impact of urban turf rule
DESCRIPTION
Florida Consumer Fertilizer Task Force West Palm Beach, FLORIDA November 2, 2007. Impact of Urban Turf Rule. Sandy Simon Senior Director, Government Affairs. United Industries Corporation, A Subsidiary of Spectrum Brands. Topics of Discussion. - PowerPoint PPT PresentationTRANSCRIPT
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Impact of Urban Turf Rule
Sandy Simon
Senior Director, Government Affairs
Florida Consumer Fertilizer Task Force
West Palm Beach, FLORIDA
November 2, 2007
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United Industries Corporation, A Subsidiary of Spectrum Brands
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Topics of Discussion
• Nutrient contributions of current turf products
• Products Affected by Rule
• Products Compliant / Non-compliant with Rule
• Required Changes
• Company resources needed to comply with Rule
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Topics of Discussion
• United Industries – number of affected products
• Cost associated with labeling compliance
• Formulation Changes – Fertilizer Input Costs
• Compliance Challenges– State Ordinance vs Inconsistent Local
Ordinances
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Turf Products – Nutrient Contributions
Nitrogen (lb per 1,000 sq ft)
– Rate: 0.5 lb – 1.4 lb
– RAN: Typical = 0.72 – 1.0 lb
– CRN: Typical = 0.3 – 0.5 lb
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Turf Products – Nutrient Contributions
• Phosphate
– 0.09 lb (lawn fertilizer)
– 1.0 lb (starter fertilizer)
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Required Changes – Lawn Products
29-2-5 [ 7.2% CRN (25% of Total N) ] 16 # Bag for 5,000 sq ft
3.2# / 1,000 sq ft Total N / M sq ft = 0.93 lbs
RAN = 0.70 lb and CRN = 0.23 lb
Environmental
Caution Statement
Do not apply near water, storm drains, or drainage ditches, Do no apply if heavy rain is expected. Apply this product only to your lawn, and sweep any product that lands on your driveway, sidewalk or street, back onto your lawn.
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Some Products affected by Rule
P2O5 = 0.16 lb
RAN = 0.5 lb
CRN = 0.62
Total N = 1.12 lb / M
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Products Affected by Rule
Remove “Lawn” from product name, remove lawn directions for use
Amended or New Federal & State Registration for fertilizer / pesticide combination products to add Environmental Caution Statement or change formulation.
Starter not a part of brand name so use as a starter turf fertilizer is prohibited.
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Company Internal Cost UndefinedReview product offering & Identify Affected Products
Change Management – Gate Approval process
Formulation Change & Cost
Customer Notification & Approval
Graphic Design Development / Change
Label Review & Approval Process
New Bags / Prepress / Printing
Inventory Management
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DOACS: 07 - 08 Specialty Fertilizers
• 152 Licensed Companies• 1,453 Registered Brands• ~ 300 Brands labeled for Lawns
– 20.6% of registered brands– § 576.021 Registration and licensing– Register each brand and grade– Does not accurately reflect number of
affected labels
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DOACS: 07 - 08 Specialty Fertilizers
For: United Industries # Labels
• Number of rate compliant labels …. 65
• Lawn Fertilizer……………………... 11
• Garden Fertilizer w/Lawn use…….. 36
• Lawn Fert/Pesticide………………. 18
• Total labels.………………………… 130
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Financial Impact for Label Revision
• Rate Compliant – (Add Environmental Statement)
– ~ $2,500.00 – Graphic design, plate change and label review.
– ~ $162,500 for updating 65 labels
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Financial Impact for Label Revision
• Lawn Fertilizer and Garden Fertilizer with Lawn Uses
– 47 Labels affected
– Reformulation, resize container, graphic design, new plates and new registration
– ~ $15,000 per container ($10K for plates, $2.5K for registration, etc)
– ~ $705,000 to comply with Rule
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Financial Impact for Label Revision
• Lawn Fertilizer / Pesticide Combination Products– Application rate determined by pesticide ai– Reformulate nutrient content & add environmental
statement– Reformulate pesticide ai (new EPA registration)– New registration fee ($4,360) and Amendment fee
($3,280)– New state registrations (National = $12,000 per
product)– (18 labels * $12,000 = $216,000) + (9 brands *
$3,280 = $29,520)– ~ $245,000 for Combination product changes
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Financial Impact for Label Revisions
• $162,500 + $705,000 + $245,000 = $1.11MM
• $8,557 – Average per product label – Based on 130 United Industries labels
• $5,130,000 for the label changes– ~ 300 Products labeled for Lawns - (DOACS Estimate)– Assume 2 sizes for each Registered Brand & Grade (600 bags)– Does not include water soluble garden fertilizers with use directions
for lawns
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Reformulation Impact
• *Urea $350• *Ammonium Sulfate $230• *Diammonium Sulfate $400• *Muriate of Potash $300
• Controlled Release Nitrogen (CRN)– $600 to $1,000 per Ton– Sulfur-Coated Urea, Polymer-Coated Urea, Methylene Urea
• Increase CRN from 15% to 30% = 10% of input cost
*Per Ton - Green Markets October 29, 2007
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Compliance Challenges
• Florida Urban Turf Rule __ State-wide Ordinance
– IFAS supports the Rule as an interim measure– Rates provide minimum N & P requirements for turfgrass
health– Protective of the Environment– Impacts labeling, formulation and registration– Rule enforced through registration and field monitoring– Provides uniformity which is vital to interstate and
intrastate commerce– Allows for routine distribution of products into Florida
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Compliance Challenges
• Multiple Local Ordinances
– Requires an assortment of new product formulas– Cost prohibitive to develop and produce multiple low
volume products– Distribution complex and cost prohibitive– Significant increase in consumer products to cover
additional formulation and distribution costs.
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Consumer EducationRight Product
Right Place
Right Time
Right Rate
+Right Practice and
Right Message
