FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: ___November 30, 2007

Subject: ___Revisions to the NOSB Policy and Procedures Manual__

Chair: __Andrea Caroe__ 

 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: _______

Guidance Statement: ________ 

Other: __X___ 

Statement of the Recommendation (including Recount of Vote):

Acceptance of the following revisions to the NOSB Policy and Procedures Manual: 

1. Section II (p6) 

 a. Add introductory paragraph to section 

 b. Add NOSB Statutory Mission paragraph 

 c. Two edits to the NOSB Mission Statement 

 d. Updated OFPA section number 

2. Section VIII 

 a. Moved NOSB Committee Recommendation form to appear before the 

 Evaluation Criteria forms (p45) 

 b. Updated NOSB Committee Recommendation form to specify uses of 

 petitioned material (p45) 

 c. Added Section on Clarification for deferral (p 54) 

3. Appendix D - Added definitions of Table and Rescind (p62) 

NOSB Vote: Motion: R. Delgado Second: B. James 

Board vote: Yes - 15 No- 0 Abstain- 0 Absent - 0 

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

The proposed revisions will improve the process of conducting NOSB business.

Response by the NOP:
National Organic Standards Board 

Recommendation for 

Revisions to the NOSB Policy and Procedures Manual 

Date: 11/30/07 

I. List: (where in FR rule example 205.606) 

N/A 

II. Committee Summary: 

As part of the on-going update to the NOSB Policy and Procedures Manual, the Policy and 

Development committee is proposing several updates to Section I, Section VIII and Appendix D. 

The revisions will allow committee members to improve the decision making process. 

1. Section II (p6) 

a. Add introductory paragraph to section 

b. Add NOSB Statutory Mission paragraph 

c. Two edits to the NOSB Mission Statement 

d. Updated OFPA section number 

2. Section VIII 

a. Moved NOSB Committee Recommendation form to appear before the Evaluation 

Criteria forms (p45) 

b. Updated NOSB Committee Recommendation form to specify uses of petitioned 

material (p45) 

c. Added Section on Clarification for deferral (p 54) 

3. Appendix D - Added definitions of Table and Rescind (p62) 

III. Board Recommendation 

To accept the revisions to the NOSB Policy and Procedures Manual. 

Board vote: 

Moved: R. Delgado Second: B. James 

Board vote: Yes- 15 No- 0 Absent- 0 Abstain-0 Recuse -0
NOSB – Policy Development Committee 

Updates to the Policy and Procedures Manual 

September 19, 2007 

Summary: 

As part of the on-going update to the NOSB Policy and Procedures Manual, the Policy 

and Development committee is proposing several updates to Section I, Section VIII and 

Appendix D. The revisions will allow committee members to improve the decision 

making process. 

Recommendation: 

The Policy Development Committee recommends the following updates to the Policy and 

Procedures Manual: 

1. Section I p 5 – 

2. Section 11- (p6) 

a. Add introductory paragraph to section 

b. Add NOSB Statutory Mission paragraph 

c. Two edits to the NOSB Mission Statement 

d. Updated OFPA section number 

3. Section VIII 

a. Moved NOSB Committee Recommendation form to appear before the 

Evaluation Criteria forms (p45) 

b. Updated NOSB Committee Recommendation form to specify uses of 

petitioned material (p45) 

c. Added Section on Clarification for deferral (p 54) 

4. Appendix D - Added definitions of Table and Rescind (p62) 

Committee Vote: 

Yes – 4 No- 0 Abstain- 0 Absent - 0 
 

NATIONAL ORGANIC STANDARDS BOARD 

 

POLICY AND PROCEDURES 

MANUAL

 

 

 

 

 

 

 Adopted October 19, 2002 

Revised August 18, 2005 

Revised March 29, 2007 

Revised November 30, 2007

1 
NOSB POLICY AND PROCEDURES MANUAL 

TABLE OF CONTENTS 

INTRODUCTION ............................................................................................................................. 5

SECTION I....................................................................................................................................... 6

NOSB VISION STATEMENT...................................................................................................... 6

NOSB STATUTORY MISSION................................................................................................... 6

“TO ASSIST IN THE DEVELOPMENT OF STANDARDS FOR SUBSTANCES TO BE USED IN ORGANIC 

PRODUCTION AND TO ADVISE THE SECRETARY ON ANY OTHER ASPECTS OF THE IMPLEMENTATION OF 

THIS TITLE.” (OFPA, SEC 2119 (A))............................................................................................... 6

NOSB MISSION STATEMENT................................................................................................... 6

DUTIES OF THE BOARD AND OFFICERS................................................................................ 6

Duty of Loyalty ...................................................................................................................... 8

Duty of Obedience ................................................................................................................ 8

Maintaining Professional and Ethical Standards .............................................................. 8

• Professional Conduct ..................................................................................................... 9

• Conflict of Interest ........................................................................................................ 10

SECTION II.................................................................................................................................... 11

BOARD MEMBER JOB DESCRIPTIONS................................................................................ 11

CONDUCTING BUSINESS....................................................................................................... 12

SECTION III................................................................................................................................... 13

ROLE OF THE EXECUTIVE DIRECTOR.................................................................................. 13

OFFICER RESPONSIBILITIES ................................................................................................ 13

ELECTION OF OFFICERS ....................................................................................................... 14

EXECUTIVE COMMITTEE ....................................................................................................... 14

MEETINGS................................................................................................................................ 15

SECTION IV .................................................................................................................................. 16

BOARD COMMITTEES ............................................................................................................ 16

COMMITTEE MEETINGS......................................................................................................... 17

STANDING COMMITTEES....................................................................................................... 17

Certification, Accreditation, and Compliance Committee .............................................. 17

Crops Committee................................................................................................................ 17

Materials Committee........................................................................................................... 18

Handling Committee........................................................................................................... 18

Policy Development Committee ........................................................................................ 18

TASK FORCES......................................................................................................................... 18

SECTION V ................................................................................................................................... 19

DUTIES OF COMMITTEE CHAIRS .......................................................................................... 19

DUTIES OF COMMITTEE VICE-CHAIR................................................................................... 19

PROCEDURES FOR THE TRANSITION OF COMMITTEE CHAIRS ...................................... 20

COMMITTEE AND BOARD PROCEDURES ON RECOMMENDATIONS............................... 20

PROCEDURES TO PRESENT COMMITTEE RECOMMENDATIONS.................................... 21

NOSB AND NOP COLLABORATION PROCESS............................................................... 21

EXAMPLE FORM FOR FORMAL RECOMMENDATION ................................................... 26

2 
SECTION VI .................................................................................................................................. 27

MISCELLANEOUS POLICIES ................................................................................................. 27

NOSB Policy for Presenters Invited by Committees....................................................... 27

NOSB Policy for Surveys Conducted on Behalf of NOSB Committees ........................ 27

NOSB Policy for Public Comment at NOSB Meetings .................................................... 28

SECTION VII ................................................................................................................................. 29

NOSB PRINCIPLES OF ORGANIC PRODUCTION AND HANDLING.................................... 29

NOSB GUIDANCE ON COMPATIBILITY WITH A SYSTEM OF SUSTAINABLE

AGRICULTURE AND CONSISTENCY WITH ORGANIC FARMING AND HANDLING .......... 31

SECTION VIII ................................................................................................................................ 32

NATIONAL ORGANIC PROGRAM MATERIALS REVIEW PROCESS...................................... 32

Phase 1: Receipt of Petition ............................................................................................. 32

Phase 2: Examination of Petition for Completeness and Eligibility............................. 32

Phase 3: Evaluation by Contractor.................................................................................. 33

Phase 5: Action by NOSB Materials Chair and the Committee that the Substance Is 

Being Petitioned for Addition or Prohibition from the National List (Crops, Livestock 

or Handling)......................................................................................................................... 34

Phase 6: Action by Full NOSB.......................................................................................... 35

TECHNICAL ADVISORY PANEL (TAP) CONTRACT PROCEDURES ...................................... 36

STATEMENT OF WORK................................................................................................................. 36

AGENCY NEED ............................................................................................................................ 36

Phase 1: Data Gathering and Compilation (120 days) ................................................... 39

Phase 2: Evaluation against Criteria (100 days)............................................................. 39

Phase 3: Recommendation (42 days) .............................................................................. 40

EVALUATION FACTORS FOR AWARD............................................................................................. 40

OTHER EVALUATION FACTORS .................................................................................................... 40

REPORTING REQUIREMENTS ........................................................................................................ 41

INFORMATION TO BE INCLUDED IN A PETITION ................................................................ 42

EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST.................. 46

NOSB RECOMMENDED DECISION FORM ................................................................................ 50

PROCEDURES FOR THE MATERIALS REVIEW PROCESS FOR NOSB MEMBERS............. 51

SUNSET REVIEW PROCESS ...................................................................................................... 52

NATIONAL LIST SUNSET REVIEW PROCESS – NOP LEVEL ................................................. 52

OVERVIEW OF THE SUNSET PROCESS-STEPS COMPLETED.............................................. 52

• FEDERAL REGISTER NOTICE........................................................................................... 52

• RECEIPT OF PUBLIC COMMENTS.................................................................................... 52

• COMMITTEES FORWARDED RECOMMENDED SUBSTANCES FOR FURTHER 

TECHNICAL REVIEW TO NOP.................................................................................................... 52

NATIONAL LIST SUNSET REVIEW PROCESS – NOSB LEVEL .............................................. 52

SUNSET PROCESS-IN PROGRESS ........................................................................................... 53

• COMMITTEES REVIEWING SUBSTANCES UNDER SUNSET REVIEW ......................... 53

• COMMITTEES REVIEWING PUBLIC COMMENTS............................................................ 53

• COMMITTEES DRAFTING RECOMMENDATIONS ON SUBSTANCES ........................... 53

3 
• COMMITTEES FORWARDING SUBSTANCES FOR ADDITIONAL TECHNICAL REVIEW 

BASED ON PUBLIC COMMENTS ............................................................................................... 53

APPENDICES AND RESOURCES............................................................................................... 57

APPENDIX A - DECISION MAKING PROCEDURES FOR THE NOP ........................................ 58

APPENDIX B - FACA FACTS...................................................................................................... 59

APPENDIX C - DUTIES OF THE DESIGNATED FEDERAL OFFICER....................................... 61

APPENDIX D - PARLIAMENTARY PROCEDURE AT A GLANCE ............................................ 62

APPENDIX E - BASIC CHEMISTRY............................................................................................ 63

4 
INTRODUCTION 

 

 

This document is intended as a guide for all members of the National Organic 

Standards Board (NOSB). Board members are entrusted with a strong 

responsibility to treat the business of the Board as fiduciaries for all members of 

the organic community and the public at large. 

 

The Board’s primary role is to advise, rather than administer and implement. As 

in every business, the Board’s success depends heavily upon the ability to 

understand each other’s respective role, and to develop the working relationship 

necessary within those roles. 

 

This manual is designed to assist the Board in its responsibilities. New Board 

members are encouraged to review this manual in depth as well as to become 

familiar with the Organic Foods Production Act (OFPA), 7 CFR Part 205, and the 

NOSB New Member Guide. Existing members are advised to periodically review 

the contents to refresh their understanding of the Board’s role and their duties. 

 

New policies and revisions to existing policies and procedures will be 

incorporated into the NOSB Policy and Procedures Manual from time to time, as 

determined by the Board. 

 

 

5 
SECTION I 

 

This section presents the NOSB’s vision and mission statement as well as 

specifics on NOSB members’ duties, and professional and ethical standards. 

NOSB VISION STATEMENT 

 

The NOSB’s vision is an agricultural community rooted in organic principles and 

values that instills trust among consumers, producers, processors, retailers and 

other stakeholders. Consistent and sustainable organic standards guard and 

advance the integrity of organic products and practices. 

 

NOSB STATUTORY MISSION

 

“To assist in the development of standards for substances to be used in organic 

production and to advise the Secretary on any other aspects of the 

implementation of this title.” (OFPA, Sec 2119 (a)) 

NOSB MISSION STATEMENT 

 

To provide effective and constructive advice, clarification and guidance to the 

Secretary of Agriculture concerning the National Organic Program (NOP), and 

the consensus of the organic community. 

In carrying out the mission, key activities of the Board include: 

 

• Assist in the development and maintenance of organic standards and 

regulations; 

• Review petitioned materials for inclusion on the National List of Approved and 

Prohibited Substances (National List); 

• Recommend changes to the National List; 

• Communicate with the organic community, including conducting public 

meetings, soliciting and taking public comments; 

• Communicate, support and coordinate with the NOP staff; 

• Provide information and education on the NOP. 

DUTIES OF THE BOARD AND OFFICERS 

 

The Organic Foods Production Act of 1990 (OFPA) defines the following specific 

responsibilities for the Board starting at Sec 2119(k) 

 

(1) IN GENERAL.—The Board shall provide recommendations to the Secretary 

regarding the implementation of this title. 

6 
(2) NATIONAL LIST.—The Board shall develop the proposed National List or 

proposed amendments to the National List for submission to the Secretary in 

accordance with section 2118. 

(3) TECHNICAL ADVISORY PANELS.—The Board shall convene technical 

advisory panels to provide scientific evaluation of the materials considered for 

inclusion in the National List. Such panels may include experts in agronomy, 

entomology, health sciences and other relevant disciplines. 

(4) SPECIAL REVIEW OF BOTANICAL PESTICIDES.—The Board shall, prior to 

the establishment of the National List, review all botanical pesticides used in 

agricultural production and consider whether any such botanical pesticide 

should be included in the list of prohibited natural substances. 

(5) PRODUCT RESIDUE TESTING.—The Board shall advise the Secretary 

concerning the testing of organically produced agricultural products for 

residues caused by unavoidable residual environmental contamination. 

(6) EMERGENCY SPRAY PROGRAMS.—The Board shall advise the Secretary 

concerning rules for exemptions from specific requirements of this title 

(except the provisions of section 2112) with respect to agricultural products 

produced on certified organic farms if such farms are subject to a Federal or 

State emergency pest or disease treatment program. 

(Additional Duties included in OFPA but not limited to): 

 6518(n)PETITIONS. The Board shall establish procedures under which 

persons may petition the Board for the purpose of evaluating substances for 

inclusion on the National List. 

 6509(d)(2) STANDARDS. The National Organic Standards Board shall 

recommend to the Secretary standards in addition to those in paragraph (1) 

for the care of livestock to ensure that such livestock is organically produced. 

 

To fulfill their responsibilities, Board members agree to adhere to three duties as 

described in this Manual: 

• Duty of Care 

• Duty of Loyalty 

• Duty of Obedience 

Duty of Care 

The Duty of Care calls upon a member to participate in the decisions of the 

Board and to be informed as to the data relevant to such decisions. In essence, 

the Duty of Care requires that a member: 

• Be reasonably informed—It is the duty of all Board members to seek and 

study the information needed to make a reasoned decision and/or 

recommendation on all business brought before the Board. The NOP will 

provide some of that information, but other information must be developed 

from independent sources. 

7 
• Participate in decisions—Board members are bound by responsibility to be 

active participants in decision-making. Absence from a meeting is no 

protection from the responsibility for decisions made at the meeting. 

• Make decisions with the care of an ordinary prudent person in a similar 

position—The law does not expect Board members to act as super human. It 

simply requires Board members to exercise judgment of an ordinary prudent 

person who may be faced with a similar issue. 

 

Duty of Loyalty 

The Duty of Loyalty requires Board members to exercise their power in the 

interest of the public and not in their own interest or the interest of another entity 

or person. A Board member’s loyalty is to the organic community and the public 

at large. In dispatching their Duty of Loyalty, Board members must: 

• Address conflicts of interest—Board members bring to the NOSB particular 

areas of expertise based upon their personal and business interests in 

organic production and marketing. Board members may have interests in 

conflict with those of the public interests. Board members must be conscious 

of the potential for such conflicts and act with candor and care in dealing with 

such situations. Board members must abide by the NOSB conflict of interest 

policy. 

• Recognize corporate opportunity—Before a Board member votes upon an 

issue in which they have a direct financial interest, that Board member must 

disclose the transaction to the Board in sufficient detail and adequate time to 

enable the Board to act—or decline to act—in regard to such transaction. 

Duty of Obedience 

Board members are bound to obey the tenants of the laws and regulations 

governing organic production, processing and marketing. To this effect, Board 

members must: 

• Act within the requirements of the law—Board members must uphold all state 

and federal statutes, including the Federal Advisory Committee Act (FACA – 

5 U.S.C. App. 2 et seq.). 

• Follow the responsibilities of the Board as defined by the Organic Foods 

Production Act of 1990. 

• Follow the requirements specified in the NOSB Policy and Procedures 

Manual. 

 

Maintaining Professional and Ethical Standards 

As appointees of the Secretary, NOSB members must maintain high professional 

and ethical standards for the conduct of all activities within and outside of the 

NOSB. Areas of particular concern include professional conduct and conflict of 

8 
interest. 

• Professional Conduct 

o Public service is a public trust, requiring ethical principles above private 

gain. 

o NOSB members shall put forth honest effort in the performance of their 

NOSB duties. 

o NOSB members shall make no commitments or promises of any kind 

purporting to bind the Government. 

o NOSB members shall act impartially and not give preferential treatment to 

any organization or individual. 

o NOSB members, committee members and task force members shall not 

engage in a financial transaction using nonpublic information, not allow the 

improper use of nonpublic information to further his/her own private 

interest or that of another, whether through advice or recommendation, or 

allow the unauthorized disclosure of nonpublic information. 

o Nonpublic information is defined as information that the board member 

gains by reason of participation in the NOSB and that he/she knows, or 

reasonably should know, has not been made available to the general 

public. This includes information that is “routinely exempt from disclosure 

in 5 U.S.C. 552 (Freedom of Information Act) or otherwise protected from 

disclosure by statute, Executive Order or regulation; is designated as 

confidential by the agency or program; or has not actually been 

disseminated to the general public and is not authorized to be made 

available to the public upon request.” 

o NOSB members, committee members and task force members shall keep 

confidential all information identified by petitioners as confidential business 

information.

1

 

o To the maximum extent possible, NOSB members should speak with one 

voice. Although there may be disagreements within NOSB committee or 

working group sessions, once NOSB members leave the session, they 

have the responsibility to support the integrity of the process, whether or 

not they agree with the final outcome. While NOSB members retain the 

right to express minority opinions, the public airing of dissension could 

strain interpersonal relationships and create distrust and conflict among 

NOSB members. Such stresses could undermine the NOSB’s ability to 

effectively carry out its role as a governmental advisory board. 

o NOSB members with diverse backgrounds are recruited to provide 

balance to the Board. While individual NOSB members represent the 

segments of the population from which they were selected, they also 

represent the greater good of the population as a whole. 

 

9 
• Conflict of Interest 

The NOSB recognizes that members have been specifically appointed to the 

Board to provide advice and counsel to the Secretary concerning policies 

related to the development of organic standards and the creation and 

amendment of the National List. NOSB members have been appointed 

because they have professional expertise which enables them to advise the 

Secretary. This professional expertise may, at times, present an inherent 

conflict of interest. To prevent overt advocacy for direct financial gain and the 

appearance of self-interest or the appearance of wrongful activity, the NOSB 

has adopted the following conflict of interest policy. 

 

Be it resolved by the National Organic Standards Board: 

Members of the Board shall refrain from taking any official Board 

action from which that Board member is or would derive direct 

financial gain. Board members shall disclose their interest to the 

Board and the public, when they or their affiliated business stand to 

gain from a vote, which they cast in the course of Board business. 

Under certain circumstances, the Board may determine whether it 

is appropriate for the member to vote. 

That members of the Board shall refrain from promoting for 

consideration any material, process or practice for which the 

member is or would derive direct financial gain arising out of such 

Board action. The act of promoting such material, process or 

practice shall include private discussion with members of the Board 

advocating the value of the material, public discussion and/or 

written advocacy. 

A "direct financial gain" is defined as monetary consideration, 

contractual benefit or the expectation of future monetary gain to a 

Board member, including but not limited to, financial gain from a 

party who manufacture distributes or holds exclusive title to a 

formula for a material or product, process or practice. 

 

 

10 
SECTION II

 

This section provides a description of the composition the NOSB. It also 

provides a list of expectations from members and presents guidelines for 

conducting business. 

BOARD MEMBER JOB DESCRIPTIONS 

 

The National Organic Standards Board (NOSB) fulfills three important roles 

• The Board serves as the primary linkage to the organic community. In that 

regard, the Board must advise the NOP on the implementation of OFPA. 

• The Board must approve all materials which appear on the National List. 

• The Board maintains the responsibility to protect and defend the integrity of 

organic standards. 

Composition of the Board 6518 (b) 

The Board shall be composed of 15 members, of which: 

(1) four shall be individuals who own or operate an organic farming operation; 

(2) two shall be individuals who own or operate an organic handling operation; 

(3) one shall be an individual who owns or operates a retail establishment with 

significant trade in organic products; 

(4) three shall be individuals with expertise in areas of environmental protection 

and resource conservation; 

(5) three shall be individuals who represent public interest or consumer interest 

groups; 

(6) one shall be an individual with expertise in the fields of toxicology, ecology, 

or biochemistry; and 

(7) one shall be an individual who is a certifying agent as identified under 

section 2116 of OFPA. [§2119(b)] 

Additionally, the position of Executive Director of the NOSB was added in 2005 to 

facilitate contact between NOP and NOSB 

11 
BOARD MEMBER STANDARDS 

• Participate in meetings—Members must make a commitment to attend 

meetings of the Board. 

• Serve on committees, as assigned—Each member must be willing to serve 

on committees as assigned by the Chair, and to participate in the work of 

those committees. 

• Be informed about the decisions to be made—Board members are expected 

to seek and study the information needed to make a reasoned decision 

and/or recommendation on all business brought before the Board. 

• Fully disclose any conflict of interest positions—Members having any 

commercial or immediate family interest that poses a potential or perceived 

conflict of interest must disclose that conflict to the Board and abide by any 

decision of the Board in dealing with the situation. 

CONDUCTING BUSINESS 

• Quorum—As specified in OFPA, a majority of the members of the Board shall 

constitute a quorum for the purpose of conducting business. [§2119(h)] A 

majority of the members of a Committee, including the Executive Committee, 

shall constitute a quorum for the purpose of conducting business. 

• Decisive votes—As specified in OFPA, two-thirds of the votes cast at a 

meeting of the board at which a quorum is present shall be decisive of any 

motion [§2119(i)]. Following Robert’s Rules of Order, all abstentions will be 

recorded as such and will not be included as part of the total vote cast. 

Similarly, all Board members who recuse themselves due to conflicts of 

interest, or are absent, shall be recorded as such and their votes will not 

counted towards the total number of votes cast. Both abstentions and 

recusals will be considered in order to establish a quorum. 

12 
SECTION III

 

This section focuses on the responsibilities of the NOSB officers, as well as 

providing the procedures for electing officers, components of the Executive 

Committee and conducting meetings. 

 

ROLE OF THE EXECUTIVE DIRECTOR

The Executive Director (ED) of the NOSB is the operational liaison to the 

National Organic Program. The ED is an employee of the U.S. Department of 

Agriculture and works with the NOP on behalf of the Board on a standing basis. 

NOP

NOSB Executive Director

NOSB

The most important functions of the ED are outlined below: 

• Implement the policies, goals, objectives, strategic plans and 

recommendations set by the NOSB and NOP. 

• Coordinate Board and committee meetings, and manage information 

reporting and communications between Board and NOP. 

• Work as liaison with NOP staff, TAP contractors and other government 

agencies (e.g., EPA, FDA, AAFCO). 

• Coordinate the recording and maintenance of records of all Board and 

committee meetings. This includes maintaining all board archives and records 

in a manner that provides for easy access to all public information in 

cooperation with the Board Secretary. 

OFFICER RESPONSIBILITIES

 

Three principal officers – Chair, Vice Chair and Secretary – guide the Board. 

 

Chair 

The Chair is responsible to assure the integrity of the Board process, including 

effectiveness of meetings and the board’s adherence to its own rules. The Chair 

shall: 

• Schedule meetings of the Board and the Executive Committee; 

• Draft meeting agendas in consultation with committee chairs and NOP staff; 

13 
• Convene and preside at meetings; 

• Review committee work plans; and 

• Review meeting minutes for accuracy. 

 

Vice Chair 

The Vice Chair shall act in the absence of the Chair. The Vice Chair shall also be 

responsible for maintenance and upkeep of the Policy and Procedures Manual. 

 

Secretary 

The Secretary is responsible for the integrity of all legal and governing 

documents of the Board. It is the Secretary’s responsibility to: 

 • Record and maintain the official Board proceedings; 

 • Circulate draft minutes for approval of the Board; 

 • Ensure that minutes of Board actions are available to members of the 

public; and 

 • Transfer custody of the Board minutes to the Secretary’s successor. 

The Secretary may delegate tasks to others, but retains responsibility for the 

official record. 

 

ELECTION OF OFFICERS 

 

Officers shall be elected for terms of one year by majority vote at the annual fall 

meeting of the Board. Candidates may be self-nominated or nominated by 

another member of the Board. Should an officer resign or fail to serve the full 

term, the Executive Committee shall appoint an interim officer. The interim officer 

shall serve in the capacity until the next regularly scheduled meeting of the 

Board, during which an election will be held to fill the remainder of the term. 

EXECUTIVE COMMITTEE 

 

The Executive Committee of the NOSB shall be comprised of the Chair, Vice 

Chair, Secretary, and the chairs of the standing committees. The Executive 

Committee, with participation of the NOP, shall meet monthly, as needed, or as 

called by the Chair, and shall conduct business on behalf of the Board, except 

that the Executive Committee shall not take action on any recommendation to the 

Secretary, including the status of materials on the National List. 

 

14 
MEETINGS 

 

For any in-person meeting, three months’ notice should be provided. To the 

extent possible, the date, time and location of the meeting shall be set by 

consensus of the Board through E-mail or telephone communication. All E-mail 

requests should allow 48 hours to respond. For public meetings all NOSB 

members shall remain at the meeting until the adjournment time (set by agenda) 

or if the Board Chair officially adjourns the meeting. 

 

For full Board conference calls, three weeks’ notice should be given to the 

members. This will reasonably allow for each to schedule the appropriate time to 

accommodate the call. The date and time of the call will be set by a consensus 

of the Board through E-mail or telephone discussion. All E-mail requests for 

meeting times should allow for 48 hours to respond. 

 

 

 

15 
SECTION IV 

BOARD COMMITTEES

 

Committees play an important role in administering the Board’s responsibilities. 

Committees exist to provide greater depth and clarity in the Board’s responsibility 

to make informed decisions. For example, at the request of the Secretary 

seeking advice on a matter related to the NOP, the full Board may request that a 

committee conduct research and analysis or draft proposed recommendations to 

be considered by the full Board. Except for the Executive Committee, no 

committees are authorized to act in place of the Board. Committees are 

empowered to analyze information and bring draft recommendations to the Board 

for action. 

 

Committee chairs are appointed by the Board Chair. The current standing 

committees are: 

• Certification, Accreditation, and Compliance 

• Crops 

• Handling 

• Livestock 

• Materials 

• Policy Development 

The Livestock Committee, the Crops Committee and the Handling Committee will 

each have co-chairs. One co-chair will guide all committee discussion and will 

oversee the committee’s work plan. The other co-chair will be responsible for the 

committee’s consideration of materials and will serve as the liaison to the 

Materials Committee. 

 

Committee recommendations are finalized by the NOSB according to the 

following process: 

1. Committee drafts the recommendation. 

2. Draft recommendation is posted for public comment. 

3. Public comments are considered by committee when making 

recommendation to the Board. 

4. Board takes action on the recommendation. 

Board actions may include adoption of the recommendation as presented by the 

committee, amending and then adopting the recommendation, rejecting the 

recommendation, or referring the recommendation back to committee for further 

development. 

16 
 

COMMITTEE MEETINGS 

 

Committees may hold meetings via telephone conference calls. Two weeks’ 

notice should be provided in scheduling such calls. The date and time set for the 

call is a product of committee dialog regarding the most conducive schedule. 

This dialog may occur on a previous conference call or through E-mail. All E-mail 

requests for meeting times should allow 48 hours to respond. 

 

Emergency calls may be scheduled with less notice only after each member is 

contacted to reach a consensus on time and date of the meeting. If the members 

do not respond to E-mail requests, the chair or their designee must contact the 

member by phone. 

 

STANDING COMMITTEES 

 

Certification, Accreditation, and Compliance Committee 

The Certification, Accreditation, and Compliance Committee drafts 

recommendations for consideration by the Board concerning the applicability, 

certification, accreditation and compliance sections of the organic regulations 

[7CFR Part 205] 

Crops Committee 

The Crops Committee drafts recommendations for consideration by the Board 

concerning the crop production section of the organic regulations as contained in 

[7CFR Part 205]. The Crops Committee reviews petitions, technical advisory 

panel reports, and public comments concerning materials used for crop 

production which have been requested for addition to or removal from the 

National List. 

Livestock Committee 

The Livestock Committee drafts recommendations for consideration by the Board 

concerning the livestock and livestock feed sections of the organic regulations as 

contained in [7CFR Part 205]. The Livestock Committee reviews petitions, 

technical advisory panel reports and public comments concerning materials used 

for livestock production which have been requested for addition to or removal 

from the National List. 

17 
Materials Committee 

The Materials Committee drafts recommendations for consideration by the Board 

concerning the National List section of the organic regulations as contained in 

[7CFR Part 205] and OFPA. The Materials Committee works with the NOP, 

NOSB Committees and TAP Contractors in managing the Materials Review 

Process. In addition to a chair appointed by the Board Chair, the Materials 

Committee shall include in its membership one of the co-chairs from each of the 

Livestock, Crops, and Handling committees. Other members may be appointed 

as needed. 

Handling Committee 

The Handling Committee makes draft recommendations for consideration by the 

Board concerning the handling and labeling sections of the organic regulations 

as contained in [7CFR Part 205]. The Handling Committee reviews petitions, 

technical advisory panel reports and public comments concerning materials used 

for processing and handling which have been requested for addition to or 

removal from the National List.

Policy Development Committee 

The Policy Development Committee works with the NOP to develop priorities for 

the Board. The Policy Development Committee shall make draft 

recommendations for consideration by the Board concerning Board operations, 

policies, procedures and work plans. 

TASK FORCES 

As determined by the Board or Executive Committee, task forces shall be 

appointed to explore specific issues and present draft recommendations to the 

Board or to a committee. Task forces may include non-Board members of the 

public. Each task force shall include at least one member of the NOSB. Minutes 

shall be taken of task force meetings. Each task force shall submit a final report 

to the Board. Each task force shall be disbanded when its work has concluded or 

when the Board determines the task force is no longer necessary. 

18 
SECTION V

 

This section starts by defining the responsibilities of the different committee 

chairs and respective vice chairs. In addition, this section covers the general 

and specific collaboration procedures between NOSB and NOP. 

 

DUTIES OF COMMITTEE CHAIRS 

 

Committee chairs are responsible for the following duties: 

• Schedule committee meetings as needed. 

• Draft committee meeting agendas and work plans in consultation with 

committee members and NOP staff. 

• Convene and preside at committee meetings. 

• Ensure that minutes are taken of committee meetings. 

• Review committee meeting minutes for accuracy. 

• Report the actions of the committee to the Board. 

• Name a committee vice-chair. 

• Serve a mentor/trainer for new committee chair during transition periods 

Committee chairs shall not act unilaterally, especially concerning issues which 

involve statutory responsibilities of the Board. Committee chairs 

DUTIES OF COMMITTEE VICE-CHAIR 

 

Committee vice-chairs are responsible for the following duties: 

• Provide support in developing and completing committee work plans. 

• Represent the committee chair in the absence of the chair. 

• Vice Chairs of the Crops, Livestock and Handling Committees will serve on 

the Materials Committee as a liaison for all petitioned substances. 

Committee vice-chairs shall not act unilaterally, especially concerning issues 

which involve statutory responsibilities of the Board. 

19 
PROCEDURES FOR THE TRANSITION OF COMMITTEE CHAIRS 

In order to avoid disruption in the quality and volume of work produced by the 

NOSB, the appointment of committee chairs will follow these procedures: 

• Ideally, the Board Chair should appoint committee chairs from members with 

at least one year of NOSB experience. It is recommended that a new 

committee chair should have experience as committee vice-chair. 

• Upon appointment, new and outgoing committee chairs should have a formal 

meeting to exchange all files related to the committee’s work and to complete 

the first committee work plan. 

• New committee chairs should review all work plan items and active files 

involving committee work. 

• The outgoing committee chair should work as mentor for the new committee 

chair and vice-chair for a period of at least two months after transition. 

COMMITTEE AND BOARD PROCEDURES ON RECOMMENDATIONS 

 

Committee recommendations are developed as follows: 

1. The committee drafts a recommendation; 

2. The draft recommendation is posted for public comment; 

3. Public comments are considered by the committee when making 

recommendation to the Board; and 

4. The Board takes action on the committee recommendation. 

 

All draft recommendations must be submitted to the NOP at least thirty (30) days 

prior to the next upcoming NOSB meeting in order to be considered at that 

meeting. 

 

The Board may take the following actions based on the committee’s 

recommendation: 

1. Adopt the recommendation as presented by the committee; 

2. Amend and adopt the amended recommendation; 

3. Reject the recommendation; or 

4. Refer the recommendation back to the committee for further development. 

20 
PROCEDURES TO PRESENT COMMITTEE RECOMMENDATIONS 

NOSB committees and task forces will follow the outline presented below in order 

to present draft policy and/or material recommendations for consideration by the 

Board: 

• Introduction—A brief summary of the issue or statement of the problem. 

• Background—An explanation with sufficient detail and rationale to support a 

proposed recommendation, including reasons why the recommendation 

should be adopted, historical context, and the regulatory framework pertinent 

to the issue. 

• Recommendation—The concise text of the recommended action. 

• Committee vote—The vote of the committee or task force shall be reported. 

• Minority opinion – If applicable, the dissenting opinion(s) of committee or task 

force members shall be reported. 

NOSB AND NOP COLLABORATION PROCESS 

 

Formal Collaboration Procedures between the NOSB and the NOP 

Formal collaboration consists of an interactive relationship between the NOP and 

the NOSB in ways that ensure that NOSB input and feedback is received by the 

NOP. Further processes may be needed for the NOP for more than one means 

of collaborating with, or receiving input from, the NOSB, depending on the type of 

issues that arise and the type of action being contemplated. 

 

A single approach to collaborating and receiving input from the NOSB may not 

suffice to ensure effective program administration. This observation is based on 

the following factors: 

• The NOSB is a FACA advisory committee, and as such, must conduct 

business in the open, under the requirements of P.L. 94-409, also known as 

“Government in the Sunshine Act” (5 U.S.C.552b). 

• USDA cannot delegate its authority as a regulatory body to private citizens, 

even when those private citizens are appointed by the Secretary to provide 

advice. 

• However, the NOSB has unique statutory authority related to the 

recommendation of materials as approved or prohibited substances for 

inclusion on the National List. 

• The NOSB cannot direct USDA or bind the Secretary through its actions; for 

example, it can not obligate funds, contract, or initiate policies on its own 

accord. 

21 
General Procedures for Formal Collaboration 

1. NOP alerts NOSB of the issue and asks for input, or NOSB alerts NOP of the 

issue and formulates input. 

2. Necessary information, including the issue in writing, research, TAP reports or 

other studies shall be provided by the NOP or other organizations regarding 

the issue prior to collaborative discussion. 

3. The issue may be placed on the agenda for the next upcoming NOSB 

meeting. 

4. NOSB or NOP may ask for public comment on the issue. 

5. NOSB may make a formal recommendation to NOP on the issue. 

6. NOP acts on the recommendation (administratively addresses the issue or 

initiates rule making). 

Special Circumstances 

There are specific areas in which the formal collaborative process needs to be 

tailored or modified. Examples below include categories of communications 

between NOP and NOSB to address the specific issues accompanied by specific 

procedures to be followed: 

1. Materials proposed to be added to or removed from the National List; 

2. Standards development or modification; 

3. Standards interpretation and questions and answers submitted to the NOP; 

and 

4. Compliance and enforcement. 

 

1. Materials proposed to be added to or removed from the National List 

The NOSB has the statutory authority to consider and recommend materials 

for addition to, or deletion from, the National List of Approved and Prohibited 

Substances. Formalized procedures to facilitate the NOSB’s role in reviewing 

and approving materials for the National List include: 

o New petition procedures. 

o Formalized Decision Criteria Forms from the NOSB for providing feedback 

to NOP on their recommended decisions. 

o Sunsetting of materials every five years. 

o New Technical Advisory Panel (TAP) contractor training for TAP 

contractors to facilitate quality TAP reviews to provide essential 

information. 

o Proposed rules to amend the National List based on NOSB 

recommendations, receive and address comments, and publish the final 

rule amending the National List. 

22 
o Collaborative processes for the review of petitioned substances, including 

utilization of the Decision Tree. 

o Collaboration to determine if draft reports submitted by TAP contractors 

are sufficient (complete, relevant and understandable.) 

 

2. Standards development or modification for formal recommendation. 

NOSB initiates, through a formal recommendation to NOP, a request for the 

development of new standards or changes to existing standards. The NOSB 

will use the Decision Making Procedures as outlined on page 53 to assist in 

explaining rationale for modifying the existing standards or why new 

standards are needed. NOP will work with the NOSB to develop proposed 

regulatory language that expresses the NOSB’s desired modification. The 

NOSB should make a formal recommendation, during a public Board 

meeting, to the NOP to prompt rule making activity by the NOP. (See 

examples following this section of formal recommendations.) 

 

3. Standards interpretation and handling questions and answers submitted to 

the NOP 

In many cases, questions arise from accredited certifying agents (ACA’s) and 

others directed to the NOP about interpreting the existing standards. The 

follow procedures are to be used to handle these questions: 

o Questions submitted to the NOP will be forwarded to the NOSB 

electronically as soon as possible. 

o NOP will alert the NOSB as to how NOP would address the incoming 

question. 

o The Board will assign the appropriate committee to address the question. 

o This committee will receive necessary information from the NOP to help 

resolve the standards interpretation and questions or will be given the 

authority to conduct research. 

o Draft answers to standards interpretation or submitted questions 

developed by committees will be shared with the NOSB and the NOP. 

o The NOSB will act on the committee’s recommended response during its 

next regularly scheduled meeting. 

o If there is a significant difference between NOP and NOSB regarding the 

interpretation or answer to the incoming question, NOP will be formally 

address this at the next public Board meeting. 

o If there is not significant difference between NOP and NOSB on the 

question and answer, NOP will post the question and answer on the NOP 

web site. 

 

23 
4. Compliance and Enforcement 

Compliance and enforcement are the authority of the regulatory body, 

(NOP). However, there may be significant or sensitive issues that arise as 

a result of compliance and enforcement actions that should prompt NOP 

to alert the NOSB for further discussion. In these instances, the NOP will 

follow the General Procedures for Formal Collaboration as outlined in the 

beginning of this section. 

 

24 
FORM FOR FORMAL RECOMMENDATION 

In submitting formal recommendations to the NOP, the NOSB will utilize the 

following cover sheet to the greatest extent possible: 

 

 

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program 

 

Date _____________ 

 

Subject ______________________________________________ 

 

Chair ______________________________________________ 

 (Sign) 

 

 

Recommendation 

 

The NOSB hereby recommends to the NOP the following: 

 Rulemaking Action ____ 

 Guidance Statement ____ 

 Other ____ 

 

Statement of the Recommendation (Including Recount of Vote): 

 

 

 

 

 

 

Rationale Supporting Recommendation (including consistency with OFPA and 

NOP): 

 

 

 

Response by the NOP: 

 

25 
EXAMPLE FORM FOR FORMAL RECOMMENDATION 

 

26 
SECTION VI 

 

MISCELLANEOUS POLICIES 

 

NOSB Policy for Presenters Invited by Committees 

 

1. Need for presentation established within the appropriate committee by the 

committee chairperson. 

2. The committee chairperson should notify the NOSB Chair with a request to 

issue an invitation at least 45 days prior to meeting. Exceptions are at the 

discretion of the NOSB Chair. 

3. Presenter(s) must be invited by committee chair and/or NOSB Chair and 

approved by the NOSB Chair. 

4. Reason(s) for presentation, subject area and bio/resume of presenter(s) to be 

circulated via email to entire board at least 2 weeks prior to meeting. 

5. Invited presenter(s) must provide objective information. 

6. Presenter(s) cannot be a petitioner on the topic under discussion. 

7. Presenter(s) must disclose any actual or perceived conflict of interest 

including information concerning who provided funding for the presentation. 

Adopted June 7, 2001 

 

NOSB Policy for Surveys Conducted on Behalf of NOSB Committees 

1. All surveys, including electronic surveys, conducted in the name of any NOSB 

Committee, must be approved by the NOSB Executive Committee before 

they are submitted for approval to USDA, which must submit for approval to 

the Office of Management and Budget (OMB); and 

2. A written report summarizing the results of the survey must be submitted to 

the full Board and the NOP as soon as possible after completion. 

Adopted October 19, 2002 

Amended March 2, 2005 

27 
NOSB Policy for Public Comment at NOSB Meetings 

1. All persons wishing to comment at NOSB meetings during public comment 

periods must sign up in advance. 

2. Persons will be called upon to speak in the order they sign up. 

3. Unless otherwise indicated by the Chair, each person will be given 5 minutes 

to speak. 

4. Persons must give their names and affiliations for the record. 

5. A person may submit a written proxy to the NOP or NOSB requesting that 

another person speak on his or her behalf. 

6. No person will be allowed to speak during the public comment period for more 

than 10 minutes. 

7. Individuals providing public comment will refrain from any personal attacks 

and from remarks that otherwise impugn the character of any individual. 

 Adopted October 19, 2002 

 Amended March 2, 2005 

28 
SECTION VII

 

NOSB PRINCIPLES OF ORGANIC PRODUCTION AND HANDLING 

 

Adopted October 17, 2001

 

1.1 Organic agriculture is an ecological production management system that 

promotes and enhances biodiversity, biological cycles, and soil biological 

activity. It emphasizes the use of management practices in preference to 

the use of off-farm inputs, taking into account that regional conditions 

require locally adapted systems. These goals are met, where possible, 

through the use of cultural, biological, and mechanical methods, as 

opposed to using synthetic materials to fulfill specific functions within the 

system. 

1.2 An organic production system is designed to: 

1.2.1 Optimize soil biological activity; 

1.2.2 Maintain long-term fertility; 

1.2.3 Minimize soil erosion; 

1.2.4 Maintain or enhance the genetic and biological diversity of the production 

system and its surroundings; 

1.2.5 Utilize production methods and breeds or varieties that are well adapted to 

the region; 

1.2.6 Recycle materials of plant and animal origin in order to return nutrients to 

the land, thus minimizing the use of non-renewable resources; 

1.2.7 Minimize pollution of soil, water, and air; and 

1.2.8 Become established on an existing farm or field through a period of 

conversion (transition), during which no prohibited materials are applied 

and an organic plan is implemented. 

1.3 The basis for organic livestock production is the development of a 

harmonious relationship between land, plants, and livestock, and respect 

for the physiological and behavioral needs of livestock. This is achieved 

by: 

1.3.1 Providing good quality organically grown feed; 

1.3.2 Maintaining appropriate stocking rates; 

1.3.3 Designing husbandry systems adapted to the species' needs; 

1.3.4 Promoting animal health and welfare while minimizing stress; and 

1.3.5 Avoiding the routine use of chemical allopathic veterinary drugs, including 

antibiotics. 

1.4 Organic handling practices are based on the following principles: 

1.4.1 Organic processors and handlers implement organic good manufacturing 

and handling practices in order to maintain the integrity and quality of 

organic products through all stages of processing, handling, transport, and 

storage; 

1.4.2 Organic products are not commingled with non-organic products, except 

when combining organic and non-organic ingredients in finished products 

which contain less than 100% organic ingredients; 

29 
1.4.3 Organic products and packaging materials used for organic products do 

not come in contact with prohibited materials; 

1.4.4 Proper records, including accurate audit trails, are kept to verify that the 

integrity of organic products is maintained; and 

1.4.5 Organic processors and handlers use practices that minimize 

environmental degradation and consumption of non-renewable resources. 

Efforts are made to reduce packaging; use recycled materials; use cultural 

and biological pest management strategies; and minimize solid, liquid, and 

airborne emissions. 

1.5 Organic production and handling systems strive to achieve agroecosystems that are ecologically, socially, and economically sustainable. 

1.6 Organic products are defined by specific production and handling 

standards that are intrinsic to the identification and labeling of such 

products. 

1.7 Organic standards require that each certified operator must complete, and 

submit for approval by a certifying agent, an organic plan detailing the 

management of the organic crop, livestock, wild harvest, processing, or 

handling system. The organic plan outlines the management practices and 

inputs that will be used by the operation to comply with organic standards. 

1.8 Organic certification is a regulatory system which allows consumers to 

identify and reward operators who meet organic standards. It allows 

consumers to be confident that organic products are produced according 

to approved management plans in accordance with organic standards. 

Certification requires informed effort on the part of producers and 

handlers, and careful vigilance with consistent, transparent decision 

making on the part of certifying agents. 

1.9 Organic production and handling operations must comply with all 

applicable local, state, and federal laws and address food safety concerns 

adequately. 

1.10 Organic certification, production, and handling systems serve to educate 

consumers regarding the source, quality, and content of organic foods and 

products. Product labels must be truthful regarding product names, claims, 

and content. 

1.11 Genetic engineering (recombinant and technology) is a synthetic process 

designed to control nature at the molecular level, with the potential for 

unforeseen consequences. As such, it is not compatible with the principles 

of organic agriculture (either production or handling). Genetically 

engineered/modified organisms (geo/gmo’s) and products produced by or 

through the use of genetic engineering are prohibited. 

1.12 Although organic standards prohibit the use of certain materials such as 

synthetic fertilizers, pesticides, and genetically engineered organisms, 

they cannot ensure that organic products are completely free of residues 

due to background levels in the environment. 

30 
NOSB GUIDANCE ON COMPATIBILITY WITH A SYSTEM OF SUSTAINABLE 

AGRICULTURE AND CONSISTENCY WITH ORGANIC FARMING AND HANDLING 

 

A significant task of the NOSB is to determine the suitability of materials for use in 

organic production and handling. Among the criteria the Board must consider, OFPA 

requires the NOSB to determine the compatibility of a material with organic practices. 

The following questions were developed by the NOSB to assist in determining the 

compatibility of materials with organic practices. 

 

In order to determine if a substance, its use, and manufacture are compatible with a 

system of sustainable agriculture and consistent with organic farming and handling, 

and in consideration of the NOSB Principles of Organic Production and Handling, the 

following factors are to be considered: 

1. Does the substance promote plant and animal health by enhancing the soil’s 

physical chemical, or biological properties? 

2. Does use of the substance encourage and enhance preventative techniques 

including cultural and biological methods for management of crop, livestock, 

and/or handling operations? 

3. Is the substance made from renewable resources? If the source of the product is 

non-renewable, are the materials used to produce the substance recyclable? Is 

the substance produced from recycled materials? Does use of the substance 

increase the efficiency of resources used by organic farms, complement the use 

of natural biological controls, or reduce the total amount of materials released 

into the environment? 

4. Does use of the substance have a positive influence on the health, natural 

behavior, and welfare of livestock? 

5. Does the substance satisfy expectations of organic consumers regarding the 

authenticity and integrity of organic products? 

6. Does the substance allow for an increase in the long-term viability of organic 

farm operations? 

7. Is there evidence that the substance is mined, manufactured, or produced 

through reliance on child labor or violations of applicable national labor 

regulations? 

8. If the substance is already on the National List, is the proposed use of the 

substance consistent with other listed uses of the substance? 

9. Is the use of the substance consistent with other substances historically allowed 

or disallowed in organic production and handling? 

10. Would approval of the substance be consistent with international organic 

regulations and guidelines, including Codex? 

11. Is there adequate information about the substance to make a reasonable 

determination on the substance's compliance with each of the other applicable 

criteria? If adequate information has not been provided, does an abundance of 

caution warrant rejection of the substance? 

12. Does use of the substance have a positive impact on biodiversity? 

Adopted April 29, 2004 - 13 yes, 0 no, 1 absent 

31 
SECTION VIII

 

PROCEDURES OF THE NOSB 

This section presents the procedures followed by the NOSB to evaluate petitions. 

First, the NOP material review process is presented. Second, a review of the 

NOSB process for selecting and reviewing the work of technical advisory panels 

is provided followed by a description needed in a formal petition. Third, the 

process for NOSB material review is provided. This section concludes by 

providing a graphical description of the sunset review process. 

NATIONAL ORGANIC PROGRAM MATERIALS REVIEW PROCESS 

 

Evaluation Procedures for Substances Petitioned for Addition or Removal from 

the National List. 

 

Phase 1: Receipt of Petition 

During this phase the National Organic Program (NOP) will: 

• Notify the petitioner via letter and/or electronic mail of receipt of the petition. 

 

Phase 2: Examination of Petition for Completeness and Eligibility 

During this phase the NOP will: 

• Determine whether the petition is complete 

• Determine if the petitioned substance is eligible for petition under the Organic 

Foods Production Act and its implementing regulations; document this review 

using the NOP-OFPA checklist. 

• Determine whether the petitioned use is approved under the statutory and 

regulatory authority of the Environmental Protection Agency (EPA) or the 

Food and Drug Administration (FDA), if applicable; 

• Identify and secure any confidential business information (CBI) designated by 

the petitioner; 

• Notify, as applicable, the petitioner via letter and/or electronic mail of 

determination of completeness and eligibility, and acknowledge the 

designation of certain information as CBI. 

• Upon determination of completeness and eligibility, the following actions will 

be taken: 

o Publish the petition on NOP website; and 

o Notify the National Organic Standards Board (NOSB) materials committee 

chairperson and the chairperson of the committee that the substance is 

being petitioned for addition or prohibition from the National List (Crops, 

Livestock or Handling). This notification will be sent via letter and/or 

electronic mail and inform the chairs that the petition is complete, provide 

32 
OFPA review and EPA/FDA determination checklist, and request 

identification of any questions the appropriate committee wishes to be 

specifically addressed in the contractor’s report. The NOSB materials 

committee, working with other applicable NOSB committees, has 21 

working days to submit any questions to the NOP. The questions 

requested by the committee should include items that need specific 

background information provided and be based on the OFPA criteria. 

o Notify the contractor of the determination of completeness and eligibility 

via letter and/or electronic mail. This letter will constitute official notice to 

the contractor to perform an evaluation of the petitioned substance. 

• Notify, as applicable, the petitioner via letter and/or electronic mail of 

determining the petition to be incomplete or ineligible. 

 

Phase 3: Evaluation by Contractor 

During this phase the contractor will: 

• Conduct activities necessary to provide responses to evaluation questions 

contained in the Statement of Work (SOW) and any additional questions 

identified by the NOSB as described above; 

• Use the evaluation report template to prepare and distribute to the NOP a 

draft evaluation report in electronic format. 

Phase 4: Sufficiency Determination 

During this phase the NOP will: 

• Submit a copy of the draft evaluation report for review to the NOSB materials 

committee and the committee that the substance is being petitioned for 

addition or prohibition from the National List (Crops, Livestock or Handling); 

• Review the draft evaluation report against the following performance criteria. 

The report will be acceptable when it: 

o Is consistent in format, level of detail and tone; 

o Is technically objective and free from opinions or conjecture; 

o Is written in a style appropriate for non-technical readers (e.g. free of 

technical jargon); 

o Is prepared using a well-defined and consistent procedure consisting of 

information gathering, information synthesis and document preparation, 

and quality assurance; 

o Is based on the best available information that can be obtained within the 

designated time frame; 

o Is thoroughly supported using literature citations; and, 

o Addresses all evaluation questions as set out in the SOW. 

 

33 
During this phase the NOSB materials committee and the committee that the 

substance is being petitioned for addition or prohibition from the National List 

(Crops, Livestock or Handling) will: 

• Review the draft evaluation report against the following performance criteria. 

The report will be acceptable when it: 

o Is consistent in format, level of detail and tone; 

o Is technically objective and free from opinions or conjecture; 

o Is written in a style appropriate for non-technical readers (e.g. free of 

technical jargon); 

o Is prepared using a well-defined and consistent procedure consisting of 

information gathering, information synthesis and document preparation, 

and quality assurance; 

o Is based on the best available information that can be obtained within the 

designated time frame; 

o Is thoroughly supported using literature citations; and, 

o Addresses all evaluation questions as set out in the SOW. 

• Notify the NOP in letter and/or electronic mail the acceptance of the report 

within 21 days of receiving the draft report. If the report is not accepted by the 

NOSB materials and the committee that the substance is being petitioned for 

addition or prohibition from the National List (Crops, Livestock or Handling), 

the committees must provide to the NOP in letter and/or electronic mail the 

specific areas of the report that were concluded to be insufficient, the 

rationale for drawing such a conclusion and the improvements to be made so 

that the document can be determined sufficient. 

• Upon concurrence by the NOP that the report is insufficient, the NOP will 

notify the contractor by letter and/or electronic mail of the areas of the report 

that are insufficient, the rationale for drawing such a conclusion and the 

improvements to be made so that the document can be determined sufficient. 

The time frame required for the completion of the changes will be determined 

through mutual agreement between the contractor and the NOP. 

Phase 5: Action by NOSB Materials Chair and the Committee that the 

Substance Is Being Petitioned for Addition or Prohibition from the National 

List (Crops, Livestock or Handling) 

During this phase the NOSB materials Chair and the committee that the 

substance is being petitioned for addition or prohibition from the National List 

(Crops, Livestock or Handling) will: 

• Convene at a mutually convenient time to review, discuss and recommend an 

action on the petitioned substance. The committee may convene a Technical 

Advisory Panel by electronic mail or conference call to provide scientific 

evaluation of the petitioned substance, as provided by OFPA 6518(k)(3). The 

NOSB materials committee or delegated committee must convene and 

recommend an action on the petitioned substance no later than 30 days 

before a scheduled meeting of the full NOSB. 

34 
During this phase the NOP will: 

• Publish the recommendation of the NOSB materials committee and the 

committee that the substance is being petitioned for addition or prohibition 

from the National List (Crops, Livestock or Handling) on the NOP website and 

request public comment on the recommendation. 

Phase 6: Action by Full NOSB 

During this phase the NOP will: 

• Set as an agenda item for the next meeting of the NOSB time sufficient to 

discuss and make a recommendation by the full NOSB on the petitioned 

substance. 

35 
TECHNICAL ADVISORY PANEL (TAP) CONTRACT PROCEDURES 

Statement of Work 

Request for Proposals to Perform Technical Advisory Panel Evaluation of 

Substances Petitioned for Inclusion on or Removal from the National Organic 

Program's National List of Allowed and Prohibited Substances. 

 

Agency Need 

See Statement of Work, 1.0 Background.

 

1. Background 

The Organic Foods Production Act of 1990 (OFPA), as amended, requires 

the Secretary of Agriculture (Secretary) to establish a National List of Allowed 

and Prohibited Substances (National List). This list identifies the synthetic 

substances that may be used, and the nonsynthetic substances that cannot 

be used, by organic production and handling operations. The OFPA 

authorizes the National Organic Standards Board (NOSB) to develop and 

forward to the Secretary a recommended Proposed National List, and 

subsequent proposed amendments to it. The OFPA provides that persons 

may petition the NOSB to evaluate a substance for inclusion on or removal 

from the National List 

The NOSB submitted a Proposed National List to the Secretary that was 

subsequently published on December 21, 2000, as part of the National 

Organic Program (NOP) final rule, 65 Fed. Reg. 80548-80684, (2000). Based 

on information supplied to the NOSB by trade associations, certification 

organizations and other organic industry sources, there are many substances 

currently used in organic production and handling that have not been 

evaluated by the NOSB for inclusion on the National List. Evaluations of these 

substances must be expedited to prevent the possible disruption of wellestablished and accepted production, handling, and processing systems. 

Section 2119 of the OFPA (7 U.S.C. 6518 (k)(3)) provides that the NOSB 

shall convene Technical Advisory Panels (TAP) to provide scientific 

evaluation of substances for inclusion on the National List. TAP evaluations 

assist the NOSB in evaluating substances being considered for addition to or 

removal from the National List. The NOP, on behalf of the NOSB, establishes 

contracts to conduct the TAP evaluations. 

 

2. Mission of USDA/AMS/NOP 

 

The mission of NOP is to establish national standards governing the 

marketing of certain agricultural products as organically produced. The NOP 

is assisted by the NOSB, which provides policy advice in carrying out the 

program, including advising the Secretary on substances for inclusion on or 

removal from the National List. 

36 
The NOSB reviews information from various sources in evaluating 

substances for inclusion on or removal from the National List. Sources include 

TAP evaluations, the Environmental Protection Agency, the Food and Drug 

Administration, the National Institute of Environmental Health Studies, and 

public comment. The NOSB submits its recommendations, along with the 

results of the required evaluation and technical advisory panel evaluation for 

each substance, to the Secretary for consideration in accordance with the 

requirements of section 2118(d) of the OFPA (7 U.S.C. 6517(d)). 

 

3. Specific Task 

The contractor(s) shall furnish technical advisory panel evaluations for crop 

production, livestock production, and processing substances submitted to the 

NOSB in response to petition notices, such as was published in the Federal 

Register on July 13, 2000, as well as other substances requiring evaluation 

as determined by the NOP. 

For crop and livestock production substances, the contractor(s) shall use the 

criteria in Section 2119 of the OFPA (7 U.S.C. 6518 (m)(l-7)). The criteria are: 

• The potential of the substance for detrimental chemical interactions with 

other materials used in organic farming systems; 

• The toxicity and mode of action of the substance and of its breakdown 

products or any contaminants, and their persistence in the environment; 

• The probability of environmental contamination during manufacture, use, 

misuse or disposal of the substance; 

• Its effects on human health; 

• The effects of the substance on biological and chemical interactions in the 

agroecosystem; 

• The alternatives to using the substance; and, 

• The compatibility of the substance with a system of sustainable 

agriculture. 

 

For processing substances, the contractor(s) shall use the criteria approved 

at the February 10, 1999, NOSB meeting. The criteria are: 

• Processing aid or adjuvant cannot be produced from a natural source and 

has no organic ingredients as substitutes; 

• Manufacture, use, and disposal do not have adverse effects on the 

environment and are done in a manner compatible with organic handling 

as described in section 6513 of the OFPA; 

• The nutritional quality of the food is maintained and the material itself or its 

breakdown products do not have adverse effects on human health as 

defined by applicable Federal regulations; 

37 
• The primary purpose is not as a preservative or used only to 

recreate/improve flavors, colors, textures, or nutritive value lost during 

processing, except in the latter case as required by law; 

• It is Generally Recognized as Safe (GRAS) by FDA when used in 

accordance with Good Manufacturing Practices (GMP) and contains no 

residues of heavy metals or other contaminants in excess of FDA 

tolerances; 

• Its use is compatible with the principles of organic handling; and, 

• There is no other way to produce a similar product without its use and it is 

used in the minimum quantity required to achieve the process. 

 

4. Minimum Skills and Experience Requirements 

Contractor(s) shall utilize qualified individuals or organizations who have 

specialized knowledge of the petitioned substances. Contractor(s) must have 

demonstrable expertise in organic production and handling or scientific 

disciplines such as veterinary medicine, chemistry, food technology, 

microbiology or toxicology. Contractor(s) must be familiar with the 

requirement for technical advisory panels described in the Organic Foods 

Production Act of 1990. 

 

5. Place of Performance 

Contractor(s) shall perform all task related activity within the United States of 

America at specific locations determined by contractor(s). During the contract 

period, the contractor(s) shall travel at contractor(s)’s expense to NOSB 

meetings for the purpose of disseminating substance review findings to the 

NOSB and general public. 

 

6. Government Furnished Equipment and Facility 

None, except that the NOP shall provide Contractor(s), on a non-routine 

basis, with substance review petitions, ancillary documents or other 

applicable information in possession of NOP. 

 

7. Compensation 

The NOP may award multiple contracts for tasks outlined in this statement of 

work. Contractor(s) shall be compensated at a firm-fixed price rate not to 

exceed $4,000.00 per substance reviewed. Total compensation shall not 

exceed $100,000.00. 

 

8. Period of Performance 

September 30, 2001 – September 30, 2002 (262 working days)(Holiday time 

off is at contractor(s)’ discretion.) 

38 
9. Scope of Performance 

Phase 1: Data Gathering and Compilation (120 days) 

Phase I is not to exceed 120 days for any one substance. During this phase 

the contractor(s) provider shall perform the following activities: 

• Characterize [the] substance(s) and identify uses and applications; 

• Determine whether [the] substance(s) are synthetic or non-synthetic (See 

7.S.C. 6502 (21) for definition of synthetic); 

• Determine [the] substance(s) chemical or biological composition and 

possible impact on human/animal health and the environment; 

• Identify [the] substance(s) relevant toxicological studies, including 

ensuring substance does not contain residues of heavy metals or other 

environmental contaminants in excess of Food and Drug Administration 

Action Level or Environmental Protection Agency tolerances; 

• Determine [the] substance(s) persistence in the environment; 

• Determine [the] substance(s) effect on soil structure and ecology; 

• Identify alternatives to the use of the substance(s); 

• Determine [the] substance(s) historical use in organic production, 

processing and handling; and 

• Determine [the] substance(s) status under OFPA and with other 

government agencies. 

Additionally, within 45 days of commencement of Phase I, the contractor(s) 

must notify the NOP in writing of any substance(s) not appropriate for 

National List evaluation. Other substances for evaluation may be substituted 

upon agreement between the NOP, the NOSB, and the contractor(s). 

 

Phase 2: Evaluation against Criteria (100 days) 

Phase II is not to exceed 100 days for any one substance. The contractor(s) 

shall engage no less than three evaluators for each substance. No current 

member of the NOSB may serve as an evaluator. Evaluators may use data 

from all relevant sources. Evaluators shall make recommendations to the 

contractor(s) as to the substance’s status as synthetic or non-synthetic and 

whether, in either case, the substance should be added to or removed from 

the National List. 

 

39 
Phase 3: Recommendation (42 days) 

Phase III is not to exceed 42 days for any one substance. Contractor(s) shall 

provide the NOP with a recommendation regarding each substance's 

suitability for inclusion on or removal from the National List. All data and 

analyses collected in Phase I and II will be forwarded to the NOP upon the 

completion of Phase III in accordance with the reporting requirements stated 

below. 

 

Evaluation Factors for Award 

The NOP may award multiple contracts for tasks outlined in this statement of 

work. Contractor(s) selection will be based on evaluation of proposals in 

accordance with the responses received to the criteria outlined in Section 4.0, 

Minimum Skills and Experience Requirements and Section 9.0, Scope of Tasks. 

Award will be made to that offeror whose combination of technical experience 

and cost represents the best value to the Government and is most advantageous 

(cost, and other factors considered), and which is within the available NOP 

resources. 

The NOP also reserves the right to reject any or all proposals received and/or 

request clarification or modification of proposals. The NOP reserves the right to 

determine a competitive range for negotiation based upon the technical and cost 

acceptability of proposals. In addition, the NOP reserves the right to award a 

contract without discussions. 

Cost evaluation will include an analysis of the total cost and cost elements (if 

applicable) to perform the required work. The total costs supplied by the offeror 

shall constitute the total firm-fixed unit price for that service or deliverable. 

Proposals that are unrealistic in terms of technical commitment, or unreasonably 

low or high in costs, will be deemed reflective of an inherent lack of technical 

competence or as indicative of a failure to comprehend the complexity involved in 

the contract requirements. Such may be grounds for rejection of the proposal. 

 

Other Evaluation Factors 

Technical proposals will be initially evaluated with respect to six (6) major factors 

for determination of the competitive range. Technical factors are listed in 

descending order of importance. The technical proposal is of greater importance 

than the cost proposal; when technical proposals are relatively equal in technical 

merit, cost will increase in importance. 

Technical Factors: 

Factor 1 Overall Technical Approach; Proposed Methodology; Demonstrated 

Understanding of the Scope of Work and the Requirements 

Factor 2 Previous Demonstrated Experience and Past Performance 

Factor 3 Quality Control 

Factor 4 Capability and Experience of Key Personnel 

40 
Factor 5 Project Management and Support Capability 

Factor 6 Reasonableness of Cost 

 

Reporting Requirements 

Progress reports are due to the NOP each 60 days after the contract award date. 

A final report is due within 60 days of the end of the contract period. The 

contractor(s) shall forward five copies of the bi-monthly progress reports and the 

final report and all deliverables to the NOP in Washington DC. Documents should 

be addressed to: Richard H. Mathews, Program Manager, National Organic 

Program, USDA-AMS-TM-NOP, 1400 Independence Avenue, S.W., Room 4008-

So., Ag Stop 0268, Washington, D.C. 20250-0200, Attention: Substance 

Evaluations. 

The narrative in the progress reports should refer back to the stated objectives 

and timeline of the original contract proposal. Beneath each objective, the 

objective's current status should be reported. Any substantive diversion from a 

stated objective, or any deviation from the proposed timeline should be 

explained. Only the activities required under the contract should be reported. At a 

minimum, the progress reports should also include the following: 

1. A short summary of the accomplishments for the reporting period; 

2. Progress on completing individual project tasks; 

3. The planned and actual schedules for task completion; 

4. Projected accomplishments for the next reporting period; and, 

5. Data on financial expenditures by task category. 

Any deliverables required under the contract should be submitted upon 

completion and addressed to: Richard H. Mathews, Program Manager, National 

Organic Program, USDA-AMS-TM-NOP, 1400 Independence Avenue, S.W., 

Room 4008-So., Ag Stop 0268, Washington, D.C. 20250-0200, Attention: 

Substance Evaluations. 

41 
INFORMATION TO BE INCLUDED IN A PETITION

 

Any person may petition to add a substance to or remove a substance from the 

National List of Allowed and prohibited Substances by submitting the information 

and following the procedures identified below. 

ITEM A

The petitioner should identify which of the following categories the substance is 

being petitioned for inclusion on or removal from the National List: 

1. Synthetic substance's allowed for use in organic crop production; 

2. Nonsynthetic substances prohibited for use in organic crop production; 

3. Synthetic substances allowed for use in organic livestock production; 

4. Nonsynthetic substances prohibited for use in organic livestock production; 

5. Nonagricultural (nonorganic) substances allowed in or on processed products 

labeled as “organic'' or “made with organic (specified ingredients)'; or 

6. Nonorganic agricultural substances not commercially available in organic 

form. 

ITEM B

The petitioner must submit the following information: 

1. The substance’s common name. 

2. The manufacturer’s name, address, and telephone number. 

3. The intended or current use of the substance such as use as a pesticide, 

animal feed additive, processing aid, nonagricultural ingredient, sanitizer, or 

disinfectant. 

4. A list of the crop, livestock, or handling activities for which the substance will 

be used. If used for crops or livestock, the substance's rate and method of 

application must be described. If used for handling (including processing), the 

substance’s mode of action must be described. 

5. The source of the substance and a detailed description of its manufacturing or 

processing procedures from the basic component(s) to the final product. 

Petitioners with concerns for confidential business information can follow the 

guidelines in the Instructions for Submitting Confidential Business Information 

(CBI) listed in #13. 

6. A summary of any available previous reviews by State or private certification 

programs or other organizations of the petitioned substance. 

7. Information regarding EPA, FDA, and State regulatory authority registrations, 

including registration numbers. 

42 
8. The Chemical Abstract Service (CAS) number or other product numbers of 

the substance and labels of products that contains the petitioned substance. 

9. The substance's physical properties and chemical mode of action including 

(a) chemical interactions with other substances, especially substances used 

in organic production; (b) toxicity and environmental persistence; (c) 

environmental impacts from its use or manufacture; (d) effects on human 

health; and, (e) effects on soil organisms, crops, or livestock. 

10. Safety information about the substance including a Material Safety Data 

Sheet (MSDS) and a substance report from the National Institute of 

Environmental Health Studies. 

11. Research information about the substance which includes comprehensive 

substance research reviews and research bibliographies, including reviews 

and bibliographies which present contrasting positions to those presented by 

the petitioner in supporting the substance's inclusion on or removal from the 

National List. 

12. A “Petition Justification Statement'' which provides justification for one of the 

following actions requested in the petition: 

o When petitioning for the inclusion of a synthetic substance on the National 

List, the petition should state why the synthetic substance is necessary for 

the production or handling of an organic product. The petition should also 

describe the nonsynthetic substances or alternative cultural methods that 

could be used in place of the petitioned synthetic substance. Additionally, 

the petition should summarize the beneficial effects to the environment, 

human health, or farm ecosystem from use of the synthetic substance that 

support the use of it instead of the use of a nonsynthetic substance or 

alternative cultural methods. 

o When petitioning for the removal of a synthetic substance from the 

National List, the petition must state why the synthetic substance is no 

longer necessary or appropriate for the production or handling of an 

organic product. 

o When petitioning for the inclusion on the National List of a nonsynthetic or 

nonagricultural substance as a prohibited substance, the petition must 

state why the nonsynthetic or nonagricultural substance should not be 

permitted in the production or handling of an organic product. 

o When petitioning for the removal from the National List of a nonsynthetic 

or nonagricultural substance as a prohibited substance, the petition must 

state why the nonsynthetic or nonagricultural substance should be 

permitted in the production or handling of an organic product. 

13. A Commercial Confidential Information Statement which describes the 

specific required information contained in the petition that is considered to be 

Confidential Business Information (CBI) or confidential commercial 

information and the basis for that determination. Petitioners should limit their 

submission of confidential information to that needed to address the areas for 

43 
o Financial or commercial information the applicant does not want disclosed 

for competitive reasons can be claimed as CBI. Applicants must submit a 

written justification to support each claim. 

o “Trade secrets'' (information relating to the production process, such as 

formulas, processes, quality control tests and data, and research 

methodology) may be claimed as CBI. This information must be (1) 

commercially valuable, (2) used in the applicant's business, and (3) 

maintained in secrecy. 

o Each page containing CBI material must have “CBI Copy'' marked in the 

upper right corner of the page. In the right margin, mark the CBI 

information with a bracket and “CBI.'' 

o The CBI-deleted copy should be a facsimile of the CBI copy, except for 

spaces occurring in the text where CBI has been deleted. Be sure that the 

CBI-deleted copy is paginated the same as the CBI copy. (The CBIdeleted copy of the application should be made from the same copy of the 

application which originally contained CBI.) Additional material 

(transitions, paraphrasing, or generic substitutions, etc.) should not be 

included in the CBI-deleted copy. 

o Each page with CBI-deletions should be marked “CBI-deleted'' at the 

upper right corner of the page. In the right margin, mark the place where 

the CBI material has been deleted with a bracket and “CBI- deleted.'' 

o If several pages are CBI-deleted, a single page designating the numbers 

of deleted pages may be substituted for blank pages. (For example, 

“pages 7 through 10 have been CBI-deleted.'') 

o All published references that appear in the CBI copy should be included in 

the reference list of the CBI-deleted copy. Published information usually 

cannot be claimed as confidential. 

National List substance evaluations conducted by the NOSB will involve a public 

and open process. No confidential information will be available for public 

inspection. 

The NOP Program Manager may request additional information from the 

petitioner following receipt of the petition. 

 

44 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: ______________________________ Substance: ___________________________ 

Committee: Crops  Livestock  Handling  Petition is for:_____________________________________________ 

___________________________________________________ on the National List § 205._________________________ 

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

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 as Organic (only for 606) Yes  No  N/A  

B. Substance Fails Criteria Category: _________ Comments: ___________________________________________________ 

___________________________________________________________________________________________________

C. Proposed Annotation (if any): _________________________________________________________________________ 

____________________________________________________________________________________________________ 

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

D. Recommended Committee Action & Vote (State Actual Motion): ______________________________________________ 

____________________________________________________________________________________________________ 

Motion by: _______________ Seconded:________________ Yes: _____ No: _____ Absent: _______ Abstain: _____ 

 

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. _____ Describe why material was rejected:___________ 

____________________________________________________________________________________________________ 

4) Substance was recommended to be deferred because _________________________________________________________ 

____________________________________________________________________________________________________ 

If follow-up needed, who will follow up _____________________________________________________________________ 

Crops Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

______________________________________ _________________________ 

 Committee Chair Date

45 
EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE 

NATIONAL LIST 

Category 1. Adverse impacts on humans or the environment? Substance ____________ 

 

Question Yes No N/A

1

Documentation

(TAP; petition; regulatory agency; other)

1. Are there adverse effects on environment 

from manufacture, use, or disposal? 

[§205.600 b.2] 

 

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3] 

 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 

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

inerts? [§6517 c (1 ) (B)(ii); 

205.601(m)2] 

 

5. Is there potential for detrimental chemical 

interaction with other materials used? 

 [§6518 m.1] 

 

6. Are there adverse biological and chemical 

interactions in agro- ecosystem? [§6518 

m.5] 

 

7. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518 m.5] 

 

8. Is there a toxic or other adverse action of 

the material or its breakdown products? 

 [§6518 m.2] 

 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

 

10. Is there any harmful effect on human 

health? [§6517 c (1)(A) (i) ; 6517 

c(2)(A)I; §6518 m.4] 

 

11. Is there an adverse effect on human 

health as defined by applicable Federal 

regulations? [205.600 b.3] 

 

12. Is the substance GRAS when used 

according to FDA’s good manufacturing 

practices? [§205.600 b.5] 

 

13. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 

b.5] 

 

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. 

46 
Category 2. Is the Substance Essential for Organic Production? Substance ___________ 

 

Question Yes No N/A

1

Documentation 

(TAP; petition; regulatory agency; other) 

1. Is there a natural source of 

the substance? 

 [§205.600 b.1] 

 

2. Is there an organic 

substitute? [§205.600 b.1] 

 

3. Is the substance essential for 

handling of organically 

produced agricultural 

products? [§205.600 b.6] 

 

4. Is there a wholly natural 

substitute product? 

 [§6517 c (1)(A)(ii)] 

 

5. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

 [§6517 c (1)(B)(iii)] 

 

6. Is there any alternative 

substances? [§6518 m.6] 

 

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

9. Is there any alternative 

substances? [§6518 m.6] 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

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. 

 

47 
Category 3. Is the substance compatible with organic production practices? 

Substance ____________________

 

Question Yes No N/A

1

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)] 

 

3. Is the substance compatible with 

a system of sustainable 

agriculture? [§6518 m.7] 

 

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3] 

 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 

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] 

 

7. Is the substance used in 

production, and does it contain 

an active synthetic ingredient in 

the following categories: 

a. copper and sulfur compounds; 

 

 

b. toxins derived from bacteria; 

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals? 

 

d. livestock parasiticides and 

medicines? 

 

 

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment cleaners? 

 

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. 

48 
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 ____________________

Question Yes No N/A

1

Documentation 

(TAP; petition; regulatory agency; other)

1. Is the comparative description 

provided as to why the nonorganic form of the material 

/substance is necessary for use 

in organic handling? 

 

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? 

 

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? 

 

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? 

 

5. Does the industry information 

provided on material / substance 

non-availability as organic, include ( 

but not limited to) the following: 

a. Regions of production (including 

factors such as climate and number 

of regions); 

 

b. Number of suppliers and amount 

produced; 

 

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; 

 

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or 

 

e. Are there other issues which may 

present a challenge to a consistent 

supply? 

 

49 
NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: 

_____________________ Substance: ___________________________ 

A. Evaluation Criteria (Documentation attached; committee recommendation attached) 

 Criteria Satisfied? 

 1. Impact on humans and environment Yes No (see B below) 

 2. Availability criteria Yes No (see B below) 

 3. Compatibility & consistency Yes 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: ____________________ Second:____________________________ 

 

Vote: 

 

 Yes: _____ 

 

 No: _____ 

 

 Abstain: _____ 

 

 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 

Synthetic Not synthetic Livestock 

Allowed1Prohibited2

Handling 

No restriction 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 

 

50 
PROCEDURES FOR THE MATERIALS REVIEW PROCESS FOR NOSB 

MEMBERS 

 

1. Upon receipt of the TAP reviews each member should read the report 

prepared by the contractor, along with the submitted petition, additional 

information and recommendations of the contracted panel of experts. 

2. Questions or clarification of the review may be answered by further review of 

the literature provided by the TAP contractor or by the Chair of the committee 

contacting the contractor directly. Questions regarding the process can be 

directed to the Chair of the Materials Committee. 

3. The materials are either directed to the processing, crops or livestock 

committee(s) depending on the specified use(s) of the material as stated in 

the petition. NOSB members assigned to those committees shall conduct a 

thorough review of the material and vote on whether it is synthetic or 

nonsynthetic and if it should be allowed or prohibited for specific use as either 

a crop, livestock or processing material. Materials may be followed by an 

annotation which restricts their use. Recommended annotations applicable to 

the material must be voted on by committee. 

4. Committee draft recommendations will be submitted to the NOP at least thirty 

(30) days prior to the next NOSB meeting where the material will be 

considered. 

5. The Chair of each committee will present the Board with the committee’s 

written votes and recommendations during the Materials Review process at 

the NOSB meeting. The recommendation should come in the form of a 

motion which must be seconded by an NOSB member to move forward. The 

process will follow Robert’s Rules of Order in which the Chair would open the 

motion for discussion. The Chair shall ask if any Board members have 

conflicts of interest. After discussion board members will vote on the motion. 

6. NOP staff will record the votes of the each NOSB member and announce 

whether or not the motion passed. 

7. If the motion fails the Board Chair asks for a new motion and the procedure is 

repeated until a final motion is passed by a 2/3 majority. 

51 
SUNSET REVIEW PROCESS 

NATIONAL LIST SUNSET REVIEW PROCESS – NOP Level 

OVERVIEW OF THE SUNSET PROCESS-STEPS COMPLETED 

• FEDERAL REGISTER NOTICE 

• RECEIPT OF PUBLIC COMMENTS 

• COMMITTEES FORWARDED RECOMMENDED SUBSTANCES 

FOR FURTHER TECHNICAL REVIEW TO NOP 

NATIONAL LIST SUNSET REVIEW PROCESS – NOSB Level 

52 
SUNSET PROCESS-IN PROGRESS 

• COMMITTEES REVIEWING SUBSTANCES UNDER SUNSET 

REVIEW 

• COMMITTEES REVIEWING PUBLIC COMMENTS 

• COMMITTEES DRAFTING RECOMMENDATIONS ON 

SUBSTANCES 

• COMMITTEES FORWARDING SUBSTANCES FOR 

ADDITIONAL TECHNICAL REVIEW BASED ON PUBLIC 

COMMENTS 

Committee substance Forms 

• Sunset Review Committee Forms 

• Name of Substance 

• National List Section, use and annotation if applicable 

• Comment (s) code number (s) 

• Status (record number of comments) 

o Renewal ( ) 

o Removal ( ) 

• Summary of comment (s) 

• Committee recommendation 

Committee Recommendations 

Committees will recommend to the full Board a determination on each substance 

for renewal, removal or deferral to seek specific technical information from the 

TAP contractors. TAP contractors shall be used to verify information provided by 

the commenters, research or seek additional information requested by the 

committee. 

 

Since sunset is defined as the reviewing of regulations to ensure the continued 

relevance and not the creation of new regulation, all substance must be renewed 

as listed. Annotations cannot be included in a recommendation during sunset 

review. If there is a need to consider changing an annotation or moving a 

material from one list to another, this may be accomplished through the existing 

procedures for petition. 

53 
Clarification for deferral 

A committee has the option of postponing, or deferring, a decision on a 

substance based on several factors including: 

• Emergence of information that had not been considered and requires more 

time on the part of the committee members to verify such information. 

• Request from the public provide more information that might affect the 

decision 

• Concern over unknown market impact. 

• Lack of information necessary to make a decision against or in favor of the 

The decision to defer should be voted by the committee and should be approved 

with a majority of votes cast and reported to the full board while in session. The 

report the Board should provide the following: 

• Reasons for deferral 

• Deferral period – Note that the Board needs to complete a vote on 

deferred materials as soon as possible. 

• Committee votes 

• Minority opinion 

Public Comment and Final NOSB Vote on Recommendations 

• Each committee will provide their recommendation to the board on each 

substance 30 days prior to the full Board meeting. The recommendation will 

be posted on the website and open to public comment. 

• NOSB Final Vote 

Rulemaking on NOSB Recommendations 

• NOP Rulemaking 

• Dockets of materials for renewal based on the assumption that deferred 

materials may take some additional time for review and a full board vote After 

each NOSB meeting, the NOP would begin rulemaking on those substances 

that were voted for renewal. The materials committee anticipates at least 

two. 

54 
National List

Sunset Review Process

 

Sunset Timeline

 

55 
Sunset Timeline

56 
 

 

 

 

APPENDICES AND RESOURCES 

57 
Appendix A - DECISION MAKING PROCEDURES FOR THE NOP 

1. Define the Problem 

a. What is the problem? 

b. Identify where we are now. 

i. State the present condition in no more than two 

sentences. 

c. Identify where we want to be. 

i. State the future objective in no more than two sentences. 

2. Analyze the Problem 

a. Why is there a problem? 

b. Is the evidence of the problem supported by credible and compelling 

facts or data? 

i. What are the facts or data used to draw an affirmative conclusion? 

c. Who does this problem affect? 

d. What is the problem's effect? 

e. In what time frame must the problem be resolved? 

f. If the problem deserves immediate attention, what other priorities must be 

adjusted to accommodate this problem? 

g. If the problem deserves immediate attention, what are the consequences 

of a delay? 

3. Develop Possible Solutions 

a. Propose ideas for possible solutions 

b. Evaluate ideas for possible solutions 

i. List pros for each possible solution 

ii. List cons for each possible solution 

c. Select a Solution 

i. Is the recommended solution legal? 

ii. Is the recommended solution practical? 

iii. Is the recommended solution supported by credible and compelling 

facts or data? 

1. What are the facts or data used to draw an affirmative conclusion? 

iv. How does the recommended solution solve the problem? 

v. How does the recommended solution meet the time frame identified in 

2(b)? 

d. Review recommended solution for unintended consequences. 

4. Develop Action Plan 

a. Develop Action Steps 

i. Identify action steps to bridge the gap between present condition and 

future objective using the recommended solution. 

b. Approve Action Plan 

c. Implement Action Plan 

 Final – 5/9/2003

58 
Appendix B - FACA FACTS 

 

1. The Federal Advisory Committee Act (FACA) (5 U.S.C. App.2) and its 

implementing regulations (41 CFR Part 101-6.10) govern the creation, 

operation, and termination of advisory committees in the Executive Branch 

of the Federal Government. The National Organic Standards Board (NOSB) 

is a Department of Agriculture (USDA) non-discretionary advisory committee 

required by the Organic Foods Production Act of 1990, as amended. 

2. Advisory committees must be chartered before they can meet or conduct 

any business. Charters must be renewed every two years or they will be 

terminated under the sunset provisions of Section 14 of the FACA, unless 

otherwise provided by law. 

3. Advisory committee meetings are required to be open to the public, with 

limited exceptions as provided for in Section 552b of title 5, United States 

Code. Meetings not subject to FACA include NOSB briefing meetings 

initiated by USDA to exchange facts and information, such as member 

orientation, and NOSB committee meetings. Such meetings are not subject 

to FACA because they are not conducted for the purpose of providing the 

USDA with NOSB advice or recommendations. 

4. Designated Federal Officials must approve all meetings and agendas, and 

attend meetings. The NOP program manager is the NOSB’s Designated 

Federal Official. 

5. Meeting notices and agendas must be published in the Federal Register to 

accommodate public participation. Although not required by FACA, the NOP 

strives to: 

a. Post a provisional agenda, on its web site, no later than 60 days before 

the meeting is scheduled to begin, 

b. Post a final agenda, on its web site, no later than 45 days before the 

meeting is scheduled to begin, and 

c. Publish notice of the meeting in the Federal Register no later than 30 

days before the meeting is scheduled to begin. 

59 
6. Detailed minutes will be kept and must contain: 

a. Date and location of the meeting, 

b. A record of the persons present, 

c. A complete and accurate description of matters discussed and 

conclusions reached, and 

d. Any advice or recommendations provided by the committee. 

7. Advisory committee documents must be available for public inspection and 

copying until the committee ceases to exist. 

8. Interested persons shall be permitted to attend, appear before, or file 

statements with any advisory committee, subject to reasonable rules or 

regulations. 

9. Additional information may be found at the FACA homepage -

http://policyworks.gov/org/main/mc 

60 
Appendix C - DUTIES OF THE DESIGNATED FEDERAL OFFICER

 

The Designated Federal Officer assigned to the National Organic Standards 

Board and its committees, under the Federal Advisory Committee Act (U.S.C. 

App.2) and its implementing regulations (41 CFR Part 101-6.10), is the National 

Organic Program’s Program Manager. The Program Manager: 

 

1. Must approve or call the meeting of the NOSB; 

2. Must approve the agenda; 

3. Must attend the meetings; 

4. Shall adjourn the meetings when such adjournment is in the public 

interest; and 

5. Chairs the meeting when directed by the Secretary of Agriculture or the 

Secretary’s designee. 

61 
Appendix D - PARLIAMENTARY PROCEDURE AT A GLANCE 

TO DO THIS YOU SAY THIS 

May you 

interrupt 

speaker?

Must you 

be 

seconded?

Is the 

motion 

debatable?

Vote 

required

Adjourn the meeting I move that we adjourn no yes no majority

Recess the meeting I move that we recess 

until... no yes no majority

Complain about 

noise, room 

temperature, etc. 

Question of privilege yes no no no vote

Suspend further 

consideration of 

something 

I move that the motion 

be laid on the table no yes no majority

End debate I move the previous 

question no yes no 2/3 vote

Postpone 

consideration of 

something 

I move we post pone 

this matter until... no yes yes majority

Have something 

studied further 

I move to refer the 

motion to the 

committee 

no yes yes majority

Amend a motion I move to amend... no yes yes majority

Introduce business (a 

primary motion) I move that... no yes yes majority

Object to procedure 

or to a personal 

affront 

Point of order yes no no

chair 

decides

Request information Point of information yes no no no vote

Ask for a vote by 

actual count to verify 

a voice vote 

I call for a division no no no no vote

Object to the 

consideration of 

some undiplomatic 

matter 

I object to the 

consideration of the 

question 

yes no no 2/3 vote

Take up a matter 

previously tabled 

I move to take from the 

table no yes no majority

Reconsider 

something already 

disposed of 

I move to reconsider... yes yes yes majority

Consider something 

vote out of its 

scheduled order 

I move we suspend the 

rules and consider... no yes no 2/3 vote

Vote on a ruling by 

the chair 

I appeal the decision of 

the chair yes yes yes majority

Table a motion - take 

matter from table 

I move to take from the 

table No Yes No majority 

Rescind motions – 

Cancel previous 

action 

I move to rescind No Yes Yes 2/3 vote 

Source: Robert’s Rules of Order

62 
Appendix E - BASIC CHEMISTRY 

 

 The science of chemistry deals with the structure of matter--material things--and 

the changes that matter undergoes. Matter can exist in any size, shape, or color. 

It is solid, liquid, or gas; living or nonliving. Chemistry seeks to identify the 

simplest parts of matter; how they are separated and purified; how they are put 

together; how they are rearranged to produce new forms of matter; and what 

energy is absorbed or released when such rearrangements are made (Matta and 

Wilbraham, 1986). A distinction should be made between chemical and physical 

changes. The OFPA and NOS definition of synthetic specifically mentions 

chemical change but not physical change. A physical property is a quality or 

condition of a substance that can be observed or measured without changing the 

substance’s composition. It can be specified without reference to any other 

substance. Other physical properties of matter include color, solubility, mass, 

odor, hardness, density, electrical conductivity, magnetism, melting point and 

boiling point. Physical properties help chemists identify substances (Matta and 

Wilbraham, 1986). When contractors are hired to technical review of substances 

for the NOSB and USDA/NOP, they typically list the physical properties of the 

substances in their review because this is the common way in which substances 

are described. 

 Physical changes may result when the temperature of a substance changes. 

Raising the temperature of a solid may turn it into a liquid (i.e., ice turns into 

water). A conversion without causing a change in the composition of the 

substance is called a physical change (Matta and Wilbraham, 1986). When ice 

undergoes the physical change of melting, this change does not change the 

nature of water. The physical properties are the same for water that has been 

frozen and melted as for water that has been converted into steam and then 

condensed (Matta and Wilbraham, 1986). Historically, the organic industry and 

the NOSB have acknowledged that physical changes do not render a substance 

synthetic. 

 However, there are some substances that have been identified where high 

temperatures during manufacturing do engender a chemical change in the 

substance. An example is mined minerals. Historically, the industry and NOSB 

has recognized that burning or excessive heating of mined mineral is considered 

to render them synthetic. Formerly, NOSB defined mined minerals as any 

naturally-occurring non-living substance derived from the earth or water. A 

mined mineral cannot have undergone molecular change through heating, 

acidification, basification or fortification with synthetic materials (NOSB Final 

Recommendation Addendum Number 25, Definitions and Interpretations, Austin, 

Texas, 1995). Therefore, heat can alter the physical properties of a substance 

and for other substances act as a catalyst in chemical reactions or change. 

 In a chemical reaction, the starting substance or substances, referred to as 

reactants, are changed into new substances or products. Chemists use an arrow 

as a shorthand form of the phrase “are changed into”; reactants products (Matta 

and Wilbraham, 1986). An example to distinguish between physical and 

chemical changes is illustrated when sulfur (a solid) is added to iron filings (a 

63 
solid). They may be separated unchanged from a mixture of the two substances 

mixed together. This separation is an example of a physical change. If the 

mixture of these two substances is heated, a chemical change takes place and 

the sulfur and iron are changed into a nonmagnetic substance, iron sulfide: Iron 

+ Sulfur Iron Sulfide (Matta and Wilbraham, 1986). A substances’ composition 

and behavior in chemical reactions--its chemical reactivity--comprise its chemical 

properties. 

 

What is a substance? 

 In chemistry, a pure substance is a homogenous material that has a definite 

chemical composition throughout. There are two kinds of pure substances. One 

kind can be decomposed into two or more different substances by simple 

chemical change; these are called compounds. There are many millions of 

compounds. 

An example of a compound is pure table salt, which can be decomposed into 

sodium and chlorine by an appropriate process. Many of the substances on the 

National Lists of Synthetic substances allowed for use in organic crop and 

livestock production (Sections 205.601 and 205.603) are compounds. Examples 

include: isopropanol, chlorine dioxide, ammonium carbonate, lime sulfur and 

copper sulfate. 

 

 The second kind of pure substances are called elements, which cannot be 

decomposed by chemical change. There are 90 natural elements; examples are 

gold, copper, oxygen, sulfur and hydrogen. Elements cannot be separated into 

simpler substances by chemical reactions. An example of an element on the 

National List is sulfur (elemental) for crop production (205.601(e)(3))( Boikess 

and Edelson, 1978). 

 

 Mixtures consist of a physical blend or two or more substances in which the 

combined substances retain their identity. Most materials found in nature are 

mixtures. Mixtures can be either homogeneous (same composition throughout) 

or heterogeneous (has non-uniform composition). A solution is a type of a 

mixture where there is a homogeneous combination of different substances. The 

difference between a heterogeneous mixture and a solution is that any sample of 

a solution has the same composition, while the composition of a mixture is not 

the same throughout. Solutions may be gaseous, liquid or solid. Examples of 

mixtures on the National List are aquatic plants and fish emulsions. The various 

compounds and elements that make up these products are within the plant, 

animal or mineral. When a particular component of the plant is desired for use in 

an agricultural input it typically has to be extracted and in many cases undergo 

additional chemical reactions to make it into a substance that is functional when 

combined with other substances. 

 

 A distinction should be drawn between a mixture and a compound. The 

elements making up a compound cannot be recovered without a chemical 

change. The substances making up a mixture or solution can. Some mixtures 

64 
can be separated into their various components by simple physical methods. An 

example is a gray-colored mixture produced by stirring together powdered yellow 

sulfur and black iron filings. The individual particles of sulfur and iron can be 

readily distinguished from one another under a microscope. The mixture is easy 

to separate because the iron filings can be removed from the mixture with a 

magnet leaving sulfur behind. Both the sulfur and the iron are unchanged in 

composition (example from Matta and Wilbraham, 1986). 

 

 The substances making up a mixture or a solution need not be elements. For 

example, one can prepare a solution by dissolving salt, a compound, in water 

another compound. In addition, the substances making up a mixture or a 

solution can be combined in varying proportions. The elements in a compound 

have fixed proportions. (paragraph found in Boikess and Edelson, 1978). Main 

groups of compounds can be classified based on similar chemical properties. 

The following are descriptions of each group (Boikess and Edelson, 1978). 

 

Salts: a compound of a metal and nonmetal, or of a metal with a negative 

polyatomic group. Compounds that have an ammonium group (NH4

+

) instead of 

a metal are also classified as salts. Some salts are NaCl, KCl, KMnO4 and 

NH

4

Cl. A salt is an ionic solid a room temperature. Most have two ionic 

components (a) a cation, which can be a polyatomic group such as ammonium or 

a monoatomic metal such as Na+

, K+, Ca

2+

 or Mn

3+

 and (b) an anion, which can 

be a negative polyatomic group or a monoatomic ion such as Cl- or NH

3

-

. A solid 

salt consists of ions in close association. When the salt dissolves in water, the 

ions are separated. Substances that exist as ions in solution are called 

electrolytes. When NaCl dissolves in water, the correct formula is Na+

 + Cl-. 

This formula treats the component ions of the salts as independent entities, 

which is approximately how they behave in water solution. Salts are called 

strong electrolytes because they usually separate completely into ions in water. 

(Boyd text) 

 

Acids: a compound that is a source of H+

 ions. An acid is usually a compound 

of hydrogen and a nonmetal or a negative polyatomic group. Unlike salts, acids 

usually are not aggregates of ions. An acid may be a gas (hydrochloric), liquid 

(sulfuric) or a solid (oxalic). Like salts, acids tend to form ions when the dissolve 

in water. When a substance separates into ions it is said to dissociate. Some 

acids dissociate completely and are called strong acids. Most acids dissociate 

only partially when dissolved in water. These are called weak acids, they are 

weak electrolytes. 

 

Bases: a compound that is a source of OH-

 ions in water solution. A compound 

of a cation and the OH- anion is a base. Bases resemble salts in many ways. 

65 
They are ionic solids that dissociate into ions when dissolved in water. Bases 

that contain a cation and OH- are generally dissociate completely in water and 

are classified as strong bases. Some strong bases are NaOH (sodium 

hydroxide) and KOH (potassium hydroxide). Compounds that do not contain 

hydroxide ions are defined as bases if they produce OH-

 ions by reaction with 

water. An example is ammonia (NH3

) which reacts with water to produce 

hydroxide ions. 

 

Nonelectrolytes: Compounds containing only nonmetals usually exist as 

discrete molecules, rather than collections of ions. These compounds do not 

dissociate into ions when they dissolve in water. Many organic compounds are 

nonelectrolytes and they will not dissolve appreciably in water i.e. oil. Some will 

dissolve in water, although they will not dissociate into ions i.e. sugar, and ethyl 

alcohol. 

 

Oxides: is a binary compound of any element with oxygen, when the oxygen 

has an oxidation number of 

-2

. Almost every element forms at least on oxide. 

The properties of oxides vary widely- depending on the element they may 

resemble a salt, acid, base or non electrolyte. 

 

What constitutes a chemical change? 

 The chemical properties of a substance are those that describe the way in which 

it can undergo change, either alone or in interactions with other substances, to 

form different materials. Such changes are called chemical reactions. The 

chemical properties that are characteristic of any substance can be describediron combines readily with oxygen to form the compound called rust. (Boikess 

and Edelson, 1978). The following are common types of chemical reactions that 

describe what is happening when different substances and compounds interact 

(Boikess and Edelson,1978). 

1. Addition or combination reaction: Two substances combine to form one: 

2Na+Cl

2

----2NaCl 

2. Decomposition reactions: One compound breaks into two or more 

compounds or elements. CaCO3

-------CaO + CO

2

 

3. Displacement reactions: Substances exchange parts. There are many 

types of these reactions but one of the most important is called metathesis 

which is the exchange of ions by two ionic compounds, with the anion of 

one compound joining the cation of the other compound and vice versa. 

AB+CD-AD + CB 

a. 1. Hydrolysis is a displacement reaction of a substance or ion with 

water. Water is a source of both H+

 and OH- ions. The OH- anion 

combines with the positive portion of the compound that is 

hydrolyzed. This positive portion may be a cation or an atom with 

a positive oxidation number. The H+

 cation combines with the 

66 
67 

negative portion of the compound, which may be an anion or an 

atom with a negative oxidation number. 

b. Acid-base reaction: an acid is a substance that can donate a 

proton, and a base is a substance that can accept a proton. 

 

 Since many materials used in organic agriculture are derived from plants and 

animals it is important to mention chemical reactions that occur in by products of 

these organisms. In living organisms, enzymes play the role in catalyzing a 

specific reaction or type of reactions. Proteins are substances extracted from 

living organisms that maybe utilized in materials that are petitioned for use in 

organic production. Proteins are sensitive to relatively small changes in pH, 

temperature, or solvent composition may cause them to denature. Denaturation 

causes physical change, the most observable result is loss of biological activity. 

Except for cleavage of disulfide bonds, denaturation stems from changes in 

secondary, tertiary, or quaternary structures through disruption of noncovalent 

interactions, such as hydrogen bonds, salt linkages and hydrophobic reactions. 

Common denaturing agents include the following: 

1. Heat--most become denatured when heated above 50-60 degrees C. 

2. Large changes in pH--adding concentrated acid or alkali to a protein in a 

aqueous solution causes changes in the charged character of ionizable 

side chains and interferes with salt linkages. 

4. Detergents--treating a protein with sodium dodecylsulfate (SDS), a 

detergent, causes the native conformation to unfold and exposes the 

nonpolar protein side chains to the aqueous environment. These side 

chains are then stabilized by hydrophobic interaction with hydrocarbon 

chains of the detergent. 

5. Organic Solvents- such as alcohols, acetone or ether. 

6. Mechanical treatment. Most globular proteins denatured in aqueous 

solution if they are stirred or shaken vigorously. 

7. Urea and guanidine hydrochloride- These substances can cause 

disruption of protein hydrogen bonding and hydrophobic interactions. 

 

Denaturation can be partial or complete. It can also be reversible or irreversible. 

Irreversible denaturation causes a fundamental change in the protein, in 

particular destroying any physiological (biological) activity. In the case of 

reversible denaturation, the change may only be temporary (Brown, 1988). 

 

References: 

 

Boikess, R.S. and Edelson, E. Chemical Principles. Harper and Row, New York, 

1978. 

Brown, W.H. Introduction to Organic Chemistry. Brooks/Cole Publishing 

Company, California, 1988. 

Matta, Michael, and Wilbraham, A.C. General, Organic and Biological 

Chemistry. Benjamin/Cummings Publishing Company, California, 1986.