Bloomberg BNA Quotes Dale Mullen on RCRA Regulating Agricultural Fertilizer

March 2, 2015

Dale Mullen, as quoted by Bloomberg BNA, says Congress never intended for organic fertilizer returned to the soil to be regulated under the solid waste provisions of the Resource Conservation and Recovery Act (RCRA). A Feb. 26 BNA article titled “Dairy Manure Case Opens Door to Broader Interpretations of RCRA, Panelists Say” describes how a recent federal court ruling allowed exactly that. Mullen notes that this is the first time RCRA has ever been used in an enforcement action against an otherwise compliant farm applying manure as fertilizer, and he says this kind of application may extend even beyond the agricultural community. Subscribers can read the full text of the article at

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