National Organic Standards Board

Handling Subcommittee

Petitioned Material Proposal - Sodium Dodecylbenzene Sulfonate

January 23, 2016

Background 

On October 9, 2015 the NOP received a petition to add Sodium Dodecylbenzene Sulfonate (SDBS) (CAS # 

25155-30-0) to the National List at §205.605 - Nonagricultural (nonorganic) substances allowed as 

ingredients in or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)) (b) Synthetics Allowed. This petition was forwarded to the Handling 

Subcommittee on November 2, 2015 for the appropriate petitioned material process to be conducted.

The petition was submitted by Ecolab, Inc. Sodium dodecylbenzene sulfonate is being petitioned for use 

as an active ingredient (1 of 2 active ingredients, the other is lactic acid) in an antimicrobial formulation, 

for use in treating fruits and vegetables in the premises of organic food retail establishments. The Ecolab 

antimicrobial material is: AFVT-Antimicrobial Fruit & Vegetable Treatment. 

The petitioner does not manufacture SDBS, but uses it as 1 of 2 active ingredients in their product 

(AFVT) formulation. They listed 3 companies that SDBS is manufactured by:

1. Pilot Chemical Company – Santa Fe Springs, CA. 

2. Stepan Company – Northfield, IL.

3. Unger Fabrikker A.S. – Fredrikstad, Norway

Sodium dodecylbenzene sulfonate is currently used (an anionic surfactant) in industrial, institutional, 

chemical detergents & cleaners, specialty cleaners, sanitization products, emulsifiers, suspension or 

wetting agents, absorbents in pesticide and other agricultural chemicals, along with numerous other 

uses. (Toxnet 2014).

Manufacturing

There are several ways to manufacture Sodium dodecylbenzene sulfonate. The primary source is to start 

with LAS (Linear alkybenzene sulfonate) which is made by the sulfonation of alkylbenzenes prepared 

from petroleum distillates. In one of the most common processes benzene is alkylated by long chain 

monoalkenes (e.g. dodecene) using hydrogen fluoride as a catalyst. The purified dodecylbenzenes (and 

related derivatives) then form dodecylbenzene sulfonic acid, which is then subsequently neutralized 

with sodium hydroxide (Kurt Kosswig, “Surfactants in Ullman’s Encyclopedia of Industrial Chemistry, 

Wiley-VCH, 2005). The final slurry can then be dried by either drum drying (this forms flakes or powder) 

or by using a spray drier system, (this forms beads) to create the desired form of Sodium 

dodecylbenzene sulfonate.

According to information provided in the petition, the sulfonation technology has been considerably 

improved, with the most modern systems beginning to use falling film reactors (FFR) (mono-tube or 

multi-tube) and SOɜ, found in many sulfonation facilities in Europe. Also mentioned in the petition: in 

the mid 90’s there was a new form of alkylation technology introduced that is now being used in Europe, 

based on heterogeneous catalyst in a fixed-bed reactor. This new technology offers: process 

simplification, elimination of acids handling and disposal (HF, HCI) as well as an overall production yield 

improvement and improved LAB quality.

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Discussion

The petitioner (Ecolab, Inc.) is trying to get SDBS added to the National List as a processing aid, so that it 

may be used as one of two active ingredients in their antimicrobial product. This product (Ecolab’s 

Antimicrobial Fruit and Vegetable Treatment) specifically formulated for use in food retail environments 

such as restaurants, cafeterias, food service operations, commissaries and kitchens. They state that it 

would help to provide the organic users a new reliable tool to aid in the battle against microorganisms 

that cause food borne illness outbreaks. The petitioner further states that when SDBS is used as one of 

two active ingredients in their formulated product it is very effective in helping to control pathogens 

(Escherchia coli O157:H7, Listeria monocytogenes, and Salmonella enterica) when used in wash water or 

on surfaces of raw or processed fruits and vegetables.

The petitioner states that in the mode of action there are three mechanisms that SDBS works by 

providing. These are: Protein denaturing; essential enzyme inactivation; and by membrane disruption 

and alteration of cell permeability.

SDBS has been cleared for use as an antimicrobial agent in produce wash water by the Food and Drug 

Administration (FDA) under 21CFR 173.405. But, it is not listed as GRAS.

Sodium dodecylbenzene sulfonate does not appear to pose any serious human health or environmental 

concerns under the proposed use pattern. But, according to the New Jersey Department of Health and 

Senior Services Hazardous Substance Fact Sheet (revised May, 2002) and the MSDS for SDBS, it can be a 

skin irritant, could possibly cause eye damage, and if inhaled be an irritant of the nose, throat, and 

lungs. This same fact sheet also states that repeated exposure could cause bronchitis to develop. SDBS 

according to the Material Data Sheet is listed as: DOT: UN3077, Rq, Environmentally Hazardous 

Substance, Solid, N.O.S. (Sodium Dodecylbenzene Sulfonate), 9, III, Marine Pollutant (Linear 

Alkylbenzene Sulfonate). Also, it has been noted that SDBS is slightly toxic to Bobwhite quail and green 

algae and moderately toxic to some species of fish.

Information provided in the EPA 2006 Registration Eligibility Document (RED) states: No environmental 

exposure is expected to occur from the majority of linear alkylbenzene sulfonate uses and it is unlikely 

that any appreciable exposure to terrestrial or aquatic organisms would occur from limited commercial 

down-the-drain use because of the very small number of pounds for these uses plus their rapid 

degradation in the environment.

There is one area of possible concern regarding SDBS and its use and compatibility with organic crop 

production in that according to one report (Estrin et al. 1982), it states that SDBS contains impurities 

that could include: neutral oil (unsulfonated materials), arsenic (As), iron (Fe), and possibly lead (Pb). 

The levels of these impurities, was not defined. It is not clear if the new methods of formulation 

mentioned in the petition further remove any of these impurities or not.

There currently are alternative materials in use by organic handlers which would include: lactic acid, 

citric acid, acidified sodium chlorite, and peracetic acid. The petitioner states that while these materials 

are available for use by organic handlers and retailers, that SDBS would enable the petitioner to provide 

a formulated product for use at the food retail, kitchen, restaurant level, etc. where there currently is 

not such a product available. It is their position that the other available materials are normally used at 

the processing level and not necessarily at the food retail levels for raw and ready to eat fruits and 

vegetables.

It would help the full committee during their deliberation of this material if organic stakeholders could 

provide us with the following information:

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• What are retailers currently using to address these concerns?

• Are any of the alternatives mentioned in the petition currently used at the retail level and if so are 

 they effective in addressing these areas of food safety concerns? 

• What are the level (if any) of impurities as mentioned in this document found in SDBS?

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

 Criteria Satisfied? 

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

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

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

4. Commercial Supply is Fragile or Potentially Unavailable ☐ Yes ☐ No ☒ N/A 

as Organic (only for §205.606)

Substance Fails Criteria Category: [2] Comments: Alternatives available

Subcommittee Action & Vote

Classification Motion: Move to classify sodium dodecylbenzene sulfonate as synthetic. 

Motion by: Harold V. Austin IV 

Seconded by: Ashley Swaffar 

Yes: 7 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

Listing Motion: Move to list sodium dodecylbenzene sulfonate at §205.605 - Nonagricultural 

(nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or 

“made with organic (specified ingredients or food group(s))” of the National List.

Motion by: Harold V. Austin IV 

Seconded by: Tom Chapman 

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

 

Approved by Harold Austin, Handling Subcommittee Chair, to transmit to NOSB February 23, 2016

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NOSB Evaluation Criteria for Substances Added To the National List – Handling

Category 1. Adverse impacts on humans or the environment? Sodium dodecylbenzene sulfonate (SDBS) 

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 Information provided in the EPA 2006 

Registration Eligibility Document (RED) 

states: No environmental exposure is 

expected to occur from the majority of linear 

alkylbenzene sulfonate uses and it is unlikely 

that any appreciable exposure to terrestrial 

or aquatic organisms would occur from 

limited commercial down-the-drain use 

because of the very small number of pounds 

for these uses plus their rapid degradation in 

the environment.

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)]

See answer to question 5 below.

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X

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 It is biodegraded rapidly under aerobic 

conditions with a half-life of approximately 1-

3 weeks; oxidative degradation initiating at 

the alkly chain. Under anaerobic conditions it 

degrades very slowly or not at all, causing it 

to exist in high concentrations in sewage 

sludge. This is thought to not be of a concern 

as it will rapidly degrade once returned to an 

oxygenated environment. (Jenson, John 

February 1999, “Fate and effects of linear 

alklybenzene sulfonates (LAS) in the 

terrestrial environment”).

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 According to the New Jersey Department of 

Health and Senior Services Hazardous 

Substance Fact Sheet (revised May, 2002) 

and the MSDS for this material, it can be a 

skin irritant, could possibly cause eye 

damage, and if inhaled can be an irritant to 

the nose, throat, and lungs. Repeated 

exposure could cause bronchitis to develop, 

according to the N.J. Dept.of Health Fact 

Sheet.

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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 SDBS contains impurities that include neutral 

oil (unsulfonated materials), arsenic (As), iron 

(Fe), and lead (Pb). (Estrin et al.1982). The 

level of these impurities was not defined. It is 

not clear if the new methods for formulating 

SDBS (as stated in the petition) further 

remove any of these impurities or not.

Category 2. Is the Substance Essential for Organic Production? Sodium dodecylbenzene sulfonate (SDBS)

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 multiple ways to manufacture 

SDBS: One process is by reacting 

dodecylbenzene with sulfuric acid (Oleum 

Process) or air/SO2 to produce 

dodecylbenzene acid (CTFA 1991a). The 

dodecylbenzene sulfonic acid is then 

neutralized with sodium hydroxide. 

The most common process is: Benzene is 

alkylated by long chain monoalkenes (e.g. 

dodecene) using hydrogen fluoride as a 

catalyst. The purified dodecylbenzenes (and 

related derivatives) then form 

dodecylbenzene sulfonic acid, which is then 

subsequently neutralized with sodium 

hydroxide (Kurt Kosswig, “Surfactants in 

Ullman’s Encyclopedia of Industrial 

Chemistry, Wiley-VCH, 2005). The final slurry 

can then be dried by either drum drying (this 

forms flakes or powder) or by using a spray 

drier system (this forms beads).

According to information provided in the 

petition the sulfonation technology has been 

considerably improved, with the modern 

systems beginning to use falling film reactors 

(FFR) (mono-tube or multi-tube) and SOɜ, in 

many of the sulfonation facilities in Europe. 

Also mentioned in the petition: in the mid 

90’s there was a new form of alkylation 

technology introduced that is now being 

used in Europe, based on heterogeneous 

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catalyst in a fixed-bed reactor. This new 

technology offers: process simplification, 

elimination of acids handling and disposal 

(HF, HCI) as well as an overall production 

yield improvement and improved LAB 

quality.

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

6. Is there an organic substitute? 

[§205.600(b)(1)]

X According to information provided by the 

petition citric or lactic acid could serve as 

possibly substitutes (For the AFVT product’s 

intended use).

7. Is the substance essential for handling of 

organically produced agricultural products? 

[§205.600(b)(6)]

X

8. Is there a wholly natural substitute product?

[§6517(c)(1)(A)(ii)]

X According to information provided by the 

petition either citric or lactic acid could 

possibly be used as a substitute for this 

material for microbial control.

9. Are there any alternative substances? 

[§6518(m)(6)] 

X Yes for the overall intended use of the 

material (when used in the finished product 

that the petitioner is requesting this material 

be added to the National List so it can be 

used as one of two active ingredients in), 

then acidified sodium chlorite or peracetic 

acid could be used instead. But they do 

mention that these materials are more apt to 

be used in commercial food processing 

establishments and not in restaurants, 

kitchens, etc. as is the intended area of use 

proposed by the AFVT product label.

10. Is there another practice (in farming or 

handling) that would make the substance 

unnecessary? [§6518(m)(6)]

X Current processes in place utilizing materials 

already allowed for use in organic handling 

and processing.

11. Have the ancillary substances associated 

with the primary substance been reviewed? 

Describe, along with any proposed 

limitations. 

X

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NOSB Evaluation Criteria for Substances Added To the National List - Handling

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

Sulfonate (SDBS)

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

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

manufacture, and disposal compatible with 

organic handling? [§205.600(b)(2)]

X

3. Is the substance compatible with a system of 

sustainable agriculture? [§6518(m)(7)]

X

4. Are the ancillary substances reviewed 

compatible with organic handling [?

X none

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

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)] Sodium Dodecylbenzene Sulfonate 

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

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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

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