Nutrient stewardship and sustainability programs
Online consultation for developing the Code of Conduct for the Management of Fertilizers
The Fertilizer Institute
January 26, 2018
The Fertilizer Institute (TFI) is pleased to provide the Food and Agriculture Organization of the United Nations on the development of the Code of Conduct for the Management of Fertilizers. The members of TFI, and our scientific partners with the International Plant Nutrition Institute (IPNI), are leading the way in development and implementation of new technologies and scientifically-based management for agricultural cropping systems to better meet social, environmental, and economic goals.
Statement of Interest
The Fertilizer Institute represents the United States fertilizer industry including producers, importers, retailers, wholesalers and companies that provide services to the fertilizer industry. TFI members provide nutrients that nourish the nation’s crops, helping to ensure a stable and reliable food, fuel, and fiber supply. Whether from organic or commercial sources, fertilizer nutrients are a key component of sustainable crop production systems. Fertilizer is a key ingredient in feeding a growing global population, which is expected to surpass 9.7 billion people by 2050. Half of all food grown around the world today, for both people and animals, is made possible through the use of fertilizer. As demand continues to grow, farmers around the world will continue to rely on fertilizer to increase production efficiency, producing more food while optimizing inputs.
Background
The 4R framework and supporting practices are integral components for enhancing water and air quality, food supply chain sustainability, crop productivity and soil health. 4R Nutrient Stewardship is a science-based framework to aid implementation of fertilizer best management practices on the farm. Properly managed fertilizers support cropping systems that provide economic, social and environmental benefits. On the other hand, poorly managed nutrient applications can decrease profitability and increase nutrient losses, potentially degrading water and air.
4R nutrient stewardship requires the implementation of best management practices (BMPs) that optimize the efficiency of fertilizer use. The goal of fertilizer BMPs is to match nutrient supply with crop requirements and to minimize nutrient losses from fields. Selection of BMPs varies by location, and those chosen for a given farm are dependent on local soil and climatic conditions, crop, management conditions and other site-specific factors.
General Comments
For clarification is the second document to address situations where fertilizer use is insufficient rather than using low to no fertilizer? Scenarios of crop production with low to no fertilizer use would lead to a decrease in global food production, resulting in an increase in food insecurity, malnutrition, and hunger. The focus of this effort should be placed on sustainable fertilizer use in a whole system approach, rather than split focus on over and under or no fertilizer use.
Given the global scope of the CoCoFe, do you think the objectives are appropriate? If not, how would you add to them or modify them?
Objectives need to focus in on what sustainable agriculture is, such as utilizing existing agricultural lands by intensifying production to maintain and increase crop yields. The first objective should include a statement on land use. To minimize environmental impacts of fertilizer, 4R Nutrient Stewardship needs to be a part of the discussion for any potential solution. The 4R Nutrient Stewardship framework should be front and center in the objectives as it is an internationally recognized framework for sustainable fertilizer use and includes science-based practices that are site specific. Additionally, the last objective needs to include nutrition. Without fertilizers, nutrition of crops would be less. Micronutrients are vital to improving human health around the world.
Suggested revised objectives:
1. increasing global food production on current agricultural land; (need to include land use – increasing production can be done by increasing land area, this is contrary to sustainable ag principles).
2. optimize the efficient use of plant nutrients;
3. minimizing the environmental impacts from the use of fertilizers including pollution by loss of nutrients via runoff, leaching, greenhouse gas emissions and other mechanisms;
4. minimizing environmental and human health impacts from pollutants such as heavy metals in fertilizers;
5. maintaining and improving food nutrition and safety.
How should the CoCoFe be structured to have the maximum positive impact?
Recommendations from a science team/network with top nutrient management specialists representing many geographical cropping regions should be provided to a governing council of policy officials from FAO.
Inclusion of the science based principles of 4R Nutrient Stewardship that are applicable to all systems, regardless of farm size, level of technology, or type of crop produced should be included. Additionally, because of work with IPNI and other fertilizer organizations, the 4R principles are already globally recognized. Considering the right source, at the right rate, at the right time and in the right place is designed to be implemented by taking into account the site-specific conditions of each field or farm. This meets the design plant that the CoCoFe will provide broad recommendations on what should be considered when designing strategies to manage fertilizers sustainably.
Who would be the best audience for the CoCoFe to meet our objectives and how could we broaden and diversify this audience to increase its influence?
The primary audience for the CoCoFe should be the agencies in individual countries that are responsible for agricultural policy. Increased influence and impact of the CoCoFe could be achieved by also addressing agricultural education, extension, research, retail entities, and crop consultant groups in each country as well as the agencies or groups in each country that are responsible for funding agricultural education, extension, and research.
What should the scope of the CoCoFe be? Which nutrient input sources should be included; only synthetic fertilizers, or also manure, biosolids, compost, etc.? Should other products such as bio-stimulants, nitrification inhibitors, urease inhibitors, etc., be included as well?
All nutrient sources that provide plant nutrition should be included in addition to advanced fertilizer formulations that help to better match nutrient availability to plant uptake. Including these products will help encourage innovation and advancements in the nutrient use efficiency of fertilizers. Inclusion of all nutrient sources and products should be based on the scientific data available on their use and efficiency.
Will the CoCoFe assist in promoting responsible and judicious use of fertilizers? Why or why not? What other suggestions do you have to help the CoCoFe meet our objectives?
The success of the CoCoFe in promoting responsible and judicious use of fertilizer is dependent on engaging governments, agricultural scientists, agricultural educators, NGOs involved in sustainability and the global fertilizer industry. The CoCoFe should be based on a rigorous science-based
framework like the 4R nutrient Stewardship, and framed through discussion with regional
stakeholders with their multiple objectives in mind for the necessary buy-in and
implementation.
Dr. Sally Flis
The Fertilizer Institute (TFI) is pleased to provide comments to the Food and Agriculture Organization of the United Nations on the Zero Draft of the Code of Conduct for the Management of Fertilizers. The members of TFI are leading the way in development and implementation of new technologies and scientifically-based management for agricultural cropping systems to better meet social, environmental, and economic goals.
General Comments
While we applaud FAO for its ambition, we believe that the proposed timeline has not provided for sufficient consultation with sectors identified as key stakeholder entities within the document. The expediency of development will not result in a document which provides meaningful guidance and recommendations.
The ‘Zero Draft of the International Code of Conduct for the Use and Management of Fertilizers’ is a broad summary of tactics for sustainable use of fertilizers with the intention of allowing individual countries or stakeholders to be sure the code is appropriate for their situation. However, within the document there is a need to be more concise language and elimination of repetition of actions assigned to respective stakeholder groups. Additionally, the definition of the identified stakeholder groups changes throughout the document, making it a challenge for readers and users to interpret.
We are encouraged to see the fertilizer industry identified as an important stakeholder with roles and actions to support effective fertilizer use and management. And, we are equally pleased with the inclusion of the principles of 4R Nutrient Stewardship. In many geographic locations, the industry is a trusted advisor to farmers in the field, and the industry should be viewed as a resource for country efforts to optimize fertilizer use. Additionally, there is growing science and broad support for basing fertilizer use decision on 4R Nutrient Stewardship. Inclusion of the 4R principles can serve as an incubator for broader resource allocation and implementation efforts.
However, while we applaud these inclusions, we believe the document would benefit from greater consultation and time for engagement with the stakeholders identified as key to successful fertilizer management. Throughout the document, there are specific tasks assigned to the fertilizer industry, not all of them may be feasible to implement and several could be improved with industry insight.
While not a complete collection of areas of concern within the fertilizer industry allocated sections, below are examples pointing to the need for great consultation and engagement.
4.11.3. Keep records of fertilizer sales and/or fertilizer applications along with other agronomic practices, data and farm records to support governments for the purpose of statistical information on fertilizer use.
While there is need to expand and improve record keeping, the challenges of data security will limit the amount of data and farm records that can and will be shared to governments for statistical information. Further consultation with the fertilizer and ag retail industry would be beneficial to clarify this tactic.
Further, some good instruments within governance, initiatives, programs and regulations already exist in relation to fertilizer value chain (production, transport, QC, labelling, trading etc.) For lack of time, these have not been considered enough and deserve to be closer looked at. Concerns with what the fertilizer industry should do around these items occur in multiple sections of the document.
In Section 7. ‘Access, Distribution and Labelling’ there are multiple items that do not recognize the structure of departments and responsibilities within the fertilizer industry. For example:
7.2.1. Ensure that persons involved in the sale of fertilizers along the fertilizer value chain are trained adequately to be capable of providing relevant information to the related actors in the supply chain, such safety information, advice on risk reduction, and information on the responsible and efficient use of the fertilizer products.
7.2.2. Ensure that persons involved in the sale of fertilizers to users are trained adequately and are capable of providing sound advice on the use of the fertilizer products they are selling, and on the environmental and health risks associated with the misuse of fertilizers.
These items would be handled by multiple professionals within a company and should be addressed as such.
In summary, substantial improvements are still required to make the current draft relevant and ready for adoption. The current timeline has not allowed for proper research and consideration of existing systems and programs. Given the critical role of fertilizers, TFI would strongly recommend giving appropriate time and consultation to the development of such a significant document: it is ultimately the extend of its content that will decide if this code is truly relevant for nutrient stewardship or if it will be dismissed as superficial and too general.