FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _____November 30, 2007_________

Subject: ___Add Sodium Carbonate Peroxyhydrate to National List___ 

Chair: Andrea M. Caroe

 ________________________________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X____ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

Recommendation to add sodium carbonate peroxyhydrate to §205.601(a) of the National List 

as algaecide. (Board vote- 14 Yes, 1 No) 

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

The Crops Committee in its consideration of the material highlighted some possible adverse 

environmental impacts, some possible natural substitute materials, and some incompatibility with 

the synthetic material categories listed by OFPA, and voted 0 Yes, 4 No. Resulting public 

comment at the full NOSB meeting presented additional information that convinced most board 

members that the material’s environmental impacts were minimal and much more 

environmentally friendly than the copper sulfate now used as the principal farm pond and rice 

production algaecide. It was also presented that the material is a safer, stabilized with natural 

sodium carbonate form of hydrogen peroxide, a material already on the National List. 

Response by the NOP:

Updated 2/25/05
Decision Sheets 

December 2006 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: __November 2007 Substance: Sodium carbonate peroxyhydrate

Committee: Crops √ Livestock  Handling  Petition is for:_To add sodium carbonate peroxyhydrate to the 

 National List § 205.601(a) as algaecide___________________________ 

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: __1,2,3_ Comments: See comments below ____________________________ 

________________________________________________________________________________________________________ 

C. Proposed Annotation (if any): _____________________________________________________________________________

________________________________________________________________________________________________________ 

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

D. Recommended Committee Action & Vote (State Actual Motion): Add sodium carbonate peroxyhydrate to National List 

________________________________________________________________________________________________________ 

 9/12/07 Motion by: Jeff Moyer Seconded: Rigoberto Delgado Yes: _0__ No: _5__ Absent: ____1_ Abstain: _____ 

 

11/29/07 RD 1st; TE 2nd ; yes 5 no 0 absent 1

 

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. 601 Describe why material was rejected: Failure to 

satisfy all three evaluation criteria 

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops X Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3

X 

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

____Gerald Davis __________11/29/2007________ 

 Committee Chair Date
Decision Sheets 

December 2006 

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance – Sodium carbonate peroxyhydrate

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 

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3] 

X 

TAP Line 233-241 

3. Is the substance harmful to the 

environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

x 

TAP 178-211 

4. Does the substance contain List 

1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2] 

 Insufficient information. 

5. Is there potential for detrimental 

chemical interaction with other 

materials used? 

[§6518 m.1] 

X 

TAP Line 213-231 

6. Are there adverse biological and 

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

X 

TAP Line 233-241 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

X 

TAP Line 248-256 When used according to label. 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? 

[§6518 m.2] 

X 

TAP Line 258-264 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X 

TAP line 233-241 

10. Is there any harmful effect on 

human health? 

[§6517 c (1)(A)(i) ; 6517 c(2)(A)i; 

§6518 m.4] 

X 

TAP line 289-304 Eye irritant. 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

X 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5] 

X 

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

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. 
Decision Sheets 

December 2006 

Category 2. Is the Substance Essential for Organic Production? Substance - Sodiun carbonate peroxyhydrate

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 line 97-109 

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 line 139-141 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

X 

TAP line 146-148 

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 line 306-314, 341-346 Barley straw inoculation of 

ponds. 

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 

Mixtures of natural alum, gypsum, limestone plus barley straw 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X 

Pond aeration devices or practices. 

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. 
Decision Sheets 

December 2006 

Category 3. Is the substance compatible with organic production practices? Substance -Sodium carbonate 

peroxyhydrate

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 

Synthetic material for use where other viable materials or 

practices exist. 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

X 

TAP 279-288. Long term use effects on soil or water pH 

could be problematic. TAP line 182-183 

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 

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. 
Decision Sheets 

December 2006 

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?