FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB)

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Date: _ 11/05/09 ____

Subject: _Diethylaminoethanol (CAS # 100-37-8) 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):

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

November 2009 meeting. The Handling Committee originally recommended that 

Diethylaminoethanol 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 Diethylaminoethanol 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 Diethylaminoethanol (CAS # 100-37-8) for use only 

as a boiler water additive for packaging sterilization on §205.605(b) with 9 voting yes, 2 no 

votes, 1 abstention, and 3 absent.

NOSB Vote: Motion: Steve DeMuri Second: Julie Weisman

Board vote: Yes - 9 No- 2 Abstain- 1 Absent - 3 

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 Diethylaminoethanol CAS # 100-37-8

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: 

Diethylaminoethanol was approved by the NOSB with annotation at the May 2002 NOSB 

meeting, after being deferred from the October 2001 meeting pending the receipt of FOIA 

information, and then added to the National List §205.605(b) effective on September 12, 

2006 by Final Rule TM-04-01FR.

Diethylaminoethanol is used primarily as a boiler water additive to inhibit carbonic acid 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 cyclohexylamine, 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 diethylaminoethanol, 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 at both 

meetings at which it was discussed. 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 and May 2002 NOSB meetings 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 

diethylaminoethanol off the list when possible. The compound passed the full board vote with 

10 yes votes and 4 no votes. It has come to the attention of the Handling Committee that 

since the original listing of diethylaminoethanol, many organic processors have either 

replaced diethylaminoethanol 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 diethylaminoethanol in organic handling under 205.605(b). 

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

in response to the Federal register notice of the sunset of diethylaminoethanol (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 diethylaminoethanol on 

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

Moved: Steve DeMuri Second: Julie Weisman

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 Diethylaminoethanol CAS # 100-37-8

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: 

Diethylaminoethanol was approved by the NOSB with annotation at the May 2002 NOSB 

meeting, after being deferred from the October 2001 meeting pending the receipt of FOIA 

information, and then added to the National List §205.605(b) effective on September 12, 

2006 by Final Rule TM-04-01FR.

Diethylaminoethanol is used primarily as a boiler water additive to inhibit carbonic acid 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 cyclohexylamine, 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 diethylaminoethanol, 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 at both 

meetings at which it was discussed. 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 and May 2002 NOSB meetings 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 

diethylaminoethanol off the list when possible. The compound passed the full board vote with 

10 yes votes and 4 no votes. During the original sunset review for this substance, it had come 
to the attention of the Handling Committee that since the original listing of 

diethylaminoethanol, some organic processors had either replaced diethylaminoethanol 

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 diethylaminoethanol containing additives, the committee questioned the need for the 

continued listing of diethylaminoethanol 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 diethylaminoethanol 

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 diethylaminoethanol 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