NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: ___November 2009____ Substance: Peracetic Acid (annotation change) 

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

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

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

3. Compatibility & Consistency Yes  No √ N/A 

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

B. Substance fails criteria? 

Criteria category: __3____ 

 Comments: The material fails criteria based on the prospect of 

expanding use of the material to un-restricted crop disease 

control use (See Category 1, #6 and Category 3, #2 & 3). The 

EPA has changed it’s regulation, whereby small concentrations 

of peracetic acid formerly allowed as an inert ingredient in 

hydrogen peroxide(HP) formulations must now be designated as 

part of the active ingredients. The Crops Committee does not 

wish to jeopardize the availability of the HP formulations currently 

used by many growers, knowing that these formulations all 

contain small, formerly allowed as inert, concentrations of 

peracetic acid. The Crops Committee recommendation pertains 

to allowing peracetic acid in hydrogen peroxide formulations, 

limited to no more than 5% concentration. 

 C. Proposed Annotation: §205.601(a)(6) Peracetic acid- for use 

in disinfecting equipment, seed, and asexually propogated planting 

material. Permitted in hydrogen peroxide formulations at 

concentration of no more than 5%. §205.601(i)(7) Peracetic acidfor use to control fireblight bacteria. Permitted in hydrogen peroxide

formulations at concentration of no more than 5%. 

Basis for annotation: 

To meet criteria above: __ Criteria: _1 and 2_______ 

 

Other regulatory criteria: ____ Citation:_______________ 

D. Final Board Action & Vote (State Actual Motion Motion is to amend the annotations from the listings for peracetic acid_on the 

National List §205.601(a)(6) and §205.601(i)(7) to add the words in each section “Permitted In hydrogen peroxide formulations at 

concentration of no more than 5%. 

Motion: _T. Ellor___ Second:_____________ 

Yes: 13__ No: __0__ 

Abstain: _0___ Absent: 0 Recuse: ___0__ 

 

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

that includes the evaluation criteria checklist: 

This recommendation intends to continue the availability of the common hydrogen peroxide formulations currently used by many 

growers, knowing that these formulations all contain small, formerly allowed as inert, concentrations of peracetic acid. Specifically, the 

recommendation pertains to allowing peracetic acid in hydrogen peroxide formulations, limited to no more than 5% concentration. See 

also recommendation presented at the November 2009 NOSB meeting to deny a petition to remove the annotations from 

§205.601(a)(6) and §205.601(i)(7) which would have resulted in the allowance of expanded usage of Peracetic acid for organic crop 

production. 

 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. ______ Describe why material was rejected: _____ _ 

___________________________________________________ __ 

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 X 

Synthetic X Not synthetic Livestock 

Allowed1

X Prohibited2

Handling 

No restriction Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP 

 Jeff Moyer . November 5, 2009 . 

 Chair Date 

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: __Nov 2009________ Substance: __Peracetic Acid (annotation change) 

Committee: Crops √ Livestock  Handling  Petition is for: To amend the annotation on the 

_listings for Peracetic Acid_ on the National List § 205.601(a)(6) and § 205.601(i)(7)_

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

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

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

3. Compatibility & Consistency Yes  No √ N/A 

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

B. Substance Fails Criteria Category: _3__ Comments: __The material fails criteria based on the prospect of expanding use of 

the material to un-restricted crop disease control use (See Category 1, #6 and Category 3, #2 & 3). The EPA has changed it’s 

regulation, whereby small concentrations of peracetic acid formerly allowed as an inert ingredient in hydrogen peroxide(HP) 

formulations must now be designated as part of the active ingredients. The Crops Committee does not wish to jeopardize the 

availability of the HP formulations currently used by many growers, knowing that these formulations all contain small, formerly 

allowed as inert, concentrations of peracetic acid. The Crops Committee recommendation pertains to allowing peracetic acid in 

hydrogen peroxide formulations, limited to no more than 5% concentration. 

Proposed Annotation (if any): §205.601(a)(6) Peracetic acid- for use in disinfecting equipment, seed, and asexually 

propogated planting material. Permitted in hydrogen peroxide formulations at concentration of no more than 5%. 

§205.601(i)(7) Peracetic acid- for use to control fireblight bacteria. Permitted in hydrogen peroxide formulations at concentration 

of no more than 5%. 

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

D. Recommended Committee Action & Vote (State Actual Motion): _Motion is to amend the annotations from the listings_ 

__for peracetic acid_on the National List §205.601(a)(6) and §205.601(i)(7) to add the words in each section “Permitted 

In hydrogen peroxide formulations at concentration of no more than 5%. 

Motion by: _Gerry Davis__ 

Seconded: Barry Flamm__ 

Yes: __6___ No: _0____ 

Absent: ___0_ 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. _____ Describe why material was rejected:___________ 

________________________________________________________________________________________________________ 

4) Substance was recommended to be deferred because ___________________________________________________________ 

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________ 

Crops X Agricultural Allowed1

 X

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

______Tina Ellor__________________ ______9-11-09___________ 

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

Category 1. Adverse impacts on humans or the environment?Substance - _Peracetic Acid(expand use)

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 X Peracetic acid is not produced and distributed for use as a solitary 

compound. It is only encountered as a solution in two- way equilibrium 

with hydrogen peroxide and acetic acid. These reaction components of 

peracetic acid- hydrogen peroxide and acetic acid- have various 

production methods, including (for acetic acid) oxidation of 

acetaldehyde, hydrolysis of acetylene, or fermentation of plant sources. 

For hydrogen peroxide, the Riedl-Pfleiderer process uses a polycyclic 

aromatic hydrocarbon derived from coal tar along with oxygen and 

hydrogen gases to produce the material. Details of which 

manufacturing process is used for the components or the potential 

adverse environmental effects from these processes were not provided 

in the TAP or the petition. General use of the material in crops would 

have adverse effects on the soil and crop environment due to nonselective biocidal effects. 

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3] 

X X See question #1 for manufacturing discussion. Environmental 

contamination from use or disposal of peracetic acid/ hydrogen 

peroxide/acetic acid formulas are not likely since they readily 

biodegrade. Small amount of stabilizer (HEDP) added to formulations 

would bio-degrade to phosphate for later plant availability. (EnvirotechHowarth & Harvey) More detail on the HEDP stabilizer’s role in 

potential crop and/or aquatic environment contamination is needed to 

fully answer this question. 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X X Other than the temporary direct effects to the crop environment, the 

material would be expected to be benign in residual environmental 

effects, notwithstanding lack of information on effects of HEDP 

stabilizer. See question #6 below for harmful effects to crop 

environment.

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 Strong oxidizer which can react violently with organic matter, 

mineral oils, and acetic acid anhydride.(TAP pg.3) 

6. Are there adverse biological 

and chemical interactions in 

agro-ecosystem? [§6518 m.5] 

X Soil application of significant amounts of the material would be toxic to 

many species of soil microbes, pest and beneficial. Foliar applications 

would kill pest and beneficial leaf inhabitants indiscriminately. (TAP p.4) 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

X See question 6. 

8. Is there a toxic or other 

adverse action of the material or 

its breakdown products? [§6518 

m.2] 

X Material is an irritant of the skin, eyes, mucous membranes, and 

respiratory tract. 

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment? [§6518 

m.2] 

X Readily biodegradable. 

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i) 

; 6517 c(2)(A)i; §6518 m.4] 

X See question 8. 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

X The material is on the EPA Extremely Hazardous Substance list.(EPA 

2000) 
12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5] 

 X OMRI Tech Brief 2 November 2000. It is listed on the FDA EAFUS list 

at http://vm.cfsan.fda.gov/eafus.html. (Everything Added to Food in the 

United States) 

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

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 - _Peracetic Acid (expand use)__

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 TAP page 1 of 13; ‘composition’ and ‘how made’. 

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 page 1 of 13; ‘composition’ and ‘how made’. 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

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)] 

 X TAP page 4 of 13 #6 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

 X Tap page 1 of 13; ‘composition’ and ‘how made’. 

9. Are there any alternative 

substances? [§6518 m.6] 

X As plant disease control- Coppers(fixed), copper sulfate, 

hydrated lime, hydrogen peroxide, lime sulfur, oils(horticultural), 

potassium bicarbonate, and elemental sulfur. 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X Disease control practices such as: proper crop site selection, 

plant disease resistance strategies, proper variety selection, crop 

rotation, etc. 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 - _Peracetic Acid 

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 X No: It is a synthetic, non-selective oxidizing agent that would be 

antagonistic (with general crop use) to many organic farming, 

microbiological-ecology based principles and practices. 

Yes: TAP page 4 of 13 #7 “Breakdown products are all part of 

the agro ecosystem” 

3. Is the substance compatible with 

a system of sustainable 

agriculture? [§6518 m.7] 

X X No: To expand usage to general plant (and soil) use would not 

be compatible due to extreme effects on soil and leaf surface 

ecologies. 

Yes: From the standpoint of residual environmental effects, “the 

breakdown products are all part of the natural agro ecosystem.” 

TAP page 4 of 13 #7 

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 

 TAP page 1 of 13 

b. toxins derived from bacteria; X TAP page 1 of 13 

c. pheromones, soaps, horticultural 

oils, fish emulsions, treated seed, 

vitamins and minerals? 

 X TAP page 1 of 13 

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 As a disinfectant/sanitizer for equipment cleaning- NOP Rule 

§205.601(a)(6)

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? 

 

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? 

 

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? 

 

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? 

 

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); 

 

b. Number of suppliers and amount 

produced; 

 

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; 

 

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or 

 

e. Are there other issues which may 

present a challenge to a consistent 

supply?