FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _____6-3-06___________________

Subject: Sunset Review - 205.601 Synthetic substances allowed for use in organic crop 

production 

Chair: Kevin O’Rell 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: _XXXXXX_ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

See attached Recommendation for Renewal of Humic Acid as Synthetic substances allowed for 

use in organic crop production on 205.601, category use (j) as plant or soil amendments. 

NOSB Vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 11 

No – 1 

Abstain – 0 

Absent – 2 

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

NOSB Sunset Material Vote 

Response by the NOP:
NOSB- Crops Committee 

Humic Acid- Sunset Recommendation 

Final NOSB Recommendation 4/20/2006

 

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: Many commentators requested to keep humic acids on 

the National List. Two specific comments expressed concern about losing their ability 

to use water extracted humic acids in their products that they make and sell to 

growers. They were concerned that their water extracted humic acid material would 

be dropped from the List along with the alkali extracted versions. This would not be 

the case, since a true “water-extracted humic acid” from a natural source with no 

synthetic ingredients added would by definition be allowed and would not need to be 

on the List. 

The NOSB deferred the vote (Nov.2005) on humic acids- naturally occurring 

deposits, water and alkali extracts only- until further information is obtained 

concerning the availability of water extracted humic acids (a wholly natural 

substitute). A Technical Evaluation Report was provided to the NOP/NOSB in order 

to arrive at an appropriate recommendation. The Report described the manufacturing 

process of alkali extracted humic/fulvic acids as well as the uses and benefits of the 

substances. The Report gave no evidence of any harmful or adverse effects to the 

environment, agro-ecosystem, or human health. No water extracted humic acid 

materials were described in the report. Search of the scientific literature on humic 

acid and comments elicited from four separate humic acid producers suggests that 

leonardite coal (typically used to make humic acids) will not solubilize in water to 

any significant degree without adding the alkali materials for extraction purposes. 

Subsequent Crops Committee contact was made with the commentators mentioned above 

to seek more information on their water extracted product. The Colorado producer of 

water extracted humic acid explained that their product is extracted from peat. When 

asked about the humic acid content of their product, they provided analytical lab test 

results of the material. Unfortunately, the submitted lab result document did not contain 

any statement as to the humic or fulvic acid content of the material, but merely listed the 

fertilizer content (NPK, etc.). When asked about the absent data, the producer said they 

have not been testing for humic or fulvic acids but only plant food content. This producer 

further explained that the humic/fulvic acid material they extract is marketed as a blended 

component of several products that also include as ingredients other materials such as 

glucose and enzymes. The amount of the humic substance applied as a component of the 

products is typically about 3 ounces per acre. The products are intended to promote 

improved soil health through enhancement of the soil biology, but not as the soil 

amendment uses listed in the Technical Evaluation report. By comparison the typical 

crop application rates of the humic acid- alkali extracted liquids range from 1-5 gallons 

per acre for soils and 1-2 pints per acre for foliar use. 
The Crops Committee makes no statement as to the validity of this product or it’s 

benefit to organic growers. This discussion is offered in order to show that this 

particular water extracted humic/fulvic acid available to the marketplace does not 

represent a functional replacement material for the alkali extracted humic acids. 

Further comments are welcomed by the Committee as to the availability of any 

water extracted humic acids that may be functionally equivalent, wholly natural, 

substitutes for the alkali extract materials. 

IV. Committee Recommendation: 

Recommendations based on comments received- 205.601(j) 

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

use category: 

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

Motion: Jeff Moyer Second: Kevin Engelbert 

Committee vote: 3-1 Absent- Ostiguy 

NOSB vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 11 

No – 1 

Abstain – 0 

Absent – 2