Factory Farming: Conclusions and Recommendations
Between 1990 and 1995, manufacturers sent hundreds of millions of pounds of hazardous materials to
fertilizer companies and businesses that appear to be farms, where they were almost certainly incorporated into nutrients that are spread on the soil that produces America's food supply. The ultimate use of these chemicals, however, is difficult to determine because of severe limitations in the federal programs -- most notably the Toxics Release Inventory -- that are theoretically designed to guarantee the public the right to know the fate of industrial waste and toxic chemicals used or generated in their communities.
Recommendations
Anyone who uses fertilizer has the right to know what is in it, and whether is was made from toxic
industrial waste. But beyond this basic public right to know, health officials need to know what is in the
nation's fertilizer in order to protect the nation's food supply, rural communities, and farmers from toxic
chemical contamination. Agricultural authorities, in turn, need an efficient means to monitor possible
contamination of the nation's cropland with toxic metals and industrial chemicals.
To achieve these goals we recommend:
- Expansion of the Toxics Release Inventory to include full chemical use reporting for all manufacturing,
utility, and waste-treatment facilities. The EPA is considering expanding the Toxics Release Inventory to
include materials accounting requirements as done in New Jersey and Massachusetts. This would be an
important first step toward fulfilling the public's right to know about toxic chemicals in their homes,
workplaces, and communities.
- Elimination of the RCRA exemption for K061 waste. This would close a recycling loophole that allows
millions of pounds of heavy metals, carcinogens, and dioxin to be incorporated into fertilizer and applied
to the nation's farmland.
- A ban on the use of any hazardous waste in fertilizer production that could possibly be contaminated
with dioxin. At a minimum this ban would prohibit waste from the steel industry, hazardous and municipal
waste incinerators (including pulp incinerators) and cement kilns as a raw feed stock for fertilizer
production.
- A moratorium on all waste incorporation into fertilizers until standards for non-degradation of the
soil can be designed and enforced. A policy of non-degradation would limit application of materials to the
soil that would result in a net increase of toxics in the soil over a 40 year or longer time period.
- All raw materials used to produce fertilizers should be tested for toxic constituents. This
requirement would include but would not be limited to cement kiln dust and mining waste.
- Full labeling of fertilizers. Fertilizers derived from toxic waste should be tested for heavy metals,
persistent organic poisons, and other toxics, and the results of those tests should be printed on labels on
the containers. All fertilizers derived from toxic waste should be labeled as such.
- Monitoring farms treated with toxic waste derived fertilizers for leaching of materials from the
cropland into the surrounding environment. In addition, a record of use of these chemicals on the land
should be retained as an addendum to the land deed in order to inform and protect future purchasers of the
land. Farms treated with toxic waste-derived fertilizers could contain high levels of heavy metals and
other persistent poisons. These chemicals are some of the most commonly found pollutants at Superfund
sites and could create a toxic legacy for generations to come.