Peracetic Acid

Crops

Identification
Chemical Name(s): CAS Number:
Peroxyacetic Acid 79-21-0
Ethaneperoxic Acid
Other Codes:
Other Names: NIOSH Registry Number: SD8750000
PAA, Per Acid, Periacetic acid UN/ID Number: UN3105

Summary Recommendation
Synthetic / Allowed or Suggested
Non-Synthetic: Prohibited: Annotation:
Synthetic Allowed 1. Allowed to disinfect equipment. Prohibited for soil (field)
(consensus) (consensus) application. Allowed to disinfect seed and asexually propagated
planting material (i.e., bulb, corm, tuber) used for planting crops.
From hydrogen peroxide and fermented acetic acid sources only.
(consensus)
2. Allowed for fireblight control with Experimental Use Permit with
documentation that alternatives including biocontrols have been
tried. (1 in favor, 2 against)

Characterization
Composition:
C2H4O3. Peracetic acid is a mixture of acetic acid (CH3COOH) and hydrogen peroxide (H2O2) in an aqueous
solution. Acetic acid is the principle component of vinegar.

Properties:
Peracetic acid is a very strong oxidizing agent and has a stronger oxidation potential than chlorine or chlorine
dioxide. It is a clear, colorless liquid with no foaming capability. It has a strong pungent acetic acid odor, pH is
acid (2.8), specific gravity is 1.114, and weighs 9.28 pounds per gallon. Stable upon transport.

How Made:
Peracetic acid (PAA) is produced by reacting acetic acid and hydrogen peroxide. The reaction is allowed to
continue for up to ten days in order to achieve high yields of product according to the following equation.

O O
|| ||
CH3-C-OH + H2O2 CH3C-O-OH + H2O
acetic acid hydrogen peroxyacetic
peroxide acid

The NOSB recommended that hydrogen peroxide be added to the National List of synthetic substances
allowed for crop production (Austin, 1995).

Due to reaction limitations, PAA generation can be up to 15% with residual levels of hydrogen peroxide (up to
25%) and acetic acid (up to 35%) with water up to 25%. Additional methods of preparation involve the
oxidation of acetaldehyde or alternatively as an end product of the reaction of acetic anhydride, hydrogen
peroxide, and sulfuric acid.

Additional methods of preparation involve the oxidation of acetaldehyde (Budavari, 1996). Another method
involves the reaction of tetraacetylethylenediamine (TAED) in the presence of an alkaline hydrogen peroxide
solution (Davies and Deary, 1991). These sources appear to be used more frequently in pulp, paper, and textile
manufacture (Pan, Spencer, and Leary, 1999).

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Specific Uses:
Its major use in the food industry is as a sanitizer. Peroxyacetic acid is used to control deposits, odor, biofilms
from food contact surfaces, and as a microbial control agent for both food contact surfaces and direct contact
with fruits and vegetables.

Action:
The primary mode of action is oxidation. PAA disinfects by oxidizing of the outer cell membrane of vegetative
bacterial cells, endospores, yeast, and mold spores. The mechanism of oxidation is the transfer of electrons,
therefore the stronger the oxidizer, the faster electrons are transferred to the microorganism and the faster the
microorganism is inactiviated or killed. It has also been reported to be virucidal (Arturo-Schaan, 1996).

Combinations:
Peracetic acid usually occurs with hydrogen peroxide, acetic acid, and a stabilizer in an aqueous solution. Most
stabilizers used are EPA List 3 (unknown toxicity) and are not considered in this TAP review.

Status
OFPA
Falls under Production Aid (7 USC 6517(b)(1)(C)(i)).

Regulatory
EPA regular Section 3 registration (40 CFR 152.25(a)). First registered in 1985 (US EPA, 1993). Registered for
indoor use only (US EPA, 1993). Some Special Local Need registrations (40 CFR 160) may have been granted
for specific crops and applications (Cal-EPA, 2000).

EPA/NIEHS/Other Appropriate Sources

OFPA 6518 (l)(1) states, “In establishing the National List or proposed amendments to the National List, the
Board shall review available information from the Environmental Protection Agency, the National Institute of
Environmental Health Studies, and such other sources as appropriate, concerning the potential for adverse
human and environmental effects of substances considered for inclusion in the proposed National List.”

EPA: It is on EPA’s Extremely Hazardous Substances list (US EPA, 2000). See the Re-registration Eligibility
Document for Peroxy Compunds (US EPA, 1993).

NIEHS: See attachment from the National Toxicology Program.

Other sources: See New Jersey Department of Health and Senior Services attachment.

Status Among U.S. Certifiers

None appear to explicitly allow it for crop use.

Historic Use
Peracetic acid was patented in 1950 to treat fruits and vegetables to reduce spoilage from bacteria and fungi
destined for processing (Greenspan and Margulies, 1950). It has since been used in systems to disinfect
recirculated wash water used to handle fresh produce (Lokkesmoe and Olson, 1995). It is used to treat bulbs
(Hanks and Linfield, 1999), to disinfect potting soil, clean irrigation equipment, (Larose, 1998), and in seed
treatment to inactivate fungal or other types of plant disease. While there is a long history of experimental field
use as a fungicide / bactericide, efficacy has only recently been established (Hei, 2000). Peracetic acid is
effective at reducing Escherichia coli O157:H7 on apples when used in a wash and as a chemical sanitizer (Wright
et al., 2000).

International
Peracetic acid does not appear on IFOAM Appendix 2 for Plant Pest and Disease Control (IFOAM, 2000). It
does not appear on EU 2092/91 Annex II. Field use of this material is not allowed under any known
International Organic Standards. Post-harvest application is discussed in the processing TAP review.

OFPA 2119(m) Criteria

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1. The potential of such substances for detrimental chemical interactions with other materials used in organic farming systems.
This material is a strong oxidizing agent. It can react violently with acetic acid anhydride, olefins (e.g.,
mineral oil), and organic matter (NTP, 2000).

2. The toxicity and mode of action of the substance and of its breakdown products or any contaminants, and their persistence and
areas of concentration in the environment.
Toxicity high via oral for guinea pigs; moderate via oral and dermal routes for rats and rabbits (Sax, 1979).
Skin and Eye Irritation Data: skin-rabbit 500 mg open SEV; eye-rabbit 1 mg SEV (NTP, 2000). An
experimental neoplastinogen (tumor-causing agent) via dermal route (NTP, 2000). It is on EPA’s
Extremely Hazardous Substances list (US EPA, 2000).

Peracetic acid is an irritant of the skin, eyes, mucous membranes, and respiratory tract (NTP, 2000;
Budavari, 1996; Lenga, 1985). When heated to decomposition, it emits acrid smoke and toxic fumes of
carbon monoxide and carbon dioxide. The vapor is heavier than air and can travel a considerable distance
to a source of ignition and flash back (NTP, 2000). Breakdown products are acetic acid (same acid found
in vinegar at 5% level) and hydrogen peroxide that breaks down to O2 and H2O.

The primary mode of action is oxidation. with mechanism of oxidation is the transfer of electrons,
therefore the stronger the oxidizer, the faster electrons are transferred to the microorganism and the faster
the microorganism is inactivated or killed.

Table 1
Oxidation Capacity of Selected Sanitizers
Sanitizer eV*
Ozone 2.07
Peracetic Acid 1.81
Chlorine dioxide 1.57
Sodium hypochlorite (chlorine bleach) 1.36
*electron-Volts

Therefore PAA has a higher oxidation potential than chlorine sanitizers but less than ozone.

3. The probability of environmental contamination during manufacture, use, misuse or disposal of such substance.
Production from hydrogen peroxide and acetic acid would depend on the process used. Hydrogen
peroxide is commonly produced by the electrolysis of water (Kirchner, 1981). Acetic acid may be
produced by fermentation (vinegar) or distillation from plant sources. However, acetic acid may also be
synthesized by hydrolysis of acetylene or oxidation of acetylaldehyde (Budavari, 1996). Acetylene and
acetaldehyde are generally produced from petrochemical sources. The environmental consequences of
petroleum production and refining are beyond the scope of this TAP review.

Misuse in handling would cause a bleaching out effect on the color of fresh fruits and vegetables resulting
in loss of quality that could be visually detected. Under normal use and disposal conditions, PAA
decomposes into acetic acid, oxygen, and water.

4. The effect of the substance on human health.

Peracetic acid is an irritant of the skin, eyes, mucous membranes, and respiratory tract (NTP, 2000;
Budavari, 1996; Lenga, 1985). When heated to decomposition, it emits acrid smoke and toxic fumes of
carbon monoxide and carbon dioxide. The vapor is heavier than air and can travel a considerable distance
to a source of ignition and flash back (NTP, 2000).

While it is not rated as a carcinogen by itself (NTP, 2000), studies indicate that it is a possible co-
carcinogen, promoting tumor production by known carcinogens (Bock, Myers, and Fox, 1976, from
abstract).

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5. The effects of the substance on biological and chemical interactions in the agroecosystem, including the physiological effects of the
substance on soil organisms (including the salt index and solubility of the soil), crops, and livestock.
The substance is used because of its biological and chemical interactions and its physiological effects on
microorganisms, including many that are naturally found in a soil environment. Among the model
organisms that show significant reductions in populations after exposure to PAA are Bacillus cereus
(Blackiston et al., 1999); B. subtilis (Leaper, 1984; Blackiston et al., 1999; Lindsay and von Holy, 1999); B..
stearothermophilus (Blackiston et al., 1999); Clostridium botulinum (Blackiston et al., 1999); C. butyricum
(Blackiston et al., 1999); C. sporogenes (Blackiston et al., 1999); Ditylenchus dipsaci (Hanks and Linfield, 1999);
Enterococcus faecium (Andrade et al., 1998); Escherichia coli (Arturo-Schaan et al., 1996), including E. coli
O157:H7 (Farrell et al., 1998), Fusarium oxysporum (Hanks and Linfield, 1999); Gluconobacter oxydans
(Winniczuk and Parish, 1997), Lactobacillus plantarum (Winniczuk and Parish, 1997), L. thermophilus
(Langeveld and Montfort-Quasig, 1996); Leuconostoc mesenteroides (Winniczuk and Parish, 1997); Listeria
monocytogenes (Mosteller and Bishop, 1993; Restaino et al., 1994); Pseudomonas aeruginosa (Restaino et al.,
1994; Lambert et al., 1999); P. fluorescens (Mosteller and Bishop, 1993; Lindsay and von Holy, 1999);
Saccharomyces cerevisiae(Winniczuk and Parish, 1997); Salmonella typhimurium (Restaino et al., 1994);
Staphylococcus aureus (Restaino et al., 1994; Lambert et al., 1999); Streptococcus delbreuckii subsp bulgaricus
(Langeveld and Montfort-Quasig, 1996); and
Yersinia enterocolitica (Mosteller and Bishop, 1993).

The immediate effect against soil organisms would be broad-spectrum and, if mishandled, potentially
violent. The toxic effects would be short-lived, and somewhat selective, favoring acid-tolerant and aerobic
bacteria. For example, experimental evidence indicates that Bacillus spp. would likely be less affected and
would recover more quickly than Clostridium spp. (Blackiston et al., 1999). However, at least one study
indicates no difference between the susceptibility of plasmid-containing E. coli strains and those strains
that do not contain plasmids (Arturo-Schaan, 1996). The breakdown products--oxygen, water, and acetic
acid--are all part of the agroecosystem. Acetic acid is produced in nature as a function of acetobacter
species of microorganism found in soil, and is part of the natural carbon cycle (Alexander, 1991).

Salt Index: The salt index has not been calculated for this substance.

Solubility: Water: 100mg/ml at 19°C. (freely soluble). Also soluble in alcohol.

6. The alternatives to using the substance in terms of practices or other available materials.
Organic alternatives for post-harvest handling include hot water and steam. It is an alternative to such
conventional treatments as formaldehyde and thiabendazole (Hanks and Linfield, 1999).

For fireblight control: Cultural practices such as pruning and sanitation; biological controls such as
Pseudomonas fluorescens (non-GMO); and copper products. Antibiotics such as oxytetracycline and
streptomycin are registered for fireblight. The NOSB recommended that these be added to the National
List (Austin, 1995).

7. Its compatibility with a system of sustainable agriculture.

Peracetic acid is a synthetic pesticide. As such, it is in a category that is generally considered incompatible
with sustainable agriculture, with only a few exceptions. PAA’s broad-spectrum nature and its tendency to
oxidize organic matter make it antagonistic to organic farming systems. The short period that it has had a
field use label means that there is little experience with how the material fits into organic farming systems.
There are a number of reasons to think that it is compatible with a system of sustainable agriculture. Given
that the compound is made from and decomposes into acetic acid and water, it appears to have a similar
compatibility to those parent substances.

TAP Reviewer Discussion

TAP Reviewer Comments

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OMRI’s information is enclosed in square brackets in italics. Where a reviewer corrected a technical point (e.g., the word should be
“intravenous” rather than “subcutaneous”), these corrections were made in this document and are not listed here in the Reviewer
Comments. The rest of the TAP Reviewer’s comments are listed here minus any identifying comments and with corrections of typos.

Reviewer #1
[Organic farmer and research plant pathologist]
After reviewing the documentation on Peracetic Acid I recommend that the product should be listed as
Synthetic, Allowed as a sanitizer for disinfecting surfaces of equipment, floors, walls, and indoor processing
and packaging facilities, and as a post-harvest treatment of fruits and vegetable surfaces at the lowest effective
dilution possible in the literature. All treated surfaces including vegetables and fruits should be rinsed with
water following the treatment. I recommend it should be Allowed with annotation as a microbiocide for
disinfecting seed and asexually propagated planting material (i.e., bulb, corm, tuber). I recommend that it
should be Prohibited for soil (including soil mixes) or plant application.

Justification: Peracetic Acid appears to be an effective microbiocide for disinfecting equipment, seeds, plant
materials, and as a post-harvest treatment of fruits and vegetables. However, Peracetic Acid is a hazardous
substance to work with and therefore protective clothing, eye gear, and respiratory equipment is required (U.S.
EPA, 2000). Peracetic acid breaks down to acetic acid, water, and oxygen that naturally occur in the
agroecosystem (Alexander, 1991). It has the advantage over chlorination, which can seriously damage aquatic
life and the formation of chlorinated hydrocarbons with mutagenic or carcinogenic properties (Arturo-Schaan,
1996). Additionally, the microbial activity of hypochlorite is reliant on environmental factors such as the pH,
temperature, organic load, and ionic concentration of the solution and may not be an effective disinfectant if
conditions are not monitored closely (Wright et al., 2000). The Guide to Minimize Microbial Food Safety
Hazards for Fresh Fruits and Vegetables (U.S. Dept Health and Human Services and Food and Drug
Adminstration, 1998) was published as a result of President Clinton’s 1997 Food Safety Initiative (“Radio
Address of the President to the Nation” January 25, 1997). The guide outlines steps to decrease the
probability of contaminating food and food products with food pathogens. Organic growers need to have
effective microbiocides available for use in their packaging and processing operations.

Peracetic Acid should be Allowed with annotation as a microbiocide for disinfecting seed and asexually
propagated planting materiel (i.e., bulb, corm, tuber) used for planting crops. The annotation should be that it
is allowed only in cases where there are documented plant or human pathogens or pests present that can not be
eliminated by hot water or temperature treatments. Such treatments should be limited to an indoor
environment with ventilation systems available and proper handling procedures followed.

Peracetic Acid should be Prohibited for soil (including soil mixes) or plant application including use for
fireblight. Its broad-spectrum, non-specific mode of action makes it incompatible to organic farming systems.
Additionally, its extremely hazardous classification with potential handling, reactivity, and human exposure
dangers may have greater implications in situations where the product is sprayed in an outdoor, less controlled
environment. There are effective organic alternatives to disinfecting materials used in soil mixes that include
heat and steam. For fireblight control cultural practices, copper products and biological control (Pseudomonas
fluorescens) options are available. Additionally, cultivars with better resistance to the pathogen should be
employed. Antibiotics such as oxytetracycline and streptomycin are registered for fireblight and were also
recommended by the NOSB to be added to the National List (Austin, 1995).

I recommend that production of the product be limited to the process of obtaining hydrogen peroxide by the
electrolysis of water (Kirchner, 1981), and acetic acid by fermentation or distillation from plant sources.
Obtaining acetic acid synthesized by hydrolysis of acetylene or oxidation of acetyladehyde (Budavari, 1996)
should be prohibited.

Reviewer #2
[Research Entomologist]
Peracetic acid is a strong, oxidizing acid that is being reviewed for possible use in organic crop production
because of its antimicrobial properties. It is probably more effective as a disinfectant in aqueous solutions
(Greenspan and Margulies 1950) than on biofilms (Ntsama et al. 1997) or in organic waste slurries (Bohm et al.
1983). It may be a better biocide for viruses (Quiberoni et al. 1999) and bacteria (Meyer and Meltz 1999) than

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it is for fungi (Colgan and Johnson 1998). Some bacteria, such as spore formers, are more resistant (Lensing
and Oei 1985).

Possible crop production uses include fireblight control (Hei 2000), bulb disinfestation (Hanks and Linfield
1999; Hanks et al. 1997), as a foliar spray to control greenhouse thrips (Gill et al. 1998), as a postharvest
treatment to protect fruits against rot (Brown 1987; Mari et al. 1999; Colgan and Johnson 1998), and as a seed
protectant (Wilson 1976). Since it is a synthetic, it would have to be added to the National List before it is
used. Although current formulations have stabilizers added, concentrated solutions still pose a problem with
fire and explosion. Exposure to aerosols can irritate skin and cause respiratory damage, as explained in the
analysis.

As a postharvest treatment of apples and pears, it actually caused increased damage from fungal rots (Colgan
and Johnson 1998). It might be more effective for control of brown rot (Monilinia sp.) on stone fruit (Mari et
al. 1999). As explained below, use in soil is prohibited by the EPA label and may be counter to the principles
of sustainable agriculture. Concentrated solutions would probably be needed to disinfest potting soil, and
questions of human and environmental safety would have to be answered. Organic methods are already
available for this purpose and for thrips control. Though it might have use as a seed protectant, bleach is more
effective (Wilson 1976). Though it effectively controlled Fusarium sp. and nematodes in vitro, field experiments
conducted with treated narcissus bulbs showed that 1-1.5% solutions did not give adequate protection unless a
fungicide was added (Hanks and Linfield 1999). Presumably, this would not be possible in organic agriculture.
According to Hei (2000), sprays of peracetic acid are not effective for fireblight control. However, injections
into trees were effective for this purpose.

Although injections for fireblight control are promising, more data on effectiveness is needed. My
recommendation is that field application of this material does not appear to be warranted at this time.
Evaluation under OFPA 2119 (m) and answers to specific questions are given below.

Evaluation Under OFPA 2119 (m) Criteria

1. It is a strong oxidizing acid. It would reaction with materials such as pyrethrins if sprayed onto foliage. It
would react violently with potting soil mixtures containing organic material. It might be phytotoxic in
concentrated solution. Other interactions in processing and livestock production are outside the scope of this
review.

2. The LD50 orally in rats is about 315 mg/kg (Busch and Werner 1974). It is a severe skin and respiratory
irritant. A solution of 1.5%, which is about half that of peroxide purchased at the drugstore, when applied to
the skin of pigs produced “signs of distress, rapid breathing, struggling, lacrimation and coughing.” Reddening
of the skin occurred, and after 40 days fissures and scaly crusts began to develop.

The material is not persistent in the environment, and breakdown products are benign. None of the
breakdown products are xenobiotics.

The mode of action is oxidation. Electrons are removed from living tissue causing chemical changes, and
probably disruption of membranes.

3. Industrial production of this material is probably through oxidation of acetaldehyde using a cobalt acetate
catalyst. Another way to produce concentrated solutions is reaction of acetic anhydride, hydrogen peroxide,
and sulfuric acid. It can also be made by oxidizing acetic acid in a special generator (Hei 2000). The spent
cobalt catalyst would have to be discharged into a toxic waste dump. The other materials could possibly be
reacted and diluted with water and discharged into waste water with a special permit.

In processing operations, misuse could cause excessive bleaching of fruits. Concentrations greater than 3%
when used in treatment of organic wastes leads to massive amounts of foaming (Bohm et al. 1983). If used
without proper protection, lungs and eyes of workers could be damaged. Peracetic acid is unstable and
degrades quickly in the environment into water, oxygen and acetic acid. The oxygen can increase the chance of
fire, and acetic acid is itself a respiratory irritant. Otherwise, the active ingredient seems to pose no threat.
Stablizers and chelating agents present in the formulations should be separately evaluated. It is possible they
are all approved inerts.

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4. The material irritates eyes, skin and the respiratory tract. Concentrated solutions are a severe explosion risk.
Unstabilized peracetic acid could explode from the friction of being pumped from the container (New Jersey
Hazardous Substance Fact Sheet).

Postharvest disinfection vats of produce being treated with dilute solutions could expose workers to low levels
that could cause respiratory problems and depress their immune systems (Heinze et al. 1981).

When solutions are heated just to warm water temperatures (40-60°C), heavier than air fumes are released that
are flammable in air. There is a danger of fire that releases toxic fumes. If the fire flashes back to the container,
an explosion could result (New Jersey Hazardous Substance Fact Sheet). Explosion and fire hazard are more
probable with concentrated solutions. Also formulations registered with the EPA have stablizers added that
make explosion less likely (Hei 2000).

As pointed out by the review, it is also a possible co-carcinogen.

5. The TAP review does a good job of analysing effects on soil microorganisms. The analysis seems
reasonable. There is not enough published information to make a good judgement of its effect on crops.
However, according to Hanks and Linfield (1999), it is not effective enough as a disinfectant in horticultural
crops, and would have to be used with a chemical fungicide. Presumably, this would not be possible in an
organic operation. As a postharvest sterilant for apples and pears, it actually caused increased damage from
fungi (Colgan and Johnson 1998). This was possibly because it killed microbials on the surface that were
antagonistic to the pathogens. Effects on livestock are not part of this review.

6. Organic alternatives for postharvest handling include steam, hot water, and treatment with biocontrol
microbials. As mentioned in the TAP review, cultural controls, biocontrol, and copper is available for
fireblight. Possibly, antibiotics will be added to the National List.

7. Broad spectrum soil sterilants generally do not fit in the concept of sustainable agriculture. Composts,
manure, and various soil amendments are added to achieve the proper microbial balance. Pathogens can be
selectively destroyed by solarization.

There is not enough information to evaluate effects on sustainable agriculture when used as a foliar spray, a
seed treatment, or as a solution for injection into trees.

How it fits into processing and organic livestock production is outside the scope of this review.

Answers to Specific Questions

1. The fireblight label is relatively recent. Is it too early to tell if it should be sprayed on trees? Is that regular (Section 3),
Experimental Use Permit (Section 5) or Special Local Need (Section 24 c) registration.
According to Hei (2000), topical application of the material is not that effective for fireblight control. He may
be somewhat biased, as his patent is for injection into the cambium layer of trees.

If it is sprayed on trees, workers and those in the way of drift would be at risk. Inhalation of aerosols could
damage lungs. Eyes could be damaged. Workers would have to use respiratory protection, eye protection, and
protective clothing.

If a company wanted to register for fireblight control, it seems like the easiest thing to do would be to register
with an experimental use permit, then conduct field trials to get the necessary data for a regular registration. I
believe that Hei (2000) Larose and and Abbot (1998) and others conducted their experiments in greenhouses.

To register as a Special Local Need (24 c), I believe the State can apply to extend a registration for an additional
use. To register there must be “an existing or imminent pest problem within a state for which the state lead
agency, based upon satisfactory supporting information, has determined that an appropriate federally registered
pesticide product is not sufficiently available.” There are antibiotics already registered for fireblight control.
The state must show that these are not effective before getting a 24c for this material. Also, tolerances must
have already been established before this registration can be obtained. I don't know if this has been done.

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For a company to register for this application, the experimental use permit followed by a regular registration
would be the way to go.

It seems like it would be much easier to get a registration for injections into the trees. Then there would be less
chance of environmental and health consequences.

2. It is not EPA labeled for soil application at this time. However, the label appears to allow use in potting media. Is this a
correct interpretation? What should be the organic status of this use?
The label for Tsunami™ 100 does not mention disinfection of potting soil. It is labeled for dipping or spraying
fruits and vegetables to disinfect them. Although I did not look at all the labels of the 21 currently registered
products (EPA 2000), it seems most of them are registered for disinfection of equipment, surfaces, etc. I think
the potting soil concept is a stretch. Because compost, peat, biosolids and other organic materials are present
in potting soils, concentrated solutions would have to be used to be effective. Addition to potting soil would
produce a violent exothermic reaction, foaming and fumes. There would be a possibility of fire.

As far as the organic status for potting soil, other alternatives such as steam and solarization are available. To
use the material at all, it would have to be added to the National List. Also, it is not true that the material
leaves no residue. Peracetic acid leaves no residue, but all the formulations have other material added to reduce
the chance of explosion. Most of the registered formulations have surfactants added to make them more
effective. Xenobiotics such as 1-hydroxethylidene-1,1-diphosphonic acid are common additives. Approved
inerts would have to be used in the formulation.

3. It is not clear what applications are used by organic farmers. While there are several references to cleaning equipment—such as
greenhouse and transplant tools, and irrigation installations—data and information on the OFPA criteria for use are not readily
accessible in the literature.
I believe that disinfecting equipment, if done indoors, would be consistent with the EPA label and would not
violate OFPA. However, I agree the published literature on this is sparse.

4. Should peracetic acid be allowed in organic crop production? Is there a need for an annotation? If so, for what? To clean
equipment and for indoor uses? What about irrigation equipment? Should field uses be allowed?
I do not know if organic farmers and farmworkers can handle concentrated solutions of peracetic acid safely.
If they are dealing with a more dilute, stabilized material such that fire and explosion risks are minimized, then
it could be used as a replacement for bleach as a disinfectant of equipment. I believe the EPA label does not
allow it to be discharged into outside irrigation lines.

It possibly has a use as a postharvest disinfectant of fruits and vegetables, but I believe that is covered in
another TAP review. Similarly, uses in the organic dairy industry would probably be covered in another review.

I do not think that sprays of this material into tree foliage is a good idea. If it turns out that injection of dilute
solutions into trees can stop fireblight, then it might be worth adding it to the National List for that purpose
only.

I agree that field application of this material does not appear to be warranted at this time.

5. Peracetic acid does not appear on the EPA master list of inert ingredients, and is therefore List 3 by default. Should the
NOSB consider its use as an inert ingredient? What about the stabilizers? Should these be considered in a separate TAP review
or are they incidental when PAA is used as an inert? What about when it is used as an active.
I do not see any justification for considering the oxidizing, corrosive, flammable, and explosive PAA as an
inert. It injures living material and is a biocide. What did you have in mind? I cannot think of any approved
pesticide where this could be considered an inert material. The stabilizers and other additives should be
evaluated as part of the approval process for this material.

[E-mail vote on these two sentences in “Suggested Annotation:” Allowed to disinfect seed and asexually propagated planting
material (i.e., bulb, corm, tuber) used for planting crops. From hydrogen peroxide and fermented acetic acid sources only.] I
support the position that peracetic acid should be obtained from fermented acetic acid sources and peroxide, if
this is technically possible and is overall the most environmentally friendly production method. If approved for

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organic production, it should be allowed for disinfecting seeds, bulbs, etc. Those who use it in this way,
however, should be advised of its efficacy.

Reviewer #3
[Organic farmer and geologist with hazardous materials experience]
Production from petrochemical sources is against one of the core values of organic production, specifically the
value of producing crops without dependence or reliance on the petrochemical industry. This is a farmer
reaction to both the negative environmental consequences of oil production and the economic constraints of
petrochemical based agricultural production. There is a viable alternative manufacturing method. Based on this
information, I support Annotation #1 “manufactured from hydrogen peroxide and acetic acid sources only.”

The dangerous effects are primarily to workers and NOT to consumers or the environment. Based on this
information I support Annotation #2 “All organic personnel handling this material must be informed of its
possible co-carcinogenic properties.” As a farmer, this is the type of information I would like to have. One of
its uses would be to reinforce the importance of handling the material according to specifications. I would also
like to know the level of potential danger at concentrations likely to be used when to washing apples for juice
or salad mix. I suggest that peracetic acid users be provided a summary of this finding (Bock, Meyers, and Fox,
1976). Any new work is done in this area that information be made available as well. This may be a
responsibility put on certification agencies and or the manufacturers of the material as well as farmers.

I suggest that the statement on [its compatibility with a system of sustainable agriculture] could be strengthened. Given
that the compound is made from and decomposes into acetic acid and water, it appears to have a similar
compatibility as the parent substances, therefore PAA should be considered compatible with an organic system
of sustainable agriculture.

It too early to tell if peracetic acid should be sprayed on trees. I believe it should be annotated as allowed with
Experimental Use Permit after alternatives including biocontrols have been tried. (Annotation #3). Peracetic
acid is not EPA labeled for soil application at this time. However the label appears to allow use in potting
media. It should be allowed for use in certified indoor nurseries if needed for production of organic starts

Commercially formulated peracetic products are relatively new on the market and organic growers are only
now becoming aware of them. The NOSB should consider what current applications used in organic
production would the use of peracetic acid be an improvement over existing materials and practices. One area
of improvement (in the sense of being more closely aligned with OFPA criteria) to look towards is its use as a
method of cleaning irrigation systems, greenhouse sanitation, tools etc. Another area of improvement to
consider is its use for foreseeable problems of post harvest sanitation, esp. salad mixes, fruits and root crop
washes. Sanitation problems in these areas have already damaged organic markets. Part of the problem is the
reluctance of organic farmers to use common sanitizers such as chlorine and ammonia, in part due to organic
regulations. While there are several references to cleaning equipment such as greenhouse and transplant tools,
and irrigation installations data and information on the OFPA criteria for such uses are not readily accessible in
the literature.

My general understanding of applying OFPA criteria for these sanitizers is whatever is washed with a sanitizer,
needs to be double or triple washed with water. In cases where the water source is not clean (which is common
for ag water) this is counterproductive. In situations where food products are involved, the residual effect of
the sanitizer is often needed for preservation. This material does not appear to require a wash before the
surface comes into contact with organic food.

Other crops should be applied for on a crop by crop basis based on emergency crop needs. This area may need
to be under the discretion of the certification agency. Peracetic acid does not appear on the EPA master list of
inert ingredients, and is therefore List 3 by default. I am not aware of peracetic acid being used as an inert
ingredient in any formulation. The NOSB should not consider its use as an inert ingredient. How can a material
this reactive be truly inert in anything?

The stabilizers should be considered incidental. This question should stay open to new knowledge. Specifically,
if a List 4 stabilizer becomes known and works well it should be allowed and products using List 3 stabilizers
should be disallowed. Disinfecting washwater is very significant for organic products. It is one of the main

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reasons for allowing its use in organic production. Especially this section “5% acetic acid and peroxyacetic acid
solutions were the most effective, causing reduction of 3.1 and 2.6 log units,respectively, without apparent
sublethal injury (Wright et al., 2000).”

The conclusion that “PAA is effective, cheap, non-toxic to mammals and not harmful to the environment”
places peracetic acid in the category or a synthetic that fits organic criteria. Any material that has these
characteristics should be strongly considered for use in organic systems (Lagger, 1998).

Conclusion
While pre-planting, production aid, and post-harvest uses all appear consistent with OFPA and existing organic
standards, field application of this material does not appear to be warranted at this time.

I believe the conclusion should include experimental use on fireblight after documented alternatives including
biocontrols have been tried. The reasons for this include:

1) That this use is primarily on tree crops and fruit above the soil. It is likely to have some impact on the soil
but not the same degree as a pre-planting soil drench or application to a field crop.
2) If it is permitted for post-harvest washing then why shouldn't it be allowed on the crop ten minutes
earlier? If it is allowed ten minutes before eating a piece of fruit, then it should be allowed to be used two
months earlier when it would be more effective at lower rates.
3) The main reason for not allowing field appliations is environmental damage to the soil. I am against
allowing it as a field soil drench. There may be some value in allowing it as a drench for potted plants in
certified nurseries. In many cases, especially in Hawaii and California, it may be necessary to pass
agricultural regulations on transportation of soil bearing plant materials. Allowing its use in this situation
could contribute to production of many more organic starts. Since the OFPA regulations call for growers
to use organic starts when possible, this would increase the possibility of using organic starts instead of
conventional ones for many large scale organic farms. The reasoning here is if organic starts can't be found
then conventional ones are allowed for organic production, which may have much worse environmental
consequences that allowing peracetic acid for this specific use.

Therefore I support Annotation #4 “Allowed for use in certified indoor nurseries if needed for production of
organic starts.”

The substance is SYNTHETIC

Summary Recommendation: ALLOWED
Suggested annotations:
1. Manufactured from hydrogen peroxide and acetic acid sources only
2. All organic personnel handling this material must be informed of its possible co-carcinogenic properties
3. Allowed for fireblight control with Experimental Use Permit with documentation that alternatives
including biocontrols have been tried
4. Allowed for use in certified indoor nurseries if needed for production of organic starts.

Conclusion
While pre-planting, production aid, and post-harvest uses all appear consistent with OFPA and existing organic
standards, field application of this material does not appear to be warranted at this time.

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