National Organic Standards Board

Livestock Subcommittee

Petitioned Material Checklist

Trace Minerals for Aquatic Animals Proposal 

August 6, 2013

Summary of Proposed Action:

The use of synthetic minerals in organic aquatic animal production was petitioned by the Aquaculture Working 

Group (AWG). The National Organic Program (NOP) allows the use of minerals in organic livestock production

as feed additives, under §205.603(d)(2) as “Trace minerals, for enrichment or fortification when FDA 

approved.” The Technical Review (TR) was compiled by the Pesticide Research Institute for the USDA 

National Organic Program. The Livestock subcommittee determined that the TR is sufficient according to 

NOSB review criteria for TR’s. 

Minerals are essential for animals raised on land or in water. Minerals, like carbohydrates, proteins, fats, and 

vitamins are foundational to good humane animal health. Natural minerals are found in sources that include 

fish, fish oils, green leafy vegetables, soybean, and many livestock by-products. The commercial availability is 

a major impediment and concern. Synthetic minerals are mainly produced by chemical methods. 

Minerals are petitioned for enrichment and fortification, if FDA approved. The use petitioned is the same use 

currently used in organic livestock production. The use of petitioned minerals should help reduce the 

harvesting of our fish populations worldwide. As our fish population declines, its can have a negative impact on 

individuals of various communities, countries, and cultures. 

All of the major standards for organic aquaculture or aquaculture allow the use of synthetic minerals. In the 

United States, synthetic minerals are NOP approved for use in land-based livestock production. For 

consistency, the allowance for synthetic minerals is a fair and balanced approach for meeting the essential 

nutrient demand of minerals in aquatic animal diets, until viable non-synthetic minerals sources are in the 

market place. 

 

The Livestock Subcommittee has received a petition for the use of synthetic minerals in aquatic animals feed 

on January 6, 2012. A TR was requested by the LSC- Chair in early January, 2013. The TR was received on 

June 24, 2013. The TR provided helpful information for the LSC and NOSB to consider in the subcommittee 

and Board to evaluate as it pertains to synthetic minerals in aquatic animal production. 

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 X Yes ☐ No ☐ N/A

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

Substance Fails Criteria Category: NA

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

Classification Motion: Move to classify trace minerals as petitioned for aquatic animals as synthetic 

Motion by: C. Reuben Walker 

Seconded by: Francis Thicke

Yes: 7 No: 0 Absent: 2 Abstain: 0 Recuse: 0 

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Listing Motion: Move to list trace minerals as petitioned for aquatic animals on section 205.611 of the 

National List 

Motion by: Francis Thicke 

Seconded by: C. Reuben Walker 

Yes: 7 No: 0 Absent: 2 Abstain: 0 Recuse: 0 

 Proposed Annotation (if any): None 

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB August 6, 2013

NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 1. Adverse impacts on humans or the environment? Substance: Trace Minerals for 

Aquatic Animals

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 X “When used as petitioned, trace minerals 

from unconsumed feed pellets have the 

potential to persist in treated bodies of 

water, ground water, sediments and 

bioaccumulate in animal tissues.” But, 

“Overall, the risk of lethal effects from 

bioconcentration of the petitioned trace 

elements is considered to be low.”

[See 2013 Trace Minerals TR, pgs. 15-16] 

2. Is there a probability of environmental 

contamination during manufacture or 

disposal? [§6518(m)(3)]

X X Environmental contamination could 

possibly occur; however, the risks are low 

when manufacturers exercise good 

standard operating procedures for 

minerals production, use, and disposal. 

[See 2013 Trace Minerals TR, pgs. 18-19] 

3. Does the substance contain inerts 

classified by EPA as “inerts of 

toxicological concern?” [§6517 

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

X 

The petitioned minerals are not requested 

for use as a pesticide, thus by definition, 

trace minerals are not inerts.

[See 2013 Trace Minerals TR, pg. 13] 

4. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)] X 

No direct interaction between trace 

minerals and other aquatic animal feed 

additives were identified. The petitioned 

trace minerals are chemically equivalent to 

trace minerals that are used for 

fortification of organic livestock feed under 

7 CFR 206.603. 

[See 2013 Trace Minerals TR, pgs. 19-20]

5. Is there a toxic or other adverse action of There is a wide range of potential toxicities 

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the material or its breakdown products?

[§6518(m)(2)] X X 

associated with the various trace minerals. 

However, comparison of (aquaculture) 

effluent concentrations to the aquatic 

toxicity ... and drinking water quality 

standards for each mineral points to a 

negligible potential for toxicity under the 

prescribed use of the substance.”

[See 2013 Trace Minerals TR, pgs. 16-17]

6. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X X According to the 2013 Aquatic Animal TR, 

pgs. 20-21) the potential may occur. The 

risk of lethal effects from bioconcentration 

of the petitioned trace elements is 

considered low. 

[See 2013 Trace Minerals TR, pgs. 21-22] 

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 Environmental concentrations of trace 

minerals are unlikely to cause adverse 

health effects in humans.

[See 2013 Trace Minerals TR, pgs. 21-22] 

8. Are there adverse biological and 

chemical interactions in the agroecosystem, including biodiversity? 

[§6518(m)(5)]

X No reported toxicity has been observed in 

non-target wildlife or livestock. The 

authors believe that minerals are unlikely 

to exhibit toxicity toward the agro-system. 

Accidental release during production may 

lead to ecological impairment. 

[See 2013 Trace Minerals TR, pg. 20] 

9. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X Trace elements are required by soil 

organisms, crops and livestock, so if the 

usage rates are kept within the 

requirements for aquatic animals, there 

should be no detrimental effects.

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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: Trace Minerals for 

Aquatic Animals 

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 

Minerals are primarily produced using 

chemical synthesis and extraction from 

either natural or reclaimed sources.

[2013 Trace Minerals TR, pgs. 13-15]. 

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

See #2

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X

See #2

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)] X X 

There are natural sources -- fish meal 

being the best source -- but availability of 

those sources and the resource demands 

required to use them widely make them 

unrealistic sources of trace minerals. 

[2013 Trace Minerals TR, pgs. 24-25]. 

6. Is there an organic substitute? 

[§205.600(b)(1)] X X See #5

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X X See #5

8. Are there any alternative substances? 

[§6518(m)(6)] X 

Trace minerals are essential. Forage fish, 

wild caught fish, and shrimp are leading 

alternatives.

[See 2013 Trace Minerals TR, pgs. 24-

25].

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X 

Trace minerals are essential. The issue 

of commercially availability and viable 

alternatives are major impediments. 

[See 2013 Trace Minerals TR, pgs. 24-

25].

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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: Trace 

Minerals for Aquatic Animals 

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 

Synthetic minerals are consistent with 

organic farming principles of several 

organic entities to include (1) European 

Union, (2) Canadian General Standards 

Board, (3) Codex Alimentarius, (4) Japan 

Ministry of Agriculture, Forestry, and 

Fisheries, (5) International Federation of 

Organic Agricultural Movements, and (6) 

NOP. [See 2013 Trace Mineral Aquatic 

Animals TR, pgs. 11-12]. 

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X 

See #1.

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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