FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _November 17, 2005________

Subject: __Sunset review of National List substances used in crop production_

Chair: ____Jim Riddle______________________________________

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X____ 

Guidance Statement: ________ 

Other: ___X_____ 

Statement of the Recommendation (including Recount of Vote): The NOSB voted to renew 34 

substances on section 205.601 of the National List. The NOSB voted to defer action on 12 

substances on 205.601. The NOSB voted to renew 8 substances on 205.602, with none deferred. 

Votes were taken on each subsection. A complete list of the recommendations to renew and defer 

appears below, along with the vote totals for each subsection. 

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

Statements from the Crops Committee explaining the rationale supported through NOSB action 

precede each of the recommendations presented below. A compilation of all deferred substances, 

complete with specific questions identified by the NOSB, are submitted to the NOP under 

separate cover. 

Response by the NOP:

Updated 2/25/05 
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (a): As algicides, disinfectants and sanitizer including irrigation system cleaning 

systems 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Ethanol, isopropanol, chlorine materials, hydrogen peroxide, peracetic 

acid and soap-based algicide/demossers were mentioned by commentors. No commentors 

specifically mentioned ozone. Many commentors supported while others objected to the 

continued use of chlorine-based materials, and hydrogen peroxide. Several commentors 

stated that it was inappropriate for the National List to contain either hydrogen peroxide 

or chlorine-based materials for crop production because these materials are inconsistent 

with organic principles. The Crops Committee neither agrees nor disagrees with the 

commentors concerning chlorine materials and hydrogen peroxide. The Committee is 

deferring these two materials until additional information is obtained because these 

substances may no longer be essential for organic productions and new information on 

the reactivity in the environment and quantity of residue remaining on product need to be 

considered. The Committee agrees with the commentors that alcohol (ethanol, 

isopropanol), ozone gas, and soap-based algicides/demossers should be renewed because 

their use does not negatively impact humans or the environment, is essential for organic 

production and is compatible with organic production practices. One commentor stated 

that all synthetic substances should be prohibited for use in organic production, however, 

due to the fact that the commentor did not provide any evidence on how any of those 

substances violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based upon Comments Received – 205.601(a)

The Crops Committee recommends the renewal of the following substances: 

(1) Alcohol i) Ethanol 

ii) Isopropanol 

(5) Ozone gas-for use as an irrigation system cleaner only 

(7) Soap-based algicide/demossers. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained. The materials to be deferred are: 

(2) Chlorine materials 

(i) Calcium hypochlorite 

(ii) Chlorine dioxide 

(iii) Sodium hypochlorite 

 (4) Hydrogen peroxide 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Moved: Second: 

Committee vote: 5 –0 Board vote: 13 yes, 0 no, 1 abstain 
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (b): As herbicides, weed barriers, as applicable. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, the continued listing of soap-based herbicides and mulches was mentioned. 

Most commentors supported the continued use of soap-based herbicides and mulches 

materials while several commentors indicated that paper-based mulches could be 

excluded because they were unnecessary for production. The Crops Committee agrees 

with the commentors who state the soap-based herbicides and mulches (plastic mulch and 

covers, newspaper and other recycled paper) should be renewed because their use does 

not negatively impact humans or the environment, is essential for organic production and 

is compatible with organic production practices. One commentor stated that all synthetic 

substances should be prohibited for use in organic production, however, due to the fact 

that the commentor did not provide any evidence on how any of those substances violated 

OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(b)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

 (1) Herbicides, soap-based—for use in farmstead maintenance (roadways, ditches, 

right of ways, building perimeters) and ornamental crops. 

 (2) Mulches. 

i) Newspaper or other recycled paper, without glossy or colored inks. 

ii) Plastic mulch and covers (petroleum-based other than polyvinyl 

chloride (PVC))

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained:

 None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Moved: Rose Second: Jim 

Committee vote: 5 – 0 

Board vote: 14 yes, 0 no 
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (c): As compost feedstocks 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. No comments were submitted that specifically mentioned newspaper or 

recycled paper as compost feed stock. One commentor stated that all synthetic substances 

should be prohibited for use in organic production, however, due to the fact that the 

commentor did not provide any evidence on how the materials on the National List 

violate OFPA, the Crops Committee does not agree with this commentor. Newspaper or 

other recycled paper meets the OFPA criteria. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(c)

The Crops Committee recommends renewing the following substances in this use 

category based on the submitted evaluation forms: 

As compost feedstocks 

Newspaper or other recycled paper, without glossy or colored inks. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

 None in this category 

The Crops Committee recommends not renewing the following substances: 

 None in this category 

Recommendations Based not on Comments Received –205.601(c)

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained. The materials to be deferred are: 

None in this category 

Moved: Second: 

Committee vote: 5-0 

Board vote: 14 yes, 0 no
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (d): As animal repellents 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. No comments were submitted that specifically mentioned soap, 

ammonium – for use as a large animal repellant, no contact with soil or edible potion of 

crop. The Crops Committee agrees with commentors who support the renewal of 

ammonium soaps because their use does not negatively impact humans or the 

environment, is essential for organic production and is compatible with organic 

production practices. One commentor stated that all synthetic substances should be 

prohibited for use in organic production, however, due to the fact that the commentor did 

not provide any evidence on how the materials on the National List violate OFPA, the 

Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(d)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

Soaps, ammonium—for use as a large animal repellant only, no contact with soil 

or edible portion of crop. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

 None in this category 

The Crops Committee recommends not renewing the following substances: 

 None in this category 

Recommendations Based not on Comments Received – 205.601(d)

None in this category 

Move: Jim Second: Gerry

Committee vote: 5 – 0 

Board vote: 14 yes, 0 no 
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (e): As insecticides (including acaricides or mite control). 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, the continued listing of ammonium carbonate, boric acid, elemental sulfur, lime 

sulfur, horticultural oils, soaps, sticky traps/barriers were mentioned. Many commentors 

supported the continued use of the materials in this category. The Crops Committee 

agrees with the commentors concerning the renewal of ammonium carbonate, boric acid, 

elemental sulfur, lime sulfur insecticidal soaps, and sticky traps/barriers because their use 

does not negatively impact humans or the environment, is essential for organic 

production and is compatible with organic production practices. A commentor indicated 

that horticultural oils should not be allowed because there are non-synthetic materials 

available. Committee agrees with the commentor and is recommending the review of oils, 

horticultural – narrow range oils as dormant, suffocating, and summer oils because the 

non-synthetic materials are available but the appropriateness of vegetable oils for this use 

is unknown. One commentor stated that all synthetic substances should be prohibited for 

use in organic production, however, due to the fact that the commentor did not provide 

any evidence on how the materials on the National List violate OFPA, the Crops 

Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(e)

The Crops Committee recommends the renewal of the following substances 

(1) Ammonium carbonate—for use as bait in insect traps only, no direct contact 

with crop or soil. 

(2) Boric acid—structural pest control, no direct contact with organic food or 

crops. 

(4) Elemental sulfur. 

(5) Lime sulfur—including calcium polysulfide. 

(7) Soaps, insecticidal. 

(8) Sticky traps/barriers. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

(6) Oils, horticultural—narrow range oils as dormant, suffocating, and summer 

oils. 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(e)

 None in this category 

Move: Jim Second: Rose 

Committee vote: 5 – 0 Board vote: 13 yes, 0 no, 1 absent
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (f): As insect management. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, all supported continued listing of pheromones. The Crops Committee agrees 

with the commentors supporting the renewal of pheromones because their use does not 

negatively impact humans, or the environment, is essential for organic production and is 

compatible with organic production practices. One commentor stated that all synthetic 

substances should be prohibited for use in organic production, however, due to the fact 

that the commentor provide any evidence on how any of those substances violated OFPA, 

the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(f)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

Pheromones. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(f)

None in this category 

Move: Jim Second: Gerry 

Committee vote: 5 - 0 

Board vote: 13 yes, 0 no, 1 absent
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (g): As rodenticides. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, they all supported continued listing of sulfur dioxide – underground rodent 

control only (smoke bombs) and Vitamin D3. The Crops Committee agrees with the 

commentors supporting the renewal of sulfur dioxide and vitamin D3 because their use 

does not negatively impact humans or the environment, is essential for organic 

production and is compatible with organic production practices. One commentor stated 

that all synthetic substances should be prohibited for use in organic production, however, 

due to the fact that the commentor did not provide any evidence on how any of those 

substances violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(g)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

(1) Sulfur dioxide—underground rodent control only (smoke bombs). 

(2) Vitamin D3. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(g)

None in this category 

Move: Gerry Second: Rose 

Committee vote: 5 – 0 

Board vote: 14 yes, 0 no
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (h): As slug or snail bait. 

III. Committee Summary: No items are in this category. No comments were made 

specific to this category. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(h)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

 None in this category 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(h)

None in this category 

Move: Second: 

Committee vote: 5-0 

Board vote: No recommendation in this subsection; no vote.
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (i): As plant disease control. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, all supported the continued listing of fixed coppers, copper sulfate, hydrogen 

peroxide, lime sulfur, horticultural oils, potassium bicarbonate, elemental sulfur, 

streptomycin, tetracycline were mentioned. No comments were submitted that 

specifically mentioned peracetic acid – for use to control fire blight bacteria. The Crops 

Committee agrees with the commentors concerning the renewal of fixed coppers, copper 

sulfate, lime sulfur, peracetic acid, potassium bicarbonate and elemental sulfur because 

their use does not negatively impact humans or the environment, is essential for organic 

production and is compatible with organic production practices. A commentor indicated 

that horticultural oils should not be allowed because there are non-synthetic materials 

available. The Crops Committee agrees with the commentor and is recommending the 

review of oils, horticultural – narrow range oils as dormant, suffocating, and summer oils 

because the non-synthetic materials are available but the appropriateness of vegetable oils 

for this use is unknown. The Crops Committee neither agrees nor disagrees with the 

commentors concerning the renewal of hydrated lime, hydrogen peroxide, streptomycin 

and tetracycline. The renewal of these materials is being deferred until additional 

information can be obtained. The use of antibiotics in organic production for therapeutic 

purposes (not growth enhancement) needs to be clarified. Hydrated lime and hydrogen 

peroxide have been suggested to be inappropriate for organic production because there is 

no OFPA category that specifically allows their use. One commentor stated that all 

synthetic substances should be prohibited for use in organic production, however, due to 

the fact that the commentor did not provide any evidence on how any of those substances 

violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received - 205.601(i)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

(1) Coppers, fixed—copper hydroxide, copper oxide, copper oxychloride, includes 

products exempted from EPA tolerance, Provided, That, copper-based materials 

must be used in a manner that minimizes accumulation in the soil and shall not 

be used as herbicides. 

(2) Copper sulfate—Substance must be used in a manner that minimizes 

accumulation of copper in the soil. 

(5) Lime sulfur. 

(7) Peracetic acid—for use to control fire blight bacteria. 

(8) Potassium bicarbonate. 

(9) Elemental sulfur. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

 (6) Oils, horticultural, narrow range oils as dormant, suffocating, & summer oils. 

 
The Crops Committee recommends not renewing the following substances: 

None in this category 

Motion: Rose Second: Jim 

Committee vote: 5 – 0 

Committee vote: Recommendations based on inconsistency with OFPA in Section 

205.601(i). The crops committee recommends deferring the following materials until 

further technical information is obtained. The materials to be deferred are:

(3) Hydrated lime. 

(4) Hydrogen peroxide. 

(10) Streptomycin, for fire blight control in apples and pears only. 

(11) Tetracycline (oxytetracycline calcium complex), for fire blight control only. 

Motion: Rose Second: Jim 

Committee vote: 5 – 0 

Board vote: 10 yes, 2 no, 2 abstain
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (j): As plant or soil amendments. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who supported continued listing of substances, the 

following were specifically mentioned: aquatic plant extracts, elemental sulfur, humic 

acid, magnesium sulfate, lignin sulfonate, micronutrients (soluble boron and sulfates, 

carbonates, oxides, or silicates of zinc, copper, iron, manganese, molybdenum, selenium 

and cobalt), vitamins B1, C, and E, liquid fish products. The Crops Committee agrees 

with the commentors concerning the renewal of elemental sulfur, magnesium sulfate, 

micronutrients and vitamins B1, C, and E because their use does not negatively impact 

humans or the environment, is essential for organic production and is compatible with 

organic production practiced. A commentor agreed with the continued listing of humic 

acid but suggested an annotation for the material. The 5-year review process only allows 

for the renewal or removal of materials as they appear on the current National List. A 

change in an annotation for a substance would need to go through the formal petition 

process established by the NOP and NOSB. A commentor stated that it was inappropriate 

for lignin sulfonate to be on the National list because non-synthetic alternatives exist 

(aeration, bubblers, or other gentle agitation). Additionally, the commentor stated that if 

the material is allowed no residues should be allowed on the product. The Crops 

Committee agrees with the commentor that additional information is needed to determine 

the suitability of lignin sulfonate for organic production. Therefore this material is being 

deferred. The Committee disagrees with some commentors concerning the renewal of 

aquatic plant extracts, humic acids, and liquid fish products. and is recommending the 

deferral of these materials until additional information is obtained concerning the 

manufacturing process(es) and stabilizers and extractants for aquatic plant extracts and 

the availability of water extracted humic acid. One commentor stated that all synthetic 

substances should be prohibited for use in organic production, however, due to the fact 

that the commentor did not provide any evidence on how any of those substances violated 

OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(j)

The Crops Committee recommends the renewal of the following substances: 

(2) Elemental sulfur. 

(5) Magnesium sulfate—allowed with a documented soil deficiency. 

(6) Micronutrients—not to be used as a defoliant, herbicide, or desiccant. Those 

made from nitrates or chlorides are not allowed. Soil deficiency must be 

documented by testing. 

(i) Soluble boron products. 

(ii) Sulfates, carbonates, oxides, or silicates of zinc, copper, iron, 

manganese, molybdenum, selenium, and cobalt. 

(7) Liquid fish products—can be pH adjusted with sulfuric, citric or phosphoric 

acid. The amount of acid used shall not exceed the minimum needed to lower 

the pH to 3.5. 
(8) Vitamins, B1, C, and E. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

(4) Lignin sulfonate—chelating agent, dust suppressant, floatation agent. 

The Crops Committee recommends not renewing the following substances:: 

None in this category 

Motion: Rose Second: Jim 

Committee vote: 5 - 0 

Motion: Rose Second: Jim 

Committee vote: 5 - 0 

Recommendations Based not on Comments Received – 205.601(j)

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

(1) Aquatic plant extracts (other than hydrolyzed)—Extraction process is limited to the 

use of potassium hydroxide or sodium hydroxide; solvent amount used is limited to 

that amount necessary for extraction. 

(3) Humic acids—naturally occurring deposits, water and alkali extracts only. 

Motion: Second: 

Committee vote: 5-0 

Board vote: 12 yes, 0 no, 2 abstain
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (k): As plant growth regulators. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, all supported the continued listing for ethylene gas – for regulation of pineapple 

flowering. The Crops Committee agrees with the commentors concerning the renewal of 

ethylene gas because their use does not negatively impact humans or the environment, is 

essential for organic production and is compatible with organic production practices. One 

commentor stated that all synthetic substances should be prohibited for use in organic 

production, however, due to the fact that the commentor did not provide any evidence on 

how any of those substances violated OFPA, the Crops Committee does not agree with 

this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(k)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

Ethylene gas—for regulation of pineapple flowering. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(k)

 None in this category 

Rose: Moved Second: Jim 

Committee vote: 5 - 0 

Board vote: 12 yes, 2 no
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (l): As floating agents in postharvest handling. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, lignin sulfonate and sodium silicate – for tree fruit and fiber processing were 

mentioned. One commentor stated that sodium silicate is unnecessary and they have 

never encountered a tree fruit producer who used it or requested to use it. The 

commentor further stated that if lignin sulfonate and sodium silicate remaining on the 

National list, they should be placed under processing rather than crop production. 

Another commentor stated that lignin sulfonate should be removed from the list because 

practical alternatives exist. The Crops Committee is recommending deferral of lignin 

sulfonate and sodium silicate to obtain additional information concerning potential 

alternatives and the need for sodium silicate. One commentor stated that all synthetic 

substances should be prohibited for use in organic production, however, due to the fact 

that the commentor did not provide any evidence on how any of those substances 

violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(l)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

 None in this category 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

(1) Lignin sulfonate. 

(2) Sodium silicate—for tree fruit and fiber processing. 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(l)

 None in this category 

Motion: Second: 

Committee vote: 5-0 

Board vote: 14 yes, 0 no
I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

 (m): As synthetic inert ingredients as classified by the Environmental Protection Agency 

(EPA), for use with nonsynthetic substances or synthetic substances listed in this section 

and used as an active pesticide ingredient in accordance with any limitations on the use of 

such substances. 

III. Committee Summary: Some commentors were proponents of keeping all materials 

on list 205.601. Of those commentors who mentioned specific substances within this use 

category, the continued listing of List 4 materials was mentioned. The Crops Committee 

agrees with the commentors concerning the renewal of EPA List 4 inerts because their 

use does not negatively impact humans or the environment, is essential for organic 

production and is compatible with organic production practiced. One commentor stated 

that all synthetic substances should be prohibited for use in organic production, however, 

due to the fact that the commentor did not provide any evidence on how any of those 

substances violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.601(m)

The Crops Committee recommends the renewal of the following substances in this use 

category: 

(1) EPA List 4—Inerts of Minimal Concern. 

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

None in this category 

The Crops Committee recommends not renewing the following substances: 

None in this category 

Recommendations Based not on Comments Received – 205.601(m)

 None in this category 

Motion: Rose Second: Jim 

Committee vote: 5 – 0 

Board vote: 14 yes, 0 no
I. List: 205.602 Nonsynthetic substances prohibited for use in organic crop 

production 

II. Category Use 

The following substances may not be used in organic crop production: 

III. Committee Summary: All commentors who mentioned 205.602 were proponents 

of keeping all materials on list 205.602. Only one material [tobacco dust (nicotine 

sulfate)], and no others, was mentioned. A commentor stated that tobacco dust (nicotine 

sulfate) should be removed from the list because it is allowed by the ECC for insect 

control. The Crops Committee disagrees with the commentor and is recommending the 

renewed listing of tobacco dust (nicotine sulfate) because this material negatively impacts 

humans and the environment, is not essential for organic production and is not 

compatible with organic production practices. The Committee agrees with commentors 

and is recommending the renewed listing of ash from manure burning, arsenic, lead salts, 

sodium fluoaluminate, strychnine,and sodium nitrate–unless use is restricted to no more 

than 20% of the crop’s total nitrogen requirement; because these materials negatively 

impact humans and the environment, are not essential for organic production and are not 

compatible with organic production practices. A commentor recommended the removal 

of the annotation for sodium nitrate. The Five-year review process looks to only 

renewing or removing materials; changes in annotation need to be petitioned. The Crop 

Committee will leave the annotation unchanged.. A commentor favored the removal of 

the annotation for Potassium chloride-unless derived from a mined source and applied in 

a manner that minimizes chloride accumulation in the soil. As stated above, annotation 

changes need to be addressed through the petition process.. One commentor stated that 

all synthetic substances should be prohibited for use in organic production, however, due 

to the fact that the commentor did not provide any evidence on how any of those 

substances violated OFPA, the Crops Committee does not agree with this commentor. 

IV. Committee Recommendation(s): 

Recommendations Based on Comments Received – 205.602

The Crops Committee recommends the renewed listing of the following substances: 

(a) Ash from manure burning. 

(b) Arsenic. 

(d) Lead salts. 

(e) Potassium chloride—unless derived from a mined source and applied 

in a manner that minimizes chloride accumulation in the soil. 

(f) Sodium fluoaluminate (mined). 

(h) Strychnine. 

(g) Sodium nitrate—unless use is restricted to no more than 20% of the 

crop's total nitrogen requirement; use in spirulina production is 

unrestricted until October 21, 2005. 

(i) Tobacco dust (nicotine sulfate). 

The Crops Committee recommends not renewing the following substances: 

None in this category 
Motion: Rose Second: Jim 

Committee vote: 4 – 0; 1 abstain 

Recommendations Based not on Comments Received – 205.602

The Crops Committee recommends deferring the vote on the following materials until 

further technical information is obtained: 

 None in this category 

Motion: Second: 

Committee vote: 5-0 

Board vote: 14 yes, 0 no