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CFNP                     TAP Report for Soy Protein Isolate—Revised                      August 2004


Most of the concerns expressed by NOSB when they deferred the original SPI TAP
report in April 2004 have been addressed. However, the following questions could not be
answered:

� What percent of soy is genetically modified?
� What is the genetic modification?
� If some soy is genetically modified, how is cross-contamination handled?
� If soy is genetically modified, could the protein from the genetic modification be
concentrated during processing into soy protein isolate?

General information concerning agricultural production of genetically modified soybeans
was provided in the revised SPI TAP report. However, specific information regarding
the use and handling of genetically modified soybeans in the petitioned substance must
be obtained from the manufacturer (Archer Daniels Midland Company).

CFNP’s previous attempts to obtain missing SPI production information from the
manufacturer were unsuccessful. Therefore, CFNP recommends that the petitioner obtain
the missing information requested by NOSB before any other action is taken. According
to 7 CFR Part 205: Final Rule with Request for Comments, “[w]hen a retail operation
contracts for the production, packaging, or labeling of organic product, it is the certified
production or handling operation that is responsible for complying with the applicable
organic production or handling regulations.�1 Since the petitioner and the manufacturer
probably have an established business relationship, the manufacturer may be more
responsive to the petitioner’s requests for additional information. It is also to the
petitioner’s benefit to obtain the missing information.

Any additional information concerning the use of hydrochloric acid (HCl) and sodium
hydroxide (NaOH) in the production of SPI should be requested from the manufacturer.
Although the revised SPI TAP report does provide some general information about these
substances, only the manufacturer will be able to answer more specific questions, such as
quantities used and disposal procedures.

In addition, the comment “FDA information needed (do not need information on use as a
food); address its use as a soil amendment� is inappropriate since FDA does not regulate
soil amendments. In this section, the GRAS status of SPI was addressed to demonstrate
that FDA does not consider SPI a threat to human health.

Please let me know if you have any questions concerning the revised SPI TAP report.
Although the revised SPI TAP report has not been re-evaluated by the original reviewers,
I strongly doubt that the revised information would change their original determinations.
In addition, all of the product-specific information requested by NOSB should be
included in the revised SPI TAP prior to its re-evaluation by the reviewers.


1
U.S. Department of Agriculture/Agricultural Marketing Service. “Applicability—Clarifications: Private
Label Products.� 7 CFR Part 205: Subpart B—Applicability 2000;
http://www.ams.usda.gov/nop/NOP/standards/FullText.pdf.


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CFNP TAP Report for Soy Protein Isolate—Revised August 2004


SUMMARY OF TAP REVIEWERS� ANALYSES�

Soy protein isolate is being petitioned for use as a fertilizer for organic crop production as
well as for turf, landscape, and other horticultural applications. Soy protein isolate, the
most highly refined soy protein, would ensure sufficient available nitrogen for plant
health and development. Due to the significant amount of processing required to extract
soy protein from whole soybeans, soy protein isolate should be classified as a synthetic
substance. Information concerning the production of soy protein isolate supplied by the
petitioner was incomplete. Attempts to obtain additional production information from the
manufacturer (Archer Daniels Midland Company) were unsuccessful. Despite the
widespread use of soy protein isolate in food and industrial products, information
concerning its use as a fertilizer is either nonexistent or not publicly available.

All three reviewers concluded that soy protein isolate, as petitioned, is a synthetic
substance. Two of the reviewers recommended that soy protein isolate should not be
included on the National List since detailed information concerning its production could
not be obtained from the manufacturer and since a wide variety of other organic fertilizer
options are available. The other reviewer recommended that soy protein isolate should be
included on the National List since it is innocuous and is very unlikely to cause any
environmental concerns. However, this reviewer also expressed some apprehension
about the lack of detailed production information for soy protein isolate.


Synthetic or Non-synthetic? Allow without restrictions? Allow only with restrictions?
(See reviewers� comments
for restrictions)

Synthetic (3) Yes (1) Yes (0)
Non-synthetic (0) No (2) No (0)


IDENTIFICATION1,2

Common Name: Soy Protein Isolate
CAS Registry Number: 9010-10-0
Other Names: Isolated Soy Protein; Soya Protein Isolate; Isolated Soya Protein


�
This Technical Advisory Panel (TAP) report was based upon the information available at the time this
report was generated. This report addressed the requirements of the Organic Foods Production Act of
1990 (OFPA), as amended, to the best of the investigator’s ability and was reviewed by experts on the
petitioned substance. The substance was evaluated according to the criteria found in Section 2118 (7
U.S.C. 6517) and in Section 2119 (7 U.S.C. 6518) of the OFPA. Any recommendation(s) presented to the
National Organic Standards Board (NOSB) was based on the information contained within the TAP report
and the evaluation of that information relative to these criteria. The TAP report does not incorporate
commercial availability, socioeconomic impact, or other factors related to the petitioned substance, which
NOSB and USDA may want to consider in their decision process.



2
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


CHARACTERIZATION3

Composition: Off-white to light brown powder
Properties:
Molecular Formula: Not Available
Molecular Weight: Not Available
Melting Point: Not Available
Boiling point: Not Applicable
Density: Not Available
Water Solubility: Insoluble

PRODUCTION

Two methods of soy protein isolate (SPI) production were described in the scientific
literature:

Precipitation with Hydrochloric Acid4,5—whole soybeans are cleaned, cracked,
�
and dehulled; the resulting soy meats are then flaked; these full-fat soy flakes
undergo hexane extraction to remove the soybean oil and are then desolventized
under conditions that prevent denaturing the soy protein; the defatted soy flakes
are slurried in water that has been pH-adjusted to 8.5-9.0 with sodium hydroxide
(NaOH) in order to disperse the soy protein and to dissolve the water-soluble
constituents (carbohydrates); this slurry is centrifuged to separate the solid and
liquid portions; the liquid is then removed and stored for further processing; the
solid portion is similarly re-extracted two more times; each time the solid portion
is re-extracted, the resulting liquid is removed and combined with the stored
liquid; the aggregate liquid is mixed with hydrochloric acid (HCl) to a pH of
about 4.5 in order to precipitate most of the soy protein; the precipitated protein is
then washed with water, neutralized (pH=7) with NaOH, and spray dried.

Separation with Polyisopropylacrylamide Gel6—whole soybeans are cleaned,
�
cracked, and dehulled; the resulting soy meats are then flaked; these full-fat soy
flakes undergo hexane extraction to remove the soybean oil and are then
desolventized under conditions that prevent denaturing the soy protein; the
defatted soy flakes are slurried in water that has been pH-adjusted to 8.5-9.0 with
sodium hydroxide (NaOH) in order to disperse the soy protein and to dissolve the
water-soluble constituents (carbohydrates); this slurry is centrifuged to separate
the solid and liquid portions; the liquid is then removed and stored for further
processing; the solid portion is similarly re-extracted two more times; each time
the solid portion is re-extracted, the resulting liquid is removed and combined
with the stored liquid; the aggregate liquid is added to collapsed
polyisopropylacrylamide gel and cooled to about 5oC, causing the gel to swell; the
swollen gel absorbs water and other small solutes; the gel does not absorb solutes
of high molecular weight, such as proteins; the swollen gel and the unabsorbed
liquid (retentate) are separated; the retentate is similarly re-extracted with




3
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


collapsed polyisopropylacrilamide gel until the desired protein concentration and
purity is reached; the final retentate is then spray dried.

Advantages of obtaining soy protein isolate via separation with polyisopropylacrylamide
gel versus precipitation with HCl include:

� Limitation/Inhibition of Microbial Growth—soy protein isolate is extracted at
temperatures as low as 5oC.

� Partial Elimination of Corrosive Chemicals—soy protein isolate is extracted
without the use of HCl.

Soy protein isolate is typically produced via precipitation with HCl, and the limited
information provided by the petitioner suggests that this is the production method that
will be used. However, the complete production method for the petitioned substance was
not supplied by the petitioner. The manufacturer and primary supplier of soy protein
isolate to the petitioner—Archer Daniels Midland Company—was unresponsive to
several requests for additional production information.

HISTORY OF USE

Non-Organic Growers: Prior to the Chinese-Japanese war of 1894-95, all soybean
production was localized in China. After the war, the Japanese began importing soybean
oil cake for fertilizer use. The earliest written reference to soybeans in the United States
occurred in 1804. Soybeans grown in the U.S. were originally utilized as a forage crop
rather than harvested for seed. By 1941, the U.S. soybean acreage dedicated to seed
production exceeded that grown for foraging and other purposes.7 Genetically modified
soybeans are now commonly grown in the U.S. In 2000, 60% of domestic farms were
growing herbicide-resistant soybeans.8 By 2003, 81% of all soybeans planted in the U.S.
were genetically engineered, totaling 59.7 million acres.9 Despite the widespread use of
soy protein isolate in food and industry products, soy protein isolate is either not
currently used as a crop or horticultural fertilizer, or information concerning its use as
such is not publicly available.

Organic Growers: Soybeans are a relatively easy crop to produce organically and
comprise the largest segment of organic legume production by volume in the United
States.10 Due to its nitrogen-fixing ability, the soybean is a moderate consumer of
nutrients and is able to furnish most of the nitrogen it requires for crop production.11 Soy
protein isolate is not currently used by organic growers as an organic crop and
horticultural fertilizer since it is not included on the National List of Allowed and
Prohibited Substances.




4
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


CURRENT STATUS

U.S. Regulatory Agencies:
EPA: According to 40 CFR Part 180 (§180.1001), residues of isolated soy
protein—when used as an adhesive—â??...are exempted from the requirement of a
tolerance when used in accordance with good agricultural practice as inert (or
occasionally active) ingredients in pesticide formulations applied to growing
crops or to raw agricultural commodities after harvest...� In addition, residues of
isolated soy protein—when used as an adhesive—â??...are exempted from the
requirement of a tolerance when used in accordance with good agricultural
practice as inert (or occasionally active) ingredients in pesticide formulations
applied to animals...� Both of these pesticide tolerance exemptions expire on
May 24, 2005 and are scheduled for reassessment during 2005.12

FDA: According to 21 CFR Part 101 (§101.82), a food product that meets
specific content and labeling requirements may make a health claim concerning
soy protein consumption and a possible reduction of coronary heart disease.13
According to the Final Rule for 21 CFR Part 101 (§101.82), FDA states that
“although soy protein is not listed as GRAS or prior sanctioned in Title 21 of the
CFR, FDA has noted that these lists ‘do not include all substances generally
recognized as safe for their intended use� and, as stated at 21 CFR 182.1, ‘[i]t is
impracticable [for FDA] to list all substances that are GRAS for their intended
use�...FDA does not take issue with the petitioner’s self-determination of GRAS
status...Although FDA has not ruled formally on the GRAS status of soy protein
ingredients, it has not challenged determinations that soy’s use as dietary protein
is GRAS. Food ingredients whose use is generally recognized as safe by qualified
experts are not required by law to receive FDA approval.�14

OSHA: According to the Occupational Safety and Health Administration, soy
protein isolate dust levels must remain below 15 mg/m3.15

International Certifiers:
EU: Soy protein isolate is not currently listed as a permitted ‘non-organic�
fertilizer or soil improver for organic crop production in the European Union.16
However, soya beans (whole, meal, and cake obtained by pressure) are permitted
as ‘non-organic� feedstuffs for organic animal production.17

Japan: Soy protein isolate is not specifically listed as an approved substance for
organic agricultural production in Japan. However, soybean cake and its powder
are allowed as fertilizers and soil improvement substances for organic agricultural
production as long as chemosynthetic substances have not been added.18

Canada: Soy protein isolate is not specifically listed as an approved organic crop
production material in Canada. However, soybean meal is allowed as an organic
fertilizer/plant food/soil amendment provided that the soybean meal was not
derived from genetically engineered soybeans.19



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CFNP TAP Report for Soy Protein Isolate—Revised August 2004



Codex Alimentarius: Soy protein isolate is not currently listed as a permitted soil
fertilizing or conditioning substance for the production of organic foods in the
Codex Alimentarius.20

APPLICATION

Soy protein isolate is being petitioned for use as a fertilizer for organic crop production as
well as for turf, landscape, and other horticulture applications. Soy protein isolate will
either be applied to the soil as pellets or to foliage as a spray. According to the petitioner,
the rate of application will be dependent upon crop requirements proportional to the
nitrogen content.

INCOMPATIBILITIES

Soy protein isolate is a stable compound and is considered non-hazardous. Soy protein
isolate has no incompatibilities with other materials, and hazardous polymerization will
not occur.21

ORGANIC FOODS PRODUCTION ACT OF 1990 (OFPA), AS AMENDED

7 USC 6517. NATIONAL LIST.

�(a) In General. The Secretary shall establish a National List of approved and
prohibited substances that shall be included in the standards for organic
production and handling established under this chapter in order for such products
to be sold or labeled as organically produced under this chapter.

(b) Content of List. The list established under subsection (a) of this section shall
contain an itemization, by specific use or application, of each synthetic substance
permitted under subsection (c) (1) of this section or each natural substance
prohibited under subsection (c) (2) of this section.

(c) Guidelines for Prohibitions or Exemptions.

(1) Exemption for Prohibited Substances. The National List may provide for the
use of substances in an organic farming or handling operation that are otherwise
prohibited under this chapter only if

(A) the Secretary determines, in consultation with the Secretary of Health and
Human Services and the Administrator of the Environmental Protection Agency,
that the use of such substances

(i) would not be harmful to human health or the environment;




6
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


(ii) is necessary to the production or handling of the agricultural product because
of unavailability of wholly natural substitute products; and

(iii) is consistent with organic farming and handling;

(B) the substance

(i) is used in production and contains an active synthetic ingredient in the
following categories: copper and sulfur compounds; toxins derived from bacteria;
pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and
minerals; livestock paraciticides and medicines and production aids including
netting, tree wraps and seals, insect traps, sticky barriers, row covers, and
equipment cleansers;

(ii) is used in production and contains synthetic inert ingredients that are not
classified by the Administrator of the Environmental Protection Agency as inerts
of toxicological concern; or

(iii) is used in handling and is non-synthetic but is not organically produced; and

(C) the specific exemption is developed using the procedures described in
subsection (d) of this section.�

Therefore, under 7 USC 6517 of the OFPA, as amended, it must be determined if
the use of soy protein isolate as a fertilizer for organic crop production as well as
for turf, landscape, and other horticultural applications is consistent with
subsection (c)(1) of 7 USC 6517. If so, then soy protein isolate should be allowed
an exemption as a synthetic substance and be included on the National List.

SECTION 2118 (7 U.S.C. 6517) AND SECTION 2119 (7 U.S.C. 6518) OFPA CRITERIA

Category 1: Impact of the Substance on Humans and the Environment

1. What is the probability of environmental contamination during manufacture, use,
misuse, or disposal of the substance [§6518(m)(3)]?

According to the petitioner, Archer Daniels Midland Company (ADM)—the
manufacturer and primary supplier of soy protein isolate to the petitioner—is
bound by all local and national regulations with respect to environmental
contamination and is fully committed to compliance.

In general, spillage and disposal procedures for soy protein isolate include:

� “Spillage—[Soy protein isolate] is non-hazardous. If dusting occurs in
confined area, a dust mask should be worn.




7
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


� Disposal—Non-contaminated waste material can be disposed of as non-
hazardous solid waste.�22

The information provided by the petitioner suggests that soy protein isolate will
be produced via extraction with NaOH, followed by precipitation with HCL and
neutralization with NaOH.

Some characteristics of HCL and NaOH are:

� HCL—colorless or slightly yellow liquid with pungent odor; extremely
corrosive; inhalation of vapor or contact with skin or eyes can cause
serious injury; ingestion may be fatal; lethal to fish at concentrations of 25
mg/L; toxic to aquatic organisms due to pH shift.23

� NaOH—odorless white solid; very corrosive; inhalation of dust or contact
with skin or eyes can cause serious injury; very harmful if ingested; can
have harmful environmental effects due to pH shift.24

Since the petitioner provided incomplete information concerning the production
of soy protein isolate, several attempts were made to obtain the missing
information from ADM. However, ADM did not respond to these requests for
additional production information. Therefore, the probability of environmental
contamination during manufacture, use, misuse, or disposal of soy protein isolate
can not be completely ascertained.

2. Is the substance harmful to the environment [§6517(c)(1)(A)(i);
§6517(c)(2)(A)(i)]?

Soy protein isolate is not expected to have any negative environmental impacts
due to its stability, insolubility in water, and compatibility with other substances.25

3. Does the substance contain List 1, 2, or 3 inert pesticide ingredients identified by
U.S. EPA’s Office of Pesticide Programs [§6517(c)(1)(B)(ii); §205.601(m)(2)]?

Soy protein isolate does not contain any List 1, 2, or 3 inert pesticide ingredients
identified by U.S. EPA’s Office of Pesticide Programs since all the soybean oil is
extracted from the soy protein isolate during processing. Soy protein isolate itself
is also not included as a List 1, 2, or 3 inert pesticide ingredient.26

4. What is the potential of the substance for detrimental chemical interactions with
other materials used in organic farming systems [§6518(m)(1)]?

Soy protein isolate is unlikely to produce detrimental chemical interactions with
other materials used in organic farming systems since soy protein isolate has no
known incompatibilities with other substances.




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CFNP TAP Report for Soy Protein Isolate—Revised August 2004


5. Does the substance cause adverse biological and chemical interactions in the
agroecosystem [§6518(m)(5)]?

Soy protein isolate is unlikely to cause adverse biological or chemical interactions
in the agroecosystem. Soy protein is readily metabolized by soil microorganisms
into ammonium and nitrate ions. These ions are an excellent source of nitrogen
for the growth and development of plants. In fact, research is being conducted to
develop biodegradable products made with soybean protein, such as plastic films.

“Polyethylene films are used to make agricultural mulch films, garbage bags,
paper coatings, laminating materials and other products...Because [polyethylene
films] don’t degrade in the environment, they can cause severe pollution
problems...Bags litter beaches and streets. Plastics can harm wildlife, especially
aquatic animals. Mulch films can block underground water circulation and hurt
soil quality.

Soy-based biodegradable films have some attractive properties...As agricultural
mulch films, soy-based plastics may even help improve soil quality. After they
degrade, they may act as a soil conditioner...Preliminary studies show ground soy
powder can be utilized by plants, helping them grow.�27

6. Does the substance cause detrimental physiological effects to soil organisms
(including the salt index and soil solubility), crops, or livestock [§6518(m)(5)]?

Soy protein isolate, a readily biodegradable material, has not shown any
detrimental physiological effects to soil organisms. The maximum residual
sodium in soy protein isolate, due to the manufacturing neutralization process,
amounts to no more than 900-1200 mg Na/100g of final product. This causes an
inconsequential amount of sodium to be added to soil systems since the soy
protein isolate application rate is typically between 1-1.5 lbs/1000 ft2.

Soy protein isolate, which has a protein content of 90% or more,28 is unlikely to
cause detrimental physiological effects to crops or livestock. Soybean meal,
another rich source of protein, is a recommended fertilizer for plants. Soybean
meal is also consumed in feed by pigs, cows, and chickens.29

7. Do either the substance or its breakdown products/contaminants cause a toxic or
other adverse action in the environment [§6518(m)(2)]?

Soy protein isolate will not cause a toxic or other adverse action in the
environment due to its stability and lack of reactivity with other materials. The
breakdown products of soy protein isolate—amino acids, ammonium ions, and
nitrate ions—are similarly non-hazardous. These breakdown products, which
result from the actions of microorganisms in soil, are readily absorbed by plants to
meet their nitrogen requirements for growth.30




9
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


According to the petitioner, soy protein isolate fertilizer contains such low levels
of heavy metals that no toxic or other adverse action in the environment from
these contaminants would be expected.

8. What is the probability of an undesirable persistence or concentration of the
substance or its breakdown products/contaminants in the environment
[§6518(m)(2)]?

Soy protein isolate is readily metabolized by soil microorganisms into amino
acids, ammonium ions, and nitrate ions. All remaining amino acids are also
converted to either ammonium or nitrate ions. Ammonium and nitrate ions are
the two forms of nitrogen that are most palatable to plants.31 Consequently,
neither soy protein isolate nor its breakdown products will result in an undesirable
persistence or concentration in the environment.

9. Is the substance harmful to human health [§6517(c)(1)(A)(i); §6517(c)(2)(A)(i);
§6518(m)(4)]?

Sufficient data have been generated to suggest a link between soy protein
consumption and several positive health benefits, such as decreased risk of
coronary heart disease, diseases of the lower gastrointestinal tract, and certain
cancers.32

Some researchers claim that isoflavones found in many soy products may be
associated with negative health effects. Isoflavones are phytoestrogens, a weak
form of estrogen, which some studies have shown to contribute to an increased
risk of cancer, especially breast cancer.33

However, it is unlikely that soy protein isolate—when used as a fertilizer—would
pose any health risk to humans. After soy protein is precipitated from defatted
soy flakes, the percentage of total isoflavones remaining in the soy protein isolate
is only about 26%.34 Using soy protein isolate as a fertilizer—not as a food
additive—further reduces the likelihood of any remaining isoflavones causing
harmful effects to humans.

Category 2: Importance of the Substance for Organic Production

1. Is the substance necessary to the production or handling of an agricultural
product due to the unavailability of wholly natural substitute materials
[§6517(c)(1)(A)(ii)]?

Although soy protein isolate is an excellent source of nitrogen for plants, other
soy-based sources are available. Soybean meal, the product remaining after
extracting most of the oil from whole soybeans, is usually sold as animal feed.
Due to the high protein content of soybean meal, it also makes an effective soil
fertilizer.35 A product known as Clean Greenâ„? is being sold as a slow-release,



10
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


soy-based fertilizer without the negative environmental impacts of excess
phosphorus.36 However, information concerning the soybean components
included in Clean Greenâ„? was not publicly available. In addition, no data
concerning the commercial or private usage of either soybean meal or Clean
Greenâ„? could be located.

According to Section 205.601 [§205.601(j)(1)] of the National List of Allowed
and Prohibited Substances, aquatic plant extracts (other than hydrolyzed) are
synthetic substances that may be used as plant or soil amendments in organic crop
production. However, the extraction process is limited to the use of potassium
hydroxide (KOH) or sodium hydroxide (NaOH). The amount of KOH or NaOH
used must also be limited to only the amount necessary for extraction.

After whole soybeans are processed into defatted soy flakes, both methods of soy
protein isolate production (precipitation with HCl versus separation with
polyisopropylacrylamide gel) limit the extraction process to the use of NaOH.
The limited production information provided by the petitioner suggests that
precipitation with HCl is the method that will be used. Unfortunately, no
information concerning the amount of NaOH required during soy protein isolate
extraction was provided. Information concerning the amount of HCl required for
precipitating soy protein isolate was also missing.

2. Is the substance non-synthetic, but not produced organically, and used in
handling [§6517(c)(1)(B)(iii)]?

Soy protein isolate is being petitioned as a fertilizer for organic crop production as
well as turf, landscape, and other horticultural applications only. Since soy
protein isolate is not being petitioned for use in organic handling, this question is
not applicable.

3. Would other available materials be suitable alternatives to using the substance
[§6518(m)(6)]?

Suitable alternatives to using soy protein isolate as a fertilizer for organic crop
production as well as turf, landscape, and other horticultural applications include:

� Cottonseed Meal—by-product of cotton manufacturing that produces a
slightly acidic reaction in soil; desirable for acid-loving plants, such as
azaleas, camellias, and rhododendrons; generally contains 7% nitrogen,
3% phosphorus, and 2% potash.

� Blood Meal—dried, powdered blood collected from cattle
slaughterhouses; a very nitrogen-rich fertilizer; may burn plants if used in
excess.




11
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


� Fish Emulsion—partially decomposed blend of finely pulverized fish;
high in nitrogen and may burn plants; strong odor usually dissipates within
two days.

� Manure—nutrient content depends upon species and diet of animal;
nutrient content highest when fresh, but also more likely to burn plants;
better used as soil conditioner than fertilizer due to overall low nutrient
content.37

� Compost—decomposed remnants of materials with plant and/or animal
origins; nutrient content depends upon plant and animal materials used.

4. Would other practices either reduce or eliminate the requirement for the
substance [§6518(m)(6)]?

Other practices that could reduce or eliminate the requirement for soy protein
isolate as a fertilizer for organic crop production include:

� Crop Rotation—the sequence of crops grown on a specific field; confers
benefits to long- and short-term soil fertility; incorporating forage
legumes, such as soybeans, into the rotation schedule provides the vast
majority of the nitrogen required by subsequent crops.

� Cover Cropping—growing a crop for the specific purpose of soil and
nutrient conservation.

� Green Manuring—incorporating into the soil a crop grown for the specific
purpose of soil improvement.

� Tillage/Cultivation—conserving crop residues and added manures in the
upper, biologically active zones of the soil; not leaving soils completely
bare and vulnerable to erosion; eliminating excessive tillage/cultivation to
minimize soil compaction and the destruction of earthworms and their
tunneling.38

Any of the practices listed above can be combined to further improve organic
crop production.




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CFNP TAP Report for Soy Protein Isolate—Revised August 2004




REFERENCES
1
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� MSDS Tools 1998;
http://www.msdsonline.com.
2
Golbitz, P. Soya & Oilseed Bluebook 2004. Soyatech (Bar Harbor, ME) 2003.
3
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� Archer Daniels
Midland Company; http://www.msdsonline.com.
4
Golbitz, P. Soya & Oilseed Bluebook 2004. Soyatech (Bar Harbor, ME) 2003.

Food Protein Research and Development Center of Texas A&M University. “Protein
5

Separations.� The Separation Sciences Program; http://www.tamu.edu/food-
protein/divisions/separ_sc/psepars.html.
6
Trank, S, Johnson, D, and Cussler, E. “Isolated Soy Protein Production Using
Temperature-Sensitive Gels.� Food Technology 1989; 43:78-83.
7
Gibson, L, and Benson, G. “Origin, History, and Uses of Soybean (Glycine max).� Iowa
State University Department of Agronomy 2002;
http://www.agron.iastate.edu/courses/agron212/Readings/Soy_history.htm.
8
United States Department of Agriculture/National Agricultural Statistics Service. “Pest
Management Practices 2000 Summary.� USDA Economics and Statistics System: Reports
2001; http://usda.mannlib.cornell.edu/reports/nassr/other/pest/pestan01.pdf.
9
Pew Initiative on Food and Biotechnology. “Genetically Modified Crops in the United
States.�; Agricultural Biotechnology Factsheets 2003;
http://pewagbiotech.org/resources/factsheets/display.php3?FactsheetID=2.
10
Hansen, R. “Organic Soybean Industry Profile.� Agricultural Marketing Resource
Center 2003; http://www.agmrc.org/soy/profiles/organicsoyprofile.pdf.
11
Kuepper, G. “Organic Soybean Production.� National Center for Appropriate
Technology 2003; http://attra.ncat.org/attra-pub/PDF/organicsoy.pdf.
12
National Archives and Records Administration/Code of Federal Regulations.
“Tolerances and Exemptions from Tolerances for Pesticide Chemicals in Food.� Title 40:
Protection of Environment 1971; 40 CFR Part 180 [§180.1001].
13
National Archives and Records Administration/Code of Federal Regulations. “Food
Labeling.� Title 21: Food and Drugs 1999; 21 CFR Part 101 [§101.82].




13
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


14
Department of Health and Human Services/Food and Drug Administration. “Food
Labeling: Health Claims; Soy Protein and Coronary Heart Disease.� Final Rule: Docket
No. 98P-0683; http://www.cfsan.fda.gov/~lrd/fr991026.html.
15
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� Archer Daniels
Midland Company; http://www.msdsonline.com.

Organic-Research. “�Non-Organic� Fertilizers and Soil Improvers (EC Reg. No.
16

2092/91: Annex II A).� Database of Organic Standards in the EU 1998;
http://www.organic-research.com/lawsregs/db/db_soil_int.asp.
17
Organic-Research. “�Non-Organic� Feedstuffs and Feed Supplements [COM(96)366:
Annex II C].� Database of Organic Standards in the EU 1998; http://www.organic-
research.com/lawsregs/db/db_feed_int.asp.
18
Ministry of Agriculture, Forestry and Fisheries of Japan. “Notification No. 59 of the
Ministry of Agriculture, Forestry and Fisheries of January 20, 2000.� Japanese
Agricultural Standard of Organic Agricultural Products 2001.
19
Certified Organic Associations of British Columbia. “Section 14: Crop Production
Materials.� British Columbia Certified Organic Production Operation Policies and
Management Standards, Version 5;
http://www.certifiedorganic.bc.ca/Standards/bk2v5sec14.htm.
20
Joint FAO/WHO Food Standards Programme. “Annex 2: Permitted Substances for the
Production of Organic Foods.� Codex Alimentarius-Organically Produced Foods 2001;
http://www.fao.org/DOCREP/005/Y2772E/y2772e0c.htm#bm12.
21
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� Archer Daniels
Midland Company; http://www.msdsonline.com.
22
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� Aerchem, Inc.;
http://www.msdsonline.com.
23
University of Oxford Physical and Theoretical Chemistry Laboratory. “Safety (MSDS)
Data for Hydrochloric Acid (Concentrated).� MSDS Data Sheets 2004;
http://ptcl.chem.ox.ac.uk/MSDS/HY/hydrochloric_acid.html.
24
University of Oxford Physical and Theoretical Chemistry Laboratory. “Safety (MSDS)
Data for Sodium Hydroxide.� MSDS Data Sheets 2004;
http://ptcl.chem.ox.ac.uk/MSDS/SO/sodium_hydroxide.html.
25
MSDS Online. “Material Safety Data Sheet: Soy Protein Isolate.� Archer Daniels
Midland Company; http://www.msdsonline.com.




14
CFNP TAP Report for Soy Protein Isolate—Revised August 2004


26
U.S. Environmental Protection Agency. “Lists of Other (Inert) Pesticide Ingredients.�
Pesticides: Regulating Pesticides; http://www.epa.gov/opprd001/inerts/lists.html.
27
Iowa State University College of Agriculture. “ISU Studies Soy-Protein Films to
Reduce Plastic Pollution.� Agriculture Information Service 1996;
http://www.ag.iastate.edu/aginfo/news/past/soyfilm.html.
28
Golbitz, P. Soya & Oilseed Bluebook 2004. Soyatech (Bar Harbor, ME) 2003.
29
Reich, L. “All Plants Love Soy.� CANOE: Home and Garden 2004;
http://www.homeandgarden.canoe.ca/HGGardening0406/11_soybeanmeal-ap.html.
30
Ibid.
31
Ibid.
32
Endres, J (ed.). Soy Protein Products: Characteristics, Nutritional Aspects, and
Utilization. AOCS Press (Champaign, IL) 2001.
33
Henkel, J. “Soy: Health Claims for Soy Protein, Questions about Other Components.�
FDA Consumer 2000; 34:13-20.
34
Wang, C, Ma, Q, Pagadala, S, Sherrard, M, and Krishnan, P. “Changes of Isoflavones
During Processing of Soy Protein Isolates.� Journal of the American Oil Chemists�
Society 1998; 75:337-41.
35
Reich, L. “All Plants Love Soy.� CANOE: Home and Garden 2004;
http://www.homeandgarden.canoe.ca/HGGardening0406/11_soybeanmeal-ap.html.
36
Michigan State University Extension. “Soy Fertilizer Will Benefit Homeowners, Local
Governments and Producers.� Agriculture and Natural Resources Education and
Communication Systems 2003; http://www.msue.msu.edu/learnnet/soy_072203.htm.
37
Relf, D. “Organic Fertilizers.� Virginia Cooperative Extension 1997;
http://www.ext.vt.edu/departments/envirohort/factsheets2/fertilizer/jan89pr6.html.
38
Kuepper, G. “An Overview of Organic Crop Production.� ATTRA National
Sustainable Agriculture Information Service 2000; http://attra.ncat.org/attra-
pub/PDF/organiccrop.pdf.




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