NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: ____April 2010________ Substance: ____ Methionine (action on petitioner’s request)

______________________ _ 

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

1. Impact on Humans and Environment Yes x No  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: ____2&3_____ 

 

Comments: The Livestock Committee rejects the petitioner’s 

request on a number of levels. The pounds of MET requested 

represents the highest levels normally fed on a daily, per ton 

basis. Averaging the pounds fed over the life of the bird would 

allow even higher levels of MET to be fed at certain times, which 

is not the direction the committee wants to head. The approach 

of the MTF continues along the lines of finding a way to keep 

poultry confined yet still meet their needs for MET, rather than 

trying to find ways to adapt rations and housing to meet their 

nutritional needs. Different management practices and housing 

strategies are much preferred to purchased inputs in organic 

farming. High use levels of synthetic MET do not meet 

consumer expectations nor follow the principles of organic 

agriculture. 

 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 amend 7 CFR § 205.603(d)(1) as follows: read DL-Methionine, DL-Methionine-hydroxy analog, and DL-Methionine hydroxyl analog

calcium (CAS #-59-51-8; 63-68-3; 348-67-4)—for use only in organic poultry production until October 1, 2015, provided that the total 

amount of synthetic methionine in the diet remains below the following levels, calculated as the average pounds per ton of 100% synthetic 

methionine (MET) in the diet over the life of the bird: Laying chickens-4 pounds; broiler chickens-5 pounds; Turkeys and all other poultry-6 

pounds. 

 .

Motion: Jeff Moyer; Second: Jennifer Hall Yes: 2 No: 12 Abstain: 0 Absent: 1 

 

 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 § 205.603. Describe why material was rejected: 

Material was rejected pending upcoming recommendation from the livestock committee to amend the petitioner’s request based on information 

gathered during committee debate, public comment and industry input. 

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 

Synthetic x Not synthetic Livestock X 

Allowed1Prohibited2

Handling 

No restriction Deferred4 Rejected3

X 

E. Approved by NOSB Chair to transmit to NOP 

Chair: Daniel G. Giacomini Date: April 29, 2010 

 

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

 Return to NOSB Reason: _____________________________________________________________________________________ 

 ____________________________________________________________________________Date: _________________________ 
National Organic Standards Board 

Livestock Committee 

Synthetic Methionine Recommendation 

February 23, 2010 

I. Introduction 

The Methionine Task Force (MTF) has once again petitioned for the extension of the deadline 

for the use of Synthetic Methionine (DL-Methionine, DL-Methionine hydroxy analog, and DLMethionine hydroxyl analog calcium; hereafter referred to as MET). 

In a petition dated July 31, 2009 the MTF requested that 7CFR § 205.603(d)(1) be amended as 

follows: DL–Methionine, DL–Methionine—hydroxy analog, and DL–Methionine—hydroxy 

analog calcium (CAS #–59–51–8; 63–68–3; 348–67–4)—for use only in organic poultry 

production until October 1, 2010. 2015, provided that the total amount of synthetic 

methionine in the diet remain below the following levels, calculated as the average 

pounds per ton of 100% synthetic methionine (MET) in the diet over the life of the bird: 

Laying chickens 4 pounds 

Broiler chickens 5 pounds 

Turkeys and all other poultry 6 pounds 

II. Background 

The July 31, 2009 petitioned represents the 4th petition involving MET, which was first petitioned 

for inclusion on the National List in 2001, with a Sunset date of October 2005. The next petition 

was on January 10, 2005, which requested a continued allowance of the use of MET without a 

Sunset Date. The NOSB, at the Spring 2005 meeting, granted an extension of the Sunset Date 

to October 1, 2008. There was also a request for a variance that would allow the feeding of 

non-organic feed for methionine research purposes; that request was not approved by the 

NOSB. Another petition was received on December 14, 2007 again requesting removal of the 

Sunset Date for MET on the National List. At the Spring 2008 meeting, the NOSB rejected the 

petition request, but recommended a new Sunset Date for MET of October 1, 2010. Which 

brings us to the current petition, which was received July 31, 2009, and requests a new Sunset 

Date for MET of October 1, 2015, along with specific allowances for the use of MET in different 

avian species. 

III. Regulatory Framework 

Amino acids do not appear on the list of synthetics that may be allowed according to the 

Organic Food Production Act (OFPA) 7 USC 6517(c)(1)(B)(i): EXEMPTION FOR PROHIBITED 

SUBSTANCES IN ORGANIC PRODUCTION AND HANDLING OPERATIONS.—The National 

List may provide for the use of substances in an organic farming or handling operation that are 

otherwise prohibited under this title only if— 

(B) the substance--- 

(i) is used in production and contains an active synthetic ingredient in the 

following categories: copper and sulfur compounds; toxins derived from bacteria; 

pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicindes and productions aids including 

netting , tree wraps, and seals, insect traps, sticky barriers, row covers and 

equipment cleansers; 
IV. Discussion 

Much of the pertinent information regarding MET remains the same, but a few points are worth 

repeating: 

 -a change in management strategies and practices, along with selection for suitable 

breeds and pastured poultry production, may lessen or eliminate the need for MET 

-feed ingredients that provide natural methionine include soybeans, field peas, potato 

protein, dairy products and by-products, white corn gluten, fresh forage (pasture), insects, 

annelids, leeches, seed meals (flax, sunflower, and hemp), quinoa, alfalfa meal, earthworms, 

fish meal, kelp, crab meal, rice hull extract, pearl millet, sorghum, lobster shell meal, crab shell 

meal, oats, wheat, and barley. Although not currently allowed in organic production, organic 

bone, meat, and feather meals are excellent sources of methionine 

 -research on alternatives to MET remains incomplete, and a supply of viable alternatives 

does not presently exist 

 -the organic poultry industry claims that the use of MET remains necessary for the 

foreseeable future, and that MET is needed for maintenance, not growth or production 

maximization 

 -the organic poultry industry continues to grow faster than the supply of natural sources 

of methionine is developing 

The Livestock Committee believes that the use of MET should cease. The committee does not 

think that the petitioner’s request to amend the current annotation of Synthetic Methionine on § 

205.603(d)(1) represents the best approach to achieve this goal. 

V. Recommendation 

 

The Livestock Committee recommends that 

Material will still be on the National List, but with a new step down rate of use. The Livestock 

Committee hopes to stimulate further development and management changes in the organic 

poultry industry that will meet consumer expectations and organic principles. Along with the 

Animal Welfare Recommendation that was passed in November 2009, which will eventually 

include stocking rates for poultry, the committee believes these goals will be met. 

The Livestock Committee and the NOSB will work in collaboration with the NOP if new 

information on MET or natural methionine becomes available. 

VI. Committee vote 

Moved: Dan Giacomini Second: Jeff Moyer 

Yes – 5 No -- 0 Absent -- 3 Abstain -- 0 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __April 2010__________________ Substance: __Methionine (action on petitioner’s request)

Committee: Crops  Livestock X Handling  Petition is for:__amending the annotation for Synthetic Methionine 

on the National List § 205.603 to read DL-Methionine, DL-Mehionine-hydroxy analog, and DL-Methionine hydroxyl analog 

calcium (CAS #-59-51-8; 63-68-3; 348-67-4)—for use only in organic poultry production until October 1, 2015, provided that 

the total amount of synthetic methionine in the diet remains below the following levels, calculated as the average pounds 

per ton of 100% synthetic methionine (MET) in the diet over the life of the bird: Laying chickens-4 pounds; broiler 

chickens-5 pounds; Turkeys and all other poultry-6 pounds. 

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

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

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

6. Compatibility & Consistency Yes  No X N/A 

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

B. Substance Fails Criteria Category: _2 & 3___ Comments: _The Livestock Committee rejects the petitioner’s request on a 

number of levels. The pounds of MET requested represents the highest levels normally fed on a daily, per ton basis. 

Averaging the pounds fed over the life of the bird would allow even higher levels of MET to be fed a certain times, which is 

not the direction the committee wants to head. The approach of the MTF continues along the lines of finding a way to 

keep poultry confined yet still meet their needs for MET, rather than trying to find ways to adapt rations and housing to 

meet their nutritional needs. Different management practices and housing strategies are much preferred to purchased 

inputs in organic farming. High use levels of synthetic MET does not meet consumer expectations nor follow the 

principles of organic agriculture.

C. Proposed Annotation (if any): _____________________________________________________________________________

________________________________________________________________________________________________________ 

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

D. Recommended Committee Action & Vote (State Actual Motion): __to amend 7 CFR § 205.603(d)(1) as follows: read DLMethionine, DL-Mehionine-hydroxy analog, and DL-Methionine hydroxyl analog calcium (CAS #-59-51-8; 63-68-3; 348-67-

4)—for use only in organic poultry production until October 1, 2015, provided that the total amount of synthetic methionine 

in the diet remains below the following levels, calculated as the average pounds per ton of 100% synthetic methionine 

(MET) in the diet over the life of the bird: Laying chickens-4 pounds; broiler chickens-5 pounds; Turkeys and all other 

poultry-6 pounds.

Motion by: Dan Giacomini__ Seconded: Jeff Moyer_____ Yes: 0_____ No: 5_____ Absent: 3_______ 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 amending National List to § 205. 603__ Describe why material was rejected:_As stated 

above, the Livestock Committee does not believe the petition represents the direction the organic poultry industry should 

move. We also reject the lifetime averaging use of the substance in calculating maximum allowed use.

4) Substance was recommended to be deferred because ___________________________________________________________

__________________________ If follow-up needed, who will follow up _______________________ 

Crops Agricultural Allowed1

 

Livestock X Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

X 

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

Kevin K. Engebert_____________________ February 23, 2010_______________ 

 Committee Chair Date
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __April 2010__________________ Substance: __Methionine (Livestock Committee motion)

Committee: Crops  Livestock X Handling  Petition is for:__removal of the annotation date of October 1, 2010 for 

Synthetic Methionine on the National List § 205.603.

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

1. Impact on Humans and Environment Yes X No  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 Category: _2 & 3___ Comments:__ High use levels of synthetic MET does not meet consumer 

expectations nor follow the principles of organic agriculture. Different management practices and housing strategies are 

much preferred to purchased inputs in organic farming. Material will still be on the National List, but with a new step down 

rate of use. The Livestock Committee hopes to stimulate further development and management changes in the organic 

poultry industry that will meet consumer expectations and organic principles. Along with the Animal Welfare 

Recommendation that was passed in November 2009, which will eventually include stocking rates for poultry, the 

committee believes these goals will be met. 

C. Proposed Annotation (if any): __ to amend 7 CFR § 205.603(d)(1) as follows: DL-Methionine, DL-Methionine-hydroxy 

analog, and DL-Methionine hydroxyl analog calcium (CAS #-59-51-8; 63-68-3; 348-67-4)—for use only in organic poultry 

production until October 1, 2012, at the following maximum levels per ton of synthetic methionine in the feed ration: 

Laying chickens – 4 pounds per ton; Broiler chickens – 5 pounds per ton; and Turkeys & all other poultry – 6 pounds per 

ton. After October 1, 2012 at the following maximum levels per ton: Laying and Broiler chickens – 2 pounds per ton; and 

Turkeys and all other poultry - 3 pounds per ton.

________________________________________________________________________________________________________ 

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

To meet consumer expectations of organic poultry production, yet allow additional time for the development of natural 

alternatives to Synthetic Methionine. 

D. Recommended Committee Action & Vote (State Actual Motion): _ to amend 7 CFR § 205.603(d)(1) as follows: DLMethionine, DL-Methionine-hydroxy analog, and DL-Methionine hydroxy analog calcium (CAS #-59-51-8; 63-68-3; 348-67-

4)—for use only in organic poultry production until October 1, 2012, at the following maximum levels per ton of synthetic 

methionine in the feed ration: Laying chickens – 4 pounds per ton; Broiler chickens – 5 pounds per ton; and Turkeys & all 

other poultry – 6 pounds per ton. After October 1, 2012 the following maximum levels per ton: Laying and Broiler 

chickens – 2 pounds per ton; and Turkeys and all other poultry - 3 pounds per ton.

Motion by: Dan Giacomini__ Seconded: Jeff Moyer______ Yes: 5_____ No: 0_____ Absent: 3______ 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 amending National List to § 205. 603__ Describe why material was rejected 

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________ If follow-up needed, who will follow up __________________ 

Crops Agricultural Allowed1

 X 

Livestock X Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

Kevin K. Engebert_____________________ February 23, 2010_______________ 

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

Category 1. Adverse impacts on humans or the environment? Substance - __Methionine_________

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 

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3] 

X 

 Methionine production process listed by EPA as a hazardous 

air pollutant (40 CFR 63.184). Potential for release of toxins 

into the environment . 

TAP p. 5 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 

X 

 Substance degrades in water and neutralized by bacteria in 

water. 

TAP p. 11 

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 X 

 When fed to excess, methionine may cause deficiencies in 

other amino acids and induce toxicity, but use is well 

understood and unlikely to be misused. 

TAP p. 5 

6. Are there adverse biological and 

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

 

X 

 See 3. above 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

 

X 

 See 3. above 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2] 

 

X 

 See 3. above 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

 

X 

 See 3. above 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

 

X 

 Essential in small amounts in the human diet, and sold overthe-counter as a dietary supplement. Used in medicine. 

TAP p. 6 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

 

X 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5] 

 

X 

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

 

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 2. Is the Substance Essential for Organic Production? Substance - _______________________

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 

 May be isolated from naturally occurring sources, produced 

from genetically engineered organisms, or entirely 

synthesized by a wide number of processes. 

TAP p. 3 

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 p. 3 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

 

X 

 TAP p. 3 

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)] 

 Fish meal, kelp, crab meal, insects, earthworms, seed meals, 

dairy products and by-products, rice hull extract, pearl millet, 

sorghum, crab shell meal, lobster shell meal, white corn 

gluten, potato protein, barley, oats, wheat, flax meal, annelids, 

leeches, fresh green forage, field peas, quinoa. 

TAP & Petition various pages 

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 Ongoing research to develop feedstuffs with a higher 

concentration of methionine. Also see 7. above 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X 

 True outdoor access, alternative feeds & more diverse feed 

rations, different management and housing strategies. 

TAP & Petition various pages 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 - ____________

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 

 Violates OFPA [7 USC 6517(c)(1)(B)(i)]. Amino acids do not 

appear on the list of synthetics allowed. The use of synthetic 

substances does not follow the principles of organic 

agriculture and is not consistent with organic farming and 

handling. 

TAP pgs. 1, 4, & 14 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

 

X 

 TAP p. 1 

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 

 Sulfur. 

TAP p. 3 

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 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? 

 

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 nonavailability 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