Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: May 25, 2012

Subject: Petition to add Gibberellic Acid to §205.605 (a) of the National 

 List for post harvest use on bananas.

Chair: Barry Flamm

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action _____X_____

Guidance Statement __________

Other _________ 

 

Statement of the Recommendation (Including Recount of Vote): 

Recommendation to add Gibberellic Acid to the National List 205.605 (a) for post 

harvest use on bananas.

MOTION FAILED (5 yes, 10 no, 0 absent 0 abstain 0 recusal) 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

The Handling committee recognizes the lack of alternatives in bananas and 

acknowledges that the research indicates that its use does not harm nutrition of 

bananas. For citrus there is evidence that it harms the nutritive value and its 

essentiality was not shown convincingly. Very little support was provided for use in 

pineapple. There was not sufficient evidence in either the petition or the TR that 

the material is necessary for citrus and pineapple. Furthermore, there is some 

evidence that the use in citrus can decrease nutritional content.

Committee Vote:

Moved: Jean Richardson Second: Harold Austin

Yes: 5 No: 10 Abstain: 0 Absent: 0 Recusal: 0 
National Organic Standards Board

Handling Committee

Petitioned Material Proposal

Giberellic Acid

March 20, 2012

Summary of Proposed Action:

This is a non-synthetic material that is allowed already for crop production and is being petitioned for 

post-harvest use to delay ripening of bananas, citrus, and pineapple. The need for it in bananas is 

also partially to delay or prevent development of the disease Black Sigatoka during transport to 

market.

Two issues are of concern to the Handling Committee that we are seeking public comment on. The 

first is whether there are cultural practices that would serve the same function in bananas to reduce 

the disease pressure after harvest. The second is the effect of post-harvest treatment on the 

nutritional content of the fruit. For this reason, it is being recommended for bananas, where the 

nutritional profile remains the same, and not recommended for other uses.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? (see 

“B” below)

1. Impact on Humans and Environment ☒ Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria ☒ Yes ☒ No ☐ N/A

3. Compatibility & Consistency ☒ Yes ☒ No ☐ N/A 

4. Commercial Supply is Fragile or Potentially Unavailable ☐ Yes ☐ No ☒ N/A 

as Organic (only for § 205.606)

Substance Fails Criteria Category: Essential and Compatible Comments: 

The Handling committee recognizes the lack of alternatives in bananas and acknowledges that the 

research that its use does not harm nutrition of bananas. But for citrus there is evidence that it harms 

the nutritive value and its essentiality was not shown convincingly. Very little support was provided for 

the use in pineapple.

Proposed Annotation (if any): for post-harvest use on bananas only.

Basis for annotation: ☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Notes: There was not sufficient evidence in either the petition or the TR that the material is 

necessary for citrus and pineapple. Furthermore, there is some evidence that the use in citrus can 

decrease nutritional content.

Recommended Committee Action & Vote, including classification recommendation (state actual 

motion):

Classification Motion: Move to determine that Giberellic Acid is non-synthetic

Motion by: Zea Sonnabend Seconded by: Harold Austin

Yes: # 5 No: # 0 Absent: # 1 Abstain: # 0 Recuse: # 0 

Listing Motion: Move that Giberellic Acid be added to the National List section 205.605(a) for 

post-harvest use on bananas only.
Revised March 2012

Motion by: Zea Sonnabend Seconded by: Tracy Favre

Yes: # 5 No: # 0 Absent: # 1 Abstain: # Recuse: # 

Crops ☐ Agricultural ☐ Allowed1 ☐

Livestock ☐ Non-synthetic ☐ Prohibited2 ☐

Handling ☐ Synthetic ☐ Rejected3 ☐

No restriction ☐ Commercial unavailable as 

organic

☐ Deferred4 ☐

1

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

2

Substance to be added as “prohibited” on National List to § 205. with Annotation (if any): 

Describe why a prohibited substance: 

3

Substance was rejected by vote for amending National List to § 205. . Describe why material 

was rejected: 

4

Substance was recommended to be deferred because 

If follow-up needed, who will follow up: 

Approved by Committee Chair to Transmit to NOSB

John Foster, Committee Chair March 20, 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 1. Adverse impacts on humans or the environment? Substance: Gibberellic Acid

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Are there adverse effects on 

environment from manufacture, use, 

or disposal?

[§205.600 b.2]

X

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3]

X

3. Is the substance harmful to the 

environment and biodiversity?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X

4. Does the substance contain List 1, 2 

or 3 inerts? [§6517 c (1)(B)(ii); 

205.601(m)2]

X active ingredient only under 

consideration. Formulations are

unknown.

5. Is there potential for detrimental 

chemical interaction with other 

materials used?

[§6518 m.1]

X

6. Are there adverse biological and X
Revised March 2012

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.

chemical interactions in agroecosystem? [§6518 m.5]

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5]

X does not come in contact with soil, 

crop or livestock.

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products?

[§6518 m.2]

X

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment?

[§6518 m.2]

X

10.Is there any harmful effect on human 

health? [§6517 c (1)(A)(i); 6517 

c(2)(A)i; §6518 m.4]

X

11.Is there an adverse effect on human 

health as defined by applicable 

Federal regulations? [205.600 b.3]

X

12.Is the substance GRAS when used 

according to FDA’s good 

manufacturing practices? [§205.600 

b.5]

X it is unclear whether the FDA 

regulates this as post-harvest 

material. The TR states it is not

GRAS but it is an approved food 

additive used in malting barley. (TR, 

2011, page 4)

13.Does the substance contain residues 

of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

X
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 2. Is the Substance Essential for Organic Production? Substance: 

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance formulated or 

manufactured by a chemical 

process? [6502 (21)]

X

2. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring 

plant, animal, or mineral, sources? 

[6502 (21)]

X

3. Is the substance created by naturally 

occurring biological processes? 

[6502 (21)]

X

4. Is there a natural source of the 

substance? [§205.600 b.1]

X the fungus Gibberella fujikuroi is the 

source.

5. Is there an organic substitute? 

[§205.600 b.1]

X

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 b.6]

X X it does seem essential for bananas to 

prevent large amounts of loss in 

shipping. Sufficient evidence was not 

shown for essentiality for citrus or 

pineapple. (petition, 2011)

7. Is there a wholly natural substitute 

product?

[§6517 c (1)(A)(ii)]

X

8. Is the substance used in handling, not 

synthetic, but not organically 

produced?

[§6517 c (1)(B)(iii)]

X

9. Is there any alternative substances? 

[§6518 m.6]

maybe waxes are alternative 

substances for citrus. No alternatives 

in bananas.

10.Is there another practice that would 

make the substance unnecessary? 

[§6518 m.6]

Perhaps there are cultural practices 

for bananas that would reduce the 

disease incidence and thus make the 

substance less necessary. The 

Handling committee seeks input on 

this issue.

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

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

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance compatible with 

organic handling? [§205.600 b.2]

X

2. Is the substance consistent with 

organic farming and handling? [§6517 

c (1)(A)(iii); 6517 c (2)(A)(ii)]

X

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7]

X

4. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600 b.3]

X while the TR states that bananas will 

ripen to their full nutritional profile, in 

other fruits (including citrus) there is 

some evidence that GA treatment can 

decrease flavonoids and polyphenols. 

(TR, Evaluation Question #7, 2011)

5. Is the primary use as a preservative? 

[§205.600 b.4]

X

6. Is the primary use to recreate or 

improve flavors, colors, textures, or 

nutritive values lost in processing 

(except when required by law, e.g., 

vitamin D in milk)? [205.600 b.4]

X

7. Is the substance used in production, 

and does it contain an active 

synthetic ingredient in the following 

categories:

a. copper and sulfur compounds;

X

b. toxins derived from bacteria; X

c. pheromones, soaps, horticultural 

oils, fish emulsions, treated seed, 

vitamins and minerals?

X

d. livestock parasiticides and 

medicines?

X

e. production aids including netting, 

tree wraps and seals, insect traps, 

sticky barriers, row covers, and 

equipment cleaners?

X

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or 

potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 

205.600 (c)] Substance: Name

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the comparative description 

provided as to why the non-organic 

form of the material /substance is 

necessary for use in organic 

handling? 

X Non-agricultural

2. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate form to fulfill an essential 

function in a system of organic 

handling? 

X

3. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate quality to fulfill an 

essential function in a system of 

organic handling? 

X

4. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate quantity to fulfill an 

essential function in a system of 

organic handling?

X

5. Does the industry information 

provided on material / substance 

non-availability as organic, include ( 

but not limited to) the following:

a. Regions of production (including 

factors such as climate and 

number of regions);

X

b. Number of suppliers and amount 

produced;

X

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts 

that may temporarily halt 

X
Revised March 2012

production or destroy crops or 

supplies; 

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X

e. Are there other issues which may 

present a challenge to a 

consistent supply?

X

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.