National Organic Standards Board 

Handling Committee 

Proposed Discussion Document 

 Petition to Remove Silicon Dioxide from National List 

March 8, 2011 

Committee Summary 

Silicon dioxide is common additive in the production of foods, where it is used primarily as a 

flow agent in powdered foods, to absorb water in hygroscopic applications, and in some cases 

used to suppress foaming in liquids under agitation. It is the primary active component of 

diatomaceous earth which has many uses ranging from filtration to insect control. 

Review of the original recommendation, historical documents, and public comments does not 

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

manufacture of silicon dioxide, though it does require special handling due to inhalation risks; 

limitations on its use and handling are governed by worker safety protocols and Good 

Manufacturing Practices. 

Silicon dioxide was voted by the NOSB at the fall 2010 meeting to be re-listed under the 

sunset review process, with the knowledge that a petition to remove silicon dioxide was in 

process of NOP review at that time. 

In 2007 (docket TM-04-07) public comment asserting that the inclusion of silicon dioxide on the 

National List was no longer necessary due to the availability of a certified organic alternative 

substance. This comment was provided by the manufacturer of the proposed alternative 

substance and since has been amended twice with additional information, all of which has 

been provided via written and oral public comment. At that time and since that time, some 

evidence has been provided to demonstrate the utility of an alternate in some applications 

where silicon dioxide is presently used. Several public comments supported re-listing silicon 

dioxide prior to the April 2010 NOSB meeting as part of the sunset review process. 

Two key features emerged from the discussions among the Handling committee: 

1. The Handling Committee has discussed and collectively agrees that there is the need to 

encourage the growth of agricultural--and preferably organic--alternatives to 

nonagricultural substances presently allowed on the National List for use in organic 

handling operations, and considers this to be just such an opportunity. 

2. Public comment indicates that while organic alternatives exist that may replace silicon 

dioxide as currently listed, the Handling Committee is concerned that alternatives do not 

exist for all uses and applications of silicon dioxide. 

The Handling Committee wants to elicit public comment to identify where alternatives to silicon 

dioxide are or may be used effectively and appropriately. Specifically, what alternatives to 

silicon dioxide are available and effective for use as: 
Proposed Discussion Document 

Silicon Dioxide 

March 8, 2011

Page 2 of 2

 An anti-caking agent in foods and animal feeds 

 A stabilizer in beer production 

 An adsorbent in tableted foods for special dietary use. 

 A carrier, such as a component of microcapsules for flavoring oils. 

 A defoaming agent. 

 Other uses allowed under FDA 

Comments from food manufacturers are particularly needed in order for the Handling 

Committee to assess the conditions under which silicon dioxide may be removed from the 

National List to promote the use of agricultural and organic alternatives and without causing 

undue burdens to manufacturers and consumers. 

Committee Vote 

Motion: To accept the discussion document 

Motion by: Katrina Heinze Second: John Foster 

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