This is a work product of the National Organic Standards Board (NOSB). It does not represent official 

National Organic Program (NOP) positions or policy.

National Organic Standards Board

Materials Subcommittee

Discussion Document

Defining “Production Aids” As Used in OFPA §6517

February 12, 2013

Background 

The Organic Foods Production Act (OFPA), Section 6517 (c)(1)(B)(i) allows substances 

to be added to the National List if (among other requirements):

(B) the substance -

(i) is used in production and contains an active synthetic ingredient in the 

following categories: copper and sulfur compounds; toxins derived from bacteria; 

pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicines and production aids including 

netting, tree wraps and seals, insect traps, sticky barriers, row covers, and 

equipment cleansers; 

There has been some discussion on the National Organic Standards Board (NOSB)

over past years concerning the meaning of “production aids.” The examples given in the 

law are materials that have a minimal impact on food, soil, or the ecosystem. However, 

there have in the past been requests to allow a range of substances under this

category, including (as recommended by the NOSB in August 2005) “carriers, 

stabilizers, adjuvants, fillers, extractants, excipients and solvents that do have an active 

function in the formulations of farm production aids such as fertilizers, soil amendments, 

compost inoculants, sanitizers, aquatic plant extracts, and fish emulsions” and “active 

substances used in pest control (disease, weed, insects and nematodes) that do not fit 

into other OFPA categories.”

1

On the other hand, some interpret OFPA’s definition of “production aids” as disallowing

materials similar to the groups mentioned in the August 2005 recommendation. The 

interpretation of the list in OFPA seems to hinge on whether one views the list “including 

netting, tree wraps and seals, insect traps, sticky barriers, row covers, and equipment 

cleansers” as exemplary (that is, a list exemplifying the kinds of things that might be 

considered “production aids”) or as items meant to be included, but not limited by type 

of substance. If it is the latter, then clearly some limitation is still implied by the fact that 

OFPA §6517 (c)(1)(B)(i) is stated as a constraint on what can be on the National List: 

“The National List may provide for the use of substances in an organic farming or 

handling operation that are otherwise prohibited under this chapter only if -(B) the 

substance - (i) is used in production and contains an active synthetic ingredient in the 

following categories:...” [Emphasis added.]

 1 http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3104476 This 

recommendation was referred to the NOP to check on its legality and was never implemented.
Although only one substance –microcrystalline cheesewax for use in log grown 

mushroom production– is listed as a “production aid” on the National List, there are 

several items listed as crop or livestock inputs on the National List that do not fit into any 

of the OFPA categories, and some recommendations for these materials refer to them 

as “production aids.” For example,

In the opinion of this committee, hydrated lime should be considered a production 

aid, insofar as it is vital to the production of two exempted sulfur or copper 

containing materials in order to make these materials non-phytotoxic to plants. 

(4/20/2006 hydrated lime sunset recommendation)

Regarding whether the OFPA provides an exemption category that would permit 

hydrogen peroxide to be considered for inclusion on the National List, the NOP 

provided feedback to the NOSB that hydrogen peroxide could be considered a 

“production aid” under section 6517 of the OFPA. As a result, hydrogen peroxide 

would be eligible for continued use in organic production. (4/20/2006 hydrogen 

peroxide sunset recommendation)

Bioplastic mulch is used as a production aid, but is not technically considered a 

row cover because it increases soil temperature, reduces weed pressure, 

maintains soil moisture levels, and may help extend the growing season. 

(8/15/2012 committee recommendation (checklist) for biodegradable biobased 

mulch film)

This [6-benzyladenine] is a production aid; thins fruit thus improving quality of 

fruit; improves air circulation thus reducing pests and disease; “enhances lateral 

bud break and lateral shoot growth, which leads to improved branching” TAP pg.

2 (5/2004 committee recommendation (checklist) for 6-Benzyladenine)

Its [Ethylene gas’] use as a synthetic is not specifically listed in the exempt 

categories of 6517(1)(B)(i) unless it is considered a crop production aid. This 

term should be more carefully defined for consistent use in decision making on 

synthetic crop materials. (Supplementary information on ethylene gas provided to 

NOSB, to be added to 1999 Technical Advisory Panel review for review of use in 

crop production. This information was prepared by OMRI staff and did not 

receive additional review by the initial three TAP reviewers.)

This material [ferric phosphate] is a production aid. (March 2005 

recommendation (checklist) for ferric phosphate.)

In addition, NOP frequently identifies petitioned substances as production aids or 

possible production aids when assessing the eligibility of a substance prior to NOSB 

review. If these materials were not so identified, they would not fit into an OFPA 

category, and the board would not need to commit resources to their evaluation. Some 

recent examples include:
Indole-3-butyric acid (IBA): “Plant hormone used for root cuttings. Does not fall 

under specific category, but could be considered a production aid.”

Carbon monoxide/exhaust gas: “TBD - unclear if product could be considered a 

production aid. EPA categorizes it as a device, rather than a pesticide.”

Carbon dioxide for aquaculture: “TBD - Unclear is use of petitioned substance 

may be considered a production aid.”

Chlorine in aquaculture: NOP underlined “equipment sanitizers,” but the petition 

also included use for disinfecting water.

Oxidized lignite: “Petitioned as a soil amendment.” (No such category.)

Biodegradable bioplastic mulch: NOP underlined “row covers,” but as the TR 

pointed out, the use is not “row covers,” but mulch.

Discussion

There are at least two distinct interpretations of the phrase “production aids.” One, a 

strict reading of the law and the legislative history, limits the application of the category 

to a narrow type of material that is delineated in the statute by example, “including 

netting, tree wraps and seals, insect traps, sticky barriers, row covers, and equipment 

cleansers.” Another interpretation of the phrase would allow materials that enable 

production of a crop and/or help inputs to work better. 

Several pesticides are allowed on the National List because they fit into other categories

–copper and sulfur compounds; toxins derived from bacteria; pheromones, soaps, 

horticultural oils, fish emulsions, treated seed, vitamins and minerals; livestock 

parasiticides and medicines– so the use of "production aids" as a catch-all for pesticides 

is considered contrary to the intention of OFPA. Furthermore, the examples listed in 

OFPA as production aids do all have something in common because they are all things 

that have only a minimal impact on the crop, soil, or surrounding ecosystem. In fact, the 

original Senate bill referred to “production aids such as machinery cleansers,” and the 

House bill did not contain any reference to production aids. The conference committee 

came up with the current language.

As noted above, others have argued for a much broader interpretation of the term –

arguing that the examples listed are not meant to limit the types of materials covered by 

the term “production aids.”

Questions:

1. Is clarification of the term “production aids” needed?
2. Should clarification give further examples of what is and is not covered by the 

term? If so, please suggest inclusions and/or exclusions

3. What kinds of materials have historically been covered by the term “production 

aids”?

4. Should clarification give a narrative definition, such as “materials used in 

production but not having direct impact on plants, soil, or the ecosystem”? If so, 

please suggest language.

Subcommittee Vote:

Motion: The Materials Subcommittee moves to accept this document and present it for 

full Board discussion at the spring 2013 NOSB meeting:

Moved: Jay Feldman Second: Jennifer Taylor

Yes: 5 No: 0 Abstain: 0 Absent: 2 Recuse: 0