Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

Dear Forum members and contributors to the online consultation,

Thank you for all for the contributions and feedback over the course of this consultation to review and revise the International Code of Conduct for the Use and Management of Fertilizers.

Feedback and comments were received from over 50 contributions to the exchange. Contributors from a broad geographic perspective included representatives of member countries, academia, NGOs, research institutions, civil society, fertilizer industry associations and companies. The full proceedings of the consultation are available here on the forum webpage.

In summary, there was consensus that a Fertilizer Code of Conduct is timely and needed given the importance of nutrient management from a global food security perspective, the need to prevent the conversion of natural lands to agricultural uses and from land degradation, and to address potential negative impacts of fertilizers.

It was generally agreed that the Fertilizer Code addressed all aspects related to optimizing benefits and minimizing risks of fertilizer use and management. However, there were some comments suggesting that the Fertilizer Code was too focused on the benefits of fertilizers rather than their negative impacts on the environment and animal and human health, and thus could be seen to be promoting the use of fertilizers and the interests of the fertilizer industry. On the other hand, there were a number of comments suggesting that the Fertilizer Code was biased towards highlighting the negative effects of fertilizers and not promoting the benefits of fertilizers sufficiently. The development of the Fertilizer Code, subject to this review, was assisted by a technical OEWG with expert representation from member countries, fertilizer industry and interested NGOs. Broad agreement was reached amongst the OEWG in regard to balancing benefits and risks of fertilizer use, thus any suggestions to change the Code in terms of further highlighting either the benefits or negative impacts of fertilizers are well-noted and recorded, however no significant changes will be made to the text in this regard.

There were some comments regarding what was missing from the Fertilizer Code, particularly specific items such as liming agents and vermicomposts, or strategies to manage fertilizer use at the field level. Where appropriate specific items will be included as examples. General strategies for managing plant nutrition are certainly referred to within the text, however it is beyond the scope of the Fertilizer Code to include specific strategies and recommendations for the use of fertilizers, nor specific policies or allowable limits on contaminants. Such information exists and should be collated into a supporting toolkit or knowledge hub containing examples, guidelines and other materials to help formulate fertilizer management policies and assist in making decisions for specific fertilizer management practices.

Within the feedback and comments, there were also many suggestions for ways to refine the document. Where appropriate such suggestions will be incorporated, however no large changes or alterations from the original text, tone and sentiment of the document will be made at this point as this had been previously agreed by the OEWG. The feedback however is documented for the record and can be used for future refinements of the Fertilizer Code, or for reference by member countries who will adopt the Code.

There were a number of comments, a significant number of which were from the fertilizer industry associations and representatives, that the Fertilizer Code was developed in too short a time frame. It was agreed by the OEWG that this initiative is urgently needed by many countries to support governments to manage the multiple aspects along the fertilizer supply chain including the regulation, quality, proper handling and proper use of fertilizers, as well as minimizing and reducing the negative impacts of fertilizers. This sentiment was also supported by the majority of the GSP Plenary. It was also highlighted by many member countries that they urgently require such a Code of Conduct related to fertilizers, and as such strongly supported its rapid adoption.

As a result of this consultation, a revised version of the Fertilizer Code of Conduct will be presented to COAG 2018 with the suggestion that it be adopted and that a review of the Code occur in 4 years’ time, thus allowing the assessment of the usefulness of the application of the code, further stakeholder engagement and buy in, and subsequent refinement. A report as such be would be presented to COAG in 2022.

Again, many thanks for all your support in assisting the development of such an important tool to help address the challenge of managing fertilizers to address food security and nutrition, while preserving the environment.

Sincerely,

Debra, Gary, Robert, Ronald and Zineb

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. 

Thanks for this "International Code of Conduct for the Use and Management of Fertilizers". This is a comprehensive Code of conduct for the use and sound management of fertilizers worldwide. However, in a developing country such as Cameroon, there is a poor management of governmental institutions, not only in this aspects, but almost in all aspect of societal life. There is almost an inexistent regulation regarding the use and management of fertilizers. And this is not going to change soon. In addition, most fertilizers are imported in the country. May be some fertilizers are packed inside the country. Then, I propose to strengthen the policies regarding the international trade of fertilizers. In addition, a survey regarding the current practices on the use and management of fertilizers in a country such as Cameroon may help to come out with a stronger Code of conduct regarding this issue.

Then, find below answers for some of the questions you required:

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

Yes. To the stakeholders in charge of use and management of fertilizers

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

No. Since many aspects of this code depend on the governments. In case of poor governance, this is going the affect the code

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

International trade is going to affect the use and management of fertilizers specially in countries with poor governance

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

I propose to strengthen the policies regarding the international trade of fertilizers.

The CoCoFe zero draft should be greatly improved before being an international Code of conduct.

1- First many scientific result presented as scientific proofs in this code are unconvincing assertions. For example sources of heavy metals pollutions are not really demonstrated. The work must keep on considering the isotopic ratios of cadmium, lead etc.because sources are several (industry, fossil combustibles, the parent rock and the original soil itself, the geological context, airborn nanoparticles).Only such studies should be deciding factors and by the way the different sources of pollution could be quantify.

2- roles of fertilizers and pesticides have not to be treated or even presented on the same rank. The negative impact developped by pesticides use is real. It is a danger for health of human population and animals.

3- How to ensure the feeding of the world population and to diminishe poverty? To day more than 50 % of people can survive thanks to the use of fertilizers. And considering the risk of use of organic fertilizers is higher than that of mineral fertilizers because developpement of bacteria strongly increase the risk for health. 10 to 20 millions of croppable lands are degraded each year because of bad agricultural practices which lead to a strong erosion of soil and then a loss of nutrients. It turns out that fertilizers use only can ensure the renewal of nutrients in the soil. Most of farmers and stakeholders have not the slightest hint that mineral fertilizers could restore the soil fertility when nutrients have gone along with clay minerals through soil erosion.

And to restore or to enhance soil fertility can keep food production and to be actually a breakthrough for feeding poor populations. FAO does not forget that hunger continues to lag behind. To provide enough food for humans must be the main target.

Daniel Nahon

professor at Aix-Marseille University (AMU)

president of directoire de la recherche of AMU

Member of Institut Universitaire de France ( chair of soil science)

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

Yes, of course it is. I think it is more useful for the governmental managers in fertilizer management.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

I think yes.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

I think we have to pay attention to all materials that are using for fertilizing. There was not good attention to soil conditioners and soil amendments in this document, also about materials that are using as plant growth promoters or anti stress and so on, because of that, I propose to change the title to “Fertilizing Material Code of Conduct”

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

No

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

As I mentioned above I propose to change the title to “Fertilizing Material Code of Conduct” and change the term “Fertilizer” to “Fertilizing Materials” in whole of the document. I defined “Fertilizing Materials” in the attached file as has been defined before in some documents.

I have also some comments and small corrections that have been done in the document attached.

The CoCoFer is a very necessary document for the actual and future generation. The live is environment dependent. The humanity will go so far as the environment will be preserved. Then, the CoCoFer document will need to respond to governments, farmers and industries demand, but in first place to the protection of the environment and the increasing of food production and its quality.

The CoCoFer document will need to be clearing and explicit, indexing more concept, terms and definition related to the type, form, use and management of fertilizers, and on the other hand, to define the permissible limits of these elements.

Best regards,

MSc. Duniesky Domínguez Palacio

Investigador Agregado

Instituto de Suelos, UCTB P. del Río

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

Yes, absolutely it is useful. Because it place an obligation to all the for all the stakeholders on the fertilizer use chain. It also provides a reference for the government to stipulate national code to improve and standard the fertilizer market and develop and refine evidence-based fertilizer recommendations.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

Yes.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

No.

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

Yes. I think that some articles in the code just goes too detail oriented, such as define programs for regulating fertilizers by government.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

What I concern is that the code might impress the public that fertilizer is such a hazard chemical product as pesticide/pestcide. It might exaggerate the negative impact of fertilizer application on environment. We must bear in mind that chemical fertilizer might have a negative impact on environment in case fertilizer is improper or inappropriate used, but it could be avoided if it is applied reasonably. Similarly, fertilizer might have some negative effect on the human health if it is disposal incorrectly, but it is not fatal.

My another concern is who will be responsible for the implement and assess the outcome of code? I suggest that a secretariat specified on the code implementation could be set up under the frame of FAO.

Thank you for this important effort. 

I am soil4climate, soil-age, Sols Vivants Québec advisory board member.

Involved with biochar, a structuring soil amendment than can hold and retain fertilizers — member of the International Biochar Initiative.

Our comments:

• Shall present soils as a living organism — a quality attributed to animals, human, the general environment, but not to soils. 
• Lets underline carbon as a driver of fertility, of water retention and absorption, and, of climate change reversal.
• Underestimation of chemical fertilizers in reducing, by oxIdation, carbon content in soils — especially when combined with soils’ tilling. World agriculture lands have lost 50-70% of their carbon content (R. Lal). 
• Synthetic fertilizers are not renewable. They will peak, and deplete. Strong dependance of some synthetic fertilizers on depleting fossil-fuels. 
• We could see more of a holistic approach, including healthy soils’ services: erosion control, healthy soils bringing biodiversity, water retention of soils with high carbon contents, historical co-evolution of soils and big herds of wild animals and need for proxies. We could read more: circular economy, potential of organic fertilizers for ‘regenerative agriculture’ and soils’ restoration, biodiversity for a livable climate, ecosystems restoration for global warming reversal. 

Kind regards, 

Benoit Lambert, PhD

Dear colleagues

kindly find attached our answers for your questions. We grab this opportunity to introduce our Association (ARAB Fertilizer Association) as representative of the Arab fertilizer producers.

AFA comprises Arab industrial companies working in the fields of fertilizers manufacturing and trading, in addition to other related fields. It further includes 180 Arab and foreign company members from twenty-nine countries from all over the world.

The Arab Region products counted for around 68 % of TSP World production, 37% of DAP production & about 70% of phosphate rock world trade, 50 % of TSP world trade, 41 % of Urea World Trade, together with 25% and 30, 4% of Ammonia, Sulphur and potash markets respectively.

As (AFA), we are supporting with the International Fertilizer Association (IFA)’ comments as we are totally agree with the development of such an important matter, but in the same time we recommend that on such as important document should have more time to discusses to improve its quality benefit and relevance for the fertilizer industry and its stakeholders.

In summary, I think we still need more time to revise several of the terms and definitions, and we recommend to postponed the adoption and give more time to all our stakeholders to read, understand it and make any suggestions for improvement as the time mentioned is not enough to discuss such an important subject related the important role of fertilizer & by our tern we will discuss this document during our next Int’l Economic & Agricultural forum beside the next Int.l technical conference in 2019 and we will organize a special Agri-experts workshop to discuss how we can improve this document & it worth to mention that we already work on such as this improving by conduction several workshops on fertilizer efficiency use and translate the IPNI‘s issue (4R Nutrient Stewardship ) to Arabic to reach our end customers ( the farmers in Arab Region) & issued the first handbook on 4R fertigation.

Dear colleagues,

I propose one additional chapter about environmental protection measures and practices to avoid negative impact of use fertilizer in the ecosystem

Best regards,

Dr Samuel Francke Chile