FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _August 17, 2005________

Subject: __Sucrose octanoate esters________ 

Chair: ____Jim Riddle______________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X_____ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

The NOSB recommends that sucrose octanoate esters be added to 205.601 for use in organic crop 

production, with no annotation, and to 205.603 for use in organic livestock production, with no 

annotation. 

Board vote – August 16, 2005 

For use in crop production – 13 yes, 0 no, 1 absent 

For use in livestock production – 13 yes, 0 no, 1 absent 

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

Rationale provided in text of recommendation below. 

Response by the NOP:

Updated 2/25/05 
EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance Sucrose Octanoate Esters

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 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X 

Esters biodegrade rapidly; are not toxic to mammals and 

other target organisms; the amount used will not 

“substantially increase amount of these esters in 

environment.” TAP pg 5, lines 234-241. 

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 

SOE does not persist; unlikely to interact with other 

materials used organic production,. TAP pg 5, lines 243-

248. 

6. Are there adverse biological 

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

X 

Non toxic to honey bees and many beneficial insects. Not 

phytotoxicity to many crops; biodegrades quickly TAP pg 

6, lines 253-276. 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

X 

No specific data exist on soil organisms but based upon 

available data, including the rate of decomposition, no 

adverse impacts are expected. TAP pg. 6 lines 266-276. 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2] 

X 

Sucrose, fatty acids carbon dioxide and water are the 

breakdown products. None are toxic. TAP pg 6, lines 281-

282. 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X 

SOEs degrade rapidly and do not resist or accumulate in the 

environment. TAP pg 6, line 287. 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

X 

No subchronic, chronic, immune, endocrine issues have 

been identified. EPA estimates ADI for humans is 2.82 lbs 

for a 176 lb person. An ocular risk exists but is unlikely if 

product is used according to label. TAP pg 6, lines 292-300. 

Used in foods. TAP pg 2, lines 65-67 & pg 3, lines 99-109. 

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? [§205.600 b.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. 
Category 2. Is the Substance Essential for Organic Production? Substance Sucrose Octanoate Esters

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 

Other materials, e.g., nonsythetic oil are alternatives for 

some or all of the targeted crops. TAP pgs 7, lines 309-335. 

Limited efficacy and a need for alternatives exist. 

5. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

X 

6. Is there any alternative 

substances? [§6518 m.6] 

X Other approved materials, e.g, soaps, are alternatives for 

some or all of the targeted crops. TAP pgs 7, lines 340-344 

Limited efficacy and a need for alternatives exist. 

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X 

Numerous practices are available to reduce the need for this 

material. These practices would have to be implemented 

prior use of this material. This material would provide 

farmers with a means to control insects when other practices 

have failed. TAP pg 8, lines 351-355. 

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

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 material degrades rapidly, has very low toxicity, its 

breakdown products are non-toxic. It has minimal to no 

environmental risk. TAP pg 5, lines 230-248. Is an EPA 

registered biopesticide TPA pg 2, line 48. 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

X 

This material degrades rapidly, has very low toxicity, its 

breakdown products are non-toxic. It has minimal to no 

environmental risk. TAP pg 5, lines 230-248 

The material increases the long-term viability of organic 

farms by providing a means to control insect damage with 

IPM and other tactics fail. This material is consistent with 

other allowed materials. 

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

This material works as a soap. TAP pg 1, lines 77-78 

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: ____August 2005_________________ Substance: Sucrose Octanoate Esters

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: Motion by: __Nancy Ostiguy__ Second:____Andrea Caroe________ 

 

 Vote: 

 

 Yes: __13___ 

 

 No: ___0__ 

 Abstain: _____ 

 Absent: __1___ 

 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 X 

Allowed1 X Prohibited2 Handling 

No restriction X Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP: 

______________________________________ _________________________ 

 Dave Carter, 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: ___August 2005__________________ Substance: Sucrose Octanoate Esters

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: _________ 

Comments: 

C. Proposed Annotation: ____________________ 

______________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________ 

D. Recommended Committee Action & Vote: Motion by: ___Rose_______________________ 

 Seconded:___Gerry_________________________ 

Sucrose Octanoate Esters [(CAS NO. 42922-74-7 (monooctonoate), 58064-47-7 (dioctanoate)] is synthetic and allowed as 

an insecticidal soap [205.601 (?)]. 

 

 Vote: 

 

 Yes: _3__ 

 

 No: _0___ 

 Abstain: _1___ 

 

 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 

Synthetic X Not synthetic Livestock X 

Allowed1 X Prohibited2 Handling 

No restriction Deferred4 Rejected3

E. Approved by Committee Chair to transmit to NOSB: 

______________________________________ _________________________ 

 Committee Chair Date