NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: __November 2009___ Substance: _Peracetic Acid (expand useage) _ 

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? 

Criteria category: _1, 2, and 3__ 

 

Comments: Criteria failures all based on the 

prospect of expanding use of peracetic acid to 

unrestricted crop disease control. See attached 

companion recommendation for peracetic acid in 

hydrogen peroxide formulations. 

 C. Proposed Annotation: ______________________________________ 

___________________________________________________________ 

 

Basis for annotation: 

 

To meet criteria above: ____ Criteria: _______________ 

 

Other regulatory criteria: ____ Citation:_______________ 

D. Final Board Action & Vote (State Actual Motion): Motion is to remove the annotations from the listings for peracetic acid on the 

national List §205.601(a)(6) and §201.601(i)(7). 

Motion: _T. Ellor Second:_R. Delgado_ 

Yes: _0___ No: _13__ 

Abstain: 0__ Absent: 2 Recuse:_0__. 

 

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

that includes the evaluation criteria checklist: 

Peracetic acid, as a component of hydrogen peroxide formulations, was reclassified by the EPA from an inert ingredient to an active 

ingredient. Peracetic acid is a necessary ingredient in currently allowed formulations of hydrogen peroxide .While we are anxious to 

preserve the hydrogen peroxide tool, we reject the notion that unrestricted, expanded use of another, more potent, broad spectrum 

oxidizing agent is compatible with organic agriculture. Another recommendation was brought before the Board at the November 2009 

meeting to allow the continued use of peracetic acid in hydrogen peroxide formulations with an upper limit of 5%. That recommendation 

passed the Board and was submitted to the NOP along with this one. 

 1—substance voted to be added as “allowed” on National List on National List to § 205.______ with Annotation (if any): ____ __ 

__________________________________________________________________________________________________ _ 

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

_____________________________________________________ ___________________________________ ____ 

 

3—substance was rejected by vote for amending National List to § 205. 601(a)(6) and .601(i)(7) Describe why material was rejected: 

The petition was to drop the annotations § 205. 601(a)(6) Peracetic acid—for use in disinfecting equipment, seed, and asexually

propagated planting material and § 205.601(i)(7) Peracetic acid—for use to control fireblight. Removing the annotation would have 

resulted in the allowance of unrestricted use of this very broad spectrum oxidizing agent for all of organic crop production.__ 

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

who conducts follow-up ________________________________ ____________________________________ 

 

Agricultural Nonagricultural Crops X 

Synthetic X Not synthetic Livestock 

Allowed1Prohibited2

Handling 

No restriction Deferred4 Rejected3

X

E. Approved by NOSB Chair to transmit to NOP (Failed) 

 Jeff Moyer . November 5, 2009 . 

 Chair Date

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

 Return to NOSB Reason: ____________________________________________________________________ 

 

_____________________________________ _________________________ 

 Date 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __May 2009________ Substance: __Peracetic Acid (expand usage) ____

Committee: Crops √ Livestock  Handling  Petition is for:__To remove the annotations from the_ 

_listings for Peracetic Acid_ on the National List § 205.601(a)(6) and § 205.601(i)(7)_

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: _1,2,3__ Comments: __Criteria failures all based on the prospect of expanding use of the 

_material to un-restricted crop disease control. See attached companion recommendation for peracetic acid in hydrogen peroxide 

formulations. 

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 is to remove the annotations from the listings_ 

__for peracetic acid_on the National List §205.601(a)(6) and §205.601(i)(7)_____________ 

Motion by: _Kevin Engelbert__ 

Seconded:_Tina Ellor____ 

Yes: __0__ No: 6__ 

Absent: ___0___ 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. (a)(6) and §205.601(i)(7) Describe why material was 

rejected:__Material failed all criteria for unrestricted use on crops. See accompanying recommendation to limit concentrations in 

Hydrogen peroxide formulations.____________________________________________ 

4) Substance was recommended to be deferred because ___________________________________________________________ 

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________ 

Crops X Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

____Tina Ellor_________________ ______9-11-09________ 

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

Category 1. Adverse impacts on humans or the environment? Substance - _Peracetic Acid(expand use) 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Are there adverse effects on 

environment from manufacture, use, 

or disposal? 

[§205.600 b.2] 

X X Peracetic acid is not produced and distributed for use as a 

solitary compound. It is only encountered as a solution in twoway equilibrium with hydrogen peroxide and acetic acid. 

These reaction components of peracetic acid- hydrogen peroxide 

and acetic acid- have various production methods, including (for 

acetic acid) oxidation of acetaldehyde, hydrolysis of acetylene, or 

fermentation of plant sources. For hydrogen peroxide, the RiedlPfleiderer process uses a polycyclic aromatic hydrocarbon 

derived from coal tar along with oxygen and hydrogen gases to 

produce the material. Details of which manufacturing process is 

used for the components or the potential adverse environmental 

effects from these processes were not provided in the TAP or the 

petition. General use of the material in crops would have adverse 

effects on the soil and crop environment due to non-selective 

biocidal effects. 

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3] 

X X See question #1 for manufacturing discussion. Environmental 

contamination from use or disposal of peracetic acid/ hydrogen 

peroxide/acetic acid formulas are not likely 

since they readily biodegrade. Small amount of stabilizer (HEDP) 

added to formulations would bio-degrade to phosphate for later 

plant availability.(Envirotech- Howarth & Harvey) More detail on 

the HEDP stabilizer’s role in potential crop and/or aquatic 

environment contamination is needed to fully answer this 

question.

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X X Other than the temporary direct effects to the crop environment, 

the material would be expected to be benign in environmental 

effects, notwithstanding lack of information on effects of HEDP 

stabilizer . 

See question #6 below for harmful effects to crop environment.

4. Does the substance contain List 1, 

2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2] 

X HEDP stabilizer. 

5. Is there potential for detrimental 

chemical interaction with other 

materials used? 

[§6518 m.1] 

X Strong oxidizer which can react violently with organic matter, 

mineral oils, and acetic acid anhydride.(TAP pg.3) 

6. Are there adverse biological and 

chemical interactions in agroecosystem? [§6518 m.5] 

X Soil application of significant amounts of the material would be 

toxic to many species of soil microbes, pest and beneficial. 

Foliar applications would kill pest and beneficial leaf inhabitants 

indiscriminately. (TAP pg.4) 

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5] 

X See question 6. 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2] 

X Material is an irritant of the skin, eyes, mucous membranes, and 

respiratory tract. 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X Readily biodegradable. 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

X See question 8. 
11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

X The material is on the EPA Extremely Hazardous Substance 

list.(EPA 2000) 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5] 

 X OMRI Tech Brief 2 November 2000. It is listed on the FDA 

EAFUS list at http://vm.cfsan.fda.gov/eafus.html. (Everything 

Added to Food in the United States) 

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not 

applicable. 

Category 2. Is the Substance Essential for Organic Production? Substance - _Peracetic Acid (expand use)__

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance formulated or 

manufactured by a chemical 

process? [6502 (21)] 

X TAP page 1 of 13; ‘composition’ and ‘how made’. 

2. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring 

plant, animal, or mineral, sources? 

[6502 (21)] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

4. Is there a natural source of the 

substance? [§205.600 b.1] 

 X 

5. Is there an organic substitute? 

[§205.600 b.1] 

 X 

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 

b.6] 

 X 

 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

 X TAP page 4 of 13 #6 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

9. Are there any alternative 

substances? [§6518 m.6] 

X As plant disease control- Coppers(fixed), copper sulfate, 

hydrated lime, hydrogen peroxide, lime sulfur, oils(horticultural), 

potassium bicarbonate, and elemental sulfur. 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X Disease control practices such as: proper crop site selection, 

plant disease resistance strategies, proper variety selection, crop 

rotation, etc. 1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not 

applicable. 
Category 3. Is the substance compatible with organic production practices? Substance - _Peracetic Acid 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance compatible with 

organic handling? [§205.600 b.2] 

 X 

2. Is the substance consistent with 

organic farming and handling? 

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

X X No: It is a synthetic, non-selective oxidizing agent that would be 

antagonistic (with general crop use) to many organic farming, 

ecology based principles and practices. 

Yes: TAP page 4 of 13 #7 “Breakdown products are all part of 

the agro ecosystem” 

3. Is the substance compatible with 

a system of sustainable 

agriculture? [§6518 m.7] 

X X No: To expand usage to general plant and soil use would not be 

compatible due to extreme effects on soil and leaf surface 

ecologies. 

Yes: From the standpoint of residual environmental effects, “the 

breakdown products are all part of the natural agro ecosystem.” 

TAP page 4 of 13 #7 

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3] 

 X 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 X 

6. Is the primary use to recreate or 

improve flavors, colors, textures, or 

nutritive values lost in processing 

(except when required by law, e.g., 

vitamin D in milk)? [205.600 b.4] 

 X 

7. Is the substance used in 

production, and does it contain an 

active synthetic ingredient in the 

following categories: 

a. copper and sulfur compounds; 

 

X 

 TAP page 1 of 13 

b. toxins derived from bacteria; X TAP page 1 of 13 

c. pheromones, soaps, horticultural 

oils, fish emulsions, treated seed, 

vitamins and minerals? 

 X TAP page 1 of 13 

d. livestock parasiticides and 

medicines? 

 X 

e. production aids including netting, 

tree wraps and seals, insect traps, 

sticky barriers, row covers, and 

equipment cleaners? 

X As a disinfectant/sanitizer for equipment cleaning- NOP Rule 

§205.601(a)(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. 
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 Comments on Information Provided (sufficient, plausible, 

reasonable, thorough, complete, unknown) 

1. Is the comparative description 

provided as to why the non-organic 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 nonavailability 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?