Top 10
Reasons to Use Archipelago Bat Guano
4.
Superior results and relatively safe compared to other organic and
synthetic phosphate fertilizers that may contain significant
concentrations of radioactive nuclides, uranium and other potentially
toxic materials, including “Mad Cow” and fluoride
The most common sources of phosphate for fertilizer include rock
phosphate, bone meal, fresh guano or manure, and fossilized guano.
Of these, rock phosphate is by far the most common source.
Actual compositions of individual
fertilizer brands certainly vary, but in general, there are widely-reported
environmental and/or health concerns associated with each.
Rock
Phosphate and Water Soluble Phosphate
“Rock phosphate” generally refers to phosphate-bearing rocks that were
deposited in oceanic sediments millions of years ago. Most of the
rock phosphate production in the U.S. is from Florida (about 85% of U.S. production) and Idaho (about 15% of U.S. production). Minor
amounts of rock phosphate are mined in North Carolina and Louisiana.
Raw rock phosphate is not used much in
agriculture because in its raw form, little of the phosphorous is
available to plants for uptake, it releases its nutrients very slowly,
and it is generally ineffective on crops.
However, when rock phosphate is leached with a strong acid, the phosphate
that remains in the acid is concentrated in a form that is much more
available to plants. The phosphoric acid that is created by this
process is then treated to form products such as superphosphate,
triple superphosphate, MAP, DAP, and
others. This form of phosphate is commonly referred to as Water
Soluble Phosphate (WSP).
The vast
majority of all phosphate fertilizers sold in the U.S. contain
WSP. However, these products are synthetic and therefore not
allowed for use in organic farming.
When a petition was made to add one of the superphosphate
products commonly known as triple superphsophate
to the National List of Allowed Synthetics so that it could be used in
organic farming, it was recommended that the petition be denied.
Some specific cited concerns with the superphosphate
included:
-
Heavy metals and radionuclides are present in
the superphosphate and these pose potential
risks to human health (citing EPA).
-Fluoride
is released when the superphosphate breaks
down.
-Production
of the superphosphate causes major
pollution.
These concerns
are addressed in more detail below.
Uranium and Radioactive Nuclides [back]
Rock phosphate typically contains a variety of potentially toxic elements.
The concentrations of these elements vary from deposit to deposit.
Some rock phosphate deposits
contain high concentrations of uranium, thorium and their radioactive
daughters. When such rock phosphate is treated to form phosphoric
acid, most of the radium-226 is collected in the waste. However,
most of the uranium and thorium remain in the final fertilizer product.
These elements are not currently removed from the fertilizer because it
is too expensive.
Although radium-226 goes preferentially to the waste, the EPA reports
that the radium-226 content of phosphate fertilizer averages 5.7 pCi/g (by statute, a radium-226
concentration greater than 5 pCi/g is the
health-based-determined lower-limit threshold for toxic waste).
Reportedly, uranium, which preferentially stays in the final fertilizer,
is another potential chemical and radioactive toxin commonly found in
rock phosphate and WSP. One study found that the uranium contents
of superphosphate fertilizers ranged from
97-196 ppm. The uranium contents of the
rock phosphate fertilizers ranged from 10-189 ppm
(background uranium levels in soil are reportedly 4-5 ppm).
Because of these high uranium concentrations in rock phosphate-based
fertilizers, one study estimated that between 1910 and 1998, about
260,000 metric tons of uranium had been applied to soils across the U.S. through the use of
phosphate fertilizer products.
It is not clear what the final fate of this uranium is. Some
studies suggest that it builds up in the soil. Others suggest that
there is no buildup in the soil, even after many years of
fertilization. Some suggest that the uranium ends up in
groundwater. This is a concern because uranium is potentially
harmful not only as a radioactive material, but also as a chemical
compound. One study provides that it is comparable to arsenic in
chemical toxicity.
Advocates of rock phosphate-derived fertilizers generally contend that there
is no danger posed by the radioactivity of these fertilizers. There
is growing evidence though that in at least one heavily-studied
health-related area, this may not be true. Many studies now report
that many, if not most, smoking-related cancers are caused by the high
radioactivity of tobacco. The element of greatest concern is
polonium-210 (the poison used to kill the ex-KGB agent in England in
November, 2006). This element is reported to be present in rock
phosphate-based fertilizer that is commonly used on tobacco.
Reportedly, after the element is introduced by fertilization, tobacco
takes this element out of the soil and concentrates it in the
leaves. The leaves are then smoked, and the smoker is exposed to
the radioactivity. Ultimately, it is reported that about 90%
smoking-related cancers may be caused by such radiation.
If you decide to delve further into this
issue, be aware that most regulations concerning naturally-occurring radionuclides appear to only be concerned with
radium-226.
Our understanding is
that this radionuclide is of greatest importance because it is the only
one that emits radiation that can penetrate skin.
All of the others apparently are alpha
emitters, and they cannot penetrate skin.
However, if ingested, alpha emitters reportedly can do harm to
internal organs.
Fluoride [back]
Another potentially harmful material that is strongly associated with
rock phosphate and fertilizers derived from rock phosphate is
fluoride. Fluoride contents of fertilizer are not regulated and
they are therefore not usually reported. One study reported
fluoride concentrations in raw rock phosphate to range between 0.19-4.2%. Reported values from other studies
generally fall within this range, with the most commonly reported value
being about 3-3.5%. Fluoride contents of phosphoric-acid-based
fertilizers reportedly are generally less, and may be as low as
0.1%. Reportedly, the fluoride that is captured during the
production of phosphoric acid from rock phosphate cannot be released into
the atmosphere or waterways because it is hazardous waste. However,
the untreated raw byproduct fluoride is reportedly sold directly to
municipalities to add to drinking water.
The concentration of fluorides in typical soils is reportedly between 200
and 300 ppm. Repeated application of
phosphate fertilizer reportedly results in buildup of fluoride in the
soil. Fluoride does not break down in the environment, and once it
is in the soil, plants can uptake the fluoride and it may end up in the
human food chain. Many foods reportedly contain abundant
fluoride.
So what’s the problem? Fluoride is harmless, isn’t it? Well,
probably not. There is great debate though over just how harmful it
is. Most of this debate concerns health problems related to
long-term exposure at low doses. Some suggest that this contributes
to various cancers, reproductive system problems, low IQ, Alzheimer’s,
increased incidence of hip fractures in the elderly, and various other
maladies. Others claim there are essentially no serious long-term
effects. The answer is likely somewhere in the middle.
There is little debate though as to the acute toxic effects of exposure
to a high dose of fluoride - sudden death. Essentially all sources
agree that death from fluoride poisoning has occurred at a dose as low as
5 mg/kg body weight and that 32 mg/kg of body weight is the certain
lethal dose. Death usually occurs within hours of exposure (one
study found that where a 3-year-old boy ingested a single dose of 16 mg
fluoride/kg body weight, death occurred 7 hours after ingestion).
Thus, because of the reportedly high fluoride content of raw rock
phosphate, some have questioned the safety of this product in homes that
have small children. For instance, the Organic Consumer’s
Association reported that with a rock phosphate containing 5% fluoride,
ingestion of one ounce of rock phosphate, the amount recommended to
fertilize a single tomato plant, could kill a small child. This is
a serious statement, so we did our own literature search to see if the
literature supports the statement. With a slight qualification,
because 5% is, based on other sources, too high for raw rock phosphate,
it appears that the statement may be substantiated by the literature.
(All of the members of ABG are scientists or engineers but none of us are
medical doctors. The information here, or anywhere in the website,
is not a medical opinion whatsoever, it is just a review of the
literature that we were able to find on the subject. You should consult
a medical doctor for an opinion.)
Our analysis of the literature follows. Five percent of one ounce
is 1,417 mg. Thus, with a 5 weight % fluoride concentration, an ounce of
rock phosphate would contain 1,417 mg of fluoride. Further, a
widely cited study reported that when rock phosphate is ingested by farm
animals, 26-28% of the fluoride is retained in the body (see Fluorine in
Animal Nutrition, C. Kick et al., 1935, Bulletin 588, Ohio Agriculture
Experiment Station.
http://www.bruha.com/pfpc/html/kick_et_al___1935.html).
And twenty six percent of 1,417 mg is 368 mg. Further, the reported
certain lethal dose of fluoride is 32 mg/kg of body weight, and 368 mg /
32 mg/kg is 11.5 kg. If Kick’s results can be used for people, and
we have interpreted his results correctly, then this is the body weight
that would receive a certain lethal dose of 32 mg/kg fluoride from
ingestion of rock phosphate containing 5% fluoride (11.5 kg is about
25 pounds). Further, most victims of fluoride poisoning are between
2-3 years of age (see
www.fluoride-journal.com/97-30-2/302-89.htm).
And at 2 years, about 26% of healthy girls weigh 25 pounds or less.
Of course though, if 3-4% fluoride were used as a more likely
concentration for rock phosphate, the potential toxicity would obviously
be lowered by 20-40%. However, because death has reportedly
occurred at concentrations as low as 5 mg/kg body weight (many sources
consider 5 mg/kg to be the lethal dose), which is 6 times lower than the
certain lethal dose used above, this difference appears to be mitigated.
Thus, in our non-medical opinion, the literature appears to support that
the statement by the Organic Consumer’s Association may be within the
realm of possibility.
Heavy Metals [back]
Heavy metal concentrations in rock phosphate and fertilizers derived from
rock phosphate are another potential concern. Unlike fluoride,
uranium, and other radioactive nuclides, some heavy metals commonly found
in fertilizers have recently become regulated by a few states.
Washington is the leader in this endeavor. As a public service,
Washington provides a regularly-updated comprehensive report on metal
concentrations found in fertilizer sampled by WSDA at
http://agr.wa.gov/PestFert/Fertilizers/ProductDatabase.htm
or
http://agr.wa.gov/PestFert/Fertilizers/docs/rptFertHMWeb.pdf.
Of the three states that comprehensively regulate heavy metals in
fertilizer, California regulates arsenic, cadmium
and lead; Oregon regulates arsenic, cadmium,
lead, mercury, and nickel; and Washington regulates arsenic, cadmium,
lead, mercury, nickel, cobalt, molybdenum, selenium, and zinc. Washington is unique in that it does
not regulate the metal content of fertilizer per se.
Instead, it regulates the amount of
metal that would be added to the soil by application of a
fertilizer. Thus, a fertilizer that does not meet the standards may
lower its suggested application rate without otherwise altering the
product, and thus be within the limits. The other states regulate
the metal contents in the fertilizer product itself.
It appears that cadmium is the heavy metal of greatest concern in
fertilizer. In a Washington State Department of Agriculture study
that considered the plant uptake of arsenic, lead, and cadmium
(coincidently, the only three metals that California regulates), cadmium
was found to be of the greatest concern because cadmium builds up in the
soil and plants can take it up. Some plants, such as lettuce, were
found to contain more cadmium in the plant when more was available in the
soil. In one study area, there was a clear linear relationship
between cadmium in soil and cadmium in plants.
Arsenic and lead were not taken up by
plants in the same way as cadmium.
Part of the problem with cadmium is that although the human body has no
use for it (U.S. Department of Health and Human Resources reports that
“there are no known good effects from taking in cadmium.”), it is readily
taken into the body because it closely mimics calcium. The U.S.
Department of Health and Human Services also reports that “cadmium stays
in the body a very long time and can build up from many years of exposure
to low levels.” Ultimately, cadmium exposure may damage the lungs, can
cause kidney disease, and may irritate the digestive
tract.
Limiting cadmium in your diet could probably help.
Reportedly, the general population is
exposed to cadmium from breathing cigarette smoke or eating cadmium
contaminated foods. It is further reported that phosphate
fertilizer alone is responsible for 41% of the human exposure to cadmium,
and that application of phosphate fertilizer is one of the principle
sources of cadmium releases to soil. Reportedly, cadmium
concentrations of phosphate fertilizers range from 0.05 to 170 ppm. One study found that continuous
fertilization with a high rate of triple superphosphate
fertilizer for a period of 23 years resulted in a 14-fold increase in
cadmium content of surface soils. Ultimately, the U.S.
Department of Health and Human Resources reports that people “who ingest
grains or vegetables grown in soils treated with municipal sludge or
phosphate fertilizer all may have increased (cadmium) exposure.”
Environmental Concerns at Rock Phosphate Mines
and Fertilizer Plants [back]
The waste that is left behind at rock phosphate processing plants poses
yet another environmental problem. The EPA reported that, if 5pCi/g
is used as the criteria for defining potentially hazardous waste, of the
755 million metric tons of potentially hazardous waste produced annually
from asbestos, copper, gold, lead, silver, uranium, and zinc mining
combined, the U.S. phosphate mining sector contributes 352 million metric
tons. This is 46% of the total. Also, as of 1985, all U.S.
mine waste (potentially hazardous and non hazardous combined) that
existed on site at the various operations within all of these mining
sectors, totaled 39,584 million metric tons. U.S. phosphate mining
operations alone contained 16,599 million metric tons of waste, or almost
42% of all the existing mine waste from these mining sectors.
It is reported that of the 23 phosphate mines in Idaho, all but one is a
Superfund site. The Idaho Department of Environmental Quality
reported that groundwater beneath phosphate processing sites in the Soda
Springs area "is contaminated with cadmium, selenium, vanadium,
fluoride, molybdenum, tributyl phosphate, and
manganese." Furthermore, "ground water studies conducted
down-gradient of the phosphorous plants northwest of Pocatello have shown
that levels of arsenic, lead, and cadmium in the ground water exceed the
federal Drinking Water Standards. Off-site soil contaminants
include radium-226, zinc, cadmium, fluoride, and total phosphorous.
On-site soil contamination includes cadmium, chromium, copper, vanadium,
radium-226, lead, and nickel." However, it appears that the
element of greatest concern in Idaho is Selenium. It is reported
that since 1996, 547 sheep have died from selenium poisoning in the
vicinity of the phosphate mines. Selenium poisoning in that area
may also have led to the deaths of horses and salamanders. Water
foul and fish are also reportedly affected.
In Florida, the greatest environmental concern appears
to be the storage of radioactive waste in areas where the radioactive
elements may inadvertently migrate to the groundwater or the ocean.
Radium-226 is reported to be one of the most potentially hazardous radionuclides present in rock phosphate waste.
The EPA reports that “mining and current methods for processing phosphate
ore for fertilizer generate large piles or “stacks” of phosphogypsum, in which naturally occurring radium is
concentrated.” U.S. Fish and Wildlife reports that
“radium-226 in sediments from phosphate settling basins in central Florida averaged 23.8
pCi/g.” They further add that 5 pCi/g radium-226 is the concentration which is the
criterion for identifying toxic waste. It is reported that the
piles of radioactive waste left behind at one phosphate fertilizer plant
alone is “one of the biggest environmental threats in Florida history.”
However, some suggest there is no problem here. The Florida
Institute of Phosphate Research, an affiliate of the University of South Florida, reports that “it is not
known at what levels radiation becomes harmful to human health. In
fact, there are some experts who believe that radiation at low levels
could be beneficial. Radiation at high levels, like that emitted in
Japan after atom bombs exploded,
is harmful to human health. It is uncertain how much radiation
becomes dangerous.” Thus, because exposure to radioactivity from
rock phosphate products is possibly beneficial, and at worst, it is less
harmful than atomic bombs, you should assess the risk of using
them. The paper suggests that comparative risks include eating 100
charcoal broiled steaks, spending 2 days in New York City, driving 40 miles in a car,
flying 2,500 miles, or canoeing for 6 minutes. Also, the article
warns to be aware of reports of “toxic” materials in phosphate
fertilizers because the word is used loosely and you might mistake
harmless materials with dangerous sounding names as materials that are
actually dangerous. The report provides that “dihydrogen
monoxide, for instance, could sound dangerous if you did not know it was
a chemical name for water.”
Bone Meal [back]
Bone meal is a phosphate product that is derived from the bodies of
animals such as cows and fish. Unless stated otherwise, the product
is usually made from cow carcasses. Bone meal is commonly used by
organic farmers and home gardeners because it is relatively abundant and
inexpensive. Also, compared to raw rock phosphate, it contains much
more available phosphate and it is generally more effective on plants.
However, because bone meal is derived from recently deceased animals,
vegetarian organizations recommend against its use. Another widely
reported problem is that dogs and other carnivorous animals that may be
attracted to the smell of bone meal will dig up gardens where this
material is applied. Some articles suggest that bone meal should
not be used if such animals are present.
A much more controversial issue concerns the possible relationship of
bone meal, Bovine Spongiform Encephalopathy (BSE or Mad Cow disease),
Creutzfeldt-Jakob disease (CJD), Alzheimer’s, and variant
Creutzfeldt-Jakob disease (vCJD) (the human
form of Mad Cow).
Most sources agree that BSE is most likely spread through the consumption
of BSE-infected meat and bone meal. Most sources also generally
agree that the prion that is the suspected
transmission agent for BSE is very difficult to destroy. Because of
this, the U.S. and Britain no longer allow cattle bone
meal to be fed to cows.
Briton
does not allow the use of bone meal in agriculture either.
The controversial aspect really begins with the purported link of BSE to vCJD. The similarity of time and space of
outbreaks of BSE in cattle and infections of vCJD
in humans in England is reportedly a strong
empirical relationship. There are also reportedly strong
similarities in the suspected prion and
symptoms in both diseases. Although most researchers appear to
agree there is a link, some hold that the connection has not yet been proven.
Even more controversial is the possible link of BSE to CJD and
Alzheimer’s. Some suggest that a reported 9,000% increase in
Alzheimer’s cases and reported misdiagnosis of CDJ as Alzheimer’s may
indicate that BSE is already infecting people in this country. We
have provided links to some informational web pages below so that you can
begin to read about this and decide for yourself if humans can be
infected with BSE, and to what extent.
But
if humans can be infected, the next question is whether there is a
mechanism for infection.
If, as
many claim, there is essentially no chance of cattle in the U.S. being BSE-infected, and all
bone meal comes from U.S. cattle, then the answer
clearly is that there is no risk. However, whether the U.S. is actually BSE-free is
controversial. We have supplied links below for more information so
that you can begin research to find the answer that you believe
most. If you find that you believe the answer is that there is
potential that BSE-infected cattle parts may be incorporated into bone
meal, the answer as to whether vCJD infection
could result from use of BSE-infected bone meal as a fertilizer is not
known for certain.
A number of sources state there is concern for gardeners using
BSE-infected bone meal. Some suggest that even though they believe
the risk is extremely low, gardeners who are concerned should wear a mask
and avoid bone meal exposure to open cuts. On the Dateline program,
two doctors suggested there was a possible link to vCJD
infections and the use of bone meal as a fertilizer in the home gardens
of victims. They had no proof of the connection, but nevertheless
suggested that it should not be used. So most of the available
information suggests that there is a possible concern, but these concerns
appear just antidotal.
No studies
are cited and no proof is given.
And although we found no studies regarding the risk of using BSE-infected
bone meal as fertilizer, we did find one published paper that addresses
the safety of fertilizer that is derived from acid treatment of bone
meal. A report that was released through the European Union’s
Health Consumer Protection Directorate-General specifically addressed the
safety of dicalcium phosphate and tricalcium phosphate made from bovine bones and used
as a fertilizer. These products are apparently made much as WSP is
made from rock phosphate – by passing strong acid through bone meal to
leach the phosphate from it. The resulting phosphate-rich acid is
then used as a fertilizer. So the study concerns this end product, and not bone meal per se.
The report concluded that it is probably safe to use these
bone-meal-derived phosphate fertilizers. However, at page 3, the
report makes an interesting qualification. There, it states that
“because of the longevity of the TSE agent protein (BSE protein) in
soils, the risk of accumulation in the environment of possible residual
risk is not completely excluded if applied in large quantities or
repeatedly on a same area.” We are not exactly sure what that
means, but it appears to say it is safe as long as you do not use
it.
Make of that what you
will. The entire report is available at
http://ec.europa.eu/food/fs/sc/ssc/out322_en.pdf
Fresh
Guano and Manure
Fresh guano and manure products may contain relatively small quantities
of phosphate. Typically, they also contain significant quantities
of nitrogen, beneficial bacteria, and organic carbon. The problem
that most people perceive with these fertilizers is that they may smell
bad and harmful bacteria such as e-coli and salmonella may be
present.
The smell may be lessened if the material is composted before
usage. The dangers of harmful bacteria are mitigated in organic
farming by a generally-observed requirement that edible portions of
plants cannot be harvested for 90 or 120 days following application of
fresh manure or guano. The time limit is 120 days if the edible part
of the plant touches the ground and 90 days if it does not touch the
ground.
ABG
Phosphate [back]
We believe that most of the concern in buying and using fertilizer comes
from the unknowns. Fertilizer companies generally do not report a
lot of information about their products and only a few states regulate
them closely. Consumer education and activism is gradually changing
this.
So here is what we know about ABG phosphate. It is 100% natural and
organic and it is OMRI listed for use in production of organic food and
fiber. It is bat guano that was deposited in caves hundreds of
thousands of years ago. As time passed, the nitrogen and moisture
mostly volatized away, leaving a fossilized material concentrated in
phosphate, calcium, and all the other non-volatile nutrients that were
present in the original guano.
At some time, thousands of years ago, the bat caves collapsed.
Thus, there are no bats or other cave creatures present. Mining is
conducted by local residents and it is done by pick, shovel, and small
automated equipment. Locally, there is stripping of the overlying
rock and this material is piled on the surface. The only processing
that is done is that it is ground to a fine grain-size and then blended
by hand on large tarps to get an even blend. There are no
processing by-products. We pay the locals very well, and through
our Indonesian partners, we support the local community the best we
can.
ABG Phosphate is more like a rock than fresh manure or guano because it
lacks organic carbon, nitrogen and potentially harmful pathogens that are
commonly associated with fresh guano or manure. Because of this,
OMRI lists ABG Phosphate as a “mined material” instead of as
“guano.” State fertilizer regulators will generally allow us to
call it “fossilized guano,” but most people appear to see only “guano,”
and immediately fear pathogens. This has been a problem for
us. We thought hard about calling it rock phosphate instead to
avoid this misperception, but we believe that the relative negative
aspects of fresh guano are less than the negative aspects of rock
phosphate. So we decided to continue to call the material
“fossilized guano,” and fight the pathogen misperception.
Table 1:
Summary Of Analysis For Pathogens (Conducted by A&L Analytical
Laboratories)
Analysis
|
Result
|
Quantitation Limit
|
E-coli Plate
Count, cfu/g
|
<10
|
10
|
Salmonella
(MPN), MPN/10g
|
<1.1
|
1
|
Carbon:Nitrogen Ratio
|
1.21
|
Calculation
|
Conductivity, mmho/cm
|
0.455
|
0.100
|
Moisture, %
|
5.79
|
0.05
|
pH, s.u.
|
7.70
|
|
Total Kjeldahl Nitrogen, %
|
2.11
|
0.01
|
Solids, Total,
%
|
94.21
|
0.05
|
Total Organic
Carbon, (TOC), %*
|
0.1
|
0.1
|
* The essential
lack of organic carbon is a strong indication that this material is not
alive. Organic carbon contents of fresh manure or guano, that would be more likely to carry potentially
harmful pathogens, would typically be much higher. In fact, manure
is applied to fields mostly for its organic carbon content.
A representative sample of
ABG Phosphate was recently examined for mineralogical composition by an
independent geologist using x-ray diffraction techniques.
His findings were that most of the
material could be weakly crystalline carbonate-apatite –Ca5(PO4,CO3) 3(OH)
with minor crandallite – Ca2Al7(PO4)
3(OH) 16.3H2O.
The uncertainty occurs because of the
weakly crystalline nature of this material.
Accessory minerals included up to 10%
calcite and minor quartz.
Much of
the calcite and iron oxide present appears to be mostly associated with
small fragments of volcanic ash, pumice and siltstone fragments that occured in the sample.
These materials probably washed into
the caves while the guano was being deposited.
At the elemental scale, the fossilized guano contains substantial amounts
of many elements, some of which are essential for plant life, and some of
which are not. The essential elements that are in greatest
concentration are phosphate (20% total and 7% available) and calcium
(17%). Other essential elements that are present in quantities that
are high enough so that ABG phosphate claims itself as a significant
source include iron, zinc, manganese and sodium (we claim the sodium
mostly to show that, unlike seabird guano that may contain up to 6%
sodium, ABG Phosphate is very low in sodium). Other essential
elements that are present in quantities that are almost high enough for
ABG Phosphate to claim as a significant source include copper and
molybdenum. ABG Phosphate is not a significant source of boron,
sulfur, magnesium, nitrogen, or potassium. Thus, of the 13
essential elements that are taken up through the soil, ABG phosphate is a
significant source of 6, and it contains at least trace amounts of 7
more. Chlorine, the one essential element that is not accounted for
here, has never been analyzed for in ABG phosphate. We will do this
in the near future and report the results.
Table 2:
Average Assay Value Concentrations of Essential Elements in ABG Phosphate
verses Minimum Concentration Required to Claim a Fertilizer as a Nutrient
Source (California)
Element
|
Concentration
of Elements Present in ABG Phosphate (%)*
|
Minimum
Concentration Required (%) to Claim as a Nutrient Source (CA)
|
Nitrogen (%)
|
0.08
|
1
|
Available Phosphate
(%)
|
7
|
1
|
Potassium (%)
|
0.17
|
1
|
Chlorine (%)
|
Not Analyzed
|
0.1
|
Boron (%)
|
0.007
|
0.02
|
Calcium (%)
|
21
|
1
|
Iron (%)
|
4.1
|
0.1
|
Magnesium (%)
|
0.17
|
0.5
|
Manganese
(%)
|
0.9
|
0.05
|
Sodium (%)
|
0.16
|
0.1
|
Sulfur (%)
|
0.02
|
1
|
Cobalt (%)**
|
0.00135
|
0.0005
|
Copper (%)
|
0.0552
|
0.05
|
Molybdenum
(%)
|
0.00042
|
0.0005
|
Zinc (%)
|
0.2278
|
0.05
|
Bold = Elements claimed by ABG Phosphate.
Italics = Elements that ABG Phosphate has almost enough of
to claim.
*Except For
available phosphate, these are average assay values, not guaranteed minimums.
**Cobalt is on
the California list even though it is
generally not considered an essential element.
Table 3:
Amount of Essential Nutrients Provided by ABG Phosphate.
Nutrient
|
Concentration
of Nutrients in ABG Phosphate (ppm)*
|
Washington Suggested Nutrient
Application Rate (lb/yr)
|
Amount of
Nutrient Demand Met if 100% of Phosphate (175 lb/yr) is Applied (%)***
|
P2O5 (ppm)**
|
120000
|
175
|
100.00
|
Nitrogen (ppm)
|
800
|
400
|
0.29
|
Potassium (ppm)
|
1700
|
400
|
0.62
|
Boron (ppm)
|
70
|
3
|
3.40
|
Calcium (ppm)
|
210000
|
200
|
153.13
|
Iron (ppm)
|
41000
|
20
|
298.96
|
Magnesium (ppm)
|
1700
|
100
|
2.48
|
Manganese (ppm)
|
9000
|
10
|
131.25
|
Sulfur (ppm)
|
200
|
100
|
0.29
|
Copper (ppm)
|
552
|
2.5
|
32.20
|
Molybdenum (ppm)
|
4.2
|
1
|
0.61
|
Zinc (ppm)
|
2278
|
7.5
|
44.29
|
*Based on
average assay value, not guaranteed minimums.
**Based on
suggested application rate as a 0-12-0 fertilizer
***To get the
suggested 175 pounds/acre/year of phosphorous from a fertilizer that
releases 12% phosphate over the course of the year, 1,458 pounds of
fertilizer would need to be applied. If this amount of ABG
Phosphate was applied, 100% of the suggested phosphate demand would be
met. Similarly, at that same application rate, 299% of the
recommended iron, 153% of the recommended calcium, 131% of the recommended
manganese, 44% of the recommended zinc needs, and 32% of the
recommended copper needs would be met. The other essential
elemental needs would not be substantially affected by application of
ABG Phosphate. It is important to note that the elements that are
most strongly associated with high heavy metal concentrations are
phosphate, iron, zinc, and manganese. ABG Phosphate fills much of
the demand for these elements.
|
Currently, only Washington, California, and Oregon have implemented
comprehensive regulations over heavy metals in fertilizers.
Generally, these states require that the source of nutrients be
identified and that the amount of heavy metals cannot exceed State
standards. The specifics of each State’s regulations are quite
varied though. California and Oregon regulate the metal contents
of fertilizer products regardless of application rate. Washington, instead, limits the amount
of metals that would be applied to soil by using a fertilizer at the
suggested maximum application rate. None of the three states
regulate all of the same elements. Also, the limits on the
regulated elements are different in each state.
Other regulatory agencies include the EPA and the Association of American
Plant Food Control Officials (AAPFCO). The EPA only regulates zinc
micronutrient fertilizer that is derived from waste products. This
is done because zinc fertilizers are the ones that are most likely to be
waste-derived. The AFFPFCO regulations are wider. This agency
generally regulates all of the metals that are regulated by the
individual states. However, the AAPFCO regulations are relatively
lax and they allow for more heavy metals than the individual
states.
Thus, to determine if ABG phosphate meets the various heavy metal
standards, both assay values and application rates are needed. Our
current packaging uses an application rate that is a default rate
suggested by the state of Washington, with the assumption that
7% phosphate would be available to the plants over the course of a
year. We recently had an independent laboratory calculate an
application rate specific to our product. The results of this
testing indicated that ABG phosphate should be considered a 0-12-0 fertilizer
for application purposes (0-7-0 for labeling purposes because this is the
amount of immediately available phosphate under the AOAC testing method,
0-12-0 for application rate because this is the amount of available
phosphate over the course of a year).
Nevertheless, based on assay values and application rates, as determined
by independent laboratories, ABG phosphate meets all of the State’s heavy
metal standards.
Table 4:
Average Assay Values For ABG Phosphate
(Conducted at
various independent laboratories)
Values in Percent
|
P2O5 Total
(%)*
|
20
|
P2O5 Available
(%)*
|
7
|
Nitrogen (%)
|
0.08
|
Potassium (%)
|
0.17
|
Aluminum (%)
|
4.8
|
Boron (%)
|
0.007
|
Calcium (%)
|
21 (we
guarantee 17)
|
Fluorine (%)
|
0.18
|
Iron (%)
|
4.1 (we
guarantee 3)
|
Magnesium (%)
|
0.17
|
Manganese (%)
|
0.9 (we
guarantee 0.5)
|
Sodium (%)
|
0.16
|
Sulfur (%)
|
0.02
|
Values in
Parts Per Million
|
Arsenic (ppm)
|
12.36
|
Cadmium (ppm)
|
8.9
|
Cobalt (ppm)
|
13.5
|
Chromium (ppm)
|
39.6
|
Copper (ppm)
|
552
|
Lead (ppm)
|
Below
Detection Limit of 1.2
|
Mercury (ppm)
|
0.37
|
Molybdenum (ppm)
|
4.2
|
Nickel (ppm)
|
20.3
|
Selenium (ppm)
|
Below
Detection limit of 5.5
|
Zinc (ppm)
|
2278 (we
guarantee 1500)
|
* The values for
total and available phosphate are guaranteed minimum values, not
averages.
Table 5: ABG Phosphate Heavy
Metal Contribution To Soil Under Washington Standards
Metal
|
Concentration in ABG Phosphate (ppm)
|
pounds/acre/year if 175 pounds/acre/year
phosphate is applied (lbs)
|
Maximum allowable pounds/acre/year (lbs)
|
% of allowable metal addition resulting
from ABG Phosphate application
|
Arsenic
|
12.36
|
0.018025
|
0.297
|
6.069023569
|
Cadmium
|
8.9
|
0.012979167
|
0.079
|
16.42932489
|
Cobalt
|
13.5
|
0.0196875
|
0.594
|
3.314393939
|
Lead
|
1.2
|
0.00175
|
1.981
|
0.088339223
|
Mercury
|
0.37
|
0.000539583
|
0.019
|
2.839912281
|
Molybdenum
|
4.2
|
0.006125
|
0.079
|
7.753164557
|
Nickel
|
20.3
|
0.029604167
|
0.713
|
4.152057036
|
Selenium
|
5.5
|
0.008020833
|
0.055
|
14.58333333
|
Zinc*
|
2278
|
3.322083333
|
7.32
|
45.38365209
|
* Note
that zinc is also a nutrient, and although application of ABG Phosphate
contributes 45% of the heavy metal addition allowed, as a nutrient, it
only provides 44% of the recommended amount that should be added.
This appears to be a catch-22 but it is
really not.
At very high
concentrations, zinc must be claimed as nutrient.
Then, only if it meets the separate
regulations for a zinc fertilizer, it is allowed.
Table 6: ABG Phosphate And
Heavy Metal Regulations (CA, OR, AAPFCO)
Table 6a: Allowable Metal Concentrations
For a 0-7-0 Fertilizer (ppm)
|
|
|
|
|
As
|
Cd
|
Co
|
Pb
|
Hg
|
Mo
|
Ni
|
Se
|
Zn
|
AAPFCO
|
91
|
70
|
21700
|
427
|
7
|
294
|
1750
|
189
|
2940
|
CDFA
|
14
|
28
|
NR
|
140
|
NR
|
NR
|
NR
|
NR
|
NR
|
OSDA
|
63
|
52.5
|
NR
|
301
|
4.9
|
NR
|
NR
|
NR
|
NR
|
|
|
|
|
|
|
|
|
|
|
Table 6b: Allowable Metal Concentrations
for a Micronutrient Fertilizer Containing 3% iron (ppm)
|
|
As
|
Cd
|
Co
|
Pb
|
Hg
|
Mo
|
Ni
|
Se
|
Zn
|
AAPFCO
|
336
|
249
|
69900
|
1389
|
18
|
900
|
5700
|
540
|
8700
|
CDFA
|
39
|
36
|
NR
|
420
|
NR
|
NR
|
NR
|
NR
|
NR
|
OSDA
|
228
|
183
|
NR
|
1020
|
13.5
|
NR
|
3990
|
NR
|
NR
|
|
|
|
|
|
|
|
|
|
|
Table 6c: Allowable Metal Concentrations
for a 0-7-0 Fertilizer Containing 3% Iron (ppm)
(AAPFCO and OSDA - Take Higher of Table 5a or 5b; CDFA - Add Tables 5a
and 5b)
|
|
As
|
Cd
|
Co
|
Pb
|
Hg
|
Mo
|
Ni
|
Se
|
Zn
|
AAPFCO
|
336
|
249
|
69900
|
1389
|
18
|
900
|
5700
|
540
|
8700
|
CDFA
|
53
|
64
|
NR
|
560
|
NR
|
NR
|
NR
|
NR
|
NR
|
OSDA
|
228
|
183
|
NR
|
1020
|
13.5
|
NR
|
3990
|
NR
|
NR
|
ABG
Phosphate Values
|
12
|
8.9
|
13.5
|
<1.2
|
0.37
|
4.2
|
20.3
|
<5.5
|
2278
|
|
|
|
|
|
|
|
|
|
|
Table 6d: The Percentage of the Allowed
Metal Concentration that is Present in ABG Phosphate (%)
|
|
As
|
Cd
|
Co
|
Pb
|
Hg
|
Mo
|
Ni
|
Se
|
Zn
|
AAPFCO*
|
3.57
|
3.57
|
0.02
|
0.09
|
2.06
|
0.47
|
0.36
|
1.02
|
26.18
|
CDFA*
|
22.64
|
13.91
|
NR
|
0.21
|
NR
|
NR
|
NR
|
NR
|
NR
|
OSDA*
|
5.26
|
4.86
|
NR
|
0.12
|
2.74
|
NR
|
0.51
|
NR
|
NR
|
WSDA*
|
6.07
|
16.43
|
3.31
|
0.09
|
2.84
|
7.75
|
4.15
|
14.58
|
45.38
|
*
AAPFCO =
Association of American Plant Food Control Officials; CDFA
= California; OSDA = Oregon; WSDA = Washington.
**
NR = Not Regulated
***
Because lead and selenium were not detected in ABG Phosphate, their
detection limits were used as the values for ABG Phosphate.
The actual values are necessarily
lower.
So in summary, ABG phosphate
does contain heavy metals, but the heavy metal concentrations are well
below all regulatory limits.
The
important thing to note is that ABG phosphate has these highly acceptable
metal concentrations while supplying at least 100% of the suggested
amounts of phosphate, iron and manganese, and 44% of the suggested amount
of zinc.
Most sources agree that
these are the elements that are the hardest to obtain without addition of
harmful non-nutrients.
This is the
real beauty of ABG phosphate: the nutrients without all the baggage.
As for fluoride, a single assay
indicated that ABG Phosphate contains 0.2%.
This is about the same as that reported
for bone meal.
It is much lower
than the values of 3-3.5% that are typically reported for rock phosphate
and 1-3% reported for rock phosphate-derived phosphoric acid
fertilizers.
This makes sense
because rock phosphate is composed of fluoroapatite,
which typically contains 3-5% fluorine, and ABG Phosphate is composed mostly
of carbonate apatite, which does not contain much fluorine. Using the same assumptions that were
used in the literature review for rock phosphate (26% retention and a
certain lethal dose of 32 mg/kg), a person would need to eat 1/16 of
their body weight to receive the certain lethal dose of fluoride from ABG
Phosphate (a person weighing 16 pounds would need to eat 1 pound of ABG
Phosphate to receive the certain lethal dose).
If the retention were 100% instead (we
have no indication of what the value really would be), a 16 pound person
would have to eat a quarter pound of ABG Phosphate to receive the certain
lethal dose of 32 mg/kg.
The worst
possible case scenario apparently would be 100% retention and death at 5
mg/kg.
In this case, death would
occur in a 25 pound person if they ate 1 ounce.
We doubt that is likely, but we really
do not know.
So in summary, you
should take care to keep this and all other fertilizer products out of
the reach of children and take care not to eat ABG phosphate.
Call poison control immediately if you
do.
Finally, we want to address the
radioactivity of ABG Phosphate.
As
stated earlier, uranium and phosphate have a natural affinity and the two
are expected to be found together in nature.
Rock phosphates generally formed in
shallow seas.
There, uranium was
in great supply because it is present in low concentrations in ocean
water.
Thus, there can be a lot of
uranium present with the phosphate.
Conversely, ABG Phosphate was formed in a terrestrial cave with no
apparent source for uranium other than the plants and insects that the
bats fed upon.
Nevertheless, as a
phosphate material, some radioactivity is expected.
We thus had a sample of ABG Phosphate
analyzed for radioactivity.
Radium-226, the radionuclide
that is most widely reported, had a concentration of
1.38 pCi/g +/-0.45.
The department of Energy reports that
approximately 1 pCi/g is typical for soil.
Other radionuclides
were present and they all derived from the uranium and thorium
series.
We really do not what to
make of the results except that as compared to values reported for the
same radionuclides in phosphate wastes, they
are low.
That comparison is
presented below.
We would have
compared the WSP fertilizer product instead, but we could not find a
comprehensive analysis for it.
All
that we know about the rock phosphate-derived WSP fertilizer itself is
that the EPA reports that the radium-226 content of it averages 5.7 pCi/g, and there are
qualitative reports of polonium-210, uranium, and thorium being
present.
Remember when reading the
following chart that raw rock phosphate is the source for both the WSP fertilizer
(the values for that are not reported here) and the phosphygypsum
waste.
Also, when fertilizer is
produced from rock phosphate, most of the thorium and uranium reportedly
go with the fertilizer and not the waste. The radium, however, mostly
reports to the waste.
Nevertheless, the concentrations of uranium and thorium are higher
in phosphate waste than in ABG Phosphate and the radium-226 is about 23
times higher in phosphate waste than in ABG Phosphate.
Also, the total reported radioactivity
of phosphate waste was 113 pCi/g, compared to 7 pCi/g for ABG
Phosphate.
Table 7: Concentration of
Radionuclides in ABG Phosphate Compared to Waste from Phosphate Plants
that Utilize Rock Phosphate to Make Phosphate Fertilizer
Nuclide
|
Concentration (pCi/g)
|
|
Phosphogypsum Waste
|
ABG
Phosphate
|
U-238
|
6.00
|
2.73
|
U-235
|
0.30
|
a
|
U-234
|
6.20
|
a
|
Pa-231
|
0.30
|
a
|
Th-232
|
0.27
|
<0.30
|
Th_230
|
13.00
|
a
|
Th-228
|
1.40
|
0.30
|
Ac-227
|
0.30
|
a
|
Ra-228
|
0.27
|
a
|
Ra-226
|
33.00
|
1.38
|
Po-210
|
26.00
|
a
|
Pb-210
|
26.00
|
a
|
Bi-212
|
a
|
<0.8
|
Bi-214
|
a
|
2.54
|
Ti-208
|
a
|
0.10
|
Total
|
113.04
|
7.05
|
The
data on phosphate waste comes from
Naturally
Occurring and Accelerator-Produced Radioactive Material, U.S. Dept. of
Energy, 1996 (Section 7.2.2.6 discusses radioactive waste
generated from phosphate mining and fertilizer production. Table
7.9 (http://web.em.doe.gov/idb96/tab79.html)
lists radionuclide concentrations of phosphate wastes.))
a =
not reported
Supporting
documents and further information can be found at the following web
sites:
General
1.
Use of Phosphate Rocks for Sustainable Agriculture, F. Zapta and R. Roy, Food and Agriculture Organization
of The United Nations (2004)
2.
Field Demonstrations of Permeable Reactive Barriers
to Remove Dissolved Uranium from Groundwater, Fry Canyon, Utah, U.S. EPA,
2000 (Natural phosphate materials (rock phosphate and bone meal)
were tested for their ability to remove dissolved uranium from
groundwater. The mineralogy of rock phosphate samples from various U.S. sites was fluoroapatite and carbonated fluoroapatite.
Bone meal was composed of predominantly hydroxyapatite.)
3.
Structural Characteristics of Apatite-Like
Substances and Composition of Phosphate Rock and Bone as Determined from Microscopical and X-Ray Diffraction Examinations, S.
Hendricks et al., Industrial and Engineering Chemistry, Dec. 1931
(American continental phosphate rock consists essentially of submicrocrystalline fluorapatite,
Ca10F2(PO4)6, which contains
some excess fluorine and a small amount of sodium.” Bone is either
carbonate apatite (Ca10CO3(PO4)6),
hydroxyapatite (Ca10(OH)2(PO4)6)
and calcium carbonate, or tricalcium phosphate
and calcium carbonate.)
4.
Organic Resource Manual, Washington State Department of
Agriculture, 1996. (at p.8: OMRI is the central clearinghouse for
determining what products and brand names are acceptable in organic
farming)
Effectiveness
of Rock Phosphate
1.
Understanding Phosphorous Fertilizers, University
of Minnesota Extension Service, Rehm, G., et
al, 1998 (Part of the reason rock phosphate is not used is “small
crop responses.”)
2.
Some
Facts on Phosphate, 1992, Published by the Potash and Phosphate
Institute, (Phosphate in raw rock phosphate “is slowly released
and seldom benefits crops during the first two or three years after
application.”)
3.
Nutrient
Management in high pH Soils, T. Fullerton, 2003, Green-up News,
University of Florida IFAS Extension (Rock phosphate “does not
release its nutrients under high pH (basic) conditions.”)
4.
Increasing
Sustainable Production and Soil Fertility on Broad-Acre Organic Farms,
Evans, J. and McDonald, L, 2005, Completed Project, Rural Industries
Research and Development Corporation (Without the addition of
elemental sulfur, rock phosphate had little effect on plant-available
soil phosphate, even in strongly acid soils.)
5.
Heavy Metals in Commercial Fertilizers, Tindall, T., Manager of Agronomy, J.R. Simplot Co., 2001, (In a controlled study on
potato and wheat grain, rock phosphate “surprisingly decreased grain
yield in the first year of the study. Unless raw rock phosphate is
treated with sulfuric acid and processed into 0-45-0 it is difficult for
crop phosphate demands to be met.”)
6.
Production of Mangnesium
Phosphate from Apatite and Carnallite, P.
Bar-On and I. Pelley, J. Agric. Food Chem., v.
27 n. 1, 1979 (“Apatites containing
fluorine are only slightly soluble in water and in organic acids, so that
the phosphate is not readily available to plants. In the fertilizer
industry the apatite is destroyed (there are several methods) to create
more soluble compounds.”)
Environmental
and Health Concerns of Rock Phosphate and Phosphoric Acid
Production
General
1.
Triple Superphosphate Crops, 2001, National Organic
Standards Board Technical Advisory Panel Review. (Review of
petition to allow Triple Superphosphate for
specific uses in organic farming. Heavy metals and radionuclides are present in the superphosphate
and these pose potential risks to human health (citing EPA).
Fluoride is released when the superphosphate
breaks down. Production of the superphosphate
causes major pollution.)
2.
Potential Danger to Human Health and the Environment,
U.S. EPA (Section of report on safety hazards of mine wastes, apparently
dating from about 1985. If 5 pci/g of
radium-226 is used as the criterion for classifying waste as potentially
hazardous, the phosphate mining sector produces more potentially
hazardous waste on an annual basis than any other mining sector studied.
The studied U.S. mining sectors included
asbestos, copper, gold, lead, silver, uranium, and zinc. Of the 755
million metric tons of potentially hazardous waste produced annually from
all of these mining sectors combined, the U.S. phosphate mining sector
contributes 352 million metric tons. This is 46% of the
total. As of 1985, all waste (potentially hazardous and non
hazardous combined) that existed on site at the various operations within
all of these mining sectors, totaled 39,584 million metric tons. U.S. phosphate mining operations
alone contained 16,599 million metric tons of waste, or almost 42% of all
the existing mine waste from these mining sectors.)
3.
2001 State of Environment Report, Upper Snake/Bear
River Basin, Idaho Dept. of Environmental Quality (Groundwater
beneath phosphate processing sites in the Soda Springs area "is
contaminated with cadmium, selenium, vanadium, fluoride, molybdenum, tributyl phosphate, and manganese."
"Ground water studies conducted down-gradient of the phosphorous
plants northwest of Pocatello (mined from the same
formation as the Soda Springs ore) have shown that levels of arsenic,
lead, and cadmium in the ground water exceed the federal Drinking Water
Standards. Off-site soil contaminants include radium-226, zinc,
cadmium, fluoride, and total phosphorous. On-site soil
contamination includes cadmium, chromium, copper, vanadium, radium-226,
lead, and nickel.")
4.
Smokey CanyonMine:
Proposed Expansion of Superfund Site Threatens Fish, Wildlife, Wildlands and Private Property, 2006 (A mine
that produces phosphate fertilizer is already a Superfund site and it is
proposed to be expanded within the Caribou-Targhee
National Forest. Selenium pollution is a major concern because it
is persistent in nature and it builds up in the food chain
(bio-accumulates))
5.
Sustainable Agriculture Research and Education Blog, Response by George Glasser
(Mr. Glasser states he has conducted extensive
research on rock phosphate contaminants and there are no rock phosphate
sources in the world that do not contain contaminants such as selenium,
cadmium, fluoride and radioactive nuclides.)
6.
Dream
House becomes a Roadblock in the New West, J. Robbins, NY Times, Dec. 2,
2006 (All but one of the 23 phosphate mines in the Idaho
“phosphate patch” have been declared Superfund sites by the EPA because
they leach selenium into the environment.)
7.
Southeast Idaho Phosphate Mining Resource Area Bannock,
Bear Lake, Bingham, and Caribou Counties, Idaho, U.S. Department of
Health and Human Services, 2006 (This report summarizes public
health assessments and consultations for hazardous waste sites in the
southeast Idaho phosphate mining resource area. Generally, there
are few public health concerns with the current land usage.)
8.
A $140-million mess, G. Pittman et al., St. Petersberg Times Online, July 6, 2003 (Piles
of radioactive waste left behind at phosphate fertilizer plant is “one of
the biggest environmental threats in Florida history.”)
9.
The
Phosphate Fertilizer Industry: An Environmental Overview.
10.
Sheep heard dies from contamination at phosphate mine,
Idaho State Journal, 2001.
11.
Polonium-210 in the environment around a
radioactive waste disposal area and phosphate ore processing plant, W. Arther and O. Markham, Health Physics, 46(4): 793-9,
1984 (Polonium-210 concentrations in soil and small mammal tissues
collected near a southeastern Idaho phosphate plant were 3-4 times
greater than background levels.)
12.
Utah
third nationally in release of toxins, P. Henetz,
The Mining News, 2005 (Phosphate processing in Soda Springs, ID
releases large amounts of mercury)
13.
Selenium poisoning, Sheep - USA (ID), 2003 (More
than 300 sheep grazing near a former phosphate mine in Soda Springs died
from acute selenium poisoning)
14.
Hunters Reminded to Limit Consumption of Elk Liver
of Animals Harvested near Phosphate Mines, T. Shanahan, 2006, Greater
Yellowstone Coalition, Original article: Idaho Department of Health and
Welfare Press Release (Because of high concentrations of selenium
in the livers of elk that graze near phosphate mines, consumption should
be limited. Hunters are warned that a large dose of selenium over a
short time may result in heart and nerve problems. Lower doses over
a longer time may cause neurological dysfunction and respiratory disease,
fatigue, loss of appetite, inflammation of the skin, inflammation of the
stomach and intestines, liver degeneration, and enlarged spleen.)
15.
Animal Deaths, Local Extinctions, and Human Health
Concerns in the Phosphate Mining Area of Southeast Idaho, 2006
(Since 1996, 547 sheep have died from selenium poisoning in the vicinity
of the phosphate mines. Selenium poisoning in that area has also
led to the deaths of horses and salamanders. Water foul and fish
are also effected.)
16.
Fluoride
Pollution: An overview (link page to fluoride and phosphate
pollution information)
Radioactivity
and Uranium as a Chemical (non-radioactive) Toxin
1.
Studies of Radioactivity and Heavy Metals in
Phosphate Fertilizer, H. Hamamo et al., Journal
of Radioanalytical and Nuclear Chemistry, v.
194, n. 2, pp. 331-336, 1995 (In 1975 alone, fertilizer that was
derived from Florida rock phosphate and used in the U.S. contained about
26,000 tons of uranium. From 1910 to 1995, approximately 260,000
tons of uranium contained in phosphate fertilizer from Florida had been applied to soils
in the United States. This study did not
find a buildup of uranium or thorium in the heavily fertilized soil that
was the subject of their analysis. Researchers are not sure where
it is going. The uranium contents of the superphosphate
fertilizers analyzed for this study ranged from 97-196 ppm. The uranium contents of the rock phosphate
fertilizers ranged from 10-189 ppm.
Apparently, the Florida rock phosphate was
substantially higher in uranium than the other (presumably Idaho phosphate). Thorium
contents ranged from 3-7 ppm in all
samples. The background uranium content of soil was approximately
4.3 ppm. The background thorium level was
approximately 9-11 ppm.)
2.
Extraction and Benificiation of
Ores and Minerals, v. 5, Uranium, U.S. EPA, 1995 (“Phosphatic” deposits are a listed type of uranium
deposit. “The central Florida phosphatic
deposits contain uranium concentrations ranging from 90 ppm to 150 ppm in phosphate
pellets, the main form of phosphate ore.” “In 1988, two phosphoric
acid manufacturing plants recovered about two million pounds of U3O8 (21
percent of U.S. production for 1988) from
the rock phosphate mined in Florida.”)
3.
Identification of Estimates of Nuclear Fuel
Resources (At $10-30 per pound U3O8, it was
estimated that 1000-2000 tons per year of U3O8
could be economically recovered from the production of phosphoric acid
(phosphate fertilizer) (But see above that in 1975 alone, about 26,000
tons of uranium was included in phosphate fertilizer. Thus, it
appears that even if uranium were recovered at economical rates, most of
the uranium would still be in the fertilizer.))
4.
Environmental Contaminants Encyclopedia , Uranium
Entry, R. Irwin et al., U.S. National Park Service, Water Resources
Division, 1997 (This an excellent resource for general
information on uranium and its effects in the environment. “The
concerns about uranium include not only radiation,
Uranium is also chemically toxic to the same degree as, for example,
arsenic.” “Uranium’s toxic hazard resides not in its radiation
effects but in its chemical effects on the renal tubules.”
Radiation levels of concern to wildlife managers are higher than for people
because wildlife managers are only concerned with population effects
whereas humans are concerned with effects to individuals. “Any
exposure to any radioactive source, including exposure to naturally
occurring radioactive materials, will have some finite probability of
increasing the lifetime risk of cancer in humans.” The greatest risk from
natural uranium comes from it being swallowed or inhaled. There is
no evidence that uranium crosses the placental barrier in humans, but
since it does cross the placental barrier in animals, it is probable that
exposure to high levels of uranium may cause human birth defects.
The natural uranium content of soil ranges from 0.5 to 5 ppm with an average of 1.8 ppm.
Some plants can have up to 80 times the concentration of uranium as the
soil.)
5.
Radiation Hazards have been Grossly Underestimated,
Internal Medical Veritas Association, 2006
(Any amount of radiation exposure is potentially dangerous. The
radiation is more likely to lead to cell membrane destruction at
slow-dose rates than fast-dose rates. Cancer-causing effects of radiation
exposure are cumulative with each exposure. “Whenever uranium is
found in nature as a component of a mineral, a host of other radionuclides are always found in the mineral in
various stages of decay. Uranium and all of its decay-rate products are
found in phosphate rock, fluorosilicic acid
(this is the fluoride added to drinking water, it is a waste product from
producing phosphoric acid from rock phosphate) and phosphate
fertilizer.”)
6.
Naturally
Occurring and Accelerator-Produced Radioactive Material, U.S. Dept. of
Energy, 1996 (Section 7.2.2.6 discusses radioactive waste
generated from phosphate mining and fertilizer production. Table
7.9 (http://web.em.doe.gov/idb96/tab79.html)
lists radionuclide concentrations of phosphate wastes.)
7.
Fertilizer
and Fertilizer Production Wastes, U.S. EPA (Radium-226 content of
phosphate fertilizer averages 5.7 pCi/g.
The report states this is not substantial given the background levels in
soil. (The EPA appears to only consider radium-226 in its analysis
of radioactivity of phosphate fertilizer. But other sources provide
that most of the radium goes to the phosphogypsum
waste and not the fertilizer. It is other radioactive nuclides that
are more likely to end up in the fertilizer. (see
http://www.byamerican.com/HealthAlert/RadioFood.html citing
EPA). Also, the Department of Energy lists 12 radioactive nuclides
that are present in phosphate fertilizer phosphogypsum
waste, and of those, radium, the one that apparently reports more to the
waste than many of others, comprises less than a third of the total
radiation (see
http://web.em.doe.gov/idb96/tab79.html).
This just appears odd that radioactivity of phosphate fertilizer would
apparently be based only on the concentration of the nuclide that is
apparently less likely to actually be in the fertilizer than many other
radioactive nuclides. It appears that this is done because they are
only concerned with gamma radiation and not alpha emitters in this
study. Lastly, other government sources provide that on
health-based criteria, >5.0 pCi/g
radium-226 is toxic in soil. Given this, it is unclear how a
content of 5.7 pCi/g in
fertilizer is unsubstantial.))
8.
Soil Cleanup Criteria in 40 CFR Part 192, U.S. EPA,
1998 (“The concentration criterion for surface soil (5 pCi/g of radium-226) is a health-based
standard. The relevant source of health risk for surface soil is
exposure to gamma radiation, which is the basis for this standard.”
Where uranium and thorium are commingled with radium, the risk of
additional radioactivity from decay of these elements must be
considered. If present, these elements must be removed to assure
the radioactivity will remain at safe levels.)
9.
Contaminants in Oil Field Produced Waters Discharged into
the Loch Katrine Wetland Complex, Park County,
Wyoming and their Bioconcentration in the
Aquatic Bird Food Chain, R. Ramirez, U.S. Fish and Wildlife Service, 1993
(At p. 17-18, “Radium -226 mimics calcium in vertebrates and can be
incorporated into bone tissue.” “Radium-226 in sediments from
phosphate settling basins in central Florida averaged 23.8
pCi/g.” 5 pCi/g radium-226 is the concentration which is
the criterion for identifying toxic waste.)
10.
Characterization of Radioactively Contaminated
Sites for Remediation Purposes, International Atomic Energy Agency,
Vienna, Austria, 1998 (When rock phosphate is made into
phosphoric acids, mono-ammonium phosphate, and the final fertilizer
product, the radium-226 is generally deposited in the phosphogypsum
waste. Uranium-238 is the radioactive contaminant of greatest
concern to agricultural contamination because it generally remains in the
fertilizer itself. Agricultural lands where the fertilizers are
used have increased levels of radiation. The phosphate fertilizers
used in this case study came from Morocco and Boucra.)
11. Phosphate Primer, Radiation and Phosphoric Acid, Florida
Institute of Phosphate Research, an affiliate of the University of South
Florida, 2004 (The superphosphate
fertilizer produced in Florida contains much of the uranium that was
present in the mined rock phosphate. The uranium used to be
extracted, but this process is not presently economical and all uranium
extraction facilities are now shut down. However, the fertilizer is
purportedly safe.)
12.
Phosphate
Primer, Introduction, Florida Institute of Phosphate Research, an
affiliate of the University of South Florida, 2004
(“Radioactivity is a natural part of all things as is the radiation it
gives off.” It comes from space, medical procedures, bricks, smoke
detectors and cigarettes. Florida rock phosphate is also
radioactive, but not as much so as an atomic bomb. Thus, “radiation
connected to phosphate mining does not significantly add to the average
overall dose a person receives as a natural part of life.” (No
mention is made though of radiation associated with phosphate use.)
Also, the article warns to be aware of reports of “toxic” materials in
phosphate fertilizers because the word is used loosely and you might
mistake materials with dangerous sounding names as materials that are
actually dangerous. “Dihydrogen monoxide,
for instance, could sound dangerous if you did not know it was a chemical
name for water.”)
13.
Phosphate Primer, Introduction to Radioactivity, Florida
Institute of Phosphate Research, an affiliate of the University of South
Florida, 2004 (Regarding radioactivity associated with Florida
phosphate, “It is not known at what levels radiation becomes harmful to
human health. In fact, there are some experts who believe that
radiation at low levels could be beneficial. Radiation at high
levels, like that emitted in Japan after atom bombs exploded, is harmful
to human health. It is uncertain how much radiation becomes
dangerous.” Thus, because exposure to radioactivity from rock
phosphate products is possibly beneficial, and at worst, less harmful
than atom bombs, you should access the risk of using them. In
considering the risk, it is suggested you apply the following reasoning:
“knowing that a 100 MPH wind kills 100 people would not lead us to
assume, or fear, that a 1 MPH wind will kill one person.”
Comparative risks include eating 100 charcoal broiled steaks, spending 2
days in New York City, driving 40 miles in a car, flying 2,500 miles, and
canoeing for 6 minutes.)
14.
Uranium
Toxicity, WISE Project, 2005 (“There is no data available for long-term effects of uranium ingestion on humans, all
information available is from intermediate-term studies on
animals.” Various sources suggest the tolerable daily intake (oral
ingestion) for uranium is between 0.2 and 0.7 µg/kg of body rate.
Suggested safe concentrations in drinking water range from 10-15
µg/liter. “Long-term ingestion of uranium by humans may produce
interference with kidney function at the elevated levels of uranium found
in some groundwater supplies.”
15.
Understanding
Radiation, U.S. Environmental Protection Agency (The paper gives
two examples of how alpha emitters are introduced into the environment by
unnatural means. One is uranium mining. The other is
phosphate mining and fertilizer production. “Mining and current
methods for processing phosphate ore for fertilizer generate large piles
or “stacks” of phosphogypsum, in which
naturally occurring radium is concentrated.” Alpha particles cannot
penetrate the skin, but if “alpha emitters have been inhaled, ingested
(swallowed), or absorbed into the blood stream, sensitive living tissue
can be exposed,” leading to an increased risk of cancer.)
16.
Idaho National Engineering and Environmental Laboratory, INEEL
Environmental Surveillance Education and Research Program (Two
examples given for how human activity exposes the environment to alpha
emitters are uranium mining and “mining and processing phosphate for
fertilizer.”)
17.
Radioactive Polonium in Food and Water, Health
Alert from the ASCA (“The widespread use of radioactive phosphate
fertilizer may be increasing levels of radioactive polonium in animal
feeds.” Cites an EPA link for fact that during processing of
phosphoric acid (fertilizer) from rock phosphate, about 86% of the
uranium, 70% of the thorium, and, 20% of the Radon-226 remain in the
phosphoric acid. Links to other information sources are given.)
18. Puffing on Polonium, R. Proctor, 2006, NY Times Opinion
(Polonium 210, the material used to poison the former KGB agent in
November, 2006, is present in tobacco and it may be that phosphate
fertilizer is the ultimate source of the toxin. Tobacco leaves
concentrate Polonium that is present in the soil. In the Caucasus,
phosphate fertilizer is not used on tobacco and tobacco growers live
longer.)
19.
Radon:
What’s New?, Cancer Survivors against Radon (Surgeon General C.
Everett Koop declared on national TV that radioactivity in cigarettes
accounts for at least 90% of all smoking related cancers. CDC
Director Ravenholt stated that Americans
receive more radiation from tobacco smoke than from any other source. Between 1938-1960, the level of Po-210 in American
tobacco tripled commensurate with increased use of superphosphate.
U.S. lung cancer rates increased 10 fold from 1938-1956. In 1930,
there were 4 lung cancer victims per 100,000 smokers, in 1960 it
increased to 40 and in 1980 it was 70. In 1977, Phillip Morris
confirmed that superphosphate fertilizer was
the source of radioactive polonium found in tobacco. In 1980, they
found how to remove the polonium but the process was too expensive to
implement.)
20.
An
Assessment of the Disposal of Petroleum Industry NORM in Nonhazardous Landfills, P. Smith et al., 1999,
Argonne National Laboratory (Figures 1 and 2 show the uranium-238
and thorium-232 decay series.)
21.
Field Demonstrations of Permeable Reactive Barriers to
Remove Dissolved Uranium from Groundwater, Fry Canyon, Utah, U.S. EPA,
2000 (Natural phosphate materials (rock phosphate and bone meal)
were tested for their ability to remove dissolved uranium from
groundwater. Phosphates can react with uranium to form
uranium-bearing minerals. The mineralogy of rock phosphate samples
from various U.S. sites was fluoroapatite.
Bone meal was composed of hydroxyapatite.)
Fluoride
as a Toxin
1.
Fluoride:
The Hidden Poison in the National Organic Standards. (Fluoride is
a toxin that should be regulated under the National Organic
Standards. Paper provides that fluoride-bearing rock phosphate is a
dangerous fertilizer.)
2.
Contamination
of Soil with Fluoride by long-term Application of Superphosphates
to Pastures and risk to grazing animals, M. McLaughlin et al., Australian Journal of Soil
Research 39(3) 627 – 640. (Superphosphate adds fluoride to the soil profile and
it accumulates in plants. If application is continued, the
continued buildup may lead to fluorosis in
grazing animals in as few as 25 years. The fluoride deposited by superphosphate is relatively soluble.)
3.
Animal Nutrition Handbook, L. Chiba, 2005. (at
pg. 253, monocalcium and dicalcium
phosphate contain 0.12-0.18% fluoride, Soft rock phosphate contains 1.2%
fluoride, ground rock phosphate contains 3.7% fluoride)
4.
The soil profile, v. 16, 2006, NJ Agricultural Experiment
Station, Rutgers Cooperative Research and Extension.
(Fluoride in rock phosphate ranges from 0.19-4.2%)
5.
Interaction Profile for: Cyanide, Fluoride,
Nitrate, and Uranium, U.S. Department of Health and Human Services, 2004 (Uranium
(chemically, not radioactively) primarily affects the kidney. It
may also affect the liver and thyroid. Fluoride decreases bone
strength, has toxic effects on the testes, and may elicit neurological
effects. Fluoride may also affect the kidney. Thus, the
kidney or renal functions are a shared toxicity target of both elements
(possibly bone as well, but not certain). There are insufficient
data to understand if there are any co-exposure effects. Report
cites study where a 3-year-old boy died from a single dose of 16 mg
fluoride/kg (presumably this is kg of body weight) 7 hours after
ingestion.)
6.
Toxicological
Profile for Fluorides, Hydrogen Fluoride, and Fluorine, U.S. Department
of Health and Human Services, 2003 (The concentration of
fluorides in soils is usually between 200 and 300 ppm.
Levels may be higher where phosphate fertilizers are used. “You may
be exposed to fluorides through dermal contact with these soils.” “While
foods generally contain low levels of fluoride, food grown in areas where
soils have high amounts of fluorides or where phosphate fertilizers are
used may have higher levels of fluorides.” The report discusses many
studies concerning health effects of fluorine and finds that the results
of many are equivocal.)
7.
ToxFAQs for Fluorine, Hydrogen Fluoride, and Fluorides,
U.S. Department of Health and Human Services, 2003 (Fluorine
cannot be destroyed in the environment, it can only change form.
Fluorides will accumulate in plants and animals. With exposure to
high levels of fluoride (not defined), bones may become more brittle,
increasing risk of breakage. At extremely high dosage (not defined)
fluoride can result in decreased fertility and sperm and testes damage.)
8.
Phosphate Rock Fertilizer: Toxic Metals, Radiation
Hazards, Fluoride, and Organic Growing, Organic Consumers Association
(At 5% fluoride, ingestion of one ounce of rock phosphate could kill a
small child. We did our own literature search to see if this could
be substantiated. It appears to be. 5% of one ounce is 1,417
mg. When rock phosphate is ingested, 26-28% of the fluorine is
retained in the body. See Fluorine in Animal Nutrition, C. Kick et
al., 1935, Bulletin 588, Ohio Agriculture Experiment Station.
http://www.bruha.com/pfpc/html/kick_et_al___1935.html.
Death from fluoride poisoning has occurred at a dose as low as 5 mg/kg
body weight and 32 mg /kg of body weight is the certain lethal dose.
www.fluoride-journal.com/97-30-2/302-89.htm.
Thus, if Kick is correct, a person weighing 25 pounds or less would
certainly die if they ingested one ounce of rock phosphate containing 5% fluoride.
Most victims of fluoride poisoning are between 2-3 years of age.
www.fluoride-journal.com/97-30-2/302-89.htm.
And at 2 years, 26% of healthy girls weigh 25 pounds or
less.)
9.
Nutrient Requirements for Preterm Infant Formulas,
C. Klien, 2002, J. Nutrition, 132:139S-1577S,
The American Society for Nutritional Sciences. (“an acute fluoride dose of approximately 5 mg/kg
or more (of fluoride) appears to be fatal in children.”)
10.
Re-Examination
of Acute Toxicity of Fluoride, K. Akiniwa,
1997, Fluoride, v. 30, No. 2, 89-104. (Certain Lethal Dose of
fluoride is 32 mg/kg)
11.
Abstracts on phosphate fertilizers that cite
effects or levels of fluoride, Part 1: 1954-1989. (various abstracts on health effects of fluoride,
examples are mostly from phosphate fertilizer) and
Abstracts on phosphate fertilizers that cite effects or
levels of fluoride, Part 2: 1990-present.
12.
Fluoride Toxicity, Health & Science Research
Institute, U.S.A. (lists chronic effects of fluoride poisoning
including Alzheimer’s, weakened bones, genetic and chromosomal damage,
cancer and disruption of immune system)
13.
The Fluoride Controversy Continues: an update – part 1,
G. Null and M. Feldman, 2002. (lists many dietary sources of
fluoride and comments on water fluoridation in general)
14.
The Fluoride Controversy Continues: an update – part
2, G. Null and M. Feldman, 2002. (Fluoride may be part of cause
for high arthritis rate in US. Studies reported in JAMA show those
exposed to 1ppm fluoridated water have higher incidence of hip
fractures. Fluoride makes bones dense and brittle. Fluoride effects the thyroid system. Fluoride in drinking
water is related to bone cancer, brain tumors, and leukemia.
Fourteen Nobel Prize winners have expressed reservations about
fluoridation of water. Fluoridated water causes genetic and
chromosomal damage to human sperm and it lowers sperm count.
Fluoride intake reduces intelligence.)
15.
Respected medical
professionals and scientists are warning of long-term health
consequences. (Quotes from physicians and scientists who have
reservations about fluoridated water because of the potential adverse
effects of fluoride. Many of the experts are from the AMA, EPA, U.S. Army, and other well-known
agencies.)
16.
50
reasons to oppose Fluoridation, P. Connett.
(names 13 Nobel Prize winners with reservations about fluoridation)
17.
Fluoride
Fact Sheet, D. Kennedy.
18.
Expert Group on Vitamins and Minerals, Review of
Fluoride, 2001 (Government publication asserting few serious
long-term health effects of fluoride exposure. Soil fluoride
concentrations are 0.2-0.3 g/kg and where fluoride is added by fertilizer
or other materials it can be 7-38 g/kg.)
19.
Fluoride, the Linus Pauling Institute at Oregon State University.
(Acute fluoride toxicity occurs at as low as 5 mg/kg. Dismisses
most claims of adverse long-term effects as unsubstantiated.)
20.
Fluorides
and sulfur dioxides as causes of plant damage, H. Bohne,
1970, Fluoride: Journal of the International Society for Fluoride
Research, v. 3, n. 3, pp. 137-142)
21.
Abstracts, Fluorapatite,
Fluoride Action Network (Cites studies in New Zealand showing fluoride contents
of rock phosphates from many sources ranging from 2.2-4.1% with an
average of 3.5%. Rock phosphate derived phosphoric acid fertilizers
had fluorine concentrations ranging from 1.08-3.0%.)
Heavy
Metals as Toxins
1.
Heavy Metals in Fertilizers Used in Organic
Production, D. Tracy and B. Backer (OMRI Advisory Council?) (An
excellent overview of the various government bodies that regulate metals
in organic fertilizers, how the various regulations work, and the
comparative metal concentrations allowable under each of the regulatory
systems. This website also has links to many of the regulatory
agency’s web sites. Of the three states that regulate heavy metals
in fertilizer, California regulates arsenic, cadmium
and lead; Oregon regulates arsenic, cadmium,
lead, mercury, and nickel; and Washington regulates arsenic, cadmium,
lead, mercury, nickel, cobalt, molybdenum, selenium, and zinc.)
2.
Levels of Nonnutritive Substances in Fertilizers, Washington
State Department of Agriculture, 2005 (Report lists metal
analyses for fertilizers licensed in Washington. The first table is
self-reported values. The second table is values obtained from WSDA’s own sampling of products that are in the first
table (we use the second table because, presumably, there is less
variability in the values that are a product of variability in the labs
that are used).)
3.
Metal Concentration in Fertilizer Sampled by WSDA,
Washington State Department of Agriculture, 2006 (Lists results
of heavy metals tests for many fertilizers that are sold in Washington.)
4. A Report on the Plant Uptake of Metals from
Fertilizers, Washington State Department of Agriculture, 2001 (In
a study that considered the plant uptake of arsenic, lead, and cadmium
(which are the only three metals California regulates), cadmium was found
to be of the greatest concern. Cadmium rich phosphate fertilizers
are a concern because they may cause cadmium buildup in the soil.
Some plants, such as lettuce, were found to contain more cadmium in the
plant when more was available in the soil. Arsenic and lead were
not taken up by plants in the same way as cadmium.)
5.
Evaluation of Heavy Metals & Dioxins in
Inorganic Commercial Fertilizers and California Croplands, California
Department of Food and Fertilizer, 2004 (Cadmium uptake by plants
is proportional to the concentration of cadmium in the soil. One
study area showed a linear relationship for beans, bell peppers and
lettuce. For all of these vegetables, where the soil cadmium
concentration was approximately 0.5 ppm, the
cadmium concentration in the vegetable was approximately 0.5 ppm. Similarly, when the soil cadmium
concentration was approximately 2.5 ppm, the
cadmium concentration in the vegetable was approximately 2.5 ppm. Another study area showed a non-linear
relationship with broccoli having the least uptake, cauliflower having
intermediate uptake and lettuce having the highest uptake. In this
study area, the cadmium content of lettuce was approximately double that
of the cadmium content of the soil. Arsenic is not taken up in
crops in significant amounts. Lead contents vary by plant type, but
there is no correlation to lead contents of soil.)
6.
Scientific
Basis for Risk-Based Acceptable Concentrations of Metals in Fertilizers
and Their Applicability as Standards, The Weinberg Group, 2001
(The study concludes that the metal concentrations at or below the values
listed on page 2 (AAPFCO recommended values) are “considered safe for
professional applicators, farm families, home gardeners, and the general
public.” Under these guidelines, most fertilizers are safe.)
7.
The soil profile, v. 16, 2006, NJ Agricultural
Experiment Station, Rutgers Cooperative Research and Extension
(Cadmium in rock phosphate from Florida is 9-17 ppm, NC rock phosphate
contains 47 ppm. Use of this can cause a
buildup of cadmium in the soil. )
8.
Phytoremediation: Using
Plants to Clean Up Soils, U.S. dept. of Agriculture, Agricultural
Research Service (“One of the primary ways toxic heavy metals,
such as cadmium, get in food is through plant uptake—the metal is taken
up by the roots and deposited in edible portions." “Contaminated
soils and waters pose major environmental, agricultural, and human health
problems worldwide.”
9.
Cadmium
Exposure and Human Health (“Most human cadmium exposure comes
from ingestion of food, and most of that arises from the uptake of
cadmium by plants.” Phosphate fertilizer is responsible for 41% of
the human exposure to cadmium. Health effects from cadmium exposure
depend on many variables and most individuals are probably not at risk
from current exposure levels. “Only if the cadmium levels in the food grown
there were significantly increased, can levels of exposure be sufficient
so as to produce kidney dysfunction,” or bone desease.)
10.
Imported
Cadmium-Contaminated Zinc Sulfate Used in Fertilizer and Other Products,
Washington State Department of Ecology, 2000 (Zinc sulfate
imported from China contained as much as 20% cadmium. The high
concentrations were self-reported by a private fertilizer company.
It is not known if any of the fertilizer products were land-applied or if
they were all successfully recalled.)
11.
ToxFAQs for Cadmium, U.S. Department of Health and
Human Services, 1999 (Cadmium does not break down in the
environment. Fish, plants and animals take up cadmium from the
environment. “Cadmium stays in the body a very long time and can
build up from many years of exposure to low levels.” The general
population is exposed to cadmium from breathing cigarette smoke or eating
cadmium contaminated foods. Cadmium damages the lungs, can cause
kidney disease, and may irritate the digestive tract.)
12.
.
Toxicological Profile for Cadmium, Department of Health and Human
Services, 1999 (Application of phosphate fertilizer is one of the
principle sources of cadmium releases to soil. This may result in greater
human exposure from food chain accumulations in plants and animals.
Cadmium concentrations of phosphate fertilizers range from 0.05 to 170 ppm. One study found that continuous
fertilization with a high rate of triple superphosphate
fertilizer for a period of 23 years resulted in a 14-fold increase in
cadmium content of surface soils. People “who ingest grains or
vegetables grown in soils treated with municipal sludge or phosphate
fertilizer all may have increased (cadmium) exposure.” “There are no
known good effects from taking in cadmium.”
13.
Role of Fertilizer and Micronutrient Applications on
Arsenic, Cadmium, and Lead Accumulation in California Cropland Soils, A.
Chang et al., U.C. Riverside, 2004 (Application of phosphate and
micronutrient fertilizers has not substantially increased levels of
arsenic, lead and cadmium in cropland soils. The mean contents of
these elements in phosphate fertilizers are 8.5 ppm
arsenic, 173 ppm cadmium, and 21 ppm lead. The mean contents of these elements
in zinc-iron-manganese micronutrient fertilizers are 32 ppm arsenic, 477 ppm
cadmium, and 21,156 ppm lead.)
14.
Cadmium
Health Effects, U.S. Department of Labor, OSHA (“The most serious
consequence of chronic cadmium poisoning is cancer (lung and prostate).
The first observed chronic effect is generally kidney damage, manifested
by excretion of excessive (low molecular weight) protein in the urine.
Cadmium also is believed to cause pulmonary emphysema and bone disease (osteomalcia and osteoporosis). The latter has been
observed in Japan ("itai-itai"
disease) where residents were exposed to cadmium in rice crops irrigated
with cadmium-contaminated water. Cadmium may also cause anemia, teeth
discoloration (Cd forms CdS)
and loss of smell (anosmia).”)
15.
Toxicological
Profile for Selenium, U.S. Department of Health and Human Services, 2003
(The concentration of selenium in phosphate rock is <1 to 300 ppm.)
16.
ToxFAQ’s for Selenium, U.S. Department of Health and
Human Services, 2003 (Selenium may concentrate up the food
chain. Low doses are beneficial to humans but large doses are
potentially harmful.)
17.
Dietary
Fact Sheet: Selenium, Office of dietary supplements, National Institutes
of Health (Some selenium is necessary for human health. It
may be beneficial to preventing cancer and in helping some cancer
patients and those effected with HIV/AIDS.
Selenium-deficient soils may lead to selenium deficient diets. (Thus,
although selenium is an apparent environmental problem for the area
around the Idaho phosphate mining
operations, it may be beneficial to you as a user of the product.))
18.
ToxFAQs for Zinc, U.S. Department of Health and Human
Services, 2005 (Zinc accumulates in soil, fish and other
organisms, but it does not build up in plants. Zinc has not been
found to be carcinogenetic. Long term exposure may cause anemia and
a decrease in levels of good cholesterol.)
19.
ToxFAQs for Nickel, U.S. Department of Health and
Human Services, 2005 (Greatest exposure to most humans is eating
food containing nickel. The most common harmful effect of contact
is an allergic reaction. Nickel is a likely carcinogen.
Animal studies show that eating large amounts has caused lung disease and
affected the stomach, blood, liver, kidneys, and immune system.)
20.
Draft
Toxicological Profile for Arsenic, U.S. Department of Health and Human
Services, 2005 (Arsenic is a common impurity in minerals used in
fertilizers. A comprehensive Italian study found arsenic contents
of fertilizers ranged from 2.2 to 322 ppm.
A sample of triple superphosphate had the
highest concentration. For the general population, food is usually
the greatest source of arsenic exposure. Ingestion of dirt is the
second greatest source of arsenic exposure for infants and children.)
21.
ToxFAQs for Arsenic, U.S. Department of Health and
Human Services, 2005 (Arsenic cannot be destroyed in the
environment, it can only change form. Fish and shellfish can
accumulate arsenic, but most of this arsenic is a form that is less
harmful than others. Arsenic is a known carcinogen causing cancer
of the lungs, bladder, liver, kidney and prostate. It can cross the
placenta and has been found in fetal tissue. It may cause low birth
weight, fetal malformations, and even fetal death. Exposure to
children may result in lower IQ scores.)
22.
New Fertilizer Standards will regulate Use of Toxic
Waste, Children’s Health Environmental Coalition, 2003 (Warns of
potential children’s health concerns associated with heavy metals in
fertilizers. “Be wary of zinc fertilizers in particular. According to
EPA, "nearly all fertilizers made from hazardous waste ingredients
are zinc micronutrient fertilizers." Also, phosphate and iron
products are more likely to have toxic metals than other fertilizers.”)
23.
Background
Information on Waste-Derived Fertilizer in California, Environmental Law
Foundation (?) (Cites EPA study that found arsenic, cadmium, lead
and dioxins are taken up by plants. Discusses concerns of arsenic
and lead in a specific iron fertilizer.)
Bone Meal
and Mad Cow
1.
World Health Organization (BSE is spread through consumption of
infected bone meal.)
2.
Report
In Support of the Update of the SSC’s Opinion
on the Safety of Dicalcium Phosphate (DCP) and Tricalcium Phosphate (TCP) from Bovine Bones and Used
as an Animal Feed Additive or as Fertilizer, European Commission,
Health Consumer Protection Directorate-General, (At page 3, “Because of
the longevity of the TSE agent protein (Mad Cow protein) in soils, the
risk of accumulation in the environment of possible residual risk is not
completely excluded if applied in large quantities or repeatedly on a
same area.” (And this is not even raw bone meal,
this is TSE agent proteins surviving in an acid solution that was passed
through bone meal.))
3.
Dateline:
US risk for BSE and CJD (Dr. Gibbs, the government’s chief
researcher on BSE, related use of bone meal in rose gardens to human BSE
(Mad Cow) infection. Another doctor asked Stone Phillips if he used
bone meal on his roses and after an affirmative response replied “I
wouldn’t if I were you.”)
4.
Growing
Roses in the High Desert, J. Phillips, 2000, (“Do NOT use bone
meal if you have dogs.” They will dig up the garden looking for the
hidden bone. There are many other references to this on the
internet.)
5.
Gardening
for Vegetarians (“Organic is not synonymous with vegetarian.”
Bone meal is not vegetarian and it should not be used. Because bone
meal is inappropriate, this and other sources encourage vegetarians to
use superphosphate even though it is not
organic.)
6.
Experts Soothe Worries about Using Bone Meal, K.
Pokorny, The Oregonian, January 7, 2004 (There
is little chance of getting Mad Cow from bone meal used as a
fertilizer. But if you are concerned, wear a mask. If you are
really concerned, do not use it. Fish meal may be a better
alternative.)
7.
USA Today Slams USDA for Cutting Back on Mad Cow
Testing, citing: Mad Cow Watch goes Blind, USA Today, August 3, 2006
(Sixty-five nations have full or partial restrictions on importing U.S.
beef because of fears that testing in this country is not
sufficient. The USDA is stopping a private beef producer from
testing all of its cows for mad cow, reportedly because it would force
others to do the same at a high price. In July, 2006, the USDA
announced it would cut testing by 90% so that out of the 100,000 cows
slaughtered daily, 110 would be tested.)
8.
Organic Consumer’s
Association web page for Mad Cow Information (Many links to
articles on the subject.)
9.
Mad Cows in the Garden, Excerpt from Spectrum
Magazine (“In a recent PBS special on mad cow disease,
researchers found that prions (Mad Cow) were
not harmed when buried in the ground for three years.” Britian has banned the use of bone meal in commercial
fertilizer. “To be on the safe side, experts recommend that
gardeners handling bone meal wear masks and gloves, and take care not to
become exposed to the substance through an accidental cut or splinter.”)
10.
Time to Plant Tulips and Daffodils, S. Ferguson, Bostongardens, 2006 (“Bone meal is simply not
the best source of phosphorus for the garden, not because it doesn’t
contain a lot of phosphorus but because it delivers it into the soil
inefficiently.” “Secondly, putting bone meal in your bulb bed is often an
invitation for dogs, squirrels, voles, moles and other critters to sniff
it out and dig up your garden. Lastly, there is some question
whether imported bone meal is a potential transmitter of Mad Cow disease;
some experts think this is an issue.”)
11.
Mad Cow Disease: The Myths, the Facts, and a
Prescription for Food Safety, F. Scalise, 2004
(There are still a lot of unknowns. There may be many more people
infected than currently thought. Testing is inadequate and “the
current U.S. testing program is more
like a game of Russian Roulette.” It is not currently known if
there is a risk of exposure to Mad Cow from cattle by-products.
There is concern about gardeners and farm workers being exposed to prion-containing dusts during the use of bone meal.)
12.
Japan - BSE Origins Baffle Japan, APEC Emerging
Infections Network, 2002 (“The Japanese government said it was
unclear how mad cow disease, or bovine spongiform encephalopathy (BSE),
had infected Japanese cattle, one year after the brain–wasting disease
was first diagnosed in the country. However, it suggested at least three
possibilities involving contaminated meat and bone meal (MBM) and
fertilizer from Europe.”)
13.
Alzheimer’s
Misdiagnosed, KTTC News, November 29, 2006 (Because of
similarities in the symptoms of the two diseases, CJD (the human form of
mad cow) may be misdiagnosed as Alzheimer’s.)
14.
Alzheimer’s Disease verses Creutzfeldt-Jakob
Disease, H. Butchko (There is a low
likelihood of mistaking CJD for Alzheimer’s. Variant CJD, the type
associated with mad cow, is different than CJD.)
15.
Alzheimer’s Disease and Related Dementias Fact
Sheet, Alzheimer’s Association, 1999 (CJD is a fatal brain
disorder that is caused by a transmissible agent.)
16.
Could
Mad Cow Disease Already be killing Thousands of Americans Every Year?, M. Greger, 2004
(“The incubation period for human spongiform encephalopathies
such as CJD can be decades. This means it can be years between eating
infected meat and getting diagnosed with the death sentence of CJD.
Although only about 150 people have so far been diagnosed with variant
CJD worldwide, it will be many years before the final death toll is
known. In the United States, an unknown number of
animals are infected with Mad Cow disease, causing an unknown number of
human deaths from CJD.” “Over the last 20 years the rates of Alzheimer's
disease in the United States have skyrocketed. According
to the CDC, Alzheimer's Disease is now the eighth leading cause of death
in the United States, afflicting an estimated 4
million Americans. Twenty percent or more of people clinically diagnosed
with Alzheimer's disease, though, are found at autopsy not to have had
Alzheimer's at all.” “At Yale, out of a series of 46 patients
clinically diagnosed with Alzheimer's, six were proven to have CJD at
autopsy. In another study of brain biopsies, out of a dozen patients diagnosed
with Alzheimer's according to established criteria, three of them were
actually dying from CJD.”)
17.
Brain Trust, The Hidden Connection between Mad Cow
and Misdiagnosed Alzheimer’s Disease, C. Kelleher, Paraview
Pocket Books, 2004 (Web page is brief review of the book.
Points out that the number of Americans with Alzheimer’s Disease (4-5
million) has increased 9,000% in the last 20 years. “Scientific
research showed between 5% and 13% of Alzheimer’s cases may actually be
another devastating brain disease called CJD (linked to Mad Cow).”)
18.
Trade
Related Infections: Farther, Faster, Quieter, A. Kimball et al.,
Globalization and Health, 1:3, 2005 (“The incubation period of vCJD is variable, estimated at up to 15-30
years. The incubation period of BSE (Bovine Spongiform
Encephalopathy), or mad cow disease, in cattle is also on the order of
years, which has complicated culling interventions.”)
19.
Report of the Scientific Veterinary Committee of
the TSE Status of Australia and the USA and on the Scrapie
Eradication Programme in Norway, Scientific
Committee on Animal Health and Animal Welfare, 1997 (“The USA has
not submitted evidence that the rendering procedures used in the USA to
prepare meat and bone meal from ruminant waste materials are effective at
inactivating TSE agents. The committee considers it is unlikely that they
all do.”)
20.
Disposing of BSE Infected Cows May Prove Difficult,
S. Wolf, Uncommon Thought Journal, 2004 (“The beastie known as a
"prion" that is involved in mad cow
(BSE) is damnably hard to kill. In fact, it seems to be one of the
hardier "bugs" in that it survives being "steamed, frozen,
disinfected, zapped with ultraviolet light or bombarded with X-rays,
tissue from sick animals can still spread the illness.” “According
to the SSC (link in original to EU Scientific Steering Committee, report
at
http://ec.europa.eu/food/fs/sc/ssc/out358_en.pdf
), BSE and TSE material needs to be treated at a high temperature (at
least 300 F) and under pressure in an alkaline solution for at least six
hours for reasonable safety. The treated material should then be
encapsulated and stored at a protected facility. What that means is that
even after the sterilization the material needs to be treated as toxic
waste.”)
21.
Variant
Creutzfeldt-Jackob Disease, World Health
Organization, 2002 (vCJD is a rare and
fatal human neurodegenerative disease that is strongly linked with
exposure to the BSE agent. The most likely route of exposure is
through bovine-based food.)
22.
Bovine
Spongiform Encephalopathy, G. Lardy et al., North Dakota State University
Extension Service, 2004 (Various forms of transmissible
spongiform encephalopathies can infect sheep,
goats, cattle, deer, elk, mink, felines, and people. BSE cannot be
spread by contact with physical infected animals. However, “little
is known regarding the minimum amount of prion
material that can cause infection.” In order to protect the U.S. cattle population, the
following ruminant (cattle) feeds have been banned by the FDA:
ruminant meat and bone meal, blood meal and blood by-products, and
“inspected meat products cooked and offered for human consumption and
further heat processed including plate waste and food casings.” (There
is something weird about this; meat that is safe for people to eat is not
safe for cows?)
23.
Agency Fought Retesting of Infected Cow, M. Kaufman, Washington
Post, February 3, 2006 (“Agriculture Department officials
overruled field scientists' recommendation to retest an animal that was
suspected of harboring mad cow disease last year because they feared a
positive finding would undermine confidence in the agency's testing
procedures, the department's inspector general said yesterday.”
“When officials from the inspector general's office met with the
head of APHIS, they were told that the protocol followed by the agency
was the international "gold standard" and nothing more was
needed, the report adds. Nonetheless, the sample was later sent to England for a different set of
tests and was found to have the mad cow infection.”)
24.
“Downer” Cows Entering U.S. Meat Supply, Report
Says (Update 1), D. Goldstein, Bloomberg.com, February 2, 2006
(“U.S. beef inspectors sometimes ignore rules for screening cattle that
are intended to prevent mad-cow disease, putting the nation's meat supply
at risk, the Agriculture Department's Inspector General said. Twenty-nine
head of cattle that couldn't walk were slaughtered over a 10-month period
at two of 12 meatpacking plants reviewed in an audit, the IG said in a
report. Of these, 20 were identified as ``downers,'' with no records of
acute injury. Downer animals are considered the highest-risk for mad- cow
disease. In one plant, auditors saw a forklift being used to transport a
downer cow to slaughter, the IG said.”)
Fresh
Guano or Manure
1.
Fertilizing the Organic Garden, C.W. Bashman
and J.E. Elis, Colorado State University
Cooperative Extension. (“Because of potential food safety
problems, never use fresh manure on food gardens.”)
2.
Manures
for Organic Crop Production, G. Kuepper, 2006.
(Manure NPK contents are compared. Gives facts on Histoplasmosis, which is a potential fear with unfossilized guano. Fresh guano is subject to
90/120 day waiting period because of related pathogens. (Because it
lacks pathogens associated with fresh guano, ABG phosphate is not listed
as a mined material instead of as guano. So long as a local organic
farm certifier agrees with our OMRI listing as an “Allowed” product, a
waiting period is not required.))
Fertilizer
Regulations
1.
California Code of Regulations, Plant Industry,
Sections 2300 through 2326 (Provides California’s regulations for
fertilizer labeling requirements and heavy metal limits.)
2.
Oregon Department of Agriculture, Division 59,
Fertilizers, Agriculture Minerals, and Limes (Provides Oregon’s regulations for
fertilizer labeling requirements and heavy metal limits.)
3.
WAC 16-200-7063, How will the department determine
whether a commercial fertilizer meets Washington standards for metals
(Provides Washington’s method for computing
metal allowances. Also lists default
application rates for various elements.)
4.
WAC 16-200-7064, What are the Washington Standards
for metals? (Provides Washington’s metal limits for
fertilizers)
5.
WAC 16-200-711, Plant nutrients in addition to
nitrogen, phosphorous and potassium (Provides Washington’s minimum amount of
nutrient that must be present to guarantee it as a source of that
nutrient.)
6.
Arsenic Concentration Limits in Fertilizer,
Minnesota Department of Agriculture (Arsenic cannot exceed 500 ppm in fertilizer.)
7.
Maine
Considers Action Against Chemicals in Fertilizer, R. Suwol,
2002 (Maine considers regulating
arsenic and lead contents of fertilizers. A specific iron
fertilizer reportedly is of great concern because of high arsenic
contents, but Federal law makes state regulation of this product
difficult.)
8.
40
CFR Parts 261, 266, 268 and 271, Zinc Fertilizers Made from
Recycled Hazardous Secondary Materials, EPA Final Rule (Federal
regulation on waste-derived zinc fertilizer)
9.
The Heavy
Metal Rule, Association of American Plant Food Control Officials, 2006
(Excerpt of rules for allowable heavy metal concentrations in
fertilizers).
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