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Safer Fertilizer Products Need to Be Labeled Safer Choice—Comments Due to EPA by Sep 11
We have an important opportunity to tell the U.S. Environmental Protection Agency (EPA) to evaluate fertilizers for compatibility with natural systems, protection of soil organisms, waterways, human health, and helping to mitigate the climate and biodiversity crises—by labeling safer fertilizers as Safer Choice. We previously initiated an action on EPA’s Safer Choice program to request it be more holistic and in sync with natural systems, not just a product substitution program. Now, we are taking action on a specific request to the agency that it labels certain fertilizers as Safer Choice for meeting standards that support the sustainability of life in agriculture, landscaping, and gardening as opposed to introducing (i) petrochemical fertilizers that contribute to the climate emergency, biodiversity collapse, and the destruction of biological systems, or (ii) biosolids that disperse hazardous contaminants. Written comments are due by September 11, 2023 (instructions below).
The U.S. Environmental Protection Agency (EPA) is considering expanding its Safer Choice program (not to be confused with Beyond Pesticides’ pre-existing Safer Choice program). EPA’s Safer Choice is a non-regulatory program that identifies alternative chemicals for a number of uses that meet expanded safety criteria. (For pesticidal uses, the program is called Design for the Environment (DfE), which has so far been limited to disinfectants.)
>>Tell EPA to add fertilizer products to Safer Choice. Comment text is at the bottom of the page.
For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods.
However, sometimes the choice of material drives the choice of system—as is the case for fertilizers. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer.
EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers.
The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants, such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers.
Dates:
- Virtual Listening Session: August 29, 2023, 2:00–3:00 p.m. EST. To receive the webcast meeting link and audio teleconference information before the meeting, you must register by 5 p.m. EST on August 28, 2023.
- Special Accommodations: To allow EPA time to process your request for special accommodations, please submit the request on or before August 22, 2023.
- Written Comments: Comments must be received on or before September 11, 2023.
>>Tell EPA to add fertilizer products to Safer Choice.
This action uses Regulation.gov to submit comments to EPA’s docket. Comments must be submitted by September 11, 2023. Please consider copying and pasting the following into your comment here!
Comment to EPA:
As EPA considers expanding the Safer Choice program, I request that it add the category of fertilizers or soil amendments.
For problems requiring a chemical solution—for example, laundry detergents—EPA’s Safer Choice is a valuable resource, and consumers would be wise to look for the Safer Choice label, which requires that EPA review all chemical ingredients, that must meet safety criteria for both human health and the environment, including carcinogenicity, reproductive and developmental toxicity, toxicity to aquatic life, and persistence in the environment. While EPA’s Safer Choice/DfE program does an admirable job of performing alternative analyses on chemicals and identifying chemicals that are less hazardous, it stops short of identifying systems that make chemical inputs unnecessary. Substituting a less toxic pesticide, for example, is not the same as switching to available organic methods.
However, sometimes the choice of material drives the choice of system—as is the case for soil amendments. Chemical fertilizers—those granular, powdered, or liquid products identified by NPK (the percentages of nitrogen, phosphorus, and potassium)—consist of highly-soluble chemical salts that feed plants directly, but poison soil microorganisms. The choice of such fertilizers rules out an organic system in which fertility inputs feed organisms in the soil, which release substances that feed plants. Chemical fertilizers also contribute to climate change because they are produced with fossil fuels and limit the ability of soil to draw down (sequester) atmospheric carbon, thus undermining efforts to mitigate the climate emergency and the horrific fire and flooding events that destroy life. Chemical fertilizers, in addition, produce weak growth that invites insects to feed on the plants. Aphids, for example, have long been known to increase on plants fertilized with soluble nitrogen fertilizer.
EPA encourages the land application of biosolids (sewage sludge), noting benefits to soil fertility and structure and other “economic and waste management benefits (e.g., conservation of landfill space; reduced demand on nonrenewable resources like phosphorus; and a reduced demand for synthetic fertilizers).” However, as summarized by the Guardian, “Now the practice is behind a growing number of public health problems. Spreading pollutant-filled biosolids on farmland is making people sick, contaminating drinking water and filling crops, livestock, and humans with everything from pharmaceuticals to PFAS.” Biosolids used as fertilizer also contribute plastic to the soil. Unfortunately, many products derived from biosolids are sold as “organic” fertilizers.
The wise gardener or farmer chooses soil amendments that are not toxic to the soil, environment, or consumers. One way to ensure freedom from chemical fertilizers or biosolids is to look for the OMRI (Organic Materials Review Institute) seal. Organic standards specifically prohibit the use of sewage sludge (aka biosolids), but the home gardener may not always be able to discern the materials from which “organic” fertilizers are made. In addition, “organic” fertilizers sourced from composted manure generally come from nonorganic confined animal feeding operations (CAFOs) and may also contain undesirable contaminants such as antibiotics, antibiotic resistance genes, pesticide degradants, or heavy metals. Since these contaminants are not regulated, Safer Choice could offer an additional indicator of safety for gardeners and farmers.
Please add the category of fertilizers or soil amendments to Safer Choice.
Thank you.