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January 18, 2018

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Ruihong Guo, Ph.D.

Acting Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations (Fall 2017

Meeting)

Background

This memorandum responds to the National Organic Standards Board (NOSB) recommendations

made at its meeting in Jacksonville, Florida on October 31–November 2, 2017.

Summary of Recommendations and AMS Responses

1. Petitioned Substances and Related Recommendations. The NOSB recommended two

amendments to the National List of Allowed and Prohibited Substances (National List). This 

section of the U.S. Department of Agriculture (USDA) organic regulations includes synthetic 

substances allowed in crop and livestock production, nonsynthetic substances prohibited in crop 

and livestock production, and non-organic substances allowed in the handling of organic 

products.

Substance Section NOSB Recommendation

Sulfur Livestock: 

§ 205.603(b)

The motion to add sulfur to the 

National List, section 205.603, 

passed.

Potassium acid tartrate 

(cream of tartar)

Handling: 

§ 205.605(b) (current)

§ 205.606 (recommended)

The motion to reclassify 

potassium acid tartrate as 

agricultural (vs. nonagricultural 

as currently listed) passed. 

AMS Response: AMS is reviewing the NOSB’s recommendations to add sulfur to the National 

List for organic livestock production and to classify potassium acid tartrate as agricultural.

2. Certification Requirements for Certain Handling Operations. The NOSB passed a set of 

recommendations related to the exclusion of certain handling operations from organic 

certification (7 CFR 205.101). The NOSB recommended a revision to the current NOP Guidance 

document NOP 5031 (Certification Requirements for Handling Unpackaged Organic Products)
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

Page 2

to clarify that handlers are only excluded from the requirements of certification if they handle 

product that is both packaged and labeled. Additionally, the Board recommended that AMS 

provide training and guidance to certifiers and to certified organic handlers to support the 

integrity and traceability of organic products.

AMS Response: AMS appreciates the NOSB’s work on this topic and is reviewing the NOSB’s 

recommendation. This topic is of particular importance as AMS considers new approaches for 

maintaining the integrity of complex supply chains. 

3. Excluded Methods. The NOSB passed a recommendation to update their November 2016 

recommendation on excluded methods by adding three methods to the “Terminology Chart” in 

that recommendation. The Board voted to classify the three methods as excluded based on the 

definition of excluded methods in the USDA organic regulations and the criteria included in the

NOSB’s 2016 recommendation.

AMS Response: AMS is reviewing the NOSB’s recommendation. 

4. Aeroponic Production of Organic Crops. The NOSB passed a recommendation to prohibit 

the use of aeroponic systems for the production of organic crops. Aeroponic systems were 

described by the NOSB as systems that do not require soil or a root-zone medium. In these 

systems, the roots are suspended in midair, and the roots are regularly sprayed with water that 

contains water-soluble nutrients. 

AMS Response: AMS is reviewing the NOSB’s recommendation. 

5. Sunset Review—Recommendations for Removal. The NOSB recommended that four 

substances be removed from the National List: Vitamin B1 for crop production, oxytocin and 

procaine for livestock production, and non-organic konjac flour for handling.

The recommendations follow the Board’s completion of the sunset reviews for these substances 

that sunset on March 15, 2022. The NOSB completed their sunset review of these substances 

early to more evenly distribute the sunset review workload (see NOSB’s Fall 2016 

recommendation). The Board requested that these four substances remain on the National list 

until their sunset date of March 15, 2022 (for sunset dates see NOP 5611 National List Sunset 

Dates). 

AMS Response: AMS is reviewing the Board’s recommendations to remove Vitamin B1, 

oxytocin, procaine, and non-organic konjac flour from the National List.
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

Page 3

Substance Use 

National List Section

Action Considered by NOSB

NOSB Recommendation

Vitamin B1 Crop production

205.601(j)

The motion to remove this substance from 

the National List passed. 

The NOSB recommended removal from the 

National List as a result of its sunset review. 

Oxytocin Livestock production

205.603(a)

The motion to remove this substance from 

the National List passed. 

The NOSB recommended removal from the 

National List as a result of its sunset review. 

Procaine Livestock production

205.603(b)

The motion to remove this substance from 

the National List passed. 

The NOSB recommended removal from the 

National List as a result of its sunset review. 

Konjac flour Handling

205.606

The motion to remove this substance from 

the National List passed. 

The NOSB recommended removal from the 

National List as a result of its sunset review. 

6. Sunset Review—Not Recommended for Removal. The NOSB completed its sunset review 

of the substances in the following table. The Board did not recommend that these substances be 

removed from the National List. With the exception of biodegradable biobased mulch film 

(sunset 2019), the substances were scheduled to sunset in 2022. The NOSB completed the 

sunset reviews for these substances early, to more evenly distribute the sunset review workload 

(see NOSB’s Fall 2016 recommendation). 

AMS response: AMS is reviewing the NOSB’s sunset reviews of the National List substances 

below.

Substance Use National List 

Section

Chlorine materials (calcium

hypochlorite, chlorine dioxide, sodium 

Crop production 205.601(a)

Herbicides, soap-based Crop production 205.601(b)

Biodegradable biobased mulch film Crop production 205.601(b)

Boric acid Crop production 205.601(e)

Sticky traps/barriers Crop production 205.601(e)
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Copper sulfate Crop production 205.601(i) 

Coppers, fixed Crop production 205.601(i) 

Humic acids Crop production 205.601(j) 

Micronutrients—soluble boron products Crop production 205.601(j)

Micronutrients—sulfates, carbonates, 

oxides, or silicates of zinc, copper, iron, 

manganese, molybdenum, selenium, and 

cobalt

Crop production 205.601(j) 

Vitamins C and E Crop production 205.601(j)

Lead salts Livestock production 205.602(d)

Tobacco dust (nicotine sulfate) Livestock production 205.602(i) 

Chlorine materials (calcium 

hypochlorite, chlorine dioxide, sodium 

Livestock production 205.603(a)

Chlorhexidine Livestock production 205.603(a)

Glucose Livestock production 205.603(a)

Tolazoline Livestock production 205.603(a)

Copper sulfate Livestock production 205.603(b)

Lidocaine Livestock production 205.603(b)

Attapulgite Handling 205.605(a)

Bentonite Handling 205.605(a)

Diatomaceous earth Handling 205.605(a)

Nitrogen Handling 205.605(a)

Sodium carbonate Handling 205.605(a)

Acidified sodium chlorite Handling 205.605(a)

Carbon dioxide Handling 205.605(b)

Chlorine materials (calcium 

hypochlorite, chlorine dioxide, sodium 

Handling 205.605(b)

Magnesium chloride Handling 205.605(b)

Potassium acid tartrate Handling 205.605(b)
MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

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Sodium phosphates Handling 205.605(b)

Casings Handling 205.606

Pectin (non-amidated forms only) Handling 205.606

Summary

AMS acknowledges and sincerely appreciates the many hours NOSB members provided in 

developing its recommendations. AMS supports NOSB’s vital role in representing the diversity

of the organic community and ensuring organic integrity.

AMS also thanks retiring board member Francis Thicke for his service. During the past five 

years, Francis tirelessly served the organic community, providing his deep expertise to advise the 

USDA on the implementation of the Organic Food Production Act and the USDA organic 

regulations.