NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP

For NOSB Meeting: May 2009 Substance: Propionic Acid

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: Organic alternatives and 

non-synthetics sources available; 

synthetics not allowed as preservatives

C. Proposed Annotation: ______________________________________ 

___________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________ 

Other regulatory criteria: ____ Citation:_______________

D. Final Board Action & Vote (State Actual Motion):

The motion presented to the committee is to list propionic acid on the National List §205.603.

Motion: Hubert Karreman Second: Kevin Englebert Yes: 0 No: 14 Recuse: 1 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:

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: The material is 

synthetic and proposed to be used as a preservative, which is not allowed according to regulation. 

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

E. Approved by NOSB Chair to transmit to NOP

 . 

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: May 2009 Substance: Propionic Acid

Committee: Crops  Livestock Handling  Petition is for: animal feed preservation as a mold inhibitor

on the National List § 205.603

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: Organic alternatives and non-synthetics sources available; 

synthetics not allowed as preservatives___________________________________________________ 

C. Proposed Annotation (if any): _____________________________________________________________________________

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

D. Recommended Committee Action & Vote (State Actual Motion): _______________________________________________ 

The motion presented to the committee is to list propionic acid on the National List §205.603. The Livestock Committee felt the 

technical review done by Science and Techonology on this material fell short of their expectations. The committee was able to rely 

on a previous and thorough review of Calcium Proprionate (attached) which also discussed, in detail, propionic acid. The Livestock 

Committee disagrees with the footnote on Category 2 items 4, 5, and 6, indicating that §205.600 (b) items under review do not apply 

to crops and/or livestock.

________________________________________________________________________________________________________

Motion by: Dan Giacomini___ Seconded:____Jennifer Hall____

 

 Yes: _0____ No: __7___ 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. __603_ Describe why material was rejected:___________ 

_Substance’s primary petitioned use is as a preservative. As such it fails the evaluation criteria laid out in 205.600(b)(4): The 

substances primary use is not as a preservative .........Substance was also rejected because it failed criteria 2 & 3 .

_______________________________________________________________________________________________________

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

No restriction Commercially UnAvailable as Organic1

 Deferred4

E. Approved by Committee Chair to transmit to NOSB:

Hubert Karreman 

 Committee Chair Date

March 10, 2009 
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

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

Acid_________

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 There should not be any environmental contamination 

during the manufacture of the synthetic substance. The 

major impurity in the final product is acetic acid and it is 

present at less than 0.3% by weight. Scrubbers are used 

during the manufacturing process to capture fugitive 

emissions (Fugitive emissions are considered a pollutant 

under the clean air act) and the scrubber condensates are 

collected and re-distilled and the organic material collected 

are used as fuel or sold as solvents (pg 3 of TR) 

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3]

X X Propionic acid is used as a carbon source by many 

microorganisms and is metabolized to acetic acid, 

methane, carbon dioxide, and water (Lin et al., 1986). 

Based on this, the U. S. EPA has waived environmental 

fate data requirements for the currently registered uses of 

propionic acid. Therefore, any concerns over the improper 

storage, use, and disposal of propionic acid should be 

minimal (pg 3 of TR)

3. Is the substance harmful to the 

environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X See #1 and #2 above.

4. Does the substance contain 

List 1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2]

X No, the substance itself is on List 4B

5. Is there potential for 

detrimental chemical interaction 

with other materials used?

[§6518 m.1]

X There is no information available to indicate that using 

propionic acid has detrimental physiological effects on soil, 

organisms, crops, or livestock. The registered uses of 

propionic acid indicate that it is used in either indoor 

treatments or limited outdoor uses for animal watering. On 

the basis of low toxicity and low potential for exposure, 

hazard to non-target organisms is expected to be minimal. 

Propionic acid is metabolized by microorganisms to acetic 

acid, methane, carbon dioxide, and water (Lin et al, 1986). 

(Pg 4 of TR)

6. Are there adverse biological 

and chemical interactions in 

agro-ecosystem? [§6518 m.5]

X There is no information available to indicate that propionic acid 

has adverse biological or chemical 

interactions in the agro-ecosystem. The U.S. EPA has reviewed 

the available eco-toxicity data on propionic 

acid and found that it is only slightly toxic to birds, fish, aquatic 

invertebrates, and mammals. (pg 4 of TR). As stated in the 2002 

TAP Review for Calcium Propionate, propionic acid has the 

potential to be highly mobile in the soil but no major adverse 

effects were noted.

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X There is no information available to indicate that using 

propionic acid has detrimental physiological effects on soil, 

organisms, crops, or livestock. The registered uses of 

propionic acid indicate that it is used in either indoor 

treatments or limited outdoor uses for animal watering. On 
the basis of low toxicity and low potential for exposure, 

hazard to non-target organisms is expected to be minimal. 

Propionic acid is metabolized by microorganisms to acetic 

acid, methane, carbon dioxide, and water (Lin et al, 

1986).(pg 4 of TR)

8. Is there a toxic or other 

adverse action of the material or 

its breakdown products? 

[§6518 m.2]

X One adverse reaction of propionic acid is that it is 

corrosive (Kung, Jr. et al., 2000). To be effective as a 

preservative, the material has to be evenly applied to 

silages, hays, and grains. If propionic acid is applied at 

harvest, it will likely cause corrosion to harvesting 

equipment such as forage harvesters or hay balers. In the 

case of the storage of grains, metal storage structures 

(i.e., metal grain bins) may be susceptible to rust and 

corrosion where the grain has been treated with propionic 

acid. (pg 5 of TR)

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment?[§6518 

m.2]

X X Under anaerobic conditions, propionic acid is used as a 

carbon source by various microorganisms and is 

metabolized to acetic acid, methane, carbon dioxide, and 

water (Lin et al., 1986). Only two incident reports 

concerning propionic acid were: 1) detections in the tissue 

of mussel (Mytilus edulis) (Yasuhara and Morita, 1987) 

and 2) in ground water as the results of the break-down of 

petroleum pollution (Goerlitz et al., 1985).(Pg 5 of TR)

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4]

X Propionic acid is in Toxicity Category III for acute oral 

toxicity, acute dermal toxicity, and acute inhalation toxicity 

and in Toxicity Category I for eye irritation and dermal 

irritation. Products containing greater than 63% propionic 

acid must include the following protective clothing label 

requirements: “Wear chemical-resistant gloves, chemicalresistant aprons, chemical-resistant footwear and goggles 

or face shield when loading application equipment unless 

a closed loading system is used. Avoid working near high 

concentrations of spray mist/vapor. Use with adequate 

ventilation. Wash thoroughly after handling.” (pg 5 of TR)

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5]

13. Does the substance contain 

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.
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 Propionic acid is produced synthetically by reacting 

ethylene (petroleum based) with a mixture of carbon 

monoxide and hydrogen to yield propionaldehyde. Either 

rhodium or cobalt is used as a catalyst in this reaction. 

The propionaldehyde is treated with air or pure oxygen in 

a carefully controlled reaction to reduce the 

propionaldehyde to propionic acid. The propionic acid is 

distilled to produce a purified product. (pg 3 of TR)

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 Petroleum is synthetic.

3. Is the substance created by

naturally occurring biological 

processes? [6502 (21)]

X

4. Is there a natural source of 

the substance? [§205.600 b.1]

X Propionic acid is naturally produced by bacterial 

fermentation (pg 3 of TR)

5. Is there an organic 

substitute? [§205.600 b.1]

X Organic vinegar is available; or propionic acid derived 

from bacteria

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 In silage production, one wholly natural product that 

possibly could be substituted for propionic acid is vinegar. 

(pg 5 of 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 See # 5 above; also: “A synthetic form of lactic acid could 

be substituted for propionic acid. Lactic acid should be the 

primary acid in well-fermented silage and fermentations 

that produce lactic acid result in the fewest losses of dry 

matter and energy from the crop during storage” (pg 5 of 

TR)

10. Is there another practice 

that would make the substance 

unnecessary? [§6518 m.6]

X Yes, proper crop harvesting methods; “In the case of 

silages, corn, hay, or other crops could be harvested at 

the optimal moisture contents. Harvesting and ensiling 

these crops at the optimal moisture contents will result in 

the proper fermentation of the crops in the silos with 

minimal mold formation and spoilage. Other practices 

such as proper packing of silages and covering (use of 

plastic covers) in bunker silos are recommended for good 

silage production. Also, good management practices in the 

removal of silage from silos at feeding will result in lower 

incidences of mold formation and spoilage. Therefore, a 

number of good management practices are available to 
make well-fermented silages without the use of 

preservatives.” (pg 5 of TR) 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 §205.600(b)(4) states: Evaluation criteria for allowed 

and prohibited substances, methods, and ingredients.

The following criteria will be utilized in the evaluation of 

substances or ingredients for the organic production and 

handling sections of the National List: (b) In addition to the 

criteria set forth in the Act, any synthetic substance used 

as a processing aid or adjuvant will be evaluated against 

the following criteria: (4) The substance’s primary use is 

not as a preservative ..........

“

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

X Yes - in that is allows a crop to be either salvaged or 

saved and thus protect a potential feed for livestock (thus 

“sustaining” a natural resource)

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

X X Yes, by reducing the effects of mold on the silage, food 

quality is preserved or maintained. No, it can have a 

corrosive effect on the metal bins that may hold such 

treated crops, or the machinery utilized for harvest, 

contaminating feed.

5. Is the primary use as a 

preservative? [§205.600 b.4]

X Petitioned as a preservation method to inhibit mold growth 

as stated in item B number3 of the petition.

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

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 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