Sunset Materials NOSB Fall 2015
How many inputs
have we reviewed
containing the
material noted?
How many MOSA
certified products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
Sunset 2017 Crop Materials §205.601
Alcohol: Ethanol, Isopropanol
Chlorine Materials: Calcium hypochlorite,
Chlorine dioxide, Sodium hypochlorite
2
Hydrogen peroxide
5
Soap-based algicide/demossers
Herbicides, soap-based
Newspaper or other recycled paper
Plastic mulch and covers
Soaps, ammonium
Ammonium carbonate
Boric acid
Elemental sulfur
Lime sulfur
Oils, horticultural
Soaps, insecticidal
Sticky traps/barriers
Sucrose octanoate esters
Pheromone
Vitamin D3
Coppers, fixed
3
7
Chlorine is
widely used as
a sanitizer on
vegetable
operations
This is a very
common
general
purpose
sanitizer
Widely used
Widely used
2
Safer Brand
Soaps comes to
mind and we
see that they
are widely
used.
Widely used
1
3
2
25
Widely used
Coppers are
commonly
used for blight
control in
solanaceous
crops.
Page | 1
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
Copper sulfate
100
Hydrated lime
Potassium bicarbonate
Aquatic plant extracts
Humic acids
4
2
2
90
Lignin sulfonate
Magnesium sulfate
20
75
Micronutrients: Soluble boron products,
Sulfates, carbonates, oxides, or silicates
of zinc, copper, iron, manganese,
molybdenum, selenium, and cobalt
Liquid fish products
150
Vitamin B1, C, E
10 20 10
Lignin sulfonate
Ethylene
Sodium silicate
EPA List 4 - Inerts of Minimal Concern
50+
Microcrystalline cheesewax
150
How many MOSA
certified products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
Coppers are
commonly
used for blight
control in
solanaceous
crops.
Common
fertilizer
ingredient
Epsom salts are
very commonly
used
particularly by
produce
growers
Very commonly
used
Very commonly
used
Rarely used
individually but
are included as
an ingredient
in some of the
products we
see for fertility.
Allowed inerts
need clarity
We certify
growers using
cheesewax in
their organic
mushroom
production.
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Sunset Materials NOSB Fall 2015
How many inputs
have we reviewed
containing the
material noted?
205.602 Prohibited nonsynthetic substances
Ash from manure burning
Arsenic
Lead salts
Potassium chloride
12
How many MOSA
certified products
contain the
material noted?
How many
clients use the
material
noted?
Some do
Comments on
material?
What is
excessive
content of
chloride in the
soil?
Sodium fluoaluminate
Strychnine
Tobacco dust (nicotine sulfate)
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Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
Sunset 2017 Livestock Materials §205.603
Alcohols: Ethanol, Isopropanol
30 and 8
Aspirin
Atropine
Biologics, Vaccines
Butorphanol
Chlorhexidine
7
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
Teat care appears to
be the most common
use we see
Very widely used
34
Extremely commonly
used – we allow
vaccines.
21 teat care
products and 16
other products
Used under
restriction,
particularly in
freezing
temperatures where
teats freezing may
occur or when SCC is
very high
Very very commonly
used for equipment
cleaning and
sanitation
Very commonly used
for dire medical
situations. We
request clarity on
single ingredients
allowed. Example –
sodium lactate;
calcium gluconate;
calcium propionate,
glycine, etc.
Not very common,
but in use on some
farms
Chlorine Materials: Calcium
hypochlorite, chlorine dioxide,
sodium hypochlorite
40
Electrolytes
50+
Flunixin
3
Furosemide
Glucose
10
Glycerin
Hydrogen peroxide
165
40
Commonly used
electrolyte ingredient
Very common
Commonly used as a
sanitizer. Common
alternative teat dip
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Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
Iodine
175
Magnesium hydroxide
Magnesium sulfate
5
43 medical
products
Oxytocin
Parasiticides: Fenbendazole
3
Parasiticides: Ivermectin
9
Parasiticides: Moxidectin
1
Peroxyacetic/Peracetic acid
Phosphoric acid
40+
Poloxalene
Tolazoline
Xylazine
1
1
1
Copper sulfate
15
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
and wound
treatment material
Extremely common in
teat dips and for
wound care. Not so
common as a
sanitizer in other
ways. 115 dips (50
with declared NPEs);
60 other products (10
with declared NPEs).
AAFCO mineral too =
196 products
An important tool for
some farmers for use
according to
restrictions, but not
super common.
Some milk buyers
prohibit use
Plan for use must be
approved.
Emergency use only
Plan for use must be
approved.
Commonly used in an
emergency
Plan for use must be
approved.
Emergency use only
Commonly used for
equipment sanitation
Commonly used for
equipment sanitation
Use is not
widespread but this
material is regularly
used by some MOSA
farmers
Very common hoof
Page | 5
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
treatment. Zinc
sulfate is an
alternative that’s
frequently requested.
Formic Acid
Iodine
See info above on
iodine
Used sometimes with
alterations
Lidocaine
Lime, hydrated
Mineral oil
1
Commonly used
topically with fly
control products and
also used as a
lubricant
We do not observe
this material being
used
Procaine
Sucrose octanoate esters
Methionine
1
45+
Trace minerals
650 + feeds;
250+ healthcare
Vitamins
420+ feeds;
230+ healthcare
EPA List 4 - Inerts of Minimal
Concern
Excipients
550+
Very common in
poultry rations
Very common almost every
livestock farm
Very common almost every
livestock farm
Clarity needed
Especially important
in teat dips and
health care products.
We feel clear, but
recognize that
there is some lack
of clarity with
defining ‘drug’. We
also request
recognition of
specific lists where
materials must be
listed.
Page | 6
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
205.602 Prohibited nonsynthetic substances
Strychnine
Sunset 2017 Handling Materials §205.605(a)
Acid, Alginic
Acid, Citric
How many
clients use the
material
noted?
Comments on
material?
We do have
clients using
this. Our
database does
not allow
numerical
data
Our understanding is
that most
commercially
available citric acid is
derived by microbial
fermentation of
carbohydrate
substances
Primarily for carcass
wash. Many of our
meat processors use
lactic acid.
Acid, Lactic
Attapulgite
Bentonite
Calcium carbonate
Very common carrier
in feed products
Calcium chloride
Used by some
cheese
makers.
Every cheese
processor
uses them
Dairy cultures
Diatomaceous earth
Enzymes
Flavors
Many
Many of our
cheese
processors
use nonanimalderived
enzymes.
We also allow
many
examples of
wood being
used for its
Many of them have
ag ancillary
ingredients
Sometimes used as a
filtration aid for
liquid products like
syrup
Many of them have
ag ancillary
ingredients
Requiring
commercial
availability for flavors
is consistent with the
rule and would open
Page | 7
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
flavoring
characteristics
– whiskey
barrels,
smoked
meats…
a market for them.
Use of NFs allow the
use of nonorganic
agriculturals in
processed products.
Declaration form
developed
collaboratively by
several certifiers is
very useful in
ascertaining needed
information from an
industry that is very
protective of
formulation
information.
Determining ag vs.
nonag can be a
challenge.
There is a national
shortage of whiskey
barrels and to
require organic is
impractical. Some
certifiers do not
review use of barrels
as a flavor issue
Kaolin
Magnesium sulfate
Nitrogen
Oxygen
Perlite
Potassium chloride
Potassium iodide
Sodium bicarbonate
We have seen
use in
packaging
We might benefit
from more education
regarding the oil-free
restriction. We seem
to recall this is rarely
at issue.
Used in the baking
Page | 8
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
industry.
Sodium carbonate
Waxes (Carnauba)
Waxes (Wood rosin)
Yeast
§205.605(b) Synthetics Allowed
Acidified sodium chlorite
Alginates
Ammonium bicarbonate
Ammonium carbonate
Ascorbic acid
Calcium citrate
Calcium hydroxide
Calcium phosphates: monobasic,
dibasic, tribasic
Carbon dioxide
Chlorine Materials: calcium
hypochlorite, chlorine dioxide,
sodium hypochlorite
Ethylene
Ferrous sulfate
Glycerides: mono and di
Glycerin
“That avocado may
not be 100%
organic.” This can
create some
confusion at the
retail level when
used on produce.
Shelf displays may
not enable
consumers to know
what’s waxed and
what isn’t. Nonretail
cases also may not
declare use of waxes.
See comment under
carnauba.
Many ancillary
substances.
Some use.
Some use
Some use
Commonly used
NOP instruction on
use is very helpful
and reasonable
See the separate
petition to list
glycerin at 606.
Seems reasonable.
This states that
saponification of
Page | 9
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
ORGANIC fats and
oils, using a National
List-consistent alkali,
enables a product to
be both synthetic
and organic. This is
useful precedent
when looking at
other saponified
products.
Used by many.
Common sanitizer
component.
Sometimes found as
an additive in salt,
but deemed to affect
label claim, so
operators choose
alternatives
Hydrogen peroxide
Magnesium carbonate
Magnesium chloride
Magnesium stearate
Nutrient vitamins and minerals
Ozone
Comments on
material?
Definitely
used by some
Used by
some.
There are ancillary
substances. We
verify non-GMO
ancillaries. Waterbased or non-GMO
oil-based have been
allowed. Liquid
formulations are
understood to be
important for proper
dispersal within
products.
Generally promoted
as a very green
sanitizer option. We
have determined
that use in water or
in atmosphere does
not affect the 100%
organic claim. This
enables operators to
use a sanitizer
Page | 10
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
without affecting the
sensible 100%
organic status of
their single
ingredient fruits and
such.
Common dairy
sanitizer.
Phosphoric acid
Potassium acid tartrate
Potassium carbonate
Potassium citrate
Potassium phosphate
Sodium citrate
Sodium hydroxide
Used mostly as a
cleaning agent for
milk-lines & for egg
washes. Use of NaOH
has removed
processed products
from 100% category.
Used in making
processed cheese
products.
Sodium phosphates
Sulfur dioxide
Tocopherols
This is used in some
personal care
products.
Xanthan gum
§205.606 Nonorganically produced agricultural products
1 at least.
Casings
Definitely
used by meat
processors.
Celery powder
Comments on
material?
Overall, MOSA doesn’t
see many ingredients
listed on .606. The one
that is most prevalent
is pectin.
We also see use of
cellulose casings. We
have prohibited use
of collagen casings,
unless they’re
obviously peelable
and not intended to
be eaten.
We believe we’ve
Page | 11
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
seen this used for
technical/functional
effect in meat
processing.
Chia (Salvia hispanica L.)
Colors (various)
1
Dillweed oil
Fish oil
Fructooligosaccharides
At least one mfr. has
switched to organic.
Galangal, frozen
Gelatin
Used by a few
Gums: Arabic, Carob bean, Guar, Locust
A few
bean
Inulin-oligofructose enriched
Kelp
We do see use of
colors, and
sometimes a color is
a combination of
materials on .606.
Use of an affidavit as
has been used for
flavors would be
good. We’ve not
developed this.
Consider need for
use in encapsulation.
There may now be
some organic
capsules, but these
may not be
appropriate for all
uses.
Sometimes we see
products that
combine organic and
nonorganic gums.
Organic sources of
some of these are
available and used.
We believe we’ve
seen operations
switch to organic
Must be organic in
livestock feed, but
not always in human
consumption
products.
Page | 12
Sunset Materials NOSB Spring 2015
How many inputs
have we reviewed
containing the
material noted?
Konjac flour
Lecithin—de-oiled
Lemongrass-frozen
Orange pulp, dried
Orange Shellac - unbleached
Pectin (non-amidated forms only)
How many
MOSA certified
products
contain the
material noted?
How many
clients use the
material
noted?
Comments on
material?
Chocolate
companies
Jam/jelly
processors &
some dairy
processors –
(5-10 total)
Peppers (Chipotle chile)
Seaweed, Pacific kombu
Starches, Cornstarch (native), Sweet
potato
Turkish bay leaves
Wakame seaweed (Undaria
pinnatifida)
Whey protein concentrate
MOSA
certifies a
major supplier
Page | 13