National Organic Standards Board

Livestock Subcommittee

Petitioned Material Checklist

Acidified Sodium Chlorite (ASC) Proposal

August 20, 2013

Summary of Proposed Action:

Evaluation Criteria (see attached checklist for criteria in each category)

 Criteria Satisfied? 

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

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

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

Substance Fails Criteria Category: 2 

Comments: 

Acidified Sodium Chlorite (ASC) was petitioned for use as a pre and post teat dip treatment in organic livestock 

production. ASC is currently allowed on the national list as a disinfectant for direct food contact under 

205.605(b). After carefully reviewing the petition, along with the Technical Evaluation Report prepared for the 

committee in 2013, we have found that this material generally satisfies the criteria related to impact on humans 

and the environment, along with general compatibility and consistency with organic principles. However, the 

TR notes that a number of functional alternative substances are available, and the committee’s research and 

outreach to producers confirms that many substances are already used as mastitis-preventing teat dips. 

Accordingly, the essentiality criteria are not met, and the committee does not recommend the addition of ASC 

to the national list as a teat dip. 

Subcommittee Action & Vote

Classification Motion: Motion to classify Acidified Sodium Chlorite (CAS # 7758-19-2 (sodium chlorite) 

and CAS # 14998-27-7 (chlorous acid)) as synthetic. 

Motion by: Joe Dickson

Seconded by: Colehour Bondera

Yes: 8 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Listing Motion: Motion to list Acidified Sodium Chlorite(CAS #s 13898-47-0 (Chlorous Acid), 7758-19-2 

(Sodium Chlorite)) to section 205.603(a) and 205.603(b) of the National List annotated as follows: Acidified 

Sodium Chlorite, Allowed for use on organic livestock as a pre and post teat dip treatment, acidified with 

lactic acid or other GRAS acid. 

Motion by: Joe Dickson

Seconded by: Colehour Bondera

Yes: 0 No: 8 Abstain: 0 Absent: 1 Recuse: 0

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

 Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB August 20, 2013 

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NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 1. Adverse impacts on humans or the environment? Acidified Sodium Chlorite

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse,? 

[§6518(m)(3)]

x Risk is minimal. TR page 9, lines 359-

369. 

2. Is there a probability of environmental 

contamination during manufacture or 

disposal? [§6518(m)(3)]

x TR page 9, lines 359-390.

3. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

x

4. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

x As petitioned, substance does not 

interact with the agroecosystem. TR page 

10 lines 410-411.

5. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

x Breakdown products are citric acid, salt 

and water (2009 handling 

recommendation). 

6. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

x When used as petitioned, SCA and its 

components exhibit minimal likelihood of 

persistence in the environment. TR page 

7 lines 296-298. 

7. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

x “When used as petitioned, acidified 

sodium chlorite and its component 

chemicals exhibit minimal likelihood of 

persistence or accumulation in the 

environment.” TR page 10, lines 436-428. 

The material is both GRAS and on the 

USDA National List for handling. 

8. Are there adverse biological and 

chemical interactions in the agroecosystem, including biodiversity? 

[§6518(m)(5)]

x As petitioned, substance does not 

interact with the agroecosystem. TR page 

10 lines 410-411.

9. Are there detrimental physiological 

effects on soil organisms, crop- s, or 

livestock? [§6518(m)(5)]

x As petitioned, substance does not 

interact with the agroecosystem. TR page 

10 lines 410-411.

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NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 2. Is the Substance Essential for Organic Production: Acidified Sodium Chlorite

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] x TR page 7, lines 280-293.

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

x TR page 6, lines 222-279

3. 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 The substance is synthetically produced. 

TR page 7, lines 280-293.

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

x The substance is synthetically produced. 

TR page 7, lines 280-293.

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

x TR page 7. 

6. Is there an organic substitute? 

[§205.600(b)(1)]

x There are a limited number of organic or 

natural substances that are appropriate 

substitutes. Nisin, a natural material that 

may be a substitute, is not authorized for 

use as a teat dip due to earlier rejection 

by NOSB as an antibiotic . A number of 

essential oils and organic acids may also 

be used as teat dips. TR page 11, lines 

542-547

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

x x See above. 

8. Are there any alternative substances? 

[§6518(m)(6)]

x The TR also suggests that a number of 

alternative substances, including iodine, 

alcohols, chlorine materials, hydrogen 

peroxide, chlorhexadine and certain 

essential oils may function as 

alternatives.

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

x Teat dips are critical in commercial dairy 

production to prevent mastitis. TR page 

12.

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Livestock

Category 3. Is the substance compatible with organic production practices? Acidified Sodium Chlorite

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

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

x TR, petition. Substance is already 

allowed for use in handling in direct food 

contact.

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

x

3. If used in livestock feed or pet food, Is 

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

x

4. If used in livestock feed or pet food, Is 

the primary use as a preservative? 

[§205.600(b)(4)]

x

5. If used in livestock feed or pet food, Is 

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

x

6. Is the substance used in production, and 

does it contain an active synthetic 

ingredient in the following categories: 

[§6517(c)(1)(B)(i); 

copper and sulfur compounds

x TR page 6, lines 210-221

toxins derived from bacteria x TR page 6, lines 210-221

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

x TR page 6, lines 210-221

livestock parasiticides and medicines x TR page 6, lines 210-221

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

x TR page 6, lines 210-221

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