Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Response to Yeast Petition 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X 

 

Statement of the Recommendation (Including Recount of Vote): 

 

The recommendation is to retain yeast on section 205.605(a) of the National 

List, rather than move it to section 205.606 as requested by the petitioner, due 

to concerns of the livestock industry and the debatable agricultural nature of 

yeast. However, the NOSB recommends that organic forms, when 

commercially available, be required for human consumption. The listing for 

yeast in Section 205.605(a) of the National List is recommended to read as: 

Yeast – When used as food or a fermentation agent, yeast must be organic if 

it’s end use is for human consumption. Non-organic yeast may be used when 

equivalent organic yeast is not commercially available. Growth on 

petrochemical substrate and sulfite waste liquor is prohibited. For Smoked 

yeast non-synthetic smoke flavoring process must be documented. 

The NOSB vote for this recommendation was 13 Yes, 0 No, 0 Abstentions, 0 

Absent, and 1 Recusal. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

Yeast can be certified as organic and many organic forms are available. 

Creating a commercial availability annotation for this 205.605 is not prohibited 

by OFPA or the NOP. 

 

NOSB Vote: 

Moved: Joe Smillie Second: Steve DeMuri 

Yes: 13 No: 0 Abstain: 0 Absent: 0 Recusal: 1 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: October 2010 Substance: Yeast 

Committee: Crops  Livestock  Handling  Petition is for moving Yeast from National List § 205.605(a) to § 205.606

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 Yes  No  N/A  

B. Substance Fails Criteria Category: 

Comments: The petitioner requested that yeast be moved to 606 so that organic production methodology would be required. While this 

may well be suitable for human consumption it would cause hardship to livestock producers who are required to use organic agricultural 

materials with no commercial availability option. The question of its agricultural nature is also controversial so the Handling Committee 

has crafted a compromise that keeps yeast on 205.605(a) but adds an annotation that requires organic if available for human 

consumption. 

________________________________________________________________________________________________________ 

C. Proposed Annotation (if any): Yeast – When used as food or a fermentation agent, yeast must be organic if its end use is for human 

consumption; nonorganic yeast may be used when equivalent organic yeast is not commercially available. Growth on petrochemical

substrate and sulfite waste liquor is prohibited. For Smoked yeast; non-synthetic smoke flavoring process must be documented. 

________________________________________________________________________________________________________ 

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: Livestock feed requirements 

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

________________________________________________________________________________________________________ 

Classification of the material: Non- synthetic; Absent: 1; Abstain: 0 

Motion by: Joe Smillie; Seconded: John Foster; Yes: 6; No: 0; Absent: 1; Abstain: 0 

Recommended Committee Action & Vote 

Motion by: Joe Smillie; Seconded: John Foster; Yes: 6; No: 0; Absent: 1; Abstain: 0 

 

 

1) Substance voted to be added as “allowed” on National List to § 205.605 with Annotation (if any): Yeast – When used as food, a 

fermentation agent, or supplement, yeast must be organic if its end use is for human consumption; nonorganic yeast may be used 

when equivalent organic yeast is not commercially available. Growth on petrochemical substrate and sulfite waste liquor is prohibited. 

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: _____________________ 

Substance was recommended to be deferred because _____________ If follow-up needed, who will follow up _____________________ 

Crops Agricultural Allowed1

 x 

Livestock Non-Synthetic x Prohibited2 

Handling Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

___Steve DeMuri___________________ __September 9, 2010______ 

 Committee Chair Date
EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST 

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

 

Question Yes No N/A

1

Documentation

(TAP; petition; regulatory agency; other)

1. Are there adverse effects on 

environment from manufacture, use, or 

disposal? [§205.600 b.2] 

 X On the National List 205.605 One of the 

benefits of organic production is that it 

eliminates adverse effects on the 

environment 

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3] 

 X 

3. Is the substance harmful to the 

environment and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 X 

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 

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5] 

 X 

8. Is there a toxic or other adverse action of 

the material or its breakdown products? 

 [§6518 m.2] 

 X 

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

 X 

10. Is there any harmful effect on human 

health? [§6517 c (1)(A) (i) ; 6517 

c(2)(A)I; §6518 m.4] 

 X 

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. 
Category 2. Is the Substance Essential for Organic Production? Substance: Yeast 

 

Question Yes No N/A

1

Documentation 

(TAP; petition; regulatory agency; other) 

1. Is there a natural source of 

the substance? 

[§205.600 b.1] 

 X 

2. Is there an organic 

substitute? [§205.600 b.1] 

 X 

3. Is the substance essential 

for handling of organically 

produced agricultural 

products? [§205.600 b.6] 

 X 

4. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

 X 

5. Is the substance used in 

handling, not synthetic, but 

not organically produced? 

[§6517 c (1)(B)(iii)] 

 X 

6. Is there any alternative 

substances? [§6518 m.6] 

 X 

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

 X 

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 

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. 

 
Category 3. Is the substance compatible with organic production practices? 

Substance Yeast 

 

Question Yes No N/A

1

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, and biodiversity? 

[§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 

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. 
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 - Yeast 

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 See Attachment 

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 See Attachment 

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 There may be supply eventually for 

all Human consumption uses and 

possibly feed but other livestock 

uses are not possible in the 

foreseeable future. See attachment 
Committee Summary 

 Petition is for moving Yeast from 

 National List § 205.605(a) to 205.606 

The petitioner requested that yeast be moved to § 205.606 so that organic production 

methodology would be required. There has been a long history to this petition. Clearly 

the petitioner has pointed out the ecological differences between organic and 

conventional production methodology. The issue of whether yeast production is 

agricultural is controversial with vocal adherents on each side. This makes its 

placement on § 205.606 problematic. Organic yeast is now available in many forms for 

human consumption so the committee wants the industry to use these organic sources. 

The NOP has recently allowed yeast to be certified after examining the certification of 

the process and the product. In discussion with members of the Livestock committee 

another concern became clear. Moving yeast to § 205.606 would cause hardship to 

livestock producers because they are required to use only organic agricultural materials 

with no commercial availability option. While there is a strong possibility that organic 

yeast may be available for feed the other uses of yeast in livestock health preparations 

could not comply with the organic requirement. Taking these policies, concerns, and 

needs into consideration, the Handling Committee has crafted a compromise that keeps 

yeast on § 205.605 but adds an annotation that requires organic if available for human 

consumption. It is the intent of the Handling Committee that this recommendation apply 

to all yeast products used as ingredients in organic food products, including, but not 

limited to, Autolysate, Bakers, Brewers, Nutritional and Smoked as listed in the previous 

recommendation.