FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _November 17, 2005________

Subject: __Sunset review of National List substances used in livestock production_

Chair: ____Jim Riddle______________________________________

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X____ 

Guidance Statement: ________ 

Other: ___X_____ 

Statement of the Recommendation (including Recount of Vote): The NOSB voted to renew 20 

substances on section 205.603 of the National List. The NOSB voted to defer action on 7 substances on 

205.603. The NOSB voted to renew 1 substance on 205.604, with none deferred. Votes were taken on 

each subsection. A complete list of the recommendations to renew and defer appears below, along with 

the vote totals for each subsection. 

Rationale Supporting Recommendation (including consistency with OFPA and NOP): Statements 

from the Livestock Committee explaining the rationale supported through NOSB action precede each of 

the recommendations presented below. A compilation of all deferred substances, complete with specific 

questions identified by the NOSB, are submitted to the NOP under separate cover. 

Response by the NOP:

Updated 2/25/05 
I. List: 205.603 Synthetic substances allowed for use in organic livestock production 

II. Category Use 

(a) As disinfectants, sanitizer, and medical treatments as applicable 

III.Committee Summary: Some commentors were proponents of keeping all materials on list 

205.603. Of those commentors who mentioned specific substances within this use category, 

the continued listings of alcohols – ethanol and isopropanol, aspirin, biologics – vaccines, 

chlorohexidine, chlorine materials – calcium hypochlorite, chlorine dioxide and sodium 

hypochlorite, electrolytes – without antibiotics, glucose, glycerine, hydrogen peroxide, 

iodine, magnesium sulfate, oxytocin and phosphoric acid were specifically mentioned. 

Several commentors stated that chlorhexidine, chlorine materials (calcium hypochlorite, 

chlorine dioxide, sodium hypochlorite), oxytocin, ivermectin, and, hydrogen peroxide should 

be removed from the list. Several commentors also requested clarification of the annotations 

for iodine and phosphoric acid. The purpose of the 5–year sunset review process is 

specifically for the renewal or removal of materials from the National List. Clarification of 

or changes in the annotation of a material will need to be submitted as a new petition and 

handled through the regular petition process to add or remove substances from the National 

List. The Committee disagrees with the commentors who recommend the removal of 

chlorhexidine from the list. The specific reasons given for removal (greater toxicity than 

other teat dip material on the national list) does not apply to the first annotation (allowed for 

surgical procedures conducted by a veterinarian). To address the concerns of the commentor, 

a change to the annotation would be required rather than removal from the National List. 

The Livestock Committee agrees with the commentors who supported the renewal of 

alcohols (ethanol and isopropanol), aspirin, biologics – vaccines, chlorohexidine, chlorine 

materials (calcium hypochlorite, chlorine dioxide and sodium hypochlorite,) electrolytes – 

without antibiotics, glucose, glycerine, hydrogen peroxide, iodine, magnesium sulfate, and 

phosphoric acid because their use does not negatively impact humans or the environment, is 

considered essential for organic production and is compatible with organic production 

practices. The Committee neither agrees nor disagrees with the commentors concerning 

oxytocin or ivermectin. These two materials are being deferred until additional information 

is obtained. One commentor stated that all synthetic substances should be prohibited for use 

in organic production; however, no evidence or rationale on how any of those substances 

violated OFPA was provided. 

IV. Committee Recommendation(s): 

Recommendations Based upon Comments Received – 205.603(a)

The Livestock Committee recommends the renewal of the following substances in this use 

category 

 

(1) Alcohol 

(i) Ethanol—disinfectant and sanitizer only, prohibited as a feed additive. 

(ii) Isopropanol—disinfectant only 

(2) Aspirin—approved for health care use to reduce inflammation. 

(3) Biologics—Vaccines. 
(4) Chlorhexidine—Allowed for surgical procedures conducted by a veterinarian. 

Allowed for use as a teat dip when alternative germicidal agents and/or physical 

barriers have lost their effectiveness. 

(6) Electrolytes—without antibiotics. 

(7) Glucose. 

(8) Glycerine—Allowed as a livestock teat dip, must be produced through the hydrolysis 

of fats or oils. 

(9) Hydrogen peroxide. 

(10) Iodine. 

(11) Magnesium sulfate. 

(14) Phosphoric acid—allowed as an equipment cleaner, provided, that, no direct contact 

with organically managed livestock or land occurs. 

The Livestock Committee recommends deferring the vote on the following materials until further 

technical information is obtained. The materials to be deferred are: 

 

 

(5) Chlorine materials—disinfecting and sanitizing facilities and equipment. Residual 

chlorine levels in the water shall not exceed the maximum residual disinfectant limit 

under the Safe Drinking Water Act. 

 (i) Calcium hypochlorite. 

(ii) Calcium dioxide. 

(iii) Sodium hypochlorite. 

(12) Oxytocin—use in postparturition therapeutic applications. 

(13) Parasiticides. Ivermectin—prohibited in slaughter stock, allowed in emergency 

treatment for dairy and breeder stock when organic system plan-approved preventive 

management does not prevent infestation. Milk or milk products from a treated animal 

cannot be labeled as provided for in subpart D of this part for 90 days following 

treatment. In breeder stock, treatment cannot occur during the last third of gestation if 

the progeny will be sold as organic and must not be used during the lactation period of 

breeding stock. 

The Livestock Committee recommends not renewing the following substances: 

None in this category

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.603(a) 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no 
I. List: 205.603 Synthetic substances allowed for use in organic livestock production 

II. Category Use 

(b) As topical treatment, external parasiticide or local anesthetic as applicable. 

IV.III. Committee Summary: Some commentors were proponents of keeping all materials on 

list 205.603. Many commentors supported the continued listing of copper sulfate, iodine, 

lidocaine, hydrated lime, mineral oil, and procaine. One commentor objected to the 

continued listing of hydrated lime because it is too harsh of a chemical to allow for direct 

contact with animals as a pest control agent, and it is hazardous to the humans who handle it. 

Some commentors requested clarification of the types of iodine that may be used in organic 

production. The purpose of the sunset review process is specifically to determine renewal or 

removal of materials from the National List. Clarification of or changes in the annotation of 

a material will need to be submitted as a new petition and handled through the regular 

petition process to add or remove substances from the National List. The Livestock 

Committee agrees with the commentors recommending the renewal of copper sulfate, iodine, 

lidocaine, mineral oil and procaine because their use does not negatively impact humans or 

the environment, is considered essential for organic production and is compatible with 

organic production practices. The Committee neither agrees nor disagrees with the 

commentors recommending the removal of hydrated lime from the National List. This 

material is being deferred until additional information is obtained. One commentor stated 

that all synthetic substances should be prohibited for use in organic production; however, no 

evidence or rationale on how any of those substances violated OFPA was provided. 

IV. Committee Recommendation(s): 

Recommendations Made that are Based upon Comments Received – 205.603(b)

The Livestock Committee recommends the renewal of the following substances in this use 

category 

(1) Copper sulfate. 

(2) Iodine. 

(3) Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to 

dairy animals. 

(5) Mineral oil—for topical use and as a lubricant. 

(6) Procaine—as a local anesthetic, use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to 

dairy animals. 

The Livestock Committee recommends deferring the vote on the following substances until 

further technical information is obtained: 

(4) Lime, hydrated—as external pest control, not permitted to cauterize physical 

alterations or deodorize animal wastes. 

The Livestock Committee recommends not renewing the following substances: 

None in this category
Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.603(b) 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no 
I. List: 205.603 Synthetic substances allowed for use in organic livestock production 

II. Category Use 

(c) As feed supplements 

V. III. Committee Summary: Some commentors were proponents of keeping all materials on 

list 205.603. Of those commentors who mentioned specific substances within this use 

category, the continued listing of milk replacers was mentioned. Many commentors 

supported the continued use of milk replacers. One commentor asked why non-organic milk 

replacer needs to be on the National List as organic milk replacers are available. The 

Livestock Committee neither agrees nor disagrees with the commentors concerning milk 

replacers. This material is being deferred until additional information is obtained. One 

commentor stated that all synthetic substances should be prohibited for use in organic 

production; however, no evidence or rationale on how any of those substances violated 

OFPA was provided. 

IV. Committee Recommendation(s): 

Recommendations Made that are Based upon Comments Received – 205.603(c)

The Livestock Committee recommends the renewal of the following substances in this use 

category 

 None in this category 

The Livestock Committee recommends deferring the vote on the following substances until 

further technical information is obtained: 

Milk replacers—without antibiotics, as emergency use only, no nonmilk products or 

products from BST treated animals. 

The Livestock Committee recommends not renewing the following substances: 

None in this category

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.603(c) 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no 
I. List: 205.603 Synthetic substances allowed for use in organic livestock production 

II. Category Use 

(d) As feed additives. 

VI.III. Committee Summary: Some commentors were proponents of keeping all materials on 

list 205.603(d). Of those commentors who mentioned specific substances within this use 

category, the continued listing of trace minerals and vitamins were mentioned. None of the 

commentors specifically stated that trace minerals and vitamins use in organic production 

should be discontinued. The Livestock Committee agrees with the commentors that use of 

trace minerals and vitamins should be continued because their use does not negatively impact 

humans or the environment, is considered essential for organic production and is compatible 

with organic production practices. One commentor stated that all synthetic substances 

should be prohibited for use in organic production; however, no evidence or rationale on how 

any of those substances violated OFPA was provided. 

IV. Committee Recommendation(s): 

Recommendations Made that are Based upon Comments Received – 205.603(d)

The Livestock Committee recommends the renewal of the following substances in this use 

category 

(1) Trace minerals, used for enrichment or fortification when FDA approved. 

(2) Vitamins, used for enrichment or fortification when FDA approved. 

The Livestock Committee recommends deferring the vote on the following substances until 

further technical information is obtained: 

 None in this category. 

The Livestock Committee recommends not renewing the following substances: 

None in this category

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.603(d) 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no 

 
I. List: 205.603 Synthetic substances allowed for use in organic livestock production 

II. Category Use 

(e) As synthetic inert ingredients as classified by the Environmental Protection Agency 

(EPA), for use with nonsynthetic substances or synthetic substances listed in this section 

and used as an active pesticide ingredient in accordance with any limitations on the use of 

such substances. 

VII. III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.603(e). Of those commentors who mentioned specific substances within this use 

category, the continued listing of EPA List 4 inerts was mentioned. None of the commentors 

specifically stated that use of EPA List 4 inerts in organic production should be discontinued. 

The Livestock Committee agrees with the commentors recommending the renewal of EPA 

List 4 inerts because their use does not negatively impact humans or the environment, is 

considered essential for organic production and is compatible with organic production 

practices. One commentor stated that all synthetic substances should be prohibited for use in 

organic production; however, no evidence or rationale on how any of those substances 

violated OFPA was provided. 

IV. Committee Recommendation(s): 

Recommendations Made that are Based upon Comments Received – 205.603(e)

The Livestock Committee recommends the renewal of the following substances in this use 

category 

(1) EPA List 4—Inerts of Minimal Concern. 

The Livestock Committee recommends deferring the vote on the following substances until 

further technical information is obtained: 

 None in this category. 

The Livestock Committee recommends not renewing the following substances: 

None in this category

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.603(e) 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no
I. List: 205.604 Nonsynthetic substances prohibited for use in organic livestock production 

II. Category Use 

 (a) Strychnine 

VIII. III. Committee Summary: Some commentors specifically mentioned that strychnine 

should remain as a prohibited substance on the National List. The Livestock Committee 

agrees with the commentors that strychnine should remain as a prohibited substance on the 

National List because its use negatively impacts humans and the environment, is not 

considered essential for organic production and is not compatible with organic production 

practices. 

IV. Committee Recommendation(s): 

Recommendations Made that are Based upon Comments Received – 205.604

The Livestock Committee recommends the renewal of the following substances in this use 

category 

(a) Strychnine. 

The Livestock Committee recommends deferring the vote on the following substances until 

further technical information is obtained: 

 None in this category. 

The Livestock Committee recommends not renewing the following substances: 

None in this category

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

Recommendations Made that are Not Based upon Comments Received – 205.604 

None in this category 

Moved: Nancy Ostiguy Second: Hue Kerriman 

Committee vote: 5-yes; 0 no; 0 abstain 

NOSB vote: 14 yes, 0 no