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 January 7, 2014 2:00 pm ET 

Present: Jay Feldman (JFe), Francis Thicke (FT), Harold Austin (HA), Zea Sonnabend, Chair (ZS), Carmela 

Beck (CBe), Mac Stone (MS) – sitting in

Absent: John Foster (JFo), 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 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

No addit TR

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

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

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. Determine need for TR

Classifica

tion 

vote: 12 

17 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

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 

meeting cancelled. Revising based on public 

comment

08 06 13 Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) 

oxide TR

No new TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Possible revisions? Will 

discuss on Jan 21

08 06 13 Spr 2014
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 Verbal 

report Spr 

2014

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 Crops Subcommittee notes of December 17, 2013

• Discuss vinasse checklist

• Ferric phosphate TR determination (CBe)

• Hydrogen chloride TR determination (JFo)

• Discuss public comment for two fall 2013 proposals (Strep-HA, MgO-FT)

• Adjourn

Discussion

• Crops Subcommittee notes of December 17, 2013 were approved with minor changes made by MA.

• Vinasse checklist. JFe circulated an email with some background for the group to use for classification.

The group discussed the complexities of this material because although it is a natural substance there 

are various opinions on how the manufacturing processes involved before, during, and after 

fermentation affect its classification (much like corn steep liquor). A member felt that that listing

Vinasse as a prohibited natural and annotating it with the forms of Vinasse that would be allowed could 

be a good route to address this petition. Another member noted that the Board should consider the 

use of manufacturing byproducts and production of residuals as a concern when determining whether 

or not this is synthetic. Members discussed the use of a decision tree for classification, but felt they 

would need a more refined decision tree. ZS and JFe will discuss this further, and ZS will contact OMRI 

about the classification process of formulations of Vinasse. 

• Ferric phosphate (CBe). The lead reviewer reviewed the documents, including the information from the 

Inerts Working Group, and feels that there is enough information from the supplemental TR to 

proceed. She noted that there are two differing opinions about Ferric phosphate regarding EDTA and 

whether or not it is an active ingredient. A member noted that a TR would not be able to provide an 

answer to that question, so the group chose to not request an additional TR for this material. (Noted in 

table above).

• Hydrogen chloride TR determination (JFo). JFo could not be on the call and will email the discussion 

points so the group can discuss it on the next call. 
• Fall 2013 Public comment. MA added the two fall 2013 proposals to the table above for record keeping 

purposes and spring 2014 meeting planning.

o Strep (HA) – The prior recommendation included removal of the expiration date, the addition 

of a new date of 2017, and the addition of a Board resolution about antibiotic use. The 

members discussed the public comment, and noted that some commenters supported the 

extension because this material has limited geographic use, while the majority opposed it 

because of the general environmental and health risk to humans, no matter the limited 

geographical use. A member asked if the NOP could review one of the comments which raised 

concerns about ...“Conclusion derived from this source...” and determine whether or not they 

should respond formally. Alternatively the members discussed adding some language to the 

proposal about this comment and that “the manufacturer disputes the findings” so when it gets 

posted for comment for the spring 2014 meeting, the public can add additional comments. The 

NOP will provide feedback to the group about this request.

o Magnesium Oxide (MgO). The Board received a total of seven comments, all opposed to relisting MgO. Four commenters noted their view that the new sunset process might hinder the 

removal of this material from the list. A member suggested an annotation with an expiration 

date. The Chair asked that JFe put that suggestion in writing and circulate it so they could 

discuss it further on the next call. 

• The meeting was adjourned

Future Call Schedule:

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-deferred to January 21 call

Discuss public comment for two fall 2013 proposals (Strep, MgO)

January 21, 2014 2:00 ET

Hydrogen chloride TR determination

Determine petition sufficiency and vote on carbon monoxide

Discuss annotation for MgO

Discuss Vinasse/vote on classification

February 4, 2014 2:00 ET- call cancelled

NOSB Training meeting in DC

Feb 18, 2014 2:00 ET

Discuss and/or modify any fall 2013 proposals based on public comments 

March 4, 2014 2:00 ET

March 18, 2014 2:00 ET

April 1, 2014 2:00 ET

April 15, 2014 2:00 ET

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
Spring 2014 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 January 21, 2014 2:00 pm ET 

Present: Jay Feldman (JFe), Francis Thicke (FT), Harold Austin (HA), Zea Sonnabend, Chair (ZS), Carmela 

Beck (CBe), John Foster (JFo), Colehour Bondera (CBo)

Absent: none

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

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14

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

No addit TR

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: 

Fall 2014 

Review:

Spr 2015
Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets

Ethanol (Alcohols)

205.601

1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

Petitioned Substances

Substance ContactTR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/N

M

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

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. Determine need for TR

Classifica

tion 

vote: 12 

17 13

Proposal 

Fall 2014?

Carbon monoxide 

(exhaust gas) List 

at §205.601

FT Petition sent to CS on 06 06 12. Petition 

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
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 

meeting cancelled. Revising based on public 

comment

08 06 13 Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) 

oxide TR

No new TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 

below, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl 

isothiocyanate 

(AITC)

List at 205.601

HA Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014.

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 Verbal 

report Spr 

2014

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 Crops Subcommittee notes of January 7, 2014

• Hydrogen chloride TR determination 

• Determine petition sufficiency and vote on carbon monoxide

• Discuss annotation for MgO

• Discuss Vinasse/vote on classification

• Adjourn
Discussion

• Crops Subcommittee notes of January 7, 2014 were approved with minor edits.

• Hydrogen chloride (JFo). JFe sent a summary document to the group prior to call for which a member

thanked him, commending the high quality. The same member noted that since alternative processes 

were not available 5 years ago, it might be worth requesting a TR to find out if alternatives now exist.

JFo will craft questions and send them to ZS.

• Discuss annotation for MgO (FT). A member proposed an annotation to include an expiration date for 

MgO of 5 years. The NOP noted that they are not supportive of expiration dates and annotations, and a 

member added that it would be reviewed again in 5 years anyway. The NOP explained that if the 

substance was listed, the CS could specifically ask for public comment about organic alternatives when 

the substance comes up for sunset review, rather than proposing an expiration date and annotation to

the original listing. Members discussed how to proceed. A member advised against becoming more 

restrictive with a particular material, which he feels causes dilution of the process. Therefore he also 

does not support the addition of an expiration date to the proposed listing. The CS Chair called for a 

straw vote so the group could determine how to proceed:

Straw vote on MgO:

Motion: to add the following annotation and expiration date to the MgO proposal: 

Although magnesium oxide is relatively benign, its manufacture creates pollution or depends on 

polluting industries. The process of using salt brine depends on additions of sulfuric or hydrochloric 

acids, which relies on industries creating sulfuric acid pollution or the chlorine industry, and organic 

production should not be reliant on those industries, which do not embrace the core values and 

principles of organics. On the other hand, the process using dolomite limestone requires high inputs of 

fossil fuel energy and results in releases of carbon dioxide into the atmosphere both from combustion 

and from the gas driven off from the limestone. 

It is hoped that organic standards can encourage manufacturing practices that are more benign, 

including those that may use nonsynthetic acids. Moreover, a rigorous review of the essentiality of liquid 

humates in light of current organic soil building practices should be conducted. Subject to a 2019 (or 5-

year) expiration date.

Yes: 3 No 4

The Chair indicated that the CS will not proceed with an expiration date in the annotation. 

• Vinasse. The Vinasse checklist (draft 2) was circulated prior to call and the group discussed the edits 

that were made since the last call. The CS Chair and lead person noted that there are eight different 

sources of vinasse approved for use by OMRI, and the form of Vinasse that a member mentioned, 

which has post-fermentation chemicals added, is not included. The primary reviewer feels that Vinasse 

should be managed in the same manner as molasses on the permitted substances list (NOP 5033) for 

materials guidance. If the CS determines that vinasse should be classified as non synthetic, then there is 

only the need for a brief summary of the determination rather than a full proposal with a checklist. A 

member felt that there was a need for a longer conversation about prohibited naturals vs allowed

synthetics. ZS noted that the proposed language remedies this, and it would be listed on the permitted 

materials guidance and not to be added to the National List. The group discussed this list with regard to 

Materials Review Organizations (MROs) and their review process when it comes to complex materials 

like Vinasse. The Chair acknowledged that MROs are following draft guidance and noted that OMRI 

struggled with this particular material because it is complicated by the fact that there are so many 

formulations. However, OMRI is satisfied that the ones they have approved are all non-synthetic. A 
member affirmed his discomfort with this direction until the MRO review process is solidified and more 

enforceable. The CS will take a straw poll on classification on the next call (Feb 18). 

The majority of members were in support of this approach, although a few members had some 

reservations. ZS will craft language for the motion and vote for the next meeting, and asked that 

members send her refinements to the language before the 18th so she can incorporate it into the next 

draft.

• Note from MA: The TR for 2017 Sunset material Ethanol was sent to the CS on January 15 and added to 

the table above. TR sufficiency due July 15, 2014

• Carbon monoxide – FT drafted and circulated a checklist and the group discussed petition sufficiency 

and the need for a TR. FT noted that he found the petition sufficient and the group agreed. He feels 

that there are outstanding issues resulting from the internal combustion engine and exhaust, since 

there are other gases besides carbon monoxide involved. The petition does state that it is for gas 

combustion engines, but the group feels the document is framed as a petition for carbon monoxide 

instead of exhaust gas. The NOP suggested looking at the propane petition as a model, but FT noted 

that although similar, CO is more complex than propane and feels like it would not be comparable. 

Another member pointed out that the propane petition wasn’t for equipment, but was actually for the 

propane gas. Members suggested proceeding with this review of exhaust gas, as opposed to carbon 

monoxide, in which case they can begin to craft a proposal and request a TR. The group discussed 

alternative options such as seeking the necessary information from other sources instead of a TR;

Perhaps the petitioner or public comment. The members felt that the information they need, including 

completeness of combustion, penetration depth into the soil, and retention of components in the soil 

would not be readily available to anyone but a contractor. The National List Manager (LB) joined the 

call to discuss this further asking the group if they felt that the information they may be able to get 

from a TR would impact their decision. Several members felt that a TR was necessary while others 

reluctantly agreed. The members decided to seek a limited scope TR. The lead reviewer will pose some 

questions and send them to the group for feedback. The CS also proposed a title change for this 

petition, from ‘carbon monoxide’ to ‘exhaust gas from an internal combustion engine’. 

• 2015 Sunset materials. The CS received TRs for two of the 2015 Sunset materials: Sodium carbonate 

peroxyhydrate and aqueous potassium silicate. The CS Chair asked that the members review them 

before the next call so they can discuss them and determine if there are any possible questions for 

inclusion in the summary documents that the NOP will post. The NOP requested these by Feb 18. 

• A petition for allyl isothiocyanate (AITC) was sent to the CS on January 21, and HA volunteered to take 

the lead on the review. The petition was added to the workplan above, including the due date for 

petition sufficiency. The CS will discuss this material on March 4. 

• The meeting was adjourned

Future Call Schedule:

January 7, 2014 2:00 ET

Discuss vinasse checklist

Ferric phosphate TR determination

 Hydrogen chloride TR determination-deferred to January 21 call

Discuss public comment for two fall 2013 proposals (Strep, MgO)

January 21, 2014 2:00 ET

Hydrogen chloride TR determination - done

Carbon Monoxide - Determine petition sufficiency and vote (?) Pet suff –done

Discuss annotation for MgO – took straw vote 
Discuss Vinasse/vote on classification

2015 sunset materials-review possible questions to include in summary.

February 4, 2014 2:00 ET- call cancelled

NOSB Training meeting in DC

Feb 18, 2014 2:00 ET

- Discuss and/or modify any fall 2013 proposals based on public comments 

- 2015 sunset materials (Sodium carbonate peroxyhydrate and aqueous potassium silicate): Review 

possible questions to include in summary. Determine TR sufficiency

- Carbon Monoxide -Discuss TR questions 

- MgO – vote?

- Vinasse edits to proposal/vote on classification

March 4, 2014 2:00 ET

- Discuss allyl isothiocyanate (AITC)

March 18, 2014 2:00 ET

April 1, 2014 2:00 ET

April 15, 2014 2:00 ET

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

Spring 2014 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 February 18, 2014 2:00 pm ET 

Present: Jay Feldman (JFe), Francis Thicke (FT), Harold Austin (HA), Zea Sonnabend, Chair (ZS), Carmela 

Beck (CBe), John Foster (JFo), Colehour Bondera (CBo)

Absent: Stacy Jones King (SJK)

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work plan

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

Substance ContactTR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

HS. TR found suffic 02 18 14. CS will add 

question to sunset listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous 

potassium silicate 

at 205.601(e) and 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA 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

No addit TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests due to NOP July 2014)

Ethanol (Alcohols)

205.601

1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

Petitioned Substances

Substance ContactTR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/N

M

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

Vote 

Scheduled 

for 02 25

14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR.

Based on classification vote 12 17 13 the CS 

determine does not have to be added to the 

Classificati

on vote: 

12 17 13

Will 

discuss/

Proposal 

Spr 2014
NL. Will send forth a proposal to the full 

Board.

vote 02 

25 14

Carbon monoxide 

(exhaust gas) List 

at §205.601

FT Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. CS will discuss questions for L’mtd 

scope TR.

TBD

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 

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimou

sly

Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) 

oxide TR

No new TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl 

isothiocyanate 

(AITC)

List at 205.601

HA Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014.

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 Verbal 

report Spr 

2014

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 Crops Subcommittee notes of January 21, 2014

• Modify any fall 2013 proposals based on public comments

o Strep (HA)

o MgO (FT)

• 2015 sunset materials: Review possible questions to include in summary. Determine TR sufficiency

o Aqueous potassium silicate - Jay

o Sodium carbonate peroxyhydrate (ZS)

o Sulfurous Acid - (CBo)

• Vinasse proposal/vote on classification and proposed guidance listing - (ZS)

• Laminarin proposal review/edits - (ZS)

• Carbon Monoxide - Discuss TR questions – (FT) if time allows

• Preliminary workplan discussion for next semester

• Adjourn

Discussion

• Crops Subcommittee notes of January 21, 2014 approved with no changes. 

• 2013 proposals: 

o Strep (HA) - The group discussed and ultimately incorporated some revised language that 

clarified a statement in the proposal about efficacy. The revision was the result of public 

comments that were received in the fall of 2013 from one of the manufacturers. The proposal 

was approved without objection and will be posted for the spring 2014 comment period. 

o MgO (FT) - The group unanimously chose to post this as is, with no revisions to the fall 2013 

proposal. 

• 2015 sunset materials: The members determined TR sufficiency for the three sunset materials and 

reviewed possible questions to include in the summary postings. They also talked about the sunset 

review in general. 

o Aqueous potassium silicate - (JFe). The TR was found sufficient. A member circulated a 

checklist that he personally uses to review materials, and included some statements/questions 

he suggested adding to the sunset summary list. The group discussed the list of questions. 

Many members felt that a couple of the questions could not be answered via public comment, 

and that the majority of the others could be folded into one another, to condense the list. The 

CS Chair feels that the two major issues identified (re: foliar application of potassium silicate 

and its impacts on the nutritive value of treated foods, and essentiality) are appropriate and 

should be included in the summary. The NOP suggested strengthening and clarifying the links 

between the questions and the OFPA criteria and noted that it would be more effective if the

statements were posed as questions. The document will be revised and resent to the CS.

o The Chair called for a straw poll for each one of the questions on the list for aqueous potassium 

silicate, which resulted in the removal of several and the combining of others. A member added 

that with regard to the two major issues, “Nutritive value” is not part of the OFPA criteria for 

crop materials and the questions should focus on those criteria the Board uses in their review.
The CS Chair requested any final comments be sent by noon Wednesday, Feb 19 so she can 

finalize the documents and send them to the NOP by the deadline. 

o A member offered that the sunset instructions do not make it clear that in order for comments 

to be considered during proposal writing, they must be submitted during the first phase of the 

sunset process (i.e. the posting of the sunset summary list). According to the new process, 

public comment received during the second phase (the posting of the proposal) would not be 

received in a timely manner and the Board would not be have the time or opportunity to make 

changes based on the comments. If new, relevant information is presented at the second 

posting that could alter the outcome of the vote; the Board does have the option of postponing 

the vote to the following meeting, although likely this would conflict with the sunset dates. 

o A member requested that in the future documents for discussion be presented to the 

Subcommittee members further in advance so they have enough time to review them prior to 

the conference call. 

o Sodium carbonate peroxyhydrate (ZS). The TR was found sufficient. The members discussed 

information cited in the TR about international research on field tests. The members 

unanimously agreed to pose a question in the summary seeking information about field 

experience, particularly in rice production. 

o Sulfurous Acid (CBo). The TR was found sufficient. The principal reviewer circulated some 

potential questions for the TR contractor, and the group felt that the questions would be better 

answered via public comment. Several members felt that the breakdown process is too 

complicated and there are too many variables to be able to glean useful answers. Other 

members disagreed, and felt the process was not complicated. A member offered to write 

some questions and send them to the Chair. The same member requested that the following 

text be added to the notes, as there wasn’t enough time on the call to discuss them. These 

answers were in response to information the NOP provided to the Subcommittee about the 

definition of fertilizers: 

§205.2 Terms defined. 

Fertilizer. A single or blended substance containing one or more recognized plant nutrient(s) 

which is used primarily for its plant nutrient content and which is designed for use or claimed to 

have value in promoting plant growth.

1. The question is not whether sulfurous acid is a fertilizer, but whether the sulfate produced by its 

degradation is.

2. You would not find sulfurous acid on any list of fertilizers from the AAPFCO because it is 

unstable (which is why it is produced on-farm by a generator) and thus not sold as a fertilizer. 

TR lines 64-66: "In fact, sulfurous acid is not chemically stable at temperatures above -196.15 o 

C. The predominate form that sulfur dioxide take in solution is as hydrogen sulfite (bisulfite, 

HSO3−―Equation 1)."

3. Sulfurous acid may be added with the intention of acidifying the soil, but the production of 

bioavailable sulfate is an important part of the process, as stated in the TR, lines 154-155: 

"Sulfite oxidation to sulfate by Thiobacillus bacteria produces bioavailable sulfur for plants." 

Lines 272-274: "Sulfurous acid contains no persistent substances of record. Hydrogen sulfite 

present in the solution is metabolized by sulfite reducing bacteria and plants that recycle 

sulfurous acid into bioavailable sulfur compounds."Lines 438-440 compare it with elemental 

sulfur: "Elemental sulfur is commonly used to lower soil pH and reclaim soil. It is costly and may 

require one to seven years for thiobacterial conversion to bioavailable sulfur (Mullen et al., 

2007)."
• Vinasse - Due to time constraints the group chose to add a conference call for February 25 (added 

below), so they would have enough time to devote to a thorough discussion on classification and a 

proposed guidance listing. 

• Laminarin. The Chair noted that this material review will be straight forward and the group will 

compete their work on the next call (Feb 25)

• Carbon Monoxide. The members will discuss the TR questions on the Feb 25 call if time allows

• Preliminary workplan discussion for next semester 25th - deferred for lack of time

• The meeting was adjourned.

Future Call Schedule:

January 21, 2014 2:00 ET

Hydrogen chloride TR determination - done

Carbon Monoxide - Determine petition sufficiency and vote (?) Pet suff –done

Discuss annotation for MgO – took straw vote 

Discuss Vinasse/vote on classification

2015 sunset materials-review possible questions to include in summary.

February 4, 2014 2:00 ET- call cancelled

NOSB Training meeting in DC

Feb 18, 2014 2:00 ET

Discuss and/or modify any fall 2013 proposals based on public comments 

2015 sunset materials (Sodium carbonate peroxyhydrate and aqueous potassium silicate): Review 

possible questions to include in summary. Determine TR sufficiency

Carbon Monoxide -Discuss TR questions 

MgO – vote?

Vinasse edits to proposal/vote on classification

Feb 25, 2014 2:00 ET

 Vinasse - discuss proposal edits/vote on classification and proposed guidance listing

 Laminarin - proposal review/edits

Carbon Monoxide - discuss TR questions 

March 4, 2014 2:00 ET

Discuss allyl isothiocyanate (AITC)

March 18, 2014 2:00 ET

April 1, 2014 2:00 ET

April 15, 2014 2:00 ET

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

Spring 2014 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 February 25, 2014 2:00 pm ET 

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

Bondera (CBo), Jean Richardson (JR) - sitting in, Mac Stone (MS) – sitting in

Absent: Carmela Beck (CBe), Francis Thicke (FT), Stacy Jones King (SJK) - on leave

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work plan

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

Substance ContactTR 

requested?

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

HS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous 

potassium silicate 

at 205.601(e) and 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA 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

No addit TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests due to NOP July 2014)

Ethanol (Alcohols)

205.601

1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

Petitioned Substances

Substance ContactTR 

requested?

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/N

M

08 13 13 

Expedited, 

modified TR

Petition 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 suffic 12 03 13

Voted 

02 25 14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

rspnse due 08 02 13. Petition found sufficient 

07 30 13. Determine need for TR. Based on 

classification vote 12 17 13 the CS determine

does not have to be added to the NL. Will 

send forth a proposal to the full Board.

Classificati

on vote: 

12 17 13

Voted 

02 25 14

Proposal 

Spr 2014
Carbon monoxide 

(exhaust gas) List 

at §205.601

FT Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. CS requested a L’mtd scope TR and 

posed some specific questions.

TBD

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 

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimou

sly

Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesium 

(HYDR) 

oxide TR

No new TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl 

isothiocyanate 

(AITC)

List at 205.601

HA Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014.

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 Verbal 

report Spr 

2014

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 Crops Subcommittee notes of February 18, 2014

• Vinasse - discuss proposal edits/vote on classification and proposed guidance listing 

• Laminarin - proposal review/edits, discuss minority opinion 

• Carbon Monoxide - discuss TR questions 

• Discuss workplan 

• Adjourn

Discussion

• Crops Subcommittee notes of February 18, 2014 approved with no changes

• Vinasse - The CS members discussed the proposal, in which they are proposing an entry for vinasse in 

the NOP Guidance on Materials for Organic Crops Production (NOP 5034-1) as a natural with a 

description to clarify which additives are synthetic and prohibited. A member suggested that if the 

Board does not use its listing authority on §205.602 to control the classification of different vinasse 

formulations and instead leaves it to the discretion of the USDA, it could result in misuse of this 

material. The group discussed various scenarios for restricting usage on the National List on §205.601 

and §205.602 and concluded that adding restrictive language in the guidance is the best path forward. 

The NOP agreed, and noted that the purpose of §205.602 is to prohibit natural substances, and this 

proposal does not do that. A member noted that he finds voting on classification problematic because 

there are forms of vinasse that are synthetic. The CS Chair noted that they are adding a description to 

the entry that will address this issue. ZS will add the minority opinion language sent to the group via 

email, and the Subcommittee moved to a vote on vinasse. 

VOTE on Vinasse

Motion to classify vinasse as non-synthetic

Motion by: ZS

Seconded by: JFo

Discussion: none

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

The vote was left open for 2 missing members and will close Wednesday at close of business Pacific 

time. Motion carried.

Motion to add the following specific language to the listing of vinasse in the Guidance on Materials 

for Organic Crops Production (NOP 5034-1): Vinasse - may not contain prohibited additives, such as 

but not limited to, pH adjusters, sanitizers, ammonium compounds, antibiotics or chlorine materials 

that are not provided for at §205.601. Nitrogen levels may not be fortified.

Motion by: ZS

Seconded by: HA

Discussion: none
Yes: 4 No: 3 Abstain: 0 Absent: 0 Recuse: 0

The vote was left open for 2 missing members and will close Wednesday at close of business Pacific 

Time. Motion carried.

ABS note: The two absent members cast their votes via email on Feb 26, 2014 and the vote tally 

above was adjusted to reflect this. 

Laminarin – The group reviewed the latest draft of the proposal and discussed the minority opinion, which 

was sent via email on February 21, 2014. The members discussed the idea that an extractant is introduced 

that is not fully removed, and therefore laminarin should be classified as synthetic. Members discussed the 

context and intended use for which laminarin is being petitioned. Several members noted that laminarin is 

not being used as an additive, and instead is used as pest control. Additionally, it is used in substantially 

smaller quantities than in fish products, and does not have a functional effect. A member agreed and 

emphasized that context, intended use, and amounts are important, and the likelihood for misuse is very 

small. Especially since cost is a factor and farmers will use only the required amounts. With regard to 

technical and functional effect, a member felt that sulfur does matter, but the CS Chair noted that it is 

minor and is already on the National List. The lead reviewer will make some edits, add the minority opinion 

language, and recirculate the document so the absent members can vote via email. 

VOTE on laminarin

Motion to classify was taken December 17, 2014 and is included below: 

Motion by: ZS

Seconded by: HA

Discussion: none

 Yes: 5 No: 2 Absent: 0 Abstain: 0 Recuse: 0

The vote will be left open until Close of Business Wednesday

 ABS Note: The two absent members cast their votes via email and were added to the tally above. 

 Motion carried.

• Carbon Monoxide – The lead reviewer was not on the call, so the group briefly discussed the questions

for the limited scope TR and will continue to discuss it on the March 4 call. 

• Discuss workplan - deferred. 

• Adjourn

Future Call Schedule:

Feb 18, 2014 2:00 ET

Discuss and/or modify any fall 2013 proposals based on public comments 

2015 sunset materials (Sodium carbonate peroxyhydrate and aqueous potassium silicate): Review 

possible questions to include in summary. Determine TR sufficiency

Carbon Monoxide -Discuss TR questions 

MgO – vote?

Vinasse edits to proposal/vote on classification
Feb 25, 2014 2:00 ET

 Vinasse - discuss proposal edits/vote on classification and proposed guidance listing - done

 Laminarin - proposal review/edits - done

 Carbon Monoxide/Exhaust gas - discuss TR questions –continued on March 4 call

March 4, 2014 2:00 ET

CO/Exhaust gas

Discuss allyl isothiocyanate (AITC)

March 18, 2014 2:00 ET

April 1, 2014 2:00 ET

April 15, 2014 2:00 ET

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

Spring 2014 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 March 4, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Jay Feldman (JFe), Harold Austin (HA), 

John Foster (JFo), Colehour Bondera (CBo), Carmela Beck (CBe), Mac Stone (MS) - sitting in

Absent: Stacy Jones King (SJK) - on leave

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work plan

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA 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

No addit

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests due to NOP July 2014)

Ammonium 

carbonate 

205.601(e)

1995 HS: 205.605(b) Summary:

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

2006 “

Arsenic 205.602(b) “

Ash from manure 

burning 205.602(a) “

Boric acid

205.601(e)

1995 “

Calcium 

hypochlorite

205.601(a)

2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide

205.601(a)

2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate

205.601(i)

2011 LS: 205.603(b) “

Coppers, fixed

205.601(i)

2011 “
Elemental sulfur

205.601(e)

205.601(i)

205.601(j)

1995

“

EPA List 4 - Inerts of 

Minimal Concern

205.601(m)

None LS: 205.603(e)

“

Ethanol (Alcohols) 

205.601(a)

1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene

205.601(k)

2011 HS: 205.605(b)

“

Herbicides, soap-

based 205.601(b)

1996

“

Humic acids

205.601(j)

2006

“

Hydrated lime

205.601(i)

2002 LS: 205.603(b)

“

Hydrogen peroxide

205.601(a) 

205.601(i)

1995 HS: 205.605(b)

LS: 205.603(a)

“

Isopropanol 

205.601(a)

TR in development

LS: 205.603(a)

“

Lead salts

205.602(d)

“

Lignin sulfonate 

205.601(j)

205.601(l)

2011

“

Lime sulfur

205.601(e) 

205.601(i)

“

Liquid fish products

205.601(j)

2006

“

Magnesium sulfate 

205.601(j)

2011 HS: 205.605(a)

LS: 205.603(a)

“

Microcrystalline 

cheesewax 

205.601(o)

“

Newspaper or 

other recycled

paper 205.601(b)

205.601(c)

2006

“

Oils, horticultural

205.601(e)

205.601(i)

1995

“
Pheromones

205.601(f)

2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

1995

“

Potassium 

bicarbonate

205 601(i)

1999

“

Potassium chloride

205.602(e)

1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers

205.601(a)

1994

“

Soaps, ammonium 

205.601(d)

1996

“

Soaps, insecticidal

205.601(e)

1994

“

Sodium 

fluoaluminate 

205.602(f)

“

Sodium 

hypochlorite 

205.601(a)

2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

2011

“

Soluble boron 

products 205.601(j)

1995

“

Sticky 

traps/barriers

205 601( )

“

Strychnine 

205.602(h)

LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

2010

“
Tobacco dust 

(nicotine sulfate) 

205 602(i)

“

Vitamin B1

205.601(j)

1995 “

Vitamin C

205.601(j)

1995 “

Vitamin D3

205.601(g)

2011 “

Vitamin E

205.601(j)

1995 “

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/NM 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 suffic 12 03 13

Voted 

02 25 14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

rspnse due 08 02 13. Petition found sufficient 

07 30 13. Determine need for TR. Based on 

classification vote 12 17 13 the CS proposes 

to not add laminarin to the NL. Will send 

forth a proposal to the full Board. 

Classifica

tion 

vote: 12 

17 13

02 25 14

Proposal 

Spr 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. Crafting questions for TR. 

TBD

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 

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimo

usly

Spr 2014
Magnesium oxide 

List at 205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide TR

No new 

TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14.

TBD

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, 

Feb 3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

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 Verbal 

report Spr 

2014

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

* Aqua highlight indicates multiple NL entries

Agenda

• Approve Crops Subcommittee notes of February 25, 2014

• Exhaust gas - discuss TR questions (FT)

• Allyl Isothiocyanate petition sufficiency (HA)

• Discuss workplan items

• Set agenda for upcoming calls

• Adjourn
Discussion

• Crops Subcommittee notes of February 25, 2014 were approved with minor changes suggested by 

members during the call. Members discussed formatting of document titles and suggested descriptive

names to make it easier to search in emails. 

• Exhaust gas (FT). Members discussed questions for a new or limited scope TR that were circulated prior 

to the call. Several of the questions were combined in an effort to shorten the list. The NOP indicated 

that some of the questions could be consolidated and responded to under the TR evaluation questions. 

The CS will complete the list of specific questions and forward to the NOP who will then forward them 

to the contractor. 

• Allyl Isothiocyanate petition sufficiency (AITC) (HA). AITC is being petitioned for addition to 205.601 as 

a pre-plant fumigant which the petitioner claims is consistent with organic principles. The CS Chair 

asked that the wording be changed to “pre-plant synthetic fumigant”. The lead reviewer noted the 

following: the natural form of AITC is derived from black mustard seed and is listed as a food additive;

some confidential business information (CBI) was redacted from the petition and; if label instructions 

for this substance are followed, EPA considers human exposure to be minimal. The Chair asked that the 

checklist be populated with information about alternatives, such as mustard seed meal and broccoli, 

which are often used for this purpose. Members discussed various aspects of the petition, 

acknowledging that the task at hand is to determine sufficiency. The CS found the petition sufficient 

and discussed the best path forward for requesting additional information. Options include completing 

the checklist with the available information, submitting additional questions to the petitioner or 

requesting a TR. The group discussed the merits of each of these options, and chose to compile a list of 

questions for a TR. Members felt that a TR would be a more appropriate source for the kinds of 

questions they would like answered, and if they need to seek further information, they could ask the 

petitioner. In particular they would like more information about the manufacturing process, some of 

which may be CBI. A member noted that although a TR would provide information regarding safety of 

the material, it cannot answer questions about essentiality, and the group would like to know if organic 

farmers have a need for this substance. 

• Discuss workplan items. 

o The CS Chair will send the 2017 Crops Sunset list to the Subcommittee members and they will 

discuss it and assign reviewers on the March 18 call. 

o The CS will request a TR for exhaust gas.

o Contamination Issues in Farm Inputs Literature Review. This topic will likely be ready to discuss 

at the fall 2014 NOSB meeting. 

• Future call agenda. The presenters have already been assigned for the spring 2014 NOSB meeting

proposals. The members will review public comments on April 1 and 15.

• The meeting was adjourned

Future Call Schedule:

Feb 25, 2014 2:00 ET

 Vinasse - discuss proposal edits/vote on classification and proposed guidance listing

 Laminarin - proposal review/edits

Carbon Monoxide - discuss TR questions 

March 4, 2014 2:00 ET

Exhaust gas (Carbon Monoxide) 

Discuss allyl isothiocyanate (AITC)

March 18, 2014 2:00 ET

Discuss TR questions for allyl isothiocyanate (AITC)

2017 Sunset list - assign reviewers

Contamination Issues in Farm Inputs Literature Review

April 1, 2014 2:00 ET

Review Public comments
April 15, 2014 2:00 ET

Review Public comments

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

Spring 2014 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 March 18, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Jay Feldman (JFe), Harold Austin (HA),

Colehour Bondera (CBo), Carmela Beck (CBe), Mac Stone (MS) - sitting in

Absent: John Foster (JFo), Stacy Jones King (SJK) - on leave

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

Work plan

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA 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

No addit

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS/NM 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 suffic 12 03 13

Voted 

02 25 14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

rspnse due 08 02 13. Petition found sufficient 

07 30 13. Determine need for TR. Based on 

classification vote 12 17 13 the CS proposes 

to not add laminarin to the NL. Will send 

forth a proposal to the full Board. 

Classifica

tion 

vote: 12 

17 13

02 25 14

Proposal 

Spr 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. Crafting questions for TR. 

TBD
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

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimo

usly

Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide TR

No new 

TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP 03 18 14

TBD

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, 

Feb 3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

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 Verbal 

report Spr 

2014

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 notes from March 4

• Discuss and finalize TR questions for AITC 

• Review Contamination Issues workplan 

• 2017 Sunset list reviewer assignments

Discussion

• Crops Subcommittee notes of March 4, 2014 were approved with no changes.

• Allyl Isothiocyanate petition sufficiency (AITC) (HA). Members discussed questions that the lead 

reviewer circulated prior to the call. The group made some edits and composed additional questions for 

clarity. HA will craft the new language and send it to the group after the call for review. 

• Review Contamination Issues workplan item. The members discussed the draft document and 

discussed how to move forward, noting that the NOP already approved this phase of the project. A 

member complimented the lead reviewer on the content and organization of the document. The 

current version is composed of two components: justification for why the Crops Subcommittee/NOSB

should undertake this project, and background research and baseline information. A member envisions 

this going forth as either a report or a discussion document, with the emphasis on the need to collect 

public comment and expert testimony. The group discussed the identification of experts to participate 

in conversations with the Subcommittee and/or Board. The CS Chair noted that a framework and 

targeted questions should be developed first before asking experts to consult, which will help them 

identify the appropriate expertise. JFe will draft the framework and questions, and offered a target 

date of May 20, 2014, in an effort to have a document ready for the fall 2014 NOSB meeting. The NOP 

asked the group to also include information about goals for this project, including language about the 

urgency and scale. The NOP also suggested that it might be helpful to review §205.203 of the National 

List as a guide when writing this document.

• 2017 Sunset list reviewer assignments. Reviewer assignments were completed and will be maintained 

on a separate Excel Spreadsheet, as it is very long. The Chair asked that the table be removed from 

above and instead be added and updated as materials are reviewed. MA has moved the table to the 

end of this document for now. 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

March 4, 2014 2:00 ET

Exhaust gas (Carbon Monoxide) 

Discuss allyl isothiocyanate (AITC)

March 18, 2014 2:00 ET

Discuss TR questions for allyl isothiocyanate (AITC)

2017 Sunset list - assign reviewers

Contamination Issues in Farm Inputs Literature Review

April 1, 2014 2:00 ET

Presentations -identify presenters and format for spring 2014 meeting

Review Public comments

April 15, 2014 2:00 ET

Review Public comments

May 20, 2014 2:00 ET

Contamination Issues in Farm Inputs
* Aqua highlight indicates multiple NL entries

2017 Sunsets (TR requests due to NOP July 2014)

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary:

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid

205.601(e)

CBo 1995 “

Calcium 

hypochlorite

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed

205.601(i)

ZS 2011 “

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

Spring 2014 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
Elemental sulfur

205.601(e)

205.601(i)

205.601(j)

HA 1995

“

EPA List 4 - Inerts of 

Minimal Concern

205.601(m)

JFe None LS: 205.603(e) “

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

Herbicides, soapbased 205.601(b)FT 1996 “

Humic acids

205.601(j)

CBe 2006 “

Hydrated lime

205.601(i)

ZS 2002 LS: 205.603(b) “

Hydrogen peroxide

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a) “

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a) “

Lead salts

205.602(d)

JFe “

Lignin sulfonate 

205.601(j)

205.601(l)

CBe 2011 “

Lime sulfur

205.601(e) 

205.601(i)

HA “

Liquid fish products

205.601(j)

CBe 2006 “

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a) “

Microcrystalline 

cheesewax 

205.601(o)

CBo “

Newspaper or 

other recycled

paper 205.601(b)

205.601(c)

CBo 2006

“

Oils, horticultural

205.601(e)

205.601(i)

HA 1995 “
Pheromones

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium 

bicarbonate

205 601(i)

JFe 1999

“

Potassium chloride

205.602(e)

ZS 1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers

205.601(a)

FT 1994

“

Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal

205.601(e)

JFo 1994

“

Sodium 

fluoaluminate 

205.602(f)

JFo

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“
Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1

205.601(j)

CBe 1995

“

Vitamin C

205.601(j)

CBe 1995

“

Vitamin D3

205.601(g)

JFo 2011

“

Vitamin E

205.601(j)

CBe 1995

“
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 1, 2014 2:00 pm ET 

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

Bondera (CBo), Mac Stone (MS) - sitting in

Absent: Francis Thicke, Vice Chair (FT), Carmela Beck (CBe), Stacy Jones King (SJK) - on leave

Staff: Michelle Arsenault (MA), Lisa Brines (LB)

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 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets

Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No addit

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance Contact

TR 

requested

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS 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 suffic 12 03 13

Voted 

02 25 14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

rspnse due 08 02 13. Petition found sufficient 

07 30 13. Determine need for TR. Based on 

classification vote 12 17 13 the CS proposes 

to not add laminarin to the NL. Will send 

forth a proposal to the full Board. 

Classifica

tion 

vote: 12 

17 13

02 25 14

Proposal 

Spr 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP.

TBD
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

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimo

usly

Spr 2014

Magnesium oxide 

List at 205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide TR

No new 

TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP.

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 Verbal 

report Spr 

2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, 

Feb 3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

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 notes from March 18

• Presentations - identify presenters and format for spring 2014 meeting

• Review Public comments

Discussion

• Crops Subcommittee notes of March 18, 2014 were approved with no changes.

• Spring 2014 proposals presentations. The members discussed who will present what at the Spring 

NOSB meeting. HA will present a brief summary of the streptomycin proposal and associated public 

comments, from both the fall and spring submissions. FT will present the Magnesium Oxide proposal. 

ZS will present both Laminarin and Vinasse. JFe will present Aqueous Potassium Silicate. CBo will 

present Sulfurous Acid. The three 2015 Sunset materials will be presented by their respective reviewers 

as indicated in the table above. The group will discuss the public comments on the next call, April 15. 

• 2017 Sunset list - assign reviewers. The CS Chair asked that on the April 15 call the group be prepared 

to sketch out a timeline for the 2017 Sunset materials reviews so they can determine the need for TRs, 

ahead of the July deadline. The NOP noted that as the July deadline approaches, we will have a better 

idea of the resources available for TRs, and that the CS should allow time for prioritization in case NOP 

can’t develop all Sunset TRs requested.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

March 18, 2014 2:00 ET

Discuss TR questions for allyl isothiocyanate (AITC)

2017 Sunset list - assign reviewers

Contamination Issues in Farm Inputs Literature Review

April 1, 2014 2:00 ET

Presentations - identify presenters and format for spring 2014 meeting

Review Public comments

April 15, 2014 2:00 ET

Review Public comments

Schedule review timeline for 2017 Sunset materials. 

May 20, 2014 2:00 ET

Contamination Issues in Farm Inputs

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

Spring 2014 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
* Aqua highlight indicates multiple NL entries

2017 Sunsets (TR requests due to NOP July 2014)

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary:

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid

205.601(e)

CBo 1995 “

Calcium 

hypochlorite

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed

205.601(i)

ZS 2011 “

Elemental sulfur

205.601(e)

205.601(i)

205.601(j)

HA 1995

“

EPA List 4 - Inerts of 

Minimal Concern

205.601(m)

JFe None LS: 205.603(e) “

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

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
Herbicides, soap

-

based 205.601(b)

FT 1996

“

Humic acids

205.601(j)

CBe 2006

“

Hydrated lime

205.601(i)

ZS 2002 LS: 205.603(b)

“

Hydrogen peroxide

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a)

“

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a)

“

Lead salts

205.602(d)

JFe

“

Lignin sulfonate 

205.601(j)

205.601(l)

CBe 2011

“

Lime sulfur

205.601(e) 

205.601(i)

HA

“

Liquid fish products

205.601(j)

CBe 2006

“

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a)

“

Microcrystalline 

cheesewax 

205.601(o)

CBo

“

Newspaper or 

other recycled

paper 205.601(b)

205.601(c)

CBo 2006

“

Oils, horticultural

205.601(e)

205.601(i)

HA 1995

“

Pheromones

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium

bicarbonate

205 601(i)

JFe 1999

“

Potassium chloride

205.602(e)

ZS 1995 HS: 205.605(a)

“
Soap

-based 

algicide/demossers

205.601(a)

FT 1994

“

Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal

205.601(e)

JFo 1994

“

Sodium 

fluoaluminate 

205.602(f)

JFo

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1

205.601(j)

CBe 1995

“

Vitamin C

205.601(j)

CBe 1995

“

Vitamin D3

205.601(g)

JFo 2011

“

Vitamin E

205.601(j)

CBe 1995

“
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 15, 2014 2:00 pm ET 

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

Bondera (CBo), Carmela Beck (CBe), 

Absent: Francis Thicke, Vice Chair (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 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets

Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No addit

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. Report is in development and 

expected mid-May

Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance Contact

TR 

requested

Notes* Vote Meeting

Vinasse - proposal 

List at §205.601

ZS 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 suffic 12 03 13

Voted 

02 25 14

Proposal 

Spr 2014

Laminarin List at 

205.601

ZS N Petition sent to CS on 06 03 13. Sufficiency 

rspnse due 08 02 13. Petition found sufficient 

07 30 13. Determine need for TR. Based on 

classification vote 12 17 13 the CS proposes 

to not add laminarin to the NL. Will send 

forth a proposal to the full Board. 

Classifica

tion 

vote: 12 

17 13

02 25 14

Proposal 

Spr 2014

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP.

TBD
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

meeting cancelled. Revising based on public 

comment

08 06 13

Minor 

revisions 

02 18 14 

Accepted 

unanimo

usly

Spr 2014

Magnesium 

oxide List at 

205.601

FT 2007 

Magnesiu

m (HYDR) 

oxide TR

No new 

TR

request

Petition sent to CS on 02 14 13. Petition

found sufficient 05 21 13. No TR requested. 

Fall 2013 meeting cancelled. Fall 2013 

meeting cancelled. Based on Straw poll 01 21 

14, CS will not revise proposal for Spr 14

08 06 13 Spr 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP.

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 Verbal 

report Spr 

2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, 

Feb 3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

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 notes from April 1, 2014

• Review Public comments

• Schedule review timeline for 2017 Sunset materials. 

Discussion

• Crops Subcommittee notes April 1, 2014 were approved with no changes.

• Public Comments

o Streptomycin - The spring comments were very similar to the fall 2013 comments. The majority 

of commenters are in support of removing Streptomycin from the list. 

o MgO - The fall and spring comments were very similar. Some commenters were against listing 

MgO and some favored the minority opinion of adding a 5- year expiration date. A member 

noted the lack of comments from growers as well as comments that humates are possibly being 

used as a crutch, although there was no evidence to support this claim. 

o Vinasse - The members felt the comments about vinasse were very helpful: Material Review 

Organizations and groups that represent them are in support of the proposal and noted that 

MROs are able to make a classification determination to determine what is or isn’t synthetic. 

The community is urging the NOP to finalize the classification guidance document as the NOSB 

is relying on the draft guidance for their review. Some reviewers suggested an annotation 

change, which could amount to a substantive change. The group discussed the possibilities of 

annotating the listing including specifying the non-synthetic variations of vinasse in the 

classification motion. A member cautioned that adding complexity and conditions to the 

motion after the Subcommittee voted is not a good tact to take unless this new annotation is 

solely for clarification. The CS Chair feels that it would be better to be more explicit in the 

motion because the synthetic and non-synthetic versions of vinasse have the same name. Then 

the ACAs would be responsible for making the determination. The NOP will provide feedback 

to the NOSB on how to proceed and if they feel it’s a substantive change the vote will be 

deferred to the fall 2014 meeting. 

o Laminarin - Two Material Review Organizations (MROs) supported the proposal in general but 

sought more guidance on its classification. Some commenters felt that the CS should get a 

technical review, which may change the classification of non-synthetic. One member supported 

the comments about laminarin containing an ‘impurity’ and the assertion that it should not be

allowed on the permitted substances list without a review. The CS Chair will summarize the 

public comments at the meeting but the group will leave the proposal as is, unless someone in 

the majority is concerned by the comments that recommended a TR and more guidance. The 

CS chair stated that if the motion for a nonsynthetic designation at the Board level fails then 

the CS will request a TR. 

o Sulfurous acid - Most of the fall 2013 comments, with a few exceptions, were is opposition to 

relisting this material, whereas the spring 2014 comments supported the proposal. 

o Sodium carbonate peroxyhydrate (SCP) - The group feels that the current annotation is 

confusing, inaccurate and does not belong, and therefore needs to be removed, even though 

there’s not a clear process for doing that. For spring 2014 the CS Chair will provide a summary 

of this material and will then explore the process for changing the annotation. Additionally, the 

CS would like to get some clarity from the NOP about the process for annotation changes. A 

member asked about this material as an alternative to Copper Sulfate. 

o Aqueous potassium silicate (APS) - The NOSB received several comments about this material 

but only two were substantive and referenced the TR.

• Members scheduled the review timeline for 2017 Sunset materials. See below.

• The meeting was adjourned
Previous CS Notes

Future Call Schedule:

April 1, 2014 2:00 ET

Presentations - identify presenters and format for spring 2014 meeting

Review Public comments

April 15, 2014 2:00 ET

Review Public comments

Schedule review timeline for 2017 Sunset materials. 

May 20, 2014 2:00 ET

Contamination Issues in Farm Inputs

2017 ZS

June 3, 2014 2:00 ET

2017 Sunsets CBo

2017 HA

June 17, 2014 2:00 ET

2017 All JFe

2017Cbe

2017 JFo

2017 HA

July 1, 2014 2:00 ET

2017 FT

2017 CBe

2017 JFo

July 15, 2014 2:00 ET

Aug 5, 2014 2:00 ET

Aug 19, 2014 2:00 ET

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

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

Spring 2014 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
2017 Sunsets (TR requests due to NOP July 2014)

Substance Contact TR Misc notes Vote Meeting

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary: 

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid 

205.601(e)

CBo 1995 “

Calcium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 “

Elemental sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995

“

EPA List 4 - Inerts of 

Minimal Concern 

205.601(m)

JFe None LS: 205.603(e) “

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene 

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

Herbicides, soapbased 205.601(b)

FT 1996 “

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
Humic acids 

205.601(j)

CBe 2006

“

Hydrated lime 

205.601(i)

ZS 2002 LS: 205.603(b)

“

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a)

“

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe

“

Lignin sulfonate 

205.601(j) 

205.601(l)

CBe 2011

“

Lime sulfur 

205.601(e) 

205.601(i)

HA

“

Liquid fish products 

205.601(j)

CBe 2006

“

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a)

“

Microcrystalline 

cheesewax 

205.601(o)

CBo

“

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

“

Oils, horticultural 

205.601(e) 

205.601(i)

HA 1995

“

Pheromones 

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium 

bicarbonate 

205 601(i)

JFe 1999

“

Potassium chloride 

205.602(e)

ZS 1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers 

205.601(a)

FT 1994

“
Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal 

205.601(e)

JFo 1994

“

Sodium 

fluoaluminate 

205.602(f)

JFo

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers 

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1 

205.601(j)

CBe 1995

“

Vitamin C 

205.601(j)

CBe 1995

“

Vitamin D3 

205.601(g)

JFo 2011

“

Vitamin E 

205.601(j)

CBe 1995

“
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 20, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Jay Feldman (JFe), Harold Austin (HA), 

John Foster (JFo), Colehour Bondera (CBo), Carmela Beck (CBe) 

Absent: none

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

Work plan 

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS will add 

question to sunset listing 

 

NA Summary: 

Spr 2014 

Review: 

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA Summary: 

Spr 2014 

Review: 

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will add question to sunset 

listing 

NA 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

No addit 

TR

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: 

Fall 2014 

Review: 

Spr 2015 

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest. 

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14

Summary: 

Fall 2014 

Review: 

Spr 2015 

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

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. Determine need for TR.

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting, will 

request Lmt’d scope TR for further review.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. 

Fall 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP.

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 Report fall

2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 3, 

2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from April 15, 2014

• Welcome Emily to Crops Subcommittee!

• Next steps for Laminarin (ZS)

• Contamination Issues in Farm Inputs (JFe) - progress report

• Confirm remaining summer schedule (including assign date for Hydrogen Chloride TR review)

• 2017 Sunsets (ZS)

Discussion

• Crops Subcommittee notes April 15, 2014 were approved with a minor correction to the section on 

streptomycin and some minor language edits. 

• Next steps for Laminarin (ZS) - ZS will compile some questions for a TR and circulate for discussion on 

June 3. After the group reviews the questions they will be able to determine whether they will request 

a full TR or a limited scope one. 

• Contamination Issues in Farm Inputs (JFe) - progress report. The document was structured as 

discussion document and the members discussed scheduling experts to join the CS calls to discuss this 

further. Included in this document, but beyond the current scope, is a longer term timeline for this 

work. The group envisions the following timeline: a discussion document for fall 2014, a proposal in 

spring 2015, and perhaps fall 2015 as well. The CS Chair indicated that the discussion document should

include the results of the literature review, information gleaned from the experts, and targeted 

questions for the community. The lead reviewer requested input regarding experts to invite and will 
begin the draft literature review for circulation prior to the next call. The discussion was added to the 

schedule below for June 3. 

• Confirm remaining summer schedule - The discussion to determine the TR sufficiency for Hydrogen 

Chloride was scheduled for June 3 (see below).

• 2017 Sunsets (ZS). ZS circulated a spreadsheet to the group with several 2017 sunset materials under 

review. She noted the difficulty in finding some of the old documents and provided the following for 

group discussion:

o Copper sulfate: Still trying to locate previous discussions, but is inclined to not request a new TR

since the last one was recent (2011). 

o Hydrated lime: Listed as lime, hydrated. Found the 2002 TR useful but it was reviewed for a 

different use (soil amendment), and as a solo material. It is used by itself and in combination 

with other materials for disease control.

o Hydrogen peroxide: No listing in petitioned substance database (1995). Well known and widely 

used, so the lead reviewer is recommending the CS not request a new TR. However, she will 

review this more thoroughly and present it for discussion again. 

o Potassium chloride. No listing in the petitioned substance database, but found a 1995 TAP 

review. This material has alternatives, and a former Board requested a petition to remove it 

from the list. The CS is waiting to hear from the NOP about alternatives for removal. The CS 

may request a limited scope TR. 

o The CS Chair urged the members to add notes to their reviews indicating the sources and 

locations of the past information, to aid the other members and future Boards with their 

reviews. In support of this, the Chair forwarded a list to the NOP indicating which information 

is missing and/or needs cross referencing or linking. ZS located all of the Committee reviews 

for the 2016 HS substances and will send to the Chair of the HS.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

April 15, 2014 2:00 ET

Review Public comments

Schedule review timeline for 2017 Sunset materials. 

May 20, 2014 2:00 ET

Contamination Issues in Farm Inputs

2017 Sunsets (ZS) 

June 3, 2014 2:00 ET

Next steps for Laminarin

Discuss draft for Contamination Issues in Farm Inputs 

2017 Sunsets (CBo) 

2017 Sunsets (HA) 

TR sufficiency on Hydrogen chloride 2016 (JFo)

June 17, 2014 2:00 ET

2017 Sunsets All (JFe) 

2017 Sunsets (CBe) 

2017 Sunsets (JFo) - TR

2017 Sunsets (HA) 

July 1, 2014 2:00 ET

2017 Sunsets (FT) 

2017 Sunsets (CBe) 

2017 Sunsets (JFo) 

July 15, 2014 2:00 ET 
Aug 5, 2014 2:00 ET

2016 Sunset reviews: (Sulf acid, SCP, APS) using new template. 

Aug 19, 2014 2:00 ET

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

2017 Sunsets (TR requests due to NOP July 2014)

Substance Contact TR Misc notes Vote Meeting

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary: 

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid 

205.601(e)

CBo 1995 “

Calcium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “ 

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Chlorine dioxide 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 “

Elemental sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995

“ 

EPA List 4 - Inerts of 

Minimal Concern 

205.601(m)

JFe None LS: 205.603(e) “ 

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“ 

Ethylene 

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

Herbicides, soapbased 205.601(b)FT 1996 “

Humic acids 

205.601(j)

CBe 2006 “

Hydrated lime 

205.601(i)

ZS 2002 LS: 205.603(b) “

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a) “ 

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a) “

Lead salts 

205.602(d)

JFe “

Lignin sulfonate 

205.601(j) 

205.601(l)

CBe 2011 “ 

Lime sulfur 

205.601(e) 

205.601(i)

HA “ 

Liquid fish products 

205.601(j)

CBe 2006 “

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a) “

Microcrystalline 

cheesewax 

205.601(o)

CBo “ 
Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

“ 

Oils, horticultural 

205.601(e) 

205.601(i)

HA 1995 “ 

Pheromones 

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“ 

Potassium 

bicarbonate 

205 601(i)

JFe 1999

“

Potassium chloride 

205.602(e)

ZS 1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers 

205.601(a)

FT 1994

“ 

Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal 

205.601(e)

JFo 1994

“

Sodium 

fluoaluminate 

205.602(f)

JFo “ 

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “ 

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers 

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“
Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“ 

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1 

205.601(j)

CBe 1995

“

Vitamin C 

205.601(j)

CBe 1995

“

Vitamin D3 

205.601(g)

JFo 2011

“

Vitamin E 

205.601(j)

CBe 1995

“
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 3, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Jay Feldman (JFe), Harold Austin (HA), 

John Foster (JFo), Colehour Bondera (CBo), Carmela Beck (CBe)

Absent: none

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

Work plan

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(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. TR returned to 

CS. TR found suffic 02 18 14. CS added

questions to sunset listing.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS added questions to sunset 

listing.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS added questions to sunset 

listing.

NA 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

No addit

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14

Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

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. Determine need for TR.

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting, will 

request Lmt’d scope TR for further review.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP.

Fall 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP.

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 Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 3, 

2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from May 20, 2014

• Next steps for Laminarin

• 2017 Sunsets (CBo)

• 2017 Sunsets (HA)

• TR sufficiency on Hydrogen chloride 2016 (JFo)

• Discuss draft for Contamination Issues in Farm Inputs

• Adjourn

Discussion

• Crops Subcommittee notes of May 20, 2014 were approved with no changes.

• Next steps for Laminarin - The CS will request a TR for Laminarin. The NOP suggested structuring the 

request in two parts. The first request could include manufacturing questions to determine 

classification then the group could proceed from there depending on that information. 

• 2017 Sunsets (CBo)

o Ammonium carbonate - listed at §205.601(e)(1) - for use as bait in insect traps only, no direct 

contact with crops or soil. The listing is for Handling not Crops. There is a TAP, but no TR or 

checklist. The lead reviewer suggests requesting a TR. 

o Boric acid - listed at §205.601(e)(3) - structural pest control, no direct contact with organic food 

or crops. There was no past TR or checklist. The previous review indicates there was a TAP 

review, but the lead person could not locate it (post meeting note from ABS: the document has 

now been posted on the NOP website). A member questioned whether or not Boric Acid can be 
used in traps, as Ammonium Carbonate is, noting that its use as listed would allow it as bait in 

traps.The lead suggested a TR be requested.

o Microcrystalline cheesewax - listed at §205.601(o) as production aids. Microcrystalline 

cheesewax (CAS #'s 64742-42-3, 8009-03-08, and 8002-74-2) - for use in log grown mushroom 

production. Must be made without either ethylene-propylene co-polymer or synthetic colors.

There was no TR or TAP but there was a checklist. The listed cheesewax is a petroleum product. 

The lead noted that there were alternatives available, thus, there is a question of essentiality. 

A TR could address the health and environmental impacts of microcrystalline cheesewax 

production as well as the availability of non-GMO soy wax.

• 2017 Sunsets (HA)

o Lime sulfur - listed at §205.601(e) as insecticide and at §205.601(i) as plant disease control. 

Original TAP review was completed in 1995 and based on that and some new information 

gleaned during the review of two other antibiotics on the National List, the lead reviewer 

suggests requesting a new TR. 

o Elemental sulfur - listed at §205.601 (e) as insecticide, at §205.601 (j) as plant or soil 

amendment, and at §205.601 (I) as plant disease control. Members discussed previous 

comments about this materials found in the original 1995 TAP review and public comment. The 

lead reviewer feels that the Subcommittee can get the needed information from Certifiers and 

Materials Review Organizations and therefore doesn’t feel there is a pressing need for a TR. A 

member noted that it’s his preference to fill out a checklist prior to making a determination 

about requesting a TR. 

o Horticultural Oils - Listed at §205.601(e) as insecticide, (6) Oils, horticultural-narrow range oils 

as dormant, suffocating, and summer oils and at §205.601(i) plant disease control, (6) Oils, 

horticultural-narrow range oils as dormant, suffocating, and summer oils. The Group discussed 

the 1995 TAP review, which indicated that toxicity is low. The lead noted that there are several 

alternatives (fish, vegetable), but doesn’t feel that a new TR is necessary. One member 

suggested they could seek a TR to ask specific questions about the phrase “narrow range” 

which seemed to be defined arbitrarily at 205.2.

o Pheromones - Listed at §205.601(f) as insect management. The group discussed pheromones in 

relation to the inerts review. The NOP and the CS Chair felt that combining these discussions 

would complicate matters and suggested that the Inerts review needs to be discussed 

separately. The NOP suggested having a presentation from the Inerts Working Group at the fall 

2014 meeting. The latest TR was done in 2012, and for that reason, the lead feels the CS does 

not need to request a new one. 

• Hydrogen Chloride 2016 TR sufficiency (JFo) - postponed to June 17 call.

• Contamination Issues in Farm Inputs - Discuss draft - postponed to June 17 call. The CS Chair asked 

that members please send comments to JFe (the lead writer) before the next call. The members were 

also asked to provide some suggestions for guest speakers so they could begin inviting people to 

participate on the calls. 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

May 20, 2014 2:00 ET

Contamination Issues in Farm Inputs

2017 Sunsets (ZS)

June 3, 2014 2:00 ET

Next steps for Laminarin

Discuss draft for Contamination Issues in Farm Inputs - postponed to June 17
2017 Sunsets (CBo) (Ammonium carbonate, Boric acid, Microcrystalline cheesewax)

2017 Sunsets (HA) (Elemental sulfur, Lime sulfur, Oils, horticultural, Pheromones)

TR sufficiency on Hydrogen chloride 2016 (JFo) - postponed to June 17

June 17, 2014 2:00 ET

TR sufficiency - Hydrogen chloride 2016 (JFo)

Discuss draft for Contamination Issues in Farm Inputs 

2017 Sunsets (CBo) – (Newspaper, plastic mulch, sticky traps and barriers)

2017 Sunsets (JFe) - Determine need for TR (Arsenic, Ash from manure burning, EPA List 4 - Inerts of 

Minimal Concern, Ethylene, Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine 

sulfate))

2017 Sunsets (CBe) - Determine need for TR (Aquatic plant extracts, Humic acids, Lignin sulfonate, 

Liquid fish products, Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or 

silicates of zinc, copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

2017 Sunsets (JFo) - Determine need for TR (Soaps (insecticidal), Sodium fluoaluminate, Sodium 

silicate, Sucrose octanoate esters, Vitamin D3

July 1, 2014 2:00 ET

2017 Sunsets (FT) - Determine need for TR (Calcium hypochlorite, Chlorine dioxide, Ethanol, 

Herbicides (soap-based), Isopropanol, Soap-based algicide/demossers, Soaps(ammonium), Sodium 

hypochlorite

2017 Sunsets (CBe) - Determine need for TR

2017 Sunsets (JFo) - Determine need for TR

July 15, 2014 2:00 ET

Aug 5, 2014 2:00 ET

2016 Sunset reviews: (Sulf acid, SCP, APS) using new template. 

Aug 19, 2014 2:00 ET

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
2017 Sunsets (TR requests due to NOP July 2014)

Substance Contact TR Misc notes Vote Meeting

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary: 

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid 

205.601(e)

CBo 1995 “

Calcium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 “

Elemental sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995

“

EPA List 4 - Inerts of 

Minimal Concern 

205.601(m)

JFe None LS: 205.603(e) “

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene 

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

Herbicides, soapbased 205.601(b)FT 1996 “

Humic acids 

205.601(j)

CBe 2006 “

Hydrated lime 

205.601(i)

ZS 2002 LS: 205.603(b) “
Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a)

“

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe

“

Lignin sulfonate 

205.601(j) 

205.601(l)

CBe 2011

“

Lime sulfur 

205.601(e) 

205.601(i)

HA

“

Liquid fish products 

205.601(j)

CBe 2006

“

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a)

“

Microcrystalline 

cheesewax 

205.601(o)

CBo

“

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

“

Oils, horticultural 

205.601(e) 

205.601(i)

HA 1995

“

Pheromones 

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium 

bicarbonate 

205 601(i)

JFe 1999

“

Potassium chloride 

205.602(e)

ZS 1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers 

205.601(a)

FT 1994

“

Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal 

205.601(e)

JFo 1994

“
Sodium 

fluoaluminate 

205.602(f)

JFo

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers 

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1 

205.601(j)

CBe 1995

“

Vitamin C 

205.601(j)

CBe 1995

“

Vitamin D3 

205.601(g)

JFo 2011

“

Vitamin E 

205.601(j)

CBe 1995

“
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 17, 2014 2:00 pm ET 

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

Bondera (CBo)

Absent: Francis Thicke, Vice Chair (FT), Carmela Beck (CBe)

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

Work plan

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA 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

No 

additional

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

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. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

will request Lmt’d scope TR for further 

review.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP.

Fall 2014

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14.

TBD
Calcium Sulfate 

(PDF)

List at 205.601

Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

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 Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from June 3, 2014

• TR sufficiency - Hydrogen chloride 2016 (JFo)

• Discuss draft for Contamination Issues in Farm Inputs

• 2017 Sunsets (CBo) - (Newspaper, plastic mulch, sticky traps and barriers)

• 2017 Sunsets (JFe) - Determine need for TR (Arsenic, Ash from manure burning, EPA List 4 - Inerts of 

Minimal Concern, Ethylene, Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine 

sulfate))

• 2017 Sunsets (CBe) - Determine need for TR (Aquatic plant extracts, Humic acids, Lignin sulfonate, 

Liquid fish products, Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or 

silicates of zinc, copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

• 2017 Sunsets (JFo) - Determine need for TR (Soaps (insecticidal), Sodium fluoaluminate, Sodium silicate, 

Sucrose octanoate esters, Vitamin D3

• Adjourn
Discussion

• Crops Subcommittee notes of May 20 were edited retroactively based on a correction from the CS 

Chair to the discussion on hydrated lime. 

• Crops Subcommittee notes of June 3, 2014 were approved with no changes.

• TR sufficiency - Hydrogen chloride 2016 (JFo) - Sunset date is September 9, 2016. Substance is used to 

de-lint cotton post harvest. The TR was found sufficient, but the lead reviewer wanted to track down 

one reference about alternatives. The HS will include a list of questions for posting. 

• Contamination Issues in Farm Inputs - The lead circulated a document to the CS prior to call, which he 

then summarized and the group discussed. The document is not a comprehensive assessment but 

rather a review of the most relevant and recent issues. One member identified several expert speakers

based on areas of expertise, who could participate on conference calls. Focus areas include composting, 

laboratory expertise, contamination in inputs, raw manure and antibiotics. The same member 

suggested engaging OMRI and WSDA first for an overarching view. The first speaker could participate 

after the July 15 call, and the rest could participate on calls in September. The goal is to identify 

protocols and guidance on how certifiers would identify contamination from farm inputs. For example 

OMRIs standards on heavy metal inputs. 

• 2017 Sunsets - Determine need for TRs. 

o Newspaper and other recycled paper (CBo) - There is a 2006 TR and a TAP review, but no 

checklist. Listed at §205.601(b)(2) Mulches. (i) Newspaper or other recycled paper, without 

glossy or colored inks. §205.601(c) As compost feedstock. Previous NOSB relisted in spring 

2011. There is some uncertainty around inks. A TR could address two issues: The annotation 

should be revisited to determine whether a better identification of hazardous inks may be 

possible. The lead posed a question about the use of newspaper for mulch and whether it 

caused a significant impact on the amount of virgin paper produced by reducing the amount of 

recycled pulp available? The group discussed this question and most feel that it’s not an issue 

because no one is using newspaper anyway. The NOP added that recycled paper may be used

to manufacture paper mulches. The group may want to request a TR, although it is not a high 

priority. 

o Plastic mulch (CBo) - Listed at §205.601(b) (2) Mulches. (ii) Plastic mulch and covers 

(petroleum-based other than polyvinyl chloride (PVC)). There is a 1995 TAP review but no TR or 

checklist. At the spring 2010 meeting, the NOSB recommended deferring the relisting until 

updated technical information was obtained. Because the TR was still not available for the 

spring 2011 meeting, and the NOSB felt that it had a long use history in organic production with

minimal known adverse effects, it was relisted. The members discussed the relationship 

between plastic and biodegradable biobased bioplastic mulch, which was recently approved for 

addition to the National List, and whether it might be desirable to move away from use of 

plastic mulch. A member noted that since this the bioplastic decision is so new (and not 

allowed yet until the final rule is published), not enough time has elapsed to compare them. 

The group does not feel that a TR would be helpful but perhaps can seek additional information 

from other sources. 

o Sticky traps and barriers (CBo) - Postponed to next call due to lack of time. 

o Soaps (insecticidal) (JFo) - There are no new use patterns and no changes in technical 

formulations since the last review. The lead acknowledged that the NOSB should consider 

carefully materials that have not had a TR in 20 years, but feels that insecticidal soap would not 

be on the top of the TR request list. There are others that are more critical.

o Sodium fluoaluminate (JFo) - Listed at §205.602 as a prohibited natural. Neither the lead nor 

the CS sees a need for a TR and will not request one. 

o Sodium silicate (JFo) - Listed at §205.601(l). There was a TR done in 2011 and there are no new 

use patterns, so the CS will not recommend a new TR. 
o Sucrose octanoate esters (JFo) - Listed at §205.601(e) and is a recent addition (2005). Approved 

in crops and livestock and although it is not used widely, it is used. The CS is not requesting a 

new TR. 

o Vitamin D3 (JFo) - Listed at §205.601(g). Reviewed in 2011, so the CS is not recommending new 

TR. 

o A member asked about having checklists for materials, especially in cases where there are no 

recent TRs or reviews, and expressed his concern that there is not a standardized process or 

format. The NOP noted that the checklists are optional for sunset reviews, and in light of the 

fact that there are 300+ sunset materials the group may not be able to complete checklists for 

everything. The Subcommittee will add standardized questions to the summary document 

about current usage in an effort to leave a written record indicating why they did or did not 

request a TR. HA, MA and JFo will look at potential forms for this purpose. 

• 2017 Sunsets (JFe) - Determine need for TRs. Postponed to July 1. 

o Arsenic 

o Ash from manure burning, 

o EPA List 4 - Inerts of Minimal Concern 

o Ethylene, 

o Lead salts, 

o Potassium bicarbonate, 

o Strychnine, 

o Tobacco dust (nicotine sulfate)

• 2017 Sunsets (CBe) - Determine need for TRs. Postponed to July 1.

o Aquatic plant extracts

o Humic acids

o Lignin sulfonate

o Liquid fish products

o Magnesium sulfate

o Soluble boron products

o Sulfates/carbonates/oxides/or silicates of zinc, copper, iron, manganese, molybdenum, 

selenium, and cobalt

o Vitamins B1, C, E

• The meeting was adjourned

ABS note: June 17, 2014

Based on the Livestock call that followed this call, the LS will send the CS its questions about the aluminum 

sulfate petition which will be reviewed jointly. CS will add to this to their discussion agenda and two 

Subcommittees will submit a combined request for a TR.

Previous CS Notes

Future Call Schedule:

June 3, 2014 2:00 ET

Next steps for Laminarin

Discuss draft for Contamination Issues in Farm Inputs - postponed to June 17

2017 Sunsets (CBo) (Ammonium carbonate, Boric acid, Microcrystalline cheesewax)

2017 Sunsets (HA) (Elemental sulfur, Lime sulfur, Oils, horticultural, Pheromones)

TR sufficiency on Hydrogen chloride 2016 (JFo) - postponed to June 17

June 17, 2014 2:00 ET

- TR sufficiency - Hydrogen chloride 2016 (JFo)
- Discuss draft for Contamination Issues in Farm Inputs

- 2017 Sunsets (CBo) – (Newspaper, plastic mulch, sticky traps and barriers)

- 2017 Sunsets (JFe) - Determine need for TR (Arsenic, Ash from manure burning, EPA List 4 -

Inerts of Minimal Concern, Ethylene, Lead salts, Potassium bicarbonate, Strychnine, Tobacco 

dust (nicotine sulfate))

- 2017 Sunsets (CBe) - Determine need for TR (Aquatic plant extracts, Humic acids, Lignin 

sulfonate, Liquid fish products, Magnesium sulfate, Soluble boron products, 

Sulfates/carbonates/oxides/or silicates of zinc, copper, iron, manganese, molybdenum, 

selenium, and cobalt, Vitamins B1, C, E

- 2017 Sunsets (JFo) - Determine need for TR (Soaps (insecticidal), Sodium fluoaluminate, Sodium 

silicate, Sucrose octanoate esters, Vitamin D3

July 1, 2014 2:00 ET

- 2017 Sunsets (CBo) - Sticky traps and barriers.

- 2017 Sunsets (JFe) - Determine need for TR (Arsenic, Ash from manure burning, EPA List 4 -

Inerts of Minimal Concern, Ethylene, Lead salts, Potassium bicarbonate, Strychnine, Tobacco 

dust (nicotine sulfate))

- 2017 Sunsets (FT) - Determine need for TR (Calcium hypochlorite, Chlorine dioxide, Ethanol, 

Herbicides (soap-based), Isopropanol, Soap-based algicide/demossers, Soaps (ammonium), 

Sodium hypochlorite

- 2017 Sunsets (CBe) - Determine need for TR (Aquatic plant extracts, Humic acids, Lignin 

sulfonate, Liquid fish products, Magnesium sulfate, Soluble boron products, 

Sulfates/carbonates/oxides/or silicates of zinc, copper, iron, manganese, molybdenum, 

selenium, and cobalt, Vitamins B1, C, E

- Assign calcium sulfate petition

July 15, 2014 2:00 ET

Aug 5, 2014 2:00 ET

- Guest speaker: OMRI?

- 2016 Sunset reviews: (Sulf acid, SCP, APS) using new template. 

Aug 19, 2014 2:00 ET

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014
2017 Sunsets (TR requests due to NOP July 2014)

Substance Contact TR Misc notes Vote Meeting

Ammonium 

carbonate 

205.601(e)

CBo 1995 HS: 205.605(b) - leavening agent Summary: 

Spr 2015 

Review:

Fall 2015

Aquatic plant 

extracts 205.601(j)

CBe 2006 “

Arsenic 205.602(b) JFe “

Ash from manure 

burning 205.602(a)

JFe “

Boric acid 

205.601(e)

CBo 1995 “

Calcium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 “

Elemental sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995

“

EPA List 4 - Inerts of 

Minimal Concern 

205.601(m)

JFe None LS: 205.603(e) “

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

LS: 205.603(a)

“

Ethylene 

205.601(k)

JFe 2011 HS: 205.605(b) – postharvest ripening and 

degreening “

Herbicides, soapbased 205.601(b)FT 1996 “

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Humic acids 

205.601(j)

CBe 2006

“

Hydrated lime 

205.601(i)

ZS 2002 LS: 205.603(b)

“

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 HS: 205.605(b)

LS: 205.603(a)

“

Isopropanol 

205.601(a)

FT TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe

“

Lignin sulfonate 

205.601(j) 

205.601(l)

CBe 2011

“

Lime sulfur 

205.601(e) 

205.601(i)

HA

“

Liquid fish products 

205.601(j)

CBe 2006

“

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a)

“

Microcrystalline 

cheesewax 

205.601(o)

CBo

“

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

“

Oils, horticultural 

205.601(e) 

205.601(i)

HA 1995

“

Pheromones 

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium 

bicarbonate 

205 601(i)

JFe 1999

“

Potassium chloride 

205.602(e)

ZS 1995 HS: 205.605(a)

“

Soap-based 

algicide/demossers 

205.601(a)

FT 1994

“
Soaps, ammonium 

205.601(d)

FT 1996

“

Soaps, insecticidal 

205.601(e)

JFo 1994

“

Sodium 

fluoaluminate 

205.602(f)

JFo

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“

Sodium silicate 

205.601(l)

JFo 2011

“

Soluble boron 

products 205.601(j)

CBe 1995

“

Sticky 

traps/barriers 

205 601( )

CBo

“

Strychnine 

205.602(h)

JFe LS: 205.604(a)

“

Sucrose octanoate 

esters 205.601(e)

JFo 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

CBe 2010

“

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe

“

Vitamin B1 

205.601(j)

CBe 1995

“

Vitamin C 

205.601(j)

CBe 1995

“

Vitamin D3 

205.601(g)

JFo 2011

“

Vitamin E 

205.601(j)

CBe 1995

“
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 1, 2014 2:00 pm ET

Present: Zea Sonnabend, Chair (ZS), Jay Feldman (JFe), Harold Austin (HA), John Foster (JFo), Carmela Beck 

(CBe), Colehour Bondera (CBo), Francis Thicke, Vice Chair (FT) 

Absent: none

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

Work plan 

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

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting. 

NA Summary: 

Spr 2014 

Review: 

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a) 

Original petition 

2006

ZS Y 

01/2014 

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting. 

NA Summary: 

Spr 2014 

Review: 

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting. 

NA 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

No 

additional

TR

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: 

Fall 2014 

Review: 

Spr 2015 

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest. 

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

Summary: 

Fall 2014 

Review: 

Spr 2015 

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

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. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

will request Lmt’d scope TR for further 

review.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. 

Fall 2014

or TBD

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TBD
Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

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

groupings, exact number to be determined

NA Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from June 17, 2014

• 2017 Sunsets - Determine need for TRs

 (CBo) - Sticky traps and barriers.

 (JFe) - Arsenic, Ash from manure burning, EPA List 4 - Inerts of Minimal Concern, Ethylene, 

 Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine sulfate) 

 (FT) - Calcium hypochlorite, Chlorine dioxide, Ethanol, Herbicides (soap-based), 

 Isopropanol, Soap-based algicide/demossers, Soaps (ammonium), Sodium hypochlorite

 (CBe) - Aquatic plant extracts, Humic acids, Lignin sulfonate, Liquid fish products, 

 Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or silicates of zinc, 

 copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

• Assign calcium sulfate petition Adjourn

Discussion

• Crops Subcommittee notes of June 17, 2014 approved with no changes.

• 2017 Sunsets - Determine need for TRs
o Sticky traps and barriers (CBo). Could not locate TAP or TR. The NOP will find this info and 

forward it, as well as post it on the website. The group discussed the history and use of traps 

which have evolved since the original listing. The lead suggested a TR which may be difficult 

due to the large, diverse nature of this category. 

o Arsenic (JFe). Listed at §205.602. Prohibited by OFPA. No TR needed. 

o Ash from manure burning (JFe). TR needed. Lead feels there should be documentation of the 

fact that this substance does not meet OFPA standards, and suggests a checklist be produced. 

o EPA List 4 - Inerts of Minimal Concern (JFe). The lead feels that a TR is needed, which they will 

discuss further on the next call. The members discussed beginning the review process on two of 

the categories of Inerts that the working group has classified. A member added that if the 

Subcommittee was to proceed with this, allowing some and not others, it would require an

annotation change which would require a petition. The NOP supported the idea of requesting a 

TR to get the process started. EBR will discuss this with National List manager. A member 

suggested voting to sunset all the Inerts then having the community petition to add them to 

the list on a specific timetable. Some materials may not pass the EPA’s Design for Environment

(DFE) process. 

o Ethylene (JFe). There are two TAP reviews and a TR. There was no checklist performed for 

listing on §205.601. The NOSB raised issues of compatibility, environmental effects of 

production, and essentiality. The feasibility of alternatives was mentioned as an area of 

uncertainty. While pineapple production without ethylene is not problematic for small growers, 

large growers are dependent on it to control the time of ripening. The group discussed the 

comments they received from several co-ops/small growers who could also be affected. A 

member added that without documentation or pressure on the community there is no 

incentive to develop alternatives. The group also discussed essentiality and adding some 

questions to the public posting of the proposal to address this. 

o Lead salts (JFe). No TR needed. Prohibited by OFPA.

o Potassium bicarbonate (JFe). There is a TAP from 1995 but no TR. There is no checklist or other 

decision document. All three reviewers recommended adding it to the National List. The TAP 

review mentioned that potassium bicarbonate does not fall into any of the OFPA categories. 

The information on essentiality/effectiveness and impacts of manufacture should be 

supplemented with up-to-date references. Limited TR/update recommended.

o Strychnine (JFe). Listed at §205.602. TR needed. Lead feels there should be documentation of 

the fact that this substance does not meet OFPA standards, and suggests a checklist be 

produced.

o Tobacco dust (nicotine sulfate) (JFe). Listed at §205.602. Prohibited by OFPA. Feels that since 

there is no documentation of the fact that this substance does not meet OFPA standards there 

needs to be a checklist and a TR. 

o Calcium hypochlorite, Sodium hypochlorite, Chlorine dioxide (FT). All three chlorine materials 

were relisted as a group on a sunset vote of 10 to 2 in April 2006. A TR was completed in 2006 

and was slightly expanded in 2011. The TR is comprehensive and is adequate. Low priority for 

new TR. 

o Ethanol, Isopropanol (FT). A TAP review addressing both ethanol and isopropanol was done in 

1995. Ethanol was added to §205.601(a)(2) in November 1995 by unanimous vote. Isopropanol 

was added to §205.601(a)(2) November 1995 by a 13 to 1 vote. Both were relisted by a 13-0 

sunset vote in November 2005. The CS received a TR for ethanol in January 2014 and a TR for 

isopropanol is in development. HA will look at TR for natural sources of ethanol.

o Soap-based herbicides (FT). TAP review in 1996. Added to §205.601(b)(1) in September 1996 

by unanimous vote. Relisted by a 13 to 0 sunset vote in November 2005. The TAP review was 

not very comprehensive. Recommended for new TR. 
o Soap-based algicide/demossers (FT). Listed under §205.601(a)(7) in September 1996 by a 

unanimous vote. Relisted by a 14 to 0 sunset vote in November 2005. Could not find a TAP 

review or TR. Recommended a new TR. 

o Soaps (ammonium) (FT). TAP review in 1996. Recommended as animal repellant in September 

1996 by a 12 to 1 vote. The 1996 TAP report contained no useful information, so a new TR is 

needed.

o Aquatic plant extracts (CBe). 2006 TAP. Vote deferred in 2005 pending updated technical info. 

Voted to relist in 2010. No TR needed. A member added that there might be an older TR listed 

under Kelp. CBe will check and if so, the NOP will add a cross reference on the website. 

o Humic acids (CBe). 1996 TAP, 2006 TR. Vote deferred in 2005 pending updated technical info. 

Voted to relist in 2010. No TR needed. Could review and cite 2012 oxidized lignite TR for more 

information.

o Lignin sulfonate (CBe). 1995 TAP, 2011 TR. Vote deferred pending updated technical info in 

2010. No new TR needed.

o Liquid fish products (CBe). 1995 TAP, 2006 TR. Voted to relist in 2005 and 2010. Liquid fish 

products - can be pH adjusted with sulfuric, citric or phosphoric acid. The amount of acid used 

shall not exceed the minimum needed to lower the pH to 3.5. No TR needed. 

o Magnesium sulfate (CBe). 1995 TAP, 2011 TR. Magnesium sulfate - allowed with a documented 

soil deficiency. Vote deferred in 2010 pending updated technical info. No TR needed. The group 

discussed non-synthetic forms or alternatives. While non-synthetic forms exist they are not 

used commercially. The NOP suggested adding a question about alternatives for public 

comment. 

o Soluble boron products, Sulfates/carbonates/oxides/or silicates of zinc, copper, iron, 

manganese, molybdenum, selenium, and cobalt (CBe). 2010 TR. Voted to relist is 2005 and 

2010. No TR needed.

o Vitamins B1, C, E (CBe). 1995 TAP. Voted to relist in 2005 and 2010. No TAP on file; Members 

discussed these items, questioning why they are on the list in this manner, and recommended a 

TR. 

• Assign calcium sulfate petition - The Chair asked that members read this petition and volunteer to 

review it. 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

June 17, 2014 2:00 ET

TR sufficiency - Hydrogen chloride 2016 (JFo)

Discuss draft for Contamination Issues in Farm Inputs 

2017 Sunsets (CBo) – (Newspaper, plastic mulch, sticky traps and barriers) 

2017 Sunsets (JFe) - Determine need for TR (Arsenic, Ash from manure burning, EPA List 4 - Inerts of 

Minimal Concern, Ethylene, Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine 

 sulfate)) 

2017 Sunsets (CBe) - Determine need for TR (Aquatic plant extracts, Humic acids, Lignin sulfonate, 

Liquid fish products, Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or 

silicates of zinc, copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

2017 Sunsets (JFo) - Determine need for TR (Soaps (insecticidal), Sodium fluoaluminate, Sodium 

silicate, Sucrose octanoate esters, Vitamin D3

July 1, 2014 2:00 ET

2017 Sunsets – Determine need for TRs

 (CBo) - Sticky traps and barriers.
 (JFe) - Arsenic, Ash from manure burning, EPA List 4 - Inerts of Minimal Concern, Ethylene, 

 Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine sulfate) 

 (FT) - Calcium hypochlorite, Chlorine dioxide, Ethanol, Herbicides (soap-based), 

 Isopropanol, Soap-based algicide/demossers, Soaps (ammonium), Sodium hypochlorite

 (CBe) - Aquatic plant extracts, Humic acids, Lignin sulfonate, Liquid fish products, 

 Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or silicates of zinc, 

 copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

Assign calcium sulfate petition

July 15, 2014 2:00 ET

Discuss EPA List 4 - Inerts of Minimal Concern

Aug 5, 2014 2:00 ET

Guest speaker: OMRI?

2016 Sunset reviews: (Sulf acid, SCP, APS) using new template. 

Aug 19, 2014 2:00 ET

Discuss petition sufficiency - calcium sulfate 

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

2017 Sunsets (TR requests due to NOP July 2014)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Ammonium 

carbonate 

205.601(e)

CBo 1995 Y (06 03) HS: 205.605(b) - leavening agent Summary: 

Spr 2015 

Review:

Fall 2015

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“ 

Arsenic 

205.602(b)

JFe N (07 01) “

Ash from 

manure 

burning 

205.602(a)

JFe ? (07 01)

“ 

Boric acid 

205.601(e)

CBo 1995 Y (06 03) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “ 

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “ 

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b)

“ 

Coppers, fixed

205.601(i)

ZS 2011 (05 20)

“ 

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“ 

EPA List 4 -

Inerts of 

Minimal 

Concern 

205.601(m)

JFe None LS: 205.603(e)

“ 

Ethanol 

(Alcohols) 

205.601(a)

FT 1995 

TAP

N (07 01) TR sent to CS 01 15 14. TR sufficiency due July 15, 

2014

LS: 205.603(a) “ 
Ethylene 

205.601(k)

JFe 2011 N (07 01) HS: 205.605(b) – postharvest ripening and 

degreening “ 

Herbicides, 

soap-based 

205.601(b)

FT 1996 Y (07 01)

“ 

Humic acids 

205.601(j)

CBe 2006 N (07 01)

“ 

Hydrated lime 

205.601(i)

ZS 2002 ? (05 20) LS: 205.603(b)

“ 

Hydrogen 

peroxide 

205.601(a) 

205.601(i)

ZS 1995 N (05 20) HS: 205.605(b)

LS: 205.603(a)

“ 

Isopropanol 

205.601(a)

FT N (07 01) TR in development

LS: 205.603(a) “ 

Lead salts 

205.602(d)

JFe N (07 01)

“ 

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“ 

Lime sulfur 

205.601(e) 

205.601(i)

HA

Y (06 03)

“ 

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“ 

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a) “ 
Microcrystallin

e cheesewax 

205.601(o)

CBo Y? (06 03)

“ 

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“ 

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N0 (06 03)

“ 

Pheromones 

205.601(f)

HA 2012 N (06 03)

“ 

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“ 

Potassium 

bicarbonate 

205.601(i)

JFe 1999 Y Lmtd 

Scope (07 

01)

“ 

Potassium 

chloride 

205.602(e)

ZS 1995 ? Lmtd 

Scope (05 

20)

HS: 205.605(a)

“ 

Soap-based 

algicide/demo

ssers 

205.601(a)

FT 1994 Y (07 01)

“ 
Soaps, 

ammonium 

205.601(d)

FT 1996 N (07 01)

“ 

Soaps, 

insecticidal 

205.601(e)

JFo 1994 Low 

Priority 

(06 17)

“ 

Sodium fluoaluminate 

205.602(f)

JFo N (06 17)

“ 

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “ 

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17) “ 

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“ 

Sticky 

traps/barriers 

205.601(e)

CBo ? (07 01)

“ 

Strychnine 

205.602(h)

JFe Y (07 01) LS: 205.604(a)

“ 

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“ 

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“ 
Tobacco dust 

(nicotine 

sulfate) 

205.602(i)

JFe ? (07 01)

“

Vitamin B1 

205.601(j)

CBe 1995 N (07 01)

“

Vitamin C 

205.601(j)

CBe 1995 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“

Vitamin E 

205.601(j)

CBe 1995 N (07 01)

“
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 15, 2014 2:00 pm ET 

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

Bondera (CBo), Francis Thicke, Vice Chair (FT), Jean Richardson - sitting on (JR)

Absent: Carmela Beck (CBe)

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

Work plan

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

Summary: Spr 2014 Review: Fall 2014

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015
Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets

Summary: Spr 2015 Review: Fall 2015

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

Summary: 

Spr 2015

Review:

Fall 2015

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

Combined TR. Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

Focus on alternatives
EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR request for Alkylphenol ethoxylates 

Herbicides, soapbased 205.601(b)FT 1996 TR 

Y

TR combined with Soap-based 

algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR combined with Herbicides, soap-based 

205.601(b)

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority
Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

will request Lmt’d scope TR for further 

review.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014)

Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14.

TR in development (expected September 

2014)

Spring 

2015

Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE)

NA Report 

Fall 2014
Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request but subcommittee voted 4-3 to 

wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from July 1, 2014

• Discuss Research Priorities (JFe, ZS)

• 2017 Sunsets - Prioritize TR requests

• Further discussion on List 4 inerts TR request

• Adjourn

Discussion

• Crops Subcommittee notes of July 1, 2014 were approved with minor changes

• Lindsay Fernandez-Salvador of OMRI was invited to speak on the next CS call. ZS asked that members 

send her questions so she can forward them to Lindsay ahead of the call. 

• Research Priorities (JFe, ZS). JFe is the point person for this workplan item and will touch base with all 

the appropriate people and report back to Materials on the August 5 call. 

• 2017 Sunsets. The CS Chair sent the summary of the 2017 Sunset TR requests prior to the call and the

group discussed the final determinations. There are 10 requests, 5 potential candidates, and 3 left to 

determine. A member emphasized the need for the completion of checklists for the items that won’t 

have TRs so the Board has background information supporting their decisions. The members further 

discussed the following materials before finalizing their list:

o Ethylene - Could promote this to medium priority for essentiality and alternatives.

o Sticky Traps - High-use pattern, but the listing is complex and it would be difficult to request a 

TR. Another member noted that this would be a candidate for a checklist, so the NOSB has a 

record in support of their decision making. The CS Chair feels this is a medium priority because

the problematic issues (such as the lures) are on the list separately.

o Tobacco dust/Nicotine sulfate - A prohibited substance so it will be a low priority. 

o Plastic mulch - The CS Chair suggested that the group wait until the final rule on biodegradable 

mulch is published before revisiting the need for this material. 
o Sodium hypochlorite - A member noted that the organic community is eagerly searching for 

bleach alternatives, and the group feels that the community, and not a TR, would be better 

suited to answer any questions. 

o Hydrogen peroxide - A TR will be requested.

o Coppers – There is a 2011 TR. Used as disease control for crops. A member suggested a limited 

Scope TR but the chair noted that it wouldn’t be necessary for this use. The member suggested 

that the NOSB identify a need for this material based on its use patterns, and feels the only way 

to do that is via a TR. 

• The Subcommittee discussed three groups of Inerts: NPEs (nonylphenol ethoxylates), the chelating 

agents EDTA/EDDS (Ethylenediaminetetraacetic acid/ Ethylenediamine-N,N'-disuccinic acid) and List 3 

inerts in pheromone dispensers. The Inerts Working Group (IWG) met this past week and determined 

that because NPEs are problematic and there is published research to this effect, the NOSB should 

review this group first. The IWG also considered EDTA but felt that NPEs were more pressing. A 

member argued for adding EDTA/EDDS as a second group. These are two chelating materials that have 

been the subject of past NOSB review, but it is an unresolved issue in the organic marketplace. Another

member supported the idea of requesting separate TRs since these materials are different. The Chair 

called a vote to determine the TR requests. The NOP indicated that the List 3 Inerts in pheromone 

dispensers will be addressed next year, and the Subcommittee voted in favoring of requesting a TR but 

delaying the review until then.

VOTE:

NPE TR request: 7 Y. 

(ABS note: Two members voted via email after the call)

EDTA/EDDS: 3 Y, 4 N 

(ABS note: Two members voted via email after the call)

List 3 inerts in pheromone dispensers: 7 Y, with 4 members opting to wait until it sunsets next year

(ABS note: Two members voted via email after the call)

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

July 1, 2014 2:00 ET

2017 Sunsets - Determine need for TRs

(CBo) - Sticky traps and barriers.

(JFe) - Arsenic, Ash from manure burning, EPA List 4 - Inerts of Minimal Concern, Ethylene, 

Lead salts, Potassium bicarbonate, Strychnine, Tobacco dust (nicotine sulfate)

(FT) - Calcium hypochlorite, Chlorine dioxide, Ethanol, Herbicides (soap-based), 

Isopropanol, Soap-based algicide/demossers, Soaps (ammonium), Sodium hypochlorite

(CBe) - Aquatic plant extracts, Humic acids, Lignin sulfonate, Liquid fish products, 

Magnesium sulfate, Soluble boron products, Sulfates/carbonates/oxides/or silicates of zinc, 

copper, iron, manganese, molybdenum, selenium, and cobalt, Vitamins B1, C, E

Assign calcium sulfate petition

July 15, 2014 2:00 ET

Discuss EPA List 4 - Inerts of Minimal Concern

Aug 5, 2014 2:00 ET
Laminarin - need to send request for limited Scope TR to LB

Ethanol TR Sufficiency

Guest speaker: OMRI

Discuss Research Priorities list

2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template.

Aug 19, 2014 2:00 ET

Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride 

Discuss petition sufficiency - calcium sulfate 

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET

2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b)

“

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20)

“

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01)

“

Isopropanol 

205.601(a)

FT N (07 01) TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“
Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995N (05 20) HS: 205.605(a)

“

Sodium fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 05, 2014 2:00 pm ET 

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

Bondera (CBo), Francis Thicke, Vice Chair (FT), Carmela Beck (CBe), Mac Stone (MS) – sitting in, Jean 

Richardson - sitting on (JR)

Absent: none

Guest Speaker: Lindsay Fernandez-Salvador, Organic Materials Review Institute (OMRI)

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

Work plan

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

Summary: Spr 2014 Review: Fall 2014

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 

01/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original petitions: 

2004, 2006

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

NA Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance ContactTR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets 

Summary: Spr 2015 Review: Fall 2015

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

Combined TR. Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

Focus on alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR request for Alkylphenol ethoxylates 
Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR combined with Soap-based 

algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR combined with Herbicides, soap-based 

205.601(b)

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting
Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014)

Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14.

TR in development (expected September 

2014)

Spring 

2015

Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from July 15, 2014

• Guest speaker: Lindsay Fernandez-Salvador (OMRI) - contamination issues

• Ethanol TR Sufficiency (FT)

• Discuss Research Priorities (JFe, ZS)

• 2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template

• Adjourn

Discussion

• Crops Subcommittee notes of July 15, 2014 were approved with no changes.

• Guest Speaker - Lindsay Fernandez-Salvador, technical director at OMRI, joined the call to discuss 

contamination issues in farm inputs. Ms. Fernandez-Salvador talked about the OMRI review standards 

for lab analyses of heavy metals and their two-tiered threshold for limits in compost/manure/mined 

minerals. She noted that the thresholds are very stringent and were established using various other 

standards, although Canada’s are now stricter and include more elements. 

• One challenge that exists is finding labs that test pesticide residues accurately both in compost and soil, 

or that detect low levels that may cause harm to plants. Labs must be ISO accredited, most are not 

equipped to test soils, and threshold levels are not clear. Additionally, tolerance levels cannot always 

be detected on plants and there needs to be an expert on staff to interpret the lab results. The extent 

of the problem is not currently quantified, and OMRI investigates on a case by case base, including 

complaints. Lindsay offered to forward additional documents, regarding suggestions made to NOP on 

pesticide residue testing. Other topics that were discussed include the need for process oriented 

standards and tolerance standards for foreign materials (i.e. plastic, glass, shoes, etc.). A member asked 

about the tolerance and enforcement of foreign materials standards, and Lindsay noted that Canada 

has standards but the US does not. Although required to have a plan in place to address this, 

organizations do not have to maintain a certain standard of success. The group also discussed the fact 

that the US allows GMO materials in compost as long as they are not being applied to crops directly. For 

these situations, OMRI uses the GMO decision tree to determine if the input is considered to be a direct 

use of GMOs. A member asked about possible topics for the NOSB address in its Research Priorities, 

including breakdown products such as heavy metals in relation to various composting processes. OMRI 

feels that the standard for heavy metals is robust, so perhaps this would not be a priority focus. Instead 

Lindsay emphasized that pesticide residues in compost is a salient issue, so perhaps contaminant 

mitigation might be a useful research topic. Other topics include problematic feedstock and guidelines, 

guidelines on types of testing, establishment of thresholds, and corrective actions. Lindsay 

recommended several other resources for the Crops Members, including the USCC (US Composting 

Council).

• Ethanol TR Sufficiency (FT). The group discussed several outstanding questions: How widely used is 

ethanol as a disinfectant/sanitizer in irrigation or other crop production and what is the availability of 

natural (non-synthetic) sources of ethanol? A member noted that ethanol is an input and is not 

required to be organic. It can be produced in non-synthetic and non-synthetic forms. When the original 

review was conducted in 1995 there were no fermented sources which is why it was added to the List, 
but the most current TR indicates that 95% are from fermented sources. This material will also be 

reviewed for sunset 2017. ABS Post call note: The TR was found sufficient. 

• Discuss Research Priorities (JFe, ZS). JFe will circulate the prior list of Research Priorities. Members 

suggested other topics for possible inclusion on the list including: No-till organic production; Citrus 

greening; Biological controls as alternative management systems; and an alternative to Re-Tain, which 

was used for post-harvest apple storage. Re-Tain was taken off the list because of inert ingredients, and 

it left a large need in organic apple production. Another member suggested a topic to focus attention 

on the application of foundational soils management practices, such as crop rotations, etc. and why 

they are beneficial. The organic community employs these principles routinely, and yet sometimes it is 

at a loss to demonstrate the benefits of such practices. The CS Chair noted that this was partially 

addressed in a previous RP on whole farm systems, but perhaps this new idea could provide 

refinement. A Subcommittee member noted that based on the feedback from the OWG on the last set 

of priorities, the more holistic and comprehensive the research project the harder it seems to get 

funding. JFe asked that members send additional ideas to him before the next MS call, in one week. 

• 2015 Sunset reviews: (Sulfurous Acid, SCP, APS) using new template

o The group discussed the new Sunset Review templates. The NOP noted that if the members 

wanted to use a checklist they can, however, it is not required. For consistency it should be 

included as an attachment and not incorporated into the actual text. Most members were 

supportive of this approach. The group discussed the mechanics of adding a “motion to 

remove” a material when the material is posted for the second review. Should this motion be 

added to all, or just the ones they do intend to remove? The Chair emphasized the need to be 

clear and uniform. The CS asked the NOP to provide feedback to the NOSB about how to 

finalize the documents specifically regarding the information that should be included in the 

summary in the review doc # 2. The group also discussed renaming the documents so it is clear 

to the stakeholders which review phase it represents. 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

July 15, 2014 2:00 ET

Discuss EPA List 4 - Inerts of Minimal Concern

Aug 5, 2014 2:00 ET

Laminarin - need to send request for limited Scope TR to LB

Ethanol TR Sufficiency

Guest speaker: OMRI

Discuss Research Priorities list

2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template

Aug 19, 2014 2:00 ET

Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride 

Discuss petition sufficiency - calcium sulfate 

Sep 2, 2014 2:00 ET

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET
2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20) “

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01) “

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Isopropanol 

205.601(a)

FT N (07 01) TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995N (05 20) HS: 205.605(a)

“

Sodium fluoaluminate 

205.602(f)

JFo N (06 17)

“
Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 19, 2014 2:00 pm ET 

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

Bondera (CBo), Francis Thicke, Vice Chair (FT), Carmela Beck (CBe)

Absent: Carmela Beck (CBe)

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

Work plan 

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

Summary: Spr 2014 Review: Fall 2014

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a) 

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance ContactTR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets 

Summary: Spr 2015 Review: Fall 2015

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

Combined TR. Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

Focus on alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR request for Alkylphenol ethoxylates 
Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR combined with Soap-based 

algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR combined with Herbicides, soap-based 

205.601(b)

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting
Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014)

Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014)

Spr 2015

Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

08 19 14 Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from August 5, 2014

• Discuss 2015 sunset reviews (Sulfurous acid, Sodium carbonate peroxyhydrate, APS)

• Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride 

• Discuss calcium sulfate petition sufficiency 

Adjourn

Discussion

• Approval of Crops Subcommittee notes of August 5, 2014 deferred to next call

• 2015 sunset reviews (Sulfurous acid, Sodium carbonate peroxyhydrate (SCP), Aqueous potassium 

silicate (APS). The members discussed the two options for presenting the 2015 Sunset reviews for the 

second-meeting posting: The Subcommittee could bring their determination about the material to the 

full Board as a way to inform the Board that the Subcommittee review was completed and it is

proposing that the material remain on the National List. The second option is for the Subcommittee to 

propose to remove every material, then the full NOSB would vote to remove every material. The 

members also discussed voting procedures for returning something to Subcommittee. The CS Chair 

would prefer to send a proposal to the Board indicating that the substance has been reviewed by the 

Subcommittee and should continue to be listed. But in light of the new Sunset process the vote to 

remove will serve to communicate to the public and the full Board that the Subcommittee reviewed the 

materials and made a proposal. The group discussed at length the recent suggestion by the NOP 

regarding voting on the Sunset materials in Subcommittee, as well as the process at the Board meeting. 

Members discussed the addition of language to the sunset proposals (see below) indicating that the 

Subcommittee will make a motion to remove on each of the materials when moving them from the 

Subcommittee to the full Board for a vote. The CS Chair proposed this language because many of the 

Board members were not comfortable with the notion that the full Board would not be able to vote on 

each item. 

A member stated that this new process is not in line with what was outlined in the new Sunset process 

published in the Federal Register in September 2013, which requires that motions to remove be 

justified by criteria established by the Organic Foods Production Act. Additionally, the member added 

that recent changes to the procedures outlined in the FR notice without a new FR notice informing the 

public inflict more harm to the credibility of board governance and reduce respect for the organic label.

The NOP noted that Subcommittee members need to cite general OFPA criteria such as essentiality or 

compatibility as the basis for proposals to remove. A member of the Subcommittee questioned how 

that could be under procedures as outlined in the FR and on the review sheet.

The NOP noted that the FR notice is not a regulation or statute, but a notice that describes evolving 

NOSB procedures. Responding to the Board’s request to vote on all sunset materials, the NOP 

suggested Subcommittees could make a motion to remove all substances. One member stated that 

this is a logistical issue and does not fundamentally change the instructions that were published in 

September 2013. The group made minor edits to the paragraph and will add it to each of the proposals. 
The members proceeded to a vote on the three 2015 Sunset Materials. Those opposing the new 

process to vote to remove all materials voted in the negative and those that support the process voted 

in the affirmative. Some Subcommittee members feel their votes do not convey the intent for whether 

the material should be removed, but only the will of the group to send the proposal forward for a full 

Board vote. The subcommittee had an interactive discussion in which one member stated that motions 

to remove must be supported by substantive justification describing how the motion substantively 

meets the criteria or criterion, as described in the FR and on the review sheet and that the NOP in 

public has said that the only way that the full board can vote on a material is if it moves from the 

subcommittee with a motion to remove. The member continued that, in his opinion, according to the 

FR notice, if there is not a motion to remove, there is no vote by the board, and the material remains 

on the National List.

The Subcommittee discussed writing a brief statement (~ two sentences) to indicate that the 

Subcommittee supported continued listing of the crop substances but is putting forth the motion to 

remove so the material will be forwarded to the Board for a full NOSB vote. One members 

interpretation of the new process is that according to the FR notice, if there is not a motion to remove, 

there is no vote by the board, and the material remains on the National List. The CS Chair asked 

members to craft the brief clarification statement and send her suggestions. She too will work on some 

language.

To be added to each Sunset proposal for clarification

The CS believes that the full board should have the opportunity to complete the review of each 

sunset material by voting. The NOP has stated that to do this a motion to remove should be 

brought from the Subcommittee for each substance. If the Subcommittee motion to remove fails to 

receive a majority, the motion will still be put forward to the full Board for review. The motion to 

remove is voted on by the full Board and needs to receive a 2/3 majority to become a 

recommendation.

Vote on Aqueous Potassium Silicate (APS)

Motion: to remove APS from the National List based on the following criteria in the Organic Foods 

Production Act (OFPA): 7 U.S.C. 6158(m), (7) its compatibility with a system of sustainable 

agriculture 

Motion by: HA

Seconded by: CBe 

Discussion: The group discussed the need for the addition of the above paragraph for clarity. 

Members also discussed the inclusion of brand names and whether they should be included. 

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

Vote on Sodium Carbonate Peroxyhydrate (SCP)

Motion: to remove SCP from the National List based on the following criteria in the Organic Foods 

Production Act (OFPA): 7 U.S.C. 6158(m), (7) its compatibility with a system of sustainable 

agriculture 

Motion by: ZS

Seconded by: HA

Discussion: none

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

Vote on Sulfurous Acid

Motion: to remove Sulfurous Acid from the National List based on the following criteria in the 

Organic Foods Production Act (OFPA): 7 U.S.C. 6158(m), (7) its compatibility with a system of 

sustainable agriculture 
Motion by: JFo

Seconded by: HA 

Discussion: Members discussed and made minor edits to the language in the proposal 

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

After the meeting, on August 25, 2014, a member suggested, in response to the Chair’s call for 

clarification, that the minority perspective be reflected in the meeting notes and on the 2015 sunset 

review documents.

• Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride. 

o The CS has no additional questions to post for ferric phosphate and will post the summary as is. 

o Hydrogen Chloride. The lead reviewer revised the document based on comments from the 

members during the call and will resend the paragraph to the group. 

• Calcium sulfate petition sufficiency. Deferred to next call.

• Contamination Issues in Farm Inputs Literature Review. The lead reviewer intends on having a 

literature review ready for the fall meeting. The group discussed the possibility of having another call to 

review this document. 

ABS Note 08 27 14: Members circulated the revised document via email after the call and voted via 

email. 

Motion to accept the Contamination Issues in Farm Inputs Literature Review

Motion by: Jay Feldman

Seconded by: Zea Sonnabend

Y: 5 N: 2 Absent: 1 Abstain: 0 Recuse: 0 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Aug 5, 2014 2:00 ET

Laminarin - need to send request for limited Scope TR to LB

Ethanol TR Sufficiency

Guest speaker: OMRI

Discuss Research Priorities list

2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template

Aug 19, 2014 2:00 ET

2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template 

Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride 

Discuss petition sufficiency - calcium sulfate 

Sep 2, 2014 2:00 ET

Discuss petition sufficiency - calcium sulfate

Sep 16, 2014 2:00 ET

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Nov 18, 2014 2:00 ET
2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20) “

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01) “

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Isopropanol 

205.601(a)

FT N (07 01) TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“
Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 2, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Harold Austin (HA), John Foster (JFo), 

Colehour Bondera (CBo), Carmela Beck (CBe), Mac Stone - sitting in 

Absent: Jay Feldman (JFe)

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

Work plan

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

Summary: Spr 2014 Review: Fall 2014

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance ContactTR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Carbon monoxide 

(exhaust gas) List at 

§205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014)

Spr 2015
Petitioned Substances

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14.

TR in development (expected September 

2014)

Spr 2015

Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14.

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Fall 2014

Propylene 

carbonate

205.601

Notice 11-6: Notice to NL Petitioners, Feb 

3, 2011 

NOP 5008: Guidance on Reassessed Inert 

Ingredients (PDF)

TBD

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from August 5 and 19, 2014

• Discuss petition sufficiency - calcium sulfate

• Verify TR sufficiency for Ethanol

• Discuss 2015 Workplan 

• Adjourn
Discussion

• Approval of Crops Subcommittee notes of August 5. The notes were approved with minor changes to 

the conversation about ethanol. The TR was found sufficient during the August 5 call and that was not 

captured in the notes.

• Approval of Crops Subcommittee notes of August 19, 2014. The group discussed the changes that JFe 

sent prior to the call. JFe was unable to participate on the call, so the group chose to defer the approval 

so he could be a part of the conversation. The Chair, as well as many members, wanted to relay their 

common sentiment that it is not respectful to make changes to documents after a call has concluded, 

and after a material was voted on. Additionally, out of respect for other members, the CS Chair asked 

that members provide more than a 24 hour notice, and ideally more than 48 hours, when circulating 

documents. 

• Discuss petition sufficiency - Calcium Sulfate. The Chair noted that the lead reviewer provided a

comprehensive summary. The petition was found sufficient and the Chair will relay that information to 

the NOP. The group discussed how to proceed given that this is a synthetic fertilizer. The CS is not 

inclined to ask for a TR and is considering rejecting the proposal. Prior Boards have done this based on 

the fact that it is a synthetic fertilizer which may not be allowed according to OFPA. ZS will send a note 

to LB noting petition sufficiency and the group will continue the discussion on the next call. 

• Verify TR sufficiency for Ethanol. The CS found the TR sufficient on the August 5 call. MA corrected the 

notes to reflect this. 

• Discuss 2015 Workplan. The 2015 workplan includes the following: Contamination Issues in Farm 

Inputs Literature Review, Laminarin, Allyl isothiocyanate (AITC), Carbon monoxide (exhaust gas), and 

calcium sulfate

• The CS Chair added a discussion of Contamination Issues in Farm Inputs document to the September 16 

call and asked members to bring suggestions for guest speakers to invite to the next few calls.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Aug 19, 2014 2:00 ET

2015 Sunset reviews: (Sulf Acid, SCP, APS) using new template 

Discuss 2016 Sunsets for 1st posting: Ferric phosphate, Hydrogen chloride 

Discuss petition sufficiency - calcium sulfate 

Sep 2, 2014 2:00 ET

Discuss petition sufficiency - calcium sulfate

Sep 16, 2014 2:00 ET

Review notes from August 19

Discuss speakers for future calls re: Contamination Issues

Oct 7, 2014 2:00 ET

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Vote on calcium sulfate 

Nov 18, 2014 2:00 ET

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014
2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

Combined TR. Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

Focus on alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR request for Alkylphenol ethoxylates 

Herbicides, soapbased 205.601(b)FT 1996 TR

Y

TR combined with Soap-based 

algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR combined with Herbicides, soap-based 

205.601(b)

Boric acid CBo 1995 TAP

Y

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “
Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a)

“

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b)

“

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20)

“

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01)

“

Isopropanol 

205.601(a)

FT N (07 01) TR in development

LS: 205.603(a)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“
Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995N (05 20) HS: 205.605(a)

“

Sodium fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 16, 2014 2:00 pm ET 

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

Feldman (JFe), Jean Richardson (JR) - sitting in

Absent: Francis Thicke, Vice Chair (FT), Carmela Beck (CBe)

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

Work plan

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

Summary: Spr 2014 Review: Fall 2014

Substance ContactTR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance ContactTR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

Petitioned Substances

Substance ContactTR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Exhaust gas

(Carbon monoxide) 

List at §205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014)

Spr 2015
Petitioned Substances

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14.

TR in development (expected September 

2014)

Spr 2015

Calcium Sulfate 

(PDF)

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14.

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Fall 2014

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from August 19, 2014

• Approve notes from September 2, 2014

• Discuss status of TRs on Allyl isothiocyanate and Exhaust Gas

• Discuss speakers for future calls re: Contamination Issues

• Adjourn

Discussion

• Approval of Crops Subcommittee notes of August 19, 2014 approved after edits were suggested by the 

group.

• Notes from September 2, 2014 were approved as is.
• MA edited the table above - removing Propylene carbonate from the workplan as it is on hold while 

the Inerts working group is continuing to address alternatives.

• The group discussed various speakers and topics to address contamination issues in farm inputs. 

Suggestions included people with extensive backgrounds in testing, soil, compost and residues, and 

pesticide testing. The CS will host speakers on October 7 and 21. 

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Sep 2, 2014 2:00 ET

Discuss petition sufficiency - calcium sulfate

Sep 16, 2014 2:00 ET

Review edits to notes of August 19

Discuss speakers for future calls re: Contamination Issues

Oct 7, 2014 2:00 ET. 

Guest speaker 

Review public comments. 

Oct 21, 2014 2:00 ET

Nov 4, 2014 2:00 ET

Vote on calcium sulfate Calls immediately after Board Meeting will be cancelled. 

Nov 18, 2014 2:00 ET

Guest speaker 

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

TR requested 08 15 14

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. 

Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on 

alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR requested 08 15 14 for Alkylphenol 

ethoxylates 

Herbicides, soapbased 205.601(b)FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b)

Isoproponol TR requested, in development

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 
Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20) “

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“
Humic acids 

205.601(j)

CBe 2006 N (07 01) “

Isopropanol 

205.601(a)

FT N (07 01) TR in development (expected Sept 2014)

LS: 205.603(a) “

Lead salts 

205.602(d)

JFe N (07 01) “

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a) “

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17) “

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03) “

Plastic mulch 

and covers 

(petroleumbased other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“
Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 October 7, 2014 2:00 pm ET 

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

Feldman (JFe), Francis Thicke, Vice Chair (FT), Carmela Beck (CBe) - sitting in, Jean Richardson (JR) - sitting in

Absent: none

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

Work plan 

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

Summary: Spr 2014 Review: Fall 2014

Substance Contact

TR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 See Table Below

Petitioned Substances

Substance Contact

TR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Exhaust gas 

(Carbon monoxide) 

List at §205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

Spr 2015
Petitioned Substances

development (expected September 2014). TR 

sent to CS 10 0 6 14. Sufficiency due 12 05 

14.

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014). TR sent 10 06 14. Sufficiency due 12 

05 14.

Spr 2015

Calcium Sulfate 

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14.

TBD

3-decene-2-one

CAS # 10519-33-2

CBe Petition sent to CS on 09 24 14. Questions or 

request for TR due 11 24 14.

TBD

Inert Ingredients

Substance Contact

TR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Fall 2014

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from September 16, 2014

• Review public comments

• Assign new petition for 3-decene-2-one sent to CS 09 24 14

• Adjourn
Discussion

• Crops Subcommittee notes of September 16, 2014 approved with no changes

• The CS plans on scheduling a guest speaker in November

• Fall meeting agenda items.

o Verbal update on inerts - EBR will present an update at the fall 2014 meeting, with input from 

ZS and JFe if needed

o Contamination in Farm Inputs - The NOSB received approximately 70 comments from 

individual commenters about this topic.

o 2015 sunset reviews: 

- Sulfurous Acid and Sodium Carbonate Peroxyhydrate (SCP) discussions were deferred 

to next call. 

- APS. The NOSB has received ~40 comments including one from the petitioner. Most of 

the comments about the 2015 sunset materials raised the issue of the Subcommittee 

process for reviewing sunset materials and did not comment specifically on the 

materials in question. 

o 2016 sunset reviews:

- Ferric phosphate received a couple of comments from growers and from Beyond 

Pesticides. 

- Hydrogen chloride discussion was deferred to the next call. 

• Petition for 3-decene-2-one. CBe volunteered to be the lead reviewer. Table above was updated to 

reflect this

• The NOP forwarded three TRs: Exhaust gas, Allyl isothiocyanate, and Isoproponol. See table for 

sufficiency due dates

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Sep 16, 2014 2:00 ET

Review edits to notes of August 19

Discuss speakers for future calls re: Contamination Issues

Oct 7, 2014 2:00 ET. 

Guest speaker 

Assign new petition for 3-decene-2-one (sent to CS 09 24 14)

Review public comments

Oct 21, 2014 2:00 ET

Continue discussion about 2015 and 2016 sunset reviews 

Review public comments

Nov 4, 2014 2:00 ET - (cancelled-Veteran’s Day)

Nov 18, 2014 2:00 ET

Vote on calcium sulfate 

Guest speaker 
2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 (Most TRs expected January 2015)

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

TR requested 08 15 14

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. 

Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on 

alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR requested 08 15 14 for Alkylphenol 

ethoxylates 

Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b)

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Isoproponol Draft TR sent to CS 09 24 14. 

TR suff due 11 24 14

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority
2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20) “

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01) “

Isopropanol 

205.601(a)

FT N (07 01) TR in development (expected Sept 2014)

LS: 205.603(a) “

Lead salts 

205.602(d)

JFe N (07 01) “

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a) “
Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“
Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 October 21, 2014 2:00 pm ET 

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

Feldman (JFe), Francis Thicke, Vice Chair (FT), Mac Stone (MS) - sitting in, Carmela Beck (CBe) - sitting in, 

Jean Richardson (JR) - sitting in

Absent: none

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

Work plan 

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

Summary: Spr 2014 Review: Fall 2014

Substance Contact

TR 

requested

Notes* Vote Meeting

Sulfurous Acid at 

205.601(j) 

Original petition 

2008

CBo Y 0

1/2014

3/2010

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. TR returned to 

CS. TR found suffic 02 18 14. CS will include 

questions in the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Sodium carbonate 

peroxyhydrate at 

205.601(a)

Original petition 

2006

ZS Y 

01/2014

08/2006

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014

Aqueous potassium 

silicate at 

205.601(e) and 

205.601(i) 

Original 

petitions: 2004, 200

6

JFe Y 

01/2014

09/2003

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. Revised TR sent to 

CS 01 15 14. TR suff due 02 15 14. TR found 

suffic 02 18 14. CS will include questions in 

the fall 2014 doc for posting.

08 19 14 Summary: 

Spr 2014 

Review:

Fall 2014
2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2003 TAP

Y

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 See Table Below

Petitioned Substances

Substance Contact

TR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

TBD

Exhaust gas 

(Carbon monoxide) 

List at §205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

Spr 2015
Petitioned Substances

development (expected September 2014). TR 

sent to CS 10 0 6 14. Sufficiency due 12 05 

14.

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014). TR sent 10 06 14. Sufficiency due 12 

05 14.

Spr 2015

Calcium Sulfate 

List at 205.601

ZS Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14.

TBD

3-decene-2-one

CAS # 10519-33-2

CBe Petition sent to CS on 09 24 14. Questions or 

request for TR due 11 24 14.

TBD

Inert Ingredients

Substance Contact

TR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Fall 2014

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

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.

Disc doc 

Fall 2014

Annotation 

Changes

Annotation change on workplan as test for 

changing annotations w/o petition

* Yellow highlight indicates Subcommittee action needed
Agenda

• Approve notes from October 7, 2014

• Continue discussion about 2015 and 2016 sunset reviews 

• Review public comments

• Adjourn

Discussion

• Crops Subcommittee notes of October 7, 2014 approved as is. 

• 2015 Sunsets 

o Sulfurous acid. A member noted that approximately 29 farmers provided comments in support 

of continued use while 145 individuals submitted comments about the sunset process as 

opposed to the material.

o Sodium carbonate peroxyhydrate – very few comments from farmers, some from the 

manufacturer and groups who were concerned about the process. CS would like to work 

separately on the annotation, which they feel is unnecessary. 

o Aqueous potassium silicate. The CS received 4 comments from the manufacturer. 

• 2016 Sunsets

o Ferric phosphate. A member noted that some of the comment attachments were missing from 

the bundled comments. MA will correct this and resend. 

o Hydrogen Chloride. A member noted that those commenters with knowledge of this material 

were in favor or relisting it, although reluctantly, noting the toxicity of the materials while 

acknowledging the lack of alternatives. Some supported the removal of this material from the 

National List. The CS recommends relisting while emphasizing the need for research into 

mechanical alternatives for de-linting cotton. The also intend on requesting an updated TR for 

future reviews. 

o Contamination in Farm Inputs. The lead will present a PowerPoint at the meeting which will 

include future directions.

o Inerts. The Chair read a prepared statement expressing her disapproval about the release of 

internal information by an NOSB member. She noted that an internal working document from 

the Inerts Working Group was circulated to members of the public and was subsequently 

incorporated into comments that were submitted to the public meeting docket. The members 

discussed actions to prevent this from happening in the future, and reminded the member that 

there is language in the Policy & Procedures Manual regarding privileged information.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Oct 7, 2014 2:00 ET. 

Guest speaker 

Assign new petition for 3-decene-2-one (sent to CS 09 24 14)

Review public comments

Oct 21, 2014 2:00 ET

Continue discussion about 2015 and 2016 sunset reviews 

Review public comments

Nov 4, 2014 2:00 ET - (cancelled-Veteran’s Day)

Nov 18, 2014 2:00 ET

Vote on calcium sulfate 

Guest speaker 
2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 (Most TRs expected January 2015)

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

TR requested 08 15 14

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. 

Focus on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on 

alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR requested 08 15 14 for Alkylphenol 

ethoxylates 

Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b)

Fall 2014 Milestones Target date

NOSB Subcommittee requests technical reports for Sunset 2017 substances Jul 15, 2014

NOP - Complete tentative agenda Aug 7, 2014

NOSB - Fall 2014 proposals due to NOP Aug 27, 2014

NOP - Post proposals, Publish FRN, Open public comment Sep 8, 2014

NOSB Subcommittees - submit tentative workplans to NOP Sept 11, 2014

Discuss workplans on ES call Sept 12, 2014

Public comment closes Oct 7, 2014

Workplans finalized on ES call (last call before fall mtg) Oct 17, 2014

NOP - Send compiled public comments to NOSB Oct 13, 2014

Fall 2014 NOSB Meeting – Louisville, KY Oct 27 - Oct 31
Isoproponol Draft TR sent to CS 09 24 14. 

TR suff due 11 24 14

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205 601( )

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority
2017 Sunsets (No TR requests)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a) “

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b) “

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20) “

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01) “

Isopropanol 

205.601(a)

FT N (07 01) TR in development (expected Sept 2014)

LS: 205.603(a) “

Lead salts 

205.602(d)

JFe N (07 01) “

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a) “
Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“
Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 18, 2014 2:00 pm ET 

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

Thicke, Vice Chair (FT), Jay Feldman (JFe), Jean Richardson (JR) - sitting in, Paula Daniels (PD) - sitting in

Absent: Carmela Beck (CBe), Jay Feldman (JFe)

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

Work Agenda

2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance Contact

TR 

requested

Notes* Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2014 

Lmtd 

Scope TR

2003 TAP

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 See Table Below
Petitioned Substances

Substance Contact

TR 

requested

Notes* Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

(expected Feb 2015)

TBD

Exhaust gas 

(Carbon monoxide) 

List at §205.601

FT Y Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014). TR 

sent to CS 10 0 6 14. Sufficiency due 12 05 

14.

Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA Y Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014). TR sent 10 06 14. TR found sufficient 

11 18 14.

Spr 2015

Calcium Sulfate 

List at 205.601

ZS N Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14. No TR request. 

Spr 2015

3-decene-2-one

CAS # 10519-33-2

CBe Petition sent to CS on 09 24 14. Questions or 

request for TR due 11 24 14.

TBD

Inert Ingredients

Substance Contact

TR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Spr 2015

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

TBD
Other Projects

Project ContactDoc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs Literature 

Review

JFe DD Disc doc 

Spr 2015

Sodium carbonate 

peroxyhydrate

ZS Pilot project for changing annotations w/o 

petition

Disc doc 

TBD

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from October 21, 2014

• Review work agenda for the fall/winter semester. Assign discussion dates

o 2016 Sunset - Ferric Phosphate (CBe)

o 2016 Sunset - Hydrogen Chloride (JFo) - new volunteer needed for transition

o Petition - Exhaust Gas (FT) - Discuss TR sufficiency 

o Petition - Allyl Isothiocyanate (HA) - Discuss TR sufficiency 

o Petition - Laminarin (ZS) - TR currently in development

o Petition - Calcium Sulfate (ZS) - no TR, not ready to vote this meeting but will schedule for 

future call.

o Petition - 3-decene-2-one (CBe) - Discuss petition sufficiency and TR request

o Discussion document - Contamination in Farm Inputs (JFe) - guest speakers, next steps and 

transition plan

• 2017 Sunsets (refer to table) - Assign transition members to work with JFe and JFo on their assignments 

for 2017 sunsets. Schedule materials for discussion: Materials that need to be reassigned:

o Potassium Bicarbonate

o EPA List 4 - Alkylphenol ethoxylates 

o Ethylene

o Ash from manure burning (.602)

o Soap, insecticidal

o Strychnine (.602)

o Tobacco dust (.602)

o Arsenic (.602)

o Lead salts (.602)

o Sodium fluoaluminate (.602)

o Sodium silicate

o Sucrose Octanoate esters

o Vitamin D3

• Adjourn

Discussion

• Crops Subcommittee notes of October 21, 2014 approved with no changes.

• MA will add extra calls and change the date of the Feb 3 call to Feb 2

• Review work agenda for the fall/winter semester. Assign discussion dates

o 2016 Sunset - Ferric Phosphate (CBe) - Assigned discussion and vote Dec 16

o 2016 Sunset - Hydrogen Chloride (JFo) - FT will take over presentation of this material at the 

spring meeting. Assigned discussion and vote Dec 16

o Petition - Exhaust Gas (FT) - Assigned TR sufficiency, discussion of checklist, and vote for Dec 2
o Allyl Isothiocyanate (HA) - Petitioned. Petition was found sufficient in April 2014. Synthetic 

substance allowed for use as a fumigant. The lead noted that the TR was found sufficient and 

thorough and is one of the better TRs they’ve received. Will discuss checklist and vote Dec 2.

o Petition - Laminarin (ZS) - TR currently in development. Will discuss TR Jan 6, if available.

o Petition - Calcium Sulfate (ZS) - No TR requested. The HS will discuss and the checklist and vote 

on Dec 16

o Petition - 3-decene-2-one (CBe) - Discussion of petition sufficiency and TR request scheduled 

for Dec 2

o Discussion document - Contamination in Farm Inputs (JFe) - guest speakers, next steps and 

transition plan. Will Britton will be invited to Dec 16 call. 

• 2017 Sunsets (refer to list and table below) - The group assigned transition members to work with JFe 

and JFo on their assignments for 2017 sunsets, and scheduled the discussion for materials that are not 

waiting for TRs (Dec 16 and Jan 6). The CS Chair suggested assigning any 205.602 materials to a CS 

alumna and not to new members. Materials that will be passed from an outgoing NOSB member will be 

added to the discussion schedule first. 

o Potassium Bicarbonate (JFe to HA)

o EPA List 4 - Alkylphenol ethoxylates (JFe to ZS) 

o Ethylene (JFe to HA)

o Ash from manure burning (.602) (CBo)

o Soap, insecticidal

o Strychnine (.602)

o Tobacco dust (.602) (CBo)

o Arsenic (.602) (FT)

o Lead salts (.602) (FT)

o Sodium fluoaluminate (.602) (ZS)

o Sodium silicate

o Sucrose Octanoate esters

o Vitamin D3

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Oct 21, 2014 2:00 ET

Continue discussion about 2015 and 2016 sunset reviews 

Review public comments

Nov 4, 2014 2:00 ET - (cancelled-Veteran’s Day)

Nov 18, 2014 2:00 ET

Vote on calcium sulfate - deferred 

Dec 2, 2014. 2:00 ET 

Contamination in Farm Inputs (JFe) - Guest speaker: Diana Tracy, Antech Lab, OR

 3-decene-2-one (CBe) - Discuss petition sufficiency and TR request 

 Exhaust Gas (FT) - Discuss TR sufficiency and checklist, and vote

Allyl Isothiocyanate (HA) - Discuss checklist/vote

Dec 16, 2014 2:00 ET

2016 Sunset Ferric Phosphate (CBe) - Discuss and vote (?)

2016 Sunset - Hydrogen Chloride (JFo/FT) - Discuss and vote.

Exhaust Gas (FT) - Discuss checklist and vote.

Calcium Sulfate (ZS) - Discuss checklist and vote

Discuss 2017 sunsets with no TRs
Jan 6, 2015 2:00 ET 

Discuss 2017 sunsets with no TRs

Laminarin - Discuss TR

Jan 20, 2015 2:00 ET

Feb 2 2:00 ET (moved from Feb 3 to Monday Feb 2)

Feb 17, 2015 2:00 ET

Feb 24, 2015 2:00 ET - Additional call

Mar 3, 2015 2:00 ET

Mar 17, 2015 2:00 ET

Apr 7, 2015 2:00 ET

Apr 21, 2015 2:00 ET

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 (Most TRs expected January 2015)

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

Y

TR requested 08 15 14

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. Focus 

on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on 

alternatives

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015

Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 31
EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR requested 08 15 14 for Alkylphenol 

ethoxylates 

Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b)

Isopropanol Draft TR sent to CS 09 24 14. 

LS: 205.603(a). TR suff due 11 24 14

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority
2017 Sunsets (No TR

s)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01)

“

Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a)

“

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b)

“

Coppers, fixed 

205.601(i)

ZS 2011? (05 20)

“

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“
Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“

Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“
Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 02, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Harold Austin (HA), Colehour Bondera 

(CBo), Jay Feldman (JFe), Carmela Beck (CBe), Tom Chapman (TC) - sitting in

Guest Speakers: Diana Tracy, Antech Lab, OR

Absent: John Foster (JFo)

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

Work Agenda

2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance Contact

TR 

requested

Notes Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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)

NA Summary: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo 2014 

Lmtd 

Scope TR

2003 TAP

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 See Table Below

Substance Contact

TR 

request?

Notes Vote Meeting

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

R i
Isopropanol

(Alcohols)

205.601(a)

FT Draft TR sent to CS and LS 09 24 14. CW is 

lead for LS

LS: 205.603(a). TR suff due 11 24 14

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

2014 TR

TR requested 08 15 14. TR sent to CS 12 04 

14. TR suff due 02 04 15

Petitioned Substances

Substance Contact

TR 

request?

Notes Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

(expected Feb 2015)

TBD

Exhaust gas

(Carbon Monoxide)

List at §205.601

FT 2014 TR Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014). TR 

sent to CS 10 0 6 14. Sufficiency due 12 05 

14. TR found sufficient 12 02 14.

Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA 2014 TR Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014). TR sent 10 06 14. TR found sufficient 

11 18 14.

Spr 2015

Calcium Sulfate 

List at 205.601

ZS N Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14. No TR request. 

Spr 2015

3-decene-2-one

CAS # 10519-33-2

List at 205.601

CBe N Petition sent to CS on 09 24 14. Questions or 

request for TR due 11 24 14. Petition found 

sufficient 12 02 14. No TR request

TBD

Inert Ingredients

Substance Contact

TR 

reqstd?

Notes* Vote Meeting
Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Spr 2015

EPA List 3 in passive 

pheromone 

dispensers

JFe Y TR request 07 15 14. Subcommittee voted 4-

3 to wait until they are scheduled to sunset, 

2018.

TBD

Other Projects

Project ContactDoc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs Literature 

Review

CBo/JFe DD Disc doc? 

Spr 2015

Sodium carbonate 

peroxyhydrate

ZS Pilot project for changing annotations w/o 

petition

Disc doc 

TBD

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from November 18, 2014

• Contamination in Farm Inputs (JFe) - Guest speaker: Diana Tracy, Antech Lab, OR 

• 3-decene-2-one (CBe) - Discuss petition sufficiency and TR request 

• Exhaust Gas (FT) - Discuss TR sufficiency and checklist

• Allyl Isothiocyanate (HA) - Discuss checklist/vote

• Adjourn

Discussion

• Crops Subcommittee notes of November 18, 2014 approved with no changes.

• Guest speaker: Diana Tracy, Antech Lab, OR. Ms. Tracy described her 30+ year career and background 

in organic which included working as an advisor for OMRI and conducting residue testing for Oregon 

Tilth. In an effort to focus the direction of the Contamination in Farm Inputs document the CS sent a list 

of questions to Ms. Tracy prior to the call, which she addressed (see questions below). Members were 

supportive of moving forward with a document that could include developing a framework/guidance 

for best practices for how the organic community uses compost materials. The goal is to raise

awareness without it being too burdensome on the community. The NOP noted that since fertilizer is 

regulated by OFPA, the USDA would have limited authority. The Chair asked for a volunteer from the 

continuing members to take over the lead role for this project, since JFe is transitioning off the Board. 

1. What kinds of pesticide residues do you expect to see in municipal/commercial composts?

2. What composting and cropping practices can reduce pesticide residues in soil and crops?

3. When composting/cropping are used to reduce pesticide residues, do they break down the pesticides or make 

them unavailable, and if the former, what are the products of the degradation?

In response to above questions, DT noted that a number of pesticides have been found, including the 

persistent pyridine herbicide (chlorpyralid. trichopyr, etc.) neonicinitoids, pyrethroids, and Treflan.
Many of these are difficult to test, although there are several factors that mitigate concentrations i.e. 

application rates vs. volume of soil. Other factors that affect concentration levels include how the 

compost is used (higher concentrations are found in mulch or sheet composting) or aged (longer aging 

time helps to reduce pesticide activity). Testing is very expensive, and it is difficult to control the inputs 

into commercial compost. From her point of view, it might be more important to focus on problems 

with heavy metals in manure or other inputs, since pesticides do break down but metals can 

accumulate. The group discussed the potential for developing guidelines for managing compost, which 

has been tried in the past but was found to be costly. The NOP noted that currently this practice is not 

in use, although the EPA is in the process of re-registering a number of the herbicides. 

4. Water contamination and treatment, particularly wastewater contamination with pesticides, 

pharmaceuticals, antibiotics, etc. (re. new study, “Treated Wastewater Irrigation: Uptake of Pharmaceutical 

and Personal Care Products by Common Vegetables under Field Conditions,” published in Environmental 

Science & Technology

This topic was outside the expertise of the guest speaker and was not discussed

• 3-decene-2-one (CBe) - Petitioned for addition to 205.601. Labeled for post-harvest use. The petition 

included some redacted information about formulations, but was deemed sufficient. The group will 

discuss the petition further on January 6, and will likely not request a TR. 

• Exhaust Gas (FT) - Members discussed the checklist that was circulated just prior to the call. The group 

discussed some additional language regarding Category 1 on the checklist (Probability of environmental

contamination during use and misuse). The lead felt that there was some inaccurate information in the 

TR but the group will pose some questions for public comment to glean more info. The CS members 

deemed the TR sufficient. 

• Allyl Isothiocyanate (HA) - Discuss checklist/vote - deferred to next call

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Nov 18, 2014 2:00 ET

Vote on calcium sulfate - deferred 

Dec 2, 2014 2:00 ET 

Contamination in Farm Inputs (JFe) - Guest speaker: Diana Tracy, Antech Lab, OR

 3-decene-2-one (CBe) - Discuss petition sufficiency and TR request 

 Exhaust Gas (FT) - Discuss TR sufficiency and checklist

Allyl Isothiocyanate (HA) - Discuss checklist/vote - deferred to next call

Dec 16, 2014 2:00 ET

Allyl Isothiocyanate (HA) - Discuss checklist/vote 

2016 Sunset Ferric Phosphate (CBe) - Discuss and vote (?)

2016 Sunset - Hydrogen Chloride (JFo/FT) - Discuss and vote

Exhaust Gas (FT) - Discuss checklist and vote.

Calcium Sulfate (ZS) - Discuss checklist and vote

Discuss 2017 sunsets with no TRs

Jan 6, 2015 2:00 ET 

Discuss 2017 sunsets with no TRs

Laminarin - Discuss TR if ready

3-decene-2-one (CBe) - Discuss cklist 

Jan 20, 2015 2:00 ET

Feb 2 2:00 ET (moved from Feb 3 to Monday Feb 2)
Feb 17, 2015 2:00 ET

Feb 24, 2015 2:00 ET - Additional call

Mar 3, 2015 2:00 ET

Mar 17, 2015 2:00 ET

Apr 7, 2015 2:00 ET

Apr 21, 2015 2:00 ET

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 (Most TRs expected January 2015)

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14

Vitamin B1, Vitamin 

C, Vitamin E

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. Focus 

on uses and alternatives.

Potassium 

bicarbonate

JFe 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on alternatives

EPA List 4 - Inerts of 

Minimal Concern

JFe Y TR requested 08 15 14 for Alkylphenol 

ethoxylates 

Herbicides, soapbased 205.601(b)

FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a)

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b)

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015

Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 30
Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe 2011

Y Lmtd 

Scope

Medium priority. Limited scope on 

alternatives to degreening

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

Y

Both listings. limited scope on inks and their 

impacts

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope 

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo 1994 Low priority

Strychnine 

205.602(h)

JFe Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe Low priority

2017 Sunsets (No TRs)

Substance Cont

act

TR New TR 

Rqust

Misc notes Vote Meeting

Aquatic plant 

extracts 

205.601(j)

CBe 2006 N (07 01)

“

Arsenic 

205.602(b)

JFe N (07 01) “
Calcium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b) 

LS: 205.603(a)

“

Chlorine 

dioxide 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Copper sulfate 

205.601(i)

ZS 2011 N (05 20) LS: 205.603(b)

“

Coppers, fixed 

205.601(i)

ZS 2011 ? (05 20)

“

Elemental 

sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995 N (06 03)

“

Humic acids 

205.601(j)

CBe 2006 N (07 01)

“

Lead salts 

205.602(d)

JFe N (07 01)

“

Lignin 

sulfonate 

205.601(j) 

205.601(l)

CBe 2011 N (07 01)

“

Liquid fish 

products 

205.601(j)

CBe 2006 N (07 01)

“

Magnesium 

sulfate 

205.601(j)

CBe 2011 N (07 01) HS: 205.605(a)

LS: 205.603(a)

“

Newspaper or 

other recycled 

paper 

205.601(b) 

205.601(c)

CBo 2006 Y Low 

Priority 

(06 17)

“

Oils, 

horticultural 

205.601(e) 

205.601(i)

HA 1995 N (06 03)

“

Pheromones 

205.601(f)

HA 2012 N (06 03)

“
Plastic mulch 

and covers 

(petroleum-

based other 

than 

polyvinylchlori

de (PVC)) 

205.601(b)

CBo 1995 N (06 17)

“

Potassium 

chloride 

205.602(e)

ZS 1995 N (05 20) HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo N (06 17)

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 N (07 01) HS: 205.605(b)

LS: 205.603(a)

“

Sodium 

silicate 

205.601(l)

JFo 2011 N (06 17)

“

Soluble boron 

products 

205.601(j)

CBe 1995 N (07 01)

“

Sucrose 

octanoate 

esters 

205.601(e)

JFo 2005 N (06 17) LS: 205.603(b)

“

Sulfates, 

carbonates, 

oxides, or 

silicates of 

zinc, copper, 

iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 

205.601(j)

CBe 2010 N (07 01)

“

Vitamin D3 

205.601(g)

JFo 2011 N (06 17)

“
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 16, 2014 2:00 pm ET 

Present: Zea Sonnabend, Chair (ZS), Francis Thicke, Vice Chair (FT), Harold Austin (HA), Colehour Bondera 

(CBo), Jay Feldman (JFe), Tom Chapman (TC) - sitting in

Absent: Carmela Beck (CBe), John Foster (JFo)

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

Work Agenda

2016 Sunsets 

Summary: Fall 2014 Review: Spr 2015

Substance ContactTR 

requested

Notes Vote Meeting

Ferric phosphate 

205.601(h) 

CAS # 10045–86–0)

CBe 2004 TAP

2010 TR

2012 TR 

Supp

No 

additional 

TR

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: 

Fall 2014 

Review:

Spr 2015

Hydrogen chloride 

205.601(n) 

CAS # 7647-01-0)

JFo/FT 2014 

Lmtd 

Scope TR

2003 TAP

Sunset Date: 09 12 16. Used to de-lint cotton 

post harvest.

2002 Petition

NOSB rec

Request for Lmtd scope TR sent to the NOP 

01 21 14. TR sent to CS 05 16 14. Sufficiency 

due 07 16 14. TR found sufficient 06 17 14. 

CS will include questions in the fall 2014 doc 

for posting.

NA Summary: 

Fall 2014 

Review:

Spr 2015

2017 Sunsets (TR requests)

Summary: Spr 2015 Review: Fall 2015 See Table Below

Substance ContactTR 

request?

Notes Vote Meeting

Ethanol (Alcohols) 

205.601(a)

FT 1995 TAP

Y

TR sent to CS 01 15 14. TR sufficiency due 

July 15, 2014. TR found sufficient 08 05 14.

Summary: 

Spr 2015

Review:

Fall 2015
Isopropanol

(Alcohols)

205.601(a)

FT 2014 TR Draft TR sent to CS and LS 09 24 14. CW is 

lead for LS

LS: 205.603(a). TR suff due 11 24 14. TR

found sufficient 12 16 14

“

Lime sulfur 

205.601(e) 

205.601(i)

HA 1995 TAP

2014 TR

TR requested 08 15 14. TR sent to CS 12 04 

14. TR suff due 02 04 15

“

Hydrogen peroxide 

205.601(a) 

205.601(i)

ZS 1995 TAP

Y

TR requested 08 15 14. TR Expected Jan/Feb 

2015

“

Vitamin B1, Vitamin 

C, Vitamin E 

205.601(j)

CBe 1995 TAP

Y

TR requested 08 15 14. Combined TR. Focus 

on uses and alternatives.

“

Potassium 

bicarbonate 

205.601(i)

JFe/HA 1999 TAP

Y Lmtd 

scope

TR requested 08 15 14. Focus on alternatives. 

Limited scope TR in development (expected 

mid-Dec)

“

EPA List 4 - Inerts of 

Minimal Concern

JFe/ZS Y TR requested 08 15 14 for Alkylphenol 

ethoxylates. TR expected Jan/Feb 2015; 

Nonylphenols only

“

Herbicides, soapbased 205.601(b)FT 1996 TR

Y

TR requested 08 15 14 TR combined with 

Soap-based algicide/demossers 205.601(a). 

TR Expected Jan/Feb 2015

“

Soap-based 

algicide/demossers 

205.601(a)

FT 1994 TAP

Y

TR requested 08 15 14 TR combined with 

Herbicides, soap-based 205.601(b). TR 

Expected Jan/Feb 2015

“

Petitioned Substances

Substance ContactTR 

request?

Notes Vote Meeting

Laminarin List at 

205.601

ZS Y Lmtd 

Scope

Petition sent to CS on 06 03 13. Sufficiency 

response due 08 02 13. Petition found 

sufficient 07 30 13. Determine need for TR. 

Based on classification vote 12 17 13 the CS 

proposes to not add laminarin to the NL. 

Returned to CS after Apr 2014 meeting. CS 

requested Lmt’d scope TR 08 06 14.

(expected Feb 2015)

TBD
Exhaust gas

(Carbon Monoxide)

List at §205.601

FT 2014 TR Petition sent to CS on 06 06 12. Petition 

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. Petition found suff 01 

21 14. TR request sent to NOP. TR in 

development (expected September 2014). TR 

sent to CS 10 0 6 14. Sufficiency due 12 05 

14. TR found sufficient 12 02 14.

12 16 14 Spr 2015

Allyl isothiocyanate 

(AITC)

List at 205.601

HA 2014 TR Petition sent to CS on 01 22 13. Petition suff 

due March 22, 2014. Petition found sufficient 

03 04 14. TR request sent to NOP ~ 04 01 14. 

TR in development (expected September 

2014). TR sent 10 06 14. TR found sufficient 

11 18 14.

12 16 14 Spr 2015

Calcium Sulfate 

List at 205.601

ZS N Petition sent to CS on 06 16 14. Questions or 

request for TR due 08 19 14. Petition found 

sufficient 09 02 14. No TR request. 

Spr 2015

3-decene-2-one

CAS # 10519-33-2

List at 205.601

CBe N Petition sent to CS on 09 24 14. Questions or 

request for TR due 11 24 14. Petition found 

sufficient 12 02 14. No TR request

TBD

Inert Ingredients

Substance ContactTR 

reqstd?

Notes* Vote Meeting

Inerts update JFe/ZS N/A Inerts –report on progress with Design for 

the Environment (DfE) 

NA Verbal 

Report 

Spr 2015

Other Projects

Project ContactDoc type Notes* Vote Meeting

Contamination 

Issues in Farm 

Inputs 

CBo/JFe DD Disc doc 

Spr 2015

Annotation 

Changes (Sodium 

carbonate

peroxyhydrate)

ZS Pilot project for changing annotations w/o 

petition

Disc doc 

TBD

* Yellow highlight indicates Subcommittee action needed

Agenda

• Approve notes from December 2, 2014

• Isopropanol TR sufficiency (TF)

• Discuss 2017 sunsets with no TRs

• Contamination in Farm Inputs next steps (JFe)
• Allyl Isothiocyanate (HA) - Discuss checklist/vote 

• 2016 Sunset Ferric Phosphate (CBe) - Discuss and vote (?)

• 2016 Sunset - Hydrogen Chloride (JFo/FT) - Discuss and vote

• Exhaust Gas (FT) - Discuss checklist and vote.

• Calcium Sulfate (ZS) - Discuss checklist and vote

• Adjourn

Discussion

• Crops Subcommittee notes of December 2, 2014 were approved with no changes.

• Isopropanol TR sufficiency (FT). The lead reviewer deemed the TR sufficient. The CS Chair will notify 

the NOP of the outcome. 

• Discuss 2017 sunsets with no TRs. Five of the 2017 materials were reassigned from the two members 

who are rotating off: four (Soaps, insecticidal, Sodium silicate, Sucrose octanoate esters, and Vitamin 

D3) were transferred from JFo to PD, and one (Strychnine) from JFe to ZS. The Chair noted that the task 

for the 2017 sunsets is to review the past materials and add questions for public comment. The 2017 

Sunset materials were added to the discussion schedule for the next several calls (see below). 

• Contamination in Farm Inputs (JFe) - The lead reviewer, who will be transferring this project to CBo

upon his departure, discussed the next steps for this project. Based on input from the guest speaker on 

the last call, Diana Tracy, the lead feels that it would be most useful to identify pathways for 

contaminants and prioritize them. The leads will discuss this further on the Jan 20 call.

• Allyl Isothiocyanate (AITC) (HA) - The lead reviewer noted that this material is being petitioned for 

addition to the NL, and is identified as synthetic. Members discussed essentiality and alternatives, in 

particular the natural sources of mustard meal or mustard cover crops, , and proceeded to a vote.

Vote:

Motion to classify AITC gas as synthetic

Motion by: HA

Seconded by: FT

Additional discussion: None

Yes: 5 No: 0 Abstain: 0 Absent: 2 Recuse: 0 

Motion to add AITC as petitioned to §205.601

Motion by: HA

Seconded by: CBo

Discussion: The lead reviewer noted that he included feedback from JFe in the checklist but

added it in the wrong location. He will move it to the correct section and resend the document 

to the group for review, but noted that this will not affect what they are voting on.

Yes: 0 No: 5 Abstain: 0 Absent: 2 Recuse: 0 

• 2016 Sunset Ferric Phosphate (CBe) - Discuss and vote (?) - deferred to next call

• 2016 Sunset - Hydrogen Chloride (JFo/FT) - Discuss and vote - deferred to next call. 

• Exhaust Gas (FT) - The lead noted that he sought feedback from the dairy community and did not find 

much support for adding this material to the list. He also noted that there are still some unknowns with 

regard to this substance such as how it affectssoil and how it might affect non-target species. A 

member noted that as well as Vitamin D, for use as rodent bait. The group proceeded to a vote:

Vote:

Motion to classify exhaust gas as synthetic

Motion by: FT

Seconded by: HA
Additional discussion: none

Yes: 5 No: 0 Abstain: 0 Absent: 2 Recuse: 0 

Motion to add Exhaust gas at §205.601

Motion by: FT

Seconded by: HA

Additional discussion: The CS Chair asked that the introduction section for checklist be fleshed 

out more to include more background, including reasons as to why the petition was initially 

deemed insufficient and was sent back for more information. The Chair also asked that the 

questions that were posed to the EPA be included here, as well as a discussion of alternatives.

Yes: 0 No: 5 Abstain: 0 Absent: 2 Recuse: 0 

• Calcium Sulfate (ZS) - The lead provided a partial checklist for discussion and indicated that she will 

complete it for the next call so the group can vote. She noted that the petition was written well and 

was complete. Calcium sulfate is synthetic, and similar to gypsum, but it is recaptured from flue gases 

produced by burning coal. The petitioners want to add it to the NL so gypsum can be recycled for use in 

organic fields. There are environmental concerns resulting from transport. A document from the 

National Institute of Environmental Health Sciences (NIEHS) was included in the petition, which 

contained an extensive survey of health effects of breathing in gypsum from wallboard. The findings

indicated that the additives, and not the gypsum, in wallboard was the hazard. A member added that 

the information from the EPA fact sheet about hazards based on variations in use and manufacture

should also be cited. The CS Chair noted that even without a TR the NOSB has a complete picture of this 

material.

• The meeting was adjourned

Previous CS Notes

Future Call Schedule:

Dec 2, 2014 2:00 ET 

Contamination in Farm Inputs (JFe) - Guest speaker: Diana Tracy, Antech Lab, OR

 3-decene-2-one (CBe) - Discuss petition sufficiency and TR request 

 Exhaust Gas (FT) - Discuss TR sufficiency and checklist

Allyl Isothiocyanate (HA) - Discuss checklist/vote - deferred to next call

Dec 16, 2014 2:00 ET

Allyl Isothiocyanate (HA) - Discuss checklist/vote - completed

2016 Sunset Ferric Phosphate (CBe) - Discuss and vote (?) deferred to Jan 6

2016 Sunset - Hydrogen Chloride (JFo/FT) - Discuss and vote - deferred to Jan 6

Exhaust Gas (FT) - Discuss checklist and vote - completed

Calcium Sulfate (ZS) - Discuss checklist

Discuss 2017 sunsets with no TRs

Jan 6, 2015 2:00 ET 

Calcium Sulfate (ZS) - vote

2016 Sunset - Hydrogen Chloride (FT) - Discuss proposal and vote

2016 Sunset - Ferric Phosphate (CBe) - Discuss proposal and vote

Laminarin (ZS) - Discuss TR if ready

3-decene-2-one (CBe) - Discuss cklist 

2017 Sunset - Ethanol (FT) - discuss summary/questions if any

2017 Sunset - Isopropanol (FT) - discuss summary/questions if any

2017 Sunset - Strychnine (ZS) - discuss summary/questions if any

2017 Sunset - Sodium fluoaluminate, hydrated lime, Potassium chloride (ZS)- discuss 

 summary/questions if any
Jan 20, 2015 2:00 ET

2017 Sunsets - Elemental sulfur, Oils (horticultural), Pheromones (HA) - discuss summary/questions 

 if any (may try to discuss on Jan 6th)

2017 Sunset - Lime sulfur (HA) - Discuss TR sufficiency

2017 Sunsets - Ash from manure burning, Tobacco dust (nicotine sulfate), and Arsenic (if time

 allows) (CBo) - discuss summary/questions if any

2017 Sunset - Lead salts, Soaps, ammonium, Sodium hypochlorite (FT) - discuss summary/questions 

 if any

Contaminants in farm inputs (CBo) - continue discussion

2017 Sunsets - Aquatic plant extracts, Humic acids, Lignin sulfonate, Liquid fish products, 

 Magnesium sulfate (CBe) - discuss summary/questions if any

Feb 2, 2:00 ET (moved from Feb 3 to Monday Feb 2)

2017 Sunsets - Ammonium carbonate, Newspaper or other recycled paper, Plastic mulch and 

 covers (CBo) - discuss summary/questions if any

2017 Sunsets - Calcium hypochlorite, Chlorine dioxide, Sodium hypochlorite (FT) - discuss 

 summary/questions if any

2017 Sunsets - Coppers (fixed), Copper sulfate (ZS) - discuss summary/questions if any

Feb 17, 2015 2:00 ET

2017 Sunsets - Hydrogen peroxide (ZS) - Discuss TR Sufficiency if available

2017 Sunsets - Herbicides, soap-based (FT) - Discuss TR Sufficiency if available

2017 Sunsets - Soap-based algicide/demossers (FT) - Discuss TR Sufficiency if available

2017 Sunsets - Soluble boron products, Sulfates, carbonates, oxides, or silicates of zinc, copper, 

 iron, manganese, molybdenum, selenium, and cobalt (CBe) - discuss summary/questions 

 if any

2017 Sunsets - Soaps, insecticidal, Sodium silicate, Sucrose octanoate esters, Vitamin D3 (PD) - 

 discuss summary/questions if any

Feb 24, 2015 2:00 ET - Additional call

2017 Sunsets - Sticky traps/barriers Microcrystalline cheesewax (CBo) - discuss summary/questions 

 if any

2017 Sunsets - Vitamin B1, Vitamin C, Vitamin E (CBe) - Discuss TR Sufficiency if available

2017 Sunsets - Potassium bicarbonate 205.601(i) (?) - Discuss TR Sufficiency if available

2017 Sunsets - Ethylene (?) - discuss summary/questions if any

2017 Sunsets - EPA List 4 - Inerts of Minimal Concern (?) -Discuss TR Sufficiency if available

Mar 3, 2015 2:00 ET

Mar 17, 2015 2:00 ET

Apr 7, 2015 2:00 ET

Apr 21, 2015 2:00 ET

Spring 2015 Milestones Target date

NOSB Training Feb 4-5, 2015

NOP - Complete Spring 2015 NOSB meeting tentative agenda Feb 7, 2015

NOSB - Spring 2015 proposals due to NOP Feb 25, 2015

NOP - Post proposals, Publish FRN, Open public comment Mar 9, 2015

Discuss work agendas on ES call Mar 13, 2015

Public comment closes Apr 6, 2015

Work agendas finalized on ES call (last call before spring mtg) Apr 10, 2015
2017 Sunsets (No TRs)

Newspaper or 

other recycled 

paper 205.601(b) 

205.601(c)

CBo 2006

Y

Both listings. Rqustd limited scope on inks 

and their impacts. Not contracted.

Soaps, ammonium 

205.601(d)

FT 1996

Y

Sticky 

traps/barriers 

205.601(e)

CBo Y Lmtd 

Scope

Limited scope. Not contracted.

Ammonium 

carbonate 

205.601(e) (used in 

traps)

CBo 1995 Low priority

Ash from manure 

burning 205.602(a)

JFe/CBo Low priority

Hydrated lime 

205.601(i)

ZS 2002 Low priority

Soaps, insecticidal 

205.601(e)

JFo/PD 1994 Low priority

Tobacco dust 

(nicotine sulfate) 

205.602(i)

JFe/CBo Low priority

Aquatic plant 

extracts 205.601(j)

CBe 2006

“

Arsenic 205.602(b) JFe/FT “

Calcium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b) 

LS: 205.603(a) “

Chlorine dioxide 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a) “

Copper sulfate 

205.601(i)

ZS 2011 LS: 205.603(b) “

NOP - Send compiled public comments to NOSB Apr 13, 2015

Spring 2015 NOSB meeting - La Jolla, CA Week of April 27 - 30
Coppers, fixed 

205.601(i)

ZS 2011

“

Elemental sulfur 

205.601(e) 

205.601(i) 

205.601(j)

HA 1995

“

Humic acids 

205.601(j)

CBe 2006

“

Lead salts 

205.602(d)

JFe/FT

“

Lignin sulfonate 

205.601(j) 

205.601(l)

CBe 2011

“

Liquid fish products 

205.601(j)

CBe 2006

“

Magnesium sulfate 

205.601(j)

CBe 2011 HS: 205.605(a)

LS: 205.603(a)

“

Oils, horticultural 

205.601(e) 

205.601(i)

HA 1995

“

Pheromones 

205.601(f)

HA 2012

“

Plastic mulch and 

covers (petroleum-

based other than 

polyvinylchloride 

(PVC)) 205.601(b)

CBo 1995

“

Potassium chloride 

205.602(e)

ZS 1995 HS: 205.605(a)

“

Sodium 

fluoaluminate 

205.602(f)

JFo/ZS

“

Sodium 

hypochlorite 

205.601(a)

FT 2011 HS: 205.605(b)

LS: 205.603(a)

“
Sodium silicate 

205.601(l)

JFo/PD 2011 “

Soluble boron 

products 205.601(j)

(Micronutrients)

CBe 1995

“

Strychnine 

205.602(h)

JFe/ZS

Sucrose octanoate 

esters 205.601(e)

JFo/PD 2005 LS: 205.603(b)

“

Sulfates, 

carbonates, oxides, 

or silicates of zinc, 

copper, iron, 

manganese, 

molybdenum, 

selenium, and 

cobalt 205.601(j)

(Micronutrients)

CBe 2010

“

Vitamin D3 

205.601(g)

JFo/PD 2011 “

Boric acid CBo 1995 TAP

Y

Ethylene 

205.601(k)

JFe/HA 2011

Y Lmtd 

Medium priority. Limited scope on 

alternatives to degreening. Not contracted.

Microcrystalline 

cheesewax

CBo Y Lmtd 

Scope

Limited scope on alternatives. Not 

contracted.