Ag Survey Question – Fertilizer Composition

For the last couple of years I have tried to only look at CSAT FAQ updates on a weekly basis. The main reason for this is that the answers to most of the questions provide clarification rather than truly new information. Some times, however, a newly posted question/answer provides such insight into the CSAT process that it deserves to be covered on a more immediate basis. Such is the case with the latest addition to the FAQ list:

1691: How will I know if a fertilizer includes a COI at or above the minimum concentration listed in Appendix A? Where can I find the percent by weight of a COI in a fertilizer?

There are generally two types of agricultural chemicals that are covered in this Agriculture Survey, pesticides and fertilizers. Since pesticides are closely regulated by the Environmental Protection Agency, it is fairly easy to identify the DHS chemicals of interest (COI) that are found in any registered pesticide and the concentration of that COI in the pesticide. All of that information is required to be listed on the label and in the MSDS sheet. More over, DHS is actually able to pre-populate the survey with the COI list for most registered pesticides, requiring the Preparer only to verify the actual percentage listed on the label.

Fertilizers present a particular problem with this survey. Most fertilizers boldly report the equivalent percentage of the three common mineral nutrients, nitrogen, phosphorus, and sulfur. The actual chemicals that provide these three nutrients will vary significantly. For example nitrogen may come from anhydrous ammonia, ammonia, or ammonium nitrate; all COI. Or it may come from urea or any number of ammonium salts; none of which are COI.

The actual chemicals used in the fertilizer may not be listed on the label. This would be especially true of many organic fertilizers, particularly compost. The manufacturer may simply conduct chemical tests to measure the mineral nutrient content.

Even where the manufacturer does know what the actual chemicals are in their particular fertilizer blend, labeling and MSDS requirements may allow the manufacturer to avoid listing the actual chemicals due to the proprietary nature of the blend. Current EPA regulations allow for the manufacturer to simply list the hazards associated with the chemical blend rather than its constituent components. Unfortunately, the EPA hazard listing requirements do not match up well with the DHS COI listing requirements. This is why the response to this question includes the following statement.

“The fertilizer Material Safety Data Sheet (MSDS) may provide [emphasis added] the percent by weight of the specific material in the fertilizer.”

There are going to be some fertilizers that the Preparer is just not going to be able to tell whether or not they contain COI at concentrations above the concentration minimums listed in Appendix A. What would have been nice if DHS had included a statement in this response that reflected that possibility; something along the lines of:

“If neither the label nor the MSDS for the fertilizer provides a list of the constituent chemicals, or doesn’t provide concentrations for the chemicals that it does list, do not include that fertilizer in your responses to this Survey.”

Of course, what would have been more helpful to DHS in their data collection effort would have been to provide a method of identifying the fertilizers that did not provide enough information on their label or MSDS to complete the Survey. A requirement to list the Fertilizer name and the name of the manufacturer would probably have been sufficient.