NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP

For NOSB Meeting: _May 2009____ Substance: ___Isoparaffinic Hydrocarbon _ 

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

 

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

3. Compatibility & Consistency Yes  No X N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance fails criteria? 

Criteria category: _1, 2, and 3_ 

Comments: It is a synthetic which fails all three 

categories. See evaluation criteria citing TR 

information and PAN (Pesticide Action Network 

Database). There are strong pyrethrum 

extraction alternatives available.

C. Proposed Annotation: ______________________________________ 

___________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________

D. Final Board Action & Vote (State Actual Motion): inclusion of Isoparaffinic Hydrocarbon under Synthetic substances 

allowed for use in organic crop production on the National List § 205.601

Motion: Tina Ellor Second: Barry Flamm Yes: _0__ No: _14__ Abstain: __0__ Absent: 

 

 1 .

Provide a summary narrative here or attach a more complete narrative, and attach the original committee recommendation

that includes the evaluation criteria checklist:

The material is a synthetic which failed three categories. It was determined that there are strong, commercially available pyrethrum 

extraction alternatives.

1—substance voted to be added as “allowed” on National List on National List to § 205.______ with Annotation (if any): ____ __ 

__________________________________________________________________________________________________ _ 

2—substance to be added to “prohibited” paragraph of National List to § 205.______ Describe why a prohibited substance:

_____________________________________________________ ___________________________________

__ ____

 _

 

___ 

3—substance was rejected by vote for amending National List to § 205. 601__ Describe why material was rejected: _____ _ 

___________________________________________________ __ 

4-substance was recommended to be deferred § 205. ______ Describe why deferred; if any follow-up is needed. If follow-up needed, 

who conducts follow-up ________________________________ ____________________________________ 

Agricultural Nonagricultural Crops X

Synthetic X Not synthetic Livestock

Allowed

1

Prohibited X 2

Handling

No restriction Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP

 . 

Chair Date

 .

F. NOP Action: Include in FR to amend National List: 

 Return to NOSB Reason: ____________________________________________________________________ 

_____________________________________ _________________________ 

 Date 

Attach Committee Recommendation here along with the completed evaluation criteria 

checklist and any attachments
Decision Sheets

December 2006

NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: ___Spring 2009_________ Substance: __Isoparaffinic Hydrocarbon__________

Committee: Crops X Livestock  Handling  Petition is for: inclusion of Isoparaffinic Hydrocarbon

under_Synthetic substances allowed for use in organic crop production on the National List § 205.601_

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

 

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

3. Compatibility & Consistency Yes  No X N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance Fails Criteria Category: _1,2 & 3_Comments: It is a synthetic which fails all three categories.See evaluation 

criteria citing TR information and PAN (Pesticide Action Network Database). There are strong pyrethrum extraction alternatives 

available. Substance is not essential due to the existence of other pyrethrin extraction methods and materials that are available and 

better meet the evaluation criteria.

C. Proposed Annotation (if any): _____________________________________________________________________________

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:______

D. Recommended Committee Action & Vote (State Actual Motion): __To include Isoparaffinic hydrocarbon 

On the National List §205.601 

Motion by: Gerry Davis__ Seconded:___Tina Ellor_ Yes: _0___ No: __5

 

__ Absent: ___1___ Abstain: ___0__ 

 

1) Substance voted to be added as “allowed” on National List to § 205. with Annotation (if any) 

_________________________________________________________________________________________________

2) Substance to be added as “prohibited” on National List to § 205. with Annotation (if any) 

______________________________________________________________________________________________ 

Describe why a prohibited substance:__________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. _____ Describe why material was rejected:___________ 

________________________________________________________________________________________________________

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops X Agricultural Allowed1 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4

E. Approved by Committee Chair to transmit to NOSB:

___Tina Ellor___________________________________ ___________

 Committee Chair Date

3/09/2009__________
Decision Sheets

December 2006

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - ___ Isoparaffinic Hydrocarbon

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 TAP lines 224-238: only references information from the 

manufacturer.

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3]

X TAP lines 247-258 

3. Is the substance harmful to the 

environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X TAP lines 263-266 “Isoparaffinic hydrocarbon (CAS 64742-47-

8) produces some harm to the environment. According to the 

US EPA (2008) in Table 3 of 40 CFR Part 63, Subpart 

MMMM, the petitioned substance solvent produces 0.001 mass 

fraction of toluene that serves as a organic hazardous air 

pollutant (HAP).”

4. Does the substance contain List 

1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2]

X This was a list 2 inert

5. Is there potential for detrimental 

chemical interaction with other 

materials used?[§6518 m.1]

X Strong oxidizers Petition page 13 (Isopar M Fluid MSDS)

6. Are there adverse biological and 

chemical interactions in agroecosystem? [§6518 m.5]

X TAP lines 283-288 “...there is potential for impairing the 

hatching of bird eggs according to the U.S. EPA (2006), if the 

spray substance is applied directly to eggs in the nest.”

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X TAP lines 293-300 “...the petitioned substance has detrimental 

physiological effects on citrus crops and foliage, fruit, and 

seedlings of other plants.”

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2]

X TAP lines 305-315 “Isoparaffinic hydrocarbon and its 

breakdown products only exhibit slight acute toxicity or other 

adverse action according to S. E. Kegley (2009). It is not a 

cholinesterase inhibitor in humans (Kegley 2009). According to 

the US EPA (2008) in Table 3 of 40 CFR Part 63, Subpart 

MMMM, isoparaffinic hydrocarbon contains just 0.001 mass 

fraction of toluene as hazardous air pollutant (HAP) in the 

solvent. According to ExxonMobil Chemical (2008) the 

petitioned substance contains typical toxic chemical 

concentrations of <0.4ppm of benzene, <1ppm naphthalene, 

and <1ppm ethylbenzene. Thus the benzene content in the 

petitioned substance is negligible. This is significant since 

benzene is linked to increased incidence of leukemia in 

humans.”

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2]

X TAP Lines 320-324 

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i) ; 

6517 c(2)(A)i; §6518 m.4]

X1 X2 X1: TAP Supplemental Information lines 359-364-1st

X2: TAP Lines 329-337-2

S & T 

TAP nd S & T TAP

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

X1 X2 X1: TAP Supplemental Information lines 359-364-1st

X2: TAP Lines 329-337-2

S & T 

TAP nd S & T TAP
Decision Sheets

December 2006

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5]

X TAP lines 279-288—although the TAP states it does not need 

to be GRAS listed because of it’s place on 21 CFR 172, § 

172.882. Natamycin is also on this list. This information is 

missing from the more recent TAP from S & T

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

X TAP lines 307

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable.
Decision Sheets

December 2006

Category 2. Is the Substance Essential for Organic Production? Substance - ___ Isoparaffinic Hydrocarbon

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 TAP lines 220-228

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 TAP lines 234-236

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)]

X TAP lines 241-242

4. Is there a natural source of the 

substance? [§205.600 b.1]

X TAP lines 214-217-information from previous S & T Tap, not 

present in more recent edition.

5. Is there an organic substitute? 

[§205.600 b.1]

X1 TAP lines 219-222-Question not addressed in newer version 

of S & T TAP

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 

b.6]

X

 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)]

X US Pat#4,281,171 Liquid Carbon Dioxide Extraction of 

Pyrethrins. Also there are commercially available pyrethrins 

extracted by other means for example Pyganic Crop Protection 

EC 1.4 and EC 5.0; Safer Brand Yard and Garden Insect Killer 

and Insect Killer Concentrate. Their extraction methods, 

however, are confidential.

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 See #7 above

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6]

X Alternative extraction methods as listed in #7 above; also 

other insecticides approved for use in organic agriculture 

without this petroleum product extraction ingredient. See also 

TAP lines 360-365. 1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable.
Decision Sheets

December 2006

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

Hydrocarbon

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Is the substance compatible 

with organic handling? [§205.600 

b.2]

X

2. Is the substance consistent with 

organic farming and handling? 

[§6517 c (1)(A)(iii); 6517 c 

(2)(A)(ii)]

X This is a petroleum product which is present in the final 

pesticide formulation and to which there are alternatives 

without the petroleum extraction.

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

X As above.

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

1X TAP says yes (lines 253-259) but refers only to non-food use. 

5. Is the primary use as a 

preservative? [§205.600 b.4]

1X It is used as a preservative, but that is not what the petition is 

for. TAP lines 270-277. The newer version has an approved 

use for pickles and froth-flotation cleaning of vegetables-Line 

167.

6. Is the primary use to recreate or 

improve flavors, colors, textures, 

or nutritive values lost in 

processing (except when required 

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

[205.600 b.4]

X

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 TAP lines 17-22

b. toxins derived from bacteria; X TAP lines 17-22

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals?

X TAP lines 17-22

d. livestock parasiticides and 

medicines?

X TAP lines 17-22

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment cleaners?

X TAP lines 17-22

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable.
Decision Sheets

December 2006

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 - ______________________________________

Question Yes No N/A Comments on Information Provided (sufficient, 

plausible, reasonable, thorough, complete, unknown)

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

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

5. Does the industry information 

provided on material / substance nonavailability 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
Decision Sheets

December 2006