NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP

For NOSB Meeting: May 2009 Substance: Sodium Chlorite, acidified for use in handling

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

 

2. Essential & Availability Criteria Yes X No  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 

B. Substance fails criteria? 

Criteria category: ___none_______ 

Comments: 

C. Proposed Annotation: Secondary direct antimicrobial food treatment and indirect food 

contact surface sanitizing. Acidified with citric acid only.

Basis for annotation: See discussion in summary narrative below

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________

D. Final Board Action & Vote (State Actual Motion): To list sodium chlorite, acidified on §205.605(b) with the annotation as 

recommended by the Handling Committee

Motion: Joe Smilie Second: Steve DeMuri Yes: 12 No: 2 Recuse: 0 Abstain: 0 Absent: 1 

 

Provide a summary narrative here or attach a more complete narrative, and attach the original committee recommendation

that includes the evaluation criteria checklist:

The Handling committee voted to recommend this material because (1) it is more effective in some situations as a sanitizer than other 

materials already on the National List (see petitioner’s response to Handling Committee questions attached); (2) the solution breaks 

down to citric acid, water, and common table salt so the breakdown products are fairly benign; (3) there is broad regulatory approval for 

the substance (FDA, USDA's Food, Safety and Inspection service, EPA, and multiple other food safety agencies around the world); 

and (4) a European food safety authority has reviewed this material and determined that trihalomethanes, reaction materials that form 

when other chlorine materials on the list (sodium and calcium hypochlorite) react with organic compounds and are of environmental 

concern, have not been reported to be formed when this material is used. One committee member voted not to list this substance 

because of concern with adding any synthetic substances to the National List.

The Handling Committee included a recommended annotation for the listing of Sodium Chlorite, acidified (ACS) on the National List. 

The recommended annotation reflected the committee’s review of the April 20, 2003 recommendation by the NOSB Processing 

Committee on the clarification of chlorine contact with organic food. There is quite a history on the annotations of these materials that 

reflect some confusion about whether or not they can be used in direct food contact and then at what levels. The Handling Committee 

wanted to recognize that confusion and be consistent with a past Board’s recommendation.

Public comment on ACS reflected that the rationale for adding the annotation was not clear and that the annotation was not clear. 

Also, one public comment reinforced that current annotations for chlorine materials in general are not clear with regard to direct food 

contact, and said that the annotations should be made consistent with practice or practice consistent with the annotations. 

The Handling Committee, after hearing public comment at the May 2009 NOSB meeting met during the meeting to review the 

annotation. The annotation has three parts:

1. The first part addresses how ACS may be used. The Handling Committee wanted to be clear in our recommendation that 

this could be used for direct anti-microbial food treatment and indirect food contact surface sanitizing. This part of the 

annotation reflects public comment that current annotations for chlorine materials are not clear on how these materials may 

be used.

2. The second part of the annotation addresses the residual chlorine levels in water discussed in the April 30, 2003 NOSB 

Processing Committee recommendation. That recommendation reflected a concern the Board had at the time about residual 

chlorine on food that consumers would consume. After further review, this concern is not relevant to ACS because after 

contact with food it breaks down to water, citric acid and table salt. After the motion to add ACS to the National List with the 

Handling Committee’s recommended annotation, a friendly amendment was made and accepted to remove this part of the 

annotation. Later in the discussion, the NOP recommended that this part of the annotation be retained if ASC was to be 

Agricultural Nonagricultural X Crops

Synthetic X Not synthetic Livestock

Allowed X 1Prohibited2

Handling X

No restriction Deferred4 Rejected3
listed as a separate listing from the other chlorine materials already on the list. Further discussion clarified for the NOP that 

that no residual chlorine exists after use. The NOP said that this addressed their concern and there was no further 

discussion on the friendly amendment meaning that this second part of the Handling Committee’s recommended annotation 

was removed for the final NOSB recommendation.

3. The third part of the annotation addresses the citric acid that is used as part of ACS. The NOSB Handling Committee 

wanted to note that only citric acid allowed for use in organic handling should be used when using ACS. The need for this 

portion of the annotation was discussed at length during Board deliberation. The petitioner confirmed that other acids can be 

used to acidify the sodium chlorite. After the motion to add Sodium Chlorite, acidified to the National List, a friendly 

amendment was made and accepted to remove this part of the annotation. A further friendly amendment was made and 

accepted to add “Acidified with citric acid only.” These two friendly amendments reflected Board discussion that the acid 

used to acidify the sodium chlorite should be compatible with organic methods and that the listing on 205.605(a) does not 

apply to sanitizers but to the 5% of non-organic ingredients allowed in food.

With regards to the public comment received that the annotation for chlorine materials already listed on the National List 205.605(b) are 

confusing, the National Organic Program suggested having the board recommend that the annotation be changed to read “Disinfecting 

and sanitizing food and food contact surfaces.” Then ACS could be added at the end of the list. The board asked for NOP guidance 

on the appropriate process with which to make that recommendation. After discussion, the NOSB decided to proceed with this 

substance, but asked that when reviewing the recommendation the program review the annotations for the other chlorine materials as 

well. If a correction based on the April 30, 2003 recommendation is not possible, we ask that the NOP let the NOSB Executive 

Committee know and the NOSB will consider a further recommendation. 

1—substance voted to be added as “allowed” on National List on National List to § 205.605(b) with Annotation (if any): Secondary 

direct antimicrobial food treatment and indirect food contact surface sanitizing. Acidified with citric acid only.

2—substance to be added to “prohibited” paragraph of National List to § 205.______ Describe why a prohibited substance:

_____________________________________________________ ___________________________________

__ ____

 _

 

___ 

3—substance was rejected by vote for amending National List to § 205.____ Describe why material was rejected: _____________ 

___________________________________________________ __ 

4-substance was recommended to be deferred § 205. ______ Describe why deferred; if any follow-up is needed. If follow-up needed, 

who conducts follow-up ________________________________ ____________________________________ 

E. Approved by NOSB Chair to transmit to NOP

Jeff Moyer May 6, 2009

 . 

Chair Date

 .

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

 Return to NOSB Reason: ____________________________________________________________________ 

_____________________________________ _________________________ 

 Date 
NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: ____May 2009_____________ Substance: Sodium Chlorite, acidified

Committee: Crops  Livestock  Handling X Petition is for: Inclusion of Sodium Chlorite, acidified on the 

National List § 205. 605b

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

 

2. Essential & Availability Criteria Yes X No  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 

B. Substance Fails Criteria Category: Comments: 

C. Proposed Annotation (if any): Secondary direct antimicrobial food treatment and indirect food contact surface sanitizing. 

Residual chlorine levels in the water in direct crop or food contact shall not exceed the maximum residual disinfectant limit under

the Safe Drinking Water Act. Citric acid used must meet requirements as listed in § 205.605(a)

Basis for annotation: To meet criteria above: _x__ Other regulatory criteria: _______ Citation:__For a thorough discussion of 

the recommended annotation see the April 30, 2003 NOSB Processing Committee recommendation titled “Measuring Effluent:

Clarification of Chlorine Contact with Organic Food”

D. Recommended Committee Action & Vote (State Actual Motion): __Recommend Sodium Chlorite, acidified for listing on 

205.605b 

________________________________________________________________________________________________________

Motion by: Katrina Heinze Seconded: Steve Demuri Yes: 3 No: 1 Absent: 1 Abstain: 1 

 

 

1) Substance voted to be added as “allowed” on National List to § 205. 605b with Annotation -- Secondary direct antimicrobial food 

treatment and indirect food contact surface sanitizing. Residual chlorine levels in the water in direct crop or food contact shall 

not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act. Citric acid used must meet requirements 

as listed in § 205.605(a)

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 § 205.606 Describe why material was rejected: 

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops Agricultural Allowed1 X

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4

E. Approved by Committee Chair to transmit to NOSB:

___Steve Demuri___________________________ March 11, 2009_______

 Committee Chair Date
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment?

Substance – Sodium chlorite, acidified

Question Ye

s

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 Technical Evaluation Report (lines 188-202) – Chloride 

is ultimate byproduct. No environmental impact is 

expected at expected concentration levels.

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3]

x Sodium chlorite is manufactured in a manner similar to 

other materials already on National List (i.e., sodium 

hypochlorite, calcium hypochlorite and chlorine dioxide). 

From 3/15/06 Crops Committee recommendation on 

Chlorine materials – “Review of the current Technical 

Evaluation Report supplied to the NOP shows that 

calcium and sodium hypochlorite, and chlorine dioxide 

are all synthetic materials not produced from naturally 

occurring sources or processes. The report states that 

no information is available from EPA or FDA to suggest 

that environmental contamination results from the proper 

manufacture, use, or disposal of calcium or sodium 

hypochlorite.”

One concern with the sodium and calcium hypochlorite 

materials already on the National List is the potential 

formation of trihalomethane compounds when 

hypochlorite ions react with organic material in the 

environment (page 1, Crops Committee 

recommendation of 3/15/06). The petition (page 12) 

references a European Food Safety Authority report that 

states, “When examining the possibility for reaction 

products, no halomethanes have been reported to be 

formed in treatments with chlorine dioxide in water. No 

chlorinated organics have been found after treatments of 

poultry carcasses with acidified sodium chlorite.”

3. Is the substance harmful to 

the environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

x Petition, p. 16 (Section 12) – breakdown products of 

ACS are citric acid, salt and water. 

Technical Evaluation Report (lines 188-202) – Chloride 

is ultimate byproduct. No environmental impact is 

expected at expected concentration levels.

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

6. Are there adverse biological 

and chemical interactions in 

agro-ecosystem? [§6518 m.5]

x See above – Category 1, #3

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

x See above – Category 1, #3

8. Is there a toxic or other 

adverse action of the material or 

x See above – Category 1, #3
its breakdown products? 

[§6518 m.2]

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment?[§6518 

m.2]

x See above – Category 1, #3

10. Is there any harmful effect 

on human health? 

[§6517 c (1)(A)(i) ; 6517 

c(2)(A)i; §6518 m.4]

x Technical Evaluation Report (lines 263-266) -- The ASC 

solution is not listed as generally recognized as safe 

(GRAS). However, both sodium chlorite and citric acid, 

which are the components used in preparation of ASC 

solution, are approved by FDA as GRAS. In addition, 

both sodium chlorite and citric acid are listed under 

indirect and direct food substances affirmed as GRAS in 

21 CFR §186.1750 and 21 CFR §184.1033, 

respectively.

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

x See above – Category 1#10

See also Technical Evaluation Report lines 212-222

12. Is the substance GRAS 

when used according to FDA’s 

good manufacturing practices? 

[§205.600 b.5]

x See above – Category 1#10

13. Does the substance contain 

residues of heavy metals or 

other contaminants in excess of 

FDA tolerances? [§205.600 b.5]

x From Technical Review – “Since ASC is a mixture of 

sodium chlorite solution and citric acid, any impurities in 

the resulting ASC solution are expected from both 

components. Currently there are no set purity criteria for 

ASC (Rao, 2007).

Sodium chlorite solution is commonly prepared by using 

technical-grade of sodium chlorite solid, which is 

comprised of 80% sodium chlorite, with sodium chloride, 

sodium carbonate, sodium hydroxide, sodium sulfate, 

and sodium chlorate making up the remainder of the 

compositions. In general, the manufacturing process 

employed in the production of sodium chlorite does not 

include any specific purification steps. Heavy metal, 

lead, may occur in the final product as a result of their 

occurrence in the starting material that are obtained from 

natural sources. Lead must be limited by the 

specifications indicating maximum levels of 5 mg/kg 

(Rao, 2007). In addition, the citric acid used to acidify 

sodium chloride solution must meet FDA specifications 

of its identity and purity.

There is no other published information to suggest that 

other heavy metals or contaminants may or may not be 

present in the petitioned substance.” 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 – Sodium chlorite, acidified

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 See petition and Technical Evaluation Report 

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 petition and Technical Evaluation Report

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)]

x See petition and Technical Evaluation Report

4. Is there a natural source of 

the substance? [§205.600 b.1]

x See petition and Technical Evaluation Report

5. Is there an organic 

substitute? [§205.600 b.1]

x See petition and Technical Evaluation Report

6. Is the substance essential 

for handling of organically 

produced agricultural 

products? [§205.600 b.6]

x Chlorine and peracetic acid, already on the National List, 

can be used in some applications in place of ASC 

solution. However, depending on the application ASC 

may be the most effective antimicrobial. For a full 

discussion, see the petitioner’s 2/24/09 response to 

questions. 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)]

x See petition and Technical Evaluation Report

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)]

x

9. Is there any alternative 

substances? [§6518 m.6]

x See above – Category 2, question 6

10. Is there another practice 

that would make the substance 

unnecessary? [§6518 m.6]

x Sanitizing of food contact surfaces or, where needed, 

direct food contact surfaces is required. See above 

Category 2, #6for discussion of alternative substances. 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 – Sodium chlorite, acidified

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Is the substance compatible 

with organic handling? 

[§205.600 b.2]

2. Is the substance consistent 

with organic farming and 

handling? [§6517 c (1)(A)(iii); 

6517 c (2)(A)(ii)]

X

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

X

4. Is the nutritional quality of 

the food maintained with the 

substance? [§205.600 b.3]

x See Technical Evaluation Report lines 227-240

5. Is the primary use as a 

preservative? [§205.600 b.4]

x See Technical Evaluation Report lines 245-250

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 See petition

See also Technical Evaluation Report lines 256-258

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

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.
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 chlorite, acidified

Question Ye

s

No N/A Comments on Information Provided (sufficient, 

plausible, reasonable, thorough, complete, 

unknown)

1. UIs the comparative description

providedU as to why the non-organic 

form of the material /substance is 

necessary for use in organic handling?

x

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 

UformU 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 

UqualityU 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

UquantityU to fulfill an essential 

function in a system of organic 

handling?

x

5. Does the industry information 

provided on material / substance nonavailability as organic, include ( but 

not limited to) the following:

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
Petitioner’s Response to NOSB Handling Committee Questions:

2/24/09

TO: Bob Pooler

USDA/AMS/TMP/NOP

RE: Response to 2/17/09 questions

Mr. Pooler, 

Ecolab has been informed of your questions regarding the petition to add Acidified Sodium 

Chlorite (ASC) to the National List and provides the following response to address both of your 

inquiries.

1. Why are materials currently on the list not suitable for applications where 

Acidified Sodium Chlorite solution is suitable? 

See response below.

2. Why are currently allowed substances not appropriate substitutes for ASC 

solution? 

The demand for an improvement of food safety has induced changes in the methods 

used for pathogen control in food processing. The adoption of new technologies 

allows the processors the ability to achieve a safer food product through reduced 

pathogen levels. This is especially important given the focus on food safety as a 

result of the recent recalls of peanut butter, jalapeno peppers, and ground beef. Food 

manufacturers today each face different challenges depending on the type of food 

produced, the size of the facility, the level of production, temperature, environment, 

time of day and physical pressures to name a few. 

The food industry has adopted a multi-hurdle approach to food safety interventions 

since the implementation of the HAACP standard in the 1990s. Ecolab believes that 

no single product or chemistry is appropriate for the wide variety of intervention 

points and application methods used to improve food safety in the modern 

manufacturing process. Put simply, there is no “silver bullet” antimicrobial 

intervention on the market today that is capable of or appropriate to tackling all of the 

issues that these processors face. We believe that offering processors multiple 

intervention formulas will allow for each individual processor to tailor its interventions 

to its specific needs. Our goal is to provide our customers with enough intervention 

options to help meet those needs and ensure a safer food supply. What works for 

one processor may not necessarily work for another. The availability of multiple 

choices of antimicrobial interventions will only help bolster the arsenal that a food 

facility can use to combat outbreaks of food-borne illness.

DAN R DAHLMAN

Regulatory Analyst

Product Registration & ComplianceFood Additives

T 651.225-3297

F 651.225-3122
According to the National List, the only offerings currently approved for food contact 

surface sanitizers in organic processing are chlorine and peracetic acid. Both 

substances have a crucial impact on the food supply, and are widely used today. 

Chlorine has a variety of applications, including water disinfection/sanitization and 

hard surface sanitization. Peracetic acid has a broad use of applications in the meat 

and poultry industries as well as in the fruit and vegetable industry, and as a 

component of a sanitizer for food processing equipment. ASC has an even broader 

range of applications including red meat, poultry, seafood, and fruits and vegetables.

It was mentioned in the Technical Evaluation Report that peracetic acid can be 

substituted for ASC. Ecolab strongly opposes this viewpoint. While both substances 

exhibit oxidative chemistry to control bacterial growth, each substance has its place 

in the processing environment and each provides its own advantages. For example, 

a typical poultry processor may purchase both a peracetic acid product and an ASC 

product for their facility. Ecolab currently markets Inspexx 100 (peracetic) and 

Sanova (ASC) for poultry processors. Inspexx 100 is typically used in poultry chillers 

when a low temperature and longer contact time occur to ensure the greatest 

reduction in bacterial contamination. Sanova, on the other hand, is used in situations 

where a much shorter contact time is required, and is typically used in the pre-chill or 

post-chill processing steps where contact time is limited, yet the same level of control 

is needed. Inspexx 100 and Sanova are both effective against Salmonella 

typhimurium, Campylobacter jejuni, Listeria monocytogenes, and E. Coli O157:H7. 

Depending on the customers needs, Ecolab can adapt and tailor its product line to 

satisfy those specific needs and offer a complete antimicrobial control package.

Ecolab currently lists 2 organic processing aids with OMRI that use peracetic acid as 

its active ingredient. Tsunami 100 is an EPA registered (1677-164) water additive for 

pathogen reduction in fruit and vegetable processing waters and for controlling the 

growth of spoilage and decay causing organisms on fruit and vegetable surfaces. 

Oxonia Active is also an EPA registered product (1677-129) for use as an acid liquid 

sanitizer for food processing equipment. The addition of ASC to the National List 

would allow Ecolab the opportunity to have OMRI review and comment on the red 

meat and poultry antimicrobial, Sanova. 

The availability of chlorine, peracetic acid, and ASC antimicrobial products in various 

types of organic facilities provides processors with an effective and complete 

package to control food borne outbreaks. Ecolab respectfully requests the inclusion 

of ASC on the National List in the interest of food safety. We urge you to vote to 

include ASC in the National List of Allowed Substances as a synthetic ingredient 

allowed in or on processed products.

Respectfully,

Dan Dahlman