS added that a different annotation might result in a different outcome, and requested that the others who 

cast a no vote weigh in with any suggestions. BF will send around some language from the last Board 

recommendation.

• The group did not have time to discuss the remainder of the agenda items, so MA added an additional call on 

Jan 29

Future Call Schedule:
January 9, 2013 2:00 EST

Vote on IBA - postponed until next meeting

Determine Sunset TRs

January 15, 2013 2:00 EST

Vote on IBA -postponed 

Discuss/vote Tetracycline proposal and checklist -postponed

Discuss checklist for sodium carbonate peroxyhydrate 

January 29, 2013 2:00 EST – additional call

Vote on IBA 

Final discussion/vote on Tetracycline proposal and checklist

Discuss checklist for sodium carbonate peroxyhydrate 

February 5, 2013 2:00 EST

February 19, 2013 2:00 EST

March 5, 2013 2:00 EST

March 19, 2013 2:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes – Additional call

Tuesday January 29, 2013 2:00 pm EST 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Carmela Beck (CBe), John Foster (JFo), Colehour Bondera (CBo),

Harold Austin (HA), Mac Stone (MS), Nick Maravell (NM) (Vice Chair), Francis Thicke (FT) 

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contact Technical 

Report 

(TR) 

requested?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Begin review fall 2013 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a) 

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Petitioned Substances – Current status of review process

Name Contact TR

requested

?

Vote 

Date

Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1 

Proposal. (CAS # 146659-78-

1) 

List at §205.601

HA/ZS Yes

9/2012 TR

01 29 

13

Petition sent to CS on 3/19. Request 

for TR 4/3/12. Draft TR sent to CS 

07/13. Add’l questions sent from CS 8-

15-12. TR deemed sufficient 11 20 12.

CS requested addtl info from TR 

contractor. TR revisions sent to CS 

1/18/13

Spr 2013

Name Contact TR

requested

?

Date

of 

vote

Notes* Meeting
Petitioned Substances – Current status of review process

Vinasse - proposal. List at

§205.601

NM Yes. 

Expedited

, modified 

TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. Delayed TR

- will move to fall. 

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

HA/ZS No

4/2011 TR

Straw 

poll: 

01 15 

13

Vote 

record

ed: 1 

29 13

Sent to CS on 06 19 11; Needs petition 

sufficiency review. TR deemed 

sufficient 

Spr 2013

Antibiotics (Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back again 

for incompleteness. 

Spr 

2013?/Fall 

2013

Aquaculture-CO2, List at 

§205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will rqst 

modification from petitioner (for use 

pattern). Updated petition was deemed 

sufficient. TR deemed unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609 

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. Petition 

sufficiency response due 08 08 12? CS 

sent request to NL Mgr 12 04 for 

additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609 

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. Petition 

Sufficiency Response due 09 04 12. CS 

sent request to NL Mgr 12 04 for 

additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, JFe N/A Petition sent to CS on 06 06 12. Petition 

Sufficiency Response due 08 06 12. 

Petition deemed insufficient 12 04 12. 

N/A
Petitioned Substances – Current status of review process

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

§205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 TR

No new 

TR rqstd

01 29 

13

12/2011 Final Recomm. Petition sent to 

CS on 11 02 12. Petition found 

sufficient 12 18 12. No TR rqst

Spr 2013

Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On 

hold

Waiting to comment on rulemaking

Food safety On 

hold

On hold

Fire blight (Tree fruit) HA On 

hold

On hold

GMO - seed purity ZS Disc doc 

10/2012

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

* Yellow highlight indicates committee action needed
Crops Subcommittee

Work Assignments, Draft Agenda (January 29, 2013/2:00pmEST meeting), Action Items

Crops Subcommittee work assignments for Spring 2013 NOSB meeting:

HA: Polyoxin D Zinc Salt; tetracycline petition (with ZS); streptomycin petition –sent back to petitioner by NOP with 

questions, waiting (with ZS) 

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid – Sunset 2015 material at 601(j)

FT: No assignments yet.

JFe: Inerts (with ZS); aqueous potassium silicate – Sunset 2015; 3. Seed Purity –in conjunction with Ad hoc GMO subcmte 

(with ZS, CBo); Plant Breeding –in conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate; indole-3-butyric acid (IBA) petition for reconsideration

NM: Vinasse; Carbon Monoxide/Exhaust Gas (sent back to petitioner)

ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate – Sunset 2015; tetracycline petition (with HA); streptomycin 

petition –sent back to petitioner by NOP with questions, waiting (with HA)

 

Agenda

• Approve agenda

• Approve January 15, 2013 subcommittee meeting notes

• Polyoxin D Zinc (HA) – review new points on checklist and VOTE

• IBA (JFo) – review new points on checklist and VOTE

• Tetracycline petition (HA and ZS) – new thoughts, prepare for 2/1 meeting

• Sodium carbonate peroxyhydrate – Sunset 2015 (ZS) – TR necessary? –postponed to next meeting. Not ready 

yet. 

• Next Meeting

• Adjourn 

Discussion 

• The agenda was approved as is, with the postponement of the discussion of sodium carbonate peroxyhydrate to 

the next meeting

• The January 15, 2013 subcommittee meeting notes were approved with no changes

• Polyoxin D Zinc (HA) –The group discussed new information that was added to the document since the last 

discussion and made some edits to the language. A member reminded the group to be mindful of the language 

when the classification vote is taken as the petitioner originally classified it as non-synthetic but revised it and 

re-classified it as synthetic. Group considered whether or not there is an impact on the beneficial aspects, and 

acknowledged that there is some CBI included that hinders their review. The members also discussed zinc 

concentrations. 

 

Vote on Polyoxin D Zinc. Chair asked for any COIs-none reported 

o Motion to classify Polyoxin D Zinc (CAS # 146659-78-1) as petitioned as synthetic: 

o Motion by: HA

o Seconded by: CBo

o The members had no declarations of interest or additional discussion

o Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0

o Motion to list Polyoxin D Zinc (CAS # 146659-78-1) as petitioned on §205.601 
o Motion by: HA

o Seconded by: CB

o No further discussion

o Yes: 3 No: 4 Abstain: 1 Absent: 0 Recuse: 0

The Chair indicated that the vote will remain open until February 5, 2013 if members would like to reread any of 

the documents that were presented. ABS note February 5: the vote was closed with no changes. 

• IBA -JFo gave a brief summary of IBA and acknowledged that the addition of language from JFe was very helpful. 

It was also noted that 5 growers provided support for this material. The NOSB had rejected broader uses of IBA 

in the past and the petitioner narrowed the scope of the item and resubmitted the petition. Although the 

resubmitted petition didn’t include any new technical info, it was rewritten in such a way to highlight some 

pertinent information that was not evident in the first petition. 

Vote on IBA: 

Motion to classify IBA (CAS# 133-32-4) as petitioned as synthetic: 

Motion by: JFo

Seconded by: HA 

There were no declarations of interest or any further discussion

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0 

Motion to list IBA as petitioned (CAS# 133-32-4) on §205.601 for the purpose of plant propagation via dipping. 

Motion by: JFo

Seconded by: HA 

No further discussion 

Yes: 3 No: 5 Abstain: 0 Absent: 0 Recuse: 0

• Tetracycline (Antibiotics). The group discussed potential questions for Brenda Book of the Washington State 

Department of Agriculture who will join the call on Friday to discuss antibiotics. Members were asked to send 

questions to HA by Wednesday afternoon (January 30) so he could compile them and forward them to Brenda

prior to the call. A member noted that pears and apples are grown in different regions in CA which is not the 

case in WA State and that the information that has been presented so far seems to be WA centric. 

 Straw vote: tetracycline for pears taken Jan 15 during call: Yes: HA, CBe, JFo, ZS No: CBo, BF, JFe, NM

 Straw vote: tetracycline for apples taken Jan 15 during call: Yes: HA, CBe, JFo, ZS, No: CBo, BF, JFe, NM

Vote on Tetracycline via email as of Jan 24 2013: 

Motion #1: 

Motion to remove the expiration date of October 21, 2014 and add the following annotation for tetracycline for 

apples only, 

§205.601 Synthetic substances allowed for use in organic crop production
 (i) As plant disease control. (12) Tetracycline, for fire blight control in apples only until October 21, 2017. 

Orchard management systems must demonstrate and document annual increase in the extent or number of alternative 

practices for controlling fire blight.

Motion by: HA 

Seconded by: ZS 

Yes: 4 No: 4 Absent: 0 Abstain: 0 Recuse: 0

Motion #2:

Motion to remove the expiration date of October 21, 2014 and add the following annotation for pears:

 §205.601 Synthetic substances allowed for use in organic crop production.

 (i) As plant disease control.

 (12) Tetracycline, for fire blight control in pears only. Orchard management systems must demonstrate and 

document annual increase in the extent or number of alternative practices for controlling fire blight. 

Motion by: Harold Austin 

 Seconded by: Zea Sonnabend

Yes: 4 No: 4 Absent: 0 Abstain: 0 Recuse: 0

The group noted that a backup vote on the motion is not required and the voting order should be reversed, so the 

motion for Pears would be voted on first, so if it does not pass at the NOSB meeting, they then can choose to combine 

the motions. The vote was left open so if members wanted to change their vote or propose a substitute motion they 

could. 

Future Call Schedule: 

January 15, 2013 2:00 EST

Vote on IBA –delayed due to time constraint 

Discuss/vote Tetracycline proposal and checklist – delayed for additional discussion and edits/will vote via email

Discuss checklist for sodium carbonate peroxyhydrate 

January 29, 2013 2:00 EST Extra call

Vote on IBA 

Review vote for Tetracycline proposal and checklist

Discuss checklist for sodium carbonate peroxyhydrate 

February 5, 2013 2:00 EST

Discuss checklist for sodium carbonate peroxyhydrate

February 19, 2013 2:00 EST

March 5, 2013 2:00 EST

March 19, 2013 2:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013
Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday February 5, 2013 2:00 pm EST 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Carmela Beck (CBe), John Foster (JFo), Colehour Bondera (CBo),

Harold Austin (HA), Nick Maravell (NM) (Vice Chair), Francis Thicke (FT), Mac Stone (MS) – non voting member

Absent: Stacy Jones King (SJK)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR) substituting for SJK

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Begin review fall 2013 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new 

TR

Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Petitioned Substances – Current status of review process

Name Conta

ct

TR

requested

?

Vote 

Date

Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

Proposal. (CAS # 146659-78-

1)

List at §205.601

HA/ZS Yes

9/2012 TR

01 29 13 Petition sent to CS on 3/19. Request 

for TR 4/3/12. Draft TR sent to CS 

07/13. Add’l questions sent from CS 8-

15-12. TR deemed sufficient 11 20 12.

CS requested addtl info from TR 

contractor. TR revisions sent to CS 

1/18/13

Spr 2013

Name Conta

ct

TR

requested

?

Date of 

vote

Notes* Meeting
Petitioned Substances – Current status of review process

Vinasse - proposal. List at

§205.601

NM Yes. 

Expedited

, modified 

TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. Delayed TR

- will move to fall. 

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

HA/ZS No

4/2011 TR

Straw 

poll: 01 

15 13

Vote

recorded

: 1 29 13

Sent to CS on 06 19 11; Needs petition 

sufficiency review. TR deemed 

sufficient

Spr 2013

Antibiotics (Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back again 

for incompleteness. 

Fall 2013

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will rqst 

modification from petitioner (for use 

pattern). Updated petition was deemed 

sufficient. TR deemed unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. Petition 

sufficiency response due 08 08 12? CS 

sent request to NL Mgr 12 04 for 

additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 TR Petition sent to CS on 07 03 12. Petition 

Sufficiency Response due 09 04 12. CS 

sent request to NL Mgr 12 04 for 

additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 12. Petition 

Sufficiency Response due 08 06 12. 

Petition deemed insufficient 12 04 12. 

N/A

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

§205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 TR

No new 

TR rqstd

01 29 13 12/2011 Final Recomm. Petition sent to 

CS on 11 02 12. Petition found 

sufficient 12 18 12. No TR rqst

Spr 2013
Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On hold Waiting to comment on rulemaking

Food safety On hold On hold

GMO - seed purity ZS Disc doc 

10/2012

GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

* Yellow highlight indicates committee action needed

Agenda

Crops Subcommittee work assignments for Spring 2013 NOSB meeting:

HA: streptomycin petition –sent back to petitioner by NOP with questions, waiting (with ZS) 

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid – Sunset 2015 material at 601(j)

FT: No assignments yet.

JFe: Inerts (with ZS); Aqueous potassium silicate – Sunset 2015; 3. Seed Purity –in conjunction with Ad hoc GMO 

subcmte (with ZS, CBo); Plant Breeding –in conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate

NM: Vinasse; Carbon Monoxide/Exhaust Gas (sent back to petitioner)
ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate – Sunset 2015; tetracycline petition (with HA); streptomycin 

petition –sent back to petitioner by NOP with questions, waiting (with HA)

Approve agenda

Approve January 29, 2013 subcommittee meeting notes 

Sodium carbonate peroxyhydrate. Sunset 2015 (ZS). TR necessary? 

Inerts update (ZS and JFe) 

Tetracycline petition, debrief meeting with WSDA, questions, thoughts, next steps, etc. 

Workplan Issues for Fall 2013

Next Meeting 

Adjourn 

Discussion

• Agenda was approved as is

• January 29, 2013 subcommittee meeting notes approved with clarifications to the voting for tetracycline to be 

completed by MA (Corrections made 02 06 13 by MA). The Jan. 24 vote was a straw vote, followed by an official 

email vote, with provision that the committee may decide to revote. 

• Sodium carbonate peroxyhydrate - Sunset 2015 (ZS). The group discussed whether or not a new TR would be 

necessary. The members feel the old TR is not adequate to conduct the new review so they recommend 

requesting a new one. The NOP will also review the documents and see if a supplemental TR or a full TR is 

needed. ZS compiled 6 key questions for submission, and would like to revisit the annotation when the TR is 

received. A member noted that the previous NOSB recommendation for this substance is not posted on website.

(MA will correct this)

• JFe will send a request to the National List Manager (LB) by Thursday Feb 7 for TRs for the three sunset

materials, and seek input about whether or not a full TR is needed. The NOP noted that the old TRs may require 

updating. 

• Inerts update (ZS and JFe) – The group discussed the presentation time for this item at the spring 2013 meeting, 

and suggested that it could be presented during the NOP update time on Tuesday. The update will include 

information about the grouping of materials; 16 groups, 9 individual materials, some of which will require TRs. 

The next steps include preparing a Federal Register notice to request information about any additional items 

that should be included. Workplan items for fall 2013: pending TR requests, the Crops Subcommittee will be 

able to complete some of the workplan items such as Vinasse. 

• A member noted that the Classification Guidance might be coming out soon, which could mean that the CS may 

need to revisit some classifications, such as vinasse and soy protein isolate. 

• Tetracycline petition, debrief meeting with WSDA, questions, thoughts, next steps, etc. 

o NM made a motion to move ahead with a 2-year extension for tetracycline (with an expiration date of 

2016). He also suggested no annotation beyond that, but instead the inclusion of a rationale for 

stakeholders. A member asked if this was the same as a statement already included in the current 

checklist about “moving towards alternative methods”. NM felt that, as a grower, the language is too 

general and enforcement may be difficult, but that a 2-year extension would convey to the community 

that the NOSB intention is to phase out tetracycline. A member added that the language included in the 

narrative is more for the certifier than the growers. A member supported submission of the document 

as is, so they could decide how to proceed once the public has had a chance to comment. In response to 

a question about growers exhausting the alternatives, ZS noted that the possibilities are never

exhausted because there are many variables that can be altered each season: timing, weather, 

materials, combinations, pruning schedules, etc. 
The group discussed including the revised motion with two annotations, the second to include a vote for 

the “sense of the Board”. The NOP does not recommend an earlier expiration date as the rulemaking 

process will take the majority of that time, at which point it will be time to re-evaluate. JFe encouraged 

the group to keep the annotations in the vote, rather than deciding to add one later at the meeting, 

after the public comment period closes. 

Vote on Tetracycline: 

The Subcommittee was unanimous in its decision to vote again on tetracycline. 

Motion # 1:

Motion to amend listing of tetracycline to remove the expiration date of 2014 and add the following annotation: 

For use in control of fireblight in apples and pears until Oct 21, 2016

Motion by: NM

Seconded by: HA

Discussion: the Chair noted for the record that members are voting before we have the completed document. 

Yes: 5 No: 3 Absent: 0 Abstain: 0 Recuse: 0

Motion # 2:

The subcommittee discussed wording for an additional resolution, to this effect: The National Organic Standards 

Board is committed to the phase out of this material. The board urges growers and certifiers between now and 

the 2016 expiration date, to encourage an annual increase in the extent and/or number of alternative practices 

that are trialed for controlling fire blight. In addition, the board strongly supports increased support for research 

into these alternative practices and materials.

• MA will add an extra Crops call for Monday Feb 11 at 2:00pm ET to finalize the tetracycline proposal. 

Future Call Schedule:

January 29, 2013 2:00 ET Extra call

Vote on IBA 

Review vote for Tetracycline proposal and checklist

Discuss checklist for sodium carbonate peroxyhydrate 

February 5, 2013 2:00 ET

Discuss checklist for sodium carbonate peroxyhydrate

Inerts update (ZS and JFe) 

Tetracycline petition, debrief meeting with WSDA, questions, thoughts, next steps, etc. 

Workplan Issues for Fall 2013

February 11, 2013 2:00 ET – additional call

February 19, 2013 2:00 ET

March 5, 2013 2:00 ET

March 19, 2013 2:00 ET
Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday February 11, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Carmela Beck (CBe), Colehour Bondera (CBo), Harold Austin 

(HA), Mac Stone (MS), Nick Maravell (NM) (Vice Chair), Francis Thicke (FT)

Absent: John Foster (JFo)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK), Miles McEvoy 

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Begin review fall 2013 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new 

TR

Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Begin review fall 2013

Spr 2014

Petitioned Substances – Current status of review process

Name Conta

ct

TR

requested

?

Vote Date Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

Proposal. (CAS # 146659-78-

1)

List at §205.601

HA/ZS Yes

9/2012 TR

01 29 13 Petition sent to CS on 3/19. 

Request for TR 4/3/12. Draft TR 

sent to CS 07/13. Add’l questions 

sent from CS 8-15-12. TR deemed 

sufficient 11 20 12. CS requested 

addtl info from TR contractor. TR 

revisions sent to CS 1/18/13

Spr 2013

Name Conta

ct

TR

requested

?

Date of vote Notes* Meeting
Petitioned Substances – Current status of review process

Vinasse - proposal. List at

§205.601

NM Yes. 

Expedited

, modified 

TR

Petition sent to CS on 03 29 12. 

Sent request for feedback on 

feasibility for modified TR to 

LBrines. LB sent feedback 09 04 12. 

The CS reqst’d a quick modified TR 

12 04 12. Delayed TR - will move to 

fall. 

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

ZS/HA No

4/2011 TR

Straw poll:

01 15 13, vote 

recorded: 1 29

13 Revoted 02 

05 13. Voted 

on resolution:

02 11 13

Sent to CS on 06 19 11; Needs 

petition sufficiency review. TR 

deemed sufficient

Spr 2013

Antibiotics (Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back 

again for incompleteness. 

Fall 2013

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner 

(for use pattern). Updated petition 

was deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from 

petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 12 

04 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. 

Petition Sufficiency response due 10 

10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 12. 

Petition Sufficiency Response due 

08 06 12. Petition deemed 

insufficient 12 04 12. 

N/A

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

JFo 6/2011 TR

No new 

01 29 13 12/2011 Final Recomm. Petition 

sent to CS on 11 02 12. Petition 

Spr 2013
Petitioned Substances – Current status of review process

§205.601

Indole-3 -butyric acid (IBA) 

2008.

TR rqstd found sufficient 12 18 12. No TR

rqst

Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc 

type

Vote 

Date

Notes Meeting

Mushroom standards On hold Waiting to comment on rulemaking

Food safety On hold On hold

GMO - seed purity ZS Disc doc 

10/2012

GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

* Yellow highlight indicates committee action needed

Agenda

• Approve agenda for call

• Approve February 5, 2013 subcommittee meeting notes
• Vote on tetracycline resolution 

Discussion

• Agenda was approved with no changes

• February 5, 2013 subcommittee meeting notes were deferred to the next call so the Subcommittee members 

had time to review them

• Vote on Tetracycline: 

Motion # 1: Voted on during the February 5, 2013 call

Motion # 2:

Resolution: The National Organic Standards Board is committed to the phase out of this material. The board 

urges growers and certifiers between now and the 2016 expiration date, to encourage an annual increase in the 

extent and/or number of alternative practices that are trialed for controlling fire blight. In addition, the board 

strongly advocates to the USDA a high priority for increased support for research into these alternative 

practices and materials.”

Motion by: NM

Seconded by: ZS

Additional Discussion: none 

Yes: 7 No: 0 Absent: 1 Abstain: 0 Recuse: 0

The group discussed some additional edits that were made to the most recent version of the document (2013 

oxytet checklist draft 9 ZS), and had a vigorous debate about various aspects of the document including blocks of 

text in the checklist, scientific references about persistence, reference to specific people, and the minority and 

majority opinions. A member suggested simplifying the checklist by not marking both Yes and No for the same 

item. The group discussed this, and one member noted that the checklist and narrative were intentionally meant 

to be redundant. A member noted that although he agreed with the suggestion that the checklist be simplified, 

it seems like this is being suggested very late in the process and would have benefited from hearing about this 

sooner. Another member suggested submitting 2 separate checklists-one for the minority, and one for majority 

opinion. Which she then offered was not necessary, because sometimes there is not a clear answer and having 

both a yes and no answer reflects that. One of the members suggested adding footnotes to some of the yes/no 

line items for easy reference. The group decided 1) to eliminate redundancies between the checklist and the 

narrative, and 2) to maintain the majority/minority opinion in the document, based on their interpretation of 

the science. HA will make the changes discussed and send the document to the group before submitting it to the 

NOP. 

Future Call Schedule:

February 5, 2013 2:00 EST

Discuss checklist for sodium carbonate peroxyhydrate

Inerts update (ZS and JFe) 

Tetracycline petition, debrief meeting with WSDA, questions, thoughts, next steps, etc. 

Workplan Issues for Fall 2013

February 11, 2013 2:00 EST – additional call

February 19, 2013 2:00 EST

March 5, 2013 2:00 EST

March 19, 2013 2:00 EST
Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday February 19, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Carmela Beck (CBe), Colehour Bondera (CBo), Harold Austin 

(HA), Mac Stone (MS), Francis Thicke (FT)

Absent: John Foster (JFo), Nick Maravell (NM) (Vice Chair)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo Yes

3/2010 TR

Original recomm May 2009

Request for TR 2 14 13

Proposal

Spr 2013

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS Yes

8/2006 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2013

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? Yes

9/2003 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2013

Petitioned Substances – Current status of review process

Name Contac

t

TR

rqsted?

Vote Date Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

(CAS # 146659-78-1)

List at §205.601

HA/ZS Yes

9/2012 

TR

01 29 13 Petition sent to CS on 3/19. 

Request for TR 4/3/12. Draft TR 

sent to CS 07/13. Add’l questions 

sent from CS 8-15-12. TR deemed 

sufficient 11 20 12. CS requested 

addtl info from TR contractor. TR 

revisions sent to CS 1/18/13

Proposal 

Spr 2013

Name Contac

t

TR 

rqsted?

Date of vote Notes* Meeting
Vinasse List at §205.601 NM Yes. 

Expedited

, modified 

TR

Petition sent to CS on 03 29 12. 

Sent request for feedback on 

feasibility for modified TR to 

LBrines. LB sent feedback 09 04 12. 

The CS reqst’d a quick modified TR 

12 04 12. Delayed TR - will move to 

fall. 

Proposal

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

ZS/HA No

4/2011 

TR

Straw poll:

01 15 13, vote 

recorded: 1 29

13 Revoted 02 

05 13. Vote on 

resltion:

02 11 13

Sent to CS on 06 19 11; Needs 

petition sufficiency review. TR 

deemed sufficient

Proposal 

Spr 2013

Antibiotics (Streptomycin) 

Amend annotation, 

§205.601

ZS/HA 3/2011 

TR

1/2006 

TR

10/1995 

TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back 

again for incompleteness. Sent to 

CS 02 28 13. Sufficiency due 04 29 

13

Proposal 

Fall 2013

AQ guidance/standards for 

plants

ZS TBD

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner 

(for use pattern). Updated petition 

was deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from 

petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 

08 08 12? CS sent request to NL 

Mgr 12 04 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 

T

R

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. 

Petition Sufficiency response due 

10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 12. 

Petition Sufficiency Response due 

08 06 12. Petition deemed 

insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. Due 

N/A
NLT 04 23 13

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

§205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 

TR

No new 

TR rqstd

01 29 13 12/2011 Final Recomm. Petition 

sent to CS on 11 02 12. Petition 

found sufficient 12 18 12. No TR

rqst

Proposal

Spr 2013

Magnesium oxide List at 

205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide

Petition sent to CS on 02 14 13.

Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert)

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On hold Waiting to comment on rulemaking

Food safety On hold On hold

GMO - seed purity ZS Disc doc 

10/2012

GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013
* Yellow highlight indicates committee action needed

Agenda

Crops Subcommittee work assignments for Spring 2013 NOSB meeting:

HA: streptomycin petition –sent back to petitioner by NOP with questions, waiting (with ZS) 

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid – Sunset 2015 material at 601(j)

FT: No assignments yet.

JFe: Inerts (with ZS); Aqueous potassium silicate – Sunset 2015 –request for updated TR sent to Lisa; Plant 

Breeding –in conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate

NM: Vinasse; Carbon Monoxide/Exhaust Gas (sent back to petitioner)

ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate – Sunset 2015; tetracycline petition (with HA); 

streptomycin petition –sent back to petitioner by NOP with questions, waiting (with HA

• Approve agenda

• Approve February 5 and February 11, 2013 subcommittee meeting notes

• Status of TR requests

• Review schedule for posting of comments, public comment closing date, procedure for CS review and reporting 

back on public comments, reassessment of CS positions based on public comments, as needed

• Assign magnesium oxide petition. [Please think about volunteering for this.]

• Workplan Issues for Fall 2013 

• Next Meeting

• Adjourn

Discussion

• Agenda was approved as is. 

• February 5, 2013 Subcommittee meeting notes approved with no changes

• February 11, 2013 Subcommittee meeting notes approved with no changes 

• Status of TR requests – SJK indicated that the Vinasse TR is in development, and she would try to find out more 

information. The TRs for the three sunset items have been requested and the Subcommittee is awaiting their 

arrival. LB confirmed by phone to expect it during April 2013.

• Aquaculture items: fall 2013: ZS and Miles McEvoy were going to look at past NOSB recommendations (one on 

aquatic plants and one on terrestrial plants in green houses) to help inform the aquaculture review and the 

workplan moving forward. MA will put a placeholder on the workplan, AQ guidance/standards for aquatic plants

(see table above). 

• JFe asked for ZSs help with magnesium oxide and classification, and FT volunteered to review the material. 

• A member asked about the status of the workplan, and whether or not the draft plan would be ready for 

discussion/acceptance by the next Executive Subcommittee call (March 8). 

• JFe suggested adding residues in compost feedstock to the workplan as a potential item and the group discussed 

this. The idea would be to draft a document about contaminants. A member felt that this is covered under 

§205.203 and the Unavoidable Residual Environmental Contaminations (UREC) provisions, and because breakdown of residues in the compost process has not been studied, the NOSB would not be able to produce useful 

results. The members suggested asking the Deputy Administrator about the NOP guidance (policy memo?) that 
was drafted and whether or not it is still in process. Members also discussed anaerobic digestion and vermicompost, and manure as well, noting that heavy metal contamination falls under the manure standards for 

general contamination on §205.203. The consensus was that this item would not be a good use of time for the 

Subcommittee. 

• A member noted that there was an information-sharing meeting on antibiotics at Organicology which several 

Board members participated in. A member asked about the sense of community with regard to the tetracycline 

opinion: It varies based on geographic location, but West Coast growers are generally supportive. MS asked 

about the potential for an overwhelming numbers of public commenters, and how the Board would 

accommodate this. Some members indicated that in the past the Board has chosen to stay late in order to hear 

all the comments. Another option would be to connect people so they could determine whether or not their 

comments echoed those of many others, and perhaps they could choose one representative who would speak 

for the many. JFe offered to help MA coordinate this effort. 

Future Call Schedule:

February 19, 2013 2:00 EST

March 5, 2013 2:00 ET

March 19, 2013 2:00 ET

March 27, 2013 2:00 ET- addition call to discuss public comments

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday March 5, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Colehour Bondera (CBo), Harold Austin (HA), John Foster (JFo), 

Nick Maravell (NM) (Vice Chair)

Absent: Carmela Beck (CBe), Mac Stone (MS)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK). Emily Brown Rosen (EBR)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status of 

review process

Name Contac

t

Technical 

Report 

(TR) 

requested

?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo Yes

3/2010 TR

Original recomm May 2009

Request for TR 2 14 13

Proposal

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS Yes

8/2006 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i)

Original petitions: 2004, 

2006

JFe? Yes

9/2003 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2014

Petitioned Substances – Current status of review process

Name Contac

t

TR

requeste

d?

Vote Date Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

(CAS # 146659-78-1)

List at §205.601

HA/ZS Yes

9/2012 

TR

01 29 13 Petition sent to CS on 3/19. 

Request for TR 4/3/12. Draft TR 

sent to CS 07/13. Add’l questions 

sent from CS 8-15-12. TR deemed 

sufficient 11 20 12. CS requested 

addtl info from TR contractor. TR 

revisions sent to CS 1/18/13

Proposal 

Spr 2013

Name Contac

t

TR

requeste

d?

Date of vote Notes* Meeting
Vinasse List at §205.601 NM Yes. 

Expedited

, modified 

TR

Petition sent to CS on 03 29 12. 

Sent request for feedback on 

feasibility for modified TR to 

LBrines. LB sent feedback 09 04 12. 

The CS reqst’d a quick modified TR 

12 04 12. Delayed TR - moved to fall

2013. 

Proposal

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend 

annotation, §205.601

ZS/HA No

4/2011 

TR

Straw poll:

01 15 13, vote 

recorded: 1 29

13 Revoted 02 

05 13. Vote on 

resltion:

02 11 13

Sent to CS on 06 19 11; Needs 

petition sufficiency review. TR 

deemed sufficient

Proposal 

Spr 2013

Antibiotics (Streptomycin) 

Amend annotation, 

§205.601

ZS/HA 3/2011 

TR

1/2006 

TR

10/1995 

TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back 

again for incompleteness. Sent to 

CS 02 27 13. Sufficiency due 04 29 

13

Proposal 

Fall 2013

AQ guidance/standards for 

plants

ZS TBD

Aquaculture-CO2, List at 

§205.609

CBo, 

ZS

No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner 

(for use pattern). Updated petition 

was deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from 

petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JF

o

2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 

08 08 12? CS sent request to NL 

Mgr 12 04 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CB

e

2/2011 

T

R

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. 

Petition Sufficiency response due 

10 10 12

Fall 2013

Carbon monoxide (exhaust 

gas) List at §205.601

NM, 

JFe

N/A Petition sent to CS on 06 06 

12Petition deemed insufficient 12 

04 12. Petition revised and sent to 

CS 2 22 13. Revised Petition 

Sufficiency Review; Rcv’d info from 

N/A
EPA 03 07 13 addressing CS's 

questions. Petition suffic due 04 23 

13

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

§205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 

TR

No new 

TR rqstd

01 29 13 12/2011 Final Recomm. Petition 

sent to CS on 11 02 12. Petition 

found sufficient 12 18 12. No TR

rqst

Proposal

Spr 2013

Magnesium oxide List at 

205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide

Petition sent to CS on 02 14 13.

Petition sufficiency due ~ 04 15 13

Fall 2013

Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert) -

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP they 

would like to continue review; Review TR 

for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP they 

would like to continue review; CS may 

want to re-evaluate request for TR since 

this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc 

type

Vote 

Date

Notes Meeting

Mushroom standards On hold Waiting to comment on rulemaking

Food safety On hold On hold

GMO - seed purity ZS Disc doc 

10/2012

GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013
* Yellow highlight indicates committee action needed

Agenda

Crops Subcommittee work assignments for Spring 2013 NOSB meeting:

HA: streptomycin petition sent back to petitioner by NOP with questions, waiting (with ZS)

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H)

CBo: Aquaculture CO2 (with ZS); Aquaculture chlorine; Sulfurous Acid Sunset

2015 material at 601(j)

FT: No assignments yet.

JFe: Inerts (with ZS); Aqueous potassium silicate Sunset 2015 request for updated TR sent to Lisa; Plant Breeding in 

conjunction with Ad hoc GMO subcmte (with ZS, CBo)

JFo: Aquaculture lignin sulfonate

NM: Vinasse; Carbon Monoxide/Exhaust Gas (sent back to petitioner)

ZS: Inerts (with JFe); Sodium carbonate peroxyhydrate Sunset 2015; tetracycline petition (with HA); streptomycin 

petition sent back to petitioner by NOP with questions, waiting (with HA)

• Approve agenda

• Approve February 19, 2013 Subcommittee meeting notes (sent out 2-25-13)

• Status of TR requests from NOP staff

• Workplan Issues for Fall 2013

• Discuss Compost, other possible workplan issues

• Discussion of public comments to-date

• Next Meeting

• Adjourn

Discussion

• The agenda was approved with the addition of an item to discuss the NOSB meeting agenda

• February 19, 2013 Subcommittee meeting notes approved with no changes

• Status of TR requests

o Antibiotics (Streptomycin) - ZS will review petition for sufficiency and have it ready for discussion on the 

March 19 call.

o Magnesium oxide. FT will review petition for sufficiency and have it ready for discussion on the April 2

call, or perhaps after the spring meeting. 

o Polyglyceryl phthalate ester of coconut oil fatty acid (inert) – The Chair asked about including this in the 

inert review. EBR is checking into this to make sure all inerts that have been petitioned will be 

combined with IWG plan for review. 

o SJK will send JFo email from G. Lockwood regarding the Aquaculture petition for lignin sulfonate 

(chelating agent for aquatic plants)

• Workplan items
o Potential discussion doc re: allowance of green waste in organic systems productions and potential for 

contaminants such as pesticides, herbicides, heavy metals, antibiotics or animal drugs. The NOP 5016 

Guidance on allowance of Green Waste says “non-organic crop residues or lawn clippings may contain 

pesticide residues. Provided ... that any residual pesticide levels do not contribute to the contamination 

of crops, soil or water, the compost is acceptable for use in organic production.” A member wanted 

clarification about how to identify “contamination”. The Subcommittee feels that considering green 

waste alone is not useful, if this topic is to be addressed it should include manure as well as compost.

With that, and given that this is a complex project, the group discussed defining contamination as a long 

term workplan item, and crafting a white paper, which could then be used as the basis for research 

priorities or as the foundation for a discussion document. A member added that this is a very difficult 

topic due to lack of research, and the data that have been collected to date are sparse and were

determined to be non-definitive. The NOP suggested that perhaps a petition as a prohibited natural for a 

certain types of manure could be a formal way to tackle this project on a smaller scale. The group 

discussed several ideas, such as starting with heavy metals as the first topic, and whether or not that 

would be an attainable goal. The consensus from the group is that they would like to put it on the 

workplan for spring 2014, and could always start working on it earlier. A member supported this and 

added that this is an issue in the community and feels that it is a topic that should be addressed. Other 

issues raised included problems associated with anaerobically digested liquid manure, and potential 

harm to soil microbes. The NOP noted that before it is added to the workplan, the Subcommittee needs 

to define the problem to be addressed and it must then be vetted by the Executive committee. A 

member reminded the group that this would be a long term project, and noted that it took OMRI 2 years 

to develop their standards on heavy metals in fertilizer and compost. Another member added that he 

supports inclusion of this on the workplan, but asked that the group keep in mind the needs of the 

farmers and growers, and supplying the growers with tools that they don’t have to second guess. An 

issue was raised regarding whether these are new problems or are a result of more sensitive detection 

levels. Likely, both are factors. The Chair will rewrite the workplan item based on today’s discussion, 

recirculate it, and present it to the Executive Subcommittee on Friday.

o ZS suggested two workplan items. 1) A review of the hydroponics and aquatic plants recommendations 

as a baseline before reviewing the aquaculture petitions. These two prior recommendations seem to be 

contradictory, and she feels this must be addressed before proceeding with the review for the rest of 

the aquaculture items. The group acknowledged the need for expediency so they can move ahead with 

the aquaculture petitions. As a follow up at the end of the call, the NOP determined that the April 2010 

Hydroponics standards stated they were for terrestrial plants, so this particular past recommendation 

didn’t conflict with the current Boards review. 2) Guidance for using biodegradable mulch. JFe will 

present these two items to the Executive Subcommittee on the next call.

• Public comments. So far there haven’t been many comments, but it is still early in the process and the group 

feels that people will need time to submit thoughtful comments.

Future Call Schedule:

March 5, 2013 2:00 ET

March 19, 2013 2:00 ET

March 27, 2013 2:00 ET- additional call to discuss public comments
Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production and 

handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday April 2, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Colehour Bondera (CBo), Harold Austin (HA), Mac Stone (MS), 

John Foster (JFo), Carmela Beck (CBe)

Absent: Nick Maravell (NM) (Vice Chair), Francis Thicke (FT)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

Sunset 2015 - § 205.601 Synthetic substances allowed for use in organic crop production - Current status 

of review process

Name Contact Technical 

Report 

(TR) 

requested?

Vote 

Date

Notes Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo Yes

3/2010 TR

Original recomm May 2009

Request for TR 2 14 13

Proposal

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS Yes

8/2006 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2014

Aqueous potassium 

silicate at 601(e) and 

601(i)

Original petitions: 2004, 

2006

JFe? Yes

9/2003 TR

Original recomm Nov 2007

Request for TR 2 14 13

Proposal 

Spr 2014

Petitioned Substances – Current status of review process

Name Contact TR

requested?

Vote Date Notes* Meeting

Polyoxin D Zinc Salt Petition

Polyoxin D Zinc Salt 

Addendum 1

(CAS # 146659-78-1)

List at §205.601

HA/ZS Yes

9/2012 TR

01 29 13 Petition sent to CS on 3/19. 

Request for TR 4/3/12. Draft TR 

sent to CS 07/13. Add’l questions 

sent from CS 8-15-12. TR deemed 

sufficient 11 20 12. CS requested 

addtl info from TR contractor. TR 

revisions sent to CS 1/18/13

Proposal 

Spr 2013
Name Contact TR

requested?

Date of 

vote

Notes* Meeting

Vinasse List at §205.601 NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. 

Sent request for feedback on 

feasibility for modified TR to 

LBrines. LB sent feedback 09 04 12. 

The CS reqst’d a quick modified TR 

12 04 12. Delayed TR - moved to 

fall 2013. 

Proposal

Fall 2013

Antibiotics (Tetracycline) 

Proposal. Amend annotation, 

§205.601

ZS/HA No

4/2011 TR

Straw poll:

01 15 13, 

vote 

recorded: 1 

29 13

Revoted 02 

05 13. Vote 

on resoltn:

02 11 13

Sent to CS on 06 19 11; Needs 

petition sufficiency review. TR 

deemed sufficient

Proposal 

Spr 2013

Antibiotics (Streptomycin) 

Amend annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 TR

Apr 2011 Final Recomm.

NOP rcv’d petition but sent back to 

petitioner for revision, Rcvd revised 

petition 01 07 13 and sent back 

again for incompleteness. Sent to 

CS 02 27 13. Sufficiency due 04 29 

13

Proposal 

Fall 2013

AQ guidance/standards for 

plants

ZS TBD

Aquaculture-CO2, List at 

§205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner 

(for use pattern). Updated petition 

was deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine List at

§205.609 and §205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from 

petitioner

Fall 2013

Aquaculture-Micronutrients 

List at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 

08 08 12? CS sent request to NL 

Mgr 12 04 for additional info

Fall 2013

Aquaculture-Lignin sulfonate 

(chelating agent for aquatic 

plants) List at §205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL 

Mgr 12 04 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe Petition sent to CS 08 10 12. 

Petition Sufficiency response due 

10 10 12

Fall 2013
Carbon monoxide (exhaust 

gas) List at §205.601

NM, JFe N/A Petition sent to CS on 06 06 

12Petition deemed insufficient 12 

04 12. Petition revised and sent to 

CS 2 22 13. Revised Petition 

Sufficiency Review; Rcv’d info from 

EPA 03 07 13 addressing CS's 

questions. Petition suffic due ~04 

23 13

N/A

Indole-3-butyric acid (IBA)

2012. CAS# 133-32-4 List at

§205.601

Indole-3 -butyric acid (IBA) 

2008.

JFo 6/2011 TR

No new TR

rqstd

01 29 13 12/2011 Final Recomm. Petition 

sent to CS on 11 02 12. Petition 

found sufficient 12 18 12. No TR

rqst

Proposal

Spr 2013

Magnesium oxide List at 

205.601

FT 2007 

Magnesium 

(HYDR) 

oxide

Petition sent to CS on 02 14 13.

Petition sufficiency due ~ 04 15 13

Fall 2013

Inert Ingredients

Inerts update JFe/ZS N/A N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

Spr 2013

Polyglyceryl phthalate ester 

of coconut oil fatty acid 

(inert) -

On 

hold

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

1,1-Difluoroethane (inert) Yes On 

hold

On 01 21 11 - Petitioner notified NOP they 

would like to continue review; Review TR 

for sufficiency. On hold

Manganese sulfate 

monohydrate (inert)

Yes On 

hold

On 02 03 11, petitioner notified NOP they 

would like to continue review; CS may 

want to re-evaluate request for TR since 

this is an inert

Ethylene DDSA / EDDS 

(inert)

JFe Yes On 

hold

On hold

Terpene Polymers (inert) ? Maybe On 

hold

On hold

Other Proposals

Name Contact Doc type Vote 

Date

Notes Meeting

Mushroom standards On hold Waiting to comment on rulemaking

Food safety On hold On hold

GMO - seed purity ZS Disc doc 

10/2012

GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013
GMO – plant breeding

(Terminology for Excluded 

Methods)

ZS GMO 

voted 02 

06 13

Joint with GMO ad hoc Subcommittee. 

GMO is lead.

Spr 2013

* Yellow highlight indicates committee action needed

Agenda

• Approve agenda

• Approve March 27, 2013 Subcommittee meeting notes

• CS public comments and board member presentations. Oxytetracycline, PDZS, and IBA

Discussion

• The agenda was approved as is

• March 27, 2013 Subcommittee meeting notes were not sent to the Subcommittee yet for approval.

• The members summarized and discussed and public comments in relation to Oxytetracycline, PDZS, and IBA. As 

for the presentation, ZS and HA will present the majority opinion and JFe will present the minority opinion. 

Members intend on addressing some of the misconceptions that were presented in the comments regarding 

residues of tetracycline and language in OFPA. Members are discussing some additional issues regarding the 

expiration date with the NOP prior to the meeting, and suggested some supplemental language which would 

allow use as an emergency spray. A member asked if the NOSB has jurisdiction over this, and if they are 

interfering in what amounts to a certification decision. Members felt that this was sanctioned in Section 18 of 

the Emergency Spray Provision, and will double check with the Deputy Administrator. The two members who 

held the minority opinion discussed their views including not undermining the supporting science. Members 

discussed the opinion of the grower community that the Board is not composed of scientists, and the members 

noted that their hope is that the expert panel will be able to address some of the concerns. 

• IBA- The vast majority of comments were against the inclusion of IBA on the list, which will be summarized and 

presented at the meeting

• PDZS- The vast majority of comments were against the inclusion of Polyoxin D zinc salt. 

• The Inerts update is in progress, which will be presented by the NOP at the meeting.

Future Call Schedule:

March 27, 2013 2:00 ET- additional call to discuss public comments

April 2, 2013 2:00 ET

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013
Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday May 7, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Zea Sonnabend (ZS), Colehour Bondera (CBo), Harold Austin (HA), Mac 

Stone (MS), John Foster (JFo), Francis Thicke (FT)

Absent: Nick Maravell (NM) (Vice Chair), Carmela Beck (CBe)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Waiting for response

Fall 2013

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013
Petitioned Substances

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr

12 04 12 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

Petition sent to CS on 02 14 13.

Petition Sufficiency response due 05 

21 13

Fall 2013

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold
Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates committee action needed

Agenda

Crops Subcommittee work assignments for Fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS.

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on 

TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 

(Sunset 2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups?; streptomycin petition (with HA); Sodium 

carbonate peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; aquaculture 

guidance/standards for plants.

• Approve agenda

• Approve notes of crops subcommittee meetings on March 27, 2013 and April 2, 2013

• Workplan Issues for Fall 2013

a. TR sufficiency determination for Vinasse 

b. Streptomycin petition – schedule presentation and vote

c. aquaculture materials petition – schedule presentations and vote

d. magnesium oxide petition – schedule presentation and vote

e. aquaculture guidance/standards for plants schedule

f. Inerts – request for TRs for some groupings?

g. contaminants in farm inputs schedule 
• Timing of NOP response to NOSB request to investigate possible use of emergency use (7 U.S.C. 

6518(k)(6) and 7 C.F.R. 205.672) of tetracycline use for fire blight

• May 3 Federal Register on NOSB decisions on carrageenan infant formula annotation, cellulose 

annotation, and inerts annotation (FR notice attached) 

• Thoughts on Spring 2013 NOSB meeting

• Next Meeting

Discussion

• The agenda was approved as is

• March 27 and April 2, 2013 Subcommittee meeting notes approved with no changes. 

• Workplan Issues for fall 2013. 

o Vinasse TR was sent to CS on April 29. The Chair would like to move forward with the 

petition sufficiency determination and as such, asked the members to review it. A member 

noted that it would be helpful to have an analysis of the final manufacturing step where 

supplemental additives are added to prevent further fermentation, but that the TR 

contractor is not able to answer those questions, so sending it back would not be 

productive. The group discussed the classification of Vinasse as synthetic, and if it is viewed 

as a fertilizer, then there is no need to move forward. The petition states that it was 

petitioned as a plant nutrient/soil amendment. A member had a specific question about 

this and will send via email.

o Streptomycin petition - members will continue the review of this material. HA offered to 

assist ZS, who has already begun this review.

o Aquaculture materials petition – The group scheduled the discussions for various materials 

(see below) and suggested that there may be a need to develop aquatic plants guidance in 

the future.

o Magnesium oxide petition (FT). FT will have a document for the group to review for the 

next meeting and will discuss the need (or not) for TR

o Hydroponics policy statement - The NOP intends on issuing guidance about this. 

o Inerts - FR notice is still with General Counsel (expected this summer), and the Working 

Group will be meeting next week, so the CS will wait and not request TRs on any groups at 

this time. The task force will be able to prepare and prioritize things in anticipation for the 

release of the FR.

o Contaminants in farm inputs. JFo noted that the group should keep in mind past NOSB 

experiences and information, and the NOP response to these instances. Additionally,

members noted the applicable guidance that already exists. The group discussed how to 

move forward including setting up a framework as a first step. This project is going to be 

large, and long term and the members felt it was necessary to create a workplan for the 

topic before determining any deadlines for project sub-goals.

• Timing of NOP response to NOSB request to investigate possible use of emergency use clause for 

tetracycline – The NOP response is high priority so SJK didn’t feel it needed to be added to the 

workplan. The Chair will discuss this on the Executive call this Friday. 

• May 3 Federal Register Notice about NOSB decisions on carrageenan, infant formula annotation, 

cellulose annotation, and inerts annotation – The NOSB will discuss this during the Executive 

Subcommittee call this Friday.
• Feedback about the spring 2013 meeting – The group discussed various aspects of the meeting, 

including the introduction of the emergency clause for tetracycline, without having voted on the 

main recommendation first. Many people were uncomfortable with the way the process was 

handled because several Board members and many members of the public were not aware of this 

document until it was projected on the screen. The group discussed the usefulness and purpose of 

the prep meeting, and the fact that some of the public feels the board is having “private” meetings.

The meeting is intended to be preparatory in nature in an effort to make sure members are familiar 

with the entire slate of proposals that will be presented, and to familiarize the group with logistics 

and administrative details. No votes are taken nor final decisions made at this meeting.

Future Call Schedule:

May 7, 2013 2:00 ET

May 21, 2013 2:00 ET

Aquaculture-CO2 (CBo, ZS)

Magnesium oxide (FT)

June 4, 2013 2:00 ET

Aquaculture-Chlorine (CBo)

June 18, 2013 2:00 ET

Aquaculture-Vitamins (CBe)

Aquaculture-Lignin Sulfonate (JFo/CBe)

Aquaculture-Micronutrients (CBe/JFo)

Streptomycin (ZS/HA)

July 2, 2013 2:00 ET

Streptomycin (ZS/HA)

July 16, 2013 2:00 ET

AWG if needed

August 6, 2013 2:00 ET 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013
NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday May 21, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Colehour Bondera (CBo), Harold Austin (HA), John Foster (JFo), Francis 

Thicke (FT), Mac Stone (MS), Zea Sonnabend (ZS)

Absent: Nick Maravell (NM) (Vice Chair), Carmela Beck (CBe)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Waiting for response

Fall 2013

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013
Petitioned Substances

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold
Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates committee action needed

Agenda

Crops Subcommittee work assignments for Fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups; streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; aquaculture guidance/standards for plants.

• Approve agenda

• Approve notes of Crops Subcommittee meeting on May 7, 2013

• Workplan Issues for Fall 2013

o magnesium oxide petition – discussion and TR sufficiency (FT)

o CO2: aquaculture (CBo)

o contaminants in farm inputs document/proposed plan (JFe)

o Inerts update (JFe)

• Report on ES discussion on NOP investigation of possible use of emergency use (7 U.S.C. 6518(k)(6) 

and 7 C.F.R. 205.672) of tetracycline use for fire blight

• Adjourn
Discussion

• The agenda was approved as is

• May 7, 2013 Subcommittee meeting notes approved without changes.

• Workplan Issues for Fall 2013

o Magnesium oxide petition – discussion and TR sufficiency (FT) – Magnesium Oxide is a 

synthetic substance petitioned to control viscosity for liquid suspension of humates. It’s

used as lime and is benign in soil, but is also non-essential. There are alternatives on the 

National List, and a member asked if the petition mentioned these and/or discussed the 

need for Magnesium Oxide over the others. The lead reviewer found the petition to be very 

thorough and the group considered the need for a TR. MgO is made from salt brine 

pumped from deep wells and the group thought that perhaps a TR could potentially give 

them more insight into any potential environmental concerns associated with the 

manufacturing process. They also discussed whether or not the NOSB could research those 

questions on their own. A member posed several questions: would the manufacturing 

process sway their determination, what subheading on §601 would this fit under, and 

where do we draw the line between essentiality and usefulness? Most members felt that 

the additional information about the manufacturing process would not alter their view. 

Subheading (j) soil amendments would be the only location under 601 that would be 

relevant. The consensus was that there are no detrimental effects but MgO is only essential 

if you apply it in liquid form, as opposed to other substances that can be applied dry. The 

petitioner indicated that it is preferable to apply as a liquid for worker health safety, and 

ease of application. The CS found the petition sufficient, and determined that they could 

complete the additional research on their own without requesting a TR. 

o CO2: aquaculture (CBo) – The members discussed the review of this substance and the 

petition and the inherent difficulties since there are no previous standards or guidance. 

Instead they relied on a previous recommendation from the Handling Subcommittee. CO2 is 

either mined or produced as a bi-product of a manufacturing process, and can be either a 

synthetic or non-synthetic process. The members discussed various topics such as the 

Canadian standards, and the worse-case scenario for CO2 effects on the environment under 

typical use patterns. The NOP indicated that they did not have any background data, but 

thought that perhaps the AWG would, so JFe will compile a list of questions for the AWG. 

The petitioner was previously asked to provide additional information about several 

petitions, and he indicated that all the answers to the questions were already included in

the petition. As a follow up to the response, the group asked for specific references in 

writing so they could locate the answers. The members would also like to have an aquatic 

plant expert available to answer questions in addition to the petitioner. 

o Contaminants in farm inputs document/proposed plan (JFe) – The Chair sent a draft 

document to group, which included background information that they discussed on the last 

call. A member noted that if the intent was for this to be a proposal for spring 2014 the 

timeline seemed too quick. The Chair noted that it is intended to be a discussion document 

not a proposal, but the member still felt spring 2014 was too early a target date. Members 

discussed inviting Lindsay Fernandez-Salvador from OMRI to speak about the process OMRI 

uses for screening for contaminants. They also discussed whether or not the NOSB should 

take up this review if OMRI has a similar, comprehensive document. A member noted that 

there would potentially always be unfinished work. 

o Inerts update (JFe) - The Inerts Working Group has not met since last CS meeting, but there 

is ongoing work being conducted. 
o The Chair relayed information from the last ES call for those who weren’t on it, regarding 

the fireblight emergency spray. The NOP determined it was not viable, and JFe asked that 

the NOP look further at this issue.

Future Call Schedule:

May 21, 2013 2:00 ET

Aquaculture-CO2 (CBo, ZS)

Magnesium oxide (FT)

June 4, 2013 2:00 ET

Aquaculture-Chlorine (CBo)

Magnesium oxide (FT)

June 18, 2013 2:00 ET

Aquaculture-Vitamins (CBe)

Aquaculture-Lignin Sulfonate (JFo/CBe)

Aquaculture-Micronutrients (CBe/JFo)

Streptomycin (ZS/HA)

July 2, 2013 2:00 ET

Streptomycin (ZS/HA)

July 16, 2013 2:00 ET

AWG if needed

August 6, 2013 2:00 ET 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday June 4, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Colehour Bondera (CBo), Harold Austin (HA), John Foster (JFo), Zea 

Sonnabend (ZS), Nick Maravell (NM) (Vice Chair), Carmela Beck (CBe), Mac Stone (MS)

Absent: Francis Thicke (FT)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Waiting for response

Fall 2013

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013
Petitioned Substances

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to LB and are 

awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info 

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Laminarin List at

205.601

TBD Petition sent to CS on 06 03 13.

Sufficiency response due 08 02 13. 

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold
Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spr 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 

(Sunset 2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups?; streptomycin petition (with HA); Sodium 

carbonate peroxyhydrate for spring 2014 (Sunset 2015), waiting on TR; aquaculture guidance/standards 

for plants.

Agenda

• Approve agenda

• Approve notes of crops subcommittee meeting on May 21, 2013

• Workplan Issues for Fall 2013

a. magnesium oxide petition – discuss recommended proposal (FT)

b. CO2: aquaculture – next steps (CBo)

c. chlorine: aquaculture – discuss checklist and related issues (CBo)

d. contaminants in farm inputs document/proposed plan - update (JFe)
e. Inerts update (JFe)

• Assign petitioned material: Addition of laminarin to section 205.601 of the National List. Please 

think about volunteering to lead the CS on this. See email from Lisa Brines, dated June 4, 2013

• Adjourn

Discussion

• The agenda was approved as is

• The May 21, 2013 Subcommittee meeting notes were approved with a minor change to the CO2 

discussion (the addition of the phrase “and can be either a synthetic or non-synthetic process.”

• Workplan Issues for Fall 2013

a. Magnesium oxide petition (FT). The Chair will let the NOP know that they will not request a new 

TR and will let FT know to proceed with the proposal and the annotation. 

b. CO2: Aquaculture next steps (CBo) – The group discussed whether or not they could move 

forward before the aquaculture rule is out. MS indicated that the Subcommittees should move 

forward with their reviews, and have them ready for the fall meeting, unless the review is not 

complete. The goal is to not rush through it for fall just to get it done, but to do it thoughtfully and 

accurately. Petition sufficiency was determined earlier and there was no request for a new TR. ZS 

noted that the checklist used was out of date and information that she had provided was omitted

from the review and therefore the draft proposal was unbalanced. Additionally, information about 

terrestrial plants should not have been included as it is not relevant.

c. Chlorine: aquaculture (CBo). The group discussed the petition and use of this material as a 

sanitizer, and discussed the need for more clarification. The Chair asked for a determination 

whether a TR is needed for chlorine. The Chair also asked that all petition sufficiency 

determinations for all aquaculture substances on the workplan be completed in the next 2 weeks. 

Poly-culture is built into organics and so if the standards for that and aquatic plant production were 

available, it would be easier to conduct this review. MS stated that CS members should not rush 

into completing the petition review for the fall meeting if they didn’t feel they had enough 

background information nor information on practical applicability in the petition.

d. Contaminants in farm inputs document/proposed plan - update (JFe) JFe wrote a more 

concise outline with timeframes because the original document had too large a scope, and will 

circulate it the group. 

e. Inerts update (JFe) - The next Inerts Working Group call is June 13th and an update will be 

provided on the next CS call. 

f. Assign petitioned material: Addition of laminarin to section 205.601 of the National List. Please 

think about volunteering to lead the CS on this. 

• Meeting adjourned
Future Call Schedule:

June 4, 2013 2:00 ET

Aquaculture-Chlorine (CBo)

Magnesium oxide (FT)

June 18, 2013 2:00 ET

Laminarin Assignment

Aquaculture-Vitamins (CBe)

Aquaculture-Lignin Sulfonate (JFo/CBe)

Aquaculture-Micronutrients (CBe/JFo)

Streptomycin (ZS/HA)

July 2, 2013 2:00 ET

Streptomycin (ZS/HA)

July 16, 2013 2:00 ET

AWG if needed

August 6, 2013 2:00 ET 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday June 18, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Colehour Bondera (CBo), Harold Austin (HA), John Foster (JFo), Zea 

Sonnabend (ZS), Francis Thicke (FT), Nick Maravell (NM) (Vice Chair), Carmela Beck (CBe), Mac Stone (MS)

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Spr 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Spr 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient...

Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to petitioner 

and are awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13.

Sufficiency response due 08 02 13. 

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold
1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups? streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; aquaculture guidance/standards for plants.
Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on June 4, 2013

• Streptomycin – draft checklist/recommendation(HA/ZS)

• Aquaculture Materials – progress report (draft checklists)

o Aquaculture-Vitamins (CBe)

o Aquaculture-Lignin Sulfonate (JFo/CBe)

o Aquaculture-Micronutrients (CBe/JFo)

• Assign petitioned material: Addition of laminarin to section 205.601 of the National List. Please 

think about volunteering to lead the CS on this. See email from Lisa Brines, dated June 4, 2013

• Magnesium oxide petition – discuss recommended proposal (FT)

• Contaminants in farm inputs document/proposed plan - update (JFe) Redrafted outline with 

timeframes.

• Inerts update (JFe/ZS)

• Adjourn

Discussion

• The agenda was approved as is

• The June 4, 2013 Subcommittee meeting notes were approved with a change to the text in points a 

and b as some of the information about CO2 was included in the section about chlorine.

• Streptomycin – draft checklist/recommendation (HA/ZS). The members discussed the edits to the 

draft checklist and proposal including the addition of an introduction and a comparison between 

tetracycline and streptomycin. Members noted that because the two materials are similar, the

proposals would be similar, in that it will have a majority and minority opinion. The group discussed 

the similarities and differences between the two substances, noting that the main differences 

include; modes of action, behavior in the soil, registration and time of usage. Streptomycin is used 

as curative (post infection), while tetracycline is used as preventative (pre-infection). Additionally, 

streptomycin can be used well into the growing season, and in human use, streptomycin is injected

which provides a much higher dosage than when it is administered orally. A member noted one 

study from Austria that found residue on fruit but in this instance, the substance was applied close 

to harvest, and no farming practices were included in the study. The members also discussed 

various questions on the checklist such as environmental contamination which the 2011 TR notes is 

unlikely, breakdown of the product, which the EPA notes as harmful to algae. In general there are 

no field studies, only lab studies, and results are contradictory. As for geographic considerations, 

there are isolated pockets of strep resistance in Pacific North West in apples and pears and in the

North East the temperature and precipitation regime is such that strep is primary treatment for 

fireblight. A member offered to update the group prior to the next call about some new research

results. The chair suggested framing this proposal differently than the tetracycline one decided that

compiling one document with a side by side comparison of the majority and minority opinions 

would make it easier for the reader. As an aside, members discussed some anecdotal data from CA 

growers regarding the use of Blossom Protect which they found was not effective, while results 

from the Pacific Northwest were mixed. Also, research trials with copper seem to have been 

successful but yeast treatments have not.
• Aquaculture Materials – progress report (draft checklists)

o Aquaculture-Vitamins (CBe). The petitioners are requesting approval of only three vitamins, 

including: B1 (Thiamine); B12 (Choline) & H (Biotin & B7) as these are the only ones 

required to be supplemented. The petition was found sufficient. CBo requested that the 

checklist be reworked with references other than solely from the petition.

o Aquaculture-Micronutrients for Aquatic Plants (CBe/JFo). The lead reviewer discussed 

information gleaned from the petition, the 2010 TR, and follow up conversations with the 

AWG. All trace elements are used in extremely small quantities. The partial list of 

micronutrients included in the petition are identified as the most useful and necessary; 

however, the science is relatively new and the petitioner would like to allow for the use of 

additional micronutrients in the future as new species are discovered. Additionally all 

micronutrients are allowed in crops with the exception of those made from nitrates or 

chlorides, and the petitioner is requesting the same allowance (minus the reference made 

to nitrates/chlorides). Micronutrients are well-known, non-toxic materials although there is 

no information on how they are manufactured. For more information regarding 

alternatives, see discussion below, under Lignin Sulfonate. The petition was found 

sufficient.

o Aquaculture-Lignin Sulfonate (JFo/CBe). JFo spoke at length with two members of the 

Aquaculture Working Group (AWG) during which they addressed specific questions that the 

Subcommittee had posed to the AWG in December. Lignin Sulfonate is an alternative to 

EDTA, which would not be allowed, but is financially preferable. Chelates are essential in 

soil systems to take up metals, and a member noted that it’s probably more essential in 

aquatic systems. The amount used in an aquatic system would not persist in an active 

microbial environment. JFo will redo the checklist using the additional information and will 

also include some additional scientific info that the AWG sent. JFo also asked the AWG 

questions about micronutrients. Although only a sample list of micronutrients was 

provided in the petition the AWG representative noted that 99 % of them are represented. 

Members discussed several possibilities for adding them to the National List, including the 

appropriateness of 601(j)(6)(ii) if they included a chloride form. They also discussed 

creating a relatively closed list so other materials, such as nickel, couldn’t be petitioned for 

use, having a truncated list and using the precedent in 601 to allay concerns and provide 

for the needs of producers. Members also discussed the manufacturing processes, which 

are variable; natural forms, which often contain accessory nutrients and require larger 

quantities and could introduce uncertainty into aquatic systems (which are tightly 

controlled), and the effectiveness of alternatives which provide chelation in a soil system 

but don’t seem to have the same effect in aquatic systems. 

• ZS volunteered to review the newly received petition for the addition of laminarin to section 

205.601 of the National List.

• Magnesium oxide petition – discuss recommended proposal (FT) – FT is working on filling out the

checklist for discussion on a future call. FT confirmed that there are manufacturing processes that 

do not use sulfuric acid, and is the case with the petitioner’s product.

• Contaminants in farm inputs document/proposed plan – update. JFe redrafted an outline with 

timeframes, and is working with ZS to further narrow the scope. They are considering two driving 

provisions in the regulation, and will determine by the next call if they will have a discussion 

document for the fall meeting. 

• Inerts update (JFe/ZS)-The Inerts WG is working with the EPA group - Design on the Environment. 

• Adjourn
Future Call Schedule:

June 4, 2013 2:00 ET

Aquaculture-Chlorine (CBo)

Magnesium oxide (FT)

June 18, 2013 2:00 ET

Laminarin Assignment

Aquaculture-Vitamins (CBe)

Aquaculture-Lignin Sulfonate (JFo/CBe)

Aquaculture-Micronutrients (CBe/JFo)

Streptomycin (ZS/HA)

July 2, 2013 2:00 ET

Streptomycin (ZS/HA)

Aquaculture-Lignin Sulfonate (JFo/CBe) review of cklist

Aquaculture-Micronutrients (CBe/JFo) review of cklist

July 16, 2013 2:00 ET

AWG if needed

August 6, 2013 2:00 ET 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday July 2, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Nick Maravell (NM) (Vice Chair), Harold Austin (HA), John Foster (JFo),

Zea Sonnabend (ZS), Francis Thicke (FT), Mac Stone (MS), Carmela Beck (CBe)

Absent: Colehour Bondera (CBo) 

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Fall 2013/Spr 

2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Fall 2013/Spr 

2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Fall 2013/Spr 

2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13-

07 02 13 - readying questions for 

contractor.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to petitioner 

and are awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13.

Sufficiency response due 08 02 13. 

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013
Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).
ZS: Inerts (with JFe) – request for TR’s for any groups?; streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for spring 2014 (Sunset 2015), waiting on TR; aquaculture guidance/standards for plants; 

laminarin (petition)

Agenda

• Approve agenda

• Approve notes of crops subcommittee meeting on June 18, 2013

• Streptomycin – sufficiency approval (confirm), draft checklist/recommendation (HA/ZS)

• Aquaculture-Lignin Sulfonate Review checklist, timing for action (JFo/CBe)

• Aquaculture-Micronutrients Review checklist, timing for action (CBe/JFo)

• Plan for finishing discussion on Aquaculture-Vitamins (CBe), Chlorine (CBo), CO2 (CBo)

• Contaminants in farm inputs document/proposed plan - update (JFe) Redrafted outline with ZS.

• Laminarin – timing for determination of petition sufficiency and need for TR. (ZS) 

• Magnesium oxide petition – Progress and date for vote (FT)

• Adjourn

Discussion

• MS announced that the fall meeting will be 3 days long, and asked that each of the Subcommittees 

think about any proposals that may be delayed in case we need to make more time for discussion. 

The options include the following: eliminate items as they drop off organically, delay aquaculture 

proposals wholesale until the spring 2014 meeting, or send proposals out for comment but delay 

voting until the spring 2014 meeting.

• The agenda was approved as is.

• The June 18, 2013 Subcommittee meeting notes were approved as is.

• Streptomycin (HA/ZS). JFe, ZS and HA spoke prior to the call about the streptomycin checklist and 

opened the discussion to the entire group. The Chair asked that the Subcommittee members add 

any feedback or comments about the version that was circulated so they can continue to edit and 

refine the document. Included in this version is language about the differences between 

tetracycline and strep, as well as a majority and minority opinion. Members also discussed some of 

the questions on the checklist that resulted in multiple answers (i.e. both yes and no). The 

petitioner is citing Confidential Business Information, which for now, doesn’t matter because they 

are petitioning it as a synthetic. The petition was deemed sufficient.

• Aquaculture-Lignin Sulfonate (JFo/CBe). Members discussed some additional questions and 

whether or not they wanted to send them back to the petitioner or just address them in the 

narrative in the proposal. The group reasserted their prior decision that the petition was sufficient. 

A member asked about using Lignin Sulfonate in an aquatic environment, and whether or not this 

was a concern. The general feeling is that this is not an issue as the amounts are minuscule. As for 

timing, this will likely be ready for the fall meeting even if the group decides to delay the 

aquaculture petitions until the spring. 

• Aquaculture-Micronutrients (CBe/JFo). The AWG is petitioning all micronutrients, and the 

Subcommittee previously discussed whether or not they could limit or close the list. The group 

discussed the potential need for a new TR and whether or not there were specific questions that 

could or needed to be addressed or clarified. JFo, who had several lengthy conversations with 

members of the AWG, noted that according to the AWG, if the current annotation for soil 

micronutrients along with selenium is applied to aquaculture, then 99.9% of the micronutrients are 

accounted for. Further, the AWG asked that if the NOSB chooses to close the list that they please 
close it as it is for soils. Members discussed the pros of this approach, which includes the benefit of 

it already existing in regulatory language. A member asked about residues in water, to which 

another member replied that the majority of these micronutrients are taken up by the plants and 

there isn’t much left in water. The members also discussed the potential problems of not bounding

the list. The Chair asked people to forward any follow up questions to the group. 

• Aquaculture - Vitamins (CBe), Chlorine (CBo), CO2 (CBo) - will discuss these items on the July 16 call.

• Contaminants in farm inputs - update (JFe). JFe redrafted the outline with ZS and will present it on a 

future call.

• Laminarin (ZS) – not discussed due to time constraints.

• Magnesium oxide petition (FT). The petition was found sufficient and the group discussed some of 

the information included in the checklist. Magnesium oxide is benign in soil but some

manufacturing processes include the use of acids, which is a limiting factor, while other 

manufacturing processes release CO2 into air. The Subcommittee did not request a TR for this, and 

instead asked the manufacturer for some additional information. FT asked for feedback from the 

members about the checklist as it was his first review. 

• Vinasse – The members feel that the TR is not sufficient as it does not address some of the 

significant questions such as removal, and technical and functional effects. Vinasse is permitted in 

the Canadian and European standards but there are processes similar to the ones for Vinasse that 

are not allowed in CN, the EU or the US. Members discussed whether or not this information can be 

gleaned from the TR contractor. A member suggested that the group can ask the right questions to 

get the information they need and will work to compile a list of 5 or 6 more questions about 

chemical changes, and processes. Another member felt that while some of the questions could be 

addressed in a revised TR, such as residuals, some could not. ZS offered to work with NM to 

compose the list of questions. 

• The meeting was adjourned.

Future Call Schedule:

July 2, 2013 2:00 ET

Streptomycin (ZS/HA)

Aquaculture-Lignin Sulfonate (JFo/CBe) review of cklist

Aquaculture-Micronutrients (CBe/JFo) review of cklist

Plan for finishing discussion on Aquaculture-Vitamins (CBe), Chlorine (CBo), CO2 (CBo)

Contaminants in farm inputs document/proposed plan - update (JFe) 

July 16, 2013 2:00 ET

Aquaculture- plant production Vitamins (B1, B12, H) (CBe)

Magnesium oxide petition (TF)

August 6, 2013 2:00 ET 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET
Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday July 16, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Nick Maravell (NM) (Vice Chair), Harold Austin (HA), John Foster (JFo),

Zea Sonnabend (ZS), Francis Thicke (FT), Mac Stone (MS), Carmela Beck (CBe), Colehour Bondera (CBo) 

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to petitioner 

and are awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13.

Sufficiency response due 08 02 13. 

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013
Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, need to make TR sufficiency determination; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).
ZS: Inerts (with JFe) – request for TR’s for any groups?; streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for spring 2014 (Sunset 2015), waiting on TR; laminarin (petition)

Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on July 2, 2013

• Streptomycin - draft recommendation, schedule vote. (HA/ZS)

• Aquaculture-Lignin Sulfonate review, final with footnote containing answers to CS questions sent to

AWG? TR update? (JFo/CBe)

• Aquaculture-Micronutrients review checklist final? TR update? (CBe/JFo) 

• Aquaculture-Vitamins (CBe) – petition sufficient, TR update?, checklist review, schedule vote. (see 

attached checklist and questions)

• Aquaculture - Chlorine (CBo) - petition & TR sufficient, checklist review, ready to vote?

• Aquaculture-CO2 (CBo) - petition sufficient, no request for TR update, checklist review, ready to 

vote?

• Contaminants in farm inputs document/proposed plan – vote? (JFe) Redrafted outline with ZS. 

Approve updated TR questions for vinasse (NM) 

• Laminarin –petition sufficiency and need for TR? (ZS) 

• Magnesium oxide petition – Update. Vote? (FT)

• Adjourn

Discussion

• Approve agenda – The laminarin discussion was postponed and replaced with research priorities

• The notes of Crops Subcommittee meeting on July 2, 2013 approved with no changes.

• Streptomycin – draft recommendation, schedule vote. (HA/ZS) - HA distributed a new draft 

document that combined 3 previously separate pieces and noted that the majority and minority 

opinions isn’t flushed out yet. The majority opinion supports an extension to 2017, and the minority 

is opposed to an extension and wants it to expire in 2014. The members discussed some specific 

language in the document that they would like to revise in an effort to present a balanced view. 

The group discussed including an executive summary which they felt would be helpful when 

presenting the document at the fall meeting. A member noted that the structure of the new 

document was much better and would like to include links and info for the public comment. ZS will 

make some comments on the draft document and forward them to the group. 

• Aquaculture-Lignin Sulfonate (JFo/CBe) - The group discussed the need for a new TR and decided 

that the questions posed just prior to the call were already answered by the petitioner and were 

already included in the updated checklist that was circulated. A member asked that the phrasing of 

one of the questions be corrected as it was not quite accurate. The phrase “... may result in periodic 

and/or episodic discharges of lignin sulfonate” should read “chelated micronutrients”. JFe asked 

that ZS add that language to the document. The Chair asked that the group read the updated 

checklist and be prepared to vote. 

• Aquaculture-Micronutrients (CBe/JFo) - The group discussed the need for a new TR and whether or 

not the 2010 TR is adequate. CBe felt that the TR was complete and the other members felt that 

information gleaned from public comments would be more helpful than a new TR. A member 

added that if they do not get enough public comment, they will be able to decide at the meeting 

how to move forward. One member noted his concern about using information about 

micronutrients in a terrestrial system and applying them to an aquatic system. 
• Aquaculture-Vitamins (CBe). MA stated that the Livestock Subcommittee requested a TR for 

vitamins for aquatic animals and trace minerals. The subcommittee requested a copy of both from 

the NL manager to see if any useful information could be found in either report that would help 

inform their evaluation of the vitamins and micronutrients petitions. 

• Aquaculture - Chlorine (CBo). CBo asked for more feedback about the draft document. A member 

had several questions and concerns, and asked that some of the language be changed to include 

more explanation. For example, there are two distinct uses indicated for chlorine but the 

information in the checklist does not make the distinction. Another member cautioned that the 

proposal should focus on the application for this specific use, rather than the “implications as used” 

as that is too far out of the scope of the petition. One member suggested asking for public 

comment from the perspective of an aquatic plant producer.

• Aquaculture-CO2 (CBo). CBo asked for more feedback about the draft document. A member 

reiterated an earlier concern that the document is not well balanced. The document detailed policy 

issues and referenced other policies not relevant to the petition. The same member also noted that 

the references to CO2 affecting the atmosphere are not accurate and need to be corrected. The 

group also discussed the inclusion of questions about the pros and cons of polyculture systems, so 

they can collect public comment. A member noted that although discussion of broader topics of 

organic and the Board’s responsibilities to the community are valuable, he feels that it shouldn’t 

delay the review of one material. 

• Contaminants in farm inputs document (JFe). The outline was redrafted and circulated but the 

document is preliminary and written informally and members felt that it was not ready for the fall 

2013 meeting.

• Approve updated TR questions for vinasse (NM) – The group has two main lingering questions

regarding the definition of synthetic versus non synthetic, and whether or not there is a chemical 

change during production and what chemicals remain in the final product. The group isn’t sure the 

TR contractor will be able to answer these questions, but ZS and HA have compiled a list of 

questions that could help elucidate. JFe will send the questions to the National List Manager. 

• Laminarin - postponed

• Magnesium oxide petition - (FT). JFe would like to talk with ZS more about this petition. During the 

review process, FT contacted the manufacturer for some additional information and although the 

processing component raised some questions he felt they were not concerning. The group does not 

feel they need to request a TR. 

• Research priorities. MS urged the group to think about potential topics for the research priorities

that have developed from the past year’s work, and send them to the Chair who will forward them 

to the Materials Subcommittee. 

• The group chose to add an extra call at 2:00pm ET on July 30. 

• Meeting adjourned

Future Call Schedule:

July 16, 2013 2:00 ET

Streptomycin (ZS/HA) –continued discussion of draft proposal

Aquaculture-Lignin Sulfonate (JFo/CBe) continued discussion/vote?

Aquaculture-Micronutrients (CBe/JFo) continued discussion/vote?
Aquaculture- plant production Vitamins (B1, B12, H) (CBe) – postponed due to time

Aquaculture - CO2- discuss/vote?

Aquaculture - Chlorine - discuss/vote?

Magnesium oxide petition (FT) –vote?

Laminarin - Petition sufficiency/TR request? (ZS) - postponed

Vinasse - discuss additional questions for Contractor

July 30, 2013 2:00 ET

Streptomycin (ZS/HA) –continued discussion of draft proposal

Aquaculture-Lignin Sulfonate (JFo/CBe) - vote?

Aquaculture-Micronutrients (CBe/JFo) - vote?

Aquaculture- plant production Vitamins (B1, B12, H) (CBe) –discuss need for TR, checklist review, 

schedule vote

Aquaculture - CO2- discuss/vote?

Aquaculture - Chlorine - discuss/vote?

Magnesium oxide petition (FT) - vote?

Laminarin - Petition sufficiency/TR request? (ZS)

August 6, 2013 2:00 ET 

Strep info (ZS) – vote?

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday July 30, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Nick Maravell (NM) (Vice Chair), Harold Austin (HA), John Foster (JFo),

Zea Sonnabend (ZS), Francis Thicke (FT), Colehour Bondera (CBo)

Absent: Mac Stone (MS), Carmela Beck (CBe), 

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13.

Fall 2013

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to petitioner 

and are awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13.

Petition sufficient 07 30 13

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013
Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for Fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.
NM: Vinasse, waiting on add’l TR question response; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups; streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; laminarin (petition)

Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on July 16, 2013

• Streptomycin - Update/vote? (HA/ZS) 

• Aquaculture - Discuss checklists for all the petitioned materials. Mini-report from Maine trip –to be 

followed by more in depth report (in writing). Voting schedule. 

• Laminarin - petition sufficiency, synthetic/nonsynthetic, need for TR? (ZS) 

• Magnesium oxide petition – Discussion. Vote? (FT)

• Research Priorities discussion (proposed CS research priorities (JFe): (i) Alternatives to chlorine; (ii) 

Bioplastic mulch. (iii) other proposals?

• Contaminants in farm inputs document/proposed plan - vote? (JFe) 

• Adjourn

Discussion

• Agenda was approved as is

• Notes from the July 16 Crops Subcommittee approved with no changes

• Streptomycin - Update/vote? (HA/ZS) – JFe will work on consolidating several drafts and resend it 

to HA so he can ready it for a vote for next call. 

• Aquaculture - JFe noted that the checklists for the aquaculture materials are nearly finished. JFe 

gave a mini-report about the Maine trip which will be followed by a more in depth written report. 

The overall consensus was that the aquaculture trip was very valuable and they gained a lot of 

insight that will be helpful with the materials review. As for the voting schedule, theCO2 document

needs to be revised and is not ready for voting in its current state. The group discussed the chlorine 

proposal and the idea of including questions for public comment. In light of that it too may not be 

ready for voting. JFe will discuss the schedule with the Board chair and report back on the next call. 

With regard to aquaculture in general a member suggested that the level of comfort people are 

experiencing centers around the policy and philosophy rather than the specific materials, and feels 

that the group needs to focus on the specific materials since they are known quantities. The 

members also discussed various aspects of aquaculture such as carrying capacity, monitoring, and 

standards which will be part of the Maine report. JFe asked that CBo distribute the documents on 

CO2 and chlorine, and include a specific motion or annotation in writing so the members can vote 

on the next call. 

• Laminarin - petition sufficiency, synthetic/nonsynthetic, need for TR? (ZS) – The lead reviewer felt 

the petition is straightforward and well explained, and the group deemed it sufficient. JFe will send 

a note to L. Brines indicating their determination. Laminarin is EPA approved and the group 

discussed the potential need for a TR. A member noted that the chemical reactions involved in the 

manufacturing process are very basic and based on that would deem this non-synthetic. He also 

noted that laminarin would be preferable to copper or sulfur. Another member supported this 

point of view but the Chair disagreed about the determination of non-synthetic and indicated that 
he would support asking for a TR to determine this. In support of this he offered to distribute some 

scientific literature to the group. Another member suggested asking the manufacturer questions to 

help clarify this issue instead of requesting a TR. ZS offered to search the references to help clarify 

this issue and will discuss this further. 

• Magnesium oxide petition – Discussion. Vote? (FT) – The group discussed the annotation and noted

that the petition is for a very specific use so the annotation doesn’t need to be complex. FT will edit 

the document and recirculate it in preparation for vote on the next call. 

• Research Priorities discussion (proposed CS research priorities (JFe): (i) Alternatives to chlorine; (ii) 

Bioplastic mulch. (iii) other proposals? Vote on list/prioritize, amend -deferred to next call.

• Contaminants in farm inputs document/proposed plan - vote? (JFe) - The group briefly discussed 

the status of this document.

• JFe will contact the Subcommittee members regarding the expectations for completion of

proposals (including motion and annotations (if applicable)) so they are ready for voting by the next 

call. 

• The meeting was adjourned.

Future Call Schedule:

July 30, 2013 2:00 ET

Streptomycin (ZS/HA) –continued discussion of draft proposal

Aquaculture-Lignin Sulfonate (JFo/CBe) - vote?

Aquaculture-Micronutrients (CBe/JFo) - vote?

Aquaculture- plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote

Aquaculture - CO2- discuss/vote?

Aquaculture - Chlorine - discuss/vote?

Magnesium oxide petition (FT) - vote?

Laminarin - Petition sufficiency/TR request? (ZS)

August 6, 2013 2:00 ET 

Strep info (ZS) – vote?

Aquaculture-Lignin Sulfonate (JFo/CBe) - vote?

Aquaculture-Micronutrients (CBe/JFo) - vote?

Aquaculture-plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote

Aquaculture-CO2-discuss/vote?

Aquaculture-Chlorine - discuss/vote?

Prioritize and vote on Research Priorities list 

Magnesium oxide petition (FT) - vote?

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET
Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday August 6, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Harold Austin (HA), John Foster (JFo), Zea Sonnabend (ZS), Francis Thicke 

(FT), Colehour Bondera (CBo), 

Absent: Carmela Beck (CBe), Nick Maravell (NM) (Vice Chair), Mac Stone (MS) – non voting

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal. 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13.

Spring 2014

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995 

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

08 06 13 Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Sent follow up questions to petitioner 

and are awaiting answers. 

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 TR Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

08 06 13 Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition sufficient 07 30 13

TBD

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013
Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for Fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.
NM: Vinasse, waiting on add’l TR question response; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups?; streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; laminarin (petition)

Agenda

• Approve agenda

• Approve notes from Crops subcommittee meeting on July 30, 2013

• Streptomycin – review checklist, vote (HA/ZS) 

• Aquaculture – Identify materials subcommittee members feel comfortable voting on, circulate updated 

checklists, discuss need for TRs (attaching Livestock Subcommittee checklist on lignin sulfonate as 

additional background)

• Magnesium oxide petition – Discussion. Vote. (FT)

• Research Priorities discussion (additional proposal to be distributed before meeting) JFe

• Laminarin –additional thoughts on need for TR from subcommittee members (ZS)

• Contaminants in farm inputs document/proposed plan (JFe) 

• Adjourn

Discussion

• Agenda was approved with no changes. 

• Notes from the July 30 Crops Subcommittee approved with no changes.

• Streptomycin. The lead reviewer summarized the petition and draft proposal which seeks to extend 

the expiration date from October 21, 2014 to October 21, 2017 to allow for transition to nonantibiotics methods for fireblight control. The group discussed the two views presented in the draft 

document, both for and against the extension. In general, proponents feel that the extension is 

necessary for producers and growers as alternative methods are not consistent or proven effective 

yet, while opponents cite studies of antibiotic resistance. The groups discussed the discussion 

section of the proposals and made some edits to the language therein, which includes the 

resolution as stated below. HA will take retain version control and JFe can make edits and send to 

HA. 

Vote on streptomycin:

5 y, 3 n, 0 absent

Motion: To remove existing expiration date of October 21, 2014 and replace it with an expiration 

date of October 21, 2017 for streptomycin for use in control of fireblight in apples and pears. 

Motion by: HA

Seconded by: ZS

Discussion: none

Yes: 5 No: 3 Abstain: 0 absent: 0 Recuse: 0 Two absent members voted via email and the vote 

tally was adjusted to reflect this.
Resolution: The National Organic Standards Board is committed to the phase out of this material. 

Between now and 2017 the Board urges growers and certifiers to include in organic systems plans 

an annual increase in the extent and/or number of alternative practices and materials that are 

trialed for controlling fire blight. In addition, the board strongly advocates to USDA a high priority 

for increased support for research into these alternative practices and materials.

Discussion: the group discussed the need to vote on this resolution and SJK felt that it is part of the 

majority position and does not warrant a separate vote. However, the members felt they wanted to 

vote separately. 

Motion by: HA

Seconded by: ZS

Discussion: none

Yes: 8 No: 0 Abstain: 0 absent: 0 Recuse: 0

• Magnesium oxide. – The group discussed the language in the draft proposal which included a very 

specific annotation. A member noted that annotations that are stringent have not historically been 

helpful, and if there is a reason to tighten the language that’s fine, but in this case it doesn’t seem 

necessary. The group reviewed the proposal and moved to vote. 

Vote on Magnesium Oxide

Motion: To classify Magnesium Oxide as petitioned as synthetic

Motion by: FT

Seconded by: CBo

Discussion: A member suggested adding the phrase “as petitioned” to the motion

Yes: 8 No: 0 Abstain: 0 absent: 0 Recuse: 0 

Motion to add Magnesium Oxide to §205.601 with the following annotation: For use only to control 

the viscosity of a clay suspension agent for humates.”

Motion by: FT 

Seconded by: ZS

Discussion: Members discussed and chose to remove the term “finely ground”

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0 

• The remainder of the agenda items were deferred to the August 20 call due to time

• Meeting was adjourned

Future Call Schedule:

 August 6, 2013 2:00 ET 

Streptomycin –confirm changes to proposal?

 Aquaculture-Lignin Sulfonate (JFo/CBe) - vote?

Aquaculture-Micronutrients (CBe/JFo) - vote?
Aquaculture-plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote

 Aquaculture-CO2-discuss/vote?

 Aquaculture-Chlorine - discuss/vote?

Research Priorities discussion

Laminarin –additional thoughts on need for TR from subcommittee members (ZS)

Contaminants in farm inputs document/proposed plan (JFe) 

August 20, 2013 2:00 ET

September 3, 2013 2:00 ET

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday August 20, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Harold Austin (HA), John Foster (JFo), Zea Sonnabend (ZS), Francis Thicke 

(FT), Colehour Bondera (CBo), Carmela Beck (CBe), Nick Maravell (NM) (Vice Chair), Mac Stone (MS) - non 

voting

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR

No new TR

Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR 

received 08 14 13. Sufficiency due 

10 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13. Revised TR sent to 

CS 08 20 13

Spring 2014

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

08 06 13 Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Tabled 

08 26 13

Fall 2013

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Aquaculture TR deemed unnecessary. 

Sent follow up questions to petitioner.

Response deemed sufficient.. 

Tabled 

08 26 13

Fall 2013

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

6/2013 

Minerals TR

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13. TR 

deemed unnecessary. 

Tabled 

08 26 13

Fall 2013

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 Crops 

TR

7/2013 TR

Aquatic 

Animals TR

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Tabled 

08 26 13

Fall 2013

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe 4/2013 

Aquatic 

Animals TR

Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Tabled 

08 26 13

Fall 2013

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

08 06 13 Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. 

Revised Petition Sufficiency Review; 

Rcv’d info from EPA 03 07 13 

addressing CS's questions. Questions 

sent back to petitioner; Petition suffic 
Petitioned Substances

due 04 23 13. Deemed insufficient?

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

Terminology for 

Excluded 

Methods 

(formerly Plant 

Breeding)

ZS Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed
Crops Subcommittee work assignments for Fall 2013 NOSB meeting:

HA: streptomycin petition (with ZS).

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on TR.

FT: Magnesium oxide.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), waiting on TR; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 

contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, waiting on add’l TR question response; Carbon Monoxide/Exhaust Gas (sent back to 

petitioner).

ZS: Inerts (with JFe) – request for TR’s for any groups? streptomycin petition (with HA); Sodium carbonate 

peroxyhydrate for Spring 2014 (Sunset 2015), waiting on TR; laminarin (petition)

Agenda

• Approve agenda

• Approve notes from the August 6 Crops Subcommittee meeting

• Streptomycin and magnesium oxide – complete voting.

• Decision/vote on petitions for plant aquaculture materials:

• Aquaculture-Lignin Sulfonate (JFo/CBe)

• Aquaculture-Micronutrients (CBe/JFo)

• Aquaculture-Vitamins (CBe) 

• Aquaculture- Chlorine (CBo) 

• Aquaculture- CO2 (CBo) 

• Research Priorities discussion (JFe)

• Laminarin –additional thoughts on need for TR from subcommittee members (ZS)

• Contaminants in farm inputs document/proposed plan (JFe) 

• Adjourn

Discussion

• Agenda was approved as is. 

• Notes from the August 6 Crops Subcommittee approved with a correction to the annotation for 

Magnesium Oxide and additional votes for MgO and Streptomycin issued via email added to the 

tally. ABS Note: CO was added back onto the workplan table above as per JFe. It was mistakenly 

removed after the spring meeting although the review process was not complete. 

• Streptomycin and magnesium oxide - A correction to the annotation for Magnesium Oxide and 

additional votes for MgO and Streptomycin issued via email added to the tally.

• Decision/vote on petitions for plant aquaculture materials: The group discussed the sense of the 

Subcommittee’s readiness with regard to voting on the aquaculture materials, and whether or not 

they felt they needed more discussion. Opinions were mixed - some felt they would prefer to wait 

until the regulation was released, and some felt ready based on the past discussions and prepared 
documents. The chair felt strongly that the Subcommittee should proceed to vote, and produce 

proposals reflecting the various points of view. 

• Aquaculture-Lignin Sulfonate (JFo/CBe) - JFo noted that no one submitted any other changes over 

the last two weeks via email as requested. The Chair suggested including a minority opinion but 

members and the NOP felt this was straightforward and did not warrant a minority opinion. The 

proposed action is to add it to the list. The group discussed restructuring the summary of the 

document and made some minor edits to the text. The motion was brought to the table for a vote, 

but after further discussion the vote was deferred to email for lack of time. 

Vote on lignin sulfonate – (Withdrawn and tabled August 26, 2013)

Motion to add lignin sulfonate to §205.609 for use as a chelating agent for aquatic 

micronutrients used in organic aquatic crop production environments. 

Motion by: JFo

Seconded by: HA 

Discussion: The Chair asked if the group would accept an amendment to the motion as 

follows: “To be used in a closed system not to be discharged into a natural body of water”. 

A member noted that there is no way to verify such a thing so doesn’t feel an annotation 

should be included as it is over prescriptive. The Chair noted that the practice is already 

employed in some aquaculture facilities, to which the previous member reiterated the lack 

of need for it to be included in an annotation. Opinions were mixed: some felt the 

annotation was redundant and some felt it didn’t matter if it was included. Another 

member noted that without some of these materials we will not have an aquaculture 

industry and we are limited to imported aquaculture, and felt it was important to vote. 

The Chair took a straw vote, as noted below, and will recirculate the documents via email 

and ask that people vote or send in further feedback, acknowledging that many members 

feel uncomfortable casting votes without further discussion.

Straw vote: 

Yes: 6 No: 2 Abstain: 0 Absent: 0 Recuse: 0 

Votes cast via email: 08 20 13: HA – Y, 

ABS NOTE August 26, 2013: After discussions via email the Subcommittee members chose 

to table the lignin sulfonate proposal and as such the motion was withdrawn by JFo and 

HA on August 26, 2013 (See below.)

• Aquaculture-Micronutrients (CBe/JFo) – The Chair proposed an annotation as follows: “Those 

made from nitrates are not allowed.”

Vote on Micronutrients: not completed. 

Motion to add micronutrients (Iron, copper, zinc, cobalt, manganese, molybdenum) to 

§205.609 of the National List. Those made from nitrates not allowed. 

Motion by: CBe

Seconded by: ?

Further discussion: The members discussed further the potential to vote on the 

aquaculture materials via email, and The Chair feels that the 3 proposals, Micronutrients, 
Vitamins and Lignin Sulfonate are very similar, and would like to add the same minority 

opinion to all and circulate them via email for a vote. 

Straw vote: 

Yes: 5 No: 2 Abstain: 1 Absent: 0 Recuse: 0 

• Aquaculture-Vitamins (CBe) - deferred

• Aquaculture- Chlorine (CBo) - - deferred

• Aquaculture- CO2 (CBo) - deferred

• Research Priorities discussion (JFe) - not discussed

• Laminarin –additional thoughts on need for TR from subcommittee members (ZS) – not discussed

• Contaminants in farm inputs document/proposed plan (JFe) – not discussed

• Meeting was adjourned

ABS NOTE August 27, 2013. After further deliberation, the Crops Subcommittee voted to table the vote on 

the aquaculture proposals until the Spring 2014 meeting:

Motion: To table the 5 plant aquaculture petitions (lignin sulfonate, vitamins, micronutrients, CO2, and 

chlorine):

Motion by: HA (via email 8 23 13).

Seconded by: JFo (via email 8 23 13)

Yes: 5 No: 2 Absent: 1 Abstain: 0 Recuse: 0

Future Call Schedule:

August 6, 2013 2:00 ET 

Streptomycin –confirm changes to proposal?

 Aquaculture-Lignin Sulfonate (JFo/CBe) - vote?

Aquaculture-Micronutrients (CBe/JFo) - vote?

Aquaculture-plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote

 Aquaculture-CO2-discuss/vote?

 Aquaculture-Chlorine - discuss/vote?

Research Priorities discussion

Laminarin –additional thoughts on need for TR from subcommittee members (ZS)

Contaminants in farm inputs document/proposed plan (JFe) 

August 20, 2013 2:00 ET

Aquaculture-Lignin Sulfonate (JFo/CBe) - vote? - not completed

Aquaculture-Micronutrients (CBe/JFo) - vote? - not completed

Aquaculture-plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote - not completed

Aquaculture-CO2-discuss/vote? - not completed 

Aquaculture-Chlorine - discuss/vote? - not completed

Research Priorities discussion - deferred
September 3, 2013 2:00 ET

Workplans

September 17, 2013 2:00 ET

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday September 3, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), John Foster (JFo), Harold Austin (HA), Zea Sonnabend (ZS), Francis Thicke 

(FT), Colehour Bondera (CBo), Carmela Beck (CBe), Nick Maravell (NM) (Vice Chair),

Mac Stone (MS) – non-voting

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR Original recomm Nov 2007

Request for TR 02 14 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR 

received 08 14 13. Sufficiency due 

10 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13. Revised TR sent to 

CS 08 20 13

Spring 2014

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

08 06 13 Fall 2013
Petitioned Substances

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Spring 2014

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Aquaculture TR deemed unnecessary. 

Sent follow up questions to petitioner.

Response deemed sufficient.

Spring 2014

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

6/2013 

Minerals TR

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13. TR 

deemed unnecessary. 

Spring 2014

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 Crops 

TR

7/2013 TR

Aquatic 

Animals TR

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Spring 2014

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe 4/2013 

Aquatic 

Animals TR

Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Spring 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

08 06 13 Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

Spring 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. 

Revised Petition Sufficiency Review; 

Rcv’d info from EPA 03 07 13 

addressing CS's questions. Questions 

sent back to petitioner; Petition suffic 
Petitioned Substances

due 04 23 13. Deemed insufficient?

Waiting on CS action based on EPA 

feedback and addendum from 

petitioner

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed

Crops Subcommittee work assignments for Spring 2014 NOSB meeting:

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), waiting on TR.

JFe: Inerts (with ZS) – request for TR’s for any groups?; Aqueous potassium silicate for Spring 2014 (Sunset 

2015), TR sufficiency; Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); 
contamination issues in farm inputs.

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, Carbon Monoxide/Exhaust Gas (sent back to petitioner).

ZS: Inerts (with JFe) – Sodium carbonate peroxyhydrate for spring 2014 (Sunset 2015), waiting on TR; 

laminarin (petition)

Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on August 20, 2013

• Workplan for spring 2014 NOSB meeting. 

• Status of checklists for the following: 

 Aquaculture-Lignin Sulfonate (JFo/CBe)

Aquaculture-Micronutrients (CBe/JFo)

Aquaculture-Vitamins (CBe)

• Discuss checklists/perspectives. Set deadline for completion and date for vote.

Aquaculture- Chlorine (? to write majority view) 

Aquaculture- CO2 (? to write majority view) 

• Future meetings: Sept 17, Oct 1, Oct 15 (last meeting before NOSB mtg), and beyond. 

 Schedule the following:

Review of public comments on strep and magnesium oxide

Sunsets: will schedule after fall meeting

Aqueous potassium silicate

Sodium carbonate peroxyhydrate

Sulfurous Acid

Petitions:

Laminarin - circulated disc points via email prior to call.

Vinasse - NM will review revisions and feedback 

Carbon monoxide?

Other issues:

Contaminants in farm inputs document/proposed plan (JFe) 

Inerts

• Adjourn

Discussion

• Agenda approved as is

• Notes of Crops Subcommittee meeting on August 20, 2013 approved as amended by chair prior to the 

call.

• Workplan for Spring 2014 NOSB meeting - There were several items from the Fall 2013 workplan that 

will be moved to the Spring 2014 workplan: Three sunset materials; aqueous potassium silicate, for 

which there was a TR requested; Vinasse for which a revised TR was received on August 20; Laminarin, 

which is under review and no TR will be requested. Carbon monoxide (CO), which was previously 

mistakenly removed from the workplan, was added back in to table above. The Subcommittee needs to 

review the feedback from the EPA and the addendum from the petitioner and make a determination.

Inerts will be updated at the spring 2014 meeting as well as Contamination Issues in Farm Inputs. 
• MS noted that the Subcommittee makeup and size may change for the fall, which the Chair will take 

into account for the workload. 

• MS indicated that it might be useful to have a seminar series on the Crops calls about aquaculture, 

much like the Livestock Subcommittee did. He offered to contact several USDA organizations, including 

the Aquaculture working group and National Institute of Food and Agriculture (NIFA) to ask for 

recommendations for speakers. A member noted that it would be helpful to hear from an algae 

specialist. Another member added that it might be helpful to get speakers to speak to both sides of the 

argument, but the Board Chair felt it was more important to hear form the people that can describe the 

system. The group would like to invite speakers to the September 17 and October 1 calls and perhaps 

have some discussion at the fall meeting. They also would like to have Mark Bradley summarize his 

perspective about the aquaculture rule. MS will circulate the list of speaker suggestions for the group 

to provide feedback. 

• ZS noted that there are two 2016 sunsets that need to be added to the table, which MA will do. 

• The group discussed the status of the checklists for the following aquaculture materials: Lignin 

Sulfonate (JFo/CBe), Micronutrients, Vitamins (CBe), Chlorine, and CO2. Several members indicated that 

the checklists are complete but feel that more discussion is needed, which is why they were delayed to 

the spring 2014 meeting. The Chair would like to schedule a contextual discussion about all 5 

aquaculture materials so the group can discuss the bigger picture and not necessarily the checklists for 

the individual materials. With regard to Lignin Sulfonate, the chair asked the members about possibly 

adding an annotation about the type of system (open, closed) if necessary, but will decide that as they

proceed.

• The group further discussed conducting a seminar series on aquaculture and the NOP asked the 

members if the seminar series was likely to alter the minority opinion that was inserted into the draft 

proposals. JFe noted that having a broader discussion about multi-trophic aquaculture systems would 

be helpful and would indicate that they’ve done due diligence, because their decisions are going to 

impact the aquaculture community. A member felt that this wasn’t necessary because the petitions are 

not systems petitions but are focused only on plant interactions. The NOP emphasized that in order to 

figure out the next steps they should have a problem statement. The NOP also added that aquatic 

plants are being certified now and perhaps looking at what certifiers are doing would be helpful. Plants 

that are and can be certified include such things as kelp, algae, and watercress. On the topic of 

hydroponics, which is a term that is not well defined, one of the members urged the group to make 

sure they were defining it the same way because hydroponics and aquatic plant production should not 

be assumed to be synonymous.

• The meeting was adjourned

Future Call Schedule:

August 20, 2013 2:00 ET

Aquaculture-Lignin Sulfonate (JFo/CBe) - vote? - not completed

Aquaculture-Micronutrients (CBe/JFo) - vote? - not completed

Aquaculture-plant production Vitamins (B1, B12, H) (CBe) - discuss need for TR, checklist review, 

schedule vote - not completed

Aquaculture-CO2-discuss/vote? - not completed 

Aquaculture-Chlorine - discuss/vote? - not completed

Research Priorities discussion - deferred

September 3, 2013 2:00 ET
Workplans

September 17, 2013 2:00 ET

Laminarin 

October 1, 2013 2:00 ET

October 15, 2013 2:00 ET

Review public comments on Strep and MgO. ZS, HA, and TF will distribute summaries of the public

comment. 

Nov 5

Nov 19

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday September 17, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), John Foster (JFo), Harold Austin (HA), Zea Sonnabend (ZS), Francis Thicke 

(FT), Colehour Bondera (CBo), Nick Maravell (NM) (Vice Chair), Mac Stone (MS) - non-voting

Guests: Mark Bradley, NOP and P.B. Ramkrishnan, Quality Certification Services (QCS), Jim Pierce (Oregon 

Tilth)

Absent: Carmela Beck (CBe) 

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK), Scott Updike (SU) 

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 2010 TR Original recomm May 2009

Request for TR 02 14 13 

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 2006 TR

09/2013 TR

Original recomm Nov 2007

Request for TR 02 14 13. TR sent to 

CS 09 16 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR 

received 08 14 13. Sufficiency due 

10 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13. Revised TR sent to 

CS 08 20 13

Spring 2014

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

08 06 13 Fall 2013
Petitioned Substances

to CS 02 28 13. Sufficiency due 04 29 

13. Petition found sufficient 07 02 13

Aquaculture-CO2, List 

at §205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Spring 2014

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Aquaculture TR deemed unnecessary. 

Sent follow up questions to petitioner.

Response deemed sufficient.

Spring 2014

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

6/2013 

Minerals TR

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13. TR 

deemed unnecessary. 

Spring 2014

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 Crops 

TR

7/2013 TR

Aquatic 

Animals TR

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Spring 2014

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe 4/2013 

Aquatic 

Animals TR

Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Spring 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

08 06 13 Fall 2013

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

Spring 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

Petition Addendum 

Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. 

Revised Petition Sufficiency Review; 

Rcv’d info from EPA 03 07 13 
Petitioned Substances

#1 (PDF) addressing CS's questions. Questions 

sent back to petitioner; Petition suffic 

due 04 23 13. Deemed insufficient?

Waiting on CS action based on EPA 

feedback and addendum from 

petitioner

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed
Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on September 3, 2013

• Guest Speakers

• Adjourn

Discussion

• Agenda was approved as is.

• Approval of notes from Crops Subcommittee meeting on September 3, 2013 was deferred to next call 

to allow for maximum time for guest participation.

• Mark Bradley gave a brief history of the aquaculture policies and summary of the impending rule. He 

noted the aquatic plants portion of the rule and what considerations were reviewed when writing the 

rule. He noted that it was a complex issue and there are challenges associated with fitting the 

petitioned materials into the existing regulations. Members had several questions for the NOP about 

aquatic plants and why the NOSB was being asked to review materials if they are already on the 

National List for other uses. P.B. Ramkrishnan, (Ram), today’s guest speaker, answered that even 

though the materials are on the list, it would be helpful to understand the different systems. The group 

discussed various aspects of this such as the definition of aquatic plants and the distinction between 

vascular and non-vascular plants. Ram noted that the 2007 NOSB recommendation uses the term nonvascular plants, which he finds extremely useful. He also noted another critical distinction in the 

recommendation: the Crops standards apply to materials meant for human consumption. Ram’s 

specialty is algae and he briefed the Board about several aspects of this component: CO2 use is only 

important for aquatic plant operations that are high-intensity, and is needed to make them 

commercially competitive; and algae is grown in raceways, ponds and bioreactors. Ram distinguished 

between algae grown for human consumption (spirullina and chlorella) and livestock. He indicated that 

livestock algae did not have to be organic because it would be fed to small fry while they are still below 

the 5% of finished market weight threshold. He also noted that it could be organically produced.

• A member asked a question about hydroponics since aquatic plants can be produced under the current 

regulations. Ram clarified that aquatic plants are non-vascular. Some aquatic plants are started in test 

tubes, then transferred to dishes, flats, and then finally to large reactors or ponds. Some are started 

and then seeded onto nets and grown in open water.

• The Chair asked a question about nutrient shifts, and Ram referenced a system in Puerto Rico as an 

example where they are growing tilapia and shrimp in ponds. The water is then used to produce micro 

algae, which is subsequently harvested for bio fuels. He indicated that the limiting factor in the system 

is CO2 where in a pond based system the limiting factor is CO2 and micronutrients. The NOP asked Ram 

if he could send some literature about the 3 different algae production systems. 

• Members discussed overprescribing their recommendations, when several members felt that it should 

be a decision left to the certifiers. The Chair added that he would support parameters to help protect 

integrity. 

• The meeting was adjourned. 
Future Call Schedule:

September 3, 2013 2:00 ET

Workplans

September 17, 2013 2:00 ET

Guests: Mark Bradley, NOP, Jim Pierce, Oregon Tilth, and P.B. Ramkrishnan, QCS

October 1, 2013 2:00 ET

Guest: Dr. Tidwell, KY State University Aquaculture Program Manager

Laminarin

October 15, 2013 2:00 ET

Guest: Max Mayeaux, USDA-NIFA

Review public comments on Strep and MgO. ZS, HA, and TF will distribute summaries of the public

comment. 

Nov 5

Nov 19

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday November 5, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe) Colehour Bondera (CBo), Carmela Beck (CBe), Zea Sonnabend (ZS), Jean 

Richardson (JR) - sitting in, Mac Stone (MS) - nonvoting

Absent: Francis Thicke (FT), Harold Austin (HA), John Foster (JFo), Nick Maravell (NM) (Vice Chair)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan (Will be replaced with updated version after November Executive Call)

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 2010 TR Original recomm May 2009

Request for TR 02 14 13

TR sent to CS on 10 25 13

TR suff response due 12 27 13

Summary-Fall 

2013/ProposalSpring 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 2006 TR

09/2013 TR

Original recomm Nov 2007

Request for TR 02 14 13. TR sent to 

CS 09 16 13. TR suff response due 

11 15 13

Summary-Fall 

2013/ProposalSpring 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR 

received 08 14 13. TR Sufficiency 

due 10 14 13

Summary-Fall 

2013/ProposalSpring 2014

Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/NM Yes. 

Expedited, 

modified TR

Petition sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modified TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to 

CS 04 29 13. Sufficiency due 06 28 13. 

Additional questions for contractor 

sent to LB 07 16 13. Revised TR sent to 

CS 08 20 13. Suff due 10 20 13

Spring 2014

Antibiotics 

(Streptomycin) 

proposal. Amend 

annotation, §205.601

ZS/HA 3/2011 TR

1/2006 TR

10/1995

TAP

Apr 2011 Final Recomm. NOP rcv’d 

petition but sent back to petitioner for 

revision. Rcvd revised petition 01 07 

13 and sent back again for 

incompleteness. Revised petition sent 

to CS 02 28 13. Sufficiency due 04 29 

08 06 13 Fall 2013

Meeting 

cancelled
Petitioned Substances

13. Petition found sufficient 07 02 13

Aquaculture-CO2, List 

at §205.609

CBo/ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner (for 

use pattern). Updated petition was 

deemed sufficient. TR deemed 

unnecessary.

Spring 2014

Aquaculture-Chlorine

List at §205.609 and 

§205.611

CBo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from petitioner

11 20 12. TR deemed suff 11 20 12. 

Aquaculture TR deemed unnecessary. 

Sent follow up questions to petitioner.

Response deemed sufficient.

Spring 2014

AquacultureMicronutrients List 

at §205.609

CBe/JFo 2010 TR 

(Nickel)

6/2013 

Minerals TR

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 08 

08 12? CS sent request to NL Mgr 

12 04 12 for additional info. Questions 

clarified by petitioner. Petition found 

sufficient 06 18 13 and 07 02 13. TR 

deemed unnecessary. 

Spring 2014

Aquaculture-Lignin 

sulfonate (chelating 

agent for aquatic 

plants) List at 

§205.609

JFo/CBe 2/2011 Crops 

TR

7/2013 TR

Aquatic 

Animals TR

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL Mgr 

12 04 12 for additional info and TR. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 and 

07 02 13.

Spring 2014

Aquaculture- plant 

production Vitamins 

(B1, B12, H) List at 

§205.609

CBe 4/2013 

Aquatic 

Animals TR

Petition sent to CS 08 10 12. Petition 

Sufficiency response due 10 10 12. 

Petition found sufficient 06 18 13

Spring 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) oxide

TR

No new TR

Petition sent to CS on 02 14 13.

Petition found sufficient 05 21 13. No 

TR requested

08 06 13 Fall 2013

Meeting 

cancelled

Laminarin List at

205.601

ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

Spring 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

Petition Addendum 

Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. 

Revised Petition Sufficiency Review; 

Rcv’d info from EPA 03 07 13 

?
Petitioned Substances

#1 (PDF) addressing CS's questions. Questions 

sent back to petitioner; Petition suffic 

due 04 23 13. Deemed insufficient?

Waiting on CS action based on EPA 

feedback and addendum from 

petitioner

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA Update Fall 

2013

Meeting 

cancelled

Polyglyceryl 

phthalate ester 

of coconut oil 

fatty acid (inert)

Sent to CS on 06 01 11; Needs petition 

sufficiency review. On hold. 

On hold

1,1-

Difluoroethane 

(inert)

Yes On 01 21 11 - Petitioner notified NOP 

they would like to continue review; 

Review TR for sufficiency. On hold

On hold

Manganese 

sulfate 

monohydrate 

(inert)

Yes On 02 03 11, petitioner notified NOP 

they would like to continue review; CS

may want to re-evaluate request for TR 

since this is an inert

On hold

Ethylene DDSA / 

EDDS (inert)

JFe Yes On hold On hold

Terpene 

Polymers (inert)

? Maybe On hold On hold

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Mushroom 

standards

Waiting to comment on rulemaking On hold

Food safety On hold On hold

Contamination 

Issues in Farm 

Inputs

JFe DD? White 

paper?

Will be worked on in discrete 

components

TBD

Seed Purity ZS/JFe/CBo Proposal GMO is lead. Joint w/Crops. Fall 2013 

* Yellow highlight indicates Subcommittee action needed
Crops Subcommittee work assignments for Spring 2014 NOSB meeting:

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), TR sufficiency 

(need vote).

JFe: Inerts (with ZS); Aqueous potassium silicate for Spring 2014 (Sunset 2015), TR sufficiency (need vote); 

Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); contamination issues in farm 

inputs (need explanation from NOP on requirements of briefing document as distinguished from document 

CS approved).

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, modified TR sufficiency, Carbon Monoxide/Exhaust Gas (sent back to petitioner).

ZS: Inerts (with JFe) – Sodium carbonate peroxyhydrate for spring 2014 (Sunset 2015), TR sufficiency (need 

vote); laminarin (petition), need vote on whether TR is needed.

Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on September 3 and 17, 2013

• Review Workplan for next (Spring 2014?) NOSB meeting, as authorized by NOP 

• Status of checklists for the following. What more is needed? Set deadline for completion and date for 

votes

o Aquaculture-Lignin Sulfonate (JFo/CBe)

o Aquaculture-Micronutrients (CBe/JFo)

o Aquaculture-Vitamins (CBe)

o Aquaculture- Chlorine (CBo), CO2 (CBo) captured in checklist 

• Other business

o Schedule the following:

- Review of public comments to CS (for canceled fall 2013 meeting). 

- Sunsets:

Aqueous potassium silicate (review and vote on TR sufficiency)

Sodium carbonate peroxyhydrate (review and vote on TR sufficiency)

Sulfurous Acid (review and vote on TR sufficiency)

o Petitions:

Laminarin (set vote on need for TR)

Vinasse (set vote on revised TR sufficiency, dated 8-16-13)

Carbon monoxide: Vote on petition sufficiency, including petition addendum of 

2/21/201)

• Other Issues

o Contaminants in farm inputs document/proposed plan (JFe). 

o Inerts

• Summarize agenda for next meeting. 

• Adjourn

Discussion

• Agenda approved as is

• Approval of Crops Subcommittee notes of September 3 and 17, 2013 deferred to next call
• Review Workplan: No new items were added to the workplan

• Status of checklists for the following:

o Aquaculture-Lignin Sulfonate (JFo/CBe) - JFe will confirm with JFo that the document is in its 

final form and will not be revised for the Spring 2014 meeting

o Aquaculture-Micronutrients (CBe/JFo) - CBe will do some minor editing based on public 

comments.

o Aquaculture-Vitamins (CBe) - CBe will do some minor editing based on public comments.

o Aquaculture- Chlorine (CBo) - CBo would like to hear other views so they can be incorporated

into the document. 

- The group will discuss these proposals once they are completed. 

o Aquaculture - CO2 (CBo) – A member indicated that this document should include alternate 

views, which CBo will solicit and incorporate. 

- The group would like to follow up with P.B. Ramkrishnan (Ram) of QCS, who was on the 

September 17th call, about some documents he said he would forward. The 

Subcommittee would like to re-invite Jim Tidwell of KSU and Jim Pierce of Oregon Tilth 

to a future call since they were supposed to be on calls that were cancelled. A member 

noted that it would be more useful to have the speakers participate before moving 

forth with the aquaculture proposals. 

• Other business

o The following items were discussed and added to the schedule below:

- Review of public comments: JFe will circulate the summary of comments with a request to 

the members to determine if revisions to the fall 2013 proposals need to be made. 

Scheduled for further discussion on February 4, 2013

- Sunsets: The following sunset items were added to the January 21 discussion schedule 

below: Aqueous potassium silicate (review and vote on TR sufficiency), Sodium carbonate 

peroxyhydrate (review and vote on TR sufficiency), and Sulfurous Acid (review and vote on 

TR sufficiency)

- Petitions:

Laminarin – The lead reviewer feels a TR is not needed but would like the other 

members to weigh in. Scheduled to discuss and vote on the need for a TR on 

December 17, 2013

Vinasse - Needs more discussion. ZS will co-review this with NM. Scheduled to vote 

on TR sufficiency January 21

Carbon monoxide - vote on petition sufficiency was scheduled for February 4

• Other issues

o Contaminants in farm inputs document/proposed plan (JFe). The NOP has asked for a briefing 

paper and the Chair inquired as to the adequacy of the paper that was adopted by CS and sent to 

the NOP July 1, 2013. The NOP feels that the document is too broad in scope and would like to see 

a more discrete list of needs to be addressed. A member noted that the introduction was 

intentionally written to be broad, but the remainder of the document focuses in on the topics. The 

group felt that some of the sections will be difficult to articulate at this time, until they can delve 

deeper into the subject matter. Additionally, the Subcommittee would like to then invite speakers 

to help define the document better, but was waiting for NOP approval before doing so. SJK asked 

that ZS rewrite a brief synopsis and send it to her for review. 

o Inerts – No update.

• The review of public comments and discussion of the potential need to revise any of the fall 2013 

proposals based on the comments was scheduled for February 4, 2013.
• The workplan table has been updated with the 2014 workplan items and will replace the one above in 

the next set of notes. Additionally, a 2014 milestone timeline has been added below and will replace 

the fall 2013 milestones.

Future Call Schedule:

September 17, 2013 2:00 ET

Guests: Mark Bradley, NOP, Jim Pierce, Oregon Tilth, and P.B. Ramkrishnan, QCS

October 1, 2013 2:00 ET (CANCELLED DUE TO GOV’T SHUTDOWN)

Guest: Dr. Tidwell, KY State University Aquaculture Program Manager

Laminarin

October 15, 2013 2:00 ET (CANCELLED DUE TO GOV’T SHUTDOWN)

Guest: Max Mayeaux, USDA-NIFA

Review public comments on Strep and MgO. ZS, HA, and TF will distribute summaries of the public

comment. 

November 5, 2013 2:00 ET

November 19, 2013 2:00 ET

Jim Tidwell (KSU) –Discuss aquaculture

Vote: TR sufficiency for Aqueous potassium silicate

Vote: TR sufficiency for Sodium carbonate peroxyhydrate

December 3, 2013 2:00 ET

Jim Pierce + additional OTCO expert on plant aquaculture

Vote on TR sufficiency for sulfurous acid

December 17, 2013 2:00 ET

Discuss/Vote: Aquaculture - CO2 

Discuss/Vote: Aquaculture - Chlorine

Discuss/Vote on need for TR for Laminarin 

January 7, 2014

Discuss/Vote: Aquaculture-Lignin Sulfonate (JFo/CBe)

Discuss/Vote: Aquaculture-Micronutrients (CBe/JFo)

Discuss/Vote: Aquaculture-Vitamins (CBe)

January 21, 2014

Three 2015 sunsets (Aqueous potassium silicate, Sodium carbonate peroxyhydrate, sulfurous acid

TR sufficiency on Vinasse

February 4, 2014

NOSB Training meeting in DC

Determine sufficiency of information and vote on carbon monoxide

Discuss and/or modify any fall 2013 proposals based on public comments

Feb 18, 2013 

2016 Sunsets: Assign lead for ferric phosphate and hydrogen chloride, discuss and determine need 

for TR

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013
NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call CANCELLED 

Fall 2013 NOSB Meeting – Louisville, KY CANCELLED

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday November 19, 2013 2:00 pm ET 

Present: Jay Feldman (Chair) (JFe), Colehour Bondera (CBo), Carmela Beck (CBe), Zea Sonnabend (ZS), 

Francis Thicke (FT), Harold Austin (HA), Zea Sonnabend (ZS), Tracy Favre (TF), Mac Stone (MS)-sitting in

Jean Richardson (JR) - sitting in

Absent: John Foster (JFo), Nick Maravell (NM) (Vice Chair)

Guest: James Tidwell, Kentucky State University

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK), Mark Bradley (MB)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR requested? Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

Cbo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

TR sent to CS on 10 25 13

TR suff response due 12 27 13

Summary: 

Fall 2013 

Review: Spr 

2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR Original recomm Nov 2007

Request for TR 02 14 13. TR sent to 

CS 09 16 13. TR sufficiency due 11 

15 13

Summary: 

Fall 2013 

Review: Spr 

2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR 

received 08 14 13. TR sufficiency 

due 10 14 13

Summary: 

Fall 2013 

Review: Spr 

2014

2016 Sunsets

Substance Contact TR requested? Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

Sunset 09 12 16 Summary: 

Spr 2014

Review: Fall

2014
Hydrogen chloride 

205.601(n) 

CAS # 7647–01–0)

Sunset 09 12 16 Summary: 

Spr 2014

Review: Fall

2014

Petitioned Substances

Substance Contact TR requested? Notes* Vote Meeting

Vinasse - proposal List at 

§205.601

ZS/NM Yes. Expedited, 

modified TR

Petitn sent to CS on 03 29 12. Sent 

request for feedback on feasibility 

for modif TR to LBrines. LB sent 

feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent 

to CS 04 29 13. Sufficiency due 06 

28 13. Additional questions for 

contractor sent to LB 07 16 13. 

Revised TR sent to CS 08 20 13. TR 

Suff due 10 20 13

Proposal 

Spring 2014

Aquaculture-CO2, List at 

§205.609

CBo, ZS No Petition sent to CS on 5 30 12. Will 

rqst modification from petitioner 

(for use pattern). Updated petition 

was deemed sufficient. TR deemed 

unnecessary.

Proposal 

Spr 2014

Aquaculture-Chlorine List 

at §205.609 and §205.611

Cbo No Petition sent to CS on 5 30 12. 

Determine petition sufficiency. CS 

requested clarification from 

petitioner 11 20 12. TR deemed 

suff 11 20 12. Aquaculture TR 

deemed unnecessary. Sent follow 

up questions to petitioner. 

Response deemed sufficient. 

Proposal 

Spr 2014

AquacultureMicronutrients List at 

§205.609

CBe/Jfo 2010 TR 

(Nickel)

6/2013 

Minerals TR

Petition sent to CS on 06 08 12. 

Petition sufficiency response due 

08 08 12? CS sent request to NL 

Mgr 12 04 12 for additional info. 

Questions clarified by petitioner. 

Petition found sufficient 06 18 13 

and 07 02 13. TR deemed 

Proposal 

Spr 2014
Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/Cbe 2/2011 Crops 

TR

7/2013 TR 

Aquatic 

Animals TR

Petition sent to CS on 07 03 12. 

Petition Sufficiency Response due 

09 04 12. CS sent request to NL 

Mgr 12 04 12 for additional info 

and TR. Questions clarified by 

petitioner. Petition found sufficient 

06 18 13 and 07 02 13. 

Proposal 

Spr 2014

Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

Cbe 4/2013 Aquatic 

Animals TR

Petition sent to CS 08 10 12. 

Petition Sufficiency response due 

10 10 12. Petition found sufficient 

06 18 13

Proposal 

Spr 2014

Laminarin List at 205.601 ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

Proposal 

Fall 2014?

Carbon monoxide 

(exhaust gas) List at 

§205.601

Petition sent to CS on 06 06 

12Petition deemed insufficient 12 

04 12. Petition revised and sent to 

CS 2 22 13. Revised Petition 

Sufficiency Review; Rcv’d info from 

EPA 03 07 13 addressing CS's 

questions. Questions sent back to 

petitioner; Petition sufficiency due

ASAP. Waiting on CS action based 

on EPA feedback and addendum 

from petitioner

?

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, 

complete groupings, exact number to 

be determined

NA ?

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs

Jfe DD? White 

paper?

The NOP requested a summary on 11 

05 13 of the briefing paper that the 

NOSB submitted in July, listing the 

discrete components that the 

Subcommittee is proposing to work on. 

This will shape the future direction of 

this item. 

Fall 2014?

* Yellow highlight indicates Subcommittee action needed
Crops Subcommittee work assignments for Spring 2014 NOSB meeting:

CBe: Aquaculture micronutrients/trace elements; Aquaculture Vitamins (B1, B12, and H).

CBo: Aquaculture CO2; Aquaculture chlorine; Sulfurous Acid for Spring 2014 (Sunset 2015), TR sufficiency 

(need vote).

JFe: Inerts (with ZS); Aqueous potassium silicate for Spring 2014 (Sunset 2015), TR sufficiency (need vote); 

Plant Breeding in conjunction with Ad hoc GMO subcmte (with ZS, CBo); contamination issues in farm 

inputs (need explanation from NOP on requirements of briefing document as distinguished from document 

CS approved).

JFo: Aquaculture lignin sulfonate.

NM: Vinasse, modified TR sufficiency, Carbon Monoxide/Exhaust Gas (sent back to petitioner).

ZS: Inerts (with JFe) – Sodium carbonate peroxyhydrate for spring 2014 (Sunset 2015), TR sufficiency (need 

vote); laminarin (petition), need vote on whether TR is needed.

Agenda

• Approve agenda

• Approve notes of Crops Subcommittee meeting on November 5, 2013

• Guest: Jim Tidwell (KSU) - Discuss aquaculture 

• Adjourn

Discussion

• Agenda was approved as is

• Crops Subcommittee notes of September 3 and 17, 2013 were approved via email after the November 

5 call.

• Crops notes of November 5 were deferred due to lack of time.

• Guest: Jim Tidwell (KSU). Dr. Tidwell noted that while his primary focus is on pond aquaculture, he has 

broadened his scope and has recently written a book on aquaculture production systems. The Crops 

Subcommittee members provided Dr. Tidwell with a list of questions prior to the call and the group 

spent the remainder of the time discussing such things as: micro-algae and its intersection with animal 

aquaculture; the differences, similarities, economic incentives, etc between conventional and organic 

aquaculture; and the interest within the community in becoming certified organic. Dr. Tidwell indicated 

that the delay in releasing standards and the associated uncertainty have resulted in the loss of interest 

in becoming certified. Some groups are already certifying sustainability so they have options if they 

cannot use the “certified organic by USDA”, so although there is a demand, it is not clear how much 

demand there is for that classification. With regard to marketing, a member noted that there is a 

traceability aspect built into the organic world and asked how this would affect the market. The Crops 

Chair asked if Dr. Tidwell would be willing to entertain more questions via email or phone. MS asked if 

we could provide Jim the list of materials under review so he could provide additional information 

about the specific use of these materials. A member asked when the standards would be available, and 

the NOP indicated that the USDA is currently working on some language for the preamble to help clarify 

the intent of the regulation, but does not have a firm date for publication. 

• Future calls: ZS noted that she might not be able to participate in the Dec 3 and asked if we could invite 

Dr. Pierce to a later call instead. On the next call the group will reassign various workplan items, discuss 

the briefing paper on Contaminants in farm inputs and determine sufficiency of the TR for vinasse.

• TR sufficiency for aqueous potassium silicate (JFe). The members discussed the summary that was 

circulated via email to the group indicating that the TR did not address two critical aspects: Essentiality 

and effects on nutrients. A member noted that the TR didn’t seem to address the difference between 

disease control and deficiency in soil, although a previous TR did contain such information. The group 
would like to request additional clarifying information from the contractor. JFe and TF will write a list of 

questions and concerns and will present it on the next call. 

• TR sufficiency for sodium carbonate peroxyhydrate was deferred until the next call. 

• ZS requested that NOP provide feedback on the Contaminated Farm Inputs workplan item 

Future Call Schedule:

November 5, 2013 2:00 ET

November 19, 2013 2:00 ET

Jim Tidwell (KSU) - Discuss aquaculture

Vote: TR sufficiency for aqueous potassium silicate -postponed

Vote: TR sufficiency for Sodium carbonate peroxyhydrate -postponed

December 3, 2013 2:00 ET

Determine TR sufficiency for aqueous potassium silicate (due 10 14 13) 

Determine TR sufficiency for vinasse (due 10 20 13)

Determine TR sufficiency for Sodium carbonate peroxyhydrate (due 11 15 13) 

Contaminants white paper and response from NOP

Determine TR sufficiency for sulfurous acid (due 12 27 13)

December 17, 2013 2:00 ET

Jim Pierce + additional OTCO expert on plant aquaculture 

Discuss/Vote: Aquaculture - CO2 

Discuss/Vote: Aquaculture - Chlorine

Discuss/Vote on need for TR for Laminarin 

January 7, 2014

Discuss/Vote: Aquaculture-Lignin Sulfonate (JFo/CBe)

Discuss/Vote: Aquaculture-Micronutrients (CBe/JFo)

Discuss/Vote: Aquaculture-Vitamins (CBe)

January 21, 2014

Three 2015 sunsets (Aqueous potassium silicate, Sodium carbonate peroxyhydrate, sulfurous acid

February 4, 2014

NOSB Training meeting in DC

Determine sufficiency of information and vote on carbon monoxide

Discuss and/or modify any fall 2013 proposals based on public comments

Feb 18, 2013 

2016 Sunsets: Assign lead for ferric phosphate and hydrogen chloride, discuss and determine need 

for TR

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014
Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday December 3, 2013 2:00 pm ET 

Present: Jay Feldman (JFe), Colehour Bondera (CBo), Francis Thicke (FT), John Foster (JFo)

Absent: Harold Austin (HA), Carmela Beck (CBe), Zea Sonnabend, Chair (ZS)

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance Contact TR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 601(j) 

Original petition 2008

CBo 3/2010 TR Original recomm May 2009

Request for TR 02 14 13 

TR sent to CS on 10 25 13

TR suff response due 12 27 13. TR found 

insufficient. Submitted additional 

questions for TR contractor 12 03 13

Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 601(a)

Original petition 2006

ZS 8/2006 TR Original recomm Nov 2007

Request for TR 02 14 13. TR sent to CS 09 

16 13. TR sufficiency due 11 15 13. TR 

found insufficient. Submitted additional 

questions for TR contractor 12 03 

 

Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium silicate 

at 601(e) and 601(i) 

Original petitions: 2004, 

2006

JFe? 9/2003 TR Original recomm Nov 2007

Request for TR 02 14 13. TR received 08 

14 13. TR sufficiency due 10 14 13. TR 

found insufficient. Submitted additional 

questions for TR contractor 12 03 13

Summary: 

Spr 2014 

Review:

Fall 2014

2016 Sunsets

Substance Contact TR 

requested?

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

Sunset 09 12 16 Summary: 

Spr 2014 

Review:

Fall 2014

Hydrogen chloride 

205.601(n) 

CAS # 7647–01–0)

Sunset 09 12 16 Summary: 

Spr 2014 

Review:

Fall 2014
Petitioned Substances

Substance Contact TR 

requested?

Notes* Vote Meeting

Vinasse - proposal List at 

§205.601

ZS/NM Yes. 

Expedited, 

modified 

TR

Petitn sent to CS on 03 29 12. Sent 

request for feedback on feasibility for 

modif TR to LBrines. LB sent feedback 09 

04 12. The CS reqst’d a quick modified TR 

12 04 12. TR sent to CS 04 29 13. 

Sufficiency due 06 28 13. Additional 

questions for contractor sent to LB 07 16 

13. Revised TR sent to CS 08 20 13. TR 

Suff due 10 20 13. TR found sufficient 12 

03 13

Proposal 

Spring 2014

Laminarin List at 205.601 ZS Petition sent to CS on 06 03 13. 

Sufficiency response due 08 02 13. 

Petition found sufficient 07 30 13

Proposal 

Fall 2014?

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition 

revised and sent to CS 2 22 13. Revised 

Petition Sufficiency Review; Rcv’d info 

from EPA 03 07 13 addressing CS's 

questions. Questions sent back to 

petitioner; Petition sufficiency due ASAP.

Waiting on CS action based on EPA 

feedback and addendum from petitioner

?

Aquaculture-CO2, List at 

§205.609

CBo, ZS No Moved to Livestock/Aquaculture 

Subcommittee workplan

NA

Aquaculture-Chlorine List 

at §205.609 and §205.611

CBo No Moved to Livestock/Aquaculture 

Subcommittee workplan

NA

AquacultureMicronutrients List at 

§205.609

CBe/JFo 2010 TR 

(Nickel)

6/2013 

Minerals 

TR

Moved to Livestock/Aquaculture 

Subcommittee workplan

NA

Aquaculture-Lignin 

sulfonate (chelating agent 

for aquatic plants) List at 

§205.609

JFo/CBe 2/2011 

Crops TR

7/2013 TR 

Aquatic 

Animals TR

Moved to Livestock/Aquaculture 

Subcommittee workplan

NA
Aquaculture- plant 

production Vitamins (B1, 

B12, H) List at §205.609

CBe 4/2013 

Aquatic 

Animals TR

Moved to Livestock/Aquaculture 

Subcommittee workplan

NA

Inert Ingredients

Substance Contact TR reqtd? Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts - Review priority inerts, complete 

groupings, exact number to be 

determined

NA ?

Other Proposals

Project Contact Doc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs

JFe DD The NOP requested a summary on 11 05 

13 of the briefing paper that the NOSB 

submitted in July, listing the discrete 

components. CS sent summary to NOP 11 

06 13. NOP sent response to CS 11 19 13 

regarding rescoping doc: Contaminated 

Inputs Literature Review and Discussion 

Document

Fall 2014?

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve agenda

• Approve Crops Subcommittee notes of November 5 & 19, 2013

• Appoint a vice chair for the Crops Subcommittee

• Reassign workplan items

• Re-work the future call schedule in light of the aquaculture materials moving to the LS

• Assign Carbon Monoxide (exhaust gas) point person 

• Determine TR sufficiency for aqueous potassium silicate (due 10 14 13)

• Determine TR sufficiency for vinasse (due 10 20 13)

• Determine TR sufficiency for sodium carbonate peroxyhydrate (due 11 15 13)

• Determine TR sufficiency for sulfurous acid (due 12 27 13)

• Adjourn

• Contaminants paper and response from NOP

Discussion

• The agenda was approved as is

• Crops Subcommittee notes of November 5, 2013 were approved with no changes.

• Crops Subcommittee notes of November 19, 2013 were approved with no changes.

• ZS, the new Chair of the Crops Subcommittee, appointed FT as Crops Vice Chair
• Reassign workplan items

o FT volunteered to be the lead for Carbon Monoxide (exhaust gas) as NM rotated off of the 

Subcommittee. 

o Other workplans items were not reassigned. 

• Future call schedule - MA noted some changes below based on the redistribution of the aquaculture 

materials to the Livestock/Aquaculture Subcommittee. 

• Aqueous potassium silicate TR sufficiency - A member noted that he looked at and cited some new 

literature and felt it would be helpful to seek input from the contractor about the validity and 

usefulness of the citations. He added that the new research raises questions that the initial TR did not 

include. ZS will submit the citations to the National List Manager (LB) to refer to the TR contractor. The 

TR, as is, was not found sufficient. 

• Vinasse TR sufficiency. The primary question is whether or not vinasse is synthetic or not. A member 

noted that if it is determined to be synthetic and is used as a fertilizer, then it would be a problem. If it 

is determined to be natural, then perhaps the review does not need to be conducted. ZS feels it is a 

fertilizer and noted that it is currently used in formulated products, but since it is typically used in 

combination with other ingredients most growers do not know they are using it. It’s not marketed as a 

fertilizer but as JFo noted it does have a list of percentages of micronutrients. A member added that it 

would likely be used as a soil amendment not a fertilizer. The petitioner was asked some additional 

questions but did not address this or the additives question. The Subcommittee determined that the TR 

was sufficient and would notify LB of its status so it could be posted on the NOP website. 

• Sodium carbonate peroxyhydrate TR sufficiency. The Crops Chair noted that there is new research 

available that was not discussed in the TR and suggested sending it back to the contractor for revision. 

• Sulfurous acid TR sufficiency. The members concluded that there are some important questions that 

were not addressed in the new TR. A member noted the word remediation was used in the review of 

sulfurous acid, and indicated that it would be more honest and useful to frame the argument about 

sulfurous acid in light of the fact that most of the soil alkalinity problems are from irrigation and not 

overuse of this substance. Using the term remediation implies pollution, when in fact irrigation is the 

norm, especially in the Western US. He suggested replacing the term remediation with compensation. 

The members determined the TR to be insufficient and will send discussion points to ZS who will send 

them to LB to forward to the TR contractor. 

• Contaminants paper and response from NOP. The NOP supplied a response to the briefing paper from 

the Crops Subcommittee asking that the group first compile a list of sources and literature to determine 

if contaminants in farm inputs is a problem before it goes forth with any other work. A member noted 

that perhaps the question is a matter of degree and not whether or not there is a problem to begin 

with. Another member added that there will be differences in degree depending on what aspect is 

being considered, and advocated a risk assessment approach. A member emphasized the desire for a 

longer term goal so the document will not linger and a solution or resolution will be evident and 

transparent. Another member suggested that this would be a great topic for the Research Priorities. 

The NOP reiterated that they would support a survey of the literature before the group moves forward, 

as this would be an achievable deliverable for the next NOSB meeting. 

• The meeting was adjourned

Future Call Schedule:

November 19, 2013 2:00 ET

Jim Tidwell (KSU) - Discuss aquaculture

Vote: TR sufficiency for aqueous potassium silicate -postponed

Vote: TR sufficiency for Sodium carbonate peroxyhydrate –postponed
December 3, 2013 2:00 ET

Determine TR sufficiency for aqueous potassium silicate (due 10 14 13). Found insufficient. 

Determine TR sufficiency for vinasse (due 10 20 13). Found sufficient.

Determine TR sufficiency for sodium carbonate peroxyhydrate (due 11 15 13). Found insufficient.

Contaminants white paper and response from NOP. 

Determine TR sufficiency for sulfurous acid (due 12 27 13). Found insufficient.

December 17, 2013 2:00 ET

Reassign workplan items

Discuss/vote on need for TR for Laminarin

Discuss Contaminants briefing paper and response from NOP

January 7, 2014

January 21, 2014

Discuss vinasse checklist

February 4, 2014

NOSB Training meeting in DC

Determine sufficiency of information and vote on carbon monoxide

Discuss and/or modify any fall 2013 proposals based on public comments

Feb 18, 2013 

2016 Sunsets: Assign lead for ferric phosphate and hydrogen chloride, discuss and determine need 

for TR

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for addition to or 

removal from the National List. They do not represent official National Organic Program (NOP) policy or regulations. 

Please see the NOP website for official NOP policy, regulations, and status of substances used in organic production 

and handling.

National Organic Standards Board (NOSB)

Crops Subcommittee (CS) Meeting Notes

Tuesday December 17, 2013 2:00 pm ET 

Present: Jay Feldman (JFe), Colehour Bondera (CBo), Francis Thicke (FT), John Foster (JFo), Harold Austin 

(HA), Zea Sonnabend, Chair (ZS), Carmela Beck (CBe), Mac Stone (MS) - sitting

Absent: none

Staff: Michelle Arsenault (MA), Stacy Jones King (SJK)

Work plan

2015 Sunsets - § 205.601 Synthetic substances allowed for use in organic crop production 

Substance ContactTR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 

601(j) 

Original petition 

2008

CBo Y 10 25 13

3/2010 TR

Original recomm May 2009

Request for TR 02 14 13 

TR sent to CS on 10 25 13

TR suff response due 12 27 13. TR found 

insufficient. Submitted additional questions 

for TR contractor 12 03 13

Summary: 

Spr 2014 

Review:

Fall 2014

Sodium 

carbonate 

peroxyhydrate at 

601(a)

Original petition 

2006

ZS Y 02 14 13

8/2006 TR

Original recomm Nov 2007

Request for TR 02 14 13. TR sent to CS 09 16 

13. TR sufficiency due 11 15 13. TR found 

insufficient. Submitted additional questions 

for TR contractor 12 03 13

Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous 

potassium silicate 

at 601(e) and 

601(i) 

Original petitions: 

2004, 2006

JFe? Y 02 14 13

9/2003 TR

Original recomm Nov 2007

Request for TR 02 14 13. TR received 08 14 13. 

TR sufficiency due 10 14 13. TR found 

insufficient. Submitted additional questions 

for TR contractor 12 03 13

Summary: 

Spr 2014 

Review:

Fall 2014

2016 Sunsets

Substance ContactTR 

requested?

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–

0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

Sunset Date: 09 12 16

2003 Petition to add to 205.601

2003 Petition supplement

2005 NOSB rec (passed)

2009 Petition to remove from 205.601(h)

2012 NOSB rec (failed)

Summary: 

Spr 2014 

Review:

Fall 2014
Hydrogen 

chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Summary: 

Spr 2014 

Review:

Fall 2014

Petitioned Substances

Substance ContactTR 

requested?

Notes* Vote Meeting

Vinasse -

proposal List at 

§205.601

ZS/N

M

Yes. 

08 13 13 

Expedited, 

modified TR

Petitn sent to CS on 03 29 12. Sent request for 

feedback on feasibility for modif TR to LBrines. 

LB sent feedback 09 04 12. The CS reqst’d a 

quick modified TR 12 04 12. TR sent to CS 04 

29 13. Sufficiency due 06 28 13. Additional 

questions for contractor sent to LB 07 16 13. 

Revised TR sent to CS 08 20 13. TR Suff due 10 

20 13. TR found sufficient 12 03 13

Classifica

tion 

vote: 12 

17 13

Proposal 

Spring 2014

Laminarin List at 

205.601

ZS Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13

Proposal 

Fall 2014?

Carbon monoxide 

(exhaust gas) List 

at §205.601

FT Petition sent to CS on 06 06 12Petition 

deemed insufficient 12 04 12. Petition revised 

and sent to CS 2 22 13. Revised Petition 

Sufficiency Review; Rcv’d info from EPA 03 07 

13 addressing CS's questions. Questions sent 

back to petitioner; Petition sufficiency due

ASAP. Waiting on CS action based on EPA 

feedback and addendum from petitioner

TBD

Inert Ingredients

Substance ContactTR reqtd? Notes* Vote Meeting

Inerts update JFe/

ZS

N/A Inerts - Review priority inerts, complete 

groupings, exact number to be determined

NA ?

Other Proposals

Project ContactDoc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs Literature 

Review

JFe DD NOP rqstd summary on 11 05 13 of the 

briefing paper that the NOSB submitted in 

July. CS sent summary to NOP 11 06 13. NOP 

response sent 11 19 13 regarding rescoping 

discussion document. NOP approved addition 

to workplan as described in NOP response.

Fall 2014?

* Yellow highlight indicates Subcommittee action needed
Agenda

• Approve agenda

• Approve Crops Subcommittee notes of December 3, 2013

• Reassign workplan items

• Discuss/vote on need for TR for Laminarin

• Discuss Contaminants briefing paper and response from NOP

• Adjourn

Discussion

• The agenda was approved as is

• Crops Subcommittee notes of December 3, 2013 were approved without changes.

• Reassign workplan items

o 2016 sunsets: CBe will review ferric phosphate and JFo will review hydrogen chloride 

o The Subcommittee rescheduled discussion items (below) since there were no items scheduled 

for January 7. The discussion for petition sufficiency of carbon monoxide was moved from Feb 

4th to January 21. 

o MA removed aquaculture material from table above and made some other minor changes to 

links. 

• Discuss/vote on need for TR for Laminarin. The lead reviewer found the petition to be sufficient and 

pointed out that laminarin is produced through an acid/base extraction method which is allowed. This 

is very different from acid extraction, as was noted in a background info document that was circulated 

to the members. Since this is a naturally occurring extract she feels its use should be encouraged in 

organic agriculture. The group discussed the limitations of using the draft classification guidance to 

determine if laminarin is synthetic or non-synthetic. The description of the extraction process indicates 

that the acid used has no technical or functional effect on laminarin, so effectively it is a processing aid. 

A member noted that the situation is complicated by the fact that the word extraction is not well 

defined. The majority of members came to agreement about the classification of laminarin and the 

group chose to proceed to vote, but to seek input from the NOP about how to move forward. SJK will 

seek information and report back to the group ASAP. A member supported a request for a TR while 

several others did not, noting that if laminarin is determined to be synthetic, then there is no need for a 

TR. ZS gave an example from OMRI about listing pyrethrum without mentioning the extractants used. 

Vote on Laminarin:

Motion to classify laminarin as petitioned as non-synthetic: 

Motion by: ZS

Seconded by: HA

Discussion: A member noted that the petitioner listed laminarin as synthetic, which the CS Chair 

noted was a requirement. 

Yes: 5 No: 2 Abstain: 0 Absent: 0 Recuse: 0 

SJK will follow up with group about how to proceed.

• Discuss Contaminants briefing paper and response from NOP. ZS noted agreement with most of the 

items in the NOPs response document, with the exception of two things: 1) the request that this 

document be a literature review only, as she feels it will be more useful and productive as a discussion 

document. To support this work, the Subcommittee would like to invite guest speakers to discuss this 

and help identify key issues. The NOP supports this request. 2) The group would like to include other 

sources of contamination and not limit it to pesticide residues. The NOP response document supports 

this request. MA added this to the workplan, with JFe as the point person. JFe will identify and schedule 

guest speakers. 
• The meeting was adjourned

Future Call Schedule:

December 3, 2013 2:00 ET

Determine TR sufficiency for aqueous potassium silicate (due 10 14 13). Found insufficient. 

Determine TR sufficiency for vinasse (due 10 20 13). Found sufficient.

Determine TR sufficiency for sodium carbonate peroxyhydrate (due 11 15 13). Found insufficient.

Contaminants white paper and response from NOP. 

Determine TR sufficiency for sulfurous acid (due 12 27 13). Found insufficient.

December 17, 2013 2:00 ET

Reassign workplan items

Discuss/vote on need for TR for Laminarin

Discuss Contaminants briefing paper and response from NOP

January 7, 2014 2:00 ET

Discuss vinasse checklist

Ferric phosphate TR determination

 Hydrogen chloride TR determination

Discuss public comment for two fall 2013 proposals

January 21, 2014 2:00 ET

Determine petition sufficiency of information and vote on carbon monoxide

February 4, 2014 2:00 ET

NOSB Training meeting in DC

Discuss and/or modify any fall 2013 proposals based on public comments

Feb 18, 2013 2:00 ET

2016 Sunsets: Assign lead for ferric phosphate and hydrogen chloride, discuss and determine need 

for TR

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014