compost: nature’s way to grow!...compost: nature’s way to grow! us composting council • po box...

Compost: Nature’s Way to Grow!

US Composting Council • PO Box 19246, Raleigh, NC 27619

phone: 301.897.2715 • [email protected]• www.compostingcouncil.org

June 26, 2020

Andrew Muench, Chemical Review Manager

Pesticide Re-Evaluation Division, Office of Pesticide Programs

Environmental Protection Agency

1200 Pennsylvania Ave., N.W.

Washington, DC 20460-0001

Re: USCC Comments of Proposed Interim Decision for Clopyralid--EPA-HQ-

OPP-2014-0167.

Dr. Muench,

The US Composting Council (USCC) advances compost manufacturing, compost

utilization, and organics recycling to benefit our members, society, and the

environment. We believe compost manufacturing and compost utilization are

central to creating healthy soils, clean air and water, a stable climate, and a

sustainable society.

The USCC currently has approximately 768 members, representing over 2000

individuals. Our signature product certification program, the Seal of Testing

Assurance (STA), has over 200 participating compost manufacturers, representing

320 different STA Certified Compost products producing over ten million cubic

yards of compost per year. Using the average published retail price1 that would

have a value of $262 million. Since certified STA manufacturers only make up a

small percentage of all compost manufacturers that represents a only a fraction of

the total worth of the industry’s product sales and does not include multiplier

effects of the value of products that compost is used in, such as retail bagged

potting soil, blends and construction fill topsoil. Furthermore, typical commercial

composters make only 20% of their income on product sales, and the rest is from

service fees for processing organic wastes (collection and tip fees). While an

estimate of the total size and value of the US compost manufacturing industry is

not available, it is clearly a multi-billion dollar industry.

Almost half of US States ban yard trimmings (including grass clippings) from

landfill disposal. Other states have aggressive recycling goals that require (or

strongly encourage) recycling of organic materials such as those generated at

homes, businesses, golf courses, roadways, etc. In the majority of US states,

sending organic materials to composting is the expected resource recovery pathway

and this trend only continues to grow. Both EPA and USDA actively promote

collecting organics for composting and compost use.

1 Composting News August 2019 http://compostingnews.com/wp-content/uploads/2019/08/cnprices.pdf

Officers

President

Patrick Geraty St. Louis Composting

Interim Past President

Bob Yost A-1 Organics

Vice President

Brian Fleury WeCare/Denali

Treasurer

Joe DiNorscia Laurel Valley Soils

Secretary

Sarah Martinez Eco-Products

Board of Directors

Eileen Banyra

Community Compost Company

Jeff Bradley Vermeer

Jim Cowhey

JPM Development, LLC

Jeff Dannis Howard County MD

Russell Faldik

New Earth Compost

Tim Goodman NatureWorks

Pierce Lewis

Dirt Hugger

Sarah Martinez Eco-Products

Robert Michitsch, Ph.D.

University of Wisconsin Stevens Point

Bob Schanz

Barnes Nursery

Jennifer Trent Iowa Waste Reduction Center

University of Northern Iowa

Executive Director

Frank Franciosi

http://compostingnews.com/wp-content/uploads/2019/08/cnprices.pdf

http://compostingnews.com/wp-content/uploads/2019/08/cnprices.pdf

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Compost is a trusted soil amendment and source of fertility for millions of home gardeners and

thousands of commercial growers, and plays a vital role in meeting national goals of waste

reduction and healthy soils. Confidence in the products they purchase is fundamental to a healthy

industry, and trust once lost is difficult to regain. The known presence of persistent herbicides in

only some composts could have a chilling effect on most composts. The STA program has been

working to increase confidence in manufactured compost by standardizing testing and reporting

processes and setting minimum guidelines for basic applications. But those decades of work could

be undone by threats of “killer compost”. It is critical that the EPA better balance the needs of crop

producers who need to control difficult weeds with the needs of home gardeners and organic

growers who rely on compost to improve soil-water dynamics, reduce synthetic chemical use and

improve the overall health of their soil.

The USCC is pleased to see that the EPA has recognized that Clopyralid and other persistent

herbicides are having a deleterious effect on the composting industry, as represented by section

IV.A.3: Measures to Address Potential Compost Contamination. Specific comments on that section

will be provided below. However, the proposed remedies do not go nearly far enough, so some

general comments are in order.

While the benefits of clopyralid use to farmers, applicators and land managers is clearly defined, the

risks via contaminated compost are much less well understood. This is because the risk evaluation

of pesticides has never included the composting pathway, and key questions about that path are

undefined. For example, what is the “No Observed Adverse Effect Level” (NOAEL) for Clopyralid

in compost? How long does the chemical have to be in the composting environment to reach that

level? What is a reasonable time frame that chemicals like Clopyralid should be required to degrade

in to be approved? In order to protect the farm and garden customers of large-scale composters,

three months would be a reasonable answer to that last question, given modern operations and

processing times. While the precise answers to these and related questions will take some time to

answer, they MUST become part of the overall herbicide approval and registration/re-registration

process.

History and costs of incidents

There have been no large scale, nationwide studies of the scope, prevalence or impact of

compost contamination by Clopyralid and other persistent herbicides. For obvious reasons,

composters who discover contamination are very reluctant to publicize that--no one wants to be

associated with “killer compost”, as herbicide-contaminated compost incidents have been called.

However, several informal reports provide strong anecdotal evidence

1. USCC Confidential reporting form. In 2014, as part of an effort to educate composters on

this issue, the USCC developed a confidential incident reporting form2. Two major incidents this

spring of 2020, in North Carolina and Oregon, have stimulated a flurry of submissions. The list of

incidents reported as of the comment submission date is attached as appendix A. The most up-to-

2 Unfortunately, all the incidents submitted between 2015 and mid-2019 were lost over several website

transitions.

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3

date version of the results can be viewed and downloaded here:

https://www.dropbox.com/s/a4fbewk1zxxb9wc/USCC%20PH%20confidential%20reporting%20for

m%20submissions%20for%20EPA.xlsx?dl=0. Many of the incident reporters sent additional photos

and supporting evidence. These can be found at

https://www.dropbox.com/sh/figs4kb89q47dn6/AADjtr3mcKrcOCVVrk6DSbpqa?dl=0. The

USCC can supply contact info of incident reporters at the request of the EPA.

2. Scotts MiracleGro® screening of composts for inclusion in their products

Scotts Miracle-Gro (SMG) began an investigation into persistent herbicides in compost through an

extensive quality monitoring program in 2017. Historically, quality monitoring was done through

analytical lab testing. However, once we began to better understand the scope of herbicide

persistence, the cost of analysis ($200 for a single persistent herbicide) became prohibitive. In

addition, SMG observed a very low correlation between the herbicide concentrations reported

through analytical testing and phytotoxicity symptoms observed on plants. This was attributed

to the small volumes of compost used for analytical testing that likely were not representative of

large compost volumes. To remedy this, SMG pivoted to relying on the use of bioassays to

determine the presence and severity of herbicides in composts. The initial step was to establish an

internal clover bioassay phytotoxicity scale based on the method developed and published by

Woods End Research Labs. Then, we internally validated our rating scale, demonstrated

repeatability, and trained clover injury raters. With this sampling method, SMG has tested over 150

different compost samples, and continues our sampling currently to ensure the quality of our

products.

The summary data from the years 2017-2019 are presented below. Because our detection method is

a bioassay for persistent herbicides, not analytical testing, this dataset shows the presence of any

persistent herbicide, not just clopyralid. It should also be noted that there is bias in this data as this

is not a random sampling of all composts on the market. The composts tested in our bioassays are

pre-screened to have a nutrient composition deemed acceptable for potential inclusion in SMG

products. Additionally, we are not screening randomly, but are targeting enhanced learnings about

where to expect problems and are focusing our efforts in these locations. Accordingly, the reduction

in herbicide hits in 2019 is most likely not due to composters having less herbicide in their

products. A more likely explanation is that we are learning from our internal testing and getting

more selective on where we go to obtain compost.

SMG will continue to screen and monitor our suppliers for the presence of persistent herbicides in

compost as part of our quality monitoring program to ensure that we are providing our consumers

with high quality products. While we have taken steps internally to manage and mitigate this

https://www.dropbox.com/s/a4fbewk1zxxb9wc/USCC%20PH%20confidential%20reporting%20form%20submissions%20for%20EPA.xlsx?dl=0



https://www.dropbox.com/sh/figs4kb89q47dn6/AADjtr3mcKrcOCVVrk6DSbpqa?dl=0



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4

problem, we urge the EPA to consider this issue and implement strategies to improve this systemic

problem with the nation’s compost supply before it gets worse.

3. Ohio State University study of Commercial Composts

To determine the prevalence of herbicide contamination in US composts, compost samples

were obtained from 70 different commercial composting facilities in the US and Canada in 2014.

All were USCC members and represented some of the largest commercial and municipal

composting facilities in North America. The samples collected were of ready-to-sell finished

compost. Each compost was tested for herbicide phytotoxicity symptoms using a potting media

bioassay using four bean seeds as an indicator species. Herbicide phytotoxicity symptoms including

loss of apical dominance, leaf curling and leaf malformation were observed during growth in a

greenhouse for 35-50 days. Plant height, dry weight, leaf number and average leaf weight were also

measured. Results showed that beans grown in three of the 70 composts (4%) displayed severe

phytotoxicity symptoms. Leaf curling and loss of apical dominance were observed in plants grown

in 4 of the composts. Samples displaying phytotoxicity symptoms were chemically tested and found

to contain picloram, clopyralid and/or aminopyralid herbicides at concentrations greater than 6 ppb.

Negative control composts had less than 1 ppb of these compounds. The positive composts were

from three different regions of the US.

4. One moderately-sized compost manufacturer located in Sonoma County, CA, reported:

a. Feedstocks included: Green debris, dairy manure, horse manure, poultry manure,

coco coir, peat moss, grape pomace and rice hulls.

b. In 2002 and 2012, composts contaminated with phytotoxic levels of Clopyralid, and

in 2009 with Aminopyralid, resulting in a total of more than $320,000 in expenses to

remediate customer damage. The aftermath will likely last for years made local and national

news).

c. A $100,000/year testing program was initiated for incoming feedstocks and finished

compost materials. The manures were segregated on the provider site for testing. The piles

were broken into predetermined sizes and blended via a loader and samples taken from each

pile for lab analysis. No manure would be allowed to enter the composting operation

without passing testing.

d. Horse manure was contaminated with Clopyralid that ranged from 4PPB to well over

40PPB. Horse manures failed testing 80% of the time, while chicken and cow failed 20%.

Rice hulls failed testing 40-50% of the time. Incoming green debris was segregated into

piles for grinding and blending. In 4 years of performing this type of incoming testing no

green debris failed testing. Clopyralid was removed from the residential market in 2002.

5. Green Mountain Compost

a. The Green Mountain Compost facility is owned and operated by the Chittenden

Solid Waste District (CSWD) in Williston, Vermont was the epicenter of a widespread,

unintentional release of herbicide-containing compost to over 500 customers in late 2011

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5

and early 2012. All told, the District realized over $800,000 in direct expenses related to the

event and spent more than a year rebuilding the compost business and repairing damage to

the brand.

b. Aminopyralid was determined to be the main culprit in this outbreak, and it was

believed to have entered the facility via horse manure and bedding. However, extensive

testing of feedstocks and finished products conducted by Dow AgroSciences as part of the

investigation identified the presence of potentially damaging concentrations of Clopyralid in

all of the commercial horse feeds tested as well as in all of the horse manure samples

submitted from all over the County where the facility is located. Clopyralid was detected in

all of the 21 separate commercial horse feed samples analyzed with concentrations ranging

from 1 ppb to 623 ppb with an average of 175 ppb. Clopyralid was in all 11 horse manure

samples analyzed with concentrations ranging between .67 – 34.8 ppb with an average of

14.3. Foodwaste samples taken randomly from different compost input streams and sent to

a commercial lab in early 2013 also resulted in samples that all showed the presence of

Clopyralid, including a concentration of 42 ppb in a sampling of bread and grain items

sampled from a local elementary school. The conclusion from all of the related testing was

that composts being made using inputs of commercially available animal manures

(particularly horse manures) and conventional grocery, restaurant, and cafeteria wastes

would all be likely to contain some level of residual Clopyralid content.

c. Early analysis efforts for the 2012 CSWD incident were severely hampered by the

lack of dependable lab analyses available nationwide. Inaccurate analysis of Clopyralid and

related pyridine compounds in compost and manure-based matrices remains commonplace

amongst public and private labs throughout the country. The participation of Dow

AgroSciences and their willingness to provide analysis in-house was the only reason that

CSWD was able to conduct a proper investigation. The availability and affordability of

reliable testing remains a major obstacle for herbicide in compost incidents now eight years

later.

General recommendations

In order to prevent herbicide contamination of compost, protect the investment in green

spaces, steward the US food production, continue diverting organics from landfills, maintain

consumer confidence in compost products, and protect the nation’s compost manufacturers, the

USCC makes the following recommendations:

1. Limit pesticide application to non-harvested crops, and prohibit use on turf (see comments

on IV.3.A below for specifics on turf prohibition) and all other uses that can be expected to

be collected for composting. Current tolerances for clopyralid residuals on harvested crops,

which range from single parts per million up to 500 ppm3, are hundreds of times higher than

the level of adverse effects in compost, since those levels were established based on human

3 https://www.govinfo.gov/content/pkg/CFR-2019-title40-vol26/xml/CFR-2019-title40-vol26-

part180.xml#seqnum180.431

https://www.govinfo.gov/content/pkg/CFR-2019-title40-vol26/xml/CFR-2019-title40-vol26-part180.xml#seqnum180.431

https://www.govinfo.gov/content/pkg/CFR-2019-title40-vol26/xml/CFR-2019-title40-vol26-part180.xml#seqnum180.431

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6

and environmental risk assessments that do not include the compost pathway. Until those

limits can be established, the herbicides must stay where they are used.

2. Change the registration process for herbicides to require an evaluation of compostability and

persistence in compost. This requires developing the test methods and standards for

registrants that must be met in order for an herbicide to receive approval. The manufacturer

will need to evaluate each active ingredient and their residual damage after the composting

process to determine levels of plant toxicity. This compost residual test must include a plant

bioassay of several sensitive host plants.

3. Require the development of test methods for compost and similar difficult matrices that

independent labs can use to affordably identify contamination by this class of herbicides at

the 1 part per billion detection limit. Currently only a very small number of labs have the

capacity and offer the analysis, and those are very expensive ($300 per test). While

bioassays can indicate whether a compost might be contaminated to the level that can cause

damage, it cannot tell which herbicide(s) is(are) the culprit(s).

4. Assign liability to all members of the supply chain: pesticide applicator, land owner,

property manager, and pesticide product distributor, for damages from compost

contaminated by Clopyralid, since per the label is should not be present in compost at

damaging levels. Liability should include removal or remediation of soils or compost

contaminated by Clopyralid-treated materials that have been moved off-site from where it

was applied. Penalties and fines for misuse need to be established and penalty amounts

listed on the label.

5. Limit application of Clopyralid to professional licensed applicators--no retail sales

(including internet sales) of Clopyralid products;. As with other controlled products, that

allows controlled distribution and tracking of products sold, and education of applicators on

allowed and disallowed applications. Manufacturers should provide documented training to

professional certified applicators.

6. Require training for state extension agents and educators of licensed pesticide applicators on

label restrictions, pesticide application, and identification of plant damage by Clopyralid

contamination.

7. Require pesticide manufacturers to supply steps to remediate contaminated compost and

garden soil. Several tactics, including use of activated charcoal, and certain biochars and

wood ashes, have shown promise. The herbicide manufactures must be responsible for

developing and providing that remediation.

Specific comments

III. A. Tolerances.

The tolerances published in the CFR are established based on risks to human health, thus are

as high as 500 ppm on grass forage. This is around 100,000 times the level of impact in compost,

so it is no wonder that horse bedding can be a likely source of contamination in compost.

Furthermore, not all potential sources of contamination are listed. For example, rice hulls are

frequently used in dairy bedding and directly in compost production as a bulking agent, but no

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7

tolerance is listed. At least one major composter reported rejecting 50% of rice hull loads due to

herbicide contamination.

IV. A. 3. Measures to Address Potential Compost Contamination

a. Expansion of Residential Turf Prohibition

The expansion of the prohibition of the use of Clopyralid from residential lawns to school

lawns are a good start, but are arbitrary and insufficient. That prohibition should be extended to all

lawn, including parks, playgrounds, cemeteries, golf courses, and commercial lawns. There could

be an exemption for grass clippings that are kept on-site, either by grasscycling in place or

composting on site, so the herbicide does not leave the property.

b. Compost Prohibition, Notification, and Recordkeeping

Given the number of reported incidents of impacts on non-target species from home and

community gardeners and commercial vegetable growers, a number that is certainly a small fraction

of the actual number of incidents, strengthening and expanding the prohibited uses is critical. The

notification of the prohibition should be expanded from the pesticide applicator and landowner and

include the land manager, and the owner and manager must be required to notify the purchasers and

users of crops and byproducts. Further, responsibility for damages from compost contaminated by

clopyralid must extend through the supply chain, and penalties for non-compliance developed and

listed as part of the notifications.

We do not support the exemption of notification from public lands applications. Public

lands may be leased and managed by private companies, and the prohibition must be communicated

to them and the recipients of products from those lands.

Recommended changes to proposed language (page 18)

· “This product is persistent and may be present in plant materials for months after

application. Do not IT IS ILLEGAL TO use, or allow to be used, treated plant material

or manure from animals that have grazed or consumed forage from treated areas for

compost, mulch, or mushroom spawn. Applicators must document that they have

advised property owners/operators of the property, land managers, or AND customers, in

writing, of this prohibition. Applicators must keep the records of notification for two

years. This record must include date of application, the name of the applicator, the EPA

registration number of the product applied, information on the area(s) treated, and a copy

of the notification. Records must be made available to State Pesticide Regulatory

Official(s), and to EPA upon request. Applications to public land are exempt from this

notification requirement.”

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8

With regards to the proposal to extend holding time or PHI for treated crops, the time that is

required must be long enough so that residual levels are low enough so that post-composting levels

are below the NOAEL, or absent an established NOAEL, below detection levels.

c. Education and Stewardship Plans

In alignment with our comments above, it is important that the educational materials be

distributed not only to land owners but accompany clopyralid along the supply chain to the compost

manufacturer so they can make informed decisions about feedstock inclusion and markets for the

finished compost.

d. Revision of Compost Pictogram

The revised pictogram is an improvement, but the

wording below the top picture (circled in red) is misleading,

since it seems to imply that it only applies to applications on

“non-cropland, rights of way and natural area” when in fact is

it the lifted crops, whether for grain or forage, that carry the

clopyralid to the compost pile.

Summary

Clopyralid, like other persistent herbicides, may be a boon to growers and turf managers, but

are becoming the bane of composters, home gardeners, and organic growers. The USCC calls for

the EPA to

1. Limit the application of persistent herbicides like Clopyralid to non-harvested crops, and

prohibit use on turf

2. Change the registration process for herbicides to require an evaluation of compostability and persistence in compost

3. Require the development of test methods for compost and similar difficult matrices that independent labs can use to affordably identify contamination by this class of herbicides at the 1 part per billion detection limit.

4. Assign liability to all members of the supply chain: pesticide applicator, land owner, property manager, and pesticide product distributor, for damages from compost contaminated by Clopyralid

5. Limit application of Clopyralid to professional licensed applicators

6. Require training for state extension agents and educators of licensed pesticide applicators on Clopyralid label restrictions

7. Require pesticide manufacturers to supply steps to remediate contaminated compost and garden soil.

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9

The USCC has appreciated the opportunity to dialogue with the EPA in the past on this issue, and

look forward to continuing to work with the Office of Pesticide Programs to restrict the use of these

valuable chemicals to applications that will not harm composts used by the nations gardeners,

home-owners, turf managers and organic vegetable growers.

Respectfully

Frank Franciosi

Executive Director

Printed: 6/26/2020Appendix A: PH incidents subm

itted to the USCC

page 1

Date/Time

Submitted

Details/Evidence of Event

Where

did the event take place? (eg, garden, field, lab, etc)*

Where

event occurred

County where

event occurred

Date adverse effects first observed

Ending date of observed adverse effects

Please provide details about the plants affected during this event below

.

Is there any evidence of herbicide use/m

isuse: (please choose 1)

How big is

your com

posting operation (tons/year or cubic yards/year)?

What

feedstocks w

ere used in the manufact

uring of the com

post?

Which of

your feedstock(s) do you suspect are the source(s) of persistent herbicide

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1


itted to the USCC

page 2

Date/Time

Submitted

6/25/2020 13:136/24/2020 17:296/24/2020 17:126/24/2020 17:016/24/2020 11:346/24/2020 11:346/23/2020 13:166/22/2020 17:406/22/2020 15:056/20/2020 17:586/17/2020 23:076/17/2020 21:306/17/2020 17:596/17/2020 17:596/17/2020 10:516/17/2020 0:03

6/16/2020 23:426/16/2020 20:596/16/2020 18:086/16/2020 17:096/16/2020 16:266/16/2020 11:236/16/2020 1:076/16/2020 0:21

Do you have any evidence to support this suspicion? If so, what is it?

Where

did you get the suspected tainted com

post?

How

much did

you get?When did

you get it?

Herbicides applied to adjacent law

n or property

Ethylene toxicity in a greenhouse environment

I give the USCC

permissio

n to share the contents of this form

with

the U.S.

EPANA

NA

NA

NA

No

No

YesYes, departTriangle la

5 cubic yarMar‐20

YesYes

YesAm

erican s6 yards04 end

YesNo

Yesna

Dean's Inn4.5 cubic y

16‐Apr‐20Yes

YesYes

Na

Sands and 2 cu. yards28‐Apr

No

YesYes

Na

Sands and 2 cu. yards28‐Apr

No

YesYes

We had theBest but in

3 cubic yar14‐Apr

YesYes

YesN/a

Deans inno1 cubic yar4/18/2020No

No

YesNA

McFarlane

1 unit29‐M

ay‐20Yes

YesYes

Na

Deans inno3/4 and th4/12/20 an

No

No

YesN/A

Dean's: 646 or 7 yardEither 4/6/2Yes

YesYes

n/aDean Innov7 yards

3.17/20Yes

YesYes

Confirmed

Dean's Inn2 yards

5/9/2020No

No

YesConfirm

edDean's Inn

2 yards5/9/2020

No

No

YesDeans Inno1.5 cu yarddelivered 5/N

oNo

YesNa

Grim

mâ€™

4 yards2/20/2020

YesYes

YesNa

Dean Innov1 yard 5/21/1930

YesYes

Yesn/a

Deans Inno1 yard4/21/2020

YesYes

YesNA

NA

NA

No

No

Yesn/a

Dean's Inn20 cubic yaordered on

YesYes

YesN/A

Dean Innov2.5 yards4/1/2o

YesYes

YesNa

Dean Innov1 1‐2 yards27‐Apr‐20

YesYes

Yestest result through Po4 yard

5/5/2020No

No

Yesnot applicaDean's Inn

2 cubic yar3.31.20No

No

Yes

Compost users only

2


itted to the USCC

page 3

Date/Time

Submitted


Where


Where

event occurred

County where

event occurred




.



How big is

your com


What

feedstocks w


uring of the com

post?

Which of



6/15/2020 21:08We have e

Home gardM

ultiple arMultnom

a5/16/2020

N/A

The followUndeterm

iN/A

N/A

N/A

6/15/2020 20:47I purchasedG

ardenDurham

, NDurham

Early May

ongoing 12 tom

ato Undeterm

inana

na6/15/2020 17:50

I received 3Garden, ra

Durham, N

Durham Co

Apr‐20Still occurinI received 3U

ndetermiI am

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not a 6/15/2020 12:40

March 202G

arden Durham

, NDurham

20‐Mar

N/a

Tomatoes,M

isuse/unN/a

N/a

N/a

6/15/2020 10:24I ordered 4garden

N. PortlandM

ultnoma

20‐AprN/A

My plants tU

ndetermi4 yards

N/A

N/A

6/14/2020 19:39Plants are G

ardenDurham

, NDurham

1‐JunOngoing

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ndetermiN/a

N/a

N/a

6/13/2020 21:03Vegetable raised gardportland o

multnom

amarch 2020`

ongoingseeds: m

arMisuse/un

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6/13/2020 14:21We purchaHom

e gardPortland, OMultnom

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ayCurrently oPeas, tom

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in/an/a

n/a6/13/2020 1:34

curling of lgarden andPortland, OMultnom

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ayongoing

first noticeMisuse/un

NA

nana

6/12/2020 23:45Curling andG

ardenOregon

Multnom

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ayOngoing

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NA

NA

NA

6/12/2020 21:24I w

as sold my hom

e Portland, OM

ultnomaDiscovered O

DNA

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isuse/unNA

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6/12/2020 17:55I purchasedHom

e gard680 E. ExetClackamas

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ndetermiNA

NA

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6/12/2020 15:37I bought soM

y home gM

y home

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ndetermiN/A

N/A

Deans Soil6/12/2020 15:23

Product: DGarden

Portland, OMultnom

aMay 28th, 202

N/A

Tomatoes,M

isuse/unN/A

Unknow

nUnknow

n6/12/2020 13:49

1 yard of Fhom

e gard5903 SE 49Multnom

a5/24/2020

ongoingpeas, tom

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aApr‐20

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hite light6/12/2020 6:41

tomatoes whom

e gardClayton, NCJohnston

late April to eanonetom

atoes: Undeterm

i0N/A

N/A

6/12/2020 2:16I purchasedBackyard cLos AngeleLos Angele

6/7/2020########

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eek Undeterm

iWe purchaW

e purchaI suspect th6/11/2020 19:19

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aycurrently sI bought coM

isuse/unn/a

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6/11/2020 18:58Soil tested Spread ove########

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isuse/un4N/a

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6/11/2020 16:07DiscoveredG

ardenGarden

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ayN/A ongoinO

bserved cMisuse/un

N/A

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6/11/2020 13:08I bought W

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6/11/2020 8:20We purchavegetable aHillsborougO

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e plantedUndeterm

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2 yards WhI believe haU

nknown

3


itted to the USCC

page 4

Date/Time

Submitted

6/15/2020 21:086/15/2020 20:476/15/2020 17:506/15/2020 12:406/15/2020 10:246/14/2020 19:396/13/2020 21:036/13/2020 14:216/13/2020 1:34

6/12/2020 23:456/12/2020 21:246/12/2020 17:556/12/2020 15:376/12/2020 15:236/12/2020 13:496/12/2020 12:176/12/2020 6:416/12/2020 2:16

6/11/2020 19:196/11/2020 18:586/11/2020 16:076/11/2020 13:086/11/2020 8:206/11/2020 2:17


Where


post?

How

much did

you get?When did

you get it?


n or property


I give the USCC

permissio


with

the U.S.

EPA

Compost users only

N/A

Deanâ€™s 4 yards

3/21, 4/12,YesYes

Yesna

sand and s3 cubic yar6‐Apr

No

No

YesI am

not a The Rock S3 yards24‐M

ar‐20Yes

YesYes

Rock Shop 5 yards Middle of MYes

YesYes

N/A

Dean Innov4 yardsApr‐20

YesYes

YesRock Shop,1.5 yards

Mar‐20

No

No

YesSource is reDean Innov2 yards

Mar‐20

YesYes

Yesn/a

Dean's Inn3.5 cubic y

4/11/2020Yes

YesYes

naDean Innov1 yard

4‐May‐20

No

No

YesNA

Deanâ€™s2 yds

14‐AprYes

YesYes

NA

Deans Inno1/2 yardDelivered 4

YesYes

YesNA

NA

NA

NA

YesYes

YesYes pictureDeans Inno4 yards

March 30thN

oNo

YesN/A

Dean's Inn4 Yards

2/28/2020No

YesYes

not a prodDean Innov2 yards

4/14/2020Yes

YesYes

Oregon DeIn bags at l4 bags (uns

9‐Mar‐20

YesYes

YesN/A

Triangle Latwo 1/2 cu

March 14 a

No

No

YesI suspect thThe com

po5 yards5‐Jun‐20

YesYes

Yesn/a

Dean in Po3 yards

april 7th, 20YesYes

YesPositive te

Deanâ€™s 4 yards

18‐AprYes

YesYes

N/A

Deans Inno2 cubic yar3/26/2020Yes

YesYes

naDeans ‐ the4 yards

3/24/2020No

No

Yesn/a

Nazo Lands8 cubic yar15‐M

ar‐20Yes

YesYes

Unknow

nDeanâ€™

s 2 yards Wh4/30/2020

No

No

Yes

4


itted to the USCC

page 5

Date/Time

Submitted


Where


Where

event occurred

County where

event occurred




.



How big is

your com


What

feedstocks w


uring of the com

post?

Which of



6/10/2020 22:17Tom

ato, suGarden

Milw

aukie Clackamas

3‐JunOn going

Lots of leafMisuse/un

Na

Na

Na

6/10/2020 21:30Slow

growtGarden

Portland, OMultnom

a5/5/2020

Ongoing

Tomatoes M

isuse/unNA

NA

NA

6/10/2020 21:10Plants w

enBackyardMy house m

ultnomaMay 21st

N/a currenTom

atoes Misuse/un

N/a

Donâ€™t kDonâ€™

t k6/10/2020 21:02

Herbicide cRaisedbedsMilw

aukie Clackamas

5/15/2020Ongoing

See aboveMisuse/un

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nknown. Soil purcha

6/10/2020 20:30I used a so

My raised gPortland, OM

ultnoma

5/12/2020Not applicaTom

atoes Undeterm

iNot applicaN

ot applicaNot applica

6/10/2020 20:29I purchasedG

arden Portland OM

ultnoma

4/30/2020Still seeing

Plants leavUndeterm

i2 cubic yarDairy Dairy

6/10/2020 20:21Delivery ofU

rban raisePortlandMultnom

a15‐M

aypresent

Tomatoes M

isuse/unN/A

N/A

N/A

6/10/2020 19:46Plants in thIn m

y homPortland o

Multnom

a30‐Apr

Continues Abnormal gRegistered

None

Purchased White light

6/10/2020 19:36Confirm

edRaised bedRaised bedM

ultnomaLate M

ayOngoing

Tomato, vaM

isuse/unN/A

N/A

N/A

6/10/2020 19:29Please see garden

portland omultnom

aapprox. 5/20

still observPlease see Misuse/un

n/an/a

n/a6/10/2020 19:23

Observed dG

arden9427 N

E CaMultnom

aMay 17 2020

June 5 202Stunted grM

isuse/intn/an/a

n/a6/10/2020 19:22

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aukieClackam

as10‐M

ayStill ongoinCurled tom

Undeterm

iN/A

N/A

N/A

6/10/2020 19:19Tom

atoes Home gardCom

post wOrange Co

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ersUndeterm

iIt came froU

nknown

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n 6/10/2020 19:19

3/17 delivePortland, Omy hom

e gMultnom

a4/30/2020

ongoingpeas deforU

ndetermii don't kno

unknown

unknown

6/10/2020 19:17Am

inopyraGarden

Damascus,Clackam

as4/30/2020

N/a

Twisted anM

isuse/unNa

Na

Na

6/10/2020 18:50I ordered FSm

all FarmPortland O

Multnom

aMarch 10th

No end datPeas badlyM

isuse/unI have a ha? I don't knThe m

ixes 6/10/2020 18:45

On 3/28/20G

arden & gM

y home M

ultnomaMay 4th, 2020

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isuse/intN/A

As this is pHorse &

co6/10/2020 17:44

June 26, 20Backyard gNotice of hM

ultnomaMay 10 2020

ongoing timTomatoes M

isuse/unn/a

n/an/a

6/10/2020 16:56Evidence o

Garden

3934 NE 16M

ultnoma

15‐May

Ongoing

SunflowersM

isuse/unNot hom

e I donâ€™t U

nknown

5/16/2020 10:37Large scaleG

ardenApex,N

CWake

April 30thMay 16th

Tomato an

Undeterm

iNot com

poNot com

poNot com

po12/30/2019 8:15

Suspected Garden be

Maryville, TBlount

Jun‐19Still occurinG

reen beaUndeterm

iNA

NA

NA

7/2/2019 15:26My husbanHom

e gardRimrock ReKittitas/Ya

ApproximatelyO

ngoingApproxim

aUndeterm

iNA

NA

NA

7/13/2015 12:56Received reG

ardensSouth CaroYork

5/1/2015Plants m

osUndeterm

i100+ tons Horse manhay

7/2/2015 11:32I put som

eGarden

KentuckyMadison

8/1/2014The plants U

ndetermined: (not enough inform

ation wa

5


itted to the USCC

page 6

Date/Time

Submitted

6/10/2020 22:176/10/2020 21:306/10/2020 21:106/10/2020 21:026/10/2020 20:306/10/2020 20:296/10/2020 20:216/10/2020 19:466/10/2020 19:366/10/2020 19:296/10/2020 19:236/10/2020 19:226/10/2020 19:196/10/2020 19:196/10/2020 19:176/10/2020 18:506/10/2020 18:456/10/2020 17:446/10/2020 16:565/16/2020 10:3712/30/2019 8:157/2/2019 15:26

7/13/2015 12:567/2/2015 11:32


Where


post?

How

much did

you get?When did

you get it?


n or property


I give the USCC

permissio


with

the U.S.

EPA

Compost users only

Dean innov2yrds 5‐Apr

No

No

YesNA

Deans Inno2.5y yds4/6/2020

YesYes

YesYes. Labs rDeans Inno2 yds

30‐AprYes

YesYes

PicturesDeanâ€™

s 1.5 cubic y5/5/20202

YesYes

YesNot applicaDeanâ€™

s 2 cubic yar5/4/2020

YesYes

YesTesting do

Dean innov2 cubic yar11‐Apr

YesYes

YesDean's Inn

Split a 3 yaDelivered 3Yes

YesYes

Data from Deans inno4 yards

03/2020‐04No

No

YesN/A

N/A

N/A

N/A

No

No

Yestests confirI ordered s4 units

4/21/2020Yes

YesYes

Dean's, Wh2 yards

April 21 202No

YesYes

N/A

Deanâ€™s 2.5 yards

4/2/2020Yes

YesYes

From M

cG8 yards thaM

archYes

YesYes

YES. EPA teDean Innov3 yards3/17 and 4/Yes

No

YesNa

Dean Innov1 yard4/17/2020

No

No

YesDepartm

enDean Innov8 yardsmultiple da

No

No

YesYes, O

regoDean Innov4 yards

28‐Mar‐20

YesYes

Yesn/a

Dean Innov4 yards ‐ I uApril 26 202No

No

YesODA testedDeanâ€™

s4 yards

2/28/20, 4/YesYes

Yesoster

Triangle la5 cubic yarApril 10 202Yes

YesYes

NA

Out of Ede

1 full scoopMay‐19

YesYes

YesMRM

Land15 yards1‐M

ay‐19Yes

YesYesYes

s given to dLocal farm100 bales olate w

inter YesYes

Yes

6


itted to the USCC

page 7

Date/Time

Submitted


Where


Where

event occurred

County where

event occurred




.



How big is

your com


What

feedstocks w


uring of the com

post?

Which of



1/12/2015 12:58Purchased In a covereArkansas

Washingto

5/1/2014########

We transp

Undeterm

ined: (not enough information w

a

7


itted to the USCC

page 8

Date/Time

Submitted

1/12/2015 12:58


Where


post?

How

much did

you get?When did

you get it?


n or property


I give the USCC

permissio


with

the U.S.

EPA

Compost users only

s given to determine use/m

isuse)Yes

8

compost: nature’s way to grow!...compost: nature’s way to grow! us composting council • po box...

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