Modifications to the Fertilizers Act. Regulations and Guidances
A preamble about soil health and ecological soil management is needed.
The Act does not have a preamble that situates fertilizer regulation and use within a soil health perspective. One is needed first for the guidances, and then later it can be added to the Act (at the Substitution stage). The preamble should provide:
- an acknowledgement that soil is at risk
- an agroecological interpretation of soil health
- a recognition that fertilizer approvals and use must contribute to soil health, while supporting productivity, safety and environmental protection
- a statement that soil health criteria will be used as part of the review of fertilizer applications
Changes to label statements for biological materials regarding role of organic matter in soil health.
The value of organic matter is poorly represented on labels. For biological fertilizers and supplements on the Primary Materials list with significant levels of organic matter, the Guidances should name the need for a label statement that describes the role of organic matter in soil health.
The distinction between fertilizers and supplements is not representative of the full role of different materials in soil fertility. Instead, there should be two categories:
- Nutrients and organic matter
- Secondary materials that stimulate or support nutrient provision
Changes to grade requirements
Organic materials with NPK levels under 5 should not required to report a specific grade. Instead, a general statement to the effect that the material is less than 5-5-5 should suffice. The current system makes organic matter look inadequate compared to synthetic fertilizers, but with this change and a label statement about the value of organic material, there will be more recognition of organic material value.
Modifications to provincial Fertilizer and Nutrient Management legislation
As discussed under Current Government Initiatives, nutrient management policy, legislation and programming at the provincial level is highly variable in effectiveness. This can not be attributed to unique provincial conditions, since soil quality is an issue in most significant production regions of the country. Although soils have differences in different regions, and the symptoms of the problem may differ, they have similar roots and require similar solutions in the broad strokes. It is only when decision makers take an unecological view of soil health problems that provincial uniqueness can be argued. All provinces should be taking an approach comparable to Quebec which has the most ecological soil health program in the country.
Sustainable protocol adoption
Sustainable production protocols, based on systems that support soil health, are discussed under Goal 5, Sustainable food production. Can be incorporated by reference under 5.1(1) of the Act. Integrated Crop Production standard minimum.
Changes to provincial extension services
Post WWII, extension services shifted to fertilizer promotion. Now they must promote organic matter, crop rotation, cover and intercropping and composting. Most ag departments don't have enough expertise to do this.
Improving ecological nutrient management research
Pan-Canadian soil health strategy to at least Quebec level (through CAP?). Equiterre, 2021