Have you read the Responsible Grain Voluntary Code of Practice posted at www.responsiblegrain.ca? Have you participated in one of the ongoing online consultation sessions?
The consultations are informative and well-run. Online participation actually has a number of advantages as compared to town hall meetings. However, work still needs to be done to explain why this code is needed and how it will be used. Beyond that, the devil is in the details and the code still needs a lot of work.
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Proponents take great pains to emphasize the voluntary aspect of the code, saying that if the grain industry develops its own guidelines, government regulations are less likely. Unfortunately the language used in the code lists “requirements” and that doesn’t mesh with the voluntary concept.
Many of the requirements are what currently exist in government law and regulation. Those are legitimately requirements. Beyond that, a large number of other practices are also listed under the requirement category and that’s not the best description. They would more appropriately be listed as best management practices or perhaps baseline operating procedures.
Here’s an example from the Nutrient Management section: “Where required by law, perform representative soil sampling as per provincial requirements; otherwise complete representative soil test (per field) at least every five years.”
This is listed under “Requirements.” Underneath, in “Recommended Practices,” it says test each field using a representative sample at least every three years.
The way it’s written certainly makes five-year testing seem like a new rule for jurisdictions that don’t already have laws and regulations in this regard. That isn’t the intent and the language needs to change.
It’s natural to wonder what value the code has if it’s voluntary. The power will come from industry audits showing most farmers follow these practices. That’s useful for the public trust of domestic consumers as well as customers around the world.
In many cases, it’s also instructive for farmers such as in this example: “where required by law, comply with the regulations on timing of nutrient application; otherwise, do not apply any nutrient sources on soils that are frozen, snow-covered or saturated with water.”
Applying fertilizer onto frozen ground and snow happens all too often in Saskatchewan with many producers unaware this practice is illegal in some other provinces. One thing the code does is list many of the rules and regulations already in place in other jurisdictions.
In this case, the footnotes explain that in Manitoba the application of livestock manure and nutrients is restricted between Nov. 10 of one year and April 10 of the following year.
Pesticide application is another example where laws are different in some parts of the country. In some provinces, pesticide applicators, including owner-operators, must have a licence to use and apply pesticides. This typically means pesticide training is required. In other provinces, no requirements exist for farmers.
Producers participating in the consultations have commented on the negative tone of the document — do this,don’t do that. The same information could be conveyed using more positive language.
It’s good to see a strong level of engagement from producers taking the time to review all the information and provide input. Social media is full of conspiracy theories, but the objectives of the code are well-intentioned and transparent.
If it wasn’t thought-provoking and at least a little bit controversial, the process wouldn’t have much value. Overall, Canada’s grain industry has a good story to tell, but there’s always room for improvement.
Kevin Hursh is an agricultural journalist, consultant and farmer. He can be reached by e-mail at kevin@hursh.ca.
