Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Wednesday, January 9, 2013, 1:00 pm EST

Present: John Foster (Chair) (JFo), Zea Sonnabend (ZS), Carmela Beck (CBe), Mac Stone (MS) - sitting in, 

Tracy Favre (TF), Joe Dickson (JD), Nick Maravell (NM)

Absent: Jean Richardson (JR), Harold Austin (Vice-Chair) (HA)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydan

toin (DBDMH)

205.605(b) JFo Yes Yes Spr

2013

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor for 

revision. TR sent to HS 07 19 12. Due no 

later than Sept 30. TR was accepted by NOP 

as sufficient as is and posted ~11 06 12

Barley 

Betafiber 205.606 JFo Yes Yes Spr 

2013

12 18 12 Revised petition sent to HS on 6/20/11; TR 

accepted as sufficient 4/30/12. TR Posted 

07 25 12

Sugar Beet 

fiber 205.606 JFo/

ZS Yes Yes Spr 

2013 12 18 12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605

(b) JD Yes Yes Spr 

2013 01 09 13

Petition sent to Subcommittee 8/17/2010; 

TR Requested 11/15/2011. Draft TR sent to 

HS 05/01/12. Deemed sufficient 11 06 12. 

TR posted ~11 06 12

2012 Formal NOSB recc

2006 Formal NOSB recc

Sodium 

gluconate 205.605 JD Yes No On 

hold

Petition sent to HS on 3/22/2011; for use in 

soap; TR Requested 11/15/2011. On hold, 

for cosmetic use.

Bergamot 

Bitter Orange 

Powder

205.606 TF Yes Yes On 

hold

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 10/27/11. 

TR sent to HS on 2/16; Updated TR sent to 

HS 04 30 12. TR posted 06/25/12. On hold.

Gibberellic 

acid 205.605 ZS, 

TF Yes Yes Fall

2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 09/27/12. 

Sent back to petitioner for additional 

questions 01 09 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

2012

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No NA Fall

2013 

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper. 2012 

Petition sent to HS 11/06/12. Petition 

Sufficiency Response Due Date: 01/27/13. 

Petition found sufficient 12 18 12. No TR 

requested 

Glycerin

removal 

from 

205.605

TF 199

5 TR ?

Petition sent to HS on 01 09 13. Sufficiency 

response due 03 11 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meetin

g

Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/”other” 

ingredients (2012 disc 

doc)

ZS Spr 2013 Proposal spring 2013. 

* Highlight indicates committee action needed. 

Agenda

• Approve notes from December 18, 2012

• Discuss/vote on sulfuric acid proposal (JD)

• Continue discussion of ammonium hydroxide checklist (JR)

• Discuss Glycerin petition

• Continue discussion on auxiliary/”other” ingredients (ZS)

• Discuss sunset 2015 materials and next steps

Discussion

• Notes from December 18, 2012 were approved with no changes.

• Sulfuric Acid –based on the previous discussion the checklist was completed and an introduction 

was added. The group weighed the environmental impacts of the production of the material vs.

usage of material to produce a seaweed extract, and felt that the due to the limited scope of the 

petition it was not possible to determine. The group discussed the fact that a substantial 

amount of Confidential Business Information (CBI) has been redacted and noted that the TR, 

was also not able produce any additional information regarding need, alternatives, and whether 
use of the substance will result in seaweed extract being classified as synthetic. Without 

knowing what the resulting product is, the group feels they are not likely to approve this 

substance. 

Vote on sulfuric acid:

Motion to classify sulfuric acid as petitioned as synthetic: 

Motion by: JD

Seconded by: JFo

No further discussion

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Motion to list sulfuric acid as petitioned on 205.605 (b)

Motion by: JD

Seconded by: TF

No further discussion

Yes: 0 No: 8 Abstain: 0 Absent: 0 Recuse: 0

The chair will circulate the discussion and voting count to the absent members for an email vote

and ask for their response. ABS note: HA and JR voted January 13 via email and the votes above 

were changed to reflect that. 

• Ammonium hydroxide discussion will be delayed until the January 15 call. A formal checklist

needs to be completed, including a summary and questions to solicit public comment about the 

claim in the petition that ammonium hydroxide can be used as a substitute for three other 

substances on the National List (see petition, item # 12 on page 12). 

• The group discussed the addition of glycerin to the workplan (petition to remove from 

§205.605) and TF volunteered to take the lead for the review. TR will determine petition 

sufficiency and whether or not a TR is necessary.

• The members discussed the 2015 Sunsets. Tragacanth: 5 years ago there was no concern or 

question about this material. Gellan gum: the NOP received comments about the manufacturing 

method so they added an annotation to limit it to high-acyl (deemed nonsynthetic) forms only. 

Marsala and sherry: it was noted that these items might contain sulfites, which the past NOSB 

considered but decided to put forth a recommendation without annotation. A member

indicated that Marsala can be made organically with a little advanced notice. Another member 

responded that the determination would be the responsibility of the certifiers and perhaps 

shouldn’t be an NOSB decision, to which another member argued that the NOSB is responsible 

for determining whether or not there is an organic alternative. EBR noted that the group should 

look at the previous recommendations to inform their decisions. Lead reviewers were assigned 

to the sunset materials and are noted in the table above.

Future Call Schedule:

December 18, 2012 1:00 EST

Vote on Sugar Beet fiber (JFo/ZS) - done

Vote on Barley Betafiber (JFo) - done

Ammonium hydroxides - discussion delayed to January 9th call

Discuss framework for sulfuric acid (JD) - 

Discuss gibberellic acid (ZS) - sending back to petitioner for further info, so will be delayed to a 

later meeting 

Continue discussion on auxiliary/”other” ingredients (ZS)

January 9, 2013 1:00 EST

Vote on Sulfuric Acid proposal (JD)
Continue discussion of ammonium hydroxides checklist (JR) 

Continue discussion on auxiliary/”other” ingredients (ZS)

Discuss sunset 2015 materials and next steps

January 15, 2013 1:00 EST

Discuss/vote on DBDMH (JFo)

Continue discussion of ammonium hydroxide checklist (JR)

Continue discussion on auxiliary/”other” ingredients (ZS)

February 5, 2013 1:00 EST

Final discussion and vote on auxiliary/”other” ingredients

February 19, 2013 1:00 EST

March 5, 2013 1:00 EST

March 19, 2013 1:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Wednesday, January 15, 2013, 1:00 pm EST

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Carmela Beck 

(CBe), Tracy Favre (TF), Nick Maravell (NM)

Absent: Jean Richardson (JR), Joe Dickson (JD)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydan

toin (DBDMH)

205.605(b) JFo Yes Yes Spr

2013

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor for 

revision. TR sent to HS 07 19 12. Due no 

later than Sept 30. TR was accepted by 

NOP as sufficient as is and posted ~11 06 

12

Barley 

Betafiber 205.606 JFo Yes Yes Spr 

2013

12 18 

12

Revised petition sent to HS on 6/20/11; TR 

accepted as sufficient 4/30/12. TR Posted 

07 25 12

Sugar Beet 

fiber 205.606 JFo/

ZS Yes Yes Spr 

2013

12 18 

12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605

(b) JD Yes Yes Spr 

2013

01 09 

13

Petition sent to Subcommittee 8/17/2010; 

TR Requested 11/15/2011. Draft TR sent 

to HS 05/01/12. Deemed sufficient 11 06 

12. TR posted ~11 06 12

2012 Formal NOSB recc

2006 Formal NOSB recc

Sodium 

gluconate 205.605 JD Yes No On hold

Petition sent to HS on 3/22/2011; for use 

in soap; TR Requested 11/15/2011. On 

hold, for cosmetic use.

Bergamot 

Bitter Orange 

Powder

205.606 TF Yes Yes On hold

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 10/27/11. 

TR sent to HS on 2/16; Updated TR sent to 

HS 04 30 12. TR posted 06/25/12. On hold.

Gibberellic 

acid 205.605 ZS, 

TF Yes Yes Fall

2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 09/27/12. 

Sent back to petitioner for additional 

questions 01 09 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d?

Mtng Vote? Notes*

2012

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No NA Fall

2013 

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 18 

12. No TR requested 

Glycerin

removal 

from 

205.605

TF

19

95 

TR

?

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meetin

g

Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/”other” 

ingredients (2012 disc 

doc)

ZS Spr 2013 Proposal spring 2013. 

* Highlight indicates committee action needed. 

Agenda

• Approve notes from January 9, 2012

• Discuss/vote on DBDMH (JFo)

• Continue discussion on auxiliary/”other” ingredients (ZS)

Discussion

• Notes from January 9, 2013 were approved with no changes.

• DBDMH is being petitioned as an antimicrobial for beef carcasses. Although the petition was 

found sufficient, it didn’t present a strong argument for essentiality or discuss alternatives. The 

members discussed potential negative health impacts, and impacts to safe drinking water, 

neither of which was very clear in the TR. Members also discussed the post-use products of 

DBDMH and their environmental impact and felt that there was not much support for this 

material. It was also noted that there are alternative materials available. DBDMH is prohibited in 

the EU, and not used internationally. The NOP noted that there are a couple of words missing in 
the TR on line 368 that have since been added, and the document was reposted on the website. 

The group also discussed the checklist (an updated version) and noted that there was no 

summary included. The chair of the Subcommittee will add an introduction as well as a synopsis 

of the discussion and will recirculate the document via email for voting.

 

Vote on DBDMH via email on: (ABS note Jan 25: vote will be taken during Jan 29 call instead of 

via email)

• Auxiliary/”other” ingredients - ZS and the NOP made some edits to various sections of the 

document including the discussion, baseline criteria, policy and agricultural sections via email 

and the new document was recirculated to the group for discussion. EBR will also provide some

language regarding GRAS (Generally regarded as safe). ZS asked for additional input about the 

baseline criteria section as well as the last bullet point: materials listed on 605 and 606 are 

synthetic additives. JFo added that this specific language seems too restrictive and could hinder 

future reviews, so the group chose to delete the last paragraph. ZS will incorporate the changes 

and resend the document to the group. 

• MA will add an extra Subcommittee call on Jan 29 at 1:00 pm (added below)

Future Call Schedule:

January 15, 2013 1:00 EST

Discuss/vote on DBDMH (JFo)-vote delayed 

Continue discussion on auxiliary/”other” ingredients (ZS)

January 29, 2013 1:00 EST

Vote on DBDMH

Continue discussion on auxiliary/”other” ingredients (ZS)

February 5, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

Final discussion and vote on auxiliary/”other” ingredients

February 19, 2013 1:00 EST

March 5, 2013 1:00 EST

March 19, 2013 1:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013
Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, January 29, 2013, 1:00 pm EST

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Carmela Beck 

(CBe), Tracy Favre (TF), Nick Maravell (NM), Jean Richardson (JR), Mac Stone (MS) - sitting in

Absent: Joe Dickson (JD)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydan

toin (DBDMH)

CAS # 77-48-5

205.605(b) JFo Yes Yes Spr

2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor for 

revision. TR sent to HS 07 19 12. Due no 

later than Sept 30. TR was accepted by NOP 

as sufficient as is and posted ~11 06 12

Barley 

Betafiber 205.606 JFo Yes Yes Spr 

2013

12 18 

12

Revised petition sent to HS on 6/20/11; TR 

accepted as sufficient 4/30/12. TR Posted 

07 25 12

Sugar Beet 

fiber 205.606 JFo/

ZS Yes Yes Spr 

2013

12 18 

12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605

(b) JD Yes Yes Spr 

2013

01 09 

13

Petition sent to Subcommittee 8/17/2010; 

TR Requested 11/15/2011. Draft TR sent to 

HS 05/01/12. Deemed sufficient 11 06 12. 

TR posted ~11 06 12

2012 Formal NOSB recc

2006 Formal NOSB recc

Sodium 

gluconate 205.605 JD Yes No On 

hold

Petition sent to HS on 3/22/2011; for use in 

soap; TR Requested 11/15/2011. On hold, 

for cosmetic use.

Bergamot 

Bitter Orange 

Powder

205.606 TF Yes Yes On 

hold

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 10/27/11. 

TR sent to HS on 2/16; Updated TR sent to 

HS 04 30 12. TR posted 06/25/12. On hold.

Gibberellic 

acid 205.605 ZS, 

TF Yes Yes Fall

2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 09/27/12. 

Sent back to petitioner for additional 

questions 01 09 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

2012

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No NA Fall

2013 

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper. 2012 

Petition sent to HS 11/06/12. Petition 

Sufficiency Response Due Date: 01/27/13. 

Petition found sufficient 12 18 12. No TR 

requested 

Glycerin

removal 

from 

205.605

TF 1995 

TR ?

Petition sent to HS on 01 09 13. Sufficiency 

response due 03 11 13

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

205.605

Petition sent to MS/HS 01/28/13. Response 

from the HS chair is requested by March 

29, 2013.

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meetin

g

Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/”other” 

ingredients (2012 disc 

doc)

ZS Spr 2013 01 29 

13

Proposal spring 2013. 

* Highlight indicates committee action needed. 

Agenda

• Approve notes from January 15, 2013

• Vote on DBDMH 

• Continue discussion on auxiliary/”other” ingredients (ZS)

Discussion
• Notes from January 15, 2013 were approved with no changes.

• The Chair asked for further discussion and declaration of interests on DBDMH before voting, for 

which there was none. 

Vote on DBDMH:

Motion to classify DBDMH (CAS # 77-48-5) as petitioned as synthetic: 

Motion by: JFo

Seconded by: JR

No further discussion

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

Motion to list DBDMH (CAS# 77-48-5) as petitioned on 205.605(b)

Motion by: JFo

Seconded by: HA

Additional discussion: EBR asked that JFo make sure the narrative is included, as the version 

sent on 1/14/13 does not have it.

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

• Auxiliary/”other” ingredients – The group discussed edits to the latest draft document, which 

included language from EBR about “Everything Added to Food in the United States” (EAFUS), 

and Generally Regarded as Safe (GRAS). The NOP asked about sunset dates and did some wordsmithing to indicate that review of “Other Ingredients” currently in use would occur at the next 

sunset review. The NOP asked that the NOSB be clear about this in its recommendation and 

noted that this procedure can be included in the Policy and Procedures Manual. Potential 

language suggested: “Items are allowed until first sunset review and subsequent rule 

amendment”. The group made additional edits to the baseline criteria and CBI sections and 

discussed how to approach the subject of affidavits.

Vote on Auxiliary/”other” ingredients

Motion to adopt the proposal on auxiliary/”other” ingredients 

Motion by: ZS

Seconded by: JR

No further discussion 

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

Future Call Schedule:

January 29, 2013 1:00 EST extra call

Discuss/complete vote on DBDMH? (JFo)

Continue discussion/vote on auxiliary/”other” ingredients (ZS)

February 5, 2013 1:00 EST

Assign PGME

Discuss upcoming assignments

Discuss workplans for fall 2013

Review final proposals for spring meeting

February 19, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

March 5, 2013 1:00 EST
March 19, 2013 1:00 EST

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, February 5, 2013, 1:00 pm EST

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Nick Maravell (NM), Jean Richardson (JR), Carmela Beck (CBe), Joe Dickson (JD), Mac Stone (MS) - sitting 

in

Absent: none

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydant

oin (DBDMH)

CAS # 77-48-5

205.605(b) JFo Yes Yes Spr

2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor 

for revision. TR sent to HS 07 19 12. Due 

no later than Sept 30. TR was accepted 

by NOP as sufficient as is and posted 

~11 06 12

Barley Betafiber 205.606 JFo Yes Yes Spr 

2013

12 18 

12

Revised petition sent to HS on 6/20/11; 

TR accepted as sufficient 4/30/12. TR 

Posted 07/25/12

Sugar Beet fiber 205.606 JFo/

ZS Yes Yes Spr 

2013

12 18 

12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605(b) JD Yes Yes Spr 

2013

01 09 

13

Petition sent to Subcommittee 

8/17/2010; TR Requested 11/15/2011. 

Draft TR sent to HS 05/01/12. Deemed 

sufficient 11 06 12. TR posted ~11 06 12

2012 Formal NOSB recc, 2006 Formal 

NOSB recc

Sodium 

gluconate 205.605 JD Yes No On hold

Petition sent to HS on 3/22/2011; for 

use in soap; TR Requested 11/15/2011. 

On hold, for cosmetic use.

Bergamot Bitter 

Orange Powder 205.606 TF Yes Yes On hold

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 

10/27/11. TR sent to HS on 2/16; 

Updated TR sent to HS 04 30 12. TR 

posted 06/25/12. On hold.

Gibberellic acid 205.605 ZS, 

TF Yes Yes Fall

2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

2012

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No NA Fall

2013 

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested

 

Glycerin

removal 

from 

205.605

TF 1995 

TR

Fall 

2013

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

205.605 JR

Petition sent to MS/HS 01/28/13. 

Sufficiency response due March 29, 

2013.
Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meeting Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/Other Ingredients ZS Proposal Spr 2013 01 29 13 Auxiliary/”other” ingredients (2012 disc 

doc)

* Highlight indicates committee action needed. 

Agenda

• Approve notes from January 29, 2013

• Assign PGME

• Discuss upcoming assignments (Glycerin, Gibb, Ammonium hydroxide, 4 sunsets)

• Discuss workplans for fall

• Review final proposals for spring meeting

Discussion

• Notes from January 29, 2013 were approved with no changes

• Polyalkylene glycol monobutyl ether (PGME): Jean Richardson volunteered to lead the review 

for this material

• Glycerin: A petition for removal has been received. A member said that since the classification 

guidance might be coming out before the fall the group may have to revisit the classification of 

this material, as well as such things as gums under sunset review. TF and ZS will co-lead the 

review for this material. MA will add review of classification guidance to the agenda at the 

bottom of the notes.

• Finalization of spring 2013 proposals. ZS is going to look at revised checklist for sugar beet fiber.

JFo will revise the checklist for Barley betafiber, placing it on the old checklist, since the revised 

version is not ready yet. The chair asked the members to finalize each of the proposals by 

completing the cover sheets and filling in votes, then sending the final docs to him and MA by 

Feb 8. 

• “Other ingredients”- ZS will provide a PowerPoint presentation for the spring meeting

• With regard to public comments, members feel that “Other ingredients” will solicit the most 

feedback, then barley betafiber and sugar beet fiber, then DBDMH 

• The Chair asked that the lead reviewer be the one to present and let MA know what format the 

presentation will take. 

• As was discussed on the last Executive Subcommittee call, the HS may have more public 

comment time allocated than needed. This will allow for adjustments to the schedule. 
• The group discussed the pre-meeting preparation time and how best to use that time to inform 

other Board members about the Handling Subcommittee proposals, especially those that do not 

sit on Handling. 

Future Call Schedule:

January 29, 2013 1:00 EST extra call

Discuss/complete vote on DBDMH? (JFo)

Continue discussion/vote on auxiliary/”other” ingredients (ZS)

February 5, 2013 1:00 EST

Assign PGME- done

Discuss upcoming assignments - done

Discuss workplans for spring - done

Review final proposals for spring meeting - done

February 19, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

March 5, 2013 1:00 EST

Glycerin

March 19, 2013 1:00 EST

Classification guidance (if released) and its implication for gums, glycerin, etc. – most likely will 

be rescheduled to after the spring 2013 meeting

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, February 19, 2013, 1:00 pm ET

Present: Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), Jean Richardson (JR), 

Carmela Beck (CBe), Joe Dickson (JD)

Absent: Nick Maravell (NM), John Foster (Chair) (JFo)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydant

oin (DBDMH)

CAS # 77-48-5

205.605(b) JFo Yes Yes Spr

2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor 

for revision. TR sent to HS 07 19 12. Due 

no later than Sept 30. TR was accepted 

by NOP as sufficient as is and posted 

~11 06 12

Barley Betafiber 205.606 JFo Yes Yes Spr 

2013

12 18 

12

Revised petition sent to HS on 6/20/11; 

TR accepted as sufficient 4/30/12. TR 

Posted 07/25/12

Sugar Beet fiber 205.606 JFo/

ZS Yes Yes Spr 

2013

12 18 

12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605(b) JD Yes Yes Spr 

2013

01 09 

13

Petition sent to Subcommittee 

8/17/2010; TR Requested 11/15/2011. 

Draft TR sent to HS 05/01/12. Deemed 

sufficient 11 06 12. TR posted ~11 06 12

2012 Formal NOSB recc, 2006 Formal 

NOSB recc

Sodium 

gluconate 205.605 JD Yes No On hold

Petition sent to HS on 3/22/2011; for 

use in soap; TR Requested 11/15/2011. 

On hold, for cosmetic use.

Bergamot Bitter 

Orange Powder 205.606 TF Yes Yes On hold

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 

10/27/11. TR sent to HS on 2/16; 

Updated TR sent to HS 04 30 12. TR 

posted 06/25/12. On hold.

Gibberellic acid 205.605 ZS, 

TF Yes Yes Fall

2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

2012

Ammonium 

hydroxide 

(boiler water 

additive)

CAS # 1336-21-6

205.605 JR No NA Fall

2013 

02 19 

13

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested

 

Glycerin

removal 

from 

205.605

TF/ZS 1995 

TR

Fall 

2013

Petition sent to HS on 01 09 13. 

Petition found sufficient 02 19 13. TR

requested 02 19 13

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

(CAS# 9038-95-

3)

205.605 JR

Petition sent to MS/HS 01 28 13. 

Sufficiency response due March 29, 

2013. Petition found sufficient 02 19 13. 

TR requested 02 19 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meeting Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe No Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF No Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD No Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/Other Ingredients ZS Proposal Spr 2013 01 29 13 Auxiliary/”other” ingredients (2012 disc 

doc)

* Highlight indicates committee action needed. 
Agenda

• Approve notes from February 5, 2013

• Ammonium Hydroxide Checklist: review, discuss and possible vote.

• Tracy - update on the petition sufficiency response to Glycerin. Scheduled for in-depth 

discussion on the 3/11 call.

• Jean - Update on petition sufficiency on polyalkylene glycol monobutyl ether PGME. This is due 

on 3/29.

• Public Comment Period. Michelle can update us on start/close and process for all board 

members and respective sub-committees.

• Discuss when Michelle will need "Lead's" presentation for Portland meeting.

• Thoughts for the fall semester work plan? 

Discussion

• Notes from February 5, 2013 approved with no change. 

• Ammonium Hydroxide Checklist: JR summarized the work to date on the Ammonium Hydroxide

review. Ammonium hydroxide is used as a boiler additive and an anti-corrosive for pipes. It does 

not appear that this is essential as there are alternative practices and other substances that do 

the same thing. The substance does not satisfy many of the criteria for organic: human health, 

environmental impacts (climate change), essentiality, and organic practices. The members 

discussed the argument set forth by the petitioner that ammonium hydroxide is required, 

despite the fact that there are three other boiler additives already on the national list. The 

group felt that this was not a very strong argument and that the negatives outweighed any of 

the positive aspects that may exists. A member asked for a comparison between ammonium 

hydroxide and the other 3 substances on the list with regard to environmental safety, worker 

safety, and efficacy, to which another member replied that it’s the ammonia that is the problem. 

The Subcommittee decided that they did not need a new TR and that the last ones were 

sufficient.

Vote on Ammonium Hydroxide 

Motion to classify ammonium hydroxide (CAS # 1336-21-6) as petitioned as synthetic

Motion by: JR

Seconded by: TF

Further discussion: none

Yes: 6 No: 0 Absent: 2 Abstain: 0 recuse: 0

Motion to add ammonium hydroxide (CAS # 1336-21-6) as petitioned to §205.605

Motion by: JR

Seconded: CBe

Further discussion: none

Yes: 0 No: 6 Absent: 2 Abstain: 0 recuse: 0

• Glycerin (petition to remove): A member asked about evaluating the past TR to determine if it is 

sufficient or if they should submit a request for a new one. A member, who was involved in 

writing the original TR, noted that at the time of the original review, synthetic glycerin was 

allowed, and commercial availability was not addressed because at that time (1995) it did not 

exist. A member also noted that the original TR seemed to include a lot of information supplied 

only by the manufacturer. The group found the petition to be sufficient and TF recommended 

requesting a new TR. HA will send TR to request to the National List Manager. 
• PGME: The petition is very specific: the addition of one form of monobutyl ether, (CAS# 9038-

95-3) at a minimum molecular weight of 1500. The members discussed the petition and noted 

that it was very well written, and did not contain any Confidential Business Information, and so 

deemed it to be sufficient. The group discussed the need for a TR, and determined that since 

this was a new substance and they had no scientific background or history, they would request 

one. HA will send TR to request to the National List Manager. 

• MA updated the group on the public comment period, and discussed the timeline for receiving 

presentations for the Portland Meeting. She would like to receive them, or determine what 

should be projected, by the Monday prior to the start of the meeting, during the pre-meeting 

preparation time.

• Workplans. The members discussed several items on the workplan for the fall 2013 meeting, 

and MA has the action item to check with EBR and the National List Manager (NLM) as to the 

status of the following: 

o Bergamot Bitter Orange Powder - Is this on hold pending information from FDA?

o Sodium gluconate. The members recalled receiving a memo from the NLM indicating 

that this substance was petitioned for use in personal care products and therefore 

should not be on list. Can it be removed from the workplan?

o Gibberellic Acid - waiting for response from petitioner. 

Future Call Schedule:

February 19, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

March 5, 2013 1:00 ET

Glycerin

March 19, 2013 1:00 ET

Classification guidance (if released) and its implication for gums, glycerin, etc. – most likely will 

 be rescheduled to after the spring 2013 meeting

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, March 5, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Jean Richardson (JR), Carmela Beck (CBe)

Absent: Joe Dickson (JD), Nick Maravell (NM)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydant

oin (DBDMH)

CAS # 77-48-5

205.605(b) JFo Yes Yes Spr 2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor 

for revision. TR sent to HS 07 19 12. Due 

no later than Sept 30. TR was accepted 

by NOP as sufficient as is and posted 

~11 06 12

Barley Betafiber 205.606 JFo Yes Yes Spr 2013 12 18 

12

Revised petition sent to HS on 6/20/11; 

TR accepted as sufficient 4/30/12. TR 

Posted 07/25/12

Sugar Beet fiber 205.606 JFo/

ZS Yes Yes Spr 2013 12 18 12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605(b) JD Yes Yes Spr 2013 01 09 

13

Petition sent to Subcommittee 

8/17/2010; TR Requested 11/15/2011. 

Draft TR sent to HS 05/01/12. Deemed 

sufficient 11 06 12. TR posted ~11 06 12

2012 Formal NOSB recc, 2006 Formal 

NOSB recc

Sodium 

gluconate 205.605 JD Yes No On hold

Petition sent to HS on 3/22/2011; for 

use in soap; TR Requested 11/15/2011. 

NOP notified HS on 02 10 12 that it is 

unable to provide TRs for personal care 

product petitions. Will be removed 

from workplan table for now.

Bergamot Bitter 

Orange Powder 205.606 TF Yes Yes Withdrawn

Sent to HS on 3/22/2011; TR Requested 

5/23/11; sent to contractor on 

10/27/11. TR sent to HS on 2/16; 

Updated TR sent to HS 04 30 12. TR 

posted 06/25/12.Removed from 

consideration. Does not have EPA 

registration for petitioned use. 
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

Gibberellic acid 205.605 ZS, 

TF Yes Yes Fall 2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

2012

Ammonium 

hydroxide 

(boiler water 

additive)

CAS # 1336-21-6

205.605 JR No NA Fall 2013 02 19 

13

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested. 

Glycerin

removal 

from 

205.605(b)

TF/ZS 1995 

TR Fall 2013

Petition sent to HS on 01 09 13. 

Petition found sufficient 02 19 13. TR

requested 02 19 13

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

(CAS# 9038-95-

3)

205.605 JR Fall 2013

Petition sent to MS/HS 01 28 13. 

Sufficiency response due March 29, 

2013. Petition found sufficient 02 19 13. 

TR requested 02 19 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meeting Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe No Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF No Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD No Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/Other Ingredients ZS Proposal Spr 2013 01 29 13 Auxiliary/”other” ingredients (2012 disc 

doc)

* Highlight indicates committee action needed. 

Agenda

• Approve notes from February 19, 2013
• Glycerin (TF) 

• Update from EBR about the following: Bergamot Bitter Orange Powder, Sodium gluconate, and 

Gibberellic Acid 

• Public comments for HS topics so far 

Discussion

• Notes from February 19, 2013 approved with no changes

• Glycerin – The Subcommittee approved the petition and requested a new TR on the last call. The 

petitioner is requesting removal from 205.605(b) and claims there is an organic version of 

glycerin that should be considered agricultural. The group discussed how to proceed with this 

material including a proposal to move it to a different section, perhaps 606, in an effort to solicit 

public feedback about supply and demand. A member noted that OMRI published an article 

about glycerin which she will locate and distribute to the other members. 

• Bergamot Bitter Orange Powder - This material was removed from consideration because it 

does not have EPA registration for petitioned use as an antimicrobial. The Chair asked about 

setting a precedent, i.e. not reviewing a material that is not EPA registered, which is the 

standard operating procedure, but in this case the status was not properly identified. 

• Sodium gluconate - The NOP informed the NOSB on February 10, 2012 that it lacks funds for TRs

for substances used in personal care products. It has been removed it from the workplan table.

• The group discussed the public comments that have come in so far, and the fact that many of 

the comments were general and not specific to any of the current proposals or topics.

• JFo asked that HA substitute for him on the March 19th call, as he will be travelling for work. The 

group will review the public comments on the next call. 

Future Call Schedule:

February 19, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

March 5, 2013 1:00 ET

Glycerin

March 19, 2013 1:00 ET

Review public comments

Classification guidance (if released) and its implication for gums, glycerin, etc. – this agenda item 

 most likely will be rescheduled to after the spring 2013 meeting

April 2, 2013 1:00 ET

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013
NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, March 19, 2013, 1:00 pm ET

Present: Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), Jean Richardson (JR), 

Carmela Beck (CBe), Joe Dickson (JD), Mac Stone - sitting in

Absent: John Foster (Chair) (JFo), Nick Maravell (NM)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydant

oin (DBDMH)

CAS # 77-48-5

205.605(b) JFo Yes Yes Spr 2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor 

for revision. TR sent to HS 07 19 12. Due 

no later than Sept 30. TR was accepted 

by NOP as sufficient as is and posted 

~11 06 12

Barley Betafiber 205.606 JFo Yes Yes Spr 2013 12 18 

12

Revised petition sent to HS on 6/20/11; 

TR accepted as sufficient 4/30/12. TR 

Posted 07/25/12

Sugar Beet fiber 205.606 JFo/

ZS Yes Yes Spr 2013 12 18 12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605(b) JD Yes Yes Spr 2013 01 09 

13

Petition sent to Subcommittee 

8/17/2010; TR Requested 11/15/2011. 

Draft TR sent to HS 05/01/12. Deemed 

sufficient 11 06 12. TR posted ~11 06 12

2012 Formal NOSB recc, 2006 Formal 

NOSB recc

Gibberellic acid 205.605 ZS, 

TF Yes Yes Fall 2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

2012

Ammonium 

hydroxide 

(boiler water 

additive)

CAS # 1336-21-6

205.605 JR No NA Fall 2013 02 19 

13

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested. 

Glycerin

removal 

from 

205.605(b)

TF/ZS 1995 

TR Fall 2013

Petition sent to HS on 01 09 13. 

Petition found sufficient 02 19 13. TR

requested 02 19 13
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr TR 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

(CAS# 9038-95-

3)

205.605 JR Fall 2013

Petition sent to MS/HS 01 28 13. 

Sufficiency response due March 29, 

2013. Petition found sufficient 02 19 13. 

TR requested 02 19 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meeting Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe No Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF No Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD No Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/Other Ingredients ZS Proposal Spr 2013 01 29 13 Auxiliary/”other” ingredients (2012 disc 

doc)

* Highlight indicates committee action needed. 

Agenda

• Approve notes from March 5, 2013

• Public comments for HS topics so far 

Discussion

• Notes from March 5, 2013 approved with no changes

• Members discussed the public comments received so far and how to address the comments at 

the meeting in an efficient manner. There were many comments submitted in the form of a 

petition about Auxiliary/other ingredients that the group felt contained misleading information,

and they discussed how to clarify the information at the spring meeting. For example, it seems 

there was a misunderstanding about the allowance of “other ingredients,” which was 

characterized in the form letter as being permitted without review by the Board, when in fact

the proposal addresses how the review should be conducted. Members and the NOP are 

concerned that some commenters characterized the NOSB review as “illegal” when in fact they 
follow OFPA and the regulations carefully in review of materials. The group also discussed the 

two fiber petitions and the lack of comments received so far. The group was hoping to receive 

comments from handlers with regard to these materials. 

• The members discussed several materials that would be on the workplan in the future for 

sunset review, including gums, and Konjac flour. 

• Members discussed a future agenda topic: Classification guidance and its implication for gums, 

glycerin, etc. is scheduled for April 2 below – This agenda item will most likely will be 

rescheduled to after the spring 2013 meeting as NOP indicated it was still in clearance.

Future Call Schedule:

February 19, 2013 1:00 EST

Continue discussion of ammonium hydroxide checklist (JR)

March 5, 2013 1:00 ET

Glycerin

March 19, 2013 1:00 ET

Review public comments

April 2, 2013 1:00 ET

Classification guidance (if released) and its implication for gums, glycerin, etc. – this agenda item 

most likely will be rescheduled to after the spring 2013 meeting. NOP indicated it was still in 

clearance

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, April 2, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Jean Richardson (JR), Carmela Beck (CBe), Joe Dickson (JD, Nick Maravell (NM), Mac Stone-sitting in, Jay 

Feldman-sitting in

Absent:

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr Technica

l Review 

(TR) 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

1,3-dibromo5,5-

dimethylhydant

oin (DBDMH)

CAS # 77-48-5

205.605(

b) JFo Yes Yes Spr 2013

01 29 

13

Petition sent to HS on 2/16/2012. TR 

requested. Rcvd and sent to contractor 

for revision. TR sent to HS 07 19 12. Due 

no later than Sept 30. TR was accepted 

by NOP as sufficient as is and posted 

~11 06 12

Barley Betafiber 205.606 JFo Yes Yes Spr 2013 12 18 

12

Revised petition sent to HS on 6/20/11; 

TR accepted as sufficient 4/30/12. TR 

Posted 07/25/12

Sugar Beet fiber 205.606 JFo/

ZS Yes Yes Spr 2013 12 18 12

Revised petition sent to Committee 

2/10/2011; Revised TR sent to HS 

04/26/12. TR accepted as sufficient 

4/30/12. TR posted 06/25/12

Sulfuric acid

(H2SO4) 205.605

(b) JD Yes Yes Spr 2013 01 09 

13

Petition sent to Subcommittee 

8/17/2010; TR Requested 11/15/2011. 

Draft TR sent to HS 05/01/12. Deemed 

sufficient 11 06 12. TR posted ~11 06 12

2012 Formal NOSB recc, 2006 Formal 

NOSB recc

Gibberellic acid 205.605 ZS, 

TF Yes Yes Fall 2013

Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

2012

Ammonium 

hydroxide 

(boiler water 

additive)

CAS # 1336-21-6

205.605 JR No NA Fall 2013 02 19 

13

2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested. 
Petitioned Substances - Status of current review process

Name National 

List 

Section

Rvwr Technica

l Review 

(TR) 

rqst?

TR 

rcv’d

?

Mtng Vote? Notes*

Glycerin

removal 

from 

205.605(

b)

TF/Z

S

1995 

TR Fall 2013

Petition sent to HS on 01 09 13. 

Petition found sufficient 02 19 13. TR

requested 02 19 13

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF)

As a boiler 

water additive

(CAS# 9038-95-

3)

205.605 JR Fall 2013

Petition sent to MS/HS 01 28 13. 

Sufficiency response due March 29, 

2013. Petition found sufficient 02 19 13. 

TR requested 02 19 13

Sunset 2015 - Status of current review process

Name CAS 

#

Rvwr TR 

rqst?

TR 

rcv’d

?

Meeting Vote Notes*

Gellan gum 

205.605(a)

JD Fall 

2013

2006 TR, 2008 Recommendation

Marsala at 

205.606 

CBe No Fall 

2013

No TR rqst, 2008 Recommendation

Sherry at 205.606 TF No Fall 

2013

No TR rqst, 2008 Recommendation

Tragacanth at 

205.606 

JD No Fall 

2013

No TR rqst, 2008 Recommendation

Other Topics

Name Rvwr Meeting Vote Notes*

Auxiliary/Other Ingredients ZS Proposal Spr 2013 01 29 13 Auxiliary/”other” ingredients (2012 disc 

doc)

* Highlight indicates committee action needed. 

Agenda

• Approve notes from March 19, 2013

• Discuss public comments

Discussion

• Notes from March 19, 2013 approved with no changes

• The members discussed comments about the sugar beet fiber proposal and noted that they 

didn’t hear from any processors that this product is essential. 
• The group discussed the comments about the auxiliary/other ingredients, including the receipt 

of two comments about international considerations, which EBR will discuss further with the 

deputy administrator, and the section in the proposal called “other considerations”. The group 

did not intend on voting on this section, so they will move it to an appendix to make that point 

clear. The intent was to vote only on the policy and procedures. Members also discussed 

making minor edits to the text that refers to the CBI discussion document. There was also a 

request to publish the checklist questions, although the group feels that since the questions 

have not changed, and the checklist is based on OFPA and the regulation, there is no need to 

solicit public comment. The group felt it was not a problem to project the checklist at the 

meeting to illustrate the revised questions. Two other issues discussed: Concept of labeling, and

adding products that have “other ingredients” to the National List. The members discussed the 

likelihood of not getting a 2/3 vote, and how to proceed if that occurs. They also discussed

proposing that organic labels include “other ingredients” and determined that using the term 

“ingredients” is the main problem, as these items aren’t really ingredients. The members will 

discuss a backup plan if the current proposal does not pass as is. 

 ABS note added April 5, 2013: Handling Subcommittee members communicated via email to 

 vote on amending the auxiliary/Other ingredients proposal to include language proposed in the 

 public comments. 

Motion to amend Auxiliary/Other ingredients proposal: ZS

Seconded by: JR

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

Future Call Schedule:

March 19, 2013 1:00 ET

Review public comments

April 2, 2013 1:00 ET

Classification guidance (if released) and its implication for gums, glycerin, etc. – this agenda item 

most likely will be rescheduled to after the spring 2013 meeting. NOP indicated it was still in 

clearance

Spring 2013 Milestones Target date

NOP – Complete tentative agenda February 8, 2013

Spring 2013 proposals due to NOP February 12, 2013

NOP - Post proposals, Publish FRN, Open public comment February 19, 2013

Subcommittees submit tentative workplans to NOP March 1, 2013

Discuss workplans on ES call March 8, 2013

NOP provides written comments on workplans to NOSB March 11, 2013

Public comment closes March 19, 2013

NOP - Send compiled public comments to NOSB March 25, 2013

Workplans finalized on ES call March 29, 2013

Spring 2013 NOSB Meeting – Portland, OR April 8-11, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, May 7, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Jean Richardson (JR), Carmela Beck (CBe), Mac Stone-sitting in

Absent: Nick Maravell (NM), Joe Dickson (JD)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

205.605 ZS, TF Yes Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No 2000 petition. 2001 Recommendation. 

2001 TAP. 2001 Background Paper.

2012 Petition sent to HS 11/06/12. 

Petition Sufficiency Response Due 

Date: 01/27/13. Petition found 

sufficient 12 18 12. No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin removal 

from 

205.605

TF 1995 TR Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

due June

Fall 2013

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) As a 

boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01/28/13. TR 

Requested 2/19/2013. TR due July. Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 205.605(a) JD 2006 TR, 2008 Recommendation Fall 2013

Marsala 205.606 CBe No 2008 Recommendation Fall 2013

Sherry at 205.606 TF No 2008 Recommendation Fall 2013

Tragacanth 205.606 JD No 2008 Recommendation Fall 2013

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Auxiliary/”other” ingredients (2012 disc doc) Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from April 2, 2013

• Gibberellic acid discussion - ZS

• Ancillary substances next steps - ZS

• Ammonium hydroxide - JR

• Arrange the anticipated agendae for the next few meeting

Discussion

• A member asked to add one item to the agenda: a discussion of the Classification of Materials 

Guidance document, and specifically the agricultural/non agricultural decision tree

• Notes from April 2, 2013 were approved with no changes.

• Ammonium Hydroxide: The HS voted on Feb 19, 2013. MA will send JR the vote count so she can 

add that information to the proposal

• Gibberellic Acid: The group discussed the response from the petitioner, which they felt was not 

very extensive, and didn’t answer all of the questions the Subcommittee had asked. The 

petitioner did include information about alternatives, i.e. plastic wrap, but explained this was a 

complementary technique, not a stand-alone alternative. The group discussed the use of

Gibberellic acid in cherries, citrus, and potatoes as well, and decided that it should be reviewed 

again. Members suggested tabling discussion until NOP can provide more information on status 

of proposed guidance on post-harvest handling substances.

• Ancillary substances. ZS suggested that the next step would be to revise the checklist and to add 

questions about ancillary substances, which she will do before passing it along to the NOP to 

finalize. The checklist could be completed by the next Handling meeting. The NOP indicated that 

the sunset review process is being revised, and ZS volunteered to work on scheduling the review 
of the sunset materials. ZS asked for a spreadsheet version of the substances on the National List 

by section including annotations, and sunset dates, which the NOP will generate and send. Those 

with likely ancillary substances will then be identified. 

• The group discussed the flavors task force and noted that MS was a member when he was first 

appointed to the Board. Flavors is one of many topics needing further clarification, and the group 

discussed the need for more information from other task force members. 

• Classification of Materials guidance and the ag/non ag decision tree. ZS is working with several 

groups that are going to submit comments about this guidance doc. There are some concerns 

about the implications of the classification for microorganisms and their products: the proposed 

guidance would result in reclassification of many substances as agricultural (and thus be required 

as organic for livestock).The group discussed submitting comments on behalf of the 

Subcommittee. ZS, who is also compiling comments for the Materials Subcommittee, asked for 

assistance with the HS document. The consensus was that commenting was important and 

useful. 

• The Chair will ask JD about a timeline for the discussion of Gellan Gum and Tragacanth. Discussion 

dates for Marsala (CB) and sherry (TF) were scheduled below. 

Future Call Schedule:

May 21, 2013 1:00 ET

Update on status of Gibb (EBR)

Review draft comments on the Classification of Materials Guidance (ZS)

June 4, 2013 1:00 ET

Gibberellic acid (ZS, TF)

Ancillary Substances (ZS)

Handling checklist review (all)

Sherry (TF)

June 18, 2013 1:00 ET

Marsala (CBe)

July 2, 2013 1:00 ET

July 16, 2013 1:00 ET

Glycerin (TF)

August 6, 2013 1:00 ET

PGME (JR)

August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013
Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, May 21, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Jean Richardson (JR), Joe Dickson (JD), Mac Stone - sitting in

Absent: Nick Maravell (NM), Carmela Beck (CBe) 

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

205.605 ZS, TF Yes Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11/06/12. Petition 

Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin removal 

from 

205.605

TF 1995 TR Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

due June

Fall 2013

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) As a 

boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01/28/13. TR 

Requested 2/19/2013. TR due July. Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 205.605(a) JD 2006 TR, 2008 Recommendation Fall 2013

Marsala 205.606 CBe No 2008 Recommendation Fall 2013

Sherry at 205.606 TF No 2008 Recommendation Fall 2013

Tragacanth 205.606 JD No 2008 Recommendation Fall 2013

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from May 7, 2013

• Update on status of Gibb (EBR)

• Review draft comments on the Classification of Materials Guidance (ZS)

Discussion

• Notes from May 7, 2013 were approved with no changes.

• Tragacanth and Gellan gum were added to the review schedule for July 16th (see below).

• Gibberellic acid (EBR) - Pending internal NOP review and USDA clearance, the anticipated 

publication date for the guidance on use of substances in post-harvest handling is July. The NOP

feels that the guidance might not be out in time for the group to review this material for the fall 

meeting. The HS asked that the NOP inform the petitioner that they are delaying the review while 

waiting for pending guidance.

• Classification of Materials Guidance (ZS) - There are aspects in the decision trees (specifically the 

ag/non ag) that impact Handling and would lead to classification of microorganisms as 

agricultural. The Materials Subcommittee will be discussing this on their next call (May 28). The 

comment deadline is June 3, and members felt that they might not be done in time so MA will see 

about posting comments manually. JFO will take the lead on doing a side-by-side comparison of 

the current guidance with past NOSB recommendations (~2009, 2010, & 2011) on Materials 

classification. ZS will forward comments from various organizations (OTA, CCOF), and EBR will 

forward the previous documents. Members noted that this guidance will also will impact glycerin, 

and should keep that in mind for their review. TF will read the comments on glycerin when the 

comment period closes and before embarking on her review. 
• NOP proposed sunset annotation change - MS is working with NOP to compile a flowchart to 

illustrate why annotation changes at sunset are problematic and will keep the Board members 

posted on efforts to develop alternative procedures. 

Future Call Schedule:

May 21, 2013 1:00 ET

Update on status of Gibb (EBR)

Review draft comments on the Classification of Materials Guidance (ZS)

June 4, 2013 1:00 ET

Gibberellic acid (ZS, TF)

Ancillary Substances (ZS)

Handling checklist review (all)

Sherry (TF)

June 18, 2013 1:00 ET

Marsala (CBe)

July 2, 2013 1:00 ET

July 16, 2013 1:00 ET

Glycerin (TF)

Gellan Gum (JD)

Tragacanth (JD)

August 6, 2013 1:00 ET

PGME (JR)

August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, June 4, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Nick Maravell (NM), Joe Dickson (JD), Mac Stone-sitting in

Absent: Jean Richardson (JR)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

205.605 ZS, TF Yes Petition sent to HS 07/27/12. Petition 

Sufficiency Response Due Date: 

09/27/12. Sent back to petitioner for 

additional questions 01 09 13

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

205.605 JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11/06/12. Petition 

Sufficiency Response Due Date: 

01/27/13. Petition found sufficient 12 

18 12. No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin removal 

from 

205.605

TF 1995 TR Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

due June

Fall 2013

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) As a 

boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01/28/13. TR 

Requested 2/19/2013. TR due July. Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 205.605(a) JD 2006 TR, 2008 Recommendation Fall 2013

Marsala 205.606 CBe No 2008 Recommendation Fall 2013

Sherry at 205.606 TF No 2008 Recommendation Fall 2013

Tragacanth 205.606 JD No 2008 Recommendation Fall 2013

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from May 21, 2013

• Handling checklist review (all)

• Ancillary Substances (ZS)

• Classification of Materials Guidance (ZS)

• Sherry (TF)

Discussion

• Notes from May 21, 2013 approved as is

• Handling checklist review (all) - The group discussed the edits to the checklist and various 

questions, for example the difference between adverse effects and contamination. The two main 

goals for this project are to simplify the questions and eliminate redundancy. A member noted 

that Category 1 questions can be simplified while Category 2 questions are more complicated. For 

example, question # 2 could be split easily into 2a, 2b, and 2c. Ultimately the members decided 

that as long as the justifications in the comment section were clear and comprehensive, splitting 

compound questions into separate questions was not always necessary. The NOP will finish the 

edits and MA will add it to the appendix of the PPM. 

• Ancillary Substances (ZS) - The group discussed the draft spreadsheet created to facilitate the 

scheduling and evaluation of the materials on the National List that may contain ancillary 

substances. The spreadsheet was initially populated with the Materials Working Group's list of 

ancillary substances in the TAPs and TRs and the NOP's list of sunset dates. To date, ZS has 

completed all of 605a and half of 605b. The group discussed the sunset review cycle and noted 

that the review of the ancillary substances will help spread out the workload. Members also 

discussed grouping similar items for review which was viewed positively, as long as it is clear what 
was reviewed and how the review was conducted. A member reminded the group that §605 and 

§606 exist to allow for use of nonorganic substances in the 5% fraction of organic products

because there has historically been recognition of this need. The group also discussed the 

inherent difficulties of reviewing these ancillary substances without using brand names, and 

instead, being able to review them as part of a generic substance, although they felt that having 

extra time to review will allow time the community to inform this process. ZS separated sanitizers 

and cleaners on the spreadsheet so they can be reviewed all at once across subcommittees. The 

NOP suggested it might be a good idea to coordinate with Crops and Livestock on review of 

sanitizers.

• Sherry (TF)/Marsala (CB) - The original petitions were considered robust, and the lead reviewers 

support relisting. A member asked that the rest of the group look at comments from organic wine 

producers about production, prior to finishing the review and writing the proposal.

Future Call Schedule:

June 4, 2013 1:00 ET

Ancillary Substances (ZS)

Handling checklist review (all)

Sherry (TF)

June 18, 2013 1:00 ET

Gibberellic acid (ZS, TF)

Marsala (CBe)

July 2, 2013 1:00 ET

July 16, 2013 1:00 ET

Glycerin (TF)

Gellan Gum (JD)

Tragacanth (JD)

August 6, 2013 1:00 ET

PGME (JR)

August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013
NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, June 18, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Nick Maravell (NM), Jean Richardson (JR), Joe Dickson (JD), Mac Stone-sitting in

Absent: none

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suffic response due 09 27 12. Sent 

back to petitioner for additional 

questions 01 09 13. Rcvd response 04 

16 13. On hold until post- harvest 

handling draft guidance is published.

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11 06 12. Petition 

Sufficiency Response Due Date: 01 27

13. Petition found sufficient 12 18 12. 

No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin Remove

from 

205.605(b)

TF 1995 TR Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13

Fall 2013

Petition for

polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 

CAS # 

71010-52-1

205.605(a) JD 2006 TR, 2008 Recommendation

2010 FR notice

Fall 2013

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Fall 2013

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Fall 2013

Tragacanth 

CAS # 9000-

65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Fall 2013

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Report Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from June 4, 2013

• Gibberellic acid (ZS, TF)

• Marsala (CBe)

• Ancillary substances--continuing discussion

Discussion

• Notes from June 4, 2013 approved with no changes

• PGME – The NOP suggested that reviewers compare the TR discussion of mode of action with that 

presented in the petition, as it is important to determine if the substance has direct contact or not 

with organic products. The Subcommittee might need further information. 

• Gibberellic acid (ZS, TF) - on hold until post-harvest handling memo is released. Noted in table 

above.

• Marsala (CBe). CBe did informal research into the need, use and availability of organic marsala, 

and found little to no information that it is in high demand. Several certifiers indicated that they 

saw very few if any processed products that contained non-organic sherry or marsala. CBe also 

attempted to contact the original petitioner (Fairfield Farm Kitchens) without success, and the rep 

from Gibson Wine Co., who was the manufacturer originally supplying the sherry and marsala to 

the petitioner. Additionally, after searching the 30 websites listed on the original sherry petition 

Organic Fortified Cooking Wine Source List, she found no organic sherry or organic marsala 

availability. An organic producer provided some additional information: organic sherry and 
marsala can be made in the US, as all the components are present; Although the US doesn’t have 

a large market for drinking sherry, it is used as a fortified cooking wine for use in processed 

organic goods. The group discussed removing marsala from the national list, which could

potentially open a market void that needs to be filled. A member asked if there were viable 

alternatives to marsala and sherry, and if they contained sulfur dioxide. A member noted that 

sulfites are not typically added to these products so it is not an issue. The NOP noted the FR 

notice amending the National List to permit non-organic sherry and marsala included a discussion 

in response to comments about sulfites having not been restricted.(Dec 13, 2010, 75 FR 

page77524) . Members may want to keep this in mind as they do their review, and if the NOSB 

recommends keeping Marsala on §205.606 they could clarify the use of sulfites. The next steps 

include looking at commercial demand, doing a label search to find products that are using 

marsala and/or sherry, and determining if they should stay on the list with an annotation or be 

removed. The NOP will send the revised Handling checklist to the group so they can use it to 

complete their review. The members plan to discuss the checklists for both marsala and sherry on 

the July 2 call.

• Ancillary substances. The group discussed whether this workplan item should result in a proposal 

or a report, and decided that a report was more appropriate since it had already been approved 

as a full Board recommendation, and is now simply an implementation of that proposal. 

Additionally, the consensus was that a report would be the best way to present the changes to 

the community. ZS will work with the NOP on the spreadsheet and will discuss it further on the 

July 2 call. 

Future Call Schedule:

June 18, 2013 1:00 ET

Gibberellic acid (ZS, TF)

Marsala (CBe)

July 2, 2013 1:00 ET

PGME-TR sufficiency

Glycerin-TR sufficiency

Marsala-Discuss checklist

Sherry-Discuss checklist

Ancillary substances-Continued discussion

July 16, 2013 1:00 ET

Glycerin (TF) – Discussion/checklist review

Gellan Gum (JD)

Tragacanth (JD)

August 6, 2013 1:00 ET

PGME discussion and decision (JR)

August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date
NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, July 2, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Jean Richardson (JR), Mac Stone (MS) - sitting in

Absent: Joe Dickson (JD), Nick Maravell (NM)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11 06 12. Petition 

Sufficiency Response Due Date: 01 27

13. Petition found sufficient 12 18 12. 

No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin Remove

from 

205.605(b)

TF 1995 TR Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 

CAS # 

71010-52-1

205.605(a) JD 2006 TR, 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-

65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Report Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from June 18, 2013

• PGME-TR sufficiency

• Glycerin-TR sufficiency

• Marsala-Discuss checklist

• Sherry-Discuss checklist

• Ancillary substances-Continued discussion

Discussion

• Notes from June 18, 2013 approved with no changes

• MS announced that the fall meeting will be 3 days long, and asked that each of the 

Subcommittees think about any proposals that may be delayed in case we need to make more 

time for discussion. Some options include the following: eliminate items as they drop off 

organically, delay aquaculture proposals wholesale until the spring 2014 meeting, or send 

proposals out for comment but delay the vote until the spring 2014 meeting.

• PGME (JR). JR circulated a draft document to the group prior to the call and the group discussed 

it. PGME has unique properties in that it’s soluble at low temperatures and insoluble at high 

temps, so it remains in the boiler and has no contact with the food. There are no natural sources, 

and there may be alternatives. The NOP noted that the TR seem to conflict with the petition and 
asked the group to address that in its discussion. Members discussed how to proceed in light of 

the fact that PGME is synthetic, but since it doesn’t contact food, it doesn’t need to be added to 

the National List (NL). The NOP asked if there were any questions the group may want to ask the

petitioner, and upon further review of the petition, the lead reviewer noted that the petitioner is 

requesting a very specific usage (specifically, PGME with a minimum molecular weight of 1500, for 

inclusion on 205.605 for use as a boiler steam additive in feed pellet mills. This form of PGME 

precipitates out and will not contact food). Based on this, the group decided they did not need to 

ask the petitioner any additional questions. The TR was found sufficient, and JFo will forward an 

email to Lisa Brines letting her know. JR will present the proposal on the August 6 call for 

discussion and potential vote. 

• Glycerin (TF). The petitioner is requesting removal of glycerin from the NL at 205.605(b) because 

they feel there is sufficient quantity of organic glycerin being produced. The petitioned organic 

version is made by microbial fermentation of organic cornstarch, and other organic forms are 

produced by saponification of organic fats and oils. . The TR was found to be very thorough and 

sufficient. A member asked about supply and market needs and it was noted that the TR included 

a list of ~20 producers. Another member asked if there are uses for synthetic glycerin that cannot 

be met by the organic natural forms. The NOP asked that the manufacturing processes be 

summarized and included in the proposal. The members discussed various ways to move this 

forward, including taking it off the list altogether, or adding it to 205.606. The Chair and cautioned 

that it was important to consider impacts to other sections. NOP noted that this petition does not 

impact listing on 205.603, as synthetic used in teat dips. JFo will send email to LB indicating that 

the TR is sufficient. 

• Marsala - Discuss checklist (CBe). CBe followed up with a certifier to confirm that there were no

known products with organic marsala, and also visited 4 retail outlets to inspect products, and 

didn’t find any either. 

• Sherry - Discuss checklist (TF). The demand for organic sherry is very small, especially in the US.

After several attempts, TF was unable to get in touch with the original petitioner and therefore 

cannot assess the need for this item. The group discussed the use of the checklist for sunset 

materials. In the past, the NOSB didn’t use the checklist, but perhaps this may be a useful tool in 

review. The NOP noted some minor edits for the checklist which TF will correct. MA will let MB 

know that the HS would like to include some questions to be posted as part of the documents

that will be sent to regulations.gov for the new sunset summary process. The members discussed

structuring the introduction for the summary document in a form useful for soliciting public 

comment. 

Future Call Schedule:

July 2, 2013 1:00 ET

PGME-TR sufficiency - done

Glycerin-TR sufficiency - done

Marsala-Discuss checklist - done

Sherry-Discuss checklist - done

Ancillary substances-Continued discussion - postponed

July 16, 2013 1:00 ET

Glycerin (TF) - Discussion/checklist review/vote?

Gellan Gum (JD) - Discuss checklist

Tragacanth (JD) - Discuss checklist

Ancillary substances - continued discussion
August 6, 2013 1:00 ET

PGME discussion and vote (JR)

August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP

Discuss workplans on ES call

NOP provides written comments on workplans to NOSB

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 21-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, July 16, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Jean Richardson (JR), Nick Maravell (NM), Mac Stone (MS)- sitting in

Absent: Joe Dickson (JD) 

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11 06 12. Petition 

Sufficiency Response Due Date: 01 27

13. Petition found sufficient 12 18 12. 

No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR Yes Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 

CAS # 

71010-52-1

205.605(a) JD 2006 TR, 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-

65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Report Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from July 2, 2013 call

• The agenda was altered because to postpone the gellan gum and Tragacanth discussions

• Glycerin (TF) - Discussion/checklist review/vote?

• Gellan gum (JD) - Discuss checklist

• Tragacanth (JD) - Discuss checklist

• Discuss sunset process

• Schedule sherry and marsala for continued discussion/vote?

• Schedule gellan gum and tragacanth gum for additional discussion/vote?

Discussion

• Notes from July 2, 2013 were approved with no changes.

• Glycerin (TF) - The petitioner has requested removal of glycerin from the National List, and the 

group discussed the completion of the checklist which is tailored more to the addition of 

materials rather than removal. Based on the manufacturing processes described in the TR and 

petition, glycerin may be synthetic or nonsynthetic. The members discussed supply and demand, 

and the information in the TR indicating that there was a plentiful supply. Since the checklist was 

designed more for evaluating materials to be added to the National List, the group felt this could

be addressed by including a comprehensive comment in the comment field. NM added that he 
would like to see the addition of a sentence or two in the comment field to explain whether the 

suppliers are organic or conventional. The NOP noted a couple of changes and the Chair asked 

that the members include a clear explanation in the comment section especially if the answer to 

the question is both Y and N. The group feels that the checklist is nearly complete, pending a few 

additions and changes. The reviewer will clarify the classification as synthetic or nonsynthetic for 

the various manufacturing processes.

• Sunset process – Members are still unclear about what to do when they need to add or change or 

an annotation. The NOP has proposed to decouple annotation changes from sunset review

because coupling them complicates the process and delays rulemaking. Outside of the sunset

review, the only pathway to make an annotation change is the normal petition process, which a 

member felt was not appropriate to ask Board Members to do. MS noted options for the Board: 

They could make annotation changes in advance of sunset, so when the sunset review is 

completed, it would require only an up or down vote. Conversely, the sunset review could be 

completed first, and the annotation could be added later. ZS offered to take this to the Materials 

Subcommittee and incorporate it into the Petition Process and TR Update Project. In the petition 

guidelines there are 12 questions and guidance as to which of those questions need to be 

answered if someone is requesting an annotation change only. ZS will send JFo/MS/EBR a copy of 

the draft Materials document in which they are revising the petition process. 

• ZS asked the group to think about research priorities and to either email them or pose them for 

discussion on the next call. A list of past recommendations was emailed to the members as a 

starting point. The group discussed the list that was circulated and questioned why they would 

want to do more research on a material that was already completed. ZS feels that sometimes the 

review process uncovers more questions, outside the scope of a petition or review, and it 

warrants further research. For example, there are still a lot of questions about biodegradeable 

mulch. JFo suggested the topic of accessing reliable marketplace/commercial availability info as a 

potential research topic, but others felt it was too large in scope and it wasn’t clear how to 

narrow it. The group will discuss this further on the next call. The Chair also asked that the group 

look at the sunset 2017 list to identify any potential research items. 

• The meeting was adjourned.

Future Call Schedule:

July 16, 2013 1:00 ET

Glycerin (TF) - Discussion/checklist review

Gellan Gum (JD) - Discuss checklist - postponed

Tragacanth (JD) - Discuss checklist - postponed

Ancillary substances - continued discussion

August 6, 2013 1:00 ET

Gellan Gum (JD) - Discuss checklist

Tragacanth (JD) - Discuss checklist 

PGME discussion and vote (JR)

Ancillary substances (ZS) - continued discussion/vote

Glycerin vote (TF)

Research priorities topics
August 20, 2013 1:00 ET

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, August 6, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Mac Stone (MS) - sitting in

Absent: Carmela Beck (CBe), Jean Richardson (JR), Nick Maravell (NM), Joe Dickson (JD)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

NA On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11 06 12. Petition 

Sufficiency Response Due Date: 01 27

13. Petition found sufficient 12 18 12. 

No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin

CAS #(56-81-5)

Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13

Opened 

vote: 08 

06 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR 2013 TR Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13

Opened 

vote: 08 

06 13

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 

CAS # 

71010-52-1

205.605(a) JD 2006 TR, 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-

65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Report Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from July 16, 2013 call

• PGME discussion and vote (JR)

• Glycerin (TF) - vote

• Gellan Gum (JD) - Discuss checklist

• Tragacanth (JD) - Discuss checklist 

• Ancillary substances (ZS) - continued discussion/vote

• Research priorities topics

Discussion

• Notes from July 16, 2013 were approved with no changes.

• PGME discussion and vote (JR) – The members discussed the PGME proposal and whether or not 

it should be added to the National List. According to the TR, PGME does not come in contact with 

food, so the members found that it does not have to be on the List. The group discussed the next 

steps and how best to craft the proposal to indicate their determination. The members made 

some minor language changes to the current proposal. EBR will edit the document and resend it 

to the group for review. 
Vote on PGME:

Motion: The Handling Subcommittee has reviewed polyalkylene glycol monobutyl ether (PGME)

(CAS # 9038-95-3) as a boiler water additive and determined that since it does not contact organic 

products it therefore does not have to be placed on the National List. 

Motion by: ZS

Seconded by: TF

Discussion: none

Yes: 5 No: 0 Abstain: 0 Absent: 3 Recuse: 0

Voting will remain open until the next meeting to allow for the absent members to vote. (CBe, JR, 

NM, JD)

Voting was amended by MA to include the following email votes: JR- Y, 

• Glycerin (TF). The group discussed the revised checklist and noted the difficulty of using the 

checklist for petitions to remove an item, as it is tailored more towards additions. Members 

discussed some specifics about glycerin, noting that it was petitioned for a very specific use, and 

that there is an adequate supply of organic alternatives. ZS suggested adding clarifying language

in the summary of proposed action indicating the specific use for Handling only, and the NOP 

suggested added some additional information in the background section about the other 3 

methods of hydrolysis. TF will add changes and recirculate the doc. The group opened the voting 

and will keep it open until the next meeting. 

Vote on glycerin:

Motion to remove glycerin produced by hydrolysis of fats and oils CAS # (56-81-5) as petitioned 

from 205.605(b)

Motion by: TF

Seconded by: HA

Discussion: none

Voting deferred to email and/or next call

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

• Gellan Gum (JD) – Members briefly discussed the tragacanth draft document that was circulated 

prior to the meeting and elected to defer further conversation to the August 20 call

• Ancillary substances (ZS) – deferred to next call due to time constraints, and expected input from 

NOP on sunset process. 

• Research priorities topics –The members discussed 3 topics for inclusion in the research priorities 

proposal: Resources for information about commercial availability in the marketplace, options 

and the state of research for organic preservatives, and consumer demand for organic products 

fortified with nutrients. ZS will add the topics to the list and present it to the group on the next 

call. 

• The group added an extra hour onto the beginning of the August 20 meeting

• Meeting was adjourned
Future Call Schedule:

August 6, 2013 1:00 ET

Gellan Gum (JD) - Discuss checklist

Tragacanth (JD) - Discuss checklist 

PGME discussion and vote (JR)

Ancillary substances (ZS) - continued discussion

Glycerin (TF) - vote

Research priorities topics

August 20, 2013 12:00 ET

Gellan Gum (JD) - Discuss checklist

Tragacanth (JD) - Discuss checklist

Ancillary substances (ZS) - continued discussion

September 3, 2013 1:00 ET

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, August 20, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Joe Dickson (JD), Mac Stone (MS) - sitting in

Absent: Nick Maravell (NM), Jean Richardson (JR)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

NA On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No 2000 petition. 2001 

Recommendation. 2001 TAP. 

2001 Background Paper. 2012 

Petition sent to HS 11 06 12. Petition 

Sufficiency Response Due Date: 01 27

13. Petition found sufficient 12 18 12. 

No TR requested

 

Voted

02 19 13

Fall 2013

Glycerin

CAS #(56-81-5)

Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13, 

Proposal

Voted

08 20 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR 2013 TR Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13. Discussion doc.

Voted

08 20 13 Disc doc

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National List 

§

Contact TR rqst? Notes* Vote Meeting

Gellan gum 

CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-

65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

On hold?

Report Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from August 6, 2013 call

• Glycerin (TF) - complete vote

• PGME - discussion and vote (JR)

• Ancillary substances (ZS) - continued discussion/vote

• Sunset 2015 - discussion how to handle the four substances now and at the fall meeting

• Gellan Gum (JD) - discuss checklist

• Tragacanth (JD) - discuss checklist 

• Sherry - discussion (TF) 

• Marsala - discussion (CBe) 

Discussion

• Notes from August 6, 2013 were approved with no changes

• Glycerin (TF) – The members discussed some minor edits that were made since the last call, 

language about glycerin being a carrier, and how the proposed removal of glycerin from the list 

affects this function. The HS expects that they will receive public comments regarding this, and 

the group chose to proceed with the completion of the vote.
Vote on glycerin:

Motion to remove glycerin produced by hydrolysis of fats and oils CAS # (56-81-5) as 

petitioned from 205.605(b) 

Motion by: TF

Seconded by: HA 

Discussion: The lead reviewer re-emphasized the petitioner’s rationale for the request to 

remove glycerin from the National List, which is that there are organic alternatives.

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

Note: Although absent from the call, JR voted via email August 20 and the above vote was 

changed to reflect that. The Chair will keep the vote open until the end of the week so 

NM can vote. The NOP noted that if the Board received new information from the 

commenters, it is feasible to delay the vote to the spring 2014 NOSB meeting. 

• PGME. New information in the Technical Review indicated that PGME does not contact food thus 

eliminating the need for it to be on the National List. As this was discovered well into the review 

process, the NOP suggested that the proposal be converted to a discussion document, so instead 

of withdrawing the document from consideration, the Board can present it at the meeting and 

the determination will be entered as part of the public record. The NOP suggested some clarifying 

language in the document: e.g. replacing “not eligible” with “may not need to be on the List”. The 

Chair will complete the revisions and finalize the document.

Vote on PGME:

Motion: To accept the discussion document as modified August 20, 2013 on the HS call. 

Motion by: TF

Seconded by: HA

Discussion: none

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

Note: JR cast her vote via email and it was included in the above tally. The Chair will keep 

the vote open until the end of the week so NM can vote. 

• Ancillary substances (ZS) – The discussion was deferred to the next call pending feedback from the 

NOP about the latest draft document. EBR noted that the NOP will distribute an official memo 

prior to the meeting in addition to the Sunset notices. The group intends on presenting a report at 

the fall 2013 meeting indicating what they are working on.

• Sunset 2015 – Members discussed the path forward with regard to the Sunset Summaries in light 

of the new NOP procedures. The Federal Register notice will list the items and signal the opening 

of the public comment period. There will also be a summary posted on the NOSB meeting site 

that will contain specific directions for leaving comments, including requests for such things as 

new industry information, availability, any changes in supply, essentiality, and alternative 

methods, and provide links to all prior reviews of the substance. At the fall 2013 NOSB meeting, 

the lead person can summarize the comments received and perhaps discuss the checklists if they 

are ready, but the checklists will not be posted. The NOP acknowledged that it will be difficult to 

separate ancillary substances from the sunset review, and perhaps after a trial run for 2016, the 
NOP will reevaluate the process and revise as needed. ZS noted that the timeline she proposed 

for review of the Ancillary Substances is in line with what NOP is proposing, and perhaps it will be 

possible to identify the next group of items for review ahead of schedule. The members wanted 

to confirm that the NOP intends on presenting an explanation of the changes to the Sunset 

process at the beginning of the fall 2013 NOSB meeting so the public is aware. 

• Gellan Gum (JD) – The lead reviewer summarized the research he conducted on Gellan gum and 

noted that it resulted in many questions revolving around ancillary substances, chemical changes 

and essentiality. Gellan gum was petitioned in 2004, a TR was requested in 2006 and after a long 

complicated debate the Board recommended its addition to 205.605(a) in 2007. Subsequently, 

the NOP added to the National List with an annotation that limits it to “high acyl forms” as a 

nonsynthetic in 2008. A member added that Gellan gum is an important alternative to legumebased gums, as legumes may be a food allergen. The group discussed the potential need and 

usefulness of a TR or limited scope TR, and suggested that questions about the uniqueness, 

essentiality and functionality would be helpful.

• Tragacanth (JD) - Tragacanth is a gum extruded from several Middle Eastern species of Astralagus, 

aleguminous shrub and is agricultural. The original petitioner, in 2008, claimed that Turkish 

producers are expanding use and are working on an organic version, but the lead reviewer was 

unable to find any current information regarding this. The group discussed the fact that the 

Handling checklist was very applicable for use in reviewing sunset 606 substances, so perhaps an 

abbreviated checklist would be more helpful. Additionally, it was noted that the previous review 

was not conducted using a checklist, so it was a bit more difficult when reevaluating. Members 

were supportive of the idea of having a unique checklist for 606 sunset items. Ideally it would 

contain only Category 4 questions, and a few other questions. 

• Sherry (TF) – An extensive review of this substance failed to uncover a demand for this item. 

Numerous attempts to contact the original petitioner have been futile and the group discussed 

their inclination to delist Sherry based on this. Additionally, the lead reviewer found information 

that Sherry can be produced organically, but had a hard time finding specific information about 

this. The group will consider the public comment which will be incorporated into their decision for 

the spring 2014 vote. 

• Marsala (CBe) – The review for marsala resulted in the same determination as for sherry; there 

were no organic products found containing sherry and there was a lack of demand.

• The HS Chair asked the four completed sunset checklists be sent to the NOP for retention, so 

when the NOSB votes on these, at the spring 2014 meeting, they will be available. 

Future Call Schedule:

August 6, 2013 1:00 ET

Gellan Gum (JD) – deferred to August 20

Tragacanth (JD) - deferred to August 20

PGME discussion and vote (JR) – opened vote

Ancillary substances (ZS) - deferred to August 20

Glycerin (TF) – opened vote
Research priorities topics - done

August 20, 2013 12:00 ET

PGME - finalize vote - done

Glycerin - finalize vote - done

Gellan Gum (JD) - Discuss checklist-done

Tragacanth (JD) - Discuss checklist-done

Ancillary substances (ZS) - continued discussion - deferred

Marsala – Discuss-done

Sherry – Discuss-done

September 3, 2013 1:00 ET

Ancillary substances (ZS) - continued discussion if NOP has sent feedback

Discuss HS workplan

Discuss Sunset Guidance

September 17, 2013 1:00 ET

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, September 3, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Carmela Beck (CBe), Joe Dickson (JD)

Absent: Nick Maravell (NM), Jean Richardson (JR)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

NA On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No

2001 TAP

2000 petition. 2001 

Recommendation. 2001 

Background Paper. 2012 Petition sent 

to HS 11 06 12. Petition Sufficiency 

Response Due Date: 01 27 13. 

Petition found sufficient 12 18 12. No 

TR requested

 

Voted

02 19 13

Fall 2013

Glycerin

CAS #(56-81-5)

Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13, 

Proposal

Voted

08 20 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR 2013 TR Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13. Discussion doc.

Voted

08 20 13 Disc doc

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Conta

ct

TR rqst? Notes* Vote Meeting

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) 2011 TR

2003 TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Microorganisms 205.605 2003 TAP Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Activated 

charcoal 

CAS #s 7440–44–

0; 64365–11–3

205.605(b) 2002 TAP Final Sunset Recommendation on

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Peracetic acid

CAS # 79–21–0

205.605(b))

2000 TAP 

handling

Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary-Spring 

2014/ProposalFall 2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) 2001 TAP Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) 2001 TAP Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Octadecylamine

CAs # 124-30-1

205.605(b) 2001 TAP Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary-Spring 

2014/ProposalFall 2015

L-Malic acid

CAS # 97 -67-6). 

205.605(a) 2003 TAP Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary-Spring 

2014/ProposalFall 2015
2002 Sodium 

acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) 2001 TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/ProposalFall 2015

Tetrasodium 

pyrophosphate

CAS # 7722–88–5

205.605(b) TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/ProposalFall 2015

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

On hold?

Update Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from August 20, 2013 call

Discussion

• Notes from August 20, 2013 were approved with no changes

• The NOP will provide feedback to the Subcommittee about Ancillary Substances soon, and the

Subcommittee will give a verbal update at the fall meeting whether or not they receive feedback.

• Workplan - The current workplan consists of 4 sunset materials, ancillary substances, and possibly 

gibberellic acid. The members discussed moving ahead with the 2016 Sunset materials, of which 

there are 10. MA will add the 10 items (with links to the previous documents and the status of the 

TRs) to the workplan table prior to sending out the notes for review so the members can review it 

for the next call. Two or three of the sunset items might have ancillary substances. The members 

discussed the plan for reviewing the sunset materials and agreed that they need to first 

determine if they need technical reports. NOP will provide an update on which TRs have already 

been commissioned. 

• Thinking forward to the fall semester and the composition and size of the Subcommittees, MS 

asked that the Subcommittee determine how many members would be ideal given the workload. 

The size and membership of each of the Subcommittees will be altered after the fall 2013 
meeting.

• The group will discuss how to present the 2015 Sunset materials and public comment summaries

on the next call.

Future Call Schedule:

September 3, 2013 1:00 ET

Discuss HS workplan

Discuss Sunset Guidance

September 17, 2013 1:00 ET

Ancillary substances (ZS) - continued discussion if NOP has sent feedback

Discuss Sunset 2015 Materials presentations for fall 2013 NOSB meeting. 

Discuss and decide what content will be delivered in addition to the summaries that LB will 

 present

October 1, 2013 1:00 ET

October 15, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, September 17, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Harold Austin (Vice-Chair) (HA), Zea Sonnabend (ZS), Tracy Favre (TF), 

Joe Dickson (JD), Nick Maravell (NM), Jean Richardson (JR), Mac Stone (MS)-sitting in

Absent: Carmela Beck (CBe)

Staff: Michelle Arsenault (MA) (Advisory Board Specialist (ABS)), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

NA On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No

2001 TAP

2000 petition. 2001 

Recommendation. 2001 

Background Paper. 2012 Petition sent 

to HS 11 06 12. Petition Sufficiency 

Response Due Date: 01 27 13. 

Petition found sufficient 12 18 12. No 

TR requested

 

Voted

02 19 13

Fall 2013

Glycerin

CAS #(56-81-5)

Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13, 

Proposal

Voted

08 20 13

Fall 2013

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR 2013 TR Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13. Discussion doc.

Voted

08 20 13 Disc doc

Fall 2013
2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Conta

ct

TR rqst? Notes* Vote Meeting

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FRnotice

Summary-Fall 

2013/ProposalSpring 2014

2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) TF 2011 TR

2003 TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Microorganisms 205.605 ZS 2003 TAP Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Activated 

charcoal

CAS #s 7440–44–

0; 64365–11–3

205.605(b) HA 2002 TAP Final Sunset Recommendation on 

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Peracetic acid

CAS # 79–21–0

205.605(b)) JR

2000 TAP Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary-Spring 

2014/ProposalFall 2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) JR 2001 TAP Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) JR 2001 TAP Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/ProposalFall 2015

Octadecylamine

CAs # 124-30-1

205.605(b) CBe 2001 TAP Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary-Spring 

2014/ProposalFall 2015

L-Malic acid

CAS # 97 -67-6). 

205.605(a) JD 2003 TAP Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary-Spring 

2014/ProposalFall 2015
2002 Sodium 

acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) JD 2001 TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/ProposalFall 2015

Tetrasodium 

pyrophosphate

CAS # 7722–88–5

205.605(b) ZS 2002 TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/ProposalFall 2015

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances

(Auxiliary/”other” ingredients) (PDF)

On hold?

Update Fall 2013

* Highlight indicates committee action needed. 

Agenda

• Approve notes from September 3, 2013

• Ancillary substances (ZS) - continued discussion if NOP has sent feedback 

• Discuss Sunset 2015 materials presentations for fall 2013 NOSB meeting. 

• Discuss and decide what content will be delivered in addition to the summaries that LB will 

present

• Discuss public comment received

Discussion

• Notes from September 3, 2013 were approved with no changes

• Ancillary substances (ZS) - The NOP has discussed some ideas about ancillary substances and will 

have some feedback for the group on the next call.

• Sunset 2015 materials presentations for fall 2013 NOSB meeting. The sunset summary document 

that was posted by the NOP will be projected and LBrines will introduce each material. The Chair 

asked that each of the 4 Subcommittee members recap the high points of their initial review and 

summarize any public comments. He also asked that each member let MA know what will be 

projected. The group discussed the new sunset process and expressed concern about the lack of 

additional information available to the public. Without a proposal or in some cases, a technical 

report, information is limited and it may not elicit much feedback. Additionally, they are 

concerned that even if they receive public comment, the Board is no longer allowed to make any 
changes to proposals during the follow up NOSB meeting, but will only be able to vote up or down 

(i. e. keep the material on the national list or remove it). The possibility of tabling some decisions 

to a third meeting was discussed, in cases where the Board finds a need to change a proposed 

motion. The Handling Subcommittee would like to request that the new sunset process be 

discussed and clarified at the meeting. Members also discussed having a separate checklist when 

reviewing sunset materials; similar to the current one, but without the voting section. A member 

found that using the checklist was very helpful, although it has not always been used 

systematically in the past. 

• Public comment. Only one comment has been received thus far, regarding ammonium hydroxide. 

The NOP noted that it would be helpful to hear what the milk producers are using now. JR offered 

to do some research and report back to the group about alternatives. 

• 2016 sunset materials were added to the above table, and the members volunteered to review 

specific items. See table above for assignments. The Chair asked that the lead reviewer look at the 

last TAP or TR and determine whether or not they would like to request a new one. He also 

indicated that it would be possible to request a partial TR if need be. Currently, one TR has 

already been requested, for microorganisms. 

• MS noted that if the Subcommittee structure changes after the elections at the fall meeting, the 

group should think about the transition process with regard to reviews in progress. 

• The meeting was adjourned

Future Call Schedule:

September 3, 2013 1:00 ET

Discuss HS workplan

Discuss Sunset Guidance

September 17, 2013 1:00 ET

Ancillary substances (ZS) - continued discussion if NOP has sent feedback - postponed

Discuss Sunset 2015 Materials presentations for fall 2013 NOSB meeting

Discuss and decide what content will be delivered in addition to the summaries that LB will 

 present

October 1, 2013 1:00 ET

Ancillary substances (ZS) - continued discussion if NOP has sent feedback

Public Comment

October 15, 2013 1:00 ET

November 5, 2013 1:00 ET

November 19, 2013 1:00 ET

December 3, 2013 1:00 ET

December 17, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013

Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013
NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call October 11, 2013

Fall 2013 NOSB Meeting – Louisville, KY October 22-24, 2013
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, November 5, 2013, 1:00 pm ET

Present: John Foster (Chair) (JFo), Zea Sonnabend (ZS), Tracy Favre (TF), Jean Richardson (JR), Carmela 

Beck (CBe), Mac Stone (MS)-sitting in

Absent: Harold Austin (Vice-Chair) (HA), Joe Dickson (JD), Nick Maravell (NM)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan (Will be replaced with updated version after November Executive Call)

Petitioned Substances

Substance National 

List §

Contact TR rqst? Notes* Vote Meeting

Gibberellic 

acid

Petition 

Addendum

Add to 

205.605

ZS, TF Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

NA On hold

2012 

Ammonium 

hydroxide 

(boiler water 

additive)

Add to 

205.605

JR No

2001 TAP

2000 petition. 2001 

Recommendation. 2001 

Background Paper. 2012 Petition sent 

to HS 11 06 12. Petition Sufficiency 

Response Due Date: 01 27 13. 

Petition found sufficient 12 18 12. No 

TR requested

 

Voted

02 19 13

Fall 2013

Meeting

cancelled

Glycerin

CAS #(56-81-5)

Remove

from 

205.605(b)

TF 1995 TR

2013 TR

Petition sent to HS on 01 09 13. 

Sufficiency response due 03 11 13. TR 

sent to HS on 06 11 13. Sufficiency 

due 08 12 13. TR found suff 07 02 13, 

Proposal

Voted

08 20 13

Fall 2013

Meeting 

cancelled

Polyalkylene 

glycol 

monobutyl 

ether PGME 

(PDF) (CAS # 

9038-95-3) As 

a boiler water 

additive

205.605 JR 2013 TR Petition sent to MS/HS 01 28 13. TR 

Requested 2 19 2013. Draft TR sent to 

HS 06 11 13. TR sufficiency response 

due 08 12 13. TR found sufficient 07 

02 13. Discussion doc.

Voted

08 20 13 Disc doc

Fall 2013

Meeting 

cancelled

Whole algal 

flour

205.606 Petition sent to HS on 09 30 13. TBD
2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Conta

ct

TR rqst? Notes* Vote Meeting

Fall 2013 

meeting cancelled

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Marsala 205.606(g) CBe No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FR notice

Summary-Fall 

2013/ProposalSpring 2014

2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) TF 2011 TR

2003 TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/Proposal-Fall 

2015

Microorganisms 205.605 ZS 2003 TAP Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009. TR requested

Summary-Spring 

2014/Proposal-Fall 

2015

Activated 

charcoal

CAS #s 7440–44–

0; 64365–11–3

205.605(b) HA 2002 TAP Final Sunset Recommendation on 

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/Proposal-Fall 

2015

Peracetic acid

CAS # 79–21–0

205.605(b)) JR

2000 TAP Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary-Spring 

2014/Proposal-Fall 

2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) JR 2001 TAP Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/Proposal-Fall 

2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) JR 2001 TAP Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary-Spring 

2014/Proposal-Fall 

2015

Octadecylamine

CAs # 124-30-1

205.605(b) CBe 2001 TAP Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary-Spring 

2014/Proposal-Fall 

2015
L-Malic acid

CAS # 97 -67-6). 

205.605(a) JD 2003 TAP Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary-Spring 

2014/Proposal-Fall 

2015

2002 Sodium 

acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) JD 2001 TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/Proposal-Fall 

2015

Tetrasodium 

pyrophosphate

CAS # 7722–88–5

205.605(b) ZS 2002 TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009

Summary-Spring 

2014/Proposal-Fall 

2015

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances

(Auxiliary/”other” ingredients) (PDF)

On hold?

Update Fall 2013

Meeting cancelled

* Highlight indicates committee action needed. 

Agenda

• Approve notes from September 17, 2013

• Public Comments 

• Discuss newly petitioned whole algal flour (Sent to HS on 09 30 13)

• Verbal update on ancillary substances (EBR)?

Discussion

• Notes from September 17, 2013 were approved with no changes

• Public Comments:

o Ammonium hydroxide. The group discussed several comments, including one that raised 

the issue of broader use of boiler chemicals currently on 205.605. The public comments 

do not provide evidence of a demand for the substance, and the primary reviewer 

believes this substance does not replace the need for the volatile amines now listed for 

use in sterilizing packaging. The primary reviewer recommended maintaining the original 

proposal as is. The NOP mentioned the potential for adding questions, so when the 

proposal gets posted again before the spring 2014 meeting, they could receive additional 

information. 
o Glycerin. Based on the analysis of the public comments received, the glycerin proposal

will not be changed. 

• Ancillary substances (EBR) - The NOP has drafted a formal memo which will be sent to the NOSB 

soon. The group discussed the process for reviewing ancillary substances, using microorganisms 

as an example of a material due to sunset in 2016 and that also contains ancillary substances. The 

first meeting at which this material will be introduced and posted for comment will be fall 2014 

and the meeting at which the NOSB will vote on this material will be spring 2015. If there is a 

recommendation for removal from the National List then it has to be done by spring 2015. The

memo will outline a new process by which NOSB can either describe approved ancillaries in their 

final sunset review document, or if there is a need for a change to an annotation NOSB will need 

to make a separate proposal, subject to public comment. There was discussion about the need to 

review ancillary substances using OFPA criteria, while giving consideration to the fact that they 

are used only in minor amounts. 

• Whole algal flour – The Handling Subcommittee received this petition just prior to the 

government shutdown and the cancellation of several of its meetings, so has not had a chance to 

discuss or review it. The NOP suggested that the members look at the FDA letter of no objection 

in response to the manufacturer’s self-declared GRAS notification, which should explain how 

whole algal flour is made.

• Workplan - ZS had previously proposed that an item be added to the HS workplan on prohibiting 

BPA in packaging and offered to work on a briefing paper for submission to the HS and Executive 

Subcommittee. Perhaps a 2015 proposal. The group considered that they may need a TR and will 

need to discuss where this would fit in the rule. The Board Chair asked the Subcommittee Chair 

how to balance this item with the other workplan items in light of the fact that the Subcommittee

membership could be changing. Several items were added to the schedule below for future 

discussions.

• The workplan table has been updated with the 2014 workplan items and will replace the one 

above in the next set of notes. Additionally, a 2014 milestone timeline has been added below and 

will replace the fall 2013 milestones.

Future Call Schedule:

October 1, 2013 1:00 ET (CANCELLED)

Ancillary substances (ZS) - continued discussion if NOP has sent feedback

Public Comment

October 15, 2013 1:00 ET (CANCELLED)

November 5, 2013 1:00 ET

November 19, 2013 1:00 ET

Review and discuss public comments and determine whether any of the proposals should be 

revised based on these comments.

Whole algal flour 

December 3, 2013 1:00 ET

Prohibiting BPA 

December 17, 2013 1:00 ET

Fall 2013 Milestones Target date

NOP – Complete tentative agenda August 9, 2013
Fall 2013 proposals due to NOP August 27, 2013

NOP - Post proposals, Publish FRN, Open public comment September 3, 2013

Subcommittees submit tentative workplans to NOP September 11, 2013

Discuss workplans on ES call September 13, 2013

NOP provides written comments on workplans to NOSB September 23, 2013

Public comment closes October 1, 2013

NOP - Send compiled public comments to NOSB ~October 7, 2013

Workplans finalized on ES call CANCELLED 

Fall 2013 NOSB Meeting – Louisville, KY CANCELLED 

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, November 19, 2013, 1:00 pm ET

Present: Zea Sonnabend (ZS), Tracy Favre (TF), Jean Richardson (JR), Harold Austin (Vice-Chair/2014 Chair) 

(HA), Joe Dickson (JD), Carmela Beck (CBe)

Absent: John Foster (Chair/2014 Vice Chair) (JFo), Nick Maravell (NM), Jennifer Taylor (JT)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Cont

act

TR 

rqst?

Notes* Vote Meeting

Gibberellic acid

Petition Addendum

Add to 

205.605

ZS, 

TF

Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

Fall 2014

Whole algal flour 205.606 HA Petition sent to HS on 09 30 13. TBD

2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR 

rqst?

Notes* Vote Meeting

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Marsala 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014
2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) TF 2011 TR

2003 

TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Microorganisms 205.605 ZS 2003

TAP 

Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009. TR requested

Summary: Fall 2014

Review: Spr 2015

Activated 

charcoal

CAS #s 7440–44–

0; 64365–11–3

205.605(b) HA 2002 

TAP

Final Sunset Recommendation on 

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Peracetic acid

CAS # 79–21–0

205.605(b)) JR

2000 

TAP

Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary: Fall 2014

Review: Spr 2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) JR 2001 

TAP

Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) JR 2001 

TAP

Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Octadecylamine

CAs # 124-30-1

205.605(b) CBe 2001 

TAP

Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary: Fall 2014

Review: Spr 2015

L-Malic acid

CAS # 97 -67-6). 

205.605(a) JD 2003 

TAP

Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary: Fall 2014

Review: Spr 2015

2002 Sodium 

acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) JD 2001 

TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary: Fall 2014

Review: Spr 2015

Tetrasodium 

pyrophosphate

CAS # 7722–88–5

205.605(b) ZS 2002 TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009

Summary: Fall 2014

Review: Spr 2015
Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Spring 2014?

* Highlight indicates committee action needed. 

Agenda

• Approve notes from November 5, 2013

• Public Comments and potential revision of fall 2013 proposals

• Discuss whole algal flour (Sent to HS on 09 30 13)

Discussion

• Notes from November 5, 2013 approved with no changes

• Public Comment

o Gellan gum, Tragacanth. Several members indicated that the comments were such that 

they would not warrant a revision of these proposals, and the Handling Subcommittee 

will not request new TRs. 

o Sherry and Marsala. The members felt that there weren’t any comments to support 

revision of the preliminary proposals, not yet posted. The group will begin writing the 

actual “initial summary”. The NOP is working on a template for the Sunset reviews, which 

may include an abbreviated checklist. The NOP is unsure when the template will be ready 

but would like to get it to the NOSB as soon as possible. As part of the review, the HS

would like to pose questions about commercial availability for the next round of 

comments. 

o Glycerin. One commenter questioned the impact of the removal of glycerin on flavorings, 

as glycerin is an ancillary substance. ZS feels that it won’t have any impact, as those 

people making organic flavorings will be able to use organic glycerin, and “natural flavors” 

can use the nonsynthetic forms, but would like to research this further. The NOP also 

noted that there could be an impact on vitamins and minerals, as glycerin is used in the 

manufacture of those. HA asked that TF look into this so the group can discuss it on the 

next call. Members discussed adding a question about the adequacy of the supply of 

organic glycerin. 

o Ammonium hydroxide, PGME - JR will maintain her position as lead reviewer for the 

presentation of Ammonium hydroxide at the spring NOSB meeting even though she is 

rotating off of the Handling Subcommittee. 

o CBe will transfer leadership of Marsala and sherry to TF for presentation at the spring

meeting. 

• Whole Algal Flour - The NOP noted that the production process wasn’t described in detail in the 

petition. For example fermentation medium and nutrients were not discussed. In review of the 

petition, the NOP recommended that Whole Algal Flour be placed on 205.606 of the National List 

and not 205.605 for which it was petitioned. HA volunteered to take the lead on this material. 
• 2016 sunsets. The new Handling Chair asked the NOSB Chair if it was possible to add one more 

member to the Subcommittee roster to accommodate the increased workload for sunset 2016. JR 

noted that she would like to remain on the Subcommittee, as she is interested. 

• The ancillary substances memo is in review within the NOP. EBR hopes to have a template ready 

soon, as well as forms and procedures in place before the December conference call to go over 

the sunset process. 

• Two key members of the Subcommittee (ZS and HA) may not be available for the December 3 call, 

and the group discussed rescheduling. HA will talk with JFo on TH and may postpone.

Future Call Schedule:

November 19, 2013 1:00 ET

Review and discuss public comments and determine whether any of the proposals should be 

revised based on these comments.

Whole algal flour 

December 3, 2013 1:00 ET

Whole algal flour

Reassign some of the materials based on membership

Update on Ancillary Substances

December 17, 2013 1:00 ET

Prohibiting BPA

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, December 3, 2013, 1:00 pm ET

Present: Harold Austin, Chair (HA), John Foster, Vice Chair (JFo), Jennifer Taylor (JT), Tracy Favre (TF), Joe 

Dickson (JD), Mac Stone (MS) - sitting in, Jay Feldman (JFe) - sitting in

Absent: Zea Sonnabend (ZS), Jean Richardson (JR)

Staff: Michelle Arsenault (MA), Emily Brown Rosen (EBR)

Work Plan

Petitioned Substances

Substance National 

List §

Cont

act

TR 

rqst?

Notes* Vote Meeting

Gibberellic acid

Petition Addendum

Add to 

205.605

ZS, 

TF

Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

Fall 2014

Whole algal flour 205.606 HA Petition sent to HS on 09 30 13. 

Petition suff (including TR Request, if 

applicable) due 11 29 13. TR found 

insufficient. Sent addit’l Q’s to TR 

contractor

TBD

2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR 

rqst?

Notes* Vote Meeting

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Marsala 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014
2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) TF 2011 TR

2003 

TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Microorganisms 205.605 ZS 2003

TAP 

Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009. TR requested by 

NOP Aug 26 2013. Due late Dec.

Summary: Fall 2014

Review: Spr 2015

Activated 

charcoal

CAS #s 7440–44–

0; 64365–11–3

205.605(b) HA 2002 

TAP

Final Sunset Recommendation on 

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Peracetic acid

CAS # 79–21–0

205.605(b)) JFo

2000 

TAP

Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary: Fall 2014

Review: Spr 2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) JT/HA 2001 

TAP

Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) JT/HA 2001 

TAP

Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Octadecylamine

CAs # 124-30-1

205.605(b) TF 2001 

TAP

Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary: Fall 2014

Review: Spr 2015

L-Malic acid

CAS # 97 -67-6). 

205.605(a) JD 2003 

TAP

Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary: Fall 2014

Review: Spr 2015

Sodium acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) JD 2001 

TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary: Fall 2014

Review: Spr 2015
Tetrasodium 

pyrophosphate

CAS # 7722–88–5

205.605(b) ZS 2002 TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009

Summary: Fall 2014

Review: Spr 2015

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Spring 2014?

* Highlight indicates committee action needed. 

Agenda

• Approve notes from November 19, 2013

• Reassign materials based on new SC membership

• Whole algal flour (HA)

• Update on Ancillary Substances (EBR)

• 2015 Sunset materials

• Other business

Discussion

• Notes from November 19, 2013 were approved with no changes

• The new Subcommittee Chair, HA, designated John Foster (JFo) as Subcommittee Vice Chair and 

welcomed Jennifer Taylor (JT) to the Subcommittee

• Reassign materials and discuss work load 

o JT volunteered to work with EBR and HA on two of the boiler chemical additives 

(Cyclohexylamine and Diethylaminoethanol). TF volunteered to lead Octadecylamine. HA 

will send a note to the two former leads (CBe and JR) requesting any material they may 

have developed for these items. Discussions dates to determine the need for Technical 

Reports (TRs) were scheduled below. The 2016 Sunset Materials are scheduled for their 

first posting in the fall of 2014 and TR requests are due to the NOP by January 15, 2014. 

• Whole Algal Flour (WAF) – The group discussed the sufficiency of the petition. The NOP 

suggested that it would be helpful to ask the petitioner about the source organism, as it seems 

many of them are GMOs. WAF is an algae that goes through a fermentation process and would be 

used to replace eggs, milk, and fat in products. HA will compile some additional question for the 

next call for the group to discuss.

• Update on Ancillary Substances. The NOP should have an update in the next week or two and will 

send a note to HS when it is ready. 

• 2015 Sunset materials. Reviews of the 2015 Sunset materials are in progress, and HA asked that 

the members prepare to discuss the public comments that were received in the fall of 2013.
o A TR for microorganisms was requested by the NOP in August 2013 and is due back in 

late December

• Other Subcommittee business

o The discussion about prohibiting BPA is scheduled for the December 17 call.

o The post-harvest handling draft guidance document is starting to move through the 

clearance process, which may have an impact on the gibberellic acid review. 

o EBR will be unavailable for the December 17 call and will locate a substitute

Future Call Schedule:

November 19, 2013 1:00 ET

Review and discuss public comments and determine whether any of the proposals should be 

revised based on these comments.

Whole algal flour

December 3, 2013 1:00 ET

Whole algal flour

Reassign materials based on new SC membership

Update on Ancillary Substances

December 17, 2013 1:00 ET

Discuss prohibiting BPA idea

Egg white lysozyme - determine need for TR

Microorganisms – Discuss checklist?

Activated charcoal - determine need for TR

Peracetic acid - determine need for TR

January 7, 2014 1:00 ET

Cyclohexylamine - determine need for TR

Diethylaminoethanol - determine need for TR

Octadecylamine - determine need for TR

Update on ancillary substances (NOP)

January 21, 2014 1:00 ET

L-Malic acid - determine need for TR

Sodium acid pyrophosphate - determine need for TR

Tetrasodium pyrophosphate - determine need for TR

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014
Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014
Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling.

National Organic Standards Board (NOSB)

Handling Subcommittee (HS) Meeting Notes

Tuesday, December 17, 2013, 1:00 pm ET

Present: Harold Austin, Chair (HA), John Foster, Vice Chair (JFo), Jennifer Taylor (JT), Tracy Favre (TF), Zea 

Sonnabend (ZS), Mac Stone (MS) - sitting in

Absent: Emily Brown Rosen (EBR), Joe Dickson (JD)

Staff: Michelle Arsenault (MA), Shannon Nally Yanessa (SNY)

Work Plan

Petitioned Substances

Substance National 

List §

Cont

act

TR 

rqst?

Notes* Vote Meeting

Gibberellic acid

Petition Addendum

Add to 

205.605

ZS, 

TF

Yes Petition sent to HS 07 27 12. Petition 

suff response due 09 27 12. Sent back 

to petitioner for additional questions 

01 09 13. Rcvd response 04 16 13. On 

hold until post- harvest handling draft 

guidance is published.

Fall 2014

Whole algal flour 205.606 HA Petition sent to HS on 09 30 13. 

Petition suff (including TR Request, if 

applicable) due 11 29 13. TR found 

insufficient. Sent addit’l Q’s to TR 

contractor

TBD

2015 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR 

rqst?

Notes* Vote Meeting

Gellan gum CAS # 

71010-52-1

205.605(a) JD Y 2006 TR, 2008 

Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Marsala 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Sherry 205.606(g) TF No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014

Tragacanth 

CAS # 9000-65-1

205.606(x) JD No 2008 Recommendation

2010 FR notice

Summary: Spr 2014

Review: Fall 2014
2016 Sunsets § 205.605(a) and 205.606

Name National 

List §

Con

tact

TR rqst? Notes* Vote Meeting

Egg white 

lysozyme 

CAS # 9001–63–2

205.605(a) TF No new 

TR

2011 TR

2003 

TAP 

Final Sunset Recommendation on 

Egg White Lysozyme on 205.605b 

(PDF) Nov 2009. 

Summary: Fall 2014

Review: Spr 2015

Microorganisms 205.605 ZS Y

2003

TAP 

Final Sunset Recommendation on 

Microorganisms on 205.605b 

(PDF) Nov 2009. TR requested by 

NOP Aug 26 2013. Due late Dec.

Summary: Fall 2014

Review: Spr 2015

Activated 

charcoal

CAS #s 7440–44–

0; 64365–11–3

205.605(b) HA No new 

TR

2002 

TAP

Final Sunset Recommendation on 

Activated Charcoal on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Peracetic acid

CAS # 79–21–0

205.605(b)) JFo No new 

TR

2000 

TAP

Final Sunset Recommendation on 

Peracetic Acid on 205.605b (PDF)

Oct 2009

Summary: Fall 2014

Review: Spr 2015

Cyclohexylamine

CAS # 108 -91-8

205.605(b) JT/HA 2001 

TAP

Final Sunset Recommendation on 

Cyclohexylamine on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Diethylaminoeth

anol

CAS # 100–37–8

205.605(b) JT/HA 2001 

TAP

Final Sunset Recommendation on 

Dethylaminoethanol on 205.605b 

(PDF) Nov 2009

Summary: Fall 2014

Review: Spr 2015

Octadecylamine

CAs # 124-30-1

205.605(b) TF 2001 

TAP

Final Sunset Recommendation on 

Octadecylamine on 205.605b 

(PDF) Nov. 2009

Summary: Fall 2014

Review: Spr 2015

L-Malic acid

CAS # 97 -67-6). 

205.605(a) JD 2003 

TAP

Final Sunset Recommendation on 

L-Malic Acid on 205.605b (PDF)

Nov 2009

Summary: Fall 2014

Review: Spr 2015
Sodium acid 

pyrophosphate

CAS # 7758–16–9

2009 Expanded 

use

205.605(b) JD 2001 

TAP

2010 TR

Apr 2011 Subcomm 

recommendation

April 2011 NOSB 

recommendation

Final Sunset Recommendation on 

SAPP on 205.605b (PDF) Nov 

2009

Summary: Fall 2014

Review: Spr 2015

Tetrasodium 

pyrophosphate

(TSPP)

CAS # 7722–88–5

205.605(b) ZS 2002 TR Final Sunset Recommendation on 

TSPP on 205.605b (PDF) Nov 

2009. May request a TR (limtd 

scope)

Summary: Fall 2014

Review: Spr 2015

Other projects

Name Contact Notes* Meeting

Ancillary 

Substances

ZS Final Recommendation: Ancillary Substances 

(Auxiliary/”other” ingredients) (PDF)

Spring 2014?

Potential future projects

Name Contact Notes* Meeting

BPA prohibition ZS Working on briefing paper for submission to NOP Discussion doc

TBD

* Highlight indicates committee action needed. 

Agenda

• Approve notes from December 3, 2013

• Discuss Tetrasodium pyrophosphate (TSPP)

• Egg white lysozyme - determine need for TR

• Activated charcoal - determine need for TR

• Peracetic acid - determine need for TR

• Discuss prohibiting BPA idea

• Other business
Discussion

• Notes from December 3, 2013 were approved with no changes. 

• Discuss Tetrasodium pyrophosphate (TSPP) - TSPP is a dough conditioner for grain based meat 

analogue products. It does not appear on labels because it is used as a processing aid. The group 

discussed the potential need for a new TR and whether or not this material should remain on the 

National List, and whether they could motion to remove without a new TR. The lead reviewer 

provided a review document with justification for why this material should be removed from the 

list. She feels that TSPP is used in foods that are over processed, which is one of the criteria used 

by the NOSB when reviewing materials. It is used to make the protein extracted from grain 

digestible. She indicated TSPP can also act as a preservative and texturizer, which is not consistent 

with the regulation criteria, but acknowledged that this is subject to interpretation. She also 

indicated that the original TR was thorough and doesn’t see the need for a new one. However,

after discussing this further, the group decided to request a limited scope TR. Potential questions 

that could be useful are how TSPP is being used, how much is used, and what alternatives are 

available. A member noted that a TR wouldn’t be able to address these questions, so it might not 

be the best option. Another member countered that in light of the new sunset process, removing 

an item should be supported by new evidence, which would be gleaned from a TR or public 

comment. ZS will compile a document for the group to review on the next call, and will submit it 

to the NOP along with a request for a new TR. The group then had a more general discussion 

about the Sunset review process and what criteria they use to determine whether or not to 

request a new TR. A member noted that TRs should be requested only when the currency or 

accuracy of an old TR is in question. The lead feels that in this instance a new TR will also help to 

illuminate the fact that this substance is a food ingredient when it is not common knowledge

because it is not disclosed on labels. 

• Egg white lysozyme - Egg white lysozyme is an enzyme, derived from egg whites, primarily used 

for inhibiting growth of microbes. It’s is a benign material. There is a 2011 TR for enzymes, and 

the lead reviewer feels there isn’t a need for a new one. One member indicated that it is not clear 

if there is an organic version, but that using organic egg whites would be cost prohibitive. It is not

clear if the alternative substances are organic. A member questioned the possibility of lysozyme 

having ancillary substances and if that would affect the review. The Subcommittee will include 

questions about ancillary substances in the initial review document and chose not to request a 

new TR. 

• Activated charcoal - Petitioned as a filtering aid to remove brown pigment from white wine or 

grape juice and reduce odor of breakdown. The group discussed activated charcoal and the 

annotation in the listing that it is ‘derived only from vegetative sources’, which prohibits 

alternative sources. After reviewing the existing documentation, the lead reviewer determined 

that there was no need for a new TR and that the material is not problematic from a human 

health or environmental standpoint.

• Peracetic acid - The lead reviewer noted that this substance is also sometimes referred to as 

Peroxyacetic acid. The last TAP review was completed in 1999, and was found to be very thorough

and technically adequate. In 2009 the NOSB reviewed this substance and received comments 

supporting its relisting, and the NOSB vote was overwhelmingly in favor of doing so. There doesn’t 

seem to be any controversy in public discourse and the HS is not inclined to ask for new TR.

• Prohibiting BPA idea - BPA is a chemical used in plastics such as can liners. BPA can leach into food 

and has been linked to adverse human health consequences, such as prenatal affects, 

reproduction ability, cardiovascular disease, and hormone disruption. The lead reviewer
circulated a background paper along with citations for two recent papers about this issue and 

asked that the group review them. The FDA has acted to prohibit BPA in certain products for 

certain segments of the population, such as infants and children. However, it has not been 

banned for such things as can liners. BPA-free can lining is more costly and has not been fully 

developed for tomato products. While the FDA hasn’t prohibited it, many manufacturers have 

voluntary removed it from their products and there has been a shift in that direction. One 

member reported a certifier receiving numerous public inquiries about why BPA is not banned in 

organic products. ZS proposed two possible directions for the NOSB: A rule change to add BPA to 

205.272(b)1, or reference of 205.272(b)(2) to prohibit BPA w/o rule change. 205.272(b)2 prohibits 

the use of any bag or container that would compromise the integrity of any organically produced 

product. The group discussed the best direction, and felt the best way to proceed would be to 

put forth a discussion document presenting the scientific evidence and posing questions about 

market reaction (how would this affect business) and how much compliance time would be

needed. Based on public comment, the HS could then decide how quickly to proceed. The 

discussion document could potentially be ready for the spring 2014 meeting, but could wait until 

fall 2014. The Subcommittee will seek approval from NOP about adding it to the workplan. A 

member suggested contacting a past NOSB member who worked on this topic professionally as 

she might have some useful insight. The HS Chair asked that the lead reviewer retitle the 

document as a briefing paper and send it to MA and HA for submission to the NOP for approval. 

• The HS Chair noted that there are a total of 104 sunset reviews for 2017 and has asked for 

volunteers from other Subcommittees. During the next few calls, the group will assign leads for 

these substances. MS volunteered to review some of them. 

• Other business

Future Call Schedule:

December 3, 2013 1:00 ET

Whole algal flour

Reassign materials based on new SC membership - completed

Update on Ancillary Substances

December 17, 2013 1:00 ET

Discuss prohibiting BPA idea

Egg white lysozyme - determine need for TR

Activated charcoal - determine need for TR

Peracetic acid - determine need for TR

Tetrasodium pyrophosphate - determine need for TR

January 7, 2014 1:00 ET

Discuss Tetrasodium pyrophosphate (TSPP) notes for TR request 

Microorganisms – discuss checklist

Cyclohexylamine - determine need for TR

Diethylaminoethanol - determine need for TR

Octadecylamine - determine need for TR

L-Malic acid - determine need for TR

Sodium acid pyrophosphate - determine need for TR

January 21, 2014 1:00 ET

Update on ancillary substances (NOP)
February 7, 2014 1:00 ET

February 21, 2014 1:00 ET

March 4, 2014 1:00 ET

March 18, 2014 1:00 ET

April 1, 2014 1:00 ET

April 15, 2014 1:00 ET

Spring 2014 Milestones Target date

Subcommittee requests technical reports for Sunset 2016 substances Jan 15, 2014

NOSB Training meeting Feb 4 - 5, 2014

NOP – Complete tentative agenda Feb 7, 2014

Fall 2013 proposals due to NOP Feb 26, 2014

NOP - Post proposals, Publish FRN, Open public comment Mar 10, 2014

Subcommittees submit tentative workplans to NOP Mar 12, 2014

Discuss workplans on ES call Mar 14, 2014

NOP provides written comments on workplans to NOSB Mar 28, 2014

Public comment closes Apr 8, 2014

Workplans finalized on ES call Apr 11, 2014

NOP - Send compiled public comments to NOSB Apr 14, 2014

Spring 2014 NOSB Meeting – San Antonio, TX ~Apr 28- May 1, 2014