FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB)

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Date: 11/05/09 ____

Subject: _Tetrasodium Pyrophosphate (CAS # 7722-88-5) Sunset Review ___

Chair: __Jeff Moyer ______________

Recommendation

The NOSB hereby recommends to the NOP the following:

Rulemaking Action: ___X __

Guidance Statement: ________

Other: ________

Summary Statement of the Recommendation (including Recount of Vote):

Tetrasodium Pyrophosphate (TSPP), with it’s annotation, was reviewed for sunset by the NOSB 

at the November 2009 meeting. A summary of the Handling committee’s recommendation is 

attached. No comments were received during the meeting that disagreed with the committee’s 

recommendation. 

The NOSB voted to recommend relisting of Tetrasodium Pyrophosphate (CAS #7722-88-5) for 

use only in meat analog products on §205.605(b) with 13 voting yes, 0 no votes and 2 absent.

NOSB Vote: Motion: Steve DeMuri Second: Dan Giacomini

Board vote: Yes - 13 No- 0 Abstain- 0 Absent - 2 

Summary Rationale Supporting Recommendation (including consistency with OFPA and 

NOP):

Response by the NOP:
National Organic Standards Board

Handling Committee Recommendation for §205.605(b)

Sunset of Tetrasodium Pyrophosphate

September 9, 2009

I. List: 

National Organic Program Subpart G: The National List of Allowed and Prohibited 

Substances. §205.605 Nonagricultural (nonorganic) substances allowed as ingredients 

in or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)).”

(b) Synthetics allowed

II. Committee Summary: 

Tetrasodium pyrophosphate (TSPP) was added to the National List §205.605(b) effective on 

September 12, 2006 by Final Rule TM-04-01FR based on the NOSB recommendation of 

April 2004. It carries the annotation “for use only in meat analog products”. 

Tetrasodium pyrophosphate (CAS # 7722-88-5) was originally petitioned for use as a pH 

buffer and dough conditioner for use in organic meat alternative products. It is a relatively 

common GRAS food additive with USDA and FDA approval for many functions in 

conventional foods, as an emulsifier, buffer, nutrient, dietary supplement, sequestrant, and 

texturizer. According to the TAP review, dated July 29, 2002, TSPP is prepared by molecular 

dehydration of dibasic sodium phosphate at 500 degrees C. Relatively minor negative 

environmental impact from manufacture and use is usually associated with it’s application in 

the detergent industry, not from it’s food uses. TSPP has been linked to kidney damage in rat 

studies, but most of the literature cited in the TAP referred to health effects related to it’s 

medical, not food, uses, and reviewers did not convey concern over it’s health effects on 

humans. 

All reviewers agreed that the substance is a synthetic. One recommended it be listed on the 

National List for the petitioned use, with limits as per Good Manufacturing Practices, but two 

reviewers were of the opinion it should not be listed. It passed a full NOSB vote for listing in 

April 2004, 10 yes, 3 no, and 1 absent. 

The NOSB has received three public comments in support of, and no public comments 

opposed to, the relisting of Tetrasodium pyrophosphate in response to the Federal register 

notice of the sunset of Tetrasodium pyrophosphate (AMS-TM-07-0136). No new information 

has been brought forward or discovered that causes the Handling Committee to recommend 

against the relisting of this substance. 

III. Committee Recommendations

The Handling Committee recommends the continued listing of Tetrasodium pyrophosphate 

(CAS # 7722-88-5) – for use only in meat analog products in the National List section 

206.605(b).

 

Moved: Steve DeMuri Second: Joe Smillie 

Committee Vote: Yes- 5 No- 0 Absent- 1 Abstain- 0 Recuse- 0