This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Minerals in aquatic animal production

August 6, 2013

*Reviewed and revised February 3, 2014

Summary of Proposed Action:

Synthetic minerals are proposed to be added to the National List at 205.611 for use in 

production of aquatic animals. Section 205.611 of the National List will contain the list of 

synthetic substances allowed in organic aquatic animal production.

Synthetic Trace Minerals are presently approved at 205.603(d)(2) for use in livestock 

production, used for “enrichment and fortification when FDA approved”.

Minerals are essential for production of healthy animals. In the case of nutrient requirements for 

fish and shrimp, the National Research Council (NRC) defines essential trace minerals as 

“required”. Petitioner requests addition to the National List of trace minerals without specific 

notation to include but not to be limited to the following: Cobalt Chloride, Copper, Potassium 

iodide, Ethanediamine dihydroiodide, Ferric Sulfate, Ferric citrate, Manganese sulfate, Sodium 

Selanate, Sodium Selanite Sodium Chloride, and Zinc Sulfate.

Minerals are produced using chemical synthesis and extraction from either natural or reclaimed 

sources and while a range of potential environmental impacts may occur from excess and 

improper disposal during manufacture, under normal animal feeding the risks to the 

environment are low, and human health effects specifically related to trace minerals in aquatic 

animal feeds have not been reported.

Minerals are included as ingredients in feed pellets at approximately 0.1% to o.2% of feed pellet 

mass. The dietary importance of a given trace mineral is conditional on the animal species 

being grown.

In considering alternative sources for trace minerals as petitioned it should be noted that feeding 

wild caught fish, fish meal, other animal based meals, together with plant based feeds such as 

soy, corn, cottonseed etc. could provide a balanced diet without the fortification of feed with 

synthetic trace minerals.

In reviewing whether minerals are compatible with organic agriculture the subcommittee took 

into consideration the Organic Food Production Act (OFPA) which limits the use of synthetics to 

various categories, one of which is “pheromones, soaps, horticultural oils, fish emulsions, 

treated seeds, vitamins and minerals”.

It should be noted that at the time of drafting this proposal there are no federal standards 

promulgated for aquatic plant or animal production and this proposal is based on NOSB 

Recommendations voted in 2007, 2008, and 2009

Evaluation Criteria (see attached checklist for criteria in each category)

Criteria Satisfied? 

1. Impact on Humans and Environment x☐ Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria x☐ Yes ☐ No ☐ N/A

3. Compatibility & Consistency x☐ Yes ☐ No ☐ N/A 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Substance Fails Criteria Category: N/A

Subcommittee Action & Vote, including classification proposal (state actual motion):

Classification Motion: Motion to classify Minerals as synthetic: 

Motion by: Francis Thicke 

Seconded by: C. Reuben Walker

Yes: 7 No: 0 Absent: 0 Abstain: 0 Recuse: 0#

Listing Motion: Motion to list Minerals at §205.611 of the National List.

Motion by: Francis Thicke 

Seconded by: C. Reuben Walker

Yes: 6 No: 1 Absent: 0 Abstain: 0 Recuse: 0

 Proposed Annotation (if any): None

Basis for annotation: ☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Notes: 

Minority Opinion: see end of document

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB February 3, 2014

NOSB Evaluation Criteria for Substances Added To the National List: Livestock

Category 1. Adverse impacts on humans or the environment? Minerals (aquatic animals) 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse? 

[§6518(m)(3)]

X When used as petitioned trace minerals 

from unconsumed feed pellets have the 

potential to persist in treated bodies of 

water, ground water, sediments and 

bioaccumulate in animal tissues. Data 

regarding persistence of trace minerals 

resulting from uses in aquaculture are 

limited. (TR 657-659). Overall the risk of 

lethal effects from bioconcentration is 

considered low (TR685-686)

2. Is there a probability of environmental 

contamination during, manufacture or

disposal? [§6518(m)(3)]

X Industrial effluents consisting of trace 

minerals may contribute to deleterious 

growth algal blooms as found in India 

(TR810-811), but under normal regulated 

operation risks are low 

3. Are there any adverse impacts on X When used as petitioned trace minerals 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

biodiversity? (§205.200) in the minute amounts used (.01-0.2% in 

feed) adverse impact on biodiversity is 

low risk

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

X No (TR 548)

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X No direct interactions between trace 

minerals and other aquatic animal feed 

additives were identified (TR 825) The 

petitioned trace minerals are chemically 

equivalent to trace minerals used in 

fortification of organic livestock feed for 

terrestrial animals.

6. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X X There is a wide range of toxicities 

associated with the range of trace 

minerals especially at excessive levels 

(TR 697-821) However a negligible 

potential for toxicity exists under the 

prescribed use. (TR 738-740)

7. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X Data on persistence in aquatic systems is 

limited (TR 658) 

Overall the risk of lethal effects from 

bioconcentration of the petitioned trace 

elements is considered low. (TR 685-686)

8. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

X Environmental concentrations of trace 

minerals are unlikely to cause adverse 

health effects in humans except during 

improper disposal (TR 920-926) and 

human health effects specifically related 

to trace minerals in aquatic animal feeds 

have not been reported (TR 927-928)

9. Are there adverse biological and 

chemical interactions in the agroecosystem? [§6518(m)(5)]

X No reported toxicity has been observed in 

non-target wildlife or livestock and toxicity 

in the ago-ecosystem is unlikely. 

Accidental release of industrial effluent 

may lead to ecological impairment.

10. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X Trace elements are required by soil 

organisms, crops and livestock, so if the 

usage rates are kept within requirements 

for aquatic animals there should be no 

detrimental effects.
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Category 2. Is the Substance Essential for Organic Production? Minerals (aquatic animals)

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X X Trace minerals are produced using 

chemical synthesis and extraction from 

either natural or reclaimed sources. (TR 

556-557)

3. 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 2 above

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X See 2 above

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X There are no direct substitutes for trace 

minerals (TR 993) There are natural 

sources- fish meal being the best source, 

but availability and resource demands to 

use them widely make them an 

unrealistic source. Many trace minerals 

can be found in vegetable oils, kelp, raw 

animal meat and so forth (TR 994-1044) 

Further the fish industry is working to 

mitigate demand for wild fish as fish 

feed.(TR 1068-1076)

In the early years of aquaculture raw 

horsemeat was used (TR 403-404)

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X X See 5 above

A combination of plant based and animal 

based feeds may meet dietary 

requirements thereby precluding 

supplementation by synthetic trace 

minerals (TR 1109-1118)

8. Are there any alternative substances? 

[§6518(m)(6)]

X See 5 above

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X There is debate as to whether vitamin or 

trace minerals are necessary to meet 

nutritional requirements of farmed fish. 

(TR 1052-1054) (TR 1096)

However when fish are reared in high 

density indoor system or other closed 

systems they need to be provided with 

complete, fortified diets (TR 1096-1098)
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Category 3. Is the substance compatible with organic production practices? Minerals (aquatic 

animals)

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

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

X Minerals are presently on the National 

List at 205.603(d)(3) and

Minerals are listed in the OFPA at 6517 

(c) (1)(B)(i)

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X See 1 above

3. If used in livestock feed or pet food, Is 

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X Trace minerals enrich and fortify feed

4. If used in livestock feed or pet food, Is 

the primary use as a preservative? 

[§205.600(b)(4)]

X

5. If used in livestock feed or pet food, Is 

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

X

6. Is the substance used in production, and 

does it contain an active synthetic 

ingredient in the following categories: 

[§6517(c)(1)(B)(i);

copper and sulfur compounds

X Some trace minerals include sulfur and 

copper compounds (TR 540-544)

toxins derived from bacteria X

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X Trace minerals

livestock parasiticides and medicines X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Minority Opinion - Minerals for aquatic animals

February 21, 2014

Since this petition is being considered in the absence of regulations defining acceptable 

practices in organic aquaculture, essentiality in particular cannot be judged at this time, so the 

NOSB needs to reconsider the approval in five (5) years. The minority believes that there should 

be a five-year expiration date as an annotation. Current consideration of the material has raised 

issues relating to health or environmental impacts, because of the broad coverage of the term 

“minerals;” alternative natural materials and management methods; and compatibility with 

organic practices. The review in five (5) years provides an opportunity for the NOSB to 

reevaluate and vote for the continued or modified use of the material under the same standard 

of review that is used to approve the material initially. 

The minority also has the following concerns:

• The listing for “minerals” without qualification of either specific synthetic substance or 

specific use or application, is inconsistent with (§6517(b) of OFPA: “The list established 

under subsection (a) of this section shall contain an itemization, by specific use or 

application, of each synthetic substance permitted under subsection (c)(1) of this section 

or each natural substance prohibited under subsection (c)(2) of this section.”)

• The listing for “minerals” includes many substances that should not be allowed in organic 

production (e.g., arsenic compounds), or used in aquatic situations (e.g., copper sulfate).

• The listing for “minerals” without qualification or specific identification does not allow an 

informed vote on either classification or other OFPA criteria. It is impossible to judge the 

health and environmental impacts of or the need for unspecified minerals.

• The petitioner has not made a case for a need for synthetic “trace minerals” in general, 

and certainly not for synthetic “minerals.”

• It is incompatible with organic agriculture to allow the routine use of synthetic materials 

to fulfill essential system functions.