Upper Tolerances for Micronutrients in Fertilizers

Transcription

1 2017 Her Majesty the Queen in Right of Canada (Canadian Food Inspection Agency), all rights reserved. Use without permission is prohibited. Upper Tolerances for Micronutrients in Fertilizers

2 Program Objectives and Mandate To ensure that fertilizers and supplements, imported into or sold in Canada, are safe for: humans plants animals the environment Regulatory authority: Canadian Food Inspection Agency Act Health of Animals Regulations (for Enhanced Feed Ban) Fertilizers Act and Regulations: equivalent to Canadian Environmental Protection Act (CEPA Sch. II and IV). Regulation of Fertilizers and supplements in Canada is a joint effort; other aspects of a product s lifecycle (manufacture, transport, use and disposal) are regulated by the Provincial, Territorial and Municipal partners.

3 Safety related authorities Fertilizers Act: 3.1 No person shall manufacture, sell, import or export in contravention of the regulations any fertilizer or supplement that presents a risk of harm to human, animal or plant health or the environment. 4 No person shall sell any fertilizer or supplement that contains destructive ingredients or properties harmful to plant growth when used according to the directions that accompany the fertilizer or supplement or that appear on the label of the package in which the fertilizer or supplement is contained. Fertilizers Regulations: 11 (1) A fertilizer or supplement shall not contain (a) any substance in quantities likely to be generally detrimental or seriously injurious to vegetation (except weeds), domestic animals, public health or the environment when used according to directions; (b) any substance that would, when applied in amounts commonly used or as specified in the directions for use leave in the tissues of a plant a residue of a poisonous or harmful substance. (3) A fertilizer shall not contain plant nutrients that are present at toxic levels if the fertilizer is used at recommended rates.

4 Micronutrients Micronutrients (Boron, Chlorine, Copper, Iron, Manganese, Molybdenum and Zinc) are essential plant nutrients required in small amounts; both deficiencies and excess have negative effects on plant growth and crop yield. Crop B Cu Mn Zn Alfalfa High Med Low Med Wheat Low High High Low Rye Low Low Low Med Clover Med Med Low Med Corn Med Low Low High Oats Low Med High Med Sugar Beet High Low Low Med Grass Low Low Low Med Deficiency symptoms Stunted growth, poor pollination, hollow stems and fruit, brittle leaves, chlorosis (marginal or interveinal), loss of fruiting bodies, chlorotic spots, leaf drop, delayed ripening, senescence and death Toxicity symptoms Marginal or tip chlorosis and necrosis, stunted growth, wilt, defoliation, reduced root mass, senescence and death, symptoms similar to pathogen attack

5 Background Some micronutrients are also metals of concern (Cu, Mo, Zn) When applied in excess, micronutrients can have adverse effects on animal and human health. Micronutrients are persistent and tend to accumulate in soil (and in some hydroponic systems). Can lead to accumulation in crops and long term environmental impacts. Use of micronutrients in hydroponic growing media may lead to metal accumulation in edible plant portions. Risks are inherently difficult to quantify and link to reportable disease/impacts and contamination events in food or feed crops (e.g. Mo in cattle). As such, use of micronutrients in agriculture need to be monitored and managed to minimize the potential for over-application

6 Regulatory Landscape Precautionary statements are required on the label Micronutrients require a guaranteed analysis on the label Cu Application rate is based on soil and tissue tests (deficiency) or is specified on the label. Appropriate application rate is based on the guaranteed amount of the micronutrient Tolerances around guarantee removed from Fertilizers Regulations in 2013 In the absence of upper tolerances for micronutrients guarantee: Lack of clear guidance to industry Lack of clear guidance to CFIA operational staff inconsistencies in enforcement Difficult to determine application rate if the guaranteed analysis is inaccurate impacts on users, farmers, consumers and the environment

7 International Scan Requirement Canada AAPFCO EU Finland 2 Australia 3 New Zealand 4 China Current Future Micronutrient Guarantee on the label Actual average Product efficacy NO NO Product must meet the Guarantee NO * Tolerance limits NO* -/ Product must meet Heavy Metal Standard -/ -/+ -/+ -/+ NA

8 Portion of International Analysis of allowed max. values for set of Micronutrient Guarantees Mn Zn Canada NZ Australia Finland Canada NZ Australia Finland Guarantee Mn Mn Mn Mn Guarantee Zn Zn Zn Zn NP NP NP NP NP most lenient strictest

9 Implementation of micronutrient tolerances Guarantee Range (%) Permissible Guarantee Exceedances (%) < % of Guarantee Micronutrient over-application occurs when label guarantee under-represents micronutrient content. Potential for adverse effects on animals, plants, human health and the environment. CFIA re-establishing upper tolerances for micronutrient guarantees that are: based on analytical variability and attainability with modern manufacturing practices aligned with international norms + standards anticipated to decrease non-compliance rates, particularly for low range guarantees (based on historical trends)

10 Implementation of micronutrient tolerances PRODUCT REGISTRATION New applications starting April 1, 2018 Files in the queue as of April 1, 2018 Upper tolerances + requirement for Fe, B and Mn results of analysis (when guaranteed) come into effect immediately Applicants may follow old or new requirements for registration. Tolerances will be enforced at renewal and in marketplace MARKETPLACE MONITORING Beginning April 1, 2018 Information letters distributed Beginning April 1, 2019 Tolerances in full force, product detention as required Compliance Verification Tool Excel spreadsheet to assist proponents, CFIA inspectors and evaluators in verifying product compliance with metals, dioxins/furans and pathogens standards as well as permissible tolerances Available upon request from paso-bpdpm@inspection.gc.ca

11 Questions / Pre-market Application Submissions Office Canadian Food Inspection Agency 59 Camelot Drive Ottawa, Ontario K1A 0Y9 Phone: Fax: