FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: ___November 30, 2007____ 

Subject: __Sunset- Calcium chloride___ 

Chair: __Andrea M. Caroe______________ 

 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X____

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

To retain calcium chloride on §205.602(c) Non-synthetic substances prohibited for use in organic 

crop production. 

(c) Calcium chloride, brine process is natural and prohibited for use except as a foliar spray to 

treat a physiological disorder associated with calcium uptake. 

NOSB Vote: Motion: G. Davis Second: T. Ellor 

Board vote: Yes - 15 No- 0 Abstain- 0 Absent - 0 

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

Potential overuse of this natural substance and resultant subsoil, surface water and ground water 

contamination warrants continued limitation of use. 

Sunset Material Vote 

Response by the NOP:
Crops Committee Recommendation for §205.602 September 12, 2007 

I. List: §205.602 Non-synthetic substances prohibited for use in organic crop 

production 

II. Prohibited non-synthetic substance 

(c) Calcium chloride 

III. Committee Summary: 

Calcium chloride is currently on the National List of non-synthetic materials prohibited 

for crop production with the annotation ... “brine process is natural and prohibited for 

use except as a foliar spray to treat a physiological disorder associated with calcium 

uptake.” In considering crop materials as part of the ongoing sunset process, the Crops 

Committee reviews the previous NOSB work pertaining to the material as well as any 

new information that has become available since the original board decision. 

Brine process calcium chloride would be classified as a mined substance of high 

solubility as mentioned in §205.203(d)(3) and as such its use is subject to the conditions 

established on the National List of non-synthetic materials prohibited for crop production. 

The foundational principle for placing high solubility materials such as calcium chloride, 

potassium chloride, etc. on a prohibited non-synthetic materials list is spelled out in 

§205.203(d) – Soil fertility and crop nutrient management practice standard. “A producer 

may manage crop nutrients ... in a manner that does not contribute to contamination of 

crops, soil, or water by plant nutrients...”. The current Crops Committee respects the 

intent of the earlier NOSB to annotate the prohibition on this material in such a way as to 

accomplish these nutrient management goals. Public comment on the present annotation 

has expressed several concerns: 

1) It is overly prescriptive in its foliar spray use guideline. Modest application rates 

applied with the proper methods in irrigation water can supply calcium nutrient 

without significant soil or water contamination and with less salt burn to the crop 

foliage, particularly in sensitive vegetable and greenhouse crops. 

2) The current annotation does not address the fact that chloride is an essential plant 

nutrient and can be deficient in some situations. In addition, some irrigation 

waters have almost no dissolved minerals (including chlorides and calcium) 

which can cause poor soil infiltration rates. Small amounts of calcium chloride 

added to irrigation water would be a very appropriate management choice to 

provide nutrients and improve the infiltration rate. 

3) The limitations on calcium chloride use are much more restrictive than the other 

mined natural chloride materials allowed in organic farming. The potassium 

chloride annotation reads “unless derived from a mined source and applied in a 

manner that minimizes chloride accumulation in the soil”. Magnesium and 

sodium chloride, although high solubility mined substances, are not on the 

prohibited non-synthetic list at all. Some consistency is needed in how these 

materials are listed. 
Further public comment suggested capturing the intent of the regulation in §205.203(d) 

and bringing consistency within §205.602 with the following annotation language: 

Generic chloride – unless derived from a non-synthetic mined and/or brined 

source and applied in a manner that minimizes chloride accumulation in soils, 

sub-soils, surface waters or groundwater. 

The Crops Committee acknowledges that annotations can not be changed during the 

sunset review process and can only be changed through the petition process. 

IV. Committee Recommendation: 

Recommendations based upon comments receivedThe Crops Committee recommends that the following material be retained on §205.602 

of the National List. 

(c) Calcium chloride, brine process is natural and prohibited for use except as a foliar 

spray to treat a physiological disorder associated with calcium uptake.

Moved: Ellor Second: Engelbert 

Committee vote: Yes: 5 No: 0 Absent: 1 Board vote: