FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB)

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Date: _ 11/05/09 ____

Subject: _Cyclohexylamine (CAS # 108-91-8) 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):

Cyclohexylamine, with it’s annotation, was reviewed for sunset by the NOSB at the November 

2009 meeting. The Handling Committee originally recommended that Cyclohexylamine be 

allowed to sunset off the National List, but based on written comments received after the original 

recommendation’s posting disagreeing with the committee’s decision, and verbal public 

comments received during the meeting also in opposition, the Handling Committee reconsidered 

it’s decision and voted to recommend relisting Cyclohexylamine to §205.605(b). Both the 

original and revised Handling Committee recommendations are attached. The board that 

originally listed the substance indicated in it’s discussion that they desired the substance to sunset 

if no longer required in organic manufacturing facilities. The Handling Committee believed that 

use of this volatile amine boiler additive was no longer necessary in the organic food processing 

industry, but public comment indicated otherwise. 

The NOSB voted to recommend relisting of Cyclohexylamine (CAS # 108-91-8) for use only as a 

boiler water additive for packaging sterilization on §205.605(b) with 10 voting yes, 2 no votes, 1 

abstention, and 2 absent.

NOSB Vote: Motion: Steve DeMuri Second: Julie Weisman

Board vote: Yes - 10 No- 2 Abstain- 1 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 Cyclohexylamine CAS # 108-91-8

September 1, 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: 

Cyclohexylamine was approved by the NOSB with annotation at the October 2001 NOSB 

meeting, and added to the National List §205.605(b) effective on September 12, 2006 by 

Final Rule TM-04-01FR.

Cyclohexylamine is used primarily as a boiler water additive to inhibit boiler and pipe 

corrosion caused by steam produced from water with problematic mineral content and 

quality. It is often used in conjunction with other volatile amine containing boiler water 

additives such as octadecylamine and diethylaminoethanol, sometimes in proprietary blends. 

It was originally petitioned as one of a group of four boiler, volatile amine containing, chemical 

additives, diethylaminoethanol, morpholine, octadecylamine, and cyclohexylamine. 

A TAP review dated February 15, 2001 (revised) reviewed cyclohexylamine, and found the 

substance to be toxic to humans through a number of modes, and both the material and it’s 

manufacturing process harmful to the environment. It was considered not compatible with 

organic production or handling practices. Three out of three reviewers recommended it be 

prohibited from use in organic handling operations, and that it not be listed. There was much 

discussion by the board regarding the negative results of the TAP versus the potential 

damage to the organic processing industry if the boiler additive was not allowed. There were 

board members adamantly opposed to it’s listing due to it’s toxic effects on the environment 

and humans, but some, primarily those with processing backgrounds, who claimed the 

material was necessary to maintain the condition of boiler and steam delivery systems in 

organic processing facilities. A compromise position was established through the use of the 

annotation “for use only as a boiler water additive for packaging sterilization”, since this use 

was considered to be more incidental in nature and would result in inconsequential amounts 

of the substance ending up in processed organic products. It was the intent of the board to 

not allow it’s use in steam for direct product contact, such as for heating via direct steam 

injection or sparging, since this would result in more of the compound in the finished organic 

processed product. A review of the transcripts from the October 2001 NOSB meeting 

indicated that there was hopeful sentiment among some board members that the industry 

would implement more organic compatible methods for minimizing boiler steam corrosion, or 

mitigate the use of the compound during organic production runs, and that future boards 

would consider sunsetting cyclohexylamine off the list when possible. The compound 

narrowly passed the full board vote with 8 yes votes, 3 no votes, and 3 abstentions (recusals) 

for conflict of interest reasons. It has come to the attention of the Handling Committee that 

since the original listing of cyclohexylamine, many organic processors have either replaced 

cyclohexylamine containing boiler additives with less toxic, non-volatile substances, turn off 
the boiler chemical feed prior to and during organic production runs, or they have 

implemented product contact mitigation procedures, such as a hot water rinse of packaging 

materials after steam treatment. The committee questions the need for the continued listing 

of cyclohexylamine in organic handling under 205.605(b). 

The NOSB has received 3 public comments in support of the relisting of cyclohexylamine in 

response to the Federal register notice of the sunset of cyclohexylamine (AMS-TM-07-0136), 

but none of those comments provided specific reasons for the relisting of the substance, or 

explained why alternate substances or mitigation procedures could not be implemented. One 

general public comment was received objecting to the relisting of all substances subject to 

sunset.

III. Committee Recommendations

The Handling Committee recommends the continued listing of Cyclohexylamine on 

§205.605(b) for use only as a boiler water additive for packaging sterilization. 

Moved: Steve DeMuri Second: Joe Smillie

Committee Vote: Yes- 0 No- 5 Absent- 1 Abstain- 0 Recuse- 0
National Organic Standards Board

Handling Committee Recommendation for §205.605(b)

Sunset of Cyclohexylamine CAS # 108-91-8

November 4, 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: 

Cyclohexylamine was approved by the NOSB with annotation at the October 2001 NOSB 

meeting, and added to the National List §205.605(b) effective on September 12, 2006 by 

Final Rule TM-04-01FR.

Cyclohexylamine is used primarily as a boiler water additive to inhibit boiler and pipe 

corrosion caused by steam produced from water with problematic mineral content and 

quality. It is often used in conjunction with other volatile amine containing boiler water 

additives such as octadecylamine and diethylaminoethanol, sometimes in proprietary blends. 

It was originally petitioned as one of a group of four boiler, volatile amine containing, chemical 

additives, diethylaminoethanol, morpholine, octadecylamine, and cyclohexylamine. 

A TAP review dated February 15, 2001 (revised) reviewed cyclohexylamine, and found the 

substance to be toxic to humans through a number of modes, and both the material and it’s 

manufacturing process harmful to the environment. It was considered not compatible with 

organic production or handling practices. Three out of three reviewers recommended it be 

prohibited from use in organic handling operations, and that it not be listed. There was much 

discussion by the board regarding the negative results of the TAP versus the potential 

damage to the organic processing industry if the boiler additive was not allowed. There were 

board members adamantly opposed to it’s listing due to it’s toxic effects on the environment 

and humans, but some, primarily those with processing backgrounds, who claimed the 

material was necessary to maintain the condition of boiler and steam delivery systems in 

organic processing facilities. A compromise position was established through the use of the 

annotation “for use only as a boiler water additive for packaging sterilization”, since this use 

was considered to be more incidental in nature and would result in inconsequential amounts 

of the substance ending up in processed organic products. It was the intent of the board to 

not allow it’s use in steam for direct product contact, such as for heating via direct steam 

injection or sparging, since this would result in more of the compound in the finished organic 

processed product. A review of the transcripts from the October 2001 NOSB meeting 

indicated that there was hopeful sentiment among some board members that the industry 

would implement more organic compatible methods for minimizing boiler steam corrosion, or 

mitigate the use of the compound during organic production runs, and that future boards 

would consider sunsetting cyclohexylamine off the list when possible. The compound 

narrowly passed the full board vote with 8 yes votes, 3 no votes, and 3 abstentions (recusals) 

for conflict of interest reasons. It had come to the attention of the Handling Committee that 

since the original listing of cyclohexylamine, some organic processors had either replaced 

cyclohexylamine containing boiler additives with less toxic, non-volatile substances, were 

turning off the boiler chemical feed prior to and during organic production runs, or they had 
implemented product contact mitigation procedures, such as a hot water rinse of packaging 

materials after steam treatment. 

Based on the knowledge that at least some organic processors had found alternatives to 

using cyclohexylamine containing additives, the committee questioned the need for the 

continued listing of cyclohexylamine in organic handling under 205.605(b), and rejected 

relisting by a vote of 5 against, 0 in favor, 1 absent, 0 abstaining, and 0 recusals. 

Since the original recommendation dated September 1, 2009 was posted, the NOSB has 

received 9 comments related to the Handling Committees original recommendation. 

Comments were received from organic manufacturers, certifiers, trade associations, and 

consultants to the organic industry. All comments disagree with the September 1, 2009 

recommendation, stating that this substance is still a necessary additive to boiler feed water 

of some organic operations to minimize corrosion of boilers and steam lines, especially for 

manufacturers who run predominantly organic products, and whose facilities are located in 

areas where water quality is exceptionally poor. There were no comments posted that agreed 

with the Handling Committees original decision. Although the Handling Committee had 

evidence that some organic processors had taken steps to eliminate cyclohexylamine from 

their operations boiler systems, it was impossible for members to survey every manufacturer 

in every situation to determine if this substance was still necessary for some. The public 

comment process worked as it was designed, providing the committee with timely information 

regarding the necessity for continued use of this material. 

III. Committee Recommendations

The Handling Committee recommends the continued listing of Cyclohexylamine on 

§205.605(b) for use only as a boiler water additive for packaging sterilization. 

Moved: Steve DeMuri Second: Julie Weisman

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