Decision Sheets 

December 2006 

NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: October 2010 

_____________________ 

Substance: ___Formic Acid_______________________ _ 

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

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

2. Essential & Availability Criteria Yes X No  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 

B. Substance fails criteria? 

Criteria category: _________ 

 

Comments: 

 C. Proposed Annotation: __for use solely as a pesticide within honeybee hives.

___________________________________________________________ 

 

Basis for annotation: 

 

To meet criteria above: _X__ Criteria: _______________ 

 

Other regulatory criteria: ____ Citation:_______________ 

D. Final Board Action And Vote Regarding Synthetic / Non-synthetic: Motion that Formic Acid be considered a synthetic 

substance. 

Motion by: Kevin Engelbert Seconded: Tina Ellor__ Yes: 14____ No: 0_____ Absent: 2______ Abstain: 0____ 

 

E. Final Board Action & Vote (State Actual Motion): Motion to add Formic Acid, CAS # 164-18-6, to the National List § 205.603(b)_for 

use as a pesticide solely within honeybee hives. 

Motion: Kevin Engelbert Second:_Tina Ellor________ Yes: 14___ No: 0 _____ Abstain: 0____ Absent: 0 . 

 

Provide a summary narrative here or attach a more complete narrative, and attach the original committee recommendation 

that includes the evaluation criteria checklist: See Committee Recommendation below. 

1—substance voted to be added as “allowed” on National List on National List to § 205.603(b) with Annotation (if any): __ for use solely as a 

pesticide within honeybee hives.

 

2—substance to be added to “prohibited” paragraph of National List to § 205.______ Describe why a prohibited substance: __ ____ 

_____________________________________________________ ___________________________________ ____ 

 

3—substance was rejected by vote for amending National List to § 205. ______ Describe why material was rejected: _____ _ 

___________________________________________________ __ 

4-substance was recommended to be deferred § 205. ______ Describe why deferred; if any follow-up is needed. If follow-up needed, who conducts 

follow-up ________________________________ ____________________________________ 

 

Agricultural X Nonagricultural Crops 

Synthetic X Not synthetic Livestock X 

Allowed1X Prohibited2

Handling 

No restriction Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP 

 Daniel G. Giacomini . October 28, 2010 

. 

Chair Date

F. NOP Action: Include in FR to amend National List: 

 Return to NOSB Reason: ____________________________________________________________________ 

 

_____________________________________ _________________________ 

 Date 
Decision Sheets 

December 2006 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: ___Fall 2010__________________ Substance: ___Formic Acid_________________________

Committee: Crops  Livestock X Handling  Petition is for:__adding Fomic Acid, CAS # 164-18-6, on the National 

List § 205.603(b) for use as a pesticide solely within honeybee hives. 

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

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

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

6. Compatibility & Consistency Yes X No  N/A 

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

B. Substance Fails Criteria Category: _________ Comments: _With the annotation, Formic Acid does not fail any 

category,based on information contained in the petition, which was the only source of information provided. Even though the 

Livestock Committee conducted additional research, the Committee has requested a Technical Review of Formic Acid, and will 

reevaluate the recommendation when the TR becomes available. Given the current situation in apiculture with regard to mites, the 

recommendation of the 2001 NOSB, the position of the Apiculture Working Group, and the fact that with the annotation Formic Acid 

meets all the Evaluation Criteria, the Livestock Committee firmly believes that Formic Acid warrants being added to the National List 

§ 205.603 

C. Proposed Annotation (if any): __for use as a pesticide solely within honeybee hives________________________ 

________________________________________________________________________________________________________ 

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

D. Committee Recommendation Regarding Synthetic / Non-synthetic: Motion that Formic Acid be considered a synthetic 

substance. 

Motion by: Kevin Engelbert Seconded: Tina Ellorl__ Yes: 6____ No: 0_____ Absent: 2______ Abstain: 0____ 

 

E. Recommended Committee Action & Vote (State Actual Motion): __Motion to add Formic Acid, CAS # 164-18-6, to the 

National List § 205.603_for use as a pesticide solely within honeybee hives. 

________________________________________________________________________________________________________ 

Motion by: Daniel G. Giacomini Seconded: Jennifer Hall__ Yes: 5____ No: 0_____ Absent: 3______ Abstain: 0____ 

 

 

1) Substance voted to be added as “allowed” on National List to § 205.603 with Annotation (if any) for use solely as a 

pesticide within honeybee hives.__________ 

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

________________________________________________________________________________________________________ 

Describe why a prohibited substance:__________________________________________________________________________

________________________________________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. _____ Describe why material was rejected:___________ 

Crops Agricultural Allowed1

 X 

Livestock X Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3 

No restriction Commercially UnAvailable as Organic1

 Deferred4 
Decision Sheets 

December 2006 

________________________________________________________________________________________________________ 

4) Substance was recommended to be deferred because ___________________________________________________________ 

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________ 

F. Approved by Committee Chair to transmit to NOSB: 

_Kevin K. Engelbert__________________ __August 3, 2010________ 

 Committee Chair Date
Decision Sheets 

December 2006 

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - __Formic Acid____________

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Are there adverse effects on 

environment from manufacture, 

use, or disposal? 

[§205.600 b.2] 

 

X 

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3] 

 

X 

 No references found stating that the production and 

transporting of formic acid cause environmental 

contamination. Petition pg. 13 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 

X 

 Because formic acid is used only in the hive, no environmental 

residues are expected to occur outside the hive. Petition pg. 

11 

No references found stating that the use of formic acid in 

honey production poses an environmental risk. Petition pg. 13 

4. Does the substance contain List 

1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2] 

 

X 

 

5. Is there potential for detrimental 

chemical interaction with other 

materials used? 

[§6518 m.1] 

X 

 Formic acid is a strong acid, and as such the potential for 

chemical interaction does exist, but on the Material Safety 

Data Sheet (MSDS) the substance is rated 0 (stable) for 

Reactivity Petition pg. 48 & 51 

6. Are there adverse biological and 

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

 

X 

 See 3 above 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

 

X 

 See 3 above with regard to soil interactions. Formic acid is 

used in conventional livestock agriculture as a preservative 

and antibacterial agent in livestock feed, and sometimes added 

to poultry feed to kill salmonella bacteria. Petition pg. 4 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2] 

 

X 

 No known ecotoxicity data, but the breakdown products are 

less toxic than formic acid itself. Petition pg. 52 & 53 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X 

 Short term degradation products are not likely, but long term 

degradation products may arise. Petition pg. 53 Although, no 

references found stating that the use of formic acid poses an 

environmental risk. Petition pg. 13 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

X 

 If mishandled there are potential acute and chronic health 

effects involving skin and mucous membrane contact, along 

with inhalation and ingestion The substance may also be 

toxic to organs with repeated or prolonged exposure. Petition 

pg. 48 If handled properly and used according to label 

instructions, no harm to human health can be expected, and 

formic acid is a natural constituent of many foods. Petition 

pg. 15 & 11 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

 

X 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5] 

 

X 

13. Does the substance contain 
Decision Sheets 

December 2006 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—

not applicable. 
Decision Sheets 

December 2006 

Category 2. Is the Substance Essential for Organic Production? Substance - __Formic Acid____________

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 

 

Petition pgs. 6 & 7 

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 

 

Petition pgs. 6 & 7 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

X 

 

Petition pgs. 6 & 7 

4. Is there a natural source of the 

substance? [§205.600 b.1] 

 X 

5. Is there an organic substitute? 

[§205.600 b.1] 

 X 

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 

b.6] 

 

 X 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

 

X 

 The use of powdered sugar or Sucrose Octanoate Ester results 

in a short term increase in mortality rates of mites outside the 

hive, but no impact inside the hive. Petition pg. 16 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

 

X 

 

9. Is there any alternative 

substances? [§6518 m.6] 

 X See 7. above 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

 

X 

 Drone comb removal helps control mites by removing a large 

portion of the mites, but does not remove them all, especially 

if the hive produces a small number of drones.. Petition pg. 29 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 

December 2006 

Category 3. Is the substance compatible with organic production practices? Substance - __Formic Acid____

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance compatible 

with organic handling? [§205.600 

b.2] 

 

X 

2. Is the substance consistent with 

organic farming and handling? 

[§6517 c (1)(A)(iii); 6517 c 

(2)(A)(ii)] 

X 

 Formic acid is produced by bees and other insects as a venom, 

but in tropical regions the mites reproduce year round and 

consequently the mite populations can increase too rapidly for 

the honey bees to contend with. Petition pgs. 4 & 24 Formic 

Acid allowed in Canada & Europe. Canadian General 

Standards Board, Organic Production Systems Permitted 

Substances List, pg. 16 & EU-Regulation2092/91, 1804/1999 

Annex C: Beekeeping and Beekeeping Products; Paragraph 

6.3(e) Petition pgs. 9 & 10 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

X 

 Honey bees produce minute levels of formic acid, which is 

found naturally in honey , and no increase in the levels of 

formic acid in honey are expected. Petition pgs. 10 & 17 

Formic Acid allowed in Canada & Europe. Canadian General 

Standards Board, Organic Production Systems Permitted 

Substances List, pg. 16 & EU-Regulation2092/91, 1804/1999 

Annex C: Beekeeping and Beekeeping Products; Paragraph 

6.3(e) Petition pgs. 9 & 10 

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3] 

 

X 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 

X 

6. Is the primary use to recreate or 

improve flavors, colors, textures, 

or nutritive values lost in 

processing (except when required 

by law, e.g., vitamin D in milk)? 

[205.600 b.4] 

 

X 

 

7. Is the substance used in 

production, and does it contain an 

active synthetic ingredient in the 

following categories: 

a. copper and sulfur compounds; 

 

X 

 

b. toxins derived from bacteria; X 

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals? 

 

X 

 

d. livestock parasiticides and 

medicines? 

 

X 

 

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment cleaners? 

 

X 

 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—

not applicable. 
Decision Sheets 

December 2006 

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 - ___Formic Acid_______________________ 

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 

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 nonavailability as organic, include ( but 

not limited to) the following: 

a. Regions of production (including 

factors such as climate and number of 

regions); 

 

X 

b. Number of suppliers and amount 

produced; 

 

X 

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts that 

may temporarily halt production or 

destroy crops or supplies; 

 

X 
Decision Sheets 

December 2006 

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