Substitution (fertilizers)

Additional changes to the Fertilizers Act and Regulations

Priority product development for soil health, financial and logistical assistance to SMEs to help with safety testing

Based on the example of the AAFC-PMRA Minor Use Pesticide program, regulators and program staff should work with manufacturers and importers on priority materials to advance soil health objectives, and particularly for SMEs, provide assistance on trial data and applications for approval.

Return to efficacy testing and post-market impact surveillance

Returning to efficacy testing regarding soil health objectives is warranted.

Reducing permitted application rates, based on assumption that farmers are diversifying crop rotations and doing other ecological soil management practices

Currently, applicants are not required to provide evidence of appropriate fertilizer use on the basis of optimal crop rotations. Instead, most directions for use (which are mandatory on labels under the Regulations) are based on individual crops, as if produced year over year in a monoculture. However, nutrient use and mobilization is very affected by crop sequencing.

For example, a classic soil conserving Prairie rotation is oilseed (e.g., canola) -cereal (barley)-pulse (peas)-cereal (wheat). The rotation can also be extended and made more complex by working in winter cereals and alfalfa in certain regions.  Applicants should be required to submit reference rotation fertilizer recommendations for the cycle, taking account of organic matter additions and contributions from the pulse crop.

Conditions on approvals and re-evaluations related toRequires changes to testing protocol guidance.

Implementing cross compliance like QC

Tie distribution licences into sustainable protocol adoption - distributors must provide fertlizer use advice consistent with protocols

Carbon taxes and other GHG mitigation measures

See Goal 5, Sustainable food production

Reducing corporate concentration in the input sector

See Goal 3, Reducing corporate concentration