National Organic Standards Board

Livestock Subcommittee

Discussion Document

Annotation Change for Lidocaine and Procaine Use in Livestock Production

July 31, 2015

I INTRODUCTION

Lidocaine and Procaine are local anesthetics. They are used to reduce or prevent pain during de-budding 

horns in calves, or general minor surgery on mature cows. They numb only the area to be worked on. 

Humane treatment of animals is critically important and the public expects high standards of animal 

welfare for organic livestock. A lengthy withholding may result in animals not being treated in a timely 

manner, or not treated at all. Based on new information received during Sunset Review of these 

materials the Livestock subcommittee requested a Technical Report on Lidocaine and Procaine for use in 

organic livestock production, and seeks public comment on a possible annotation change to reduce the 

withholding period from 90 days to 8 days for slaughter stock. 

II BACKGROUND

When added to the National List in 1995 there was no scientific rationale for the 90 day withholding, 

and the NOSB analysis in their document entitled “Local Anesthetics” provided very little information. 

The NOSB had not requested a Technical Report on these materials until this summer.

In December 2007, after much public comment and consultation, the NOP agreed that the NOSB could 

require double FDA withdrawal times, or double FARAD times (when appropriate), on a number of 

livestock materials. 

As a proposed compromise to satisfy the intent of the NOSB, many commenters suggested that 

USDA should consider amending the annotations of Atropine, Butorphanol, Flunixin, 

Furosemide, Tolazoline, and Xylazine by establishing extended withdrawal periods, calculated 

using withdrawal times from the Food Animal Residue Avoidance Databank (FARAD).The FARAD 

is a National Food Safety Project administered through the USDA Cooperative State Research, 

Education, and Extension Service. It is a system designed to provide livestock producers, 

extension specialists, and veterinarians with practical information on how to avoid drug, 

pesticide and environmental contaminant residue problems. FARAD is a repository of 

comprehensive residue avoidance information. It is also sanctioned to provide ‘‘withholding 

period’’ (also known as withdrawal period) estimates to the U.S. Pharmacopeia-Drug 

Information (USP–DI) Veterinary Medicine Advisory Committee. Commenters suggested that 

USDA account for an extra margin of at least double the withdrawal times of FARAD to safely 

capture the intent of the NOSB. USDA agrees with the position... 

Based on public comment, USDA consulted further with the FDA, concerning the ability to 

extend the withdrawal period on these approved drugs. Based on our consultations, USDA 

agreed to clarify the rationale for extending the FDA established withdrawal period. Secondly, 

USDA agreed to clarify the language used to authorize the use of the substances by indicating 

the extended withdrawal periods (at least two-times that required by the FDA) were only 

relevant for use of the substances under the NOP regulations. Therefore, to clarify our rationale 

for extending the withdrawal periods established by the FDA, we acknowledge that this 
determination was not based on scientific research or risk assessments. The decision to extend 

the FDA withdrawal periods (or any other withdrawal period) for the use of Flunixin and 

Furosemide (and other substances) was based on consumer preference and the 

recommendations of the NOSB. FDA exercises full responsibility for determining and enforcing 

the withdrawal intervals for animal drugs. No food safety arguments are used or implied to 

support the use of extended withdrawal periods authorized under the NOP regulations. Rather, 

we determined that extended withdrawal periods are more compatible with consumer 

expectations of organically raised animals. (72 FR 70479) 

III RELEVANT AREAS OF THE RULE

Section 205.238 Livestock healthcare practice standard.

(a) The producer must establish and maintain preventive livestock healthcare practices, including:

(5) Performance of physical alterations as needed to promote the animal’s welfare and in a 

manner that minimizes pain and stress;

...

(c) The producer of an organic livestock operation must not:

(7) Withhold medical treatment from a sick animal in an effort to preserve its organic status. All 

appropriate medications must be used to restore an animal to health when methods acceptable 

to organic production fail. Livestock treated with a prohibited substance must be clearly 

identified and shall not be sold, labeled or represented as organically produced.

Lidocaine: §205.603(b) as topical treatment, external parasiticide or local anesthetic as applicable 

(4) Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy animals

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/2017 

Procaine: §205.603(b) as topical treatment, external parasiticide or local anesthetic as applicable. 

(7) Procaine—as a local anesthetic, use requires a withdrawal period of 90 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy animals

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 6/27/2017

IV DISCUSSION

During the present Sunset Review of Lidocaine and Procaine the Livestock subcommittee was unable to 

find any record of the rationale for the much extended withdrawal period of 90 days for these materials 

when used on slaughter stock. Historical NOSB and NOP documents from 1995 to the present were 

reviewed. The December 2007 commentary (72 FR 70479) cited above implies that perhaps the 90 days 

is a doubling of the FDA or FARAD withholding period, but no such 45 day withholding was found in FDA 

or FARAD or other sources.
In FARAD the recommended withdrawal interval for lidocaine in cattle is listed as 1 day for meat and 24 

hours for milk after epidural use of lidocaine, and for subcutaneous use of lidocaine it is 4 days for meat 

and 72 hours for milk.

FARAD provides information on procaine only as it relates to procaine combined with an antibiotic and 

thus it would not be used in organic production. Procaine on its own is apparently not readily available 

in the US and public comment from veterinarians only suggests a similarity with lidocaine. Further 

information on procaine is needed.

During Review of these materials the NOSB in its initial request for public comment asked:

1. Since this material was last reviewed have alternative materials emerged?

2. What is the scientific rationale for what appears to be an excessively long withdrawal period?

3. Is there research to indicate that a shorter withdrawal period would be appropriate?

Public comment did not provide any alternatives, did not provide any scientific rationale for the lengthy 

withholding period, and recommendations were received suggesting that a very short withholding 

period, such as 5 days would be scientifically acceptable. 

In contrast to butorphanol, which is a systemic anesthetic, lidocaine and procaine numb only the area to 

be worked on. Science indicates that the half-life of lidocaine and procaine in all animals studied is very 

short—typically less than one hour. 

There appears to be public support to reduce the Withholding period in order to ensure humane 

treatment of animals. The 90 day withholding period is far in excess of the withholding period used in 

conventional livestock production.

The Livestock subcommittee has requested a Technical Report on lidocaine and procaine used in 

livestock production. Following receipt of public comment in response to this Discussion Document, and 

the findings presented in the Technical Report, the NOSB may develop a Proposal to amend the 

withholding period of lidocaine and procaine.

V REQUEST FOR PUBLIC COMMENT

1. Is Lidocaine widely used; under what circumstances is it used; how is it administered; should the 

withholding period be the same in all animal species?

2. Is Procaine used; under what circumstances; how is it administered; should the withholding period be 

the same in all animal species?

3. Should the annotation for Lidocaine at 205.603(b) be amended as follows?

Lidocaine—as a local anesthetic. Use requires a withdrawal period of 90 days 8 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy animals 
4. Should the annotation for Procaine at 205.603(b) be amended as follows?

Procaine—as a local anesthetic, use requires a withdrawal period of 90 days 8 days after 

administering to livestock intended for slaughter and 7 days after administering to dairy 

animals.

Motion to change annotations for lidocaine and procaine on §205.603 

Motion: Jean Richardson

Seconded by: Francis Thicke 

Yes: 4 No: 0 Abstain: 0 Absent: 2 Recuse: 0