FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _____6-7-06___________________

Subject: Sunset Review - 205.601 Synthetic substances allowed for use in organic crop 

production 

Chair: Kevin O’Rell 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: _XXXXXX_ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

See attached Recommendation for Renewal of Hydrogen Peroxide as Synthetic substances 

allowed for use in organic crop production on 205.601, category use (a) as algicides, 

disinfectants, and sanitizers including irrigation system cleaners and as (i) as plant disease 

control. 

NOSB Vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 12 

No – 0 

Abstain – 0 

Absent – 2 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

NOSB Sunset Material Vote 

Response by the NOP:
NOSB- Crops Committee 

Hydrogen Peroxide - Sunset Recommendation 

Final NOSB Recommendation 4/20/2006

I. List: 205.601 Synthetic substances allowed for use in organic crop production 

 

II. Category Use(s) 

(a): As algicide, disinfectants, and sanitizers, including irrigation system cleaners. 

(i): As plant disease control 

III. Committee Summary: The renewal of hydrogen peroxide was deferred for two reasons. 

First, the Crops Committee thought that more information and public comment was needed, and 

second, because of concern that there was no OFPA category that specifically allows its use. 

Review of the Technical Evaluation Report for hydrogen peroxide shows that the substance does 

not occur naturally, but poses no true threat to the environment because it easily breaks down 

into water and oxygen, or hydrogen and hydroxyl depending on ph. The potential uses of 

hydrogen peroxide include: disinfectant, bleaching agent, oxygenerator, carrier for foliar sprays, 

aeration in compost piles, and as vapor phase hydrogen peroxide, an inhibitor of post-harvest 

decay of table grapes. Pure hydrogen peroxide has an oxygen content of 47% and is relatively 

stable. While almost exclusively used in low concentrations, in concentrations greater than 50% 

hydrogen peroxide can cause burns, and at concentrations above 8% it can be corrosive, 

because oxygen readily combines with other elements. In field sprays, the release of oxygen 

when hydrogen peroxide is applied to plants enables them to more easily take up nutrients 

through their leaves, and is considered to be a safe fungicide. Hydrogen peroxide is used to 

eliminate bacteria in fresh vegetable and fruit packing sheds. Hydrogen peroxide in diluted forms 

is used by humans as a mouthwash and an antiseptic. There are no known cases of hydrogen 

peroxide causing environmental contamination. 

All public comments, except one, were in favor of keeping hydrogen peroxide on the National List. 

The lone dissenter was against any synthetics being used in organic production of any kind, but 

the commentator provided no evidence of how the substance violated the OFPA. Most 

commentators agreed that there are no known adverse impacts on humans or the environment 

from either the use or manufacture of hydrogen peroxide. Most of the commentators stated that 

there are no other similar products available that are more compatible with organic crop 

production practices, and that the availability of hydrogen peroxide probably lessens damage to 

the environment and harm to humans by lowering the amount of toxic substances used as 

alternate measures. 

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. 

IV. Committee Recommendation: 

Recommendations based upon comments received – 205.601(a) and 205.601(i) 

The Crops Committee recommends renewal of the following material to the use category: 

(a) As algicide, disinfectants, and sanitizer, including irrigation system cleaners. 

 (4) Hydrogen peroxide 

(i) As plant disease control 

 (4) Hydrogen peroxide 
Motion: Kevin Engelbert Second: Jeff Moyer 

Committee vote: 3-0 Absent (Delgado, Ostiguy) 

NOSB vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 12 

No – 0 

Abstain – 0 

Absent – 2