ers formulated in compliance with 21 CFR 178.1010 are acceptable for use in sanitizing shell eggs provided they are
registered with EPA for this use.
The ingredients in the materials used to wash and sanitize eggs must be GRAS ( 21 CFR, 182 and 184) and must be
used in accordance with Good Manufacturing Practices ( 21
CFR 182.1). They also must be listed on Section 205.605 of
the National List, according to Section 205.105(c), to be
allowable in organic.
Useful materials listed at Section 205.605 include non-synthetic citric and lactic acids, sodium carbonate, the synthetic sanitizers chlorine, hydrogen peroxide, ozone and
PAA, and the alkali potassium hydroxide. Many handlers
use potassium hydroxide, which is permitted by FDA. The
National List at Section 205.605(b) permits use of potassium hydroxide except for lye peeling of fruits and vegetables other than peaches, so this use is consistent with the
The use of any substance in organic production or handling is restricted by the organic system plan that must be
agreed to by the producer or handler and the certifying
agent and must be consistent with the organic regulation.
Substances are used for a purpose, and the purpose must
be consistent with all relevant regulations, including those
of FDA, EPA and FSIS, depending upon which agency has
primary responsibility for the agricultural product.
Ultimately, it is important to make all regulatory guidelines as clear and easy to understand as possible. It would
help eliminate much confusion if the organic industry
pushes the NOP to have the NOSB create a list of allowed
and prohibited substances for nonprocessing handling, to accompany existing lists for crop production and processing. o
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Richard C. Theuer, Ph.D., is an adjunct professor in the
Department of Food, Bioprocessing and Nutrition Sciences, North Carolina State University, a consultant to
industry and a member of the OMRI Advisory Council
and the OMRI Processing Review Panel. He was a member of the inaugural National Organic Standards Board (1992–1995),
serving as chair of the NOSB Processing, Handling and Labeling Committee. He served on the OMRI Board of Directors from 2003 to 2009
and chaired the OMRI Board in 2005 and 2006. You can reach him at
Note: The author acknowledges the insightful comments of material
input experts currently with QAI and formerly with the Washington
State Department of Agriculture Organic Program, Oregon Tilth
and Pennsylvania Certified Organic, who kindly reviewed this article. However, the author remains solely responsible for its content.