From: Protena Nicaragua Proteína Naturales, S.A. Km 27, Panamericana Norte Nicaragua To: Program Manager, USDA/AMS/TM/NOP, Room 4008-So., Ag Stop 0268, 1400 Independence Ave., SW., Washington, DC 20250 Phone: (202) 720–3252 Fax: (202) 205–7808.
[email protected] (electronic submission) Subject: Petition: Sodium Citrate as Processing Aid (Anticoagulant) for Spray Dried Blood Products In this petition, we address each of the Items listed in the new NOP 3011: National List Petition Guidelines (effective March 11, 2016) Most all of the information contained in this petition has already been made available to USDA-NOP in the Technical Evaluation Report for Citric acid and Salts (Handling/Processing), compiled by OMRI for the USDA National Organic Program, Feb 17, 2015 (See attachment # 1 – Sodium Citrate TR2015) https://www.ams.usda.gov/sites/default/files/media/Citric%20Acid%20TR%202015.pdf. Direct quotes from this report are “italics”. Since citric acid is a necessary precursor for sodium citrate, citric acid is also an essential part of this evaluation. Sodium citrate is produced when citric acid is mixed with sodium hydroxide or sodium bicarbonate. Item A.1 — This is a petition to include Sodium Citrate in the List of Synthetic substances allowed for use in organic crop production (§ 205.601). If approved, sodium citrate would be allowed as synthetic organic ingredient (anticoagulant) for processing bovine blood after collection at slaughter, so the blood will maintain a liquid state while being processed into organic crop fertilizer (spray dried blood meal and spray dried hemoglobin). Item A.2 — The OFPA Category (7 U.S.C.