DEBORAH KLEIN

PRINCIPAL REGULATORY SPECIALIST I

REGULATORY AFFAIRS, NORTH
AMERICAN FOOD, DRUG & COSMETICS
M 336 508 8926 TEAM
1 ECOLAB PLACE
ST. PAUL, MN 55102-1390
Deborah.klein@ecolab.com

November 17, 2017

Re: U.S. USDA National Organic Program (NOP) Compliant Materials

To Whom It May Concern:

There have been questions regarding the compliance of Ecolab products for use under the
National Organic Program (NOP). The NOP identifies specific synthetic and nonsynthetic
substances that are allowed in organic crop production, organic livestock production, and
processed organic food products. These allowed or prohibited substances are listed in 7CFR
Part 205, sections 601-606, otherwise known as the National List.

The attached list of Ecolab cleaning and sanitation products are those that are allowed for
contact with organic food products and consist of synthetic and/or non-synthetic ingredients
that are consistent with 7CFR Part 205.

Cleaning products containing ingredients not on the National List, including alkaline and/or
acid cleaning compounds, general cleaners and detergents, equipment lubricants, hand
washing compounds, etc., can always be used in organic production, provided these materials
do not come into direct contact with the organic food product and/or are removed (rinsed) prior
to running an organic product.

If sanitizers, disinfectants or any other products are used containing materials not on the
National List, the facility must document in the Organic System Plan (OSP) what measures
are employed to prevent contact of the organically produced ingredients or products with
these prohibited substances.

All cleaning, sanitation and disinfecting materials shall be made part of your Organic System
Plan (OSP) and always submitted to your USDA Accredited Certifier for review and approval –
please include appropriate Organic/Standard Operating Procedures (O/SOP’s), labels and
SDS forms for all materials planned to be used.

Finally, the NOP does not issue approval letters for any materials or products. The NOP
National List recognizes only individual raw materials that may or may not be used in certified
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organic operations. The attached list of products includes those Ecolab products meeting the
NOP National List requirements.

If you have any questions, please contact your Ecolab Technical Services or Regulatory
Affairs.

Kind Regards,

Deborah Klein
Principal Regulatory Specialist I
Ecolab Regulatory Affairs

Enclosed: Addendum- Allowed U.S Organic Product List

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Addendum- Allowed U.S. Organic Product List

Detergents INSPEXX 150 (US & CA)

AC-3 3DT INSPEXX 150
ASTRI-L (NA) INSPEXX 250
QUORUM GREEN II (US) TSUNAMI 100 (US & CA)
SODIUM HYDROXIDE ST-300
(CAUSTIC), 50% VICTORY

Sanitizers Laundry Products

ECO-SAN ADVACARE 120
ENVIRO SAN SANITIZER/SOUR
ESTEEM SANI-NC ADVACARE DISINFECTANT
EQUIPMENT SANITIZER ADVACARE OXIDIZER
KAY LIQUID BLEACH CHLORINE BLEACH 2000
KEYSTONE SANITIZER ECOLAB PERFORMANCE
LOW TEMP DISHMACHINE ECO-STAR DESTAINER
SANITIZER FACILIPRO DESTAINER
OXONIA ACTIVE (US & CA) LAUNDRI DESTAINER
PHASE 1 SANITIZER TURBOBRITE
PRISTINE QF
QUINTET CHLORINE SANITIZER Miscellaneous
QUORUM GREEN OXY-PAK S
ULTRA SAN OXY-PAK S10
XY-12 OXY-PAK (US)
PHOSPHORIC ACID FG
Food Contact REDOXX 60 (US)
ANTIMICROBIAL FOOD SURPASS 100 (908877)
ADDITIVE BASE (25 PCT) Astri- CID (CA)
FOOD ADDITIVE ACTIVATOR
CONCENTRATE