This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 

National Organic Standards Board

Handling Subcommittee

Petitioned Material Proposal

Ammonium Hydroxide

February 19, 2013

*Revised February 18, 2014 - request for further public comment

Summary of Proposed Action:

Ammonium hydroxide is petitioned to be added to the National List at 205.605 as a boiler water 

additive. The Handling subcommittee proposes not to add Ammonium hydroxide to the National 

List. 

Ammonium hydroxide is a powerful alkali petitioned for use as a boiler additive because it 

neutralizes carbonic acid in condensate to prevent corrosion, reducing pH to 8.5 or 9.0. The 

level of ammonium hydroxide required in steam would depend on the level of carbon dioxide in 

the steam. Ammonium hydroxide is produced by the addition of water to Ammonia. Ammonia is 

produced on a large scale worldwide and one of its largest uses by production volume is as an 

ingredient in conventional fertilizer (prohibited in organic agriculture).

Ammonium hydroxide is a severe irritant which must be handled properly because exposure by 

humans and other mammals during production or use presents a serious toxicological concern. 

It is toxic by all routes, inhalation, dermal and ingestion and the toxicity is well documented. It is 

an air and water pollutant and contributes as a greenhouse gas. It is toxic to fish and other 

aquatic species. Spillage could cause considerable environmental damage.

There are a number of alternative practices which can be used instead of boiler additives. 

These include replacement of steam lines with stainless steel piping, water treatment, physical 

or chemical deaeration, interruption of boiler water treatment prior to organic processing runs, 

bleed runs, dismantling and cleaning systems prior to organic food handling, steam to steam 

heat exchangers, a separate secondary boiler to generate steam for direct food contact 

applications.

The petition requests addition of ammonium hydroxide as a “boiler additive” to neutralize carbon 

dioxide in order to prevent acid attack in steam condensate lines. Where steam is used in or on 

food it is termed “culinary steam” and used in food processing for sanitation or sterilization of 

food contact surfaces, including packaging sterilization. 

REQUEST FOR FURTHER PUBLIC COMMENT

The National List currently includes three volatile synthetic amines as boiler additives, namely 

Cyclohexylamine, Diethylaminoethanol , and Octadecyclamine, listed at 205.605(b) for use only

as boiler additives in packaging sterilization. These three boiler additives will be discussed in 

fall, 2014, as part of Sunset Review (for 2016 materials). Because of Sunset Review for the 

three boiler additives listed above, the NOSB seeks further public comment on essentiality of 

ammonium hydroxide as a boiler additive, including scope of use as culinary steam. 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 

Evaluation Criteria (Applicability noted for each category; Documentation attached)

Criteria Satisfied?

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 ☐ Yes No X N/A 

as Organic (only for § 205.606)

Substance Fails Criteria Category: [ 3] Comments:

Ammonium hydroxide has the potential to cause significant toxic damage to humans, mammals, 

aquatic systems and greenhouse gasses and is not essential or compatible with organic 

agriculture and handling.

Proposed Annotation (if any): None proposed

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

NA 

Recommended Committee Action & Vote

Classification Motion:

Motion to classify ammonium hydroxide (CAS # 1336-21-6) as petitioned as synthetic 

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 6 No: 0 Absent: 2 Abstain: 0 Recuse: 0

Listing Motion: 

Motion to list ammonium hydroxide (CAS # 1336-21-6) at § 205.605b 

Motion by: Jean Richardson

Seconded by: Colehour Bondera

Yes: 0 No: 6 Absent: 2 Abstain: 0 Recuse: 0

Approved by John Foster, Subcommittee Chair, to transmit to NOSB February 19, 2013

NOSB Evaluation Criteria for Substances Added To the National List

Category1. Adverse impacts on humans or the environment? Ammonium hydroxide

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

petition; regulatory agency; other)

1. Are there adverse effects on the 

environment, or is there a probability of 

environmental contamination during use

or misuse of the substance?

[§205.600(b)(2), [§6518(m)(3)]

X Toxic to environment if spilled or 

volatized to atmosphere (TAP 2001 and 

petition pages 8, 9, and 10)

2. Are there adverse effects on the 

environment or is there a probability of 

environmental contamination during 

manufacture or disposal of the 

substance? [§6518(m)(3)]

X Worker injury through breathing, 

ingestion or dermal contact and terrestrial 

damage with spills during manufacture. 

(Petition pages 8, 9, 10, and TAP 2001).
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X Toxic damage will occur through spills in 

terrestrial or aquatic systems, and 

ammonia contributes to greenhouse

gases (Petition pages 8-10) Fish are 

particularly at risk for toxic effects.

4. Does the substance contain inerts

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

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

X

5. Is there undesirable persistence or 

concentration of the material or 

breakdown products in the environment?

[§6518(m)(2)]

X Yes if spilled, or released into air the gas 

contributes to Greenhouse gases.

6. Are there any harmful effects on human 

health from the main substance or the 

ancillary substances that may be added 

to it? [§6517(c))(1)(A)(i); 6517 

(c)(2)(A)(i); §6518(m)(4), 205.600(b)(3)]

X Yes toxic if inhaled, ingested or dermal 

contact

7. Is the substance, and any ancillary 

substances, GRAS when used according 

to FDA’s good manufacturing practices? 

[§205.600(b)(5)]

X

8. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600

(b)(5)]

X

Category 2. Is the Substance Essential for Organic Production? Ammonium hydroxide

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

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X Ammonium hydroxide is manufactured 

from natural gas which is used to convert 

atmospheric nitrogen to ammonia and 

then water is added to produce the 

hydroxide form (petition page 4 and TAP 

2001).

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

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is the substance essential for handling of 

organically produced agricultural 

products? [§205.600(b)(6)]

X Processors can utilize a number of alternative 

practices, such as stainless steel pipelines, 

physical and chemical deaeration, interrupt 

boiler water treatment prior to organic 

processing etc. These alternative practices 

cost time and money. (petition page 11) 

although economic considerations are not 

one of the criteria for suitability of materials 

used in organic production systems (TAP 

2001, page 9)

8. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X

9. Are there any alternative substances? 

[§6518(m)(6)]

X There are 3 boiler additives on the NL

10. Is there another practice (in farming or 

handling) that would make the substance 

unnecessary? [§6518(m)(6)]

X There are a number of alternative practices 

which can be used (Petition page11) These 

include pre-treating water, replacing steam 

pipelines with stainless steel etc.

11. Have the ancillary substances associated 

with the primary substance been 

reviewed? Describe, along with any 

proposed limitations. 

X

Category 3. Is the substance compatible with organic handling practices? Ammonium

hydroxide

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

petition; regulatory agency; other)

1. Is the substance consistent with organic 

handling? 

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

X As a general rule ammonia products are 

not considered compatible with organic 

production or handling (TAP 2001, page 

7, page 9

2. Is the manner of the substance’s use, 

manufacture, and disposal compatible 

with organic handling? [§205.600(b)(2)]

X See 1 above

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X See 1 above

4. Are the ancillary substances reviewed 

compatible with organic handling [?

X

5. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X

6. Is the primary use as a preservative? 

[§205.600(b)(4)]

X

7. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive 

values lost in processing (except when 

required by law)? [§205.600(b)(4)]

X
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and then may be 

voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised Jun 2013 

Category 4. Is the commercial supply of an organic agricultural substance fragile or potentially 

unavailable? [§6610, 6518, 6519, §205.2, § 205.105(d), §205.600(c)] Ammonium hydroxide

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

petition; regulatory agency; other)

1. Is the comparative description as to why 

the non-organic form of the material 

/substance is necessary for use in 

organic handling provided? 

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 about 

unavailability include (but is 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

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X

e. Other issues which may present a 

challenge to a consistent supply?

X