Updated June 17, 2010

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Calcium Acid Pyrophosphate

Chair: Tracy Miedema

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action

Guidance Statement

Other X

Statement of the Recommendation (Including Recount of Vote): 

Not to add calcium acid pyrophosphate to § 205.605(b) of the National List.

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

The NOSB considered a petition to add Calcium Acid Pyrophosphate to the 

National List, section 205.605, and per board procedures, first made a 

determination as to whether the material should be classified as a synthetic or 

a non-synthetic. The Handling Committee recommended a synthetic 

classification, and the full board concurred with that recommendation in its

vote at the full board meeting: Yes: 13; No: 1; Absent: 0.

This material was petitioned to the NOSB for use as a leavening agent in 

organic baked goods. The Handling Committee voted 5 no, 0 yes, and 2 

absent for the listing of this material to the National List, thereby 

recommending it not be listed. The full board likewise rejected listing at its 

April 2011 NOSB meeting. 

The manufacture of Calcium acid pyrophosphate (CAPP) involves the 

reaction of phosphoric acid produced from phosphate rock with Calcium 

oxide. Heavy metal contamination from mining operations is a concern, as is 

the environmental effect of the phosphoric acid component of the 

manufacture. The petition did not provide compelling evidence that the 

material is essential for organic production, even for its petitioned use as a 

leavening agent for organic baked products. Sodium acid pyrophosphate 

(SAPP) is already listed for use for this purpose, and although there is 
Updated June 17, 2010

mention of the fact that this material could be substituted for SAPP to reduce 

sodium content of organic baked items, there is no comparative discussion in 

the petition of what the actual sodium reduction would be, whether it would be 

significant enough to justify adding another synthetic material to the National 

List, or even if organic consumers desire lower sodium content in their baked 

goods. The TR states potential sodium reduction of up to 26%, but it is 

formula dependent. Calcium phosphates, also already listed materials, are 

also used in the leavening of bread and bakery products and do not contain 

sodium. There is no explanation as to the reasons for preference of CAPP 

over these materials, if one exists. 

After publishing of the Handling Committee recommendation for the full board 

meeting, the petitioner submitted public comment opposing the committee 

viewpoint, but no other public comments were received in favor of listing the 

material. Several public comments were received opposing listing, agreeing 

with the committee recommendation. 

NOSB Vote:

Moved: Steve DeMuri Second: Mac Stone

Yes: 5 No: 9 Abstain: 0 Absent: 0 Recusal: 0
Decision Sheets 

April 2010 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: April 2011 Substance: Calcium Acid Pyrophosphate 

Committee: Crops  Livestock  Handling X Petition is for the addition of Calcium Acid Pyrophosphate to the National List § 

205.605(b) “for use as a leavening agent" in baked goods. 

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

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

3. Compatibility & Consistency Yes X No  N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

Substance Fails Criteria Category: 1and 2. Comments: The manufacture of Calcium acid pyrophosphate (CAPP) involves the reaction of phosphoric acid 

produced from phosphate rock with Calcium oxide . Heavy metal contamination from mining operations is a concern, as is the environmental effect of the 

phosphoric acid component of the manufacture. The petition does not provide compelling evidence that the material is essential for organic production, even 

for its petitioned use as a leavening agent for organic baked products. Sodium acid pyrophosphate (SAPP) is already listed for use for this purpose, and 

although there is mention of the fact that this material could be substituted for SAPP to reduce sodium content of organic baked items, there is no comparative 

discussion in the petition of what the actual sodium reduction would be, whether it would be significant enough to justify adding another synthetic material to 

the National List, or even if organic consumers desire lower sodium content in their baked goods. The TR states potential sodium reduction of up to 26%, but it 

is formula dependent. Calcium phosphates, also already listed materials, are also used in the leavening of bread and bakery products and do not contain 

sodium. There is no explanation as to the reasons for preference of CAPP over these materials, if one exists. 

Proposed Annotation (if any): N/A

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:____________________ 

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

 To classify Calcium Acid Pyrophosphate as a synthetic

Classification of the material: Synthetic: X Non- synthetic_____________ 

Motion by: Steve DeMuri Seconded: Tracy Miedema Yes: 5 No: 0 Absent: 2 Abstain: 0 

Recommended Committee Action & Vote: To add Calcium Acid Pyrophosphate to section 205.605(b) of the National List

 

Motion by: Steve DeMuri Seconded: Tracy Miedema Yes: 0 No: 5 Absent: 2 Abstain: 0 

 

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

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

Describe why a prohibited substance:_______________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. 605(b) Describe why material was rejected: 

 Fails Categories 1 and 2 of the National List petitioned material evaluation criteria. See above 

4) Substance was recommended to be deferred because _________________________________________________________

 If follow-up needed, who will follow up: N/A

Crops Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic X Rejected3

X 

No restriction Commercially UnAvailable as Organic1

 Deferred4 

C. Approved by Committee Chair to transmit to NOSB: 

Steve DeMuri April 29, 2011 

Committee Chair Date
Decision Sheets 

April 2010 

EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST 

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

 

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; 

other)

1. Are there adverse effects on environment 

from manufacture, use, or disposal? 

[§205.600 b.2] 

X The TR, page 7, describes 

environmental concerns with the 

phosphoric acid used to produce the 

CAPP, and heavy metal contamination 

from phosphate rock mining, another 

input to the CAPP manufacturing 

process. 

2. Is there environmental contamination during 

manufacture, use, misuse, or disposal? 

[§6518 m.3] 

X Heavy metal contamination of 

groundwater and estuaries possible 

during manufacture if not mitigated. 

These metals can be taken up by plants 

and marine life leading to concentration 

of heavy metals in food products. TR 

page 7 

3. Is the substance harmful to the environment 

and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 X No evidence the substance itself is 

harmful. 

4. Does the substance contain List 1, 2, or 3 

inerts? [§6517 c (1 ) (B)(ii); 205.601(m)2] 

 X No evidence it contains these inerts. 

5. Is there potential for detrimental chemical 

interaction with other materials used? 

[§6518 m.1] 

 X None identified in the TR. 

6. Are there adverse biological and chemical 

interactions in agro-ecosystem? [§6518 m.5] 

 X The substance is added to food as a 

leavening agent, not to soil or crops. 

7. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518 m.5] 

X There can be an uptake of heavy metals 

from the phosphate rock component of 

the manufacturing process, but no 

evidence to suggest the material itself 

has detrimental physiological effects on 

soil organisms, crops, or livestock. 

8. Is there a toxic or other adverse action of the 

material or its breakdown products? 

[§6518 m.2] 

 X None mentioned in the TR. 

9. Is there undesirable persistence or 

concentration of the material or breakdown 

products in environment? [§6518 m.2] 

 X No evidence of this in the TR. 

10. Is there any harmful effect on human health? 

[§6517 c (1)(A) (i) ; 6517 c(2)(A)I; §6518 

m.4] 

X According to the MSDS and TR, the 

substance may cause skin, eye, and 

respiratory tract irritation. Can be 

harmful if ingested in large quantities. 

TR page 8. 
Decision Sheets 

April 2010 

11. Is there an adverse effect on human health as 

defined by applicable Federal regulations? 

[205.600 b.3] 

 X No evidence of such in the TR. 

12. Is the substance GRAS when used according 

to FDA’s good manufacturing practices? 

[§205.600 b.5] 

X The substance is isn’t listed as GRAS by 

the FDA, but was affirmed as GRAS by 

the SCOGS with no limitations other 

than Good Manufacturing Processes. TR 

page 5. 

13. Does the substance contain residues of heavy 

metals or other contaminants in excess of 

FDA tolerances? [§205.600 b.5] 

 X There is no evidence that the substance 

contains heavy metals in excess of FDA 

tolerances. TR page 7. 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

April 2010 

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

 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; 

other) 

1. Is the substance formulated or manufactured 

by a chemical process? [6502 (21)] 

X The typical manufacturing method 

described by the petitioner states that 

food grade phosphoric acid produced 

from phosphate rock is reacted with 

calcium oxide (lime) to precipitate 

calcium dihydrogen phosphate. The 

calcium dihydrogen phosphate is filtered 

and undergoes calcinations at 270°C to 

form CAPP. The material is then milled 

to a powder and packaged. TR page 4. 

2. Is the substance formulated or manufactured 

by a process that chemically changes a 

substance extracted from naturally occurring 

plant, animal, or mineral, sources? [6502 

(21)] 

X See above 

3. Is the substance created by naturally 

occurring biological processes? [6502 (21)] 

 X See # 1 above. 

4. Is there a natural source of the substance? 

[§205.600 b.1] 

 X Components of some of the 

manufacturing inputs are natural, but 

some are synthetic, rendering it a 

synthetic (not natural) substance. 

5. Is there an organic substitute? [§205.600 b.1] X According to the petition and the TR, 

page 5, there are no organic substitutes 

known. 

6. Is the substance essential for handling of 

organically produced agricultural products? 

[§205.600 b.6] 

 X May be useful as a reduced sodium 

leavening agent, but no compelling 

evidence is provided that it meets 

essentiality criteria, since other listed 

materials serve the same function. 

7. Is there a wholly natural substitute product? 

[§6517 c (1)(A)(ii)] 

 X There is no evidence a natural substitute 

product exists. TR page 5. 

8. Is the substance used in handling, not 

synthetic, but not organically produced? 

[§6517 c (1)(B)(iii)] 

 X Used in handling, but IS synthetic and 

not organically produced. 

9. Is there any alternative substances? [§6518 

m.6] 

X SAPP is currently listed and used for the 

same purpose, but petitioner states 

CAPP would be a low sodium option. 

Calcium phosphates are already listed 

and used for the same purpose as well. 

No compelling rationalization provided, 

other than the sodium claim, as to why 

SAPP or Calcium phosphates don’t 

suffice for the petitioned application. 

10. Is there another practice that would make the 

substance unnecessary? [§6518 m.6] 

X Unleavened organic bakery products 

could be produced, by acceptability by 

organic consumers is unknown. 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b)are N/A—not applicable. 
Decision Sheets 

April 2010 

 

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

 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; 

other) 

1. Is the substance compatible with

organic handling? [§205.600 b.2] 

X 

2. Is the substance consistent with organic 

farming and handling, and biodiversity? 

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

X X Consistent with Handling, but not 

applicable to farming and biodiversity, 

since it is not applied to soil or crops.. 

3. Is the substance compatible with a system of 

sustainable agriculture? [§6518 m.7] 

 X Petitioned for use in a Handling 

application. 

4. Is the nutritional quality of the food 

maintained with the substance? [§205.600 

b.3] 

X Nutritional quality is not negatively 

affected by it’s use, per the TR, page 6. It 

can have the benefit, however, of 

providing a low sodium leavening agent 

alternative for organic processors. 

5. Is the primary use as a preservative? 

[§205.600 b.4] 

 X Primary use would be as a leavening 

agent for organic baked goods, not 

preserving. TR page 6. 

6. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive values 

lost in processing (except when required by 

law, e.g., vitamin D in milk)? [205.600 b.4] 

 X This substance, for the purpose 

petitioned, would act as a leavening 

agent, not to recreate or improve quality 

attributes lost in processing. However, 

there is an indirect impact on the texture 

of baked goods as CAPP neutralizes 

baking soda and CO2 expands in the 

product during the baking process. TR 

page 6. The texture change is a result of 

processing, not a replacement function. 

 

7. Is the substance used in production, and does 

it contain an active synthetic ingredient in 

the following categories: 

 X Not petitioned to this committee for use 

in organic production, just handling. 

a. Copper and sulfur compounds; X See above 

b. Toxins derived from bacteria; X See above 

c. Pheromones, soaps, horticultural oils, fish 

emulsions, treated seed, vitamins and 

minerals? 

 X See above 

d. Livestock parasiticides and medicines? X See above 

e. Production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleaners? 

 X See above 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

April 2010 

Category 4. Is the commercial supply of an agricultural substance as 

organic, fragile or potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 

(d), 205.600 (c) 205.2, 205.105 (d), 205.600 (c)] 

 

Substance: Calcium Acid 

Pyrophosphate

Question Yes No N/A Comments on Information Provided 

(sufficient, plausible, reasonable, 

thorough, complete, unknown) 

1. Is the comparative description provided as 

to why the non-organic form of the 

material /substance is necessary for use in 

organic handling? 

 X This category pertains only to substances 

petitioned for addition to section 205.606. 

All questions in this category (4) not 

applicable. 

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate form to fulfill an 

essential function in a system of organic 

handling? 

 X 

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quality to fulfill an 

essential function in a system of organic 

handling? 

 X 

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quantity to fulfill an 

essential function in a system of organic 

handling? 

 X 

5. Does the industry information provided on 

material / substance non-availability as 

organic, include ( but not limited to) the 

following: 

 X 

a. Regions of production (including factors 

such as climate and number of regions); 

 X 

b. Number of suppliers and amount 

produced; 

 X 

c. Current and historical supplies related to 

weather events such as hurricanes, 

floods, and droughts that may 

temporarily halt production or destroy 

crops or supplies; 

 X 

d. Trade-related issues such as evidence of 

hoarding, war, trade barriers, or civil 

unrest that may temporarily restrict 

supplies; or 

 X 

e. Are there other issues which may present 

a challenge to a consistent supply? 

 X