المنتدى العالمي المعني بالأمن الغذائي والتغذية

In terms of a global guideline for nutrient management, it seesm that the comments below seem to vary from a code that will provide guidance to farmers or as a broader policy framework for governance. The former would seem adequately covered in the 4R nutrient stewardship principles which have wide acceptance in industry and with growers. These principles have been applied in a wide range of situations and cover the important aspects of nutrient management for a sustainable future. As such they should be strongly referenced and applied by advisors and growers - it is the principle of management espoused by 4R and supported by science that is critical not the detail for particular situations that seems to cloud the direction of this code.

It would be disappointing scientifically as well as challenging soil health, food security and the environment if some of the opinions in the comments section became embedded in an important code. Fertilizers feed half of the global population and directly address soil health through replacing nutrient that are moved along the food chain. This is such a complex and significant issue that simple or simplistic solutions will not address the challeneges we face. Because the problem is multi-dimensional, the solutions will also be manifold and will have particular applications in particular situations - but I propose that these would fit well into the 4R framework meaning effective communication to stakeholders.

The document provided seems to have a lot of repetition in it which may, or may not be useful in the way it is interpreted. There also seems to be a need for a much wider stakeholder consultation than one month and the 50 contributions noted below.

Yes, the Code of Conduct for the Use of Management of Fertilizers is beneficial and useful very much. It would be more benefial to the fermers because of fixation of price as well as the clear understanding of availability of fertilizers in different point of time.   I feel the subsidy factors could have been highlighted in different way. 

Dear Colleagues,

on behalf of the European Commission please find enclosed the consolidated comments from concerned Europen Commissions's services.

We look forward to the next steps towards a rapid adoption of this very important Code of Conduct,

best regards,

Luca Montanarella

General Comments on the CoCoFe Zero Draft

The document continues to be overly negative.

Much of the document focuses on over application of fertilizers. We believe the benefits of fertilizers do not receive enough attention. A rebalancing of the document is needed – as we all know, needs and challenges vary by region.

Why rush the process?

With no deadline other than that which is self-imposed, we believe it better to stop and take a more considered approach. The stigma created by the rush means the document will not be universally received and is destined to become a political piece that invites friction. Consider a new approach that allows time for more consensus. Differences can be resolved, but the process of moving from division to consensus takes time. Forcing through the document will create unnecessary friction that could persist for many years.

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

• On the title of the document, “International Code of Conduct for the Use and Management of Fertilizers” what does “Management” really mean? Management of fertilizer at what level of the value chain? If at the supply chain user levels, then the proper word is “handling” not management. If so, then management should be replaced with “handling” throughout the document.
• If management is the proper word for the title, then it implies a broader and more complex process along the value chain, which includes production and value addition (see the definition of fertilizer management in the document). The document does not address production to a large extent and instead just mentions it as rhetoric. However, the document emphasizes fertilizer use; therefore, perhaps “handling” is more appropriate than “management”.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

• The Zero Draft reflects little to none of the comments made by many contributors who provided useful responses on how to address the CoCoFe and its content. The efforts to give sound feedback seem to be fulfilling a formality.
• Regarding the CoCoFe goals of “minimizing” environmental impact and “minimizing” the negative effect of contaminant toxicity in the soil (i.e., heavy metals), the use of the word “minimizing” is a misnomer. By addressing the proper handling and use of fertilizer down the supply chain (especially at the farm level), this only reduces the negative effect of contaminant toxicity in the soil. To actually minimize, the CoCoFe would need to address the production process of fertilizer, which is the source of contaminants. Therefore, “minimizing” should be replaced with “reducing” throughout the text and when applicable.
• The introduction says the goal of the document is to maximize benefits and reduce environmental impacts. This is hardly the case. The content of the document is not balanced and focuses much more on reducing pollution rather than maximizing benefits.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

• The document addresses fertilizer overuse while downplaying underuse. For example: The CoCoFe was developed “to respond to the UNEA3 declaration on soil pollution” which implies overuse, unless soil pollution also includes degradation. Perhaps “degradation” should be defined as well? As it stands, the document may contribute to the negative view of fertilizer by focusing mostly on overuse. Underuse can also have negative environmental impact, not only through soil degradation, but also by reducing biodiversity of flora and fauna.
• Section 1.3 “monitoring the production” ­– If that is the intent, much more elaboration is needed to address the production and beneficiation process of fertilizer. This section currently does not do enough to address production and beneficiation issues, especially in the context of reducing contaminants and then minimizing their effects on humans, animals, and the environment by also addressing the handling and use of fertilizer.
• Fertilizer Misuse (p. 10) – This definition needs to be expand or reformulated. It addresses only the overuse of fertilizer and neglects the underuse, which is also a problem in many developing countries.
• Economic analysis is being shorted. It’s rarely mentioned, and yet the cost will determine what is approved. Recommendations should be driven through a cost and benefit analysis for evidence-based policy or regulatory recommendations and before they are approved. Some recommendations are not realistic and should be removed.
• Inorganic fertilizer and organic materials should be clearly defined and differentiated. Although both can be used as nutrients sources, one (inorganic sources) is standardized and the other (organic) is not since its nutrient content depends on the source of the materials. This becomes a problem when making nutrient use recommendations according to soil conditions and crops, especially in the context of ISFM. 

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

• There is a lot of repetition of text, which is more noticeable in policy recommendations under the different sections of the document. We recommend consolidating these or focusing the recommendations according to the appropriate section.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

• Sufficient time must be given to socialize the document among stakeholders, especially those the document is targeted to (players up and down the supply chain and farmers as end users). Otherwise the document will be perceived as an effort from an international bureaucratic group that is disconnected from the reality of the [smallholder] farming industry and countries’ political and socio-economic conditions, ending in a fruitless and futile effort. By getting feedback from stakeholders who will be affected by this document, it will truly be balanced.
• The document contributes to the skepticism of fertilizer use when fertilizer is labeled as a chemical product. The use of the word “chemical” feeds into the argument of those who are opposed to the use of fertilizer since it makes it comparable to actual agro-chemicals (pesticides, herbicides, fungicides, etc.). Recognizing that some fertilizer suffers chemical transformation, fertilizer should be labeled as mineral or inorganic rather than chemical.
• Continuing the above point, the Code of Conduct on the Distribution and Use of Pesticides can be used as a model, but agro-chemicals are not fertilizers and vice versa. They should not be treated as such. This includes recommendations on Labeling with stating the expiration date, etc. There is no precedent to treat containers as having held toxic chemicals, like pesticides, so Section 7.3.3 can be eliminated.
• Goals and Objectives are difficult to differentiate. The differences between Goals and Objectives should be better defined.
• Section 2 – Most of these terms and definitions exist and they are standardized. We should use the standardized terms and make reference to relevant sources.
• Section 3.5 – Are these policy recommendations? It should be stated what they are, and they should be based on evidence before being adopted.
• Section 4.10 – National universities and groups like IFDC can develop new fertilizers, in many cases, in collaborations with the private industry. New products should not be limited to the private industry.
• Section 4.10.3 – Protection from low-level chronic exposure? Is there evidence this is a problem to humans?
• Section 5 – There is a disproportionate focus on recycling. There seems to be poor understanding of all the work on biosolids conducted over the years. Much of what is called for here has already been done. We’re all in favor of recycling, but so little is done currently for very solid reasons. If the document focuses so much on recycling, then more experts need to weigh in and their feedback taken into account. There is no need to reinvent the wheel. Section 5.5.3 is a naïve statement.
• Section 7.1.6.4 – The government should not require all hazards to be listed.
• Section 7.2.6.5 – Businesses should offer incentives just as governments can (Section 4.7.2). While it’s observable that incentives have done harm, there are occasional reasons for doing so, such as when we first teach farmers that fertilizers can and do increase yields.

It was not clear why there is too much emphasize on overuse of fertilizers, but little attention has been paid to adverse consequences of poor nutrition of crop plants with mineral fertilizers. The imbalance between low and overuse of fertilizers should be avoided. Below a few examples are given about the adverse consequences associated with inadequate mineral nutrition of crop plants.

An adequate mineral nutrition is required for better tolerance (resistance) of crop plants to pathogen and pest attack: Crop plants are facing diverse of threats if the mineral fertilizers are applied at low doses. Besides well-known decreases in productivity, a poor mineral nutrition increases high risk of pathogenic infection and pest pressure (see Lawrence et al., 2007 in Mineral Nutrition and Diseases, American Phytopathological Society; Dordas, 2008; Agron. Sustain. Dev. 28: 33–46). A suboptimal application of fertilizers raises a high risk for the use of pesticides and fungicides. There are many published scientific evidence demonstrating why a poor mineral nutrition makes the crop plants highly susceptible to pest and pathogenic attack (see Marschner, 2012; Relationship between Nutrition, Plant Diseases and Pests. In Marschner’s Mineral Nutrition of Higher Plants, Elsevier).

Fighting human malnutrition with better plant nutrition: An optimal mineral fertilization of plants is also required to produce more nutritious food for human populations, especially with micronutrients and protein. In recent years, a biofortification concept has emerged and developed as a novel strategy to improve nutritional value of staple food crops in order to combat hidden hunger (i.e., micronutrient deficiency) problem, especially in children and women living in developing world (Cakmak et al., 2010, Cereal Chem. 87:10-20; Bouis and Saltzman, 2017, Global Food Security, 12: 49-58). Hidden hunger refers to deficiencies of micronutrients including zinc, iron, selenium and iodine that affects about 2 billion people worldwide and causes serious health complications such as impairments in immune system, mental functions, and physical development. Agronomic biofortification, involving application of micronutrient-containing fertilizers, has been shown to be highly impactful and cost effective strategy for improving nutritional value of staple food crops with micronutrients and contributing to human nutrition (Valenca et al., 2017, Global Food Security, 12:8-114; Cakmak and Kutman, 2018, Eur. J. Soil Sci. 69: 172-180; Olum et al., 2018, Nutrients 10: 4/407, DOI: 10.3390/nu10040407 and www.harvestzinc.org).

Hidden hunger problem has also adverse impacts on economic development and causes losses up to 5 % of gross domestic product in a given country having high incidence of micronutrient deficiencies (Stein, 2007, Food Nutrition Bull. 28: 125-134; Harding et al., 2018, Public Health Nutr. 21: 785-795).

The points raised above suggest that this Fertilizer Code of Conduct should emphasize the adverse consequences of low use of mineral fertilizers, at least regarding the increase in susceptibility of crop plants to pathogen and pest attack (otherwise it may lead farmers to apply more pesticides and fungicides). The zero draft document should also highlight the well-known potential and positive impacts of fertilizer strategy (agronomic biofortification) to reduce hidden hunger problem in children.

Science is missed in the document: Surprisingly, many sections of this “FAO report” are superficial and provide too much generic statements. I strongly suggest to avoid those generic formulations and statements. The document should be based on published, peer-reviewed scientific data/evidence (with a proper citation). I believe, this document can benefit significantly from a scientific panel consisting of experienced and well-recognized scientists and stakeholders in the field. Source of information given in the (revised) Code of Conduct should be provided by paying attention to authority, accuracy and currency of the corresponding information.

“The dose makes the poison”: As indicated above, the document focused mainly on overuse-related problems and concerns, and highlighted “responsible use” of fertilizers. These terminologies need a clarification and discussion to avoid misconceptions about mineral fertilization of crop plants. Science-based definitions and discussions are required. When this issue is discussed, it is important to remember the well-known fundamental statement on poisons made about 500 years ago by Paracelsus (the father of toxicology): The dose makes the poison. It is obvious: too much of anything is toxic. This FAO document should therefore give priority to optimal (or proper) use of fertilizers, while discussing the adverse consequences of both low use and overuse of fertilizers. Increasing awareness of the importance of the optimal use of fertilizers would be a useful and important message of this document.

Listen to plants: There is too much emphasize on soil test, soil maps and other geospatial methods for efficient and effective use of fertilizers and identification of suitable fertilizer formulations. These are fine and correct; but almost no attention is paid to leaf tissue analyses for effective use of fertilizers. Soil and leaf tests need to be combined for development proper fertilizer application rates. There are many situations where soil analysis results for mineral nutrients does not correlate with mineral nutritional status of plants or leaf tissue concentrations of the nutrients. In most cases, agricultural soils have many physical and chemical problems which restrict the nutrient acquisition capacity of roots, leading to poor correlation between leaf and soil analysis results. This document should also highlight importance of leaf tissue analysis (besides soil tests) in better and reliable fertilizer recommendations.

Dear colleagues,

Find attached my contributions. The 3 main critics would be: 1- I have noticed there is no mention or recognition of use of fertilizers for nutrient build up at soil level, many regions in the world and specially in Argentina the shortage of use of mostly P fertilizers has depleted P levels at soils at very dramatic low levels, so the good practice there would be a fertility plan that would allow the soil to replenish that. 2- Also there is no mention of fertilizer/nutrient application at seed, which is in fact a growing practice. 3- No to consider Fertilizer blending: For physical blends such as Urea+MAP or others, parameters might be considered in order to guarantee a good fertilizer performance, such as appropriate fertilizer average size, dust and humidity content. Otherwise the blend might segregate at farm and excess and/or lack of certain nutrient will occur. This is not mentioned in the document and in Argentina for example does not work good. 

Best

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

Yes, the International Code of Conduct for the Use and Management of Fertilizers is beneficial and useful for governments and fertilizer industry, especially for end users (farmers). The Code make many end users (farmers) know how to properly use fertilizers and potential nutrient sources of reused or recycled.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

I think the code address almost all aspects to ensure the responsible use of fertilizers.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

No.

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

All items or subjects within this Code are necessary.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

I suggest that "Biofertilizer" in terms and definitions should include some other functions such as potassium releasing.

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

Yes, the International Code of Conduct is very beneficial and useful for governments, fertilizer industry, agricultural extension and advisory services, actors in the nutrient recycling industry, and end-users. Because guidelines and recommendations are provided in the Code, which makes the stakeholders know what to do and how to do.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

I think the Fertilizer Code is a comprehensive code of use and management of fertilizers, and has already addressed all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

Safety should be paid more attention to because fertilizers and pesticides are often used together in order to being operated easily，which should be mentioned in the Code.

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

There are no redundant or unnecessary items or subjects in the Code.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

I have no any other suggestions or comments by now.

As a lead of GSP P1 in Morocco and after consultation with different stakeholders concerned by CoCoFe, We are pleased to share with you our comments and remarks on this zero draft.

In fact,  this code of Conduct for the Use and Management of Fertilizers is a timely initiative and it will help to ansewrs many questions related to the best use of Fertilzers to increase the food security over the world. Nevertheless, the overall document still has some indirect references to pesticides when we all know that pesticides and fertilizers have very different usages. Also, it would be very useful if the Cocofe could include a bibliography section at the end of the Code as well as footnotes to refer to the studies on which they base their recommendations.

Please find more comments on this draft in the attach file.

All the best

Dr Rachid Moussadek

Vice Chair of GSP NENA

INRA-Morocco

As a participant in the open-ended workgroup, I appreciate this additional opportunity to comment, on behalf of the International Plant Nutrition Institute, on this zero draft Code.

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

A Code agreed upon by all major stakeholders in agriculture would be very much beneficial and useful. It would be useful to the fertilizer industry as a guide to areas of improvement. It would be useful to governments as a means of establishing clear guidelines for international trade in sustainably produced agricultural products and commodities. It would be useful to consumers in assuring clear messaging regarding the safety and quality of agricultural products and the sustainability of the systems with which they are produced. It would be useful to agricultural industry to help them identify evidence-based approaches to sustainable crop nutrition practices.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

The zero draft of the Code is comprehensive in covering necessary aspects, but is far too long and full of redundancies to make it useful to the stakeholders involved in responsible use.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

The current version of the Code, to its credit, addresses the many stakeholders involved in the use and management of fertilizers, and its impacts, both positive and negative. What is missing is a sense of the crucial importance of fertilizers to humanity. Fully half of human nutritional needs depend on nitrogen fertilizer (Erisman et al., 2008). Fertilizer use supports the huge increase in global agricultural productivity that has avoided the large-scale clearing of land that would have resulted in far greater impacts on the environment in general and greenhouse gas emissions in particular (Burney et al., 2010). Fertilizer nitrogen used at rates economically optimal for farmer profit also contributes to the maintenance and improvement of soil organic matter, a key component of soil health (Poffenbarger et al., 2017). Efforts to improve responsible fertilizer management with farmers and food supply chains can successfully improve sustainability (Cui et al., 2018; Thomson et al., 2017).  A greater sense of the urgency of responsible management would be appropriate, given its integral role in meeting many of the relevant Sustainability Development Goals.

Also, the preamble should recognize the contributions of fertilizer to agricultural production of fiber and fuel in addition to that of food.

Burney et al. 2010. Greenhouse gas mitigation by agricultural intensification. Proc. Nat. Acad. Science. www.pnas.org/cgi/doi/10.1073/pnas.0914216107

Cui et al. 2018. Pursuing sustainable productivity with millions of smallholder farmers. Nature doi:10.1038/nature25785

Erisman et al., 2008. How a century of ammonia synthesis changed the world. Nature Geoscience 1:636-639.

Poffenbarger et al. 2017. Maximum soil organic carbon storage in Midwest U.S. cropping systems when crops are optimally nitrogen-fertilized. PLoS ONE 12(3): e0172293. doi:10.1371/journal.pone.0172293

Thomson et al. 2017. Science in the Supply Chain: Collaboration Opportunities for Advancing Sustainable Agriculture in the United States. Agric. Environ. Lett. 2:170015 doi:10.2134/ael2017.05.0015

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

1. In many instances, responsibilities for different stakeholders are spelled out in similar but unnecessarily different language. For instance, it is unclear why the fertilizer industry is called on in 3.7.2 to “Promote the application of fertilizers at the proper time and amount, as well as use of the most appropriate fertilizer source and placement in accordance with global principles of plant nutrient management such as ISFM and 4R Nutrient Stewardship” while governments, research institutes, and universities are referred only to ISFM for global principles in all of section 3.6.  Should the same principles not apply to all stakeholders involved in supporting responsible use? 

2. The structure and length of the document make it difficult for the user to identify the applicable principles. There are separate sections on topics of fertilizer use, nutrient reuse and recycling, compositions, access and labelling, extension and outreach, and monitoring, but often within each of these sections, each of these same topics are again addressed in separate points. This results in a high level of redundancy. There is considerable opportunity to reduce the length of the document, which would improve its accessibility and clarity to users.

3. Another example of redundancy can be seen in points 1.3.1 to 1.3.7.  There is considerable redundancy among these seven points. Unifying them into a smaller number of more discrete points prevents future abuse of the Code in the way of those who seek to emphasize one of these points over and above the others.

4. There appears to be a preamble to the “preamble and introduction.” It currently introduces considerable confusion where it states “This document is an International Code of Conduct for the Use and Management of Fertilizers. It has been prepared to support and implement the Voluntary Guidelines on Sustainable Soil Management…” The scope of soil management differs from that of fertilizer management or nutrient management.  The whole of the text on the first page could be eliminated without any loss to the document.

Redundancies impose severe limitations on the usability and applicability of the Code. Addressing the issues identified, and reviewing all sections of the document for further redundancies, would likely require much more time than has been allocated. I suggest the process be revised to include a thoughtful rewrite to address redundancies and produce a more concise document that could then be subject to a broader and deeper stakeholder consultation process. The target length of the more concise stakeholder consultation document should be ten pages or less, as compared to the current 40 pages.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

1. This document is beyond too long.
2. A glossary of terms has been attempted, but falls short of completeness and there evidently has been no scientific consensus on developing the terms. There could be quite a bit of debate around each term as it is currently defined. For example, the definition of soil health, referenced to FAO, differs substantially from that of the US Department of Agriculture.
3. The code itself is a mixture of "shoulds" and explanations, but explanations are in the same bullet level as the "shoulds," making it unclear what constitutes the code and what constitutes explanations.
4. Points are spelled out in varying levels of detail. For example, point 3.5.3 makes very specific statements about soil and plant analysis, and could much more appropriately be shortened down to “Ensure support for evidence-based assessment of soil capacity to supply nutrients, and plant nutritional status.” The code should not direct all countries to use the same approach. There are many ways to assess soil fertility and plant nutrition, but the science needs support.
5. If general principles can be identified, they will cut across government, fertilizer industry, retailer, salesperson, farmer, and consumer boundaries.