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 Jun 2013 

National Organic Standards Board

Handling Subcommittee

Petitioned Material Checklist

Ammonium Hydroxide

February 19, 2013

Summary of Proposed Action:

Ammonium Hydroxide is a powerful alkali petitioned for use as a boiler additive because it neutralizes carbonic 

acid in condensate to prevent corrosion. Ammonium hydroxide is produced by the addition of water to 

Ammonia. Ammonia is produced on a large scale worldwide and one of its largest uses by production volume 

is as an ingredient in non-organic fertilizer.

Ammonium hydroxide is a severe irritant which must be handled properly because exposure by humans and 

other mammals during production or use presents a serious toxicological concern. It is toxic by all routes, 

inhalation, dermal and ingestion and the toxicity is well documented. It is an air and water pollutant and 

contributes as a greenhouse gas. It is toxic to fish and other aquatic species. Spillage could cause 

considerable environmental damage.

Ammonium hydroxide is not essential to organic production. There are other boiler additives on the National 

List. There are also a number of alternative practices which can be used instead of boiler additives. The 

addition of ammonium hydroxide is not consistent with organic agriculture. 

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

Criteria Satisfied? 

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

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

3. Compatibility & Consistency ☐ Yes ☒ No ☐ N/A 

4. Commercial Supply is Fragile or Potentially Unavailable ☐ Yes ☐ No ☒ N/A 

as Organic (only for §205.606)

Substance Fails Criteria Category: [3] Comments:

Ammonium hydroxide has the potential to cause significant toxic damage to humans, mammals, aquatic 

systems and greenhouse gasses and is not essential or compatible with organic agriculture and handling.

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

Classification Motion: Move to classify Ammonium hydroxide (CAS # 1336-21-6) as petitioned is 

synthetic

Motion by: Jean Richardson 

Seconded by: Tracy Favre 

Yes: 6 No: 0 Absent: 2 Abstain: 0 Recuse: 0

Listing Motion: Move to list Ammonium hydroxide (CAS # 1336-21-6) to the National List Section 

205.605b]

Motion by: Jean Richardson 

Seconded by: Carmela Beck

Yes: 0 No: 6 Absent: 2 Abstain: 0 Recuse: 0

 Proposed Annotation (if any): none

Approved by John Foster, Subcommittee Chair, to transmit to NOSB February 19, 2013
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 Jun 2013 

NOSB Evaluation Criteria for Substances Added To the National List

Handling

Category 1. Adverse impacts on humans or the environment? Ammonium hydroxide 

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

petition; regulatory agency; other)

1. Are there adverse effects on the 

environment, or is there a probability of 

environmental contamination during use

or misuse of the substance?

[§205.600(b)(2), [§6518(m)(3)]

X Toxic to environment if spilled or 

volatized to atmosphere (TR (2001) and 

petition)

2. Are there adverse effects on the 

environment or is there a probability of 

environmental contamination during 

manufacture or disposal of the 

substance? [§6518(m)(3)]

X Worker injury through breathing, 

ingestion or dermal contact and terrestrial 

damage with spills during manufacture. 

(Petition and TR).

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X Toxic damage will occur through spills in 

terrestrial or aquatic systems, and 

ammonia contributes to greenhouse 

gases (Petition pages 8-10) Fish are 

particularly at risk for toxic effects.

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

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

X

5. Is there undesirable persistence or 

concentration of the material or 

breakdown products in the environment?

[§6518(m)(2)]

X When released into air the gas 

contributes to Greenhouse gases.

6. Are there any harmful effects on human 

health from the main substance or the 

ancillary substances that may be added 

to it? [§6517(c))(1)(A)(i); 6517 

(c)(2)(A)(i); §6518(m)(4), 205.600(b)(3)]

X Yes toxic if inhaled, ingested or dermal 

contact

7. Is the substance, and any ancillary 

substances, GRAS when used according 

to FDA’s good manufacturing practices? 

[§205.600(b)(5)]

X

8. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600

(b)(5)]

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 Jun 2013 

NOSB Evaluation Criteria for Substances Added To the National List

Handling

Category 2. Is the Substance Essential for Organic Production? Ammonium hydroxide 

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 Ammonium hydroxide is manufactured 

from natural gas which is used to convert 

atmospheric nitrogen to ammonia and 

then water is added to produce the 

hydroxide form.

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

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is the substance essential for handling of 

organically produced agricultural 

products? [§205.600(b)(6)]

X

8. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X

9. Are there any alternative substances? 

[§6518(m)(6)]

X There are non-organic alternatives on the 

NL

10. Is there another practice (in farming or 

handling) that would make the substance 

unnecessary? [§6518(m)(6)]

There are a number of alternative 

practices which can be used (Petition 

page11) These include pre-treating 

water, replacing steam pipelines with 

stainless steel etc.

11. Have the ancillary substances associated 

with the primary substance been 

reviewed? Describe, along with any 

proposed limitations. 

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 Jun 2013 

NOSB Evaluation Criteria for Substances Added To the National List

Handling

Category 3. Is the substance compatible with organic handling practices? Ammonium hydroxide

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

petition; regulatory agency; other)

1. Is the substance consistent with organic 

handling? 

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

X

2. Is the manner of the substance’s use, 

manufacture, and disposal compatible 

with organic handling? [§205.600(b)(2)]

X

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X

4. Are the ancillary substances reviewed 

compatible with organic handling?

x

5. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X

6. Is the primary use as a preservative? 

[§205.600(b)(4)]

X

7. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive 

values lost in processing (except when 

required by law)? [§205.600(b)(4)]

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 Jun 2013 

NOSB Evaluation Criteria for Substances Added To the National List

Handling

Category 4. Is the commercial supply of an organic agricultural substance fragile or potentially 

unavailable? [§6610, 6518, 6519, §205.2, § 205.105(d), §205.600(c)] Ammonium Hydroxide

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

petition; regulatory agency; other)

1. Is the comparative description as to why 

the non-organic form of the material 

/substance is necessary for use in 

organic handling provided? 

X The Petition describes in detail the 

reasons for petitioned use of this boiler 

additive

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 about 

unavailability include (but is 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. Other issues which may present a 

challenge to a consistent supply?

X