Decision Sheets

December 2006

NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: ____November 2011___ Substance: Potassium Hydroxide

Committee: Crops  Livestock  Handling X Petitioned for annotation change from ―Potassium hydroxide—

prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches during the Individually Quick Frozen 

(IQF) production process‖ to ―Potassium hydroxide—prohibited for use in lye peeling of fruits and vegetables except when used for 

peeling peaches‖ on the National List § 205.605(b)

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 X No  N/A 

3. Compatibility & Consistency Yes X No  N/A 

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

B. Substance Fails Criteria Category: _________ Comments: ___________________________________________________ 

________________________________________________________________________________________________________

C. Proposed Annotation (if any): annotation change from ―Potassium hydroxide—prohibited for use in lye peeling of fruits and 

vegetables except when used for peeling peaches during the Individually Quick Frozen (IQF) production process‖ to ―Potassium 

hydroxide—prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches during the canning or 

Individually Quick Frozen (IQF) production process‖

 Basis for annotation: To meet criteria above: ________ Other regulatory criteria: The petition is to change the annotation for 

the current §205.605 (b) listing of potassium hydroxide to add the allowed use of lye peeling of peaches for canning, in addition to 

peaches for freezing. Citation:__

D. Recommended Committee Action & Vote (State Motion): __Recommend changing the annotation for potassium hydroxide 

from ―Potassium hydroxide—prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches during 

the Individually Quick Frozen (IQF) production process‖ – to ―Potassium hydroxide—prohibited for use in lye peeling of fruits and 

vegetables except when used for peeling peaches during the canning or Individually Quick Frozen (IQF) production process‖ on the 

National List § 205.605(b)

________________________________________________________________________________________________________

Motion by: DICKSON Seconded: MIEDEMA Yes: 6 No: 0 Absent: 1 Abstain: 0 

 

 

1) Substance voted to be added as ―allowed‖ on National List to § 205. X with Annotation (if any) prohibited for use in lye 

peeling of fruits and vegetables except when used for peeling peaches

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 Agricultural Allowed1 

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic X Rejected3

No restriction Commercially UnAvailable as Organic1

 

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

______________________________________ _________________________

 Committee Chair Date
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December 2006

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

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

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 TAP lines 163-186: “Peach processing plants using lye 

peeling are generally restricted by state and local waste water 

treatment requirements, which has resulted in a limited 

number of plants and sites in operation (O„Bara, 2001). Data 

supplied by the petitioner indicates that alkalinity of waste is 

not a factor, due to the natural acidity of the fruit, which must 

be additionally buffered during on-site treatment (Finn, 

2001).”

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3]

X See #1 above. 

3. Is the substance harmful to the 

environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X See #1 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

6. Are there adverse biological and 

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

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem.

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem.

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2]

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem.

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2]

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem.

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4]

X TAP lines 193-194: “The petitioner has submitted 

experimental data showing no increase in potassium content of 

the fruit due to 193 the use of potassium hydroxide.”

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

X See #10 above. 

12. Is the substance GRAS when 

used according to FDA‟s good 

manufacturing practices? [§205.600 

b.5]

X TAP lines 216-237: “Potassium Hydroxide is Generally 

Recognized As Safe under 21 CFR 184.1631. Federally 

approved food uses are 218 summarized in Table 1.” 

Referenced table includes used in peeling of fruits and 

vegetables, allowed under 21 CFR 173.315(a)(1) 

13. Does the substance contain X TAP lines 229-236
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December 2006

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

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.
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December 2006

Category 2. Is the Substance Essential for Organic Production? Substance - Potassium Hydroxide

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

The petition and the TAP describe the production method in 

detail. TAP lines 48-51:

Food grade potassium hydroxide is obtained 

commercially from the electrolysis of potassium 

chloride solution in the presence of a porous 

diaphragm [21 CFR 184.1631(a)]. The reaction can be 

characterized as follows: 

KCl + H2O → HCl + KOH

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 According to the TAP, the source potassium chloride is 

natural, but the process renders the resultant potassium 

hydroxide synthetic (lines 138-139). Potassium chloride 

occurs naturally as sylvite, and it can be extracted from 

sylvinite or from salt water. Potassium hydroxide is also a byproduct of the synthesis of nitric acid from potassium nitrate 

and hydrochloric acid.

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)]

X See #2.

4. Is there a natural source of the 

substance? [§205.600 b.1]

X Potassium hydroxide can be obtained naturally by the leaching 

of wood ash, but this method is not commercially practiced

(TAP lines 136-140). 

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

 

Petitioner states that this substance is the only viable method 

of commercial peach peeling, and as such, is used to make 

products meet consumer expectations. 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)]

X TAP lines 141-143: 

Solutions of some natural acids such as citric and 

tartaric have been used to peel peaches. This works 

by disintegrating the peel and requires large volumes 

of water. It also prevents browning. However, this is 

not apparently used due to the corrosive effect of the 

solutions on metal equipment (Woodruff, 1986).

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)]

X Substance is synthetic. 

9. Is there any alternative 

substances? [§6518 m.6]

 X

See #7. The only natural alternative is not commercially 

viable. 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6]

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.
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December 2006

Category 3. Is the substance compatible with organic production practices? Substance - Potassium Hydroxide

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 This substance is used as an ingredient in an organic processed 

food. It is not used in agriculture.

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

X Nutritional quality of food is not degraded, and is in some 

cases improved over other processing methods. 

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;

Petitioned material is not for use in production

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.
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December 2006

Category 4. Is the agricultural substance inconsistently or not commercially available as organic? 

Substance - Color, Beta-carotene extract, derived from carrots

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 This is not an agricultural substance. 

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
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December 2006

Additional Background

List: § 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as ―organic‖ or ―made with organic (specified ingredients or 

food group(s)).‖ (b) Synthetics allowed--Potassium hydroxide—prohibited for use in lye 

peeling of fruits and vegetables except when used for peeling peaches.

Committee Summary

Potassium hydroxide is a synthetic, inorganic compound produced by the electrolysis of 

potassium chloride. Also known as potash, it is a strong base and alkaline in solution. 

Much of its utility in food processing is based on its function as a caustic strong base. 

Potassium hydroxide is widely used in food processing as a pH adjuster, cleaning 

agent, stabilizer, thickener and poultry scald agent. It is also used in the lye peeling of 

fruits and vegetables. The FDA lists potassium hydroxide as GRAS for humans (21 

CFR 184.1631), which are allowed under 21CFR 173.315(a)(1) - Chemicals used in 

washing or to assist in the peeling of fruits and vegetables. In fruit and vegetable 

peeling, potassium hydroxide serves to weaken the glycolytic bonds of pectin, which is 

responsible for skin adhesion. Weakening these bonds allows the peeling of fruit and 

vegetable skins by water spray or other mechanical methods. 

In 1995, the NOSB approved the addition of potassium hydroxide to 205.605(b), with an 

annotation prohibiting its use in the lye peeling of fruits and vegetables. This restriction 

was based on concerns about the environmental effects of the waste products of the lye 

peeling process, and the fact that mechanical and non-chemical alternatives were 

available for most fruits and vegetables. 

In 2001, a petitioner sought to expand the use of potassium hydroxide by amending the 

annotation to read ―prohibited for use in lye peeling of fruits and vegetables except 

when used for peeling peaches during the Individually Quick Frozen (IQF) production 

process.‖ The 2001 TAP review for that expansion noted that ―The stone fruit (peaches, 

nectarines, and apricots) do not appear to currently have alternative methods available 

on a commercial scale to achieve peeling without the use of caustic substances.‖ The 

2001 TAP review also noted that the environmental effects which had originally resulted 

in the restrictive annotation could be mitigated with the use of good wastewater 

management practices. Peach processing plants are generally restricted by state and 

local wastewater treatment requirements, and the natural acidity of the fruit and 

additional pH adjusments buffer the alkalinity of the wastewater. Because no 

commercially viable alternatives are available, and processing practice mitigates the 

potential environmental effects, the NOSB approved the expanded annotation. 

A new petition from the same petitioner was filed in 2011, seeking to expand the 

annotation again to allow the use of potassium hydroxide for the peeling of fresh 

peaches to be canned. The petition confirms the lack of commercially viable alternatives 

for this use, and the mitigation of potential environmental impact. The processing of 

peaches for canning and freezing is identical up until the freezing or canning step.

Based on the petition, the 2001 TAP review, and the rationale of the 2001 NOSB, the 

Handling Committee supports the expansion of this annotation to allow potassium 

hydroxide to be used in the peeling of both IQF and canned peaches. Accordingly, since 
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December 2006

canning and freezing are the primary commercially processing methods used for 

peaches, we favor removing the language regarding IQF methods so that the exception 

to the prohibition on lye peeling applies to all peach peeling. 

Committee Recommendation(s)

The handling committee recommends the expansion of the annotation of the following 

substance in this use category as published in the final rule:

§ 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as ―organic‖ or ―made with organic (specified ingredients or 

food group(s)).‖ (b) Synthetics allowed--Sulfur dioxide—Potassium hydroxide—

prohibited for use in lye peeling of fruits and vegetables except when used for peeling 

peaches.