National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Chlorine Materials in Aquatic Livestock Production

August 20, 2013

Summary of Proposed Action:

Chlorine Materials are petitioned for use in aquatic livestock production, to be added to 205.611 - Synthetic 

substances allowed for use in organic aquatic animal production as follows:

(x) Chlorine materials—disinfecting and sanitizing food contact surfaces, Except, That, residual chlorine 

levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking 

Water Act (Calcium hypochlorite; Chlorine dioxide; and Sodium hypochlorite)

(i) Calcium hypochlorite.

(ii) Chlorine dioxide

(iii) Sodium hypochlorite

Chlorine materials are widely used for their disinfectant properties, and are currently approved for such uses in 

crop, livestock and processed organic product production. Annotations for each listing limit the use of chlorine 

materials to disinfection and sanitation, and require that residual chlorine levels be consistent with Safe 

Drinking Water Act levels. The Livestock Subcommittee has received a petition for the use of Chlorine 

Materials in aquatic livestock production. These materials are used in aquatic animal production for the 

disinfecting hard surfaces and culture water in nurseries, growout operations with tanks, harvest and slaughter 

equipment, and in processing facilities. Given that the materials’ use in aquaculture applications is identical to 

existing uses in other production categories, the committee has not requested a new Technical Evaluation 

Report, but it is instead relying on recent TR’s developed for Handling and Crops uses of this group of 

materials.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? 

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

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

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

as Organic (only for § 205.606)

Proposed Annotation (if any): see listing motion below

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

Notes: This annotation is consistent with other listings of Chlorine on the NL, and ensures that any 

environmental impact is effectively mitigated. 

Recommended Subcommittee Action & Vote, including classification recommendation (state actual motion):

Classification Motion: Chlorine Materials (Calcium hypochlorite, chlorine dioxide, sodium hypochlorite) 

are synthetic.

Motion by: Joe Dickson

Seconded by: Jean Richardson 

Yes: 9 No: 0 Absent: 0 Abstain: 0 Recuse: 0

Listing Motion: Motion to add chlorine materials (Calcium hypochlorite, chlorine dioxide, sodium 

hypochlorite) to §205.611 with the following annotation: Chlorine materials - Disinfecting and 

sanitizing facilities and equipment. Residual chlorine levels in the water in direct animal contact (for 

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example, culture water) shall not exceed the maximum residual disinfectant limit under the Safe Drinking 

Water Act.

Motion by: Joe Dickson

Seconded by: Tracy Favre

Yes: 5 No: 1 Abstain: 1 Absent: 2 Recuse: 0 

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

NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 1. Adverse impacts on humans or the environment? Substance: Chlorine Materials

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 2006 Crops TR lines 212-266. The TR 

identities several areas of potential 

environmental impact, but notes that 

existing EPA regulations and the 

annotation restricting effluent to the levels 

of the Safe Drinking Water Act are 

sufficient to mitigate any environmental 

impact. The petitioner and a number of 

producers have confirmed that chlorine 

materials are not used in direct contact 

with the environment (e.g. ponds and net 

pens) and the restrictive annotation would 

prohibit such uses regardless. Should 

any doubt persist about this issue, we 

could consider including a targeted 

question in the recommendation to elicit 

technical responses from the sector.

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X See Question 1

3. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

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

X No. [2006 Crops TR]

4. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X The annotation restricts use to levels no 

greater than those determined by the 

Safe Drinking Water Act, so the potential 

for detrimental chemical interaction is 

similar to that posed by municipal tap 

water. 

5. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X The annotation restricts use to levels no 

greater than those determined by the 

Safe Drinking Water Act, so the potential 

for detrimental chemical interaction is 

similar to that posed by municipal tap 

water. Any presence of the substance in 

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the overall agroecosytem would be 

required by the annotation to meet the 

requirements of the Safe Drinking Water 

Act, ensuring presence below 4 ppm.

6. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X No. The substance degrades rapidly to 

naturally occurring compounds in the 

presence of air and sunlight [2006 Crops 

TR 417-432] This TR also confirms (in 

lines 384 –402) that these materials are 

not persistent in the environment in 

general, and that in water and soil, 

sodium and calcium hypochlorite 

separate into sodium, calcium and 

hypochlorite ions. Chlorine dioxide is also 

reactive and breaks down quickly. While 

the TER does not directly address its fate 

in aquatic environments, again, the 

annotation would limit the extent to which 

any chlorine material could be discharged 

into sea water or any other part of the 

environment.

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 See Q # 1

8. Are there adverse biological and 

chemical interactions in the agro-

ecosystem, including biodiversity? 

[§6518(m)(5)]

X Any presence of the substance in the 

overall agroecosytem would be required 

by the annotation to meet the 

requirements of the Safe Drinking Water 

Act, ensuring presence below 4 ppm. 

9. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X The substance is not used in direct 

contact with soil or terrestrial livestock. It 

is only used in contact with hard surfaces 

and equipment, or culture water. [2006 

Crops TR 322-327, petition]

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NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 2. Is the Substance Essential for Organic Production? Substance: Chlorine Materials

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 Yes. 2006 TR Lines 149-171

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 This process does not involve the 

chemical transformation of a natural 

substance; the starting materials are 

synthetic. 2006 TR Lines 177-178

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X 2006 TR Lines 183-184

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X 2006 TR Lines 183-184

6. Is there an organic substitute? 

[§205.600(b)(1)]

X 2006 TR Lines 183-184

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X Petition page 7-8 (notes the limitations on 

alternative materials) and 2011 Crops 

TER page 12.

8. Are there any alternative substances? 

[§6518(m)(6)]

X

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X

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NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 3. Is the substance compatible with organic production practices? Substance: Chlorine 

Materials 

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

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

toxins derived from bacteria X

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X

livestock parasiticides and medicines X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X

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