FORMAL RECOMMENDATION BY THE 

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: March 2, 2005 

Subject: Addition of Ferric Phosphate to National List 

Chair: Jim Riddle 

Recommendation 

The NOSB herby recommends to the NOP the following: 

 Rulemaking Action: X 

 Guidance Statement: 

 Other: 

Statement of the Recommendation (including Recount of Vote):

Add Ferric Phosphate to section 205.601 H of the National List. 

Vote: 10 yes, 0 no, 2 abstain, 2 absent 

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

The material is consistent with OFPA and meets the three criteria – minimal impact on 

humans and environment, no non-synthetic substance is available for mollusk control, and 

the material is compatible and consistent with organic production practices. 

Response by the NOP:
DRAFT 

EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance Ferric Phosphate ___ 

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 

 

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3]

X 

Accidental release to water can result in the death of 

mollusks; it is registered for use by EPA on snails and slugs 

but cannot be used near water (TAP, pg. 3) 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X 

Ferric phosphate occurs naturally in soils; it is GRAS (TAP 

pg. 5 & 6). Only a problem if it comes in contact with 

water. 

4. Does the substance contain List 

1, 2, or 3 inerts? [§6517 c (1)(B)(ii); 

205.601(m)2]

X 

No inert ingredients were identified by the U.S. EPA’s 

office of Pesticide Programs (TAP, pg 6). 

5. Is there potential for 

detrimental chemical interaction 

with other materials used [§6518 

m.1]

X 

No potential for detrimental chemical interactions are 

expected with other materials used. (TAP pg 6 & 7). Ferric 

phosphate has low water solubility. (TAP pg 17 & 21) 

6. Are there adverse biological 

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

X 

No potential for detrimental chemical interactions are 

expected within an agroecosystem (TAP pg 6 & 7). The 

material should not be used near ponds, streams, etc. 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X 

Ferric phosphate is abundant is soil; it is not expected to 

cause detrimental physicological effects to soil organisms, 

crops or lilvestock. (TAP pg 7) 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? [§6518 m.2] 

X 

No toxic or other adverse actions are expected. Under 

conditions of extreme temperatures (>50C, which does not 

occur ‘naturally’) does the material release toxic fumes. 

(TAP pg. 4 & 7) 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment? [§6518 m.2]

X 

The amount of ferric phosphate used to control snails and 

slugs is miniscule compared to the amount of this material 

naturally in soil (TAP pg. 7). Breakdown products are used 

by other soil organisms resulting in a very low persistence 

(TAP pg 22). 

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i) ; 

6517 c(2)(A)i; §6518 m.4] 

X 

Ferric phosphate is a GRAS substance (TAP pg 6 & 22). 

Only under conditions of excessive ferric phosphate 

exposure are there any harmful impacts to humans. LD50 is 

>5000mg/kg. (TAP pg 7) The LD50 of NaCl is 4000 mg/kg. 

(Ostiguy) 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

X 

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? [§205.600b.5] 

X 

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. 
DRAFT 

Category 2. Is the Substance Essential for Organic Production? Substance ___ Ferric Phosphate 

___ 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is there a natural source of the 

substance? [§205.600 b.1] 

X 

2. Is there an organic substitute? 

[§205.600 b.1] 

X 

3. Is the substance essential for 

handling of organically 

produced agricultural products? 

[§205.600 b.6] 

X 

4. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

X 

The other options, including biological, barrier, repellents, 

physical and cultural control, are effective but all have their 

limitations (TAP pg9). These options are not effective in 

most circumstances 

5. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

X 

6. Are there any alternative 

substances? [§6518 m.6] X 

The other options, including biological, barrier, repellents, 

physical and cultural control, are effective but all have their 

limitations (TAP pg9). These options are not effective in 

most circumstances 

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X 

The other options, including biological, barrier, repellents, 

physical and cultural control, are effective but all have their 

limitations (TAP pg9). These options are not effective in 

most circumstances 

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. 
DRAFT 

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

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 

“When used as a molluscicide, ferric phosphate is consistent 

with organic farming and handling. Ferric phosphate is not 

harmful to humans, animals, plants, non-target insects, or 

soil microbes. (It) is a stable compound that does not persist 

or form undesirable products in the environment under 

normal conditions of use and storage.” (TAP pg. 10) 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

X 

When used as a molluscicide, ferric phosphate is compatible 

with a system of sustainable agriculture. “Ferric phosphate 

is not harmful to humans, animals, plants, non-target 

insects, or soil microbes. (It) is a stable compound that does 

not persist or form undesirable products in the environment 

under normal conditions of use and storage. (TAP pg. 10) 

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 

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 

b. toxins derived from bacteria; X 

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals? 

X 

The material is a mineral. 

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 

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. 
NOSB RECOMMENDED DECISION 

Form NOPLIST2. Full Board Transmittal to NOP 

For NOSB Meeting: ___March 2, 2005_____ Substance: Ferric Phosphate___

A. Evaluation Criteria (Documentation attached; committee recommendation attached) 

 Criteria Satisfied? 

1. Impact on humans and environment Yes X No  (see B below) 

2. Availability criteria Yes X No  (see B below) 

3. Compatibility & consistency Yes X No  (see B below) 

B. Substance fails criteria? 

Criteria category: _ ________

Comments: 

C. Proposed Annotation: _____________________________________ 

___________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________ 

D. Final Board Action & Vote: Add to ferric phosphate to section 205.601 H 

 Motion by: __Nancy Ostiguy_______________ Second:____Rose Koenig_______________

 

 Vote: 

 

 Yes: _10__ 

 

 No: __0__ 

 Abstain: __2__ 

 Absent: 2 

 1—substance voted to be added as “allowed” on National List 

Annotation: ___________________________________________________________________ 

 ___________________________________________________________________ 

 2—substance to be added to “prohibited” paragraph of National List 

Describe why a prohibited substance:_______________________________________________ 

_____________________________________________________________________________ 

 3—substance was rejected by vote for amending National List 

Describe why material was rejected:________________________________________________ 

_____________________________________________________________________________ 

 4-substance was recommended to be deferred 

Describe why deferred; if any follow-up is needed. If follow-up needed, who conducts followup._____________________________________________________________________ 

_____________________________________________________________________________ 

Agricultural Nonagricultural Crops X 

Synthetic X Not synthetic Livestock 

Allowed1 X Prohibited2 Handling 

No restriction X Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP: 

______________________________________ ______March 2, 2005____________ 

 Jim Riddle, NOSB Chair Date 

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

 Return to NOSB  Reason: ____________________________________________________________________ 

_____________________________________ _________________________ 

 Richard H. Mathews, Program Manager Date 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __March 2, 2005____ Substance: Ferric Phosphate

Committee: Crops X Livestock  Handling 

A. Evaluation Criteria (Documentation attached; committee recommendation attached) 

 Criteria Satisfied? 

1. Impact on humans and environment Yes X No  (see B below) 

2. Availability criteria Yes X No  (see B below) 

3. Compatibility & consistency Yes X No  (see B below) 

B. Substance fails criteria? 

Criteria category: _2._____ 

Comments: There are other materials 

and methods available for controlling 

snails and slugs 

C. Proposed Annotation: ___ ___________________________________ 

Basis for annotation: 

To meet criteria above: ___ Criteria: ______________ 

Other regulatory criteria: ____ Citation:_______________ 

D. Recommended Committee Action & Vote: Add to ferric phosphate to section 205.601 H 

Motion by: __ Rose Koenig__ Seconded:___ Nancy Ostiguy_____________ 

 

 Vote: 

 

 Yes: _5___ 

 

 No: _0__ 

 Abstain: __0_ 

 

 1—substance voted to be added as “allowed” on National List 

Annotation: _____ ________________________________________ 

 ___________________________________________________________________ 

 2—substance to be added to “prohibited” paragraph of National List 

Describe why a prohibited substance:_______________________________________________ 

_____________________________________________________________________________ 

 3—substance was rejected by vote for amending National List 

Describe why material was rejected:________________________________________________ 

_____________________________________________________________________________ 

 4-substance was recommended to be deferred 

Describe why deferred; if follow-up is needed. If follow-up needed, who will follow up 

__________________________ 

_____________________________________________________________________________ 

Agricultural Nonagricultural Crops X 

Synthetic X Not synthetic Livestock 

Allowed1 X Prohibited2 Handling 

No restriction X Deferred4 Rejected3 X 

E. Approved by Committee Chair to transmit to NOSB: 

_____Nancy Ostiguy____________________ ____March 1, 2005____________

 Committee Chair Date