It is appalling that, in this day and age, the Commonwealth of Virginia
maintains such little control over the application of poultry litter as
fertilizer.  Poultry litter is overabundant in many areas.  It appears that
the disposal problem gets more attention than safeguarding the health of
humans and wildlife from not only excessive nutrient chemicals but also from
contained toxic and septic contaminants.  Contaminants analyzed should also
include commonly found endocrine disruptor chemicals such as arsenic.  What
should be mandatory are chemical analyses of each batch of litter removed,
limits imposed on constituents applied, and post application analyses of the
soil and surface water and groundwater, where applicable.  Poultry litter
should be prevented from sale to farms bordering streams unless best
management practices, especially buffer zones are implemented.

Cheers,
Bob Luce