United States Solid Waste and EPA530-F-97-053
Environmental Protection Agency Emergency Response December 1997
(5305W) http://www.epa.gov
Office of Solid Waste
ve/EPA Environmental
Fact Sheet
Waste-Derived Fertilizers
Concerns have been raised regarding the use of certain wastes in the manufacture
of agricultural fertilizers and soil amendments, and the potential for ecological or human
health risks, as well as crop damage, when such fertilizers are applied to farmlands. In
conjunction with state governments, the U.S. Environmental Protection Agency (EPA)
has launched a major effort to assess whether or not contaminants in fertilizers may be
causing harmful effects, and whether additional government actions to safeguard public
health and the environment may be warranted.
Wastes Used in Fertilizers
Most fertilizers that are commonly used in agriculture contain the three basic
plant nutrients: nitrogen, phosphorus, and potassium. Some fertilizers also
contain certain "micronutrients," such as zinc and other metals, that are
necessary for plant growth. Materials that are applied to the land primarily to
enhance soil characteristics (rather than as plant food) are commonly referred to
as soil amendments.
Fertilizers and soil amendments can be derived from virgin raw material,
composts and other organic matter, and wastes, such as sewage sludge and
certain industrial wastes. These wastes can include some that are regulated as
hazardous under state and federal regulations.
Industrial waste materials are often used in fertilizers as a source of zinc and
other micronutrient metals. Current information indicates that only a relatively
small percentage of fertilizers is manufactured using industrial wastes as
ingredients, and that hazardous wastes are used as ingredients in only a small
portion of waste-derived fertilizers. Some fertilizers and soil amendments that
are not derived from waste materials can nevertheless contain measurable levels
of heavy metals such as lead, arsenic, and cadmium.
EPA's longstanding policy encourages the beneficial reuse and recycling of
industrial wastes, including hazardous wastes, when such wastes can be used
as safe and effective substitutes for virgin raw materials. Although EPA is
examining whether some fertilizers or soil conditioners may contain potentially
harmful levels of contaminants, the Agency believes that some wastes can be
used beneficially in fertilizers when properly manufactured and applied.
Fertilizer Regulations
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While a number of states currently have testing and labeling requirements
for fertilizers, such requirements typically address only the agriculturally
beneficial ingredients (e.g., plant food) of the fertilizers. Relatively few states
require comprehensive testing and disclosure of all chemical components of
fertilizers. As a general rule, soil amendments are subject to fewer state regula-
tory controls than are fertilizers.
Certain types of wastes that are used for agricultural purposes are subject to
federal regulations, which are often administered by states. Sewage sludges that
are used in agriculture are regulated under the Clean Water Act, and are
currently subject to concentration limits for the metals arsenic, cadmium,
copper, lead, mercury, molybdenum, nickel, selenium, and zinc. In addition, for
fertilizers that contain hazardous waste, EPA standards specify limits on the
levels of heavy metals and other toxic compounds that may be contained in the
fertilizer products. These concentration limits were based on the "best
demonstrated available technology" for reducing the toxicity and mobility of the
hazardous constituents. However, fertilizer made from one specific type of
hazardous waste-air pollution control dust generated during steel
manufacturing-is not subject to those concentration limits. This exemption was
based on a 1988 finding by EPA that the composition of this particular waste is
comparable to the materials that would otherwise be used to make this type of
fertilizer, and that its typical use was not harmful. All other fertilizers that
contain hazardous wastes are, however, subject to the contaminant
concentration limits established by EPA.
In some states, the regulations on hazardous waste use in fertilizers may be
more stringent than the federal standards, since states can adopt regulations
that are more stringent and/or broader in scope than the federal regulations.
Likewise, some states may regulate the use of nonhazardous wastes in
fertilizers, although such practices are not currently subject to regulation at the
federal level.
Actions Being Taken by EPA
To determine whether contaminants in fertilizers (both waste-derived and
nonwaste-derived) may pose unacceptable risks to human health or the
environment, EPA is currently assessing: (1) the types of wastes that are being
used in fertilizer manufacture, and the composition of fertilizers with regard to
toxic metals and other potentially hazardous constituents; (2) the potential for
soil contamination, and associated risks to human health and the environment,
from nonbeneficial constituents, based on fertilizer content and application
rates; (3) incidents of crop damage or other problems thought to be related to
waste-derived fertilizer use or fertilizer containing hazardous constituents; (4)
current regulatory requirements for fertilizer composition in various states and
in foreign countries.
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Since the American Pacific Northwest has been the focus of many concerns
regarding waste-derived fertilizers, EPA's Region 10 office is the lead federal
organization working with Washington and other states to coordinate state and
federal efforts in this area. Region 10 is an active participant in the Washington
State Fertilizer Advisory Workgroup, and will be assisting the state in
conducting further field studies and research on contaminants in fertilizers in
the state of Washington.
EPA will carefully review all collected information to determine the nature
and magnitude of the problem, if any. Based on the outcome of this
investigation, EPA will consult with the U.S. Department of Agriculture (USDA)
to determine whether additional actions beyond current regulations are
necessary to protect public health and the environment, and/or agricultural land
resources. Any such actions also will be done in consultation with the states, in
order to complement and reinforce state efforts underway. Although it is not
clear at this time that additional government action will be needed, possible
actions that could be taken by EPA or the states include: (1) issuing guidance or
regulations on labeling of fertilizer ingredients; (2) further restricting the use of
hazardous waste in fertilizers; or (3) issuing comprehensive new regulations for
contaminants in all fertilizers and soil conditioners.
When the Agency completes its initial assessment of available data on
contaminants in fertilizers, it will identify data gaps and determine what
further information is needed. As new information becomes available, EPA will
continue to provide updates on its activities and findings related to the use of
fertilizers.
For More Information
This fact sheet is available in electronic format on the Internet at
http://www.epa.gov/oswer/hazwaste. For additional information or to order
copies of this or any other document, call the RCRA Hotline. Callers within the
Washington Metropolitan Area must dial 703-412-9810 or TDD 703-412-3323
(hearing impaired). Long-distance callers may call 1-800-424-9346 or TDD 1-
800-553-7672. The RCRA Hotline operates weekdays, 9:00 a.m. to 6:00 p.m.
Write to the RCRA Information Center (5305W), US EPA, 401 M Street, SW,
Washington, DC 20460.
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