Bios%mulants: A State Fer%lizer Regulatory Program Perspec%ve. AAPCO March 9, 2016
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1 Bios%mulants: A State Fer%lizer Regulatory Program Perspec%ve AAPCO March 9, 2016
2 Framing the ques%on: Fer%lizer Regula%on No na%onal regulatory program Regulated by individual states Regula%ons and requirements vary between states
3 Elements of State Fer%lizer Regula%on May, or may not, include: fer%lizers (plant nutrients), soil amendments, plant amendments, hor%cultural growing media (e.g. poong soil), compost, and beneficial substances (e.g. silicon, fulvic acid)
4 Elements of State Fer%lizer Regula%on State programs may, or may not, regulate: product registra%on, labels (format, terms) labeling (promo%onal materials), ingredients, heavy metals (limits), inspec%on, sampling, and analysis.
5 The Role of the Associa%on of American Plant Food Control Officials (AAPFCO) Promote uniformity through consensus Uniform: Defini%ons Model bills for legisla%on Labels and labeling Inspec%on methods Sampling and analysis
6 The Role of AAPFCO Not regulatory Par%cipa%on is voluntary Conformity trumped by state laws Defini%ons - one of the most commonly used, and useful, func%ons
7 "Define your terms... or we shall never understand one another. - Voltaire, Dic$onnaire philosophique, 1764
8 Regulatory Defini%ons Fair and equitable regula%on requires accurate and complete defini%ons. Regulatory defini%ons must have clear boundaries. (What s in? What s out?)
9 The Defini%on of Bios%mulant?
10 It depends on who you ask.
11 European Bios%mulant Industry Council (EBIC) Plant bios%mulants contain substance(s) and/ or micro-organisms whose func%on when applied to plants or the rhizosphere is to s%mulate natural processes to enhance/benefit nutrient uptake, nutrient efficiency, tolerance to abio%c stress, and crop quality. From du Jardin, et al., 2012
12 European Commission (EC) To date, the European Commission (execu%ve arm of the EU) has been unable to agree on a regulatory defini%on of bios%mulant.
13 Bios%mulant Coali%on (US) Substances, including micro-organisms, that are applied to plant, seed, soil or other growing media that may enhance the plant s ability to assimilate applied nutrients, or provide benefits to plant development. Bios%mulants are not plant nutrients and therefore may not make nutrient claims or guarantees.
14 Associa%on of American Plant Food Control Officials (AAPFCO) The Bios%mulant Coali%on defini%on was submifed to AAPFCO, but considered too vague for a regulatory defini%on. Currently, AAPFCO does not accept the use of the term bios%mulant on labels or in labeling.
15 Relevant AAPFCO Terms Soil Amendment... any substance or mixture of substances which is intended to improve the physical, chemical, biochemical, biological or other characteris%cs of soil, except fer%lizers...
16 Relevant AAPFCO Terms Plant Amendment... any substance applied to plants or seeds which are intended to improve growth, yield, product quality, reproduc%on, flavor, or other favorable characteris%cs of plants, except fer%lizers...
17 Relevant AAPFCO Terms Beneficial Substance or Compound... any substance or compound other than primary, secondary, and micro plant nutrients that can be demonstrated by scien%fic research to be beneficial to one or more species of plants, when applied exogenously. (To date, only silicon and hydrophobic fulvic acid.)
18 Relevant EPA Term Plant Regulator (PGR) A plant growth regulator, through physiological ac%on, is intended to accelerate or retard growth, or alter plant behavior or the produce of the plant. - EPA Label Review Manual (2014), page 2-6
19 Whether a product is considered to be a plant growth regulator depends on whether the plant response or mode of ac%on being claimed would go beyond what would be expected from simple nutri%on. - EPA Label Review Manual (2014), page 2-6
20 What materials are Bios%mulants? Reference frequently cited by industry: The Science of Plant Bios1mulants A bibliographic analysis by Prof. Patrick du Jardin (prepared for EBIC)
21 What materials are Bios%mulants? (From Jardin et al.) Humic substances Released from organic mafer by decomposi%on humins, humic acid, fulvic acid, etc. Soil: help forma%on of soil aggregates, may chelate or complex nutrients. Plants: hormonal effects, increase enzyme ac%vity, s%mulate mitrochondrial respira%on, and more.
22 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials
23 What materials are Bios%mulants? (From Jardin et al.) Complex organic materials complex organic materials are obtained from composts, manure, sewage sludge extracts, agroindustrial and urban waste products. Include humic substances. Provide organic mafer, nutrients, promote bacterial ac%vity, control soil-borne pathogens, enhance degrada%on of pes%cide residues and xenobio%cs.
24 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements,
25 What materials are Bios%mulants? (From Jardin et al.) Beneficial chemical elements Five main beneficial elements Aluminum (Al), Cobalt (Co), Sodium (Na), Selenium (Se) and Silicon (Si) Effects include cell wall rigidifica%on, herbivore deterring, osmoregula%on, reduced transpira%on by crystal deposits, thermal regula%on via radia%on reflec%on, enzyme ac%vity by co-factors, plant nutri%on via interac%ons with other elements during uptake and mobility, an%oxydant protec%on, interac%ons with symbionts, pathogen and herbivore response, protec%on against heavy metals toxicity, plant hormone synthesis and signalling.
26 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements, Inorganic salts, including phosphite,
27 What materials are Bios%mulants? (From Jardin et al.) Inorganic salts, including phosphite... phosphites and phosphates, but also bicarbonates, sulphates, nitrates provide protec%on against fungi, which may involve direct fungicidal ac%on or indirect protec%on by s%mula%ng plant defenses...
28 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements, Inorganic salts, including phosphite, Seaweed extracts,
29 What materials are Bios%mulants? (From Jardin et al.) Seaweed extracts... biofer%lisers, soil condi%oners and bios%mulants... Micro- and macronutrients, special polysaccharides (like alginates, laminarin and carragheenans), sterols, N-containing compounds like betaines, and hormones...
30 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements, Inorganic salts, including phosphite, Seaweed extracts, Chi%n and chitosan deriva%ves,
31 What materials are Bios%mulants? (From Jardin et al.) Chi%n and chitosan deriva%ves... bioac%ve biopolymers from which many deriva%ves are produced by hydrolysis and chemical modifica%on... The main func%on is in plant protec%on against viruses, bacteria, fungi and insects, via the ac%va%on of host defense genes and the development of so-called immune response.
32 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements, Inorganic salts, including phosphite, Seaweed extracts, Chi%n and chitosan deriva%ves, An%transpirants,
33 What materials are Bios%mulants? (From Jardin et al.) An%transpirants A) Physical barriers on the leaf surface kaolin, latex, wax, polyacrylamide B) Physiologically regulate opening of stomata abscisic acid, acetylsalicylic acid Lower leaf temperature, reduce evapora%on within leaf and to atmosphere
34 What materials are Bios%mulants? (From Jardin et al.) Humic substances, Complex organic materials, Beneficial chemical elements, Inorganic salts, including phosphite, Seaweed extracts, Chi%n and chitosan deriva%ves, An%transpirants, Free amino acids and other N-containing substances.
35 What materials are Bios%mulants? (From Jardin et al.) Free amino acids and other N-containing substances. S%mulate enzymes regula%ng nitrate assimila%on, Krebs cycle, and enhance nitrogen use efficiency, increasing photosynthesis and plant growth.... s%mulate plant defenses to bio%c and abio%c stress...
36 What materials are Bios%mulants? Jardin didn t include microbial inoculants Mycorrhizal fungi Form symbio%c rela%onship with plant roots Effec%vely increases plant roo%ng area by joining root and hyphae Plant provides sugars Fungi provides nutrients, water, enzymes, hormones
37 What materials are Bios%mulants? Mycorrhizal fungi Trichoderma fungi Bio-pes%cide parasi%ze other fungi and plantparasi%c nematodes Increase secondary root forma%on Solubilize phosphates and iron Infect plants to induce systemic resistance
38 What materials are Bios%mulants? Mycorrhizal fungi Trichoderma fungi Plant-growth-promo%ng rhizobacteria Fix atmospheric nitrogen Solubilize phosphates Chelate iron Increase mineral uptake Synthesize phytohormones (e.g. auxins, cytokinins)
39 Three Big Ques%ons for Regulators 1) Does the product work? As claimed, when applied according to directed rates? Lab vs. Field? Limi%ng condi%ons? (e.g. temp, soil ph)
40 Three Big Ques%ons for Regulators 2) How does the ac%ve work? Pes%cidal vs. non-pes%cidal Bios%mulant, or release from pest pressure?
41 Three Big Ques%ons for Regulators 2) How does the ac%ve work? Pes%cidal vs. non-pes%cidal Microbial vs. non-microbial Combo product Inoculant, or nutrients?
42 Three Big Ques%ons for Regulators 2) How does the ac%ve work? Pes%cidal vs. non-pes%cidal Microbial vs. non-microbial Direct vs. indirect Affect plant cell, or alter nutrients in soil?
43 Three Big Ques%ons for Regulators 2) How does the ac%ve work? Pes%cidal vs. non-pes%cidal Microbial vs. non-microbial Direct vs. indirect Biological vs. biochemical Fungal hyphae providing nutrients, or hormones?
44 Three Big Ques%ons for Regulators 3) How is it regulated? A bios%mulant soil amendment, plant amendment, or beneficial substance; or a PGR?
45 Status of Bios%mulant as a Term Vague defini%ons Ac%on poorly understood Not an AAPFCO-defined term Most states will not accept it in labeling
46 Future of Bios%mulant as a Term To build a defini%on 1. Submit defini%ons to AAPFCO for individual materials 2. Use those materials to build categories (e.g. PGPR) 3. Use the categories to build a build a defini%on for bios%mulant
47 Excep%on Most state fer%lizer programs will accept the term bios%mulant if it is used as part of the name of an EPA- registered product.
48 Thank You
49 Ques%ons?
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