All chemicals used on cotton now must be bio-degradable within two weeks of application.

That's great news, do you know whose regulation that is? EPA (FIFRA), USDA...? It would be great to have a link.

This project may be quite a bit simpler than I expected. :-]

This is from a company selling the stuff, but might be worth a read as it verifies what lazygardens said. I'm a skeptic by nature.....

sjerin, did you forget a link?

I posed the question to EPA through their website, I'll post what I get back.

Some of those are used pre-planting...especially paraquat, which is used in small amounts and generally by brush/wick applications (it's not good stuff to come in contact with). Diuron, Fomesafen, and Pendimethalin are other ones generally used pre-planting.

They're not going to be found in boll-formed residues in any concentration worth worrying about.

Also, Valor = Flumioxazin. This is "weird" herbicide in it's mode of action. It's applied shortly before or shortly after germination/emergence of the crop. The crop breaks through the surface of the soil and grows just fine, but after a moisture event (which means application timing is important) it forms a barrier on top of the soil which keeps weed seeds that it's labeled to prevent from emerging. The weed seeds are perfectly viable and if the land is tilled or the barrier is otherwise broken those seeds will begin to grow as normal. It's a neat chemical weed protection.

Oops, yes I did. :)

http://www.backtonaturecompost.com/cbc.html

Tox, you start by talking about pesticides, insect killers, on cotton and then list several herbicides, plant killers. Different things, even though a lot of herbicides on used on "conventional" cotton fields as well.
Since cotton is not an edible crop why would anyone think they must be biodegradable within two weeks of application? There are now systemic insecticides being used on cotton and some research indicates those are throughout the plant, in every part.

Here is a link that might be useful: pesticides used on cotton

nc-crn: excellent info, thanks!

sjerin: Thanks for the link. That's the page for the brand of CBC that I get locally here in central MO. I never thought of looking them up. I see that they say "The USDA and EPA now require that all chemicals used on cotton be biodegradable within a two week period." But they don't give a link so we're still on the hunt for those regs.

kimmsr: I generally use the term pesticides to refer to all herbicides, fungicides and insecticides, which may not be quite correct (or the same as others). In any case the page you linked mentions various problems related to their use on cotton, but unless I missed it there was no list of chemicals in current use. I'm happy to include anything in the evaluation that is actually being used on cotton, so if there is a list somewhere, please post. I am trying to get beyond vague 'it's bad' statements and look at the details.

The Back to Nature CBC website also says:

"In the past, the primary concern with cotton gin waste was arsenic. For years, arsenic acid was used as a defoliant prior to harvesting in most of the U.S. On the High Plains of Texas, early freezes normally eliminate the need for chemical defoliants, and in the rare years where chemical defoliation was needed, sodium chlorate, rather than arsenic, was used. The EPA outlawed arsenic as a defoliant in the early âÂÂ90s and the EPA now requires that all chemicals used on cotton be bio-degradable within two weeks."

I'm not sure what the date is on the paper I posted at the top of the thread but it still lists an arsenic compound. So that might be on the way out if I can verify it.

Have you considered sending an email with your questions to the company? In a reply they will be putting their info in writing, so I would think they wouldn't risk feeding you a line.

Good idea, I'll shoot them an email.

Thanks gardengal, that makes you, me and the EPA at least. :-] I did consult my Funk & Wagnells earlier and it said "specifically, insecticides", but that's out of step with what you're saying. Wouldn't be the first time.

The use of the term pesticide to cover all those 'cides is widespread.

Well this is interesting! Here is my question to EPA:

"What are the current regulations on biodegradability of pesticides used on cotton? I am trying to answer questions about whether pesticide residues may persist in cotton burr compost. Specifically herbicides that may harm garden plants, but it does not have to be limited to that. I've been told that all pesticides used on cotton must be 'biodegradable within 2 weeks.' I have no verifiable references on this supposed regulation. "

Their response:

'The EPA assesses the environmental fate of all EPA-registered pesticides, but we have no biodegradability regulations, policies or recommendations for herbicides on cotton. With regard to plant damage from manure-based compost, the EPA has received reports related to certain herbicides (e.g. aminopyralid, clopyralid, picloram etc) that have been reported in compost, but our database indicates that these incidents have not been associated with cotton use."

So, the EPA has refuted the claim made by Back to Nature on their website. I wrote to BTN at the same time I wrote to EPA and did not receive a response. I will be forwarding EPA's response to them as a courtesy.

I am now forced to doubt their other claim that arsenic based pesticides are no longer used on cotton. I will have to confirm that elsewhere.

Of course this does not tell us anything quantitative about pesticide residues in CBC, just that one vendor appears to be making a specious marketing claim. More to come.

This post was edited by toxcrusadr on Thu, Apr 17, 14 at 17:11

Arsenic based pesticides/herbicides aren't used much by anyone.

You're going to find agricultural use of arsenic in animal feed (especially poultry), but that's on the decline (only very recently on the decline). As far as herbicides, some areas with really bad pigweed + nutsedge use an arsenic based MSMA...but it's not widely used.

I guess there's no really 'safe' compost to be bought, anymore. I do wonder about the cow and chicken compost--what's in them since the farmers seem to feed them all kinds of carp these days? For awhile some 'all-natural' composts had sewage sludge in them; all technically A-ok. We all will just have to grow our own, I guess.

Thanks for posting your answer from the EPA.

I think there may be a few composting places where you can find stuff with a relatively low load of residues. For example food waste composting operations are sprouting up, and depending on what they mix in for other ingredients, they may have manure- and sludge-free product. I think that's the best bet.

In my world safety is a relative term - it's all about the dose. There are toxins all over the place (including the fire resistant additives in the plastic in this keyboard I'm typing on). It's very hard to get away from them completely. So I try to control my exposure by hitting the highest contributors first. Perhaps one day toxic chemical use will be so much lower that you won't have to look so hard for what you're seeking.

Thanks for your input, toxcrusadr. I appreciate it!

Very interesting thread, Tox, thanks.

BTW, the bit about the former use of arsenic acid segues with current concerns about rice now grown on those lands, as rice is an unusually aggressive uptaker of arsenic, apparently. Presumably the arsenic is persistent in the soil.

NC or others have comment about this?

That reminds me, I have not heard anything back from Back to Nature about the wording on their web page.

Thanks for undertaking this project Tox. I look foward to hearing what the EPA has to say,or more specifly what if any meaningful work they are doing in this area. I attempted soliciting them taking action on enforcement of rules they made concurning CFCs and refrigerants in 1990. After 2 years I have seen no action whatsoever. Fact is the extent of what they have done is quote chapter and verse of those sweeping laws and are unable to direct me to the EPA employees who act to end violations. What I found is that EPA has a boat load of people working to inact regulations and few if any going back to see what effect earlier rules are having.

I hear ya...nothing more frustrating than an 'initiative' that ends up on the shelf. Actually though, quite a few of EPA's regulations are carried out by state agencies. Air, water, waste, landfils, etc. It is sometimes more effective to get hold of someone at the state level, or the Regional EPA office for the region.

I did not feel like we got much back from EPA on that question, but if necessary I could track down someone in FIFRA to get more detailed info.

Talked to an expert at this and he said they no longer spray anything on a cotton field that does not degrade within a 2 week span or somewhat earlier.

There it is again, but we still don't know the origin of the 'two weeks rule'. EPA said directly (as posted earlier in the thread) that they have no such regulation related to cotton. So I am still wondering where this 2-week limit is coming from.

I am trusting the farmer to know what to do regarding chemicals. If they say there is no residue, then as for myself I will trust. If you contact EPA as you said, you can get different answers every time you contact them. I look at it like this --- if a person has a problem using a product because they believe it is unsafe then they should certainly not use it.

I agree with you on every point. I was just hoping to find more definitive information to help people make more informed decisions. The issue of getting different answers from regulatory agencies is real. I work for one, as a matter of fact (not EPA) and we're guilty of the same thing. That's why I ended my post with "I'm still wondering where it's coming from" rather than "it doesn't exist." :-D

I still like cotton burr compost myself. The wife just planted some bulbs with it last weekend.

Maybe contact the Department of Agriculture for info.

Good idea, I have not tried that yet.

I wrote USDA's Ask the Experts and will report back on the results. I don't have a lot of hope because EPA is really the pesticide regulatory agency, but we'll see. Maybe there's a cotton expert at USDA who will know where to go for definitive info.

daaaaammmmm, I doubled down this year and have used 20-30 bags of the stuff under the assumption that its safe. one thing I've noticed is in our wet missouri spring, this stuff is got mushrooms growing in it like nobody's business. carpets of mushrooms in it. it only makes me feel slightly better that hopefully the mushrooms are breaking down the compounds. I'm going to spray all of it with Bio Ag effective microbes

On a trip to a cotton growing area in Texas earlier this year, I asked at a processing facility associated with the coop, and they did confirm that all pesticides used on their cotton were biodegradable in two weeks. Even better, they were happy to supply a list, if desired, of all the pesticides used. I didn't get a list (didn't think anyone here would be that interested), but I suspect that contacting a gin which might be producing the product might provide useful info.

What I found even more interesting in the visit was how organic cotton is processed. There is no sweeping and preparation of the equipment as they move from conventional to organic cotton; it is just another batch of cotton coming through, although it is segregated. This is quite a contrast to vegetable preparation where there are pretty rigid segregation standards.

In our area, somewhat removed from the source, the compost is expensive compared to other products because it is sought after for its high quality. Cottonseed meal has also become fairly expensive at times because of demand, but the feed store still sells a lot.

Renais

Oliver: It's not uncommon for mushrooms to grow on fibrous material, usually wood chips, but in any case they are typically not harmful to garden plants. Fungi are very important to the soil food web and, by extension, to plant health.

renais: Too bad you didn't get that list! But thanks for the tip, if anyone wants to chase it down we now have a lead. I have no cotton gins nearby, our small cotton growing region is hundreds of miles away.

Since I keep hearing the rapid decomposition thing and nothing else that refutes it, I'm not too worried about this issue, and I still consider cotton burr a great compost based on experience and test results.

As I mentioned above, I visited a facility processing this material, and was impressed with their work, but did not pick up literature. However, I knew the town where the compost was made, so it wasn't too hard to identify a facility there. They do state "the EPA now requires that all chemicals used on cotton be bio-degradable within two weeks " on their website http://www.backtonaturecompost.com/faq.html.  Note that they do not make any exception for systemics. Having seen some of how they operate, I would be completely comfortable using the product of this facility. Note that they also address concerns about use of this product in organic gardening.

As I noted earlier, cotton burr compost has developed such a good reputation here that it has become somewhat expensive. I'm happy, however, to see the positive impact on the environment that this composting is providing.

Renais

Back to Nature (BTN) was discussed earlier in this thread...they're the company that I asked about where that 'rule' originated and they did not answer the question. I stated earlier I have no actual doubts about their product, I was just not able to get any info on this 'EPA rule' from either BTN or EPA.

Revisiting this with a little more info.

I found this thread:

https://www.helpfulgardener.com/forum/viewtopic.php?t=24358

which mentions a study of pesticide residues in CBC.

A study was done in CA on the affects of composting cotton gin trash on its residual chemicals, as well as its use as a soil amendment. The study showed chemical reductions at 3 intervals up to 51 days of total composting time.

Most commercial cotton gin compost has been composted for a year or more. Tests on commercial CGC show chemical levels below EPA safety levels, and in some cases below levels naturally occurring in the environment. I see that CGC products meet the requirements of the United Status Composting Council, but probably not the OMRI.

Unfortunately no citations were given for those studies, and that user last visited the site in 2011. But there are papers out there in the literature so it would be good if we could find them. I don't have much access to scientific literature at present, at least from my desktop. But I'll see what I can do.

This may be the study from CA referred to above.

https://www.tandfonline.com/doi/abs/10.1080/03601238609372539

Chemical residues during screening, composting, and soil incorporation of cotton gin waste

W. L. Winterlin
Department of Environmental Toxicology , University of California ,
Davis, CA, 95616,

M. M. McChesney Department of Environmental Toxicology ,
University of California , Davis, CA, 95616,

S. R. Scnoen
Department of Environmental Toxicology , University of California ,
Davis, CA, 95616 &

J. N. Seiber
Department of Environmental Toxicology , University of California ,
Davis, CA, 95616

Journal of Env. Science & Health, Nov 2008

Abstract

The behaviour of residues of five chemicals was studied during aerobic and semi‐anaerobic Composting of both whole gin waste and the fines fraction. Propargite, methidathion, and chlorate residues declined significantly during both composting treatments while DEF and paraquat were stable to composting, when composted gin wastes were amended to field soil, residue levels were generally very low to undetectable in the soil, indicating little potential hazard for a composting‐amendment operation.

***

This is the general assumption I usually make: residues may not be zero but with the exception of the known persistent herbicides (picloram and chlorpyrifos, IIRC), pesticides generally break down in the compost to the extent that the residue is either not detectable or low enough to have no observable effects after mixing the compost into soil. This goes for cotton waste or anything else.

Whew! That's a relief. Thanks for doing the research, tox. Now we know that odor is just the natural CBC odor.

I was pretty sure all along as far as the odor goes, just because pesticide residues are going to be in the ppm range and not detectable by anyone other than Superman. Pesticides do have carriers, solvents, emulsifiers, wetting agents, etc., and some of those are smelly, but they evaporate or leach away pretty fast, leaving no trace. By the time the stuff is gin waste, there should be no sign of it to the naked eye or nose. It's what you can't see (or smell) that requires a little more in-depth analysis - literally, in the lab.