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 June 20 2013

National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Vitamins in aquatic plant production (B1, B12, and H)

+

February 18, 2014

Summary of Proposed Action:

Synthetic vitamins B1, B12 and H are proposed to be added to the National List at 205.609 for 

use in production of aquatic plants. Section 205.609 of the National List will contain a list of 

synthetic substances for use in the production of aquatic plants.

Healthy plant growth in water and on land depends on the level of nutrients available in plant 

environment. Synthetic vitamins (B1, C and E) are presently on the National List at 205.601(j)(8) 

as plant or soil amendments. Vitamins B1 (Thiamine), Vitamin B12 (Choline), and Vitamin H are 

the only vitamins being petitioned and for use in organic aquatic plant production, and only for 

use in closed systems. 

The manufacture of vitamins can be by chemical processes, fermentation or extraction 

depending on the specific vitamin. Fermentation can be synthetic or non-synthetic. Vitamins 

should not be considered persistent in marine environments. Adverse effects due to persistence 

are more likely to be seen in closed systems.

Synthetic vitamins are not specifically manufactured for use in aquatic plant production. 

However, the vitamins proposed for use in aquatic plants production are produced from the 

same type of processes and manufacturers of vitamins for organic livestock. 

In reviewing whether vitamins are compatible with organic farming the subcommittee took into 

consideration the Organic Food Production Act (OFPA) which limits the use of synthetics to 

various categories, one of which is “pheromones, soaps, horticultural oils, fish emulsions, 

treated seed, vitamins, and minerals.” Vitamins are listed in the OFPA at 6517(c)(1)(B)(i).

The NOP received the petition for the use of synthetic vitamins in aquatic plants on August 3, 

2012. The Crops subcommittee deemed the petition sufficient on June 16, 2013; no technical 

review (TR) was requested. In October, 2013, the aquatic petitions were transferred to the 

Livestock Subcommittee to be considered as a group. The crops subcommittee did not request 

a TR because vitamins are already allowed at §205.603(d)(3) for livestock feed, and specific 

ones (B1, C, and E) are allowed for crops at §205.601(j)(8).TR references in this Checklist are 

from the TR dated April 29, 2013 requested by the livestock subcommittee for vitamin use in 

production of aquatic animals.

The NOSB seeks public input on the essentiality of the use of vitamins in aquatic plant 

production.

It should be noted that at the time of drafting this proposal there are no federal standards 

promulgated for aquatic or animal production and this proposal is based on NOSB 

Recommendations of Standards voted in 2007, 2008, and 2009. 
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 June 20 2013

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: [ ] Comments: N/A

Subcommittee Action & Vote.

Classification Motion: Motion to classify vitamins (B1, B12, and H), as petitioned, as 

synthetic:

Motion by: Jean Richardson 

Seconded by: Colehour Bondera

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

Listing Motion: Motion to list vitamins (B1, B12 and H) at §205.609 of the National List 

Motion by: C. Reuben Walker 

Seconded by: Jean Richardson

Yes: 6 No: 1 Absent: 0 Abstain: 0 Recuse: 0

 Proposed Annotation: None proposed

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

Notes: 

Minority Opinion: see end of document

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB February 18, 2014
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 June 20 2013

NOSB Evaluation Criteria for Substances Added To the National List: Crops

Category 1. Adverse impacts on humans or the environment? Vitamins for aquatic plants 

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 Vitamins are dissolved in growing media 

for aquatic plants in very dilute solutions 

ranging from 0.4-0.02 ppm. Media and 

plant cultures are in containers, such as 

on-shore tanks and ponds. The petitioner 

does NOT seek allowance for synthetic 

vitamins for production of aquatic plants 

in public waters. (Petition page 2).

It is unlikely that vitamin use or misuse 

will result in environmental impairment 

due to their short half lives in aquatic 

systems. (TR 972-973 and 807-829).

Large amounts of vitamins released into 

open waters may result in promotion of 

algal blooms and red-tides (TR 986-987) 

and perhaps eutrophication (TR 1075-

1079).

Overall, accidental release of small 

amounts of vitamins into the environment 

is not assumed to pose any significant 

risk (TR 982-983).

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X See 1 above.

Industrial production of synthetic vitamins 

includes use of reagents and 

fermentation waste which can have 

negative environmental impacts, but no 

specific examples of such contamination 

are cited in TR (TR 945-987).

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X See 1 above.

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

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

X No (TR 541-548).

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems? [§6518(m)(1)]

X Overall vitamins should not be 

considered persistent in marine 

environments as these compounds 

readily decompose in oxic (oxygen rich) 

environments (TR 827-829).
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 June 20 2013

6. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X See 5 above and 7 below.

7. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X See 5 above.

The vitamins petitioned , Thiamine, 

Choline and Biotin are water soluble.

The potential for toxicity is generally 

dependent on the vitamin’s solubility 

properties. Water soluble vitamins 

(thiamine, riboflavin, pyridoxine, 

pantothenic acid, niacin, biotin, folic acid, 

choline, inositol, and ascorbic acid) are 

rapidly depleted and these vitamins do 

not bioaccumulate in animal fatty tissue. 

Lipid-soluble vitamins A, D, E, and K 

bioaccumulate in fatty tissue (TR 847-

876). Literature on bioaccumulation or 

persistence of vitamins in aquatic 

environments is limited. In general lipid 

soluble vitamins are more likely to 

bioaccumulate in fatty tissues (TR 830-

836). 

Adverse effects due to persistence will be 

more severe in closed systems (TR 805-

806).

8. 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 1, 5, and 7 above.

Limited information is available regarding 

potential for environmental or human 

health toxicity at the small levels used 

(TR 1045-1050).

9. Are there adverse biological and 

chemical interactions in the agroecosystem? [§6518(m)(5)]

X It is unlikely that vitamins used in closed 

containers during aquatic plant 

production would enter a terrestrial agroecosystem.

No studies have been found indicating 

toxic effects of vitamins in soil dwelling 

organisms (TR 1030-1033).

Overloading aquatic ecosystems with 

nutrients could potentially reduce BOD , 

but with good regulations in place 

negative impacts are unlikely from use in 

closed systems as petitioned.

10. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X See 1, 7, and 9 above.

No studies have been found indicating 

toxic effects of vitamins on soil-dwelling 

organisms (TR 1033).
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 June 20 2013

NOSB Evaluation Criteria for Substances Added To the National List: Crops

Category 2. Is the Substance Essential for Organic Production?: Vitamins for aquatic plants 

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 There are 3 vitamins petitioned. 

Production methods vary. All three can 

be produced by fermentation, but are 

typically commercially produced by 

chemical processes (TR 553-554).

Fermentation can be considered 

synthetic or non-synthetic (TR 785-786).

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 X See 2 above.

Extraction from natural sources is widely 

considered inefficient and low yielding 

(TR 574-773).

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 X There are no known natural alternatives 

(Petition page 7)

Vitamin B1 can be produced from many 

plant sources.

Vitamin B7 can be produced from both 

plant and animal sources, including fish 

meal and fish solubles.

Vitamin B 12 can be produced from 

animal and fish by-products.

6. Is there an organic substitute? 

[§205.600(b)(1)]

X None.

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X

8. Are there any alternative substances? 

[§6518(m)(6)]

X X See 5 above .

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X Little information was provided to be able 

to answer this question
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 June 20 2013

NOSB Evaluation Criteria for Substances Added To the National List: Crops

Category 3. Is the substance compatible with organic production practices? Vitamins for 

aquatic plants

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 Vitamins B1, C and E are presently on 

the National List at 205.601(j)(8) as plant 

or soil amendments.

Vitamins are listed in the OFPA at 6517 

(c) (1)(B)(i)

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X See 1 above. 

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 X Thiamine and biotin are sulfur containing. 

(TR 537-539).

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

Minority Opinion - Vitamins In aquatic plant production

February 21, 2014

A minority of the subcommittee suggested that the subcommittee adopt an annotation motion 

for plant vitamins use in aquaculture that set a 5-year expiration date on the listing, with a 

justification explaining that the specific time frame for an expiration date allows the Board to 
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 June 20 2013

monitor the use of the material, update its scientific and essentiality review, incentivize 

alternatives and continuous improvement, and vote on the continuation of use pending the 

receipt of a petition requesting that use be extended.

Support for the annotation is based on the following justification: Since this petition is being 

considered in the absence of regulations defining acceptable practices in organic aquaculture, 

essentiality in particular cannot be judged at this time. Therefore, the NOSB needs to reconsider 

the approval in five years at the least. Current consideration of the material has raised issues 

relating to health or environmental impacts, especially relating to those in water receiving 

discharges or open water systems; alternatives derived from natural source; and compatibility 

with organic and sustainable agriculture. In particular, although the petitioner has stated that the 

vitamins would be used in closed systems and needed only for growth of starter cultures, there 

is nothing in the proposed listing from the subcommittee to restrict the use to starter cultures in 

closed systems. The review in 5 years provides an opportunity for the Board to reevaluate and 

vote for the continued or modified use of the material under the same standard of review that is 

used to approve the material initially. 

In addition, the minority makes the following comments and additions to the majority checklist, 

which it believes does not provide a full assessment of environmental and health standards 

review required under the Organic Foods Production Act (OFPA): The petitioner has told the 

subcommittee that the vitamins will be used only in closed systems for starting cultures. The 

minority believes that this should be part of the annotation.

With regard to checklist Category 1, Adverse Impacts on Humans and the Environment, the 

minority believes the following need to be considered:

• Vitamin B1: Commercial production involves a six-step synthetic procedure beginning 

with ethyl 3-ethoxypropionate as the feedstock and reactants including ethyl formate, 

acetamidine hydrochloride, phosphorus(V) oxychloride, alcoholic ammonia, hydrobromic 

acid, and 4-methyl 5-hydroxyethyl thiazole. TR lines 594-600.

• A search of the patent literature revealed two methods for vitamin B1 (thiamine) 

production by fermentative methods that appear to use genetically engineered bacteria. 

TR lines 601-606.

• Vitamin B7 (H, biotin): The synthesis begins with fumaric acid as the starting material 

and involves 15 linear synthetic steps, including vicinal bromination of fumaric acid, 

benzylamine, oxalyl chloride, acetic anhydride, zinc, acetic anhydride, acetic acid, 

dihydrogen sulfide, potassium hydrosulfide, zinc/acetic acid, an appropriate Grignard 

reagent, hydrogen over palladium, hydrobromic acid, silver d-camphorsulfonate, sodium 

diethyl malonate, and hydrobromic acid. TR lines 660-672. 

• Microbial fermentation methods have been developed to produce only the biologically 

active isomer of biotin. As an example, a microorganism of the genus Kurthia (bacteria) 

was developed with resistance through exposure to a mutagen, selecting lines capable 

of producing d-biotin under aerobic conditions (Hoshino, 2002). TR lines 673-679.

• MSDSs for several feedstock chemicals and other chemical reagents used in the 

synthesis of biotin (vitamin B7) indicate the potential for ecological damage if 

accidentally released into the environment. TR lines 946-946.

• Vitamin B12. Microorganism fermentation is the exclusive commercial method of 

synthesizing vitamin B12. Some strains are genetically engineered. TR lines 770-773.

• All: The fermentative production of vitamins presents a slight risk of product 

contamination from genetic material in the fermentation broth and any chemicals used 

during processing. TR lines 918-920.

• If released to the water, most of the water-soluble vitamins are not expected to adsorb to 

suspended solids and sediment. TR lines 930-931.
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 June 20 2013

• Many of the feedstock chemicals and reagents used in vitamin synthetic procedures are 

considered petrochemicals or may be obtained from genetically modified organisms 

(GMOs). Acetone, for example, is a commonly used chemical reagent derived from 

petroleum as well as from GMOs such as corn. TR lines 955-958

• Waste streams resulting from the fermentative production of vitamins may also pose 

risks to the environment. In general, the EPA assumes “no control features for the 

fermentor offgases, and no inactivation of the fermentation broth for the liquid and solid 

waste releases,” suggesting that environmental exposure to these waste streams is 

likely. Some potential risks to the environment include the transfer of novel genes into 

crops, poisoned wildlife, and the creation of new and more potent viruses, in addition to 

a host of unknown risks. TR lines 959-966.

• Release of large amounts of vitamins into the environment may result in eco-toxic 

events, such as the promotion of algal blooms and red tides. TR lines 985-987. 

• Unicellular photosynthetic algae require nutritional intake of vitamin B1 (thiamine), B7 

(biotin), and B12 (cobalamin) (NAS, 1969). These vitamins, as well as other macro- and

micronutrients, can be a limiting growth factor for environmentally beneficial and 

deleterious algae. TR lines 976-979

• Excessive vitamin loadings can lead to synergistic and/or antagonistic effects for the 

absorption and bioavailability of minerals and other trace nutrients. TR lines 1011-1012.

• Overloading aquatic ecosystems with nutrients, such as vitamins, could potentially lead 

to depletion of the dissolved oxygen content and eutrophication. This is commonly 

manifested through occurrences of algal blooms and red tides, fish kills, and overall loss 

of biodiversity from the aquatic system. TR lines 1075-1077.

With regard to checklist Category 2, Essentiality, the minority believes the following need to be 

considered:

• Vitamins B1, B7, and B12 may all be produced through fermentation. Vitamins B1 and 

B7 may also be produced through chemical reactions of synthetic chemicals. (See 

Category 1, question 2.)

• Natural forms are produced by plants, animals, and microorganisms.

• Natural sources of the three vitamins include:

o Vitamin B1: Dried brewers yeast, wheat middlings, wheat mill run, rice bran, rice 

polishings, dried torula yeast, groundnut (peanut) meal, wheat bran, barley, dried 

fish solubles, cottonseed meal, soybean meal, linseed meal, dried distillers 

solubles, broad beans, lima beans, dried delactose whey, glandular meals 

(liver/kidney), green leafy crops, outer coat or germ of cereals. 

o Vitamin B7: Dried brewers yeast, dried torula yeast, dried distillers solubles, 

rapeseed meal, safflower seed meal, sunflower seed meal, whole hens eggs, 

rice polishings, dried brewers grains, liver and lung meal, rice bran, dried 

delactose whey, cottonseed meal, groundnut meal, soybean meal, dried skim 

milk, alfalfa meal, oats, sorghum, dried blood meal, dried fish solubles, fish meal, 

wheat bran, wheat mill run, legumes, green vegetables. 

o Vitamin B12: Animal by-products, liver, kidney, heart, muscle meats, fish meals, 

shellfish, meat and bone meal, condensed fish solubles, and poultry by-product 

meal. TR lines 1189-1192; 1207-1211; 1237-1238.

Under Category 3, Compatibility, the minority points out the following:

• Compatibility depends on how they are used—on routine basis, or occasionally, when 

needed.

• Synthetic vitamins are permitted for animals only when natural vitamins are not available 

in EEC, UK, Japan, and IFOAM standards. TR lines 495-525.

• It is not sustainable to depend on external synthetic inputs.