Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: December 2, 2011

Subject: Petition to add odorized propane to the National List, Synthetic 

substances allowed for use in organic crop production, § 205.601(g)(3) –

Rodenticides.

Chair: Tracy Miedema

 

 

The NOSB hereby recommends to the NOP the following: 

Other - Not to add odorized propane to the National List 

Statement of the Recommendation (Including Recount of Vote): 

The motion to list odorized propane on the National List failed by a vote of 9 

yes, 5 no. Odorized propane was classified as synthetic by a vote of 14 yes, 0 

no.

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

The NOSB recommends against approving the petition because: (1) the use 

does not fit into any of the categories of allowable uses of synthetics in 7 

U.S.C. § 6517(c)(1)(B)(i), and (2) the use fails the criteria for impacts on 

humans and the environment, essentiality, and compatibility with organic and 

sustainable agriculture.

NOSB Vote: Propane is a nonsynthetic.

Moved: John Foster Second: Steve DeMuri

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recusal: 0

NOSB Vote: Add odorized propane to § 205.601 Synthetic substances 

allowed for use in organic crop production 

(g) As rodenticides. 

Moved: John Foster Second: Tina Ellor

Yes: 9 No: 5 Abstain: 0 Absent: 0 Recusal: 0

NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: November-December, 2011 __ Substance: odorized propane__

Committee: Crops X Livestock  Handling  Petition is for: _odorized propane_ 

on the National List § 205.601________________________________

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

1. Impact on Humans and Environment Yes  No X N/A 

2. Essential & Availability Criteria Yes  No X N/A 

3. Compatibility & Consistency Yes  NoX N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance Fails Criteria Category: 1,2,3 Comments: 

C. Codex._____________See following evaluation._Many adverse impacts on ecological system, including soil structure and biology and 

predators; many other available practices; questionable efficacy because collapsed burrows may be reestablished; incompatible with organic 

and sustainable practices. See checklist and references for details._________________________________________________

D. Proposed Annotation (if any): _________________________________________________________________________ 

____________________________________________________________________________________________________

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

D. Recommended Committee Action & Vote, including classification recommendation (State Actual Motion): 

_Add odorized propane for rodent control to § 205.601______________________________________________________________

Classification of the material: Synthetic ____ X____ Non- synthetic_____________ Absent:_________ Abstain _____ 

Motion by: _______________ Seconded:________________ Yes: _____ No: _____ Absent: _______ Abstain: _______

Recommended Committee Action & Vote _ ______________________________________________________

___________________________________________________________________________________________________

 

Motion by: John Foster_ Seconded:___Tina Ellor___ Yes: _3___ No: ___4__ 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. 201______Describe why material was rejected: 

Many adverse impacts on ecological system, including soil structure and biology and predators; many other available 

practices; questionable efficacy because collapsed burrows may be reestablished; incompatible with organic and sustainable 

practices. It does not fit any allowable category of synthetic input under 7 U.S.C. § 6517(c)(1)(A)

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:

______________________________________ _________________________

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

Category 1. Adverse impacts on humans or the environment? Substance: odorized propane 

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 Propane is a byproduct of natural gas 

processing and petroleum refining. Most 

of the U.S. supply of liquid propane is 

produced in the United States. Methane 

and other hydrocarbons, including 

propane, are obtained by separation from 

natural gas using a combination of 

increased pressure and decreased 

temperature. Propane is also a byproduct 

of crude petroleum refining, which uses 

chemical processes to break down and 

modify the structure of petroleum 

compounds (MEA, 2006). TR 182-186

2. Is there environmental contamination during 

manufacture, use, misuse, or disposal? 

[§6518 m.3]

X Propane is prohibited for use in organic 

handling due to its potential adverse effect on 

human health and the environment and because 

it is a synthetic byproduct of the petrochemical 

industry (USDA, 2009b) TR 116-118 

3. Is the substance harmful to the environment

and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i]

X Franklin ground squirrels are an 

endangered species1. The petitioned 

method of collapsing burrows using 

propane may injure or kill nontarget 

species, including many predators of 

rodents, occupying or living nearby the 

treated burrows. TR 272-273

Inhabitants of burrows include burrowing 

owls, black footed ferrets, snakes, tiger 

salamanders, and others.2,3

 1 http://www.ag.purdue.edu/entm/wildlifehotline/pages/groundsquirrels.aspx

2 “Belowground, the burrows are sheltered and cool no matter the weather above. This comfortable climate draws a 

diverse cast of grassland animals—mice, voles, tarantulas, and several species of beetles that live exclusively in 

rodent tunnels. Then there are the local amphibians. Ground squirrels actually make it possible for moisture-loving 

amphibians to live in the hot, dry hills of the Diablo Range. As the weather warms and ponds dry up, California redlegged frogs, western toads, ensatina salamanders, and California tiger salamanders retreat to the cool refuge of 

squirrel burrows—often while the squirrels are still living inside. The frogs and toads come and go, but the taxicabtinted tiger salamanders move in for the long haul: they stay underground for up to ten months each year, emerging 

only in winter to breed.

“With this crowd, squirrel burrows are almost mini-ecosystems of their own. Worms and beetles crawling out of the 

walls may get eaten by the amphibians, while mice and voles go after the squirrels’ caches of nuts and seeds. Larger 

creatures— burrowing owls, coyotes, and San Joaquin kit foxes—often enlarge abandoned burrows and convert 

them into dens.

“But ground squirrels do even more for grassland ecosystems than spread seeds and build shelters. Plentiful and 

prolific, they are a dinnertime mainstay for most of California’s savanna predators. Local badger populations depend 

almost entirely on ground squirrel colonies, says retired district naturalist Ron Russo. And studies of golden eagles 

in the park district show that ground squirrels may comprise up to 70 percent of their diets when the birds are rearing 

their young. DiDonato says the sheer abundance of ground squirrels around San Antonio Reservoir and Sunol 

Regional Wilderness supports the densest population of nesting golden eagles anywhere in the world. And back 

when grizzly bears prowled California, they dug out entire colonies for a snack.” Lord of the Burrows: The 

Incredible Edible Ground Squirrel, http://baynature.org/articles/jan-mar-2008/lord-of-the-burrows
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]

? No interactions between propane and other 

common substances used in agriculture 

were identified. TR 265-266

6. Are there adverse biological and chemical 

interactions in agro- ecosystem? [§6518 m.5]

X The petitioned method of collapsing 

burrows using propane may injure or kill 

nontarget species, including many 

predators of rodents, occupying or living 

nearby the treated burrows. TR 272-273

7. Are there detrimental physiological effects on 

soil organisms, crops, or livestock? [§6518 

m.5]

X The petitioned method of collapsing 

burrows using propane may injure or kill 

nontarget species, including predators of 

rodents, occupying or living nearby the 

treated burrows. TR 272-273

The force produced by the 

propane/oxygen reaction may disturb the 

soil and soil organisms due to the 

concussive forces and/or loud noises 

generated. If a fire is produced from the 

propane explosion, soil structure may be 

altered and soil organic matter may be lost 

or consumed. Reduced soil porosity and 

increased soil pH due to alterations in soil 

chemistry may also be expected. These 

effects can indirectly affect water retention 

of the soil and increase erosion. Because 

propane is readily degraded by soil 

bacteria, soil disturbance related to 

propane itself would not be expected. 

TR 276-284

8. Is there a toxic or other adverse action of the 

material or its breakdown products?

 [§6518 m.2]

X Explosivity.

9. Is there undesirable persistence or 

concentration of the material or breakdown 

products in environment?[§6518 m.2]

X Readily broken down by soil 

microorganisms within 24 hours. TR 200-

201 When exploded, all of the propane is 

consumed in the reaction (CCOF, 2010). TR 

77 All of the propane is consumed in the 

reaction (CCOF, 2010). TR 256-257

10. Is there any harmful effect on human health? 

[§6517 c (1)(A) (i) ; 6517 c(2)(A)I; §6518 

m.4]

X The use of propane/oxygen explosion 

devices also poses a physical safety risk to 

the operator. Improper use and/or 

inadequate safety gear could result in 

injury from explosion, flying debris, or fire 

(Meyer Industries, 2010).

 3 “Interestingly enough, the survival of many other species seems to hinge on the survival of the prairie dog. About 

90% of the [black footed] ferret's diet consists of prairie dogs. In addition, the golden eagle, Ferruginous Hawk, and 

swift fox diets include a large percentage of prairie dogs. According to Nicole Rosmarino/Southern Plains Land 

Trust,(12) the mountain plover appears to be a prairie dog obligate or at the very least is highly dependent on prairie 

dogs for survival, using the borrows for breeding, nesting, and feeding. Burrowing owls, prairie falcons badgers and 

a host of other prairie animals are associated with prairie dog colonies. In fact, some ecologists consider the prairie 

dog to be a keystone species of the prairie(12). According to Miller et. al,(13) nearly 170 species rely on prairie dog 

colonies to some extent for their very survival. Miller further concludes that the prairie dog fits the definition of a 

keystone species because prairie dogs affect the ecosystem structure, function, and composition in a way that is not 

duplicated by other species.” 

http://environmentalchemistry.com/yogi/environmental/200706prairiedogreconciliation.html
TR 308-310

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: odorized propane 

Question Yes No N/A1 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)] 

CO2? TR 325-326

5. Is the substance used in handling, 

not synthetic, but not organically 

produced? 

 [§6517 c (1)(B)(iii)] 

X

6. Are there any alternative 

substances? [§6518 m.6] 

X CO2 asphyxiant, vit D3, TR 316-333

7. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 

X Trapping, supporting predator habitat, flooding, 

ecologically-based rodent management TR 340-367

See additional sources.4 Ground squirrels find and 

reopen collapsed burrows.5

 Habitat modification..6 

Encouraging predators.7

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. 

 4 http://icwdm.org/wildlife/pocketgopher.asp

http://www.unitedwildlife.com/AnimalsPrairieDogs.html

http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7438.html

5 http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7438.html

6

http://environmentalchemistry.com/yogi/environmental/200704prairiedogcontrollethal.html

http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7438.html

http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7433.htmlhttp://environmentalchemistry.com/yogi/environme

ntal/200706prairiedogreconciliation.html

7 http://people.uleth.ca/~michener/predators.htm

http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7433.html

http://yardener.com/YardenersPlantProblemSolver/DealingWithPestAnimals/Gophers/SolutionsForGophers/Dispa

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

Substance: odorized propane

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, and 

biodiversity? [§6517 c (1)(A)(iii); 

6517 c (2)(A)(ii)] 

X Not listed use of synthetic. Fossil fuel source.

Dangers to soil organisms and predators of rodents.

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7] 

X Fossil fuel source.

Dangers to soil organisms and predators of rodents.

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 - ______________________________________

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

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 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