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.htmAnd 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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