National Organic Standards Board

Handling Subcommittee

Petitioned Material Proposal - Ammonium Hydroxide

November 18, 2014

Summary of Proposed Action:

Ammonium hydroxide is petitioned to be added to the National List at §205.605 as a boiler water 

additive. Ammonium hydroxide is a synthetic substance manufactured from natural gas; natural gas is 

used to convert atmospheric nitrogen to ammonia to which, water is added. The Handling 

Subcommittee proposes not to add ammonium hydroxide to the National List. 

Background:

Ammonium hydroxide has been on the National Organic Standards Board (NOSB) Work Agenda on 

and off for several years; review of this proposal should be considered in light of that history and 

changing trends in processing over the intervening years.

* The NOSB Organic Good Manufacturing Practices of 1995 did not include boiler additives.

 

* In 2001 ammonium hydroxide was petitioned for addition to the National List. The lengthy TAP 

Review (2/15/01) included many appendices and a Steam Paper which analyzes and compares all the 

boiler additives. This report included a recommendation to prohibit ammonium hydroxide. In August 

2001 there was also a lengthy analysis submitted to the NOSB comparing all the boiler additives.

* NOSB Recommendation dated October 2001 was to approve limited use of three boiler additives, 

cyclohexylamine, diethylaminoethanol and octadecylamine, and to approve ammonium hydroxide “for 

use as a boiler additive only, with removal from the National List October 21, 2005. If Office of General 

Counsel says no to shorter sunset date, the material remains prohibited.” Vote: 10 in favor, 3 

abstentions 1 no

* The Final Rule of NOP dated September 2006 (71 FR 53299) concluded that while most 

commenters wanted the chemical included some did not, however, the expiration date recommended 

by the NOSB had lapsed. Therefore, it was not added to the list. 

* A new petition was submitted on 10/30/12 to add ammonium hydroxide to the National List “solely for 

use as a boiler water additive, to neutralize carbon dioxide in steam condensate.” Petitioner suggests 

that addition of ammonium hydroxide as a boiler additive would allow elimination from the National List 

of the three synthetic volatile amines, cyclohexylamine and diethylaminoethanol, two neutralizing 

amines, and octadecylamine, a filming amine – these are approved for the limited use of packaging 

sterilization. 

* The petition was determined to be sufficient and on 2/19/13 the Handling Subcommittee voted not to 

add ammonium hydroxide to the National List (6:0 with two absences).. However, there was some 

public comment suggesting that ammonium hydroxide may be able to replace the three boiler additives 

scheduled for sunset discussion in October 2014, so this proposal was posted with a request for further 

public comment a vote by the full NOSB was deferred pending additional public comment on all boiler 

additives. 

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Discussion

Ammonium hydroxide is a powerful alkali petitioned for use as a boiler additive because it neutralizes 

carbonic acid in condensate to prevent corrosion, reducing pH to 8.5 or 9.0. The level of ammonium 

hydroxide required in steam would depend on the level of carbon dioxide in the steam. Ammonium 

hydroxide is produced by the addition of water to Ammonia. Ammonia is produced on a large scale 

worldwide. One of its largest uses by production volume is as an ingredient in conventional fertilizer 

(prohibited in organic agriculture).

Ammonium hydroxide is a severe irritant which must be handled properly because exposure by 

humans and other mammals during production or use presents a serious toxicological concern. It is 

toxic by all routes – inhalation, dermal and ingestion – and the toxicity is well documented. It is an air 

and water pollutant and contributes as a greenhouse gas. It is toxic to fish and other aquatic species. 

Spillage could cause considerable environmental damage.

There are a number of alternative practices that can be used instead of boiler additives. The 

alternatives include: replacement of steam lines with stainless steel piping, water treatment, physical or 

chemical deaeration, interruption of boiler water treatment prior to organic processing runs, bleed runs, 

dismantling and cleaning systems prior to organic food handling, steam to steam heat exchangers, a 

separate secondary boiler to generate steam for direct food contact applications.

The petition requests addition of ammonium hydroxide as a “boiler additive” to neutralize carbon 

dioxide in order to prevent acid attack in steam condensate lines. Where steam is used in or on food it 

is termed “culinary steam” and used in food processing for sanitation or sterilization of food contact 

surfaces, including packaging sterilization. Petitioner also suggested that the form of ammonium 

hydroxide in steam condensate is ammonium carbonate, which is on the National List at §205.605(b). 

However, ammonium carbonate is allowed for use “only as a leavening agent.”

Public comment was received in Fall 2013, Spring and Fall 2014 from several commenters, including 

the petitioner. The majority of the public comments recommended not adding ammonium hydroxide to 

the National List. There were no comments from any processor or handler asking for addition of this 

chemical. There was no evidence provided that ammonium hydroxide could replace the three other 

boiler chemicals under sunset discussion. 

Public comment did not indicate a demand for ammonium hydroxide, and there are many alternative 

practices that can be used instead of ammonium hydroxide as a boiler additive.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? (see “B” 

below)

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

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

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

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

as Organic (only for § 205.606)

Substance Fails Criteria Category: 3. Comments: 

Ammonium hydroxide has the potential to cause significant toxic damage to humans, mammals, 

aquatic systems and greenhouse gasses and is not essential or compatible with organic agriculture and 

handling.

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Proposed Annotation (if any): none

Recommended Committee Action & Vote

Classification Motion: Ammonium hydroxide (CAS # 1336-21-6) as petitioned is synthetic

Motion by: Jean Richardson 

Seconded by: Zea Sonnabend 

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

Listing Motion: To add ammonium hydroxide (CAS # 1336-21-6) to the National List Section 

205.605(b)

Motion by: Jean Richardson

Seconded by: Tracy Favre 

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

Approved by Harold Austin, Subcommittee Chair, to transmit to NOSB December 16, 2015

NOSB Evaluation Criteria for Substances Added To the National List

Category 1. Adverse impacts on humans or the environment?

Substance: Ammonium hydroxide

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Are there adverse effects on environment 

from manufacture, use, or disposal?

[§205.600 b.2]

X 

Toxic to environment if spilled or 

volatized to atmosphere (TAP 2001 and 

petition pages 8, 9, and 10)

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3]

X 

Worker injury through breathing, 

ingestion or dermal contact and terrestrial 

damage with spills during manufacture. 

(Petition pages 8,9, 10, and TAP 2001).

3. Is the substance harmful to the 

environment and biodiversity?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X 

Toxic damage will occur through spills in 

terrestrial or aquatic systems, and 

ammonia contributes to greenhouse 

gases. (Petition pages 8-10) Fish are 

particularly at risk for toxic effects.

4. Does the substance contain List 1, 2 or 3 

inerts? [§6517 c (1)(B)(ii); 205.601(m)2]

X

5. Is there potential for detrimental chemical 

interaction with other materials used?

[§6518 m.1]

X Ammonium hydroxide dissolves copper 

and zinc (Petition page 8 and TAP 2001)

6. Are there adverse biological and 

chemical interactions in agro-ecosystem? 

[§6518 m.5]

X Petitioned substance is intended for use 

in handing facilities, not land application, 

but spills would have negative impacts. 

Ammonia is used in conventional fertilizer 

but not permitted in organic agriculture.

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7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5]

X Yes, (petition page 10)

8. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518 m.2]

X Yes if spilled, or released into air

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment? 

[§6518 m.2]

X When released into air the gas 

contributes to greenhouse gases.

10. Is there any harmful effect on human 

health? [§6517 c (1)(A)(i); 6517 c(2)(A)i; 

§6518 m.4]

X Yes, toxic if inhaled, ingested, or dermal 

contact

11. Is there an adverse effect on human 

health as defined by applicable Federal 

regulations? [205.600 b.3]

X Yes, if inhaled, ingested, or dermal 

contact

12. Is the substance GRAS when used 

according to FDA’s good manufacturing 

practices? [§205.600 b.5]

X

13. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 

b.5]

X

Category 2. Is the Substance Essential for Organic Production? 

Substance: Ammonium hydroxide

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance formulated or 

manufactured by a chemical process? 

[6502 (21)]

X Ammonium hydroxide is manufactured 

from natural gas which is used to convert 

atmospheric nitrogen to ammonia and 

then water is added to produce the 

hydroxide form (petition page 4 and TAP 

2001).

2. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring plant, 

animal, or mineral, sources? 

[6502 (21)]

X

3. Is the substance created by naturally 

occurring biological processes? [6502 

(21)]

X

4. Is there a natural source of the 

substance? [§205.600 b.1]

X

5. Is there an organic substitute? [§205.600 

b.1]

X

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6. Is the substance essential for handling of 

organically produced agricultural 

products? [§205.600 b.6]

X Processors can utilize a number of 

alternative practices, such as stainless 

steel pipelines, physical and chemical 

deaeration, interrupt boiler water 

treatment prior to organic processing etc . 

These alternative practices cost time and 

money. (petition page 11) Although, 

economic considerations are not one of 

the criteria for suitability of materials used 

in organic production systems. (TAP 

2001, page9)

7. Is there a wholly natural substitute 

product?

[§6517 c (1)(A)(ii)]

X

8. Is the substance used in handling, not 

synthetic, but not organically produced?

[§6517 c (1)(B)(iii)]

X

9. Is there any alternative substances? 

[§6518 m.6]

X

10. Is there another practice that would make 

the substance unnecessary? [§6518 m.6]

X There are a number of alternative 

practices that can be used. (Petition 

page11) These include pre-treating 

water, replacing steam pipelines with 

stainless steel etc.

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

Substance: Ammonium hydroxide

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance compatible with organic 

handling? [§205.600 b.2]

X As a general rule ammonia products are 

not considered compatible with organic 

production or handling (TAP 2001, page 

7, page 9)

2. Is the substance consistent with organic 

farming and handling? [§6517 c 

(1)(A)(iii); 6517 c (2)(A)(ii)]

X See 1 above

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7]

X See 1 above

4. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600 b.3]

X

5. Is the primary use as a preservative? 

[§205.600 b.4]

X

6. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive 

values lost in processing (except when 

X

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required by law, e.g., vitamin D in milk)? 

[205.600 b.4]

7. Is the substance used in production, and 

does it contain an active synthetic 

ingredient in the following categories:

a. copper and sulfur compounds;

X

b. toxins derived from bacteria; X

c. pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals?

X

d. livestock parasiticides and 

medicines?

X

e. production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleaners?

X

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or 

potentially unavailable? [§6610, §6518, §6519, §205.2, §205.105 (d),§ 205.600 (c), §205.2, 

§205.105 (d), §205.600 (c)] Substance: Name Ammonium Hydroxide

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the comparative description provided

as to why the non-organic form of the 

material /substance is necessary for use 

in organic handling? 

X Not an agricultural substance

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate form to 

fulfill an essential function in a system of 

organic handling? 

X

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate quality to 

fulfill an essential function in a system of 

organic handling? 

X

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate quantity to 

fulfill an essential function in a system of 

organic handling?

X

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5. Does the industry information provided 

on material / substance non-availability 

as organic, include ( but not limited to) 

the following:

a. Regions of production (including 

factors such as climate and number 

of regions);

X

b. Number of suppliers and amount 

produced;

X

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts that 

may temporarily halt production or 

destroy crops or supplies; 

X

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X

e. Are there other issues which may 

present a challenge to a consistent 

supply?

X

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