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(2) Would not the association do well to set a limit, or at least to suggest a limit, for 

 each of the important plant-food elements, below which a guaranteed constituent 

 would be considered as "materially" low? C. A. MOOERS, Tennessee Station. 



I have no suggestion or criticism to make with regard to the "tentative definitions 

 of fertilizers and of misbranding and adulteration." They cover the ground fully to 

 my mind. It is impossible to so frame definitions that there will not be a chance for 

 difference of opinion as to what constitutes "misleading statement, or design, or 

 device," and the best a law can do, it seems to me, is to lay down the general principles 

 and leave it to the judgment of the individual officer in charge of the inspection work 

 to decide whether the law in special cases has been Violated as to misbranding. The 

 recommendation of the committee as to work in the future would seem to be along the 

 lines that give most promise of carrying the matter to a successful issue. F. W. WOLL, 

 Wisconsin Station. 



Owing to the brief time in which to mak3 a reply, I have only a few suggestions to 

 make. 



Definition 1 is more comprehensive than in most of the state fertilizer acts, and is 

 evidently framed to include not only all materials sold as fertilizer, but, as well, air 

 amendments. I confess I have considerable doubts about the wisdom of legislation 

 so comprehensive at this time lest it too greatly encumber purely domestic exchanges. 

 My present inclination is to prefer rather a law that takes into account only what are 

 commonly recognized as commercial fertilizers. 



I realize that there is considerable interstate traffic in certain lime products, as 

 amendments, and that there is a possibility that abuse may spring up in this trade, but 

 could it not be reached specifically rather than indirectly by including all amend- 

 ments. The definition proposed is so broad that a carload of sand becomes a fertilizer 

 if the sand is to be applied to affect the condition of the soil. The same is true of a 

 carload of coal ashes applied for purely physical effects. 



I do not believe it is a wise principle to enact police legislation far beyond present 

 needs. 



In making the above statements, I realize that the definitions for adulteration and 

 misbranding which follow definition 1 are such that the objections I have offered to 

 the definition for the word "fertilizer" may seem to be unnecessary-, but I take it 

 that if these definitions are adopted it will be for the purpose of advocating their 

 incorporation in future state and national legislation, and that, in such setting, they 

 will be accompanied by other clauses specifying the fertilizer materials that must be 

 matters of guaranty. As soon as such clauses are introduced, the embarrassments I 

 have in mind are likely to appear. 



I desire to add that, in my judgment, the association, which is not specifically an 

 organization charged with the execution of fertilizer acts, should not undertake the 

 formulation and recommendation of a national fertilizer law, at least, until a full and 

 formal conference shall have been had with the fertilizer control executive officials 

 of the several States. WM. FREAR, Pennsylvania Station. 



* I certainly think this law would be an advantage, especially to the manu- 

 facturers, as there would be uniformity in all of the States. As the case is now many 

 of the fertilizer manufacturers are required to get out separate printed matter for 

 many of the States. However, I do not believe the control of sale of fertilizers should 

 go outside of the State in which sold, as I believe it can be looked after much better by 

 men who are in close proximity to the places where fertilizers are handled. * * * 

 T. L. CALVERT, Ohio Department of Agriculture. 



On most of the recommendations I am heartily in accord with the views of the com- 

 mittee. In section 1, which defines a fertilizer and fertilizer material, it seems to me 

 that some specific exemptions should be made. For instance, there are on sale in 

 this State for the purpose of soil improvement prepared lime, limestone, land plaster, 

 and marl, and hence our law expressly exempts barnyard manure, lime, wood ashes, 

 and plaster when sold under their respective names. From the definition prepared 

 by the committee there would no doubt arise the question as to whether such materials 

 should not properly be included under a fertilizer law based on this definition. This 

 point may not be well taken. I merely offer it for your consideration. 



In a under 2 the question would naturally arise as to what is meant by "materially 

 under the guaranty," and the interpretation of this term would be left solely to the 

 judgment of the official in charge of fertilizer control. If it is possible to do so, I 

 believe some definite statement as to what should be considered a material deficiency 

 in any ingredient should be made, such a statement being based on the guaranteed 

 content. That is, if the fertilizer was guaranteed to contain a certain percentage of 

 ammonia, available phosphoric acid, and potash, a deficiency exceeding a certain per 



