DOE's plan to eliminate industrial wastes in ag fertilizers
October 12, 2000
Department of Ecology
P. O. Box 47600
Olympia, Washington 98504-7600
Dear Mr. Gallagher,
I am writing on behalf of our 40,000 members to urge implementation of Ecology's draft plan to eliminate dioxin and other dangerous persistent, bioaccumulative toxic (PBT) pollutants that are produced, used, stored and disposed of in Washington State.
We strongly support the plan's recommendation to address the widespread problem of using industrial wastes in agricultural fertilizers. We applaud Ecology's plan for addressing two key points as follows:
- "Make steel-mill flue dust subject to the same standards as other hazardous wastes and waste-derived fertilizers applied to land. This waste contains dioxin, arsenic, cadmium, lead and mercury and was widely used in fertilizers in Washington state until the state convinced the Environmental Protection Agency to reverse an exemption that encouraged its use in fertilizers."
- "Develop a regulation to limit concentrations of metals (including mercury, lead, cadmium and arsenic) in fertilizers sold within Washington State."
These are good steps in the right direction; however, they do not go far enough. We understand that the draft PBT plan as written does not prevent the toxic wastes that contain PBTs from being used for fertilizer. The plan actually would establish amounts of PBT metals (and other metals) that can be added to soil over time and build up. There is no mention of modifying this rule and taking a preventive approach. Nor is there any mention of addressing dioxin or other PBTs in fertilizer, which has been documented by state agencies.
We urge you to strengthen the language of Ecology's draft plan not just to limit but to prohibit PBT-contaminated substances in any fertilizer product. To allow any amount of PBT-contaminated substances in agriculture does not serve the interest of protecting public health, but rather would protect industrial exploitation of a hidden, hazardous waste disposal method.
Our food supply is contaminated with PBTs including dioxin, mercury, and others not only from fertilizers, but from a myriad of sources including pulp mills, incinerators, and other polluters. Ecology's plan must address all of these sources with concrete actions. These industrial wastes have no place in our environment and our food production system.
Dioxin from incinerators, for example, goes into the air and the particles settle on grazing land. Cows eat the grass and the dioxin becomes concentrated in their meat and milk. It also concentrates in livestock fed dioxin-tainted grain. Dioxin particles fall into rivers, lakes and the oceans — or get there from runoff. Fish and shellfish ingest particles of sediment and dioxin builds up in their bodies. According to leading epidemiologists, such as Richard Clapp of the Boston University School of Public Health, more than 90 percent of our dioxin exposure comes from food — mostly fish, poultry and non-skim dairy products.
The Department of Ecology's own Web site acknowledges that many PBTs are linked to a variety of adverse effects on human health, including effects on the nervous and reproductive systems and are associated with cancer and developmental problems. The developing fetus and children are most vulnerable because their young systems are still developing.
We applaud Ecology for proposing a plan to identify and explore options for PBT elimination. We understand the need for a timeline to achieve these goals, yet we envision a shorter time frame than the target date of 2020 for phasing out use and production of these chemicals. To allow 20 years for cleaner technologies to emerge and replace existing technologies is too lenient and increases the cumulative threat. Setting a shorter timeframe, 2002 or 2003, will prompt substitutes for the products or processes that generate PBTs. Necessity is the mother of invention. We support regulatory requirements, not voluntary compliance.
We urge you to make the draft plan stronger to prohibit these dangerous pollutants from our environment, especially from our food supply system. PBT wastes laden with dioxin and other deadly chemicals have no place in our environment, in fertilizer or our food chain.
Chief Executive Officer