The International Fertilizer Association (IFA) recognizes the impressive effort that has gone into this framework, and we acknowledge its ambition to be as comprehensive and exhaustive as possible in terms of data collection. However, its ambition could undermine the feasibility and practicality, in particular for smaller-sized companies, which have limited resources for that type of exercise. We have the following suggestions for improvement: The indicator B.9. 2 on the Management of Fertilizers provides a diverse and complete list of recommended sustainability practices, but it is unclear how the wealth of information reported could ultimately fit under a single indicator. We are fully supportive of this indicator, but believe that it deserves more thought.
However, we question the Fertilizer Use Intensity Indicator (B.9.1), expressed in Kg / ha. Fertilizer use intensity depends on a number of biophysical (soil, crop, and climate) as well as socioeconomic factors, thus different conditions will necessarily lead to higher or lower fertilizer use per ha. In addition, access, supply, and government policies could influence the amount of fertilizers applied in a given region. Thus we recommend eliminating the indicator of fertilizer use intensity or replacing it with a Nutrient Use Efficiency Indicator.
Last but not least, the soil degradation indicator (B.8.1) is vague and responsibilities and knowledge of soil conditions are unclear, in particular, if the land is owned but not used. Who should report in this case? While this indicator is highly relevant for national data sets, it is difficult for a company to report on, as most companies do not manage a lot of land directly. While we fully recognize the importance of knowledge improvement on soil health, we would recommend removing this indicator from this assessment and rather enforcing it for countries to be measured on a regional or national scale.
الدكتور Yvonne Harz-Pitre