Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Sunset review of silicon dioxide on National List 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X 

 

Statement of the Recommendation (Including Recount of Vote): 

Silicon dioxide is common additive in the food production and handling, where 

it is used in multiple ways, such as a flow agent, to absorb water, a foam 

suppressant, a filtration aid, and as an insect management tool. The NOSB 

recommends that silicon dioxide be renewed and relisted on 7 CFR 

§205.605(b) without annotation. The NOSB unanimously passed the motion to 

relist silicon dioxide by a vote of 14-0. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

The recommendation to re-list silicon dioxide in 7 CFR §205.605(b) was made 

in accordance with the National Organic Program and the NOSB’s Policy & 

Procedures Manual. The substance is consistent with OFPA 1990 and NOP 

regulations and evaluation criteria. 

 

NOSB Vote: 

Moved: John Foster Second: Steve DeMuri

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recusal: 0 
Sunset Recommendation – 2012 

Silicon Dioxide 

September 7, 2010

Page 2 of 3

National Organic Standards Board 

Handling Committee 

Sunset Recommendation – 2012 

Silicon Dioxide 

September 7, 2010 

List: 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in 

or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)).” 

(b) Synthetics allowed 

Silicon dioxide 

Committee Summary 

Silicon dioxide is common additive in the production of foods, where it is used primarily 

as a flow agent in powdered foods, to absorb water in hygroscopic applications, and in 

some cases used to suppress foaming in liquids under agitation. It is the primary active 

component of diatomaceous earth which has many uses ranging from filtration to insect 

control. 

In 2007 (docket TM-04-07) public comment asserting that the inclusion of silicon dioxide 

on the National List was no longer necessary due to the availability of a certified organic 

alternative substance. This comment was provided by the manufacturer of the proposed 

alternative substance. At that time and since that time, insufficient documentation has 

been provided (such as testimonials from food manufacturers using the proposed 

alternate) to demonstrate the utility of the proposed alternate in all applications where 

silicon dioxide is presently used. Several commenters supported of re-listing these 

materials prior to the April 2010 NOSB meeting. 

Review of the original recommendation, historical documents, and public comments 

does not reveal unacceptable risks to the environment, human, or animal health as a 

result of the use or manufacture of these materials. It does require special handling due 

to inhalation risks; limitations on its use and handling are governed by worker safety 

protocols and Good Manufacturing Practices. There is no new information contradicting 

the original recommendation which were the basis for the previous NOSB decisions to 

list the material. 

The Handling Committee is aware that a petition to remove silicon dioxide from the 

National list is currently in the NOP review process; the complete petition had not 

reached the Handling Committee in time to review and vote at the October 2010 NOSB 

meeting. We intend on reviewing the petition in due course. 
Sunset Recommendation – 2012 

Silicon Dioxide 

September 7, 2010

Page 3 of 3

Committee Recommendation(s) 

The handling committee recommends the renewal and inclusion of the following 

substance in this use category as published in the final rule: 

Silicon dioxide 

Committee Vote 

Motion: John Foster Second: Steve DeMuri 

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