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博士 Scott Angle

成员起始时间
组织: IFDC
国家: 美国
专业领域：
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I am president and CEO of IFCD. Since 1974, IFDC has focused on increasing and sustaining food security and agricultural productivity in over 100 developing countries through the development and transfer of effective and environmentally sound crop nutrient technology and agribusiness expertise. The organization’s collaborative partnerships combine cutting-edge research and development with on-site training and education. IFDC has contributed to the development of institutional capacity building in 150 countries through more than 700 formal training programs, primarily as part of IFDC’s long-term agricultural development projects. Demonstration plots, farmer field schools and in-field trainings have assisted millions of farmers in developing countries. IFDC is a public international organization, governed by an international board of directors with representation from developed and developing countries. The nonprofit Center is supported by various bilateral and multilateral aid agencies, private foundations and national governments.

该成员提交的意见和建议涉及：

    • 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.

      Dr. J. Scott Angle

      President and CEO of the International Fertilizer Development Center (IFDC)

       

      Please respond to the questions leaving your comments below:

      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.

       

       

       

      See the attachments:

    • For more than 40 years, the International Fertilizer Development Center (IFDC) has been a source of information on fertilizer, soil fertility, and plant nutrition, and a source of support and technical assistance to the agriculture sector and the fertilizer industry. IFDC is a leading center for the research and development of new fertilizer products and for promoting their rational use by means of agro-economic research to improve soil fertility, increase productivity and production, and improve food security and nutrition around the world with a major focus on developing countries.

      The following comments serve as IFDC’s official contributions to the CoCoFe.

      IFDC scientists believe the judicious use of fertilizer calls for a holistic approach, starting with good quality fertilizer products, with reduced contaminants, which greatly depends on the source of nutrients, beneficiation of mined feedstock, and the production process. When supplied with good quality products and knowledge on their proper application, farmers’ judicious use of fertilizer can produce sufficient, quality, nutritious, and safe food for a fast-growing population while addressing environmental and human health hazards. With a finite amount of resources — namely land, fertile soil, and fresh water — and in the context of climate change, additional factors to consider for promoting the appropriate use of fertilizer are:

      1. Increased investment to revamp agronomic and soil research for resilient agriculture, to innovate nutrient recycling in the context of a circular economy, and to develop the next generation of fertilizer products with lower contaminants, greater efficiency, and balanced nutrients congruent with advances in crop genetics, cropping technologies, and soil conditions.
      2. A better policy, legal, and regulatory framework to guarantee not only the best quality fertilizer products but also their distribution and rational use.
      3. The revamping of extension services for better technical assistance and training to encourage responsible fertilizer recommendations by the supply chain stakeholders and fertilizer use by farmers.

      IFDC scientists and experts in fertilizer production, agronomy, and economics are well-positioned to support the development of the CoCoFe and its implementation through technical assistance and training to fertilizer supply and demand chain stakeholders.

      Specific comments on the CoCoFe

      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?

      First, IFDC suggests establishing clearer goals for the CoCoFe from which the objectives can emanate. In addition, fewer objectives will help simplify the elaboration of the CoCoFe and perhaps facilitate its adoption.

      IFDC also suggests combining the stated objectives 3 and 4 and to consider the following four objectives, which we believe embrace the CoCoFe goals:

      1. Increase food production by increasing yields to close the yield gap in developing countries and to supply the increasing global need of more, nutritious, and safer food;
      2. Optimize the efficient use of nutrients (organic and inorganic) to maximize benefits of better natural resource conservation (land, soil, and water) and effectively promote sustainable agriculture production systems;
      3. Minimize nutrient losses and the accumulation in the soil and in vegetative materials of contaminants and trace elements present in inorganic fertilizer and organic nutrient sources.

      Considering the effects of climate change on agriculture, IFDC further suggests adding the following objective:

      4. Support the adaptation of crops to imminent environmental changes for more resilient agriculture production systems considering balanced nutrient fertilizer products, nutrient recycling, and carbon sequestration.

      In addition, although the CoCoFe is intended to address the use of fertilizer to “minimize environmental and human health impacts from pollutants from fertilizer,” it is necessary to clarify that the CoCoFe approach will only reduce such effects. However, a lot can be done to further reduce the impacts on environment and human health. Research and innovation should aim at improving the beneficiation of mined feedstock and the production processes of fertilizer to eliminate contaminants and non-nutritious trace elements (pathogens, organic and non-desirable chemicals) to enhance fertilizer quality.

      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?

      IFDC believes the scope of the CoCoFe should be on promoting the most efficient use of plant nutrients to effectively sustain agricultural production, which embraces inorganic fertilizer and organic nutrient sources. 

      Considering the aim of the CoCoFe is “to assist member countries  to design policies and regulatory frameworks for the sustainable use of fertilizers,” and the nature of organic materials — which comprises multiple sources with erratic nutrient content depending on the organic material source — makes it difficult to standardize such materials as a source of nutrients, and therefore regulate it. On the contrary, inorganic nutrient sources/fertilizer, given their physical and chemical characteristics, facilitate standardization and regulation.

      However, it is crucial to regulate organic materials (biosolids, compost, etc.) for contaminants and hazardous chemicals (heavy metals, pathogens, toxic organics —including pesticides —etc.). To that end, IFDC suggests developing a subset within the CoCoFe clearly addressing the recycling of organic materials to be used as a source of nutrients for food crops.

      Recognizing that organic materials can be a valuable source of nutrients, in the traditional intensive production systems, they should be seen first as soil amendments to improve soil structure and increase microbial activity, water retention, and cationic exchange, among others, all of which facilitate the absorption of nutrients by the plant root; and second, as a source of nutrient supply to the soil and the plants. Nutrient supply from organic materials can be considered a positive externality in the context of a circular economy; therefore, organic materials should be supplementary to inorganic sources, not the main source of nutrients. The exception can be purely organic agricultural systems in which organic materials can be both soil amendments and the main source of nutrients.

      With respect to the use of bio-stimulants, nitrification inhibitors, urease inhibitors, etc., they should be part of the discussion and the CoCoFe, since they can help improve nutrient use efficiency and achieve the stated environmental and perhaps human hazards objectives.

      Additional comments:

      • Although IFDC supports better policy and regulatory framework for the responsible use of fertilizer, it is important to recognize that the regulatory burden from the adoption of the CoCoFe has the potential to impact the cost of supplying and using fertilizer. This has greater implications for developing countries, such as in sub-Saharan Africa, considering that fertilizer production in these countries is almost non-existent, and its use is low to negligible. This is especially true among small-scale agricultural producers, due in part to fertilizers’ relatively high retail price resulting from high transaction costs along the international and domestic supply chains. Therefore, the regulatory burden could hinder the efforts of international donor and government programs to reduce the retail cost of fertilizer.

      Therefore, economic analyses may be needed to weigh the impact from the potential burden introduced by the CoCoFe as opposed to the impact of a lax regulatory system that will make countries vulnerable to questionable nutrient content in organic products and to hazardous contaminants and non-nutritious trace elements in inorganic fertilizers and organic products.

      • The CoCoFe has the potential to promote the responsible and judicious use of fertilizers if the right audience is brought into the consultation and discussion, and plenty of time is spent in mainstreaming the CoCoFe among the different stakeholders — a process that may take many rounds of discussions at different levels and consequently take several years before the CoCoFe comes to fruition and starts being implemented.
      See the attachments: