USCC Win: AAPFCO Approves Test for Compost WEP Labelling Change

The American Association of Plant Food Control Officials (AAPFCO) is an organization of state Department of Agriculture (DOA) officials. More specifically, it represents the Control Officials that register and regulate the distribution of fertilizer, soil amendments and liming agents (and sometimes pesticides and animal feed) in each U.S. state, its territories, as well as Canada. The organization creates model laws and regulations to assist interstate commerce of these agricultural and horticultural staples. Its primary goals pertain to consumer protection, by requiring ‘truth in labeling’, and uniform regulation from state to state.

In response to State regulations regarding phosphorous fertilizer usage, AAPFCO developed recommended language regarding 'Fertilizer Restrictions for Urban Landscapes", as well as other related Statements of Uniform Interpretation and Policy to assist States in developing science-based regulation. Unfortunately, many states have been overzealous in their regulation, often 'just going too far' (e.g., almost eliminating even maintenance applications of phosphorous on turf), while some have not dealt with more significant causes of nutrient contamination (e.g., over fertilization or manuring on agricultural land, strict enforcement of NPDES Phase II regulation [sediment control regulation during construction]). Unfortunately, many states have ignored relevant science, regulating all phosphate sources the same and ignoring their actual mobility. In many of these states, compost is impacted by these regulations, if they make nutrient claims, and sometimes when they don’t.

For this reason, the USCC’s Industry Liaison to AAPFCO (Ron Alexander) researched a means to illustrate the difference between phosphorous in compost (and other carbon-based products) and those found in many chemical fertilizers. In order to be able to claim that carbon-based products contain lower amounts of water-extractable phosphate (WEP), an acceptable lab method had to exist or be developed. These efforts led to the identification and evaluation of the SERA (Southern Extension & Research Activity) -17 WEP test method, which was originally developed for manure and biosolids. Note that several composters are already testing for WEP, especially if their product is to be used in stormwater or erosion control applications, and in states which are limiting phosphate usage in certain turf applications. Working with The Pennsylvania State and Colorado State Universities, the USCC proposed the WEP test method and a definition for WEP. The importance of this claim relates not only to the potential negative environmental impacts of highly soluble phosphate sources, but also helps compost customers better manage nutrient addition for proper plant growth. 

At the July AAPFCO meeting, the test method for WEP was found to be acceptable, however sampling methods need to be further ‘fleshed out’ and the definition will likely go ‘official’ at the next AAPFCO meeting (February 2022).

Water extractable phosphorous – the amount of phosphate in a carbon-based fertilizer that is readily water  soluble, as determined by the SERA (Southern Extension & Research Activity) -17 test method.

The final piece of the puzzle was illustrating how testing for the WEP content of compost could be used to make slow-release phosphorous claims on fertilizer labels, while following existing labeling regulation (and format). See the example below; and note that the amount of phosphate that is not water extractable, is claimed as slowly available phosphate. After some discussion, it was determined that making slowly available phosphate claims for carbon-based products was in fact allowable.

During the next article, the author will discuss how monitoring WEP and making slowly available phosphate claims can assist composters in their market development efforts.

Author: Ron Alexander is President of R. Alexander Associates, Inc., a compost and organics recycled product marketing consulting company. He is also the USCC’s Industry Liaison to AAPFCO.

Ron@alexassoc.net   /   www.alexassoc.net

Efforts Supported by the Industry

ORGANIZATIONS

• American Biogas Council - represent 3,000 professionals

• US Composting Council - represent 2,000 professionals

• Water Environment Federation - 35,000 members and 75 affiliated associations

• US Biochar Initiative

• Association of Compost Producers (CA) - represent 100 composters

• California Association of Sanitation Agencies

• Colorado Composting Council

• Georgia Recycling Coalition

• Illinois Composting Council

• Illinois Food Scrap Coalition

• Michigan Organics Council

• Mid-Atlantic Biosolids Association

• New York City Department of Environmental Protection

• North East Biosolids & Residuals Association

• North Carolina Composting Council

• Northwest Biosolids Organization - represents 130 WWTP

• Washington Organic Recycling Council

PRIVATE AND PUBLIC ENTITIES

• A-1 Organics 

• Agresource

• Barr-Tech 

• Black Gold 

• Cedar Grove Composting 

• DC Water 

• Denali Water Solutions

• ERTH Products, LLC 

• Green Soil Mgt (IL) 

• Howard County (MD) Dept of Public Works 

• Inland Empire Composting Authority

• Kellogg Garden Products 

• McGill Environmental Systems 

• Milorganite / MMSD 

• NEFCO 

• Newtrient 

• Nutrients PLUS, LLC 

• St. Louis Composting 

• Sustane Natural Fertilizer 

• Synagro 

• Walker Industries (Canada)