Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?
First of all, it is important to make clear that the code is a no binding document. The title should be change accordingly to reflect that : replace “International code of conduct” by “Voluntary code of conduct for….”
The code might be useful, provided :
- it is clearly linked with VGSSM ;
- it is clear for users that fertilization need a global agronomic approach, as crops rotation for instance, is a key point : this code should not been seen as the “alpha and omega” used in isolation regarding fertilization
- it gives broad guidance without entering into too precise details as fertilization is much dependent of local context
- it is consistent and relevant for all countries, be they more or less developed.
- it covers the totality of the field concerned, from the production to the use of fertilizers ;
- it takes into due account both sectorial issues and public interests ;
- it gives a sufficient place to farmes as they are the main concerned users of fertilizers
In these conditions, it could be useful to policy makers, fertilizer manufacturers, users, farm advisers, fertilizer stakeholders and consumers of the food produced thanks to their use, and stakeholders affected by impacts of production and use of fertilizers.
Circular economy is increasing as a necessity to supply sustainable fertilizer. The production of fertilizers will become more complex and more diverse, including wastes from variable quality : the protection of farmers, users and consumers requires to take in consideration use of fertilizers, but also their production, to ensure safety of the entire chain from production to safe food production.
Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?
No: Point 1.3 that states: “1.3. The intent of the Fertilizer Code is to assist countries in the establishment of systems for monitoring the production, trade, distribution, quality, management and use of fertilizers to achieve sustainable agriculture and the Sustainable Development Goals (SDGs) by promoting integrated, efficient and effective use of quality fertilizers with the following outcomes: “. However :
1 – While the steps management and use are presents and widely developed, fertilizers production, trade, distribution, quality (including soil health, and food safety) are only delegated to government responsibility, especially circular economy and pollution considerations, even if the 2018 world soil day is “be the Solution for Soil pollution !”. Directives have to be added for producers, without waiting the step of state controls.
Indeed, fertilizers bring nutrients to the plants but may also bring pollutants to the soil and affect environment, production and health of food producers and consumers: the Code must highlight the important step of fertilizer production.
2 - promotion of integrated, efficient and effective use of fertilizers needs to integrate soil consideration but also climate and especially water availability : even with high quality fertilizers and positive soil properties, plant production is conditioned upon water availability. This point is missing in the current proposition and has to be improved.
NB : We propose reformulation to point 1.3 so that it is more consistant with Point 1.2 (see the french proposed amendments to the code at the end of this document)
Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?
Yes, see above and on following boxes + french authorities amendments.
Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?
Regarding the use of nitrification inhibitor , further risk analysis on medium -long term impacts on soil is necessary. Indeed nitrification is a natural process, we don't have enough evidence so far on possible impacts on soil due to its inhibition. Furthermore, impacts on human heath have to be assesed. The same applies for urease inhibitors. Reference to these inhibitors should be cautious .
Parts 3 and 4 have redundancies, about fertilizers management.
It is desirable to produce many significant amendments and additions before to obtain a document suitable to be validated by the COAG (see attached document). A best established document will be more profitable for all the stakeholders and for GSP and ITPS credibility.
Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.
See following (attached, Ed.) document to obtain a document suitable to be validated by the COAG.
France