Global Forum on Food Security and Nutrition (FSN Forum)

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.