"Recycled" hazardous wastes in fertilizer
Feb. 25, 2001
Christie Todd Whitman
Environmental Protection Agency
401 M Street, SW
Washington D.C., 20460
Re: docket # F-2000-RZFP-FFFFF
Dear Ms. Whitman,
We're writing on behalf of our 40,000 member households to urge you to strengthen a proposal regarding "recycled" hazardous wastes in fertilizer.
We commend the U. S. Environmental Protection Agency for proposing initial steps to limit toxic waste in fertilizer, but the draft plan falls short of a common-sense threshold. The plan as drafted does not prevent toxic wastes from being used for agricultural, lawn and garden fertilizers. It only would establish amounts of these toxins that can be added to soil over time and build up. This defies a common-sense threshold that would ban all toxic, hazardous waste from being recycled into any fertilizer. Our shoppers were appalled when news of this practice first came out in a 1997 newspaper exposé.
Our food supply already is contaminated with persistant bioaccumulative toxins including dioxin, mercury, lead and others. These compounds have no place at all in our agricultural systems, in fertilizer, our food chain, or in the environment as a whole. The Washington Department of Ecology and other authorities acknowledge these PBTs are linked to a variety of adverse effects on human health. They're known to effect the nervous and reproductive systems, as well as cause cancer and developmental problems. Children are most vulnerable because their young systems are still developing.
- We urge a ban against the use of any hazardous wastes, including dioxin-laden waste, in any fertilizer. EPA has proposed a limit of 8 ppt for dioxin in fertilizer, not a ban on waste from dioxin-polluting industries. Dioxin pollution can and should be prevented. There is no way dioxin should wind up on our farms and in our food. Until a ban is in place, we ask you to adopt the most stringent technology-based standards for all fertilizers.
- Eliminate a loophole that allows hazardous steel-mill waste to be turned into any fertilizer. Between 1990 and 1995, a reported two million pounds of lead was sent from Oregon steel mills to Moxee City, Washington to be made into fertilizer. In April 1999, Washington state test results show that steel mill waste had the highest levels of dioxin out of any fertilizer sources tested, including pulp-mill waste, cement-kiln dust and tire-incinerator ash. The state tests also show that fertilizers from steel-mill waste can contain lead, as well as some of the highest levels of arsenic, cadmium and mercury found in fertilizer. Steel-mill waste should not get special exemptions.
- Eliminate an exemption for mining wastes used to make micro-nutrient or any fertilizer product. EPA itself says it's aware of at least one fertilizer that benefits from this loophole. EPA says "data compiled by EPA on fertilizer contaminants indicate that 'Ironite' (brand name fertilizer) contains, by a wide margin, the highest levels of arsenic of all fertilizer products surveyed." Ironite should not get special treatment.
- Retain existing requirements for managing hazardous waste being made into fertilizer. EPA has proposed lifting requirements for hazardous waste permits and for tracking shipments of such waste made into fertilizer. We urge EPA to maintain the regulations to ensure proper handling, tracking and treatment of the waste.
- Adopt full reporting and tracking systems, including labeling requirements so consumers know what hazardous wastes are being made into fertilizer and what toxics they may contain. Anything less than full disclosure is to deny consumers their basic right to know. Labels must include the levels of contaminants and whether the product was made from hazardous waste.
PCC Natural Markets is a consumer-owned retail food business in western Washington. We remind you that the natural and organic food industry has been growing 20-25 percent over the past several years, in part, because consumers are demanding a wholesome, healthful food supply. Consumers do not want our farms, gardens and lawns to serve as a cheap and convenient dumping ground for industrial polluters.
Randy Lee and Tracy Wolpert, Acting Co-CEOs