NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP

For NOSB Meeting: 

May 2009

Substance: Propane - CAS Reg. # 74-98-6

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

1. Impact on Humans and Environment Yes  No X N/A 

 

2. Essential & Availability Criteria Yes  No X N/A 

3. Compatibility & Consistency Yes  No X N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance fails 

criteria? 

Criteria category: 1, 2, 

& 3.

Comments: see 

summary narrative 

below.

C. Proposed Annotation: NONE

___________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________

D. Final Board Action & Vote (State Actual Motion): To add Propane to the National List in section 205.605(b)

Motion: Steve DeMuri Second: Julie Weisman Yes: 0 No: 14 Abstain: 0 Absent: 1

 

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

that includes the evaluation criteria checklist:

Propane fails Category 1 by nature of it’s potential adverse effect on human health and it’s potential environmental impacts, and fails 

the “essential” component of Category 2. As a synthetic by-product of the petrochemical industry, it also fails Category 3 Compatibility 

criteria. Although propane could replace currently listed C02 as a propellant, it is not deemed essential, because consumers of organic 

cooking oils can use pump sprays without any propellant for the same result. 

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. 605(b) Describe why material was rejected: 

Substance fails Category 1 by nature of it’s potential adverse effect on human health and it’s potential environmental impacts, and fails 

the “essential” component of Category 2. As a synthetic by-product of the petrochemical industry, it also fails Category 3 Compatibility 

criteria. Although propane could replace currently listed C02 as a propellant, it is not deemed essential, because consumers of organic 

cooking oils can use pump sprays without any propellant for the same result. 

 

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 X Crops

Synthetic X Not synthetic Livestock

Allowed1Prohibited2

Handling X

No restriction Deferred4 Rejected X 3

E. Approved by NOSB Chair to transmit to NOP

Jeff Moyer 

Chair Date

May 6, 2009 .

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: Propane - CAS Reg. 74-98-6 

Committee: Crops  Livestock  Handling X Petition is for inclusion of Propane as a processing aid on the 

National List § 205.605 (b).

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

4. Impact on Humans and Environment Yes  No X N/A 

(see B below) 

5. Essential & Availability Criteria Yes  No X N/A 

6. Compatibility & Consistency Yes  No X N/A 

7. Not or Inconsistently Available as Organic Yes  No  N/A X 

B. Substance Fails Criteria Category: 1, 2, and 3. 

C. Proposed Annotation (if any): _____________________________________________________________________________

________________________________________________________________________________________________________

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

D. Recommended Committee Action & Vote (State Motion): Move to add Propane to the National List section 205.605(a).

________________________________________________________________________________________________________

 

Motion by: Steve DeMuri Seconded: Katrina Heinze Yes: 0 No: 5 Absent: 1 Abstain: 0

 

 

 

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 adding to the National List in § 205. 605(b). 

________________________________________________________________________________________________________

Substance fails Category 1 by nature of it’s 

potential adverse effect on human health and it’s potential environmental impacts, and fails the “essential” component of Category 

2. As a synthetic by-product of the petrochemical industry, it also fails Category 3 Compatibility criteria. Although propane could 

replace currently listed C02 as a propellant, it is not deemed essential, because consumers of organic cooking oils can use pump 

sprays without any propellant for the same result. 

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic X Rejected X 3

No restriction Commercially UnAvailable as Organic1

 Deferred4
E. Approved by Committee Chair to transmit to NOSB:

 

 Committee Chair Date: 

Steve DeMuri 

March 14, 2008
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

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

Question Ye

s

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 According to the Technical Evaluation Report, page 3, 

dated 2/6/09, studies have been done that show no 

significant effects on the environment from propane. 

However, the petition claims some contribution of VOC to 

the atmosphere when propane is used as a propellant, but 

30 – 40% less than is currently produced by a CO2 and 

ethyl alcohol mixture, the current propellant used for 

organic cooking sprays. In addition, this substance is a byproduct of the petrochemical industry. Due to the effects of 

exploration and drilling is destructive to the environment 

and not consistent with sustainable practices.

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3]

X Some during use, according to the petition, none mentioned 

during manufacture or disposal. 

Also, see additional paragraph above.

3. Is the substance harmful to the 

environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X See above.

4. Does the substance contain 

List 1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2]

X

5. Is there potential for detrimental 

chemical interaction with other 

materials used?[§6518 m.1]

X None indicated in the TR, or in the petition.

6. Are there adverse biological 

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

X

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? [§6518 m.2]

X Highly Flammable and explosive, can cause frostbite in 

liquid form, asphyxiant. Page 1 of the TR.

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment?[§6518 

m.2]

X Page 3 of the TR – Propane released into the environment 

dissipates rapidly.

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i) ; 

6517 c(2)(A)i; §6518 m.4]

X Page 1 of the TR describes that propane is highly 

flammable and explosive, so misuse could cause 

explosions or fire. Direct contact with the liquid may cause 

frostbite. 

Page 4 of the TR states that the substance is an 

asphyxiant., 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

X Overexposure can cause dizziness, confusion, excitation, 

and asphyxia. Page 1 or the TR.

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5]

X FDA considers propane to be GRAS as a food ingredient 

(21 CFR 184.1655 and 170.3 (0) (25)) when used in 

accordance with current Good Manufacturing Practices. 

Page 2 of the TR.

13. Does the substance contain X Page 4 or the TR states that propane may contain residues 
residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

of heavy metals and other contaminants.

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 – Propane

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 Page 2 of the TR- Propane is a constituent of natural gas 

and crude petroleum and is separated during the 

production of gasoline using fractional distillation under 

pressure. As such it is considered a synthetic substance.

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 TR Page 3 – Propane is a naturally occurring component 

of natural gas and crude oil. 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)]

X TR page 3 – Propane, along with other hydrocarbons such 

as crude oil, butane, gasoline, etc., is created by the 

decomposition of organic matter over many years. This 

decomposition, combined with heat and pressure, 

transforms the soft parts of plants and animals into solid, 

liquid, or gaseous hydrocarbons known as fossil fuels -

coal, crude oil, or natural gasPropane is isolated and 

extracted when crude oil is refined. As such it is 

considered a synthetic substance.

4. Is there a natural source of 

the substance? [§205.600 b.1]

X TR page 3 – Propane is produced by distillation from 

natural gas, or is produced as a by-product of gasoline 

production from crude oil. Both natural gas and crude oil 

are natural sources.

5. Is there an organic 

substitute? [§205.600 b.1]

X Listed substance CO2 is used as a propellant in organic 

cooking sprays currently, but there is no organic 

substitute..

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 Propane is produced form natural sources, therefore could 

be construed as natural in the conventional world. Page 3 

of the TR. 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)]

X

9. Is there any alternative 

substances? [§6518 m.6]

X Page 3 of the TR – Compressed air and nitrogen could be 

used. Petition states listed CO2 is currently used for the 

same purpose.

10. Is there another practice 

that would make the substance 

unnecessary? [§6518 m.6]

X The use of commercially available pump sprayers could 

substitute for propane propelled cooking oils. Consumers 

would add the oil of their choice to a manually pumped 

device for spraying onto cooking surfaces. 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 –

Propane

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

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

X

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

X Used as a propellant, propane has no effect on the 

nutritional quality of the food.

5. Is the primary use as a 

preservative? [§205.600 b.4]

X Substance is to be used as a propellant, not a 

preservative.

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 Substance is to be used as a propellant.

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

b. toxins derived from bacteria; X

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals?

X

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

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 agricultural substance inconsistently or not commercially available as organic? 

Substance – Propane

Question Ye

s

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?

X

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?

X

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?

X

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?

X

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);

X

b. Number of suppliers and amount 

produced;

X

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; 

X

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X
e. Are there other issues which may 

present a challenge to a consistent 

supply?

X