Updated June 17, 2010 

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Sodium Acid Pyrophosphate

Chair: Tracy Miedema

 

 The NOSB hereby recommends to the NOP the following: 

Rulemaking Action

Guidance Statement

Other

Statement of the Recommendation (Including Recount of Vote): 

Not to expand the current listing of Sodium Acid Pyrophosphate in section 

205.605(b) of the National List for use as a sequestrant for cooked and 

uncooked produce. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

The petition was to expand the allowed use of Sodium Acid Pyrophosphate

(SAPP) on the National List § 205.605(b) to include it’s use as a sequestrant on 

cooked and uncooked produce. It is currently listed “for use only as a leavening 

agent”. The TR mentioned no data was found on the material itself that indicated it 

posed potential negative impact on human health or the environment, but it did 

discuss that one of the primary inputs in the manufacture of SAPP, Phosphoric 

acid, does pose a threat if waste is not carefully managed. The petitioner did not 

provide compelling evidence that SAPP is necessary or essential to organic 

handling, and as a matter of fact, a Handling Committee survey of organic 

handlers who could potentially use this material did not reveal any who actually 

would if it was listed. 

The Handling Committee recommended against expanded listing of the material. 

The vote was 0 yes, 6 no, and 1 absent for expansion of the listing. After the 

Handling Committee recommendation was published, the petitioner submitted 

public comments disagreeing with the committee recommendation, but no other 

comments in favor of the expanded listing were received. Several comments were 

received agreeing with the committee recommendation. The full board concurred 

with the Handling Committee recommendation at the April 2011 NOSB meeting 

with the vote for the expanded listing shown below. 
Updated June 17, 2010 

NOSB Vote:

Moved: Steve DeMuri Second: Mac Stone

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recusal: 0
Decision Sheets 

April 2010 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: April 2011 Substance: Sodium Acid Pyrophosphate 

Committee: Crops  Livestock  Handling X Petition is to expand the allowed use of Sodium Acid Pyrophosphate on the 

National List § 205.605(b) to include it’s use as a sequestrant on cooked and uncooked produce. It is currently listed “for use only as a 

leavening agent”. 

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 X No  N/A 

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

Substance Fails Criteria Category: 1 and 3. The TR mentions no data was found on the material itself that indicated it posed potential negative impact on 

human health or the environment, but it did discuss that one of the primary inputs in the manufacture of SAPP, Phosphoric acid, does pose a threat if waste is 

not carefully managed. The petitioner did not provide compelling evidence that SAPP is necessary or essential to organic handling, and as a matter of fact, a 

survey of organic handlers who could potentially use this material did not reveal any who actually would if it was listed. 

Proposed Annotation (if any): N/A

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

B. Recommended Committee Action & Vote, including classification recommendation (State Actual Motion): 

 To classify Sodium Acid Pyrophosphate as a synthetic material.

Classification of the material: Synthetic: ____ Non- synthetic_____________ 

Motion by: Steve DeMuri Seconded: Katrina Heinze Yes: 6 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Recommended Committee Action & Vote To expand the listing of Sodium Acid Pyrophosphate on 205.605(b) to include use as a sequestrant on cooked and 

uncooked produce. 

 

Motion by: Steve DeMuri Seconded: Katrina Heinze Yes: 0 No: 6 Absent: 1 Abstain: 0 Recuse: 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. 605(b) Describe why material was rejected: 

 For the reasons described in the Criteria Category discussion in Section A above. 

4) Substance was recommended to be deferred because _________________________________________________________

 If follow-up needed, who will follow up: N/A

Crops Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic X Rejected3

X 

No restriction Commercially UnAvailable as Organic1

 Deferred4 

C. Approved by Committee Chair to transmit to NOSB: 

_Steve DeMuri____________________________________ April 29, 2011 _________________________ 

 Committee Chair Date
Decision Sheets 

April 2010 

EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST 

Category 1. Adverse impacts on humans or the environment? Substance: Sodium Acid Pyrophosphate

 

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 The TR, page 9, describes 

environmental concerns with the 

phosphoric acid used to produce the 

SAPP, and potential heavy metal 

contamination from phosphate rock 

mining, used to produce the phosphoric 

acid.. 

2. Is there environmental contamination during 

manufacture, use, misuse, or disposal? 

[§6518 m.3] 

X Heavy metal contamination of 

groundwater and estuaries possible 

during manufacture if not mitigated. 

These metals can be taken up by plants 

and marine life leading to concentration 

of heavy metals in food products. TR 

page 9 

3. Is the substance harmful to the environment 

and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 X No evidence the substance itself is 

harmful. TR page 9. 

4. Does the substance contain List 1, 2, or 3 

inerts? [§6517 c (1 ) (B)(ii); 205.601(m)2] 

 X No evidence it contains these inerts. 

5. Is there potential for detrimental chemical 

interaction with other materials used? 

[§6518 m.1] 

 X None identified in the TR. 

6. Are there adverse biological and chemical 

interactions in agro-ecosystem? [§6518 m.5] 

 X The substance is added to food as a 

leavening agent now, and has been 

petitioned to allow use as a sequestrant 

for vegetables. It is not applied to soil or 

crops. 

7. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518 m.5] 

X There can be an uptake of heavy metals 

from the phosphate rock component of 

the manufacturing process, but no 

evidence to suggest the material itself 

has detrimental physiological effects on 

soil organisms, crops, or livestock. TR 

page 9. 

8. Is there a toxic or other adverse action of the 

material or its breakdown products? 

[§6518 m.2] 

 X None mentioned in the TR. 

9. Is there undesirable persistence or 

concentration of the material or breakdown 

products in environment? [§6518 m.2] 

 X No evidence of this in the TR. 

10. Is there any harmful effect on human health? 

[§6517 c (1)(A) (i) ; 6517 c(2)(A)I; §6518 

m.4] 

 X According to the MSDS and TR, SAPP 

may cause body irritation in some 

individuals, but no evidence of it being 

acutely hazardous to human health. 
Decision Sheets 

April 2010 

11. Is there an adverse effect on human health as 

defined by applicable Federal regulations? 

[205.600 b.3] 

 X No evidence of such in the TR. 

12. Is the substance GRAS when used according 

to FDA’s good manufacturing practices? 

[§205.600 b.5] 

X TR page 6. 

13. Does the substance contain residues of heavy 

metals or other contaminants in excess of 

FDA tolerances? [§205.600 b.5] 

 X There is no evidence that the substance 

contains heavy metals in excess of FDA 

tolerances. 

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 

April 2010 

Category 2. Is the Substance Essential for Organic Production? Substance: Sodium Acid Pyrophosphate 

 

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 SAPP is manufactured by (1) partial 

neutralization of phosphoric acid 

(H3PO4) with sodium hydroxide 

(NaOH) or sodium carbonate (Na2CO3)

to form monosodium phosphate 

(NaH2PO4) and then (2) dehydration of 

monosodium phosphate at 

approximately 250° C to form SAPP 

(Na2H2P2O7). Phosphoric acid and 

sodium carbonate are the feedstock for 

producing SAPP. 

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 See above 

3. Is the substance created by naturally 

occurring biological processes? [6502 (21)] 

 X See # 1 above. 

4. Is there a natural source of the substance? 

[§205.600 b.1] 

 X Components of some of the 

manufacturing inputs are natural, but 

some are synthetic, rendering it a 

synthetic (not natural) substance. 

5. Is there an organic substitute? [§205.600 b.1] X According to the petition and the TR, 

page 6, there are no organic substitutes 

known. 

6. Is the substance essential for handling of 

organically produced agricultural products? 

[§205.600 b.6] 

 X May be useful as a reduced sodium 

leavening agent, but no compelling 

evidence is provided that it meets 

essentiality criteria, since other listed 

materials serve the same function. 

7. Is there a wholly natural substitute product? 

[§6517 c (1)(A)(ii)] 

 X There is no evidence a natural substitute 

product exists. TR page 5. 

8. Is the substance used in handling, not 

synthetic, but not organically produced? 

[§6517 c (1)(B)(iii)] 

 X Used in handling, but IS synthetic and 

not organically produced. 

9. Is there any alternative substances? [§6518 

m.6] 

X Citric acid is used currently by some 

manufacturers to reduce oxidation on 

cut fruits and vegetables. There was no 

explanation in the petition as to why 

citric acid couldn’t be used. 

10. Is there another practice that would make the 

substance unnecessary? [§6518 m.6] 

X A primary purpose for the material 

stated in the petition was for cut 

potatoes. An HC survey of major 

organic potato producers revealed that 

prompt production of manufactured 

potato products from raw potatoes 

greatly reduced the oxidation occurrence 
Decision Sheets 

April 2010 

on cut or peeled surfaces of the 

vegetables. Stored potatoes tend to 

oxidize more easily the longer they are 

held post harvest prior to further 

manufacturing. All organic potato 

handlers contacted stated they would not 

use the material even if listed, and 

would instead continue managing 

harvest and storage to reduce browning. 

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 

April 2010 

Category 3. Is the substance compatible with organic production practices? Substance: Sodium Acid Pyrophosphate 

 

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, and biodiversity? 

[§6517 c (1)(A)(iii); 6517 c (2)(A)(ii)] 

X X Consistent with Handling, but not 

applicable to farming and biodiversity, 

since it is not applied to soil or crops.. 

3. Is the substance compatible with a system of 

sustainable agriculture? [§6518 m.7] 

 X Petitioned for use in a Handling 

application. 

4. Is the nutritional quality of the food 

maintained with the substance? [§205.600 

b.3] 

X Nutritional quality is not negatively 

affected by it’s use, per the TR, page 6. 

5. Is the primary use as a preservative? 

[§205.600 b.4] 

 X Primary use would be as an anti-oxidant 

to reduce browning in cut cooked or 

uncooked produce, not to limit microbial 

growth. 

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 This substance, for the purpose 

petitioned, would act as an anti-oxidant 

on cut cooked or uncooked produce, not 

to recreate or improve factors lost during 

processing. 

 

7. Is the substance used in production, and does 

it contain an active synthetic ingredient in 

the following categories: 

 X Not petitioned to this committee for use 

in organic production, just handling. 

a. Copper and sulfur compounds; X See above 

b. Toxins derived from bacteria; X See above 

c. Pheromones, soaps, horticultural oils, fish 

emulsions, treated seed, vitamins and 

minerals? 

 X See above 

d. Livestock parasiticides and medicines? X See above 

e. Production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleaners? 

 X See above 

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 

April 2010 

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: Sodium Acid 

Pyrophosphate

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 This category pertains only to substances 

petitioned for addition to section 205.606. 

All questions in this category (4) not 

applicable. 

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 non-availability as 

organic, include ( but not limited to) the 

following: 

 X 

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