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Sunset 2017 Review 

Meeting 2 - Review

Handling Substances §205.605(b)

October 2015

As part of the National List Sunset Review process, the NOSB Handling Subcommittee has evaluated the 

need for the continued allowance for or prohibition of the following substances for use in organic 

handling.

Reference: 7 CFR 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)).’’

§205.605(b) Synthetics allowed:

Acidified sodium chlorite

Alginates

Ammonium bicarbonate

Ammonium carbonate

Ascorbic acid

Calcium citrate

Calcium hydroxide

Calcium phosphates: monobasic, dibasic, 

tribasic

Carbon dioxide

Chlorine Materials: calcium hypochlorite, 

chlorine dioxide, sodium hypochlorite

Ethylene

Ferrous sulfate

Glycerides: mono and di

Glycerin

Hydrogen peroxide

Magnesium carbonate

Magnesium chloride

Magnesium stearate

Nutrient vitamins and minerals

Ozone

Phosphoric acid

Potassium acid tartrate

Potassium carbonate

Potassium citrate

Potassium phosphate

Sodium citrate

Sodium hydroxide

Sodium phosphates

Sulfur dioxide

Tocopherols

Xanthan gum

Links to additional references and supporting materials for each substance can be found on the 

NOP website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned
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Acidified sodium chlorite

Reference: 205.605(b) - Secondary direct antimicrobial food treatment and indirect food contact surface 

sanitizing. Acidified with citric acid only. 

Technical Report: 2008 TAP 

Petition(s): 2006 Sodium Chlorite, Acidified

Past NOSB Actions: 2009 NOSB recommendation 

Recent Regulatory Background: Added to NL effective 03/15/2012 (77 FR 8089)

Sunset Date: 03/15/17

Subcommittee Review 

Specific Uses of the Substance: ASC solution is used as a processing aid in wash and/or rinse water, in 

accordance with the FDA limitation for using on direct food contact and indirect food contact: 

• Direct Food Contact (Secondary Direct Food Additive) ─ Poultry carcass, organs and parts; red meat 

carcass, organs and parts, seafood (finfish and crustaceans), and fruits and vegetables (raw and 

further processed); processed, comminuted or formed meat products; and 

• Indirect Direct Food Contact ─ Hard surface food contact sanitation.

Manufacture: In the petition, it states that ASC solutions are made on-site and on-demand by mixing a 

solution of sodium chlorite with natural citric acid. Sodium chlorite (25%) and citric acid (50%) solutions 

are stored separately in bulk on site. Both solutions are pumped by proportional pumps and a water 

dilution module to make the final use dilution product, which typically contains 0.1% sodium chlorite 

and 0.6% citric acid and 99.3% water. Sodium chlorite is made by the reduction of chlorine dioxide, 

which is, in turn, from the reduction of sodium chlorate in the presence of sulfuric and hydrogen 

peroxide or sulfuric acid and sodium chloride. The resulting solution may be dried to a solid and the 

sodium chlorite content may be adjusted to about 80% by the addition of sodium chloride, sodium 

sulfate, or sodium carbonate. Sodium chlorite is marketed as a solid or an aqueous solution (such as 

25% by weight). 

The acid used to acidify sodium chlorite is natural citric acid, which is stated in the petition. However,

there is no information in the petition regarding how the natural citric acid was manufactured.

Discussion: The NOSB in its initial request for public comment asked:

Is the substance essential for organic food production? Since the material was last reviewed, have 

additional commercially available alternatives emerged? The Handling Subcommittee encourages 

current users of acidified sodium chlorite to provide detailed comments describing the situations in 

which it is the most appropriate or effective antimicrobial for a given application.

Public comment did not provide any alternatives. Several handlers wrote in and stated that this product 

is essential for use in their OSP.

This material satisfies the OFPA Evaluation criteria.

Motion to Remove

This proposal to remove acidified sodium chlorite will be considered by the NOSB at its public meeting. 
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The Subcommittee proposes removal of Acidified Sodium Chlorite from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Tom Chapman

Yes: No: 4 Abstain: 0 Absent: 3 Recuse: 0 

Alginates

Reference: 205.605(b) Synthetics allowed

Technical Report: 1995 TAP

Petition(s): 1995 Alginates

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Alginates are polysaccharides derived from brown seaweeds. The use of the alkalizing agent used to 

produce alginates renders them synthetic. Alginates are derivatives of alginic acid. 

Alginates occur naturally in seaweed mainly in the form of sodium, potassium, calcium and magnesium 

salts of alginic acid (2015 Technical Review, Saltmarsh, Barlow, & eds., 2013). “Extraction involves ion 

exchange in an alkaline medium followed by precipitation, purification, recovery of alginic acid and 

conversion to the appropriate salt” (2015 Technical Review, Saltmarsh, Barlow, & eds., 2013).

Alginates are unique in that they form gels or act as coatings or thickeners without requiring heating, 

thereby making them ideal for applications where the food is sensitive to temperatures. Alginate 

materials are considered GRAS and have been used for over 50 years. Alternative materials include 

carrageenan, modified cellulose and some gums.

The Handling Subcommittee had brought forth the following questions for public comment:

1. Please bring forth any information regarding the effect of alginic acid and/or alginates on human 

digestion.

2. Is alginic acid in use in organic handling and should it have its own National List listing? What are the 

non-synthetic alternatives in specific handling uses? 

Public comment was mixed regarding the relisting of alginates. Those in favor of its relisting note the 

long history of use with no ill effects on either the human digestive system or on the ecosystem due to 

harvesting, and assert that the properties imparted by alginates are essential for some processed food 

formulations. Those opposed expressed concerns regarding the concentration of heavy metals in the 

wild harvested seaweed and the fact that alginates are used primarily to enhance texture in foods, and 
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therefore not compatible with OFPA criteria.

The Handling Subcommittee proposes that alginates remain on the National List. 

Motion to Remove

This proposal to remove Alginates will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Alginates from the National List based on the following criteria 

in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: Compatibility

Vote in Subcommittee

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 4 Abstain: 0 Absent: 3 Recuse: 0

Ammonium bicarbonate

Reference: 205.605(b) - for use only as a leavening agent

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Ammonium carbonates are used as leavening agents. Ammonium bicarbonate has critical functionality 

as a raising (leavening) agent in certain cookies and crackers. Compared to Baking Soda it produces 

more gas, thus not leaving behind a salty or soapy taste in the finished baked goods, as it completely 

decomposes into water and gaseous products that evaporate during the baking process. It is used in 

baking where yeast is not used. Ammonium bicarbonate cannot be used for moist baked goods. It also 

helps provide certain characteristic textures (such as in crackers), as well as aids in controlling cookie 

spread.

This is the only leavening agent (ammonium carbonates) that is completely eliminated through the 

baking process. There are no organic alternatives to replace ammonium bicarbonate.

The ammonium carbonates are made from ammonia and carbon dioxide. Ammonium bicarbonate is 

made when carbon dioxide is bubbled through an ammonia solution. Crystals of ammonium 

bicarbonate precipitate from this saturated solution.

Ammonium carbonates are approved for use in the following organic standards: the European Union, 

Canada, Australia, New Zealand, Japan, IFOAM, and Codex. They are considered GRAS by the FDA.

Discussion: The original TAP combined the two ammonium carbonates (ammonium carbonate and 
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ammonium bicarbonate) for their preliminary review. Subsequently they have been looked at together 

during their previous two Sunset Reviews. The original TAP, previous subcommittee review, public 

comments, historical information, and current review found no environmental concerns and none have 

been brought to the subcommittee’s attention during this current review. Likewise, there were no 

human health concerns raised during the original TAP review or during the following two Sunset 

Reviews. The current Sunset Review and public comment periods (oral and written) also have not raised 

any environmental, human health concerns, or any other reason why this material should not continue 

to be allowed for organic handling.

During the 1st public comment period of the current review cycle a responses to a stakeholder survey 

mentioned that this material was still critical for Handlers, especially for baking crackers and similar 

baked goods. Other commenters supported its continued allowance on the National List. There were no 

comments against its relisting.

The subcommittee would see no reason to delist this material at this time.

Motion to Remove

This proposal to remove ammonium bicarbonate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of ammonium bicarbonate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

none given

Vote in Subcommittee

Motion by: Harold Austin

Seconded by: Ashley Swaffar 

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

Ammonium carbonate

Reference: 205.605(b) –for use only as a leavening agent

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Ammonium carbonates are used as leavening agents. Ammonium carbonate is used as a raising 

(leavening) agent for flat baked goods, such as cookies and crackers. It is often referred to as “Bakers 

Ammonia” in cooking recipes and by chefs. Ammonium carbonate is also used to make breadsticks, 

cookies, and crackers because it helps to make them both lighter and crispier. It is also used in many 

traditional Greek cooking recipes. The ammonium carbonates are heat activated, so baked goods will 
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not rise until whatever is being baked actually goes into the oven, thus helping with food preparation 

and time requirements. This is the only leavening agent (ammonium carbonates) that is completely 

eliminated through the baking process. There are no organic alternatives to replace the ammonium 

carbonates.

The ammonium carbonates are made from ammonia and carbon dioxide. Ammonium carbonate is 

made when carbon dioxide is passed through an ammonia solution and by then allowing the vapors to 

distill, thus the resulting solid is ammonium carbonate.

Ammonium carbonates are approved for use in the following organic standards: the European Union, 

Canada, Australia, New Zealand, IFOAM, and Codex. They are considered GRAS by the FDA.

Discussion: The original TAP combined the two ammonium carbonates (ammonium carbonate and 

ammonium bicarbonate) for their preliminary review. Subsequently they have been looked at together 

during their previous two Sunset Reviews. The original TAP, previous subcommittee review, public 

comments, historical information, and current review found no environmental concerns and none have 

been brought to the subcommittee’s attention during this current review. Likewise, there were no 

human health concerns raised during the original TAP review or during the following two reviews. The 

current Sunset Review and public comment periods (oral and written) also have not raised any 

environmental, human health concerns, or any other reason why this material should not continue to be 

allowed for organic handling.

During the 1st public comment period of this review cycle there were no specific comments either to 

relist or delist this material. Comments in support/or otherwise, of this material during the upcoming 2nd

and final comment period would be useful in determining the final full board vote on this material.

The subcommittee would see no reason to delist this material at this time.

Motion to Remove

This proposal to remove ammonium carbonate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of ammonium carbonate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

none given

Vote in Subcommittee

Motion by: Harold Austin

Seconded by: Ashley Swaffar 

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

Ascorbic acid

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)
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Sunset Date: 06/27/2017

Subcommittee Review 

Specific Use: Dietary supplement and nutrient, flavor ingredient, used in curing and pickling, in flour to 

improve baking quality, as an antioxidant in fats and oils, and a wide variety of other food processing 

uses. Ascorbic acid is one of the most common sources of Vitamin C.

Discussion: Ascorbic acid is a vital nutrient necessary for humans and other primates. It is added to 

many foods to restore Vitamin C lost during the processing. Some FDA regulations require Vitamin C 

fortification, which is often achieved with Ascorbic acid. It is manufactured using a culture process from 

dextrose. 

Public comment for ascorbic acid was divided, with some comments remarking that ascorbic acid is 

being used as a preservative and therefore not consistent with organic agriculture. However, the 

majority of comments strongly supported relisting of ascorbic acid, stating the ingredient to be critically 

essential to maintaining nutrients and freshness in their products. 

The HS is supportive of relisting ascorbic acid. 

Motion to Remove

This proposal to remove ascorbic acid will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Ascorbic acid from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: Compatibility 

Vote in Subcommittee

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

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

Calcium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Specific Uses of the Substance: Calcium citrate provides calcium in nutritive supplements, and it can 

also be used as a water softener due to its chelation properties. It is used to wash processing equipment 

in order to eliminate off flavors, and as a pH adjuster and chelator in cleaning and sanitizing products. It 

is also used for its chelating properties to remove scale from boilers, evaporators and other processing 
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equipment. Calcium citrate is widely used in cosmetic and personal care products for many of these 

same functions. 

Approved Legal Uses of the Substance: Citric acid is listed under 21 CFR Part 184.1195 as Generally 

Recognized as Safe (GRAS). It is prepared by neutralizing citric acid with calcium hydroxide or calcium 

carbonate. It is permitted in food with no limitations other than current good manufacturing practice. It 

is also permitted by FDA in infant formula. 

The EPA listed citric acid and its salts in the 2004 List 4A (minimal risk inerts). 

International: The citrate salts are generally listed as allowed, but with restrictions associated with their 

usage. Calcium citrate is not listed in the CODEX and JAS organic standards.

Discussion: The NOSB in its initial request for public comment did not ask for any specific information 

from stakeholders.

Several commenters in favor of relisting stated:

• Acts as a buffering agent and sequester. Also, it imparts some flavor to the product. Sourced 

through fermentation of the citric acid process and part of a naturally sources process.

• One certifier state that some clients use calcium citrate.

While there were not specific questions asked of the public, the subcommittee did receive very few 

specific comments about calcium citrate. If a handler uses this material and feels it is important to keep 

on the list the Handling Subcommittee would like to receive comments from users specifically on the 

use of calcium citrate and why it is essential to keep on the National List.

This material satisfies the OFPA Evaluation criteria and the Handling Subcommittee supports the 

relisting of calcium citrate.

Motion to Remove

This proposal to remove calcium citrate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of calcium citrate from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

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

Calcium hydroxide

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 
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sunset recommendation

Recent Regulatory Background Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Calcium hydroxide is also known as slaked lime, which is quick lime, calcium oxide mixed with water.

Uses: Calcium hydroxide may be used as a component of aluminum free baking powder; it also clarifies 

sugar for molasses, and conditions corn for tortillas.

Although the original TAP (1995) suggest that calcium hydroxide may reduce the nutritional value of 

food, no health issues have been raised in public comment. No alternatives have been identified.

Public Comment indicated broad support for continued listing of this material and no opposition.

Motion to Remove

This proposal to remove calcium hydroxide will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Calcium Hydroxide from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Tracy Favre

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

Calcium phosphates (monobasic, dibasic, and tribasic) 

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

The original TAP looked at the calcium phosphates (monobasic, dibasic, and tribasic) and found them to 

be synthetic by nature. The calcium phosphates are used as raising (leavening) agents and used as a 

critical component in baking powder (aluminum free). All three of the calcium phosphates are used as 

leavening agents: dough conditioner, yeast food, or as an expanding agent. Monobasic and dibasic 
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calcium phosphate are often used for reduced sodium baking. 

Monobasic is also a buffer, firming agent, sequestering agent, and is popular in pancake mixes (usually 

used in combination with sodium bicarbonate). It is also used in baked goods, such as cookies, cakes, 

and potato chips, and as a firming agent for canned fruits and vegetables. 

Dibasic is used in enriched flour, noodle products, and in both dry and cooked forms of breakfast 

cereals. It is often used as a dough conditioner. It also can be used as a thickening agent for various 

cheese products.

Tribasic is an anti-caking agent, buffering agent. It also provides a very critical function as a free flow aid 

in finely powdered salt, used in baking. It is also used as a food source for yeast in bread making. It is 

used as an anti-caking agent in dry powders, such as in spices. Another use is as a thickener, stabilizer 

and as a sequestering agent for some dairy products.

Calcium is derived from either mined limestone or from oyster shells. The phosphorus is derived from 

mined phosphates. Calcium hydroxide is neutralized with phosphoric acid to create calcium phosphate.

Discussion: The original TAP combined the three calcium phosphates (monobasic, dibasic, and tribasic) 

for their preliminary review. Subsequently they have been looked at together during their previous two 

Sunset Reviews and the Reaffirmation vote (2010). They were found to be synthetic. The original TAP 

and the previous two Sunset Reviews all found the calcium phosphates to be of little concern to the 

environment, human health, of low toxicity, and of low environmental contamination concern during 

manufacture. (One reviewer did make mention that the raw materials do come from mining).

During the 1st posting, under the current review cycle, the Subcommittee asked if there were any 

changes in the source of the raw materials that make up the three calcium phosphate materials: there 

were no changes noted.

Also during the 1st posting under the current review cycle, there were 11 written public comments. 

Numerous comments were in support of the continued listing, including several organic handlers and 

one certifier stating it was used by several (60) handlers that they certify. Responses to an industry 

sponsored survey showed that it is used in baking powder, does not have an organic substitute and is 

essential in organic baked goods when yeast is not used in the baking process. This material had strong 

support for its continued listing, from those that currently use this material in their organic handling 

process.

There was a concern raised by a few members of the public regarding the cumulative effect on human 

health, with the use of the inorganic forms of phosphates as a whole, caused by an overall increase in 

usage. This concern would include the calcium phosphates as one of several materials mentioned. These 

public comments recommended either removal or annotations be added (which cannot be done during 

the sunset review process).

There are five phosphates (however, TSPP was voted for removal at the Spring NOSB meeting in La Jolla) 

on the National List at §205.605(b). No single phosphate food additive or ingredient can be implicated as 

an isolated risk factor. Concerns arise from the increase in cumulative use of phosphates and possible 

health effects on the general population. Given the new information and research since the last Sunset 

Review, the Handling Subcommittee has requested a new Technical Report. This should help clarify the 

probability of negative human health effects resulting from the cumulative effect of phosphates in food 
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products at various dose levels over time on the population as a whole, and alternative materials. Given 

that this Technical Review may not be received in time for the Fall 2015 meeting, the Handling 

Subcommittee recommends voting on this material at the Fall meeting, but, should the TR indicate 

probable cumulative negative health effects from phosphates, the Handling Subcommittee would make 

a new proposal to review all phosphates again at the Spring 2016 meeting.

Motion to Remove

This proposal to remove calcium phosphates (monobasic, dibasic, and tribasic) will be considered by the 

NOSB at its public meeting. 

The Subcommittee proposes removal of Calcium Phosphates (monobasic, dibasic, and tribasic) from the 

National List based on the following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 

205.600(b) if applicable: Possible effect of the substance on human health.

Vote in Subcommittee

Motion by: Harold Austin

Seconded by: Jean Richardson

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

Carbon dioxide

Reference: 205.605(b)

Technical Report: 1995 TAP; 2006 TAP

Petition(s): 2007 Carbon Dioxide

Past NOSB Actions: 10/1995 NOSB minutes and vote; 2007 NOSB Committee recommendation;

11/2005 sunset recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Carbon dioxide is used in modified atmosphere packaging, modified atmospheric storage, the freezing 

of foods, beverage carbonation, as an extracting agent, and for pest control in grain and produce 

storage. 

It is available in limited supplies from underground wells and as a byproduct of various manufacturing 

processes. All of the processes require purification of the carbon dioxide before being used in the food 

processing and handling. 

This material satisfies the OFPA evaluation criteria. 

There has been no public comment opposed to the relisting of carbon dioxide. Public comment in 

support of relisting was submitted by a number of food processors and associations. 

The Handling Subcommittee proposes that carbon dioxide remain on the National List. 
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Motion to Remove

This proposal to remove carbon dioxide will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Carbon Dioxide from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Lisa de Lima

Seconded by: Ashley Swaffar

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

Chlorine materials

Reference: 205.605(b) 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).

Technical Report: 2006 TR - Handling

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Specific Uses of the Substance: Sodium and calcium hypochlorite are chlorinated inorganic disinfectants 

used to control bacteria, fungi, and slime-forming algae that can cause diseases in people and animals. 

These disinfectants also are used in cleaning irrigation, drinking water, and other water and wastewater 

systems. Chlorine dioxide is an antimicrobial disinfectant and pesticide used to control harmful 

microorganisms including bacteria, viruses, and fungi on inanimate objects and surfaces primarily in 

indoor environments. It is used in cleaning water systems and disinfecting public drinking water 

supplies. It also is used as a bleaching agent in paper and textile manufacturing, as a food disinfectant 

(e.g., for fruit, vegetables, meat, and poultry), for disinfecting food processing equipment, and treating 

medical wastes, among other uses.

Approved Legal Uses of the Substance: With regard to organic production, calcium hypochlorite, 

sodium hypochlorite, and chlorine dioxide are currently approved for disinfecting and sanitizing 

livestock facilities and equipment and as algicides, disinfectants, and sanitizers (including irrigation 

system cleaning) in organic crop production. In addition, these chlorine materials are approved for 

disinfecting and sanitizing food contact surfaces in the production of processed products labeled as 

"organic" or "made with organic." Residual chlorine levels from all of these approved uses may not 
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exceed the maximum residual disinfectant limit under the Safe Drinking Water Act (currently 4mg/L or 

4ppm).

Discussion: The NOSB in its initial request for public comment asked:

Is the substance essential for organic food production? Since the material was last reviewed, have 

additional commercially available alternatives emerged? The Handling Subcommittee encourages 

current users of chlorine materials to provide detailed comments describing the situations in which they 

are the most appropriate or effective antimicrobial for a given application.

Several commenters opposed to the relisting stated:

• They are concerned about the NOP guidance on the use of chlorine, which allows for a higher 

concentration than allowed in the Safe Water Drinking Act to be used in wash tanks. They were 

especially concerned about organic food products that could absorb the higher concentration of 

chlorine into the food. They stated that poultry, eggs, leafy vegetables, root crops and more 

could absorb highly chlorinated water and the final effluent after the wash tank could still only 

contain the required 4 PPM. To address this concern, they suggested the annotation for 

chlorine be amended to the following: Chlorine materials, only as present as residual chlorine 

levels in water delivered by municipal or other public water systems, which shall not exceed the 

maximum residual disinfectant limit under the Safe Drinking Water Act.

• Another commenter stated that the use of chlorine on food contact surfaces should be handled 

separately from the use of dissolved chlorine in tank situations, especially on foods that can 

absorb some of the wash water. 

• Several commenters in support of relisting stated:

• Essential materials required for food safety. To the best of our knowledge, our partners in dairy 

production as well as our member farms choose chlorine materials as the preferred sanitizer for 

food contact surfaces. Disallowing sodium hypochlorite, calcium hypochlorite and chlorine 

dioxide would have a profound effect on the dairy industry. Please keep Chlorine Materials on 

the National List.

• Chlorine materials are vital sanitizing agents that are used to sanitize food contact surfaces such 

as equipment and utensils. Chlorine is desirable because it is effective and because it 

evaporates and leaves little residue. The majority of our organic manufacturing facilities rely on 

chlorine to prevent the growth of pathogenic microorganisms. We request that chlorine 

materials remain on the list of substances that are allowed in organic handling.

While there are concerns about the relisting of this material, chlorine has been used for many years as a 

sanitizer and is necessary in the organic industry for proper sanitation. There are also specific 

requirements to use chlorine above the 4ppm SDWA limit in several commodity specific industries. For 

example, as stated in 9 CFR 590.516 Sanitizing and drying of shell eggs prior to breaking: “Immediately 

prior to breaking, all shell eggs shall be spray rinsed with potable water containing an approved sanitizer 

of not less than 100 ppm nor more than 200 ppm of available chlorine or its equivalent. ”

Over the past year Electrolyzed Water and hypochlorous acid have been discussed by the program and 

many stakeholders in the organic community. The Handling Subcommittee feels that Electrolyzed water 

and hypochlorous acid should be allowed under the current listing for chlorine materials on the National 

List. Electrolyzed water devices generate active ingredients that are equivalent to other chlorine

materials on the National List. The Handling Subcommittee believes the national list could be clarified in 
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this matter and is reviewing a petition to explicitly add hypochlorous acid to the national list. 

This material satisfies the OFPA Evaluation criteria and the Handling Subcommittee supports the 

relisting of Chlorine Materials.

Motion to Remove

This proposal to remove Chlorine materials will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Chlorine materials from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Jean Richardson

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

Ethylene

Reference: 205.605(b) allowed for postharvest ripening of tropical fruit and degreening of citrus.

Technical Report: 1995 TAP; 1999 TAP - Processing

Petition(s): 1995 N/A, 2008 Ethylene (for use with pears)

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/1999 NOSB minutes and vote (add tropical 

fruit and citrus); 11/2005 sunset recommendation; 11/2008 recommendation for pears; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Ethylene is a flammable gas made from natural gas or crude oil. It’s a synthetic analog of a natural gas 

produced by plants. It is used in the post-harvest ripening of tropical fruit and the degreening of citrus. 

The subcommittee brought forth the following question for public comment: 

1. The subcommittee is considering editing the annotation and removing its allowed use for the degreening of citrus. If you use this material for the de-greening of citrus please let us know why you need 

to use it, and what the impact on your operation would be if it was removed from the List.

There has been no public comment opposed to the relisting of Ethylene. All public comment submitted 

has been in favor of relisting without an annotation change. One organization stated that “...without 

ethylene, organic tropical fruit would not be readily found in produce aisles.” One certifier noted they 

have six members currently using it for the degreening of citrus. 

This material satisfies the OFPA evaluation criteria.

The Handling Subcommittee proposes that Ethylene remain on the National List.
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Motion to Remove

This proposal to remove ethylene will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Ethylene from the National List based on the following criteria 

in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Lisa de Lima

Seconded by: Jean Richardson

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

Ferrous sulfate

Reference: 205.605(b) - for iron enrichment or fortification of foods when required by regulation or 

recommended (independent organization).

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Ferrous sulfate provides the iron needed by the body to produce red blood cells. It is used to treat or 

prevent iron-deficiency anemia, a condition that occurs when the body has too few red blood cells 

because of pregnancy, poor diet, excess bleeding, or other medical problems.

Public comment was divided, with some supporting ferrous sulfate remaining on the list, while others 

spoke to the fact that ferrous sulfate should only be used in products that by law require fortification. 

Motion to Remove

This proposal to remove ferrous sulfate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Ferrous sulfate from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: Compatibility

Vote in Subcommittee

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 7 Abstain: 0 Absent: 0 Recuse: 0
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Glycerides (mono and di)

Reference: 205.605(b) for use only in drum drying of food. 

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Mono- and diglycerides occur naturally in food as minor constituents of fats, in combination with the 

major constituent of food fats: triglycerides. They are also metabolic intermediates of triglycerides. 

When manufactured, they are prepared by the glycerolysis of fats or oils, or from fatty acids derived 

from edible sources (FDA 2014). These edible sources are commonly animal fats or vegetable oils such 

as soybean, canola, sunflower, cottonseed, coconut or palm oil (Frank 2014), and their main fatty acids 

used to manufacture mono- and diglycerides include lauric, linoleic, myristic, oleic, palmitic, and stearic 

acid (FDA 2014). The glycerol component of mono- and diglycerides is also derived from these edible 

fats and oils. (TR 2015 56-62).

Mono- and diglycerides are manufactured by the reaction of glycerin with fatty acids or the reaction of 

glycerin with triglycerides in the presence of an alkaline catalyst. The process is called 

transesterification. Organic solvents may be used in manufacture of glycerides. The products are 

purified to obtain a mixture of glycerides, free fatty acids, and free glycerin that contains at least 90 

percent-by-weight glycerides.

Mono- and diglycerides have many applications as food processing aids. They are principally used as 

emulsifiers. This function also translates into stabilization, preventing food separation, stabilizing air 

pockets and extending shelf life (Frank 2014). 

However, the only use for which mono- and diglycerides are permitted in organic food processing is in 

the drum drying of food. In this application, mono- and diglycerides can have various functions, but 

most significantly they act as an emulsifier and release agent. When mixed with food, mono- and 

diglycerides help prevent sticking during processing, and in drum drying they help to strip the food from 

the cylinder walls once dried. In drum drying, a puree or slurry of food is added to one or two heated 

cylinders at varying feed rates depending on the particular food’s viscosity. As the cylinders or drums 

rotate, the slurry dries. The process creates powder or very fine flakes that can serve as the basis for 

snacks, soups, baked chips, some bakery items and cereals (Fusaro 2012). The use of mono- and 

diglycerides in dehydrated potatoes also aids in rehydration (O'Brien 2004).

The direct-food uses for mono- and diglycerides under the FDA GRAS listing at 21 CFR 184.1505 include 

use as an emulsifier, dough strengthener, flavoring agent, adjuvant, lubricant, release agent, solvent, 

vehicle, thickener, active surface-agent and texturizer. 

History: Mono- and diglycerides were first added to the National List in 2002 after being recommended 
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by the NOSB at the April 1995 NOSB Meeting. Discussion at that meeting noted that the food industry 

was trying to move away from their use, but that the material was still necessary for potato flake 

products. Thus, the NOSB voted to recommend restricting its use to drum roll drying of food. The 

substance was reassessed during the Sunset review process in 2010 and the NOSB voted unanimously to 

recommend relisting it on §205.605(b). At that time, the NOSB did not find any evidence suggesting that 

proposed organic alternatives were favorable replacements. In their review of original 

recommendations, historical documents and public comments, the NOSB did not identify any 

unacceptable risks to the environment, human, or animal health as a result of the use or manufacture of 

the substance. The 2015 TR does not identify unacceptable human health or environmental risks.

International: Glycerides (mono and diglycerides) are permitted on the Canada Permitted Substances 

List, CAN/CGSB- 200 32.311 Table 6.3 “Non-organic Ingredients Classified as Food Additives” with the 

following annotation: “For use only in drum drying of products. Organisms from genetic engineering are 

excluded. Documentation is required. Shall be produced from organic sources unless not commercially 

available.”

Glycerides are not permitted for use in organic food processing in the EU, Japan or IFOAM

Alternatives: Glycerides are not universally used by drum drying operations. Alternatives for drying 

foods include spray drying, freeze drying, fluidized bed dryers, air lift dryers, etc. Drum drying is 

preferred for potato flakes. Freeze drying is said to be an acceptable alternative to drum drying. 

Organic soy lecithin and gum arabic could be alternative substances.

The NOSB requested the following information from stakeholders during the first posting of this 

material:

1. The subcommittee would like to better understand the extent of use of glycerides (mon- and di-) in 

drum drying. Are glycerides essential to organic food production? Describe the effects on your 

operation if glycerides were removed from the National List 

2. There appear to be many alternatives to use of glycerides for drum drying of foods, such as spray 

drying, freeze drying, fluidized bed dryers, air lift dryers, etc. Freeze drying is said to be an acceptable 

alternative to drum drying. Which of these alternatives have you found to be effective in your 

business?

Public comment yielded little additional information and some confusion in terms of use. One certifier 

noted that mono-and diglycerides are important emulsifiers in organic foods. Another certifier noted 

that mono and diglycerides are used in 6 personal care products that they certify.

There was no opposition to the continued listing of glycerides.

Motion to Remove

This proposal to remove glycerides (mono and di) will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Glycerides (mono and di) from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given
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Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin

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

Glycerin

Reference: 205.605(b) - produced by hydrolysis of fats and oils. 

Technical Report: 1995 TAP; 2013 TR

Petition(s): 1995 N/A, Glycerin (2012 Petition to remove)

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

In 2012 the NOSB received a petition to remove Glycerin from 205.605(b) and reclassify it as 

agricultural, and be listed at 205.606. 

Petitioner stated as follows: “....An important reason that glycerin produced by hydrolysis of fats and oils 

should have been included at §205.606 is that items listed at §205.606 are subject to the restriction that 

they can be used “only when the product is not commercially available in organic form.” Certified 

organic glycerin is currently available, but there is no “commercial availability” requirement to 

incentivize processors to use it or certifiers to require it. Consequently, glycerin should be removed from 

the National List in order to encourage organic agricultural production.” ....

This matter was discussed at length by the NOSB, and received considerable public comment over a 

period of two years, including presentation at the NOSB meetings in Spring and Fall 2014 and Spring of 

2015.

The NOSB proposal dated October 21 2014, included the following:

“....Because of the confusion around classification of glycerin (depending upon the manufacturing 

methods and source material), and the concerns regarding commercial availability of organically 

produced glycerin, the Handling Subcommittee, after significant discussion, is proposing the listing of 

glycerin at §205.606 and removal of glycerin from §205.605(b). ...”

In April 2015 the NOSB voted to remove Glycerin –produced by hydrolysis of fats and oils- from 

205.605(b)

The Handling Subcommittee proposes to remove Glycerin from 205.605(b), however, in order to ensure 

continuity of supply during Rulemaking based on NOSB votes of April 2015, we propose to renew this 

listing until Rulemaking is completed.

Motion to Remove

This proposal to remove Glycerin will be considered by the NOSB at its public meeting. 
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The Subcommittee proposes removal of Glycerin from the National List based on the following criteria 

in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: The Subcommittee 

proposes removal of Glycerin from the National List at 205.605(b) based its unanimous vote in April 

2015 to reclassify Glycerin as agricultural and List it at 205.606.

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin 

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

Hydrogen peroxide

Reference: 205.605(b)

Technical Report: N/A for handling use

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Hydrogen Peroxide is widely used as a disinfectant and bleaching agent. It is an effective and an 

environmentally benign substance used to reduce and control microorganisms for food safety purposes. 

It is critical for sanitizing aseptic packaging.

Discussion: The NOSB in its initial request for public comment asked:

Is hydrogen peroxide essential for organic food production? Since the material was last reviewed, have 

additional commercially available alternatives emerged? The Handling Subcommittee encourages 

current users of hydrogen peroxide to provide detailed comments describing the situations in which it is 

the most effective antimicrobial for a given application.

Public comment did not provide any alternatives. Several Handlers wrote in and stated that this product 

is essential for use in their OSP.

This material satisfies the OFPA Evaluation criteria

Motion to Remove

This proposal to remove Hydrogen Peroxide will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Hydrogen Peroxide from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given
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Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

Yes: 0 No: 4 Abstain: 0 Absent: 3 Recuse: 0 

Magnesium Carbonate

Reference: 205.605(b) — for use only in agricultural products labeled “made with organic (specified 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.

Technical Report: 1996 TAP

Petition(s): Magnesium Carbonate (2005)

Past NOSB Actions: 09/1996 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

This material was originally petitioned as a filter aid, but it is used as a flow agent in free flowing salt, 

ant-caking agent, color retention agent, drying agent, bleach additive in flour and cheese, and a color 

enhancer in canned green beans and peas.

Public comment indicates some processor use of the material. One NGO stated that it is not essential 

but since it is used only in “made with “ category it would not threaten organic integrity.

The material does not appear to be essential to organic handling. 

Motion to Remove

This proposal to remove magnesium carbonate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of magnesium Carbonate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable:

available alternatives/essentiality

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin

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

Reference: 205.605(b) – derived from sea water.

Technical Report: 1995 TAP

Petition(s):N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/1999 NOSB minutes and vote; 11/2005 

sunset recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

This material is used as a processing aid, coagulant/ firming agent in tofu production, but it can be used 

to dress cotton fibers, or as a color retention agent and other uses.

During initial Review the subcommittee requested public comment on whether or not this material 

should be re-classified as non-synthetic because it is derived from sea water by brine drying.

Public comment agrees that this material should be re-classified as non-synthetic and moved from a 

listing at 205.605 (b) to 205.605 (a).

The Handling Subcommittee will recommend that this material be re-classified as non-synthetic and 

listed on 205.605(a).

Public comment from tofu producers, trade associations and certifiers indicates that this material 

“makes a specific type of tofu texture that cannot be duplicated with other coagulants. Elimination from 

the National List would be extremely detrimental to all tofu manufacturers in the United States”.

The subcommittee also asked the public to provide information as to whether Nigari is an FDA allowed 

food ingredient, and did not receive clear public comment on this topic.

The TAP (1995) suggested that Magnesium chloride be listed only for specific uses. In 1999 when the 

“derived from sea water” annotation was made it was recommended that it be annotated for use only 

in tofu production.

In its initial review this year the Handling Subcommittee also asked whether this material should be 

annotated for use only in tofu production. Public comment indicated that at least one NGO

recommends an annotation “as a coagulant in making tofu”. Public comment suggests that while use of 

magnesium chloride for making tofu is consistent with organic practices, the use of this material for 

color enhancement may not be consistent with organic.

Motion to Remove

This proposal to remove magnesium chloride will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Magnesium Chloride from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable:

none given
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Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin

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

Magnesium stearate

Reference: 205.605(b) - for use only in agricultural products labeled “made with organic (specified 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Magnesium stearate is used as an anti-caking agent in salt. It is a flow agent, lubricant and may be an 

incidental additive. It is used as a lubricant, allowing manufacturers to produce more per hour as the 

machine can run faster. The most common use of magnesium stearate in the “made with” organic 

category is as a binding agent in dietary supplements.

Typically manufactured as a synthetic from hydrogenation of cottonseed or other vegetable oil. 

Produced by adding aqueous solution of magnesium chloride to sodium stearate. Stearic acid is made 

by saponification of edible fat (lye plus tallow) that is treated with an acid to form stearic acid. 

Alternatives: Organic flours and starches can replace magnesium stearate as an additive in some 

products. Non synthetic flow agents are available as alternatives, depending on the product and 

process.

In 2010 the Codex Committee on Food Additives recommended that magnesium stearate be deleted 

from Codex.

The Subcommittee in its initial review requested public comment on availability of alternatives and any 

information on possible negative human health impacts. Public comment was quite limited. Certifiers 

provided data on the number of processors using magnesium stearate. This is a relatively small number.

There was no information provided indicating any human health impacts and no comment 

recommending removing this material from the National List.

Magnesium stearate is allowed only in agricultural products labeled “made with organic’” and is 

prohibited in agricultural products labeled “organic” and the subcommittee recommends it’s continued 

listing.
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Motion to Remove

This proposal to remove magnesium stearate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Magnesium Stearate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Tracy Favre

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

Nutrient vitamins and minerals

Reference: 205.605(b) Nutrient vitamins and minerals, in accordance with 21 CFR 104.20, Nutritional 

Quality Guidelines For Foods. 

Technical Report: 1995 TAP - Minerals; 1995 TAP - Vitamins; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2011 

Handling Subcommittee Proposal; 04/2011 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/2017

Subcommittee Review 

Brief History of this issue

 In 1995 the NOSB added nutrient vitamins and minerals to the National list with the following 

annotation, ‘‘Accepted for use in organic foods for enrichment or fortification when required by 

regulation or recommended by an independent professional organization.’’ A second 

recommendation was also passed entitled ‘‘Final Recommendation Addendum Number 13, The 

Use of Nutrient Supplementation in Organic Food.’’ This stated, ‘‘Upon implementation of the 

National Organic Program (NOP), the use of synthetic vitamins, minerals, and/or accessory 

nutrients in products labeled as organic must be limited to that which is required by regulation 

or recommended for enrichment and fortification by independent professional associations.’’

 The final rule that was published in 2000 (65 FR 13512) came out with the current annotation. It 

was recognized soon after that the cross reference to the FDA’s fortification policy for food at 

21 CFR 104.20 was not accurate and that a correction to the current listing is necessary.

 The existing annotation is not what the original NOSB recommended in 1995. In 2011 the 
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Handling Subcommittee proposed to change the annotation at sunset but received 

approximately 2000 comments against it due to concerns about broadening the scope. The 

Subcommittee withdrew the proposal prior to the April 2011 NOSB meeting and the NOSB 

supported relisting with existing annotation for the 2012 sunset review. 

 In 2007 the NOP provided an interpretation of the regulation that mistakenly concluded that 21 

CFR 104.20 allowed a wide variety of nutrients that were not limited to just vitamin and 

minerals.

 In 2010 the NOP met with the FDA to clarify the meaning of the FDA guidance at 21 CFR 104.20. 

The NOP issued a memo to the NOSB in April 2010 explaining this clarification. 

 On January 12, 2012 a proposed rule was published in the Federal Register (77 FR 1980) to 

change the annotation to: 

§ 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or 

food groups(s)).’’ 

(b) Synthetics allowed

Vitamins and minerals. For food— vitamins and minerals identified as essential in 21 CFR 

101.9. For infant formula—vitamins and minerals as required by 21 CFR 107.100 or 

§ 107.10. 

 This proposed rule clarified that the "nutrients" that were not on these CFR sections had to be 

petitioned individually for the National List because this listing did not cover them.

 NOP did not finalize the proposed rule, but on September 27, 2012 published an Interim Rule 

(77 FR 59287), which renewed without change the original listing, as per the NOSB April 2011 

recommendation. 

 In 2011 through 2013 many other nutrients were petitioned. A few were recommended to be 

listed by the NOSB and most were not. No rulemaking has happened to add the recommended 

substances or clarify the current reference, so the prohibited ones are still in use and the 

allowed ones have not been added to the National List.

 In 2014 the Handling Subcommittee commissioned a new Technical Report in preparation for 

Sunset 2017 reviews. This was completed in February 2015. It clarifies a lot about which 

substances are required and permitted and which are covered by the 21 CFR citations or other 

regulations.

 Both the TR and the proposed rule are required reading to understand this issue.
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Discussion: It is clear from the long history of this issue that the annotation and possibly the name of 

the listing need to change. The NOP has not been able to proceed from their proposed rule and the 

previous changes suggested by the NOSB were not adopted. However this is a complicated issue and so 

the HS's approach will be to post a Discussion Document with some options for annotation changes so 

that a decision to change the annotation can be made as soon as possible after this sunset review. This 

discussion document will be posted separately for the Spring 2016 meeting.

The 2015 TR sheds light on a lot of information about vitamins and minerals that was not available to 

the NOSB before. The first key point is that some vitamins are produced through fermentation 

processes from agricultural or microbial starting points. This means that they are non-synthetic and 

should probably be listed on §205.605(a). The TR refers primarily to Vitamins D2, B2, B12, E, F, K, and C 

as being exclusively or probably non-synthetic.

Secondly, from both the TR and the 2012 proposed rule, the citation to 21CFR 104.20 is inaccurate and 

can be misleading. The correct citation is 21 CFR 101.9. The HS would favor the listing to be re-named 

and characterized as was suggested in the proposed rule: 

Vitamins and minerals. For food— vitamins and minerals identified as essential in 21 CFR 101.9. 

For infant formula—vitamins and minerals as required by 21 CFR 107.100 or § 107.10.

Since this is a huge group of different substances, the TR went into length about their manufacturing 

processes, effects on human health, effects on the environment and uses. There was no information 

among these pages that gave concern that these substances did not meet the review criteria. Likewise 

public comment was received with concerns about the unnecessary use of synthetic ingredients, but no 

new information was provided in comments from the first posting regarding the review criteria beyond 

the alternatives and compatibility issues.

Regarding alternatives, the primary alternative is for people to get their vitamins and minerals from the 

food itself rather than supplementation. Non-synthetic supplements, such as yeasts, can also provide 

some vitamins or minerals. However, there is well known data that show that food may not have as high 

level of vitamins and minerals as it used to because of soil depletion and other factors. Also humans are 

eating a lower portion of their diet consisting of fresh raw products and a higher amount of highly 

processed and non-nutritive foods and therefore are not getting enough vitamins and minerals. 

However it is unrealistic for organics to make up for all the deficiencies of the modern diet and lack of 

nutritive value must be balanced with consumers who wish to choose to consume fewer synthetic 

ingredients.

Finally there is information in the TR about the ancillary substances used in formulating vitamins and 

minerals. (2015 TR lines 229 - 324). The chart takes up more than a page from just one supplier of 

vitamins. As the TR says on lines 310 - 311, "These ancillary substances are GRAS. Good manufacturing 

practice (GMP) requires that they be used at levels that avoid unacceptable environmental, human 

health, and toxicological effects." Lines 700 and 701 of the TR states, "There is no literature to suggest 
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that the manufacture or use of vitamins and minerals with ancillary substances is harmful to the 

environment or to biodiversity." There may be a separate ancillary substance proposal presented at 

future date.

Motion to Remove

This proposal to remove Nutrient vitamins and minerals will be considered by the NOSB at its public 

meeting. 

The Subcommittee proposes removal of Nutrient vitamins and minerals from the National List based on 

the following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Zea Sonnabend

Seconded by: Harold Austin

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

Ozone

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Specific Uses of the Substance: Ozone is used as a disinfectant and in post-harvest treatment for 

produce to retard spoilage in cold storage or in wash water. It is effective and environmentally benign 

substance used to reduce and control microorganisms for food safety purposes.

Discussion: The NOSB in its initial request for public comment asked:

Is ozone essential for organic food production? Since the material was last reviewed, have additional 

commercially available alternatives emerged? The Handling Subcommittee encourages current users of 

ozone to provide detailed comments describing the situations in which it is the most effective 

antimicrobial for a given application.

Public comment did not provide any alternatives. Several Handlers wrote in and stated that this 

product is essential for use in their OSP.

This material satisfies the OFPA Evaluation criteria.
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Motion to Remove

This proposal to remove Ozone will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Ozone from the National List based on the following criteria in 

the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Zea Sonnabend

Yes: 0 No: 4 Abstain: 0 Absent: 3 Recuse: 0

Phosphoric acid

Reference: 205.605(b) - cleaning of food-contact surfaces and equipment only

Technical Report: 2003 TAP

Petition(s):N/A

Past NOSB Actions: 10/1999 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Specific Uses of the Substance: Phosphoric acid is used in cleaning operations to remove encrusted 

surface matter and mineral scale found on metal equipment such as boilers and steam producing 

equipment. Orthophosphoric acid is routinely used as a cleaning compound in its dilute form to remove 

oxidation from non-stainless steel surfaces, staining of stainless steel, lime and scale from heat 

exchangers and in Clean In Place cleaning operations especially in dairy processing to remove buildup of 

calcium and phosphate salts from processing equipment. 

Discussion: The NOSB in its initial request for public comment asked:

Is the substance essential for organic food production? Since the material was last reviewed, have 

additional commercially available alternatives emerged? The Handling Subcommittee encourages 

current users of phosphoric acid to provide detailed comments describing the situations in which it is 

the most effective cleaner for a given application.

Public comment did not provide any alternatives. Several handlers wrote in and stated that this product 

is essential for use in their OSP.

This material satisfies the OFPA Evaluation criteria.

Motion to Remove

This proposal to remove -phosphoric acid will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Phosphoric Acid from the National List based on the following 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Zea Sonnabend

Yes: 0 No: 4 Abstain: 0 Absent: 3 Recuse: 0 

Potassium acid tartrate

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Potassium acid tartrate is a bi-product of wine making. It is used in baked goods. Public comment 

indicates broad support for this material from producers and certifiers. 

No Public comment has been received which opposes its continued listing.

Motion to Remove

This proposal to remove potassium acid tartrate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of potassium acid tartrate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 0 No: 7 Abstain: 0 Absent: 0 Recuse: 0 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Potassium carbonate

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Potassium carbonate is a strongly alkaline white salt which is made by passing carbon dioxide through a 

solution of potassium hydroxide. It is a caustic material with chlorine gas a bi-product at manufacture 

collected to avoid environmental pollution and human health impacts. Historically it was potash.

Uses: pH control, leavening agent; can be a boiler water additive; used in soap production.

Commonly used in the Dutch alkali process for processing cocoa and chocolate to reduce acidity. Used 

in soft drinks and confections. Used as a buffering agent in making wine and mead. It is used to 

tenderize tripe.

The original TAP suggested that it be used only when sodium carbonate is not appropriate.

Public comment does not indicate that it is widely used. One certifier notes that it is used in the wine 

industry. No public comment was received opposing its continued listing.

Motion to Remove

This proposal to remove potassium carbonate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Potassium carbonate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

None given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Tracy Favre 

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

Potassium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s):N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Potassium citrate is manufactured from adding potassium bicarbonate and potassium carbonate to 

citric acid. It is an alkaline salt.

Uses: chelating agent, buffering agent, nutrient supplement, pH adjuster, flavor adjuvant, flavor 

enhancer, and as a medication.

Potassium citrate can be used to replace some phosphates in processing.

Public comment indicated support for this material remaining on the National List. There was no 

opposition to continued listing.

Motion to Remove

This proposal to remove potassium citrate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Potassium Citrate from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: none given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Ashley Swaffar

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

Potassium phosphate

Reference: 205.605(b) - for use only in agricultural products labeled “made with organic (specific 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”. 

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Potassium phosphate is used as a pH control in milk and dairy products; it is antimicrobial in yeast. The 

initial TAP included a recommendation to prohibit this material in products labeled “organic”, but 

approved its use in “made with” products.

International: Potassium phosphate is not listed in CODEX, does not appear on the EU, JAS or IFOAM
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

organic standards, but is listed in the Canadian organic standard for products in the 70%-95% category 

only.

Some Public Comment indicates that potassium phosphate is an efficient pH buffering substance with 

no organic alternatives. The industry indicated that potassium phosphate is used in non-dairy 

beverages; that it prevents precipitation and impaired mouthfeel; that the alternatives are not as good;

and loss of this product would mean impaired quality and marketability.

Public comment indicated a dramatically increased demand for phosphates in production of processed 

foods but that consumers are not necessarily aware of this increase in phosphorus intake because 

phosphorus may not appear on the nutritional panel. Without knowledge of phosphorus amounts in 

each organic product where phosphates are added, the consumer cannot make an informed choice. 

Other commenters recommended removal based on lack of essentiality and incompatibility with organic 

agriculture.

Public comment also raises new information relating to possible negative human health impacts 

associated with the cumulative effect of phosphates used as food additives. One organization stated 

“recent studies have shown that inorganic forms of phosphate, such as calcium and sodium phosphate, 

cause hormone mediated harm to the cardiovascular system.” Other commenters provided examples 

of peer reviewed research indicating that the cumulative effects of phosphates as a group contributing 

to renal damage and failure, osteoporosis and heart failure. Such public commenters recommended 

either removal from the National List or at least an annotation to eliminate uses prohibited by 205.600 

(b) (4) to ensure the OFPA criteria is met. Clinical studies appear to indicate that while the phosphorus 

content of each processed product may be low, and not in itself detrimental to human health, the 

cumulative effect of consuming many products with added phosphates as ingredients, may be 

considerable.

There are 5 phosphates on the National List at 205.605(b). No single phosphate food additive or 

ingredient can be implicated as an isolated risk factor. Concerns arise from the increase in cumulative 

use of phosphates and possible health effects on the general population. Given the new information 

and research since last Sunset Review, the Handling Subcommittee has requested a new Technical 

Report which should clarify the probability of negative human health effects resulting from the 

cumulative effect of phosphates in food products at various dose levels over time on the population as a 

whole, and alternative materials. Given that this TR may not be received in time for the Fall 2015 

meeting, the HS recommends voting on this material at the Fall 2015 meeting, but, should the TR 

indicate probable cumulative negative health effects from phosphates, the HS would make a new 

proposal to review all phosphates again at the Spring 2016 meeting.

Motion to remove:

This proposal to remove potassium phosphate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of potassium phosphate from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

Effect of the substance on human health, essentiality, and its compatibility with a system of sustainable 

agriculture.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 3 No: 2 Abstain: 1 Absent: 1 Recuse: 0

Sodium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Specific Uses of the Substance: Sodium citrate is used as an emulsifier in dairy products to keep fats 

from separating, and in cheese making where it allows the cheeses to melt without becoming greasy. 

Approved Legal Uses of the Substance: Sodium citrate is listed under 21 CFR Part §184.1751 as 

Generally Recognized as Safe (GRAS). The listing allows its production from citric acid and sodium 

hydroxide or sodium carbonate. It is allowed as an ingredient used in food with no limitation other than 

current good manufacturing practice.

The EPA lists citric acid and its salts in the 2004 List 4A (minimal risk inerts). 

International: The citrate salts are generally listed as allowed in the following international organic 

standards, but with restrictions associated with their usage. Canada: Sodium citrate is restricted to use 

with sausages or milk products (Table 6.3). CODEX: Sodium citrate is listed in Table 3 for 

sausages/pasteurization of egg whites/milk products. EU: Sodium citrate (E331) is allowed under EC 

889/2008 Section A as an ingredient in the preparation of foods of animal origin. JAS: Sodium citrate is 

allowed, but limited to use for dairy products, or for albumen and sausage as low temperature

pasteurization (Table 1). IFOAM: The calcium, potassium and sodium citrates are allowed as additives.

Discussion: The Subcommittee stated in Meeting 1 that it is considering removing this material from 

the National List based on availability of alternatives that include citric acid and potassium citrate. The 

Subcommittee and asked those using this material to comment on whether an alternative material 

would be sufficient in their operation, and to comment on whether a removal of sodium citrate from 

the National List would have an impact on their operation.

Several commenters in favor of relisting stated:

• Sodium citrate is a common, safe material that is used in many organic cheeses. It binds 

calcium, reduces acidity and works as an emulsifier to provide a smooth texture to organic 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

cheeses. We use organic cheese ingredients that contain sodium citrate in our products. We 

also use sodium citrate for buffering (acid control) in organic sauces. Potassium citrate is an 

option, but it has an unpleasant metallic taste. Sodium phosphates are another options, but 

they need to be used in higher quantities and are not as effective. We request that sodium 

citrate remain on the national list. 

• Sodium citrate is a processing aid used by a number of our brands. It is used in both "organic" 

and "made-with organic" products. It is used in fruit snacks, milk based drinks, plant based 

yogurt and plant based frozen desserts. To date, we have not found an alternative that works in 

our products. We did some initial research at the retail level, and found sodium citrate listed in 

at least four other organic food brands' products.

• We use sodium citrate as part of the process of preparing fresh fruit for use in our yogurts. We 

are concerned about the potential impacts of removing sodium citrate from the National List 

because neither citric acid nor potassium citrate would have the same effect in our fruit. We use 

sodium citrate primarily for its ability to buffer pH, but we know that it also does have an effect 

on the flavor of our products. Neither citric acid nor potassium citrate would have the same 

buffering effect in our products. We already use citric acid, in addition to sodium citrate, in our 

fruit so we know that we need these ingredients for entirely different purposes and one could 

not substitute for the other. It is harder to predict the outcome of trying to substitute potassium 

citrate for sodium citrate in our products, but we do know that it would pose a considerable 

reformulation challenge.

• Sodium citrate is used in a personal care product (lubricant). We have no information as to 

whether the alternatives listed are practical replacements or not.

• A Trade Association provided the following comments from members:

• Plant based dessert, plant based ice cream, plant based yogurt, organic fruit snacks, organic 

fruit gummies, 95%+ organic and made-with. Certified for over 20 years. Products sold in all 50 

states. Used for cream plug in cream, emulsifier, and as a processing aid. We have not found 

any alternatives. Essential.

• Cheese, cheese and dairy powders and seasonings. Certified for over 15 years. Products sold in 

Wisconsin, Pennsylvania, Missouri, & South Dakota. Finished products are sold throughout the 

U.S. Used for the emulsification of cheese. Sodium phosphates are an alternative, but they are 

being considered for removal as well. Currently use sodium phosphate, but it is being 

considered for removal as well. We would not be able to manufacture our products without this 

ingredient. Loss of this substance would result in the loss of all organic business. Entire business 

unit eliminated. Ingredient is essential.

• Used in the preparation of fruit for use in our yogurts. Products are sold in all 50 states. We use 

sodium citrate primarily for its ability to buffer pH, but we know that it also does have an effect 

on the flavor of our products. Neither citric acid nor potassium citrate would have the same 

buffering effect in our products. We already use citric acid, in addition to sodium citrate, in our 

fruit so we know that we need these ingredients for entirely different purposes and one could 

not substitute for the other. It is harder to predict the outcome of trying to substitute potassium 

citrate for sodium citrate in our products, but we do know that it would pose a considerable 

reformulation challenge. Essential

• Fruit Snacks 50 MM dollar business. Certified since 2002. Products in 50 states. Used for pH 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Buffer; critical for gel structure and flavor. For organic fruit snacks it helps the product solidify. 

Otherwise, it remains a liquid and we have not found another material that works for us. We are 

initiating an investigation on an alternative solution but do not know of one at this time. 

Ingredient is essential

• Gummy confections, gummy nutritional supplements, panned jelly beans. Products are 

distributed around the U.S. and have been certified for up to 20 years. Used as an acidulant, 

flavor and sodium source. One facility uses both citric acid and potassium citrate. However, only 

the function can be obtained with sodium citrate in specific products. Allowed organic 

alternatives are not available. Products using this ingredient will have a decrease in quality and 

function if this material is removed. Any production loss due to decrease in quality would 

impact the economic health of the operation. Companies would not be able to manufacture 

products without this ingredient. Ingredient is essential.

One comment was received opposing relisting:

• Citric acid should be re-classified as synthetic, or annotated to require use of processes that do 

not involve synthetic chemical reactions. If truly non-synthetic citric acid is available, then 

synthetic citric acid should not be allowed. If non-synthetic citric acid is not available, then the 

use of synthetic citric acid –and the citrates—should be restricted to uses that are in compliance 

with §205.600(b)(4).

The subcommittee received several comments from stakeholders using sodium citrate supporting the 

relisting. Comments were received stating that handlers could not continue manufacturing specific 

products without the continued listing of sodium citrate. The Handling Subcommittee will further 

review comments during the next comment period specifically looking for any alternatives to sodium 

citrate. If any stakeholder knows of a suitable alternative to sodium citrate please submit written or 

public to the subcommittee.

This material satisfies the OFPA Evaluation criteria and the Handling subcommittee supports the 

relisting of sodium citrate.

Motion to Remove

This proposal to remove sodium citrate will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of sodium citrate from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

Yes: 0 No: 7 Abstain: 0 Absent: 0 Recuse: 0 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sodium hydroxide

Reference: 205.605(b) - prohibited for use in lye peeling of fruits and vegetables.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Sodium hydroxide is an extremely caustic and toxic material. It was traditionally made by running water 

through wood ash. It is also known as caustic soda or lye.

Uses: Processing aid to adjust pH. Used in production of pretzels and cocoa. Alters proteins and starch 

so that the surface of pretzels become smooth and brown in baking. May also be used in olive 

processing to reduce bitterness of some varieties of green olives. May also be used as a cleaning agent. 

Used in the paper industry in chemical pulping and tissue digestion. Broad range of uses in food 

production from poultry scalding to soft drinks processing, ice cream thickener. Because it is not always 

easy to obtain food grade sodium hydroxide sodium carbonate is often used instead of sodium 

hydroxide. Hominy corn (maize) kernels are reconstituted using sodium hydroxide to make grits.

Public comment from processors indicates strong support for continued listing. No public comment 

indicates opposition to continued listing.

Motion to Remove

This proposal to remove sodium hydroxide will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of sodium hydroxide from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 0 No: 7 Abstain: 0 Absent: 0 Recuse: 0
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sodium phosphates

Reference: 205.605(b) - for use only in dairy foods.

Technical Report: 2001 TAP

Petition(s): 1995 N/A, 2001 Sodium Phosphate

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/2001 NOSB minutes and vote; 11/2005 sunset 

recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

The material was added in 1996 with the “dairy use only” annotation. The material is derived from 

phosphoric acid.

Uses: Acidity control agent, antimicrobial, boiler water additives, sequestrants, texturizer, nutrient, and 

dietary supplement. Prevents separation of water and fat in cheese; emulsifier in non-fat cheese and 

milk; creates organoleptic characteristics not otherwise present.

Use in the soy processing was not added to the range of uses permitted for sodium phosphates because 

the reviewers found that the petitioner did not adequately justify its essentiality.

The petition, dated March 21, 2001, was a request from the manufacturer for use of sodium phosphate 

in “Food and Beverage Products formulated with Soymilk and Dry Soymilk Similar to or equivalent to 

Dairy Products.” A Technical Panel Report was requested.

TAP, dated September 21 2001, indicates a lack of consensus of the use of these orthophosphates (mondi- and tri sodium phosphate). One reviewer suggested prohibition based on review of all OFPA criteria; 

one reviewer suggested use only as limited by 21 CFR requirements. Another reviewer suggested that it 

be listed with stringent conditions on all uses of sodium orthophosphates, which would allow all FDA 

permitted uses, but only with a case by case determination of need, essentiality, nutritional impact and 

alternatives.

The TAP Review (2001) notes that “toxicity of sodium phosphates is generally related to sequestration 

of calcium and the subsequent reduction of ionized calcium. It is an irritant, and ingestion may injure 

the mouth throat and gastrointestinal tract, resulting in nausea, vomiting, cramps and diarrhea” (p 5). 

Other human health/medical impacts were noted by TAP reviewers related to use of phosphates as 

bowel purgatives and cleansers. The also noted low calcium reported in susceptible individuals (TAP p 

6). 

The relationship between sodium phosphate and calcium sequestration raises issues of concern given 

that use of this material is for use only in dairy products. When calcium combines with phosphate the 

body’s ability to absorb calcium is reduced. Phosphates also combine with iron and magnesium and 

perhaps niacin.

There appear to be a number of alternatives that could be used such as lecithin, agar, alginic acid, 

pectins and gums.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

International: Sodium phosphates are permitted on the Canadian organic standards’ list for dairy 

products only, but not listed in the following organic standards: EU, CODEX, IFOAM or JAS.

Public comment: Public comment from industry indicates support of this material, especially as an 

emulsifier in cheese production where its use is considered essential. It is also considered essential in 

making high protein smoothies, stabilizing the texture of the product. Another comment indicates its 

use as a chelating/buffering agent in ultra-pasteurized heavy cream, reducing production time.

Public comment indicated a dramatically increased demand for phosphates in production of processed 

foods but that consumers are not necessarily aware of this increase in phosphorus intake because 

phosphorus may not appear on the nutritional panel. Without knowledge of phosphorus amounts in 

each organic product where phosphates are added, the consumer cannot make an informed choice. 

Other commenters recommended removal based on lack of essentiality and incompatibility with organic 

agriculture.

Public comment also raises new information relating to possible negative human health impacts 

associated with the cumulative effect of phosphates used as food additives. One organization stated 

“recent studies have shown that inorganic forms of phosphate, such as calcium and sodium phosphate, 

cause hormone mediated harm to the cardiovascular system.” Other commenters provided examples 

of peer reviewed research indicating that the cumulative effects of phosphates as a group contributing 

to renal damage and failure, osteoporosis and heart failure. A brief literature review shows clinical 

research from 2010 (Journal of Kidney Disease: April 2010 4(2):89-100), and 2013 (Sim et al, American 

Journal of Medicine, January 2013) suggesting potential serious renal impacts in subjects with normal 

renal function, from cumulative phosphorus, and specifically from cumulative impact of sodium 

phosphate. A daily limit of 70 mg/kg/day was recommended in one study.

Such public commenters recommended either removal from the National List or at least an annotation 

to eliminate uses prohibited by 205.600 (b) (4) to ensure the OFPA criteria is met. Clinical studies 

appear to indicate that while the phosphorus content of each processed product may be low, and not in 

itself detrimental to human health, the cumulative effect of consuming many products with added 

phosphates as ingredients, may be considerable.

In Conclusion: There are 5 phosphates on the National List at 205.605(b). No single phosphate food 

additive or ingredient can be implicated as an isolated risk factor. Concerns arise from the increase in 

cumulative use of phosphates and possible health effects on the general population. Given the new 

information and research since last Sunset Review, the Handling Subcommittee has requested a new 

Technical Report which should clarify the probability of negative human health effects resulting from 

the cumulative effect of phosphates in food products at various dose levels over time on the population 

as a whole, and alternative materials. Given that this TR may not be received in time for the Fall 2015 

meeting, the HS recommends voting on this material at the Fall 2015 meeting, but, should the TR 

indicate probable cumulative negative health effects from phosphates, the HS would make a new 

proposal to review all phosphates again at the Spring 2016 meeting.

Further, the subcommittee seeks clarification about which dairy food products have sodium phosphate 

as an ingredient, or as a processing aid and whether or not the material is always listed on the label or 

appears on the nutritional panel?
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Motion to Remove

This proposal to remove sodium phosphates will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of sodium phosphates from the National List based on the 

following criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: 

Effect of substance on human health; essentiality; compatibility with a system of sustainable agriculture.

Vote in Subcommittee

Motion by: Jean Richardson

Seconded by: Harold Austin 

Yes: 1 No: 4 Abstain: 1 Absent: 1 Recuse: 0

Sulfur dioxide

Reference: 205.605(b) for use only in wine labeled “made with organic grapes,” Provided, That, total 

sulfite concentration does not exceed 100 ppm. 

Technical Report: 1995 TAP; 2011 TR

Petition(s): 1995 N/A; 2010 Sulfur Dioxide

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation; 12/2011 petition review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Use: Sulfur dioxide is used to prevent spoilage and oxidation in wine. Sulfur compounds have long been 

an integral part of traditional winemaking, and some sulfur dioxide is naturally occurring in grapes. 

Sulfites are used to prevent oxidation and to halt malolactic fermentation. Wines without added sulfites 

have a very short shelf life and must be kept in optimized storage conditions in order to remain viable. 

The use of sulfur dioxide in organic products is strictly limited to wine production and those products 

may only be labeled as “Made with organic grapes.” The NOP provides guidance on the use of sulfur 

dioxide in wines made with organic grapes in Policy Memo 10-2.

Manufacture: According to the 2010 technical report: The most common method of production occurs 

by burning sulfur, but sulfur dioxide can be produced by purifying and compressing sulfur dioxide gas 

from smelting operations (ATSDR, 1998). Sulfur dioxide has been produced by burning molten sulfur in a 

special burner with a controlled amount of air. The burner gas, free of dust and cooled, is dissolved in 

water in a series of two towers. In a third tower, the solution is sprayed at the top and flows down while 

steam is injected at the base. The gas issuing from the third tower is then cooled to remove most 

moisture and passed up a fourth tower against a countercurrent of sulfuric acid. The dried gas is 

liquefied by compression
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

International: The use of sulfur dioxide is allowed in wines and some other alcoholic products under 

the following organic standards: Canadian, EU, IFOAM and Codex. These Japanese Agricultural 

Standards (JAS) do not apply to alcoholic products. According to the 2010 technical report: “The 

Canadian organic standard permits the use of sulfurous acid (sulphurous acid) as a preservative only in 

alcoholic beverages labeled as organic made from grapes or other fruit. The minimum use of sulfur 

dioxide is recommended, however labeling wines containing sulfites as ‘organic’ is permitted. The 

maximum allowable level of sulfur dioxide in alcoholic beverages with less than five percent residual 

sugar is 100 ppm and 30 ppm for total sulfites and free sulfites, respectively. In alcoholic beverages with 

five percent or more and less than ten percent residual sugar, 150 ppm and 35 ppm, respectively, are 

permitted. In alcoholic beverages with ten percent or more residual sugar, 250 ppm and 45 ppm 

respectively, are permitted.... The European Economic Community (EEC) permits the use of sulfur 

dioxide in fruit wines without added sugar (including cider and perry) or in mead labeled as organic. The 

maximum permissible level of sulfur dioxide in these products is 50 mg/L. In this context, ‘fruit wine’ is 

defined as wine made from fruits other than grapes. The maximum permissible level of sulfur dioxide in 

cider and perry prepared with addition of sugars or juice concentrate after fermentation is 100 mg/L 

(EEC 889/2008, 2008). Sulfur dioxide is listed as an acceptable food additive in wine, cider, perry, and 

mead labeled as organic by the CODEX Alimentarius Commission (CODEX Alimentarius Commission, 

2010; GL 32-1999). Sulfur dioxide is permitted for use in making cider and perry (14.2.2), grape wines 

(14.2.3) and wines made with fruit other than grapes (14.2.4). Sulfur dioxide is also acceptable for use in 

mead (14.2.5).”

Ancillary Substances: No ancillary substances were mentioned in the 2010 technical report or by public 

comment.

Discussion: In 2010, a petition was submitted to remove the restrictive annotation limiting the use of 

sulfur dioxide to wines “made with organic grapes,” effectively expanding the use of sulfur dioxide to all 

organic wines. A motion to amend this annotation at the Fall 2011 NOSB meeting did not pass. The 

handling subcommittee did not ask any specific questions about the substance. Limited public 

comment was received noting the substance was used as a preservative but its limited to the “made 

with...” category did not threaten organic integrity. The substance satisfies OFPA criteria. 

Motion to Remove

This proposal to remove sulfur dioxide will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of sulfur dioxide from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: None given

Vote in Subcommittee

Motion by: Tom Chapman

Seconded by: Harold Austin 

Yes: 0 No: 7 Abstain: 0 Absent: 0 Recuse: 0
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Tocopherols

Reference: 205.605(b) derived from vegetable oil when rosemary extracts are not a suitable alternative

Technical Report: 1995 TAP; 2015 limited scope TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Mixed tocopherols for use as antioxidants in foods or animal feeds are manufactured in liquid and 

powder forms. They are commonly extracted from distillates of vegetable oils. Tocopherols are 

separated from the other compounds in the oil distillate by multiple extraction and refining steps. 

Tocopherols are added to foods to help prevent oxidation of the fatty acids present in the lipid 

components of the food. Tocopherols are one of the main sources of Vitamin E. 

In the first 2017 Sunset public posting for tocopherols, a table from the most recent Technical Review 

(TR) showed some of the more common formulations along with their ancillary substances. The 

Handling Subcommittee sought public comment on the following: 

1. The following table shows ancillary substances used in common tocopherol formulations. 

Please provide information as to whether these ancillary substances or others are also used in 

organic tocopherol formulations. 

There were no direct responses to the question posed, however some additional ancillary substances 

were identified. Public comment was divided on the relisting of tocopherols, with some comments 

stating that the material’s primary use is as a preservative and therefore inconsistent with organic 

production. Additionally, commenters asserted that non-synthetic tocopherols are commercially 

available and should be used instead of synthetic. However, the majority of comments were strongly in 

favor of relisting, stating that tocopherols are critically essential to maintaining food safety, preventing 

rancidity and providing nutrients to their products. Some comments stated the use of rosemary oil 

imparted off flavors or fragrances to their products that were not acceptable to consumers. 

Further, some comments addressed the issue of ancillary substances and stated that due to the myriad 

formulations required for some technical and functional effects, they would not be in favor of 

restrictions on the ancillary substances used in tocopherol formulations. 

Given the feedback on the commercial availability of non-synthetic tocopherols, the Handling 

Subcommittee is considering a proposal to reclassify tocopherols to 205.605(a) and seeks input on how 

that might impact organic producers. 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Motion to Remove

This proposal to remove tocopherols will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of tocopherols from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: Compatibility

Vote in Subcommittee

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

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

Xanthan gum

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review 

Xanthan gum is an extracellular polysaccharide derived from a microorganism through a fermentation 

process followed by purification. It is used in many products as a thickener and stabilizer. Its unique 

advantages over other gums are that it can be used in lesser quantities that enable products to comply 

with the 95% organic rule, and that it works well at low temperatures so that heating can be avoided.

One supplier pointed out that xanthan gum is produced in a very similar fashion to gellan gum and 

therefore should be considered non-synthetic and moved from 205.605 (b) to 205.606(a). Other 

commenters agreed that the fermentation is an allowed non-synthetic process and the extraction steps 

with alcohol do not chemically change to xanthan gum and are not present in the final product to have a 

functional effect.

On the other hand, some public interest commenters believe that more guidance is needed before 

determining that fermentation is always a natural process and that xanthan gum should have a new 

Technical Review before making such a change or renewing it on the National List.

Information was brought up about the potential harm to premature infants, citing a link between one 

product containing xanthan gum and infants developing necrotizing enterocolitis. This particular 

situation unfolded between 2011 and 2013 and caused the recall of the formulated product from one 

(of several) plants producing it because of likelihood of contamination of the product with other 

bacteria. While it was deemed inconclusive whether the problem came from the xanthan gum itself, the 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

other ingredients in this one product's formula, or outside contamination, there is not a clear enough 

research link here on xanthan gum to warrant removal from the National List. It could however be 

suggested to not feed xanthan gum to premature infants.

The only ancillary substance identified for xanthan gum is guar gum. Because guar is already on the 

National List, there is no supplemental ancillary substance proposal at this time.

Motion to Remove

This proposal to remove Xanthan gum will be considered by the NOSB at its public meeting. 

The Subcommittee proposes removal of Xanthan gum from the National List based on the following 

criteria in the Organic Foods Production Act (OFPA) and/or 7 CFR 205.600(b) if applicable: Act (OFPA) 

criteria 7 U.S.C. 6518(m)(6) the alternatives to using the substance in terms of practices or other 

available materials: and (7) its compatibility with a system of sustainable agriculture.

Vote in Subcommittee

Motion by: Zea Sonnabend

Seconded by: Harold Austin

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