REVIEW CRITERIA
Ecology’s review criteria for waste-derived and micronutrient fertilizers are based on the Dangerous Waste Regulations, chapter 173-303 Washington Administrative Code (WAC). If a fertilizer product does not meet the standards for the analytical tests described in the Initial Criteria below, the Department of Ecology will recommend that the product not be registered for sale or distribution by the Department of Agriculture. However, should a fertilizer product fail one or more of these analytical tests, the registrant may chose to enter into the Secondary Criteria to further evaluate the product for registration in Washington. As described below, the Secondary Criteria require the registrant to provide information to rebut the presumption that the Dangerous Waste Regulations apply to the fertilizer product or that the product is not in compliance with the regulations. The Secondary Criteria are applied only to those products that have failed the Initial Criteria or those products manufactured solely from organic waste materials such as animal parts. Note: In May 2000, the Department of Ecology amended the Initial Criteria to eliminate testing for Polycyclic Aromatic Hydrocarbons (PAH). PAH's are complex organic compounds that are sometimes found in petroleum or other chemical wastes. In the first year of reviewing waste-derived and micronutrient fertilizers Ecology found very few products with detectable levels of PAH's and the concentrations that were measured were extremely low. It was determined that because the concentrations found were not remotely approaching regulatory levels and the cost of a PAH analysis was significant, that Ecology would withdraw this requirement and encourage fertilizer registrants to spend the savings on testing to assure their products are meeting the Washington Metals Standards. Registrants of waste-derived or micronutrient fertilizer products must provide copies of: Initial Criteria
Secondary Criteria If a fertilizer product fails any of the above tests, the registrant must provide the information in the secondary criteria, below. The secondary criteria must be passed or that product will not be recommended for registration in Washington. This information must be provided for Ecology to determine: 1) the fertilizer product is not subject to the state DW regulations or 2) the product is in compliance with the state DW regulations.
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