The PESTLE model



PESTLE stands for - Political, Economic, Sociological, Technological, Legal, and Environmental.

PESTLE analysis is in effect an audit of an organization's environmental influences with the purpose of using this information to guide strategic decision-making. The assumption is that if the organization is able to audit its current environment and assess potential changes, it will be better placed than its competitors to respond to changes.

The PESTLE model

The PESTLE model provides users with a series of headings under which users can brainstorm or research key factors:

  • Political: what is happening politically in the environment in which you operate, including areas such as tax policy, employment laws, environmental regulations, trade restrictions and reform, tariffs and political stability?
  • Economic: what is happening within the economy, for example; economic growth/ decline, interest rates, exchange rates and inflation rate, wage rates, minimum wage, working hours, unemployment (local and national), credit availability, cost of living, etc.
  • Sociological: what is occurring socially in the markets in which you operate or expect to operate, cultural norms and expectations, health consciousness, population growth rate, age distribution, career attitudes, emphasis on safety, global warming.
  • Technological: what is happening technology-wise which can impact what you do, technology is leaping every two years, how will this impact your products or services, things that were not possible five years ago are now mainstream,for example mobile phone technology, web 2.0, blogs, social networking websites. New technologies are continually being developed and the rate of change itself is increasing. There are also changes to barriers to entry in given markets, and changes to financial decisions like outsourcing and in sourcing.
  • Legal: what is happening with changes to legislation? This may impact employment, access to materials, quotas, resources, imports/ exports, taxation etc.
  • Environmental: what is happening with respect to ecological and environmental aspects? Many of these factors will be economic or social in nature.

Advantages and disadvantages of using a PESTLE analysis


  • Simple framework.
  • Facilitates an understanding of the wider business environment.
  • Encourages the development of external and strategic thinking.
  • Can enable an organization to anticipate future business threats and take action to avoid or minimize their impact.
  • Can enable an organization to spot business opportunities and exploit them fully.


  • Some users over simplify the amount of data used for decisions - it is easy to use scant data.
  • To be effective this process needs to be undertaken on a regular basis.
  • The best reviews require different people being involved each having a different perspective.
  • Access to quality external data sources, this can be time consuming and costly.
  • The pace of change makes it increasingly difficult to anticipate developments that may affect an organization in the future.
  • The risk of capturing too much data is that it may make it difficult to see the wood for the trees and lead to 'paralysis by analyses.
  • The data used in the analysis may be based on assumptions that subsequently prove to be unfounded (good and bad).

Fertilizer industry in India

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The Indian fertilizer industry has been supplying a substantial portion of the growing demand of the fertilizer with the country. India is the third largest producer of fertilizer in the world. There are 60 large size fertilizer plants in the country manufacturing a wide range of nitrogenous phosphate and complex fertilizers. Besides there are 81 medium and small scale single super phosphate units.

The cooperative sector has come to play a significant role in the Indian fertilizer industry .in terms of nutrients the share of cooperative sector in the installed capacity is 19.7% for nitrogen and 10.2% for phosphate. Indian farmers fertilizer cooperative limited (IFFCO), a multi-unit co-operative society established on November 3, 1967 accounts for 64 % of the installed capacity of nitrogen and the total of the phosphate capacity in the cooperative sector. In the last 42years iffco has emerged as the pioneer venture in the cooperative sector. It has witnessed a meteoric rise and has blossomed into the largest manufacturer and marketer of fertilizers in the country. The success of iffco has encouraged the growth of the cooperative movement in India.

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At present there are 57 large scale fertilizer units. These manufacture an extensive range of phosphate, nitrogenous and complex fertilizers. 29 of these 57 units are engaged in the manufacturing of urea, while 13 of them produce Calcium Ammonium Nitrate and Ammonium Sulphate. The remaining 20 fertilizer plants manufacture complex fertilizers and DAP. There are also a number of medium and small scale industries in operation, about 72 of them. The following table elucidates the installed capacity of each sector.

The Department of Fertilizers is responsible for the planning, promotion and development of the Fertilizer industry. It also takes into account the import and distribution of fertilizers and also the financial aspect. There are four main divisions of the department. These include Fertilizer Imports, Movement and Distribution, Finance and Accounts, Fertilizers Projects and Planning and Administration and Vigilance. It makes an assessment of the individual requirements of the states and union territories and then lays out an elaborate supply plan.

Size of Indian Fertilizer Industry

The production of food grains in India rose by an excess of 156 million MT since 1951-52. The fertilizer industry has played a major role in this mass production of food grains. The fertilizer industry came into being in India in the year of 1906. The first manufacturing unit of Single Super Phosphate (SSP) had a manufacturing capacity of 6000 MT.

As per Government of India records on 31.01.2007; the Indian fertilizer industry has made a production of 120.61 LMT of nitrogen (N) and 56.59 LMT of phosphatic (P) nutrient. The installed capacity of urea in India is estimated to be 207.52 LMT. These successes in the production by the fertilizer companies of India have crowned India the 3rd largest fertilizer producer in the world.

Growth of Indian Fertilizer Industry

The Indian fertilizer industry has come a long way since the setting up of the manufacturing unit of Single Super phosphate (SSP) near Chennai in 1906 A new impetus to the growth of Indian Fertilizer industry was provided by the set up the two fertilizer plants- Fertilizer & Chemicals Travancore of India Ltd. (FACT) in Kerala and the Fertilizers Corporation of India (FCI) in Bihar. This was during the forties and the fifties. The aim was to create an industrial base that would provide

India with self reliability in food grains.

India witnessed significant growth of the fertilizer industry during the sixties and the seventies. By 2003, India had an installed capacity of 12.11 million MT of nitrogen and 5.36 million MT of phosphate. Today, with 57 large sized fertilizer plants manufacturing a wide variety of the nitrogenous, complex and phosphatic fertilizers, the Indian fertilizer industry is the 3rd largest producer in the world. One of the major factors that have led to the rapid increase in the production capacity of fertilizers in India is the policy environment. With the formulation and implementation of investor friendly policies, large investments poured into the private, public and co-operative sectors and this propelled the growth of the Indian fertilizer industry.

Indian fertilizer industry has reached international levels of capacity utilization by adopting various strategies for increasing the productions of fertilizers. These include the following:

  • Expansion and increase in efficiency through modernization and revamping of existing fertilizer units.
  • Reviving some of the closed fertilizer plants.
  • Using alternative sources, such as coal or liquefied natural gas for the production of fertilizers, especially urea.
  • Establishing joint venture projects with companies in countries that abound in cheaper resources of raw materials.

Global Demand for Indian Fertilizer

Global demand for Indian fertilizerhas been on steady rise and so has been its demand for fertilizer imports. India at present holds the fourth position as an exporter of fertilizer in the global market.

But its own demand for fertilizer almost equals its exporting capacity. The rapid rate of population growth and the rising demand for food products has increased the demand of fertilizer in India.

The primary factor behind the demand of fertilizer in India is the nature of Indian soil. Although the soil for agriculture is rich in silt, it is deficient in nutrients such as potassium, phosphate and nitrogen. To supplement these nutrients, India has to produce and also import fertilizers.

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Apart from the inorganic fertilizers, the demand for organic fertilizers produced in India has increased in recent years. One of the major players in the field of organic manures and bio-products is M.J. Exports. U.K is a major importer of organic fertilizer from India. Many countries prefer organic fertilizers because of the lower risks of environmental hazards

Government Policies and Indian Fertilizer Industry

Government policies and Indian fertilizer industry share a direct nexus, with pricing mechanisms, productive growth and subsidies forming the crux of the economic objectives of the government. The government policies for the fertilizer industry are devised to ensure a sustainable growth and development path in one of the most intensive sectors of the Indian economy.

Growth, production and usage of the fertilizer industry are directly dependent on the government policies. Production of foodgrain in India derives the main stimulus for its growth from the fertilizer industry. The government has intervened time and again in determining the prices, movement and distribution of the fertilizers and its successful policies have pitted India as the third largest consumer and producer of the agro-input in the world after China and the United States.

The policies pursued by the government are devised in response to the recommendations of the high-powered committees of the country. The Sivaraman Committee Report (1966) highlighted the importance of the balanced use of fertilizers along with providing adequate credit support for its distribution and usage. The committee also provided inputs for realizing the importance of liberalization of fertilizer marketing that would promote the production of the domestic companies.

Major Players in Indian Fertilizer Market

The fertilizer sector in India holds a major share among the energy intensive industries of the country. The industry has shown unparalleled growth in the past few years. Although growing in an accelerating rate, the industry is faced with a number of challenges, inter alia, the lack of major plant resources such as nitrogen, phosphate and potassium. Notwithstanding these specificities, India produces both nitrogenous and phosphatic fertilizers in the domestic market. Urea and ammonium are the two popularly manufactured nitrogenous fertilizers in India. The various companies dedicated to the manufacture of fertilizers also produce straight phosphatic fertilizers such as single super phosphate and complex fertilizers such as di-ammonium phosphate or DAP. The lack of indigenous reserves of potash in India has stunted the production of potassic fertilizers in the country.

The Indian fertilizer industry has a capacity of 56 lakh MT of phosphatic nutrient and 121 lakh MT of nitrogen. While the private sector has a huge installed capacity for phosphatic fertilizers, capacity utilization of nitrogenous fertilizers is higher in the public sector.

Challenges before Indian Fertilizer Industry

The growth trajectory of the Indian fertilizer industry has camouflaged the impending challenges with which it is faced.

Growth and development of agriculture in India derives a significant stimulus from the fertilizer industry. Agricultural milieu in India could be jeopardized by the uncertainties in the fertilizer industry. The government is faced with the piquant situation, which demands a balance between the needs of the farmers and the fertilizer manufacturers.

The challenges before the Indian fertilizer industry relate to the incertitude in the supply of fertilizers. There has been a surge in the demand for fertilizers in the past few years. Good monsoonal showers have led to the growth in agriculture, inadvertently increasing the consumption rate of fertilizers. However, the robust growth in consumption propensity has not been met with the required surge in fertilizer production. This has widened the gap between the demand and supply of fertilizers, which has led to an increase in the dependence of the country on imports. This also reflects on the lack of realizing of the domestic capacity utilization of the reserves in the country.

Concluding remarks on Indian Fertilizer Industry

The Indian fertilizer industry has helped in the growth of the Indian economy. The fertilizer sector by enhancing the agricultural productivity has in turn resulted in providing a major support to the farmers who are primarily dependent on agriculture. Fertilizers have also played a pivotal role in India's food Security.

For the Indian government, food has been the primary objective owing to its huge population. In India, therefore the fertilizer industry has wielded immense influence, like no other sectors in India.

To cater to the needs of the individual, government top priority has been towards production of food grain. Since the poor farmers could not afford to buy expensive fertilizing agents, the government's interventionist policy helped in providing the farmers fertilizers at a reasonable cost. The government formulated the Retention Price-Cum Subsidy scheme which has been a major impetus for the fertilizing industry since 1977 to 1992.

The following data compares the consumption against the production of fertilizers in India over the years.

Increase in fertilizer consumption:

  • 1950-51: .07mn Mts
  • 1975-76: 2.9mn Mts
  • 2005-06: 20.3mn Mts

Increase in fertilizer production:

  • 1951-52: .04 million Mts
  • 1975-76: 1.8mn Mts
  • 2005-06: 15.5mn Mts

These periods also witnessed a rapid increase in food grain production, which was estimated to be initially 121 million tons from 52 million tons and finally increased to 208 tons.

At present the government has formulated a new pricing scheme (NPS) replacing the RPS.

The fertilizer industry of India is not same in terms of stock, its yield, and technology. Because of this, the urea plants have been assorted into groups to reduce them from being diverse and incomparable under the NPS scheme. The NPS has been modified, promoting further investment in the Indian fertilizer sectors.

The Fertilizer Association of India (FAI) has been set up a model which is based on several factors that include fertilizer prices, high yielding areas, irrigated areas, fertilizer nutrient prices and previous years' fertilizer consumption. An estimate of the demand and supply till the end of the 11 th five year plan is given in the chart below:

Today, India stands as the third largest fertilizer consumer and producer of the world. It has been observed that the subsidies on Indian fertilizer have been rising at constant rate. This is due to the rise in the cost of production and the inability of the government to raise the maximum retail price of the fertilizers. The population of the country is rapidly increasing at 1.5% annually. This requires higher production of food grains. The total cropped area is only 30% of the net geographical area, which is not enough for increasing the agricultural productivity.

Now, the main focus is on the improvement of the farm income, for which the fertilizer industry needs to lay more stress on the agricultural activities in the country. This will also help to improve terms between the government agencies and the fertilizer industry in India.


In order to secure health with high life expectancy and to become self-efficient, which means supply and demand for domestic consumption is guaranteed, each government must strive and direct all its efforts towards increasing renewable resource production, thereby maintaining or reducing its demand by diversification of the staple food and at the same time remove health hazardeous wastes. Increased monoculture with a single outlet will continue to cause problems to farmers and the ecological environment. In order to foster de-urbanisation, the farmer has to be offered attractive alternatives, which means security through a change froma mono- to a multiple-product agricultural industry. This alternative must include clean technologies providing the people with a cleaner environment [prevention of infectious diseases], food, feed, fertiliser, fuel as well as energy. In SE Asia and parts of the Pacific Region, the sagopalm (Metroxylon sagu)is a unique renewable resource and was therefore selected for this presentation. The palm grows well in swampy areas unsuitable for other crops, is very suitable for humid tropical low lands and contains an average of 160 kg starch, which can be increased to 275 kg in a well attended farm. This means that an average 25 t of starch/hectare sagopalm cultivation could be obtained. A comprehensive socio-economic integrated biosystem will be presented, whereby the sagopalm farm can be used to supply (1) house building material (2) energy through gasification (3) mushroom production (4) starch flour (5) ethanol for biofuel (6) methane or biogas for energy (7) aquaponics and fish production for food (8) microbial protein for animal feed (9) compost or other residual effluent for organic fertilisation of the farm Such a system would increase self-efficiency on the farm, clean environment through reutilisation of the so-called 'waste' into value-added products and thus greatly increase the income of the farming community.


It was 2003 when Jason O'Brien got sick of watching binners and crows rip through the large blue garbage container in the vacant lot outside his kitchen window -- the vacant lot underneath the SkyTrain on Commercial Drive. It couldn't be used for either residential or commercial space, but O'Brien had bigger outcomes in mind for the aesthetically displeasing piece of land anyway.

Imagine if he could turn his backyard mess into a rehabilitation centre, a mechanism to reduce crime, promote community, give recreational space and produce food?

It may sound like a lofty goal, but anyone familiar with community gardens will mention the above benefits. Hence MOBY was born. MOBY, an acronym for "My Own Back Yard," is one of the newest community gardens in Vancouver.

Community gardens like MOBY are primarily hobbies here in Vancouver, but internationally they are known for their ability to feed entire cities. This form of inner city food production is known as urban agriculture, a widely discussed topic at the recently held 2006 World Urban Forum in Vancouver.

No veggies in the city

The term urban agriculture is relatively new, as is the acceptance of urban agriculture as a viable form of sustainable food practice in the city. As few as 20 years ago, putting the words urban and agriculture together would have been unheard of. In the past, urban agriculture has been viewed by governments as a form of squatting in which people used land that they had "no right" to be on in order to obtain some form of food security.

But food shortage crises and rising concerns about declining oil supplies have begun to give urban agriculture some legitimacy in the eyes of municipalities all over the globe. The David Suzuki Foundation estimates that much of our food travels over 2,400 kilometers just to get to our dinner table. What's even more astounding is that the production of the food needed to feed a family of four, including packaging and distribution, releases up to eight tons of carbon dioxide annually.

Add to that the current migration of the world's population to cities -- with nearly 50 per cent of people in the world living in urban environments -- and urban food security becomes a huge issue.

The city -- our beautiful construct of industry, services and the arts -- must be reconceptualized. Where it was previously a place where citizens could live entire lives without realizing that food comes from somewhere other than a grocery store, it must become a place where we integrate agricultural knowledge and urban life.

Urban dirt

Urban agriculture encompasses production, processing, and marketing, not only of vegetables, but of eggs, meat, flowers and dairy products as well. It was estimated by the United Nations Development Agency in 1996 that 15 to 20 per cent of the food produced in the world is produced by some 800 million urban and peri-urban farmers and gardeners.

Many cities in the world have already taken the plunge and are accepting and promoting urban agriculture. Cities like Havana, Cuba; Kampala, Uganda; and Rosario, Argentina have done so in response to desperate food shortages, which forced them into accepting innovative ways of managing food needs. Due to such a food crisis following the fall of the Soviet Union in 1991, Havana, Cuba, has become a fully self-sustaining city.

Before 1991, Cuba had been importing as much as 50 per cent of its food from Eastern Europe under special trade agreements. The documentary Seeds in the City: The Greening of Havana explains that Havana also had a gasoline shortage, which kept trucks from importing food from rural Cuba into the cities. This combination of events left Cuba with a dire food shortage.

In response to the food shortage, Cubans began to grow their own food within cities, despite strict laws against urban agriculture in places like Havana. Spaces such as rooftops, balconies and vacant lots were used for food production. The government soon warmed up to the idea, and grants of land were made to any person who promised to grow food on it. Markets were opened and urban food production not only helped to feed citizens, it eventually became profitable for urban farmers.

Follow Havana

Havana has set an example for the success of other cities wishing to adopt formalized versions of urban agriculture. John Ssebaana Kizito, former mayor of the city of Kampala in Uganda, boasted of urban agriculture's success in his city at the World Urban Forum.

Kampala farmers not only provide fruits and vegetables, they also supply 70 per cent of the poultry products consumed in the city. In addition to food security, agriculture in the city of Kampala has opened up new job opportunities for people migrating to the urban setting.

Back in Vancouver, a wealthy global city in the first world, we are also recognizing the benefits of urban agriculture. The city of Vancouver has recently set a goal to increase the number of community gardens in the city from 900 to 3,000 by the year 2010. Or, as they say, increase the gardens to 2,010 by 2010.

It's clear, however, that Vancouver is not in a state of food crisis. In fact, with the Agricultural Land Reserve so close to and even covering some of Vancouver's urban centre, practices such as urban agriculture can seem almost redundant. So why are we taking steps towards increasing the amount of urban agriculture in our city?

Food stress

"We currently have a sufficient amount of food," explained Herb Barbolet, food consultant for the local organization Farm Folk/City Folk. Despite this, we have reason to increase urban agriculture now. "Obviously, with population pressures, this is going to get more and more problematic," said Barbolet. "With globalization of the food system [the capacity to obtain food] it's only going to get worse."

While we may not be out to produce enough food to take up a substantial portion of our Vancouverite diet, urban agriculture and community gardening have a number of other benefits. Despite decades of neglected agriculture and materialism amongst urban dwellers, awareness about food security is raising rapidly in the city.

"A lot of young people are very smart with issues of food security," said Barbolet.

Strathcona Community Garden, located in Vancouver near Clark and Venables, began for reasons of food security. "The people who did the backbreaking work to start [the Strathcona] garden were from the hotels in the Lower Eastside," said Muggs, an organizer of the Strathcona Community Garden, referring to the garden's inception in 1985. Since then, it has become a diverse and eclectic garden with 290 plots, 200 fruit trees and beehives that produce up to 5,000 pounds of honey in a year.

Social growth

Despite the initial intent of food production, the Strathcona Community Garden is now more concerned with fulfilling a desire to cultivate social and educational benefits, such as greening the city, health, exercise, recreation, increased community and increased safety in neighborhoods.

For people concerned with the high prices related to organic food, growing their own food is sometimes a viable option -- that is, if they're prepared for the year-round TLC a garden needs. For those willing to take up a new hobby though, gardening may be just the ticket.

"We have people who don't even have a plot who come down to join the work party," explained Muggs, referencing Strathcona's monthly work parties in which 40 to 60 gardeners come together to help manage the gardens and orchards. The community aspect of the gardens is an appealing draw to all its members. O'Brien has already noticed the social benefits of the newly formed MOBY. Although the garden members are primarily people he invited from his community, there are many people under 30, most of whom are socially and politically conscious. He dreams of the space being a place that is aware, political and sexy.

The benefits of community extend beyond just socializing with one another. Making eye contact, chatting and knowing your neighbours increases security and reduces crime in neighbourhoods because people begin to look out for one another and respect each other. The cleaning and greening of previously vacant space reduces crime because managed land is more respected -- by people of all social classes -- than desolate wasteland.

The garden project has become something that O'Brien has become deeply invested in. Members of MOBY are planning to compile a web site with resources for starting gardens as well as initiate a network of gardens across the city, allowing gardeners to share knowledge and experiences beyond their own plots of land.

An increase in urban agriculture in Vancouver is good, if only for disaster mitigation. While even 3,000 community gardens is a far cry from cities like Berlin, Germany -- which has around 80,000 gardens -- the head start Vancouverites are getting on potential food shortages is important.

Urban agriculture in the developed world serves a different purpose than that of developing countries. Rather than needing it for food production, we desire it for community development and disaster mitigation. Nevertheless, the importance of understanding how food is cultivated and linking urban lifestyles with agricultural knowledge will lead to increasingly sustainable cities. Ideally, the understanding of gardening on a basic level will help us to determine more efficient ways to use the land, our waste and our resources in the future.

Amanda McCuaig has been an editor at Simon Fraser University's student newspaper The Peak for the past two years.


Instead of traditional separate application of organic, lime and "mineral" fertilizers the complete fertilizers has been designed that enable the application of all fertilizers in one dressing. In the complete fertilizers as organic matter component is used partly slowly decomposed form like brown coal, partly fast decomposed form like straw or bark and partly the form of high water holding capacity like peat or lignocelulose. As lime is used partly calcium carbonate and partly calcium oxide or hydroxide keeping the pH of fertilizer in proper alkaline range enabling the ammonification process in the fertilizer mass. As industrial fertilizers are used partly regular and partly slowly releasing forms.

Problems of the concentration of mineral salts in nutrient solution and in organic substrata as depending from capillary movement and distribution and activity of root system were investigated in sub irrigation method of tomato production.

The idea of this method consists in growing plants in bottomless or bottom-perforated 400-450 mm height plastic containers filled with peat or peat-bark substrata. Containers are placed in shallow layer of stagnant nutrient solution.

Distribution of tomato root system depends from air to water relationship. When optimum - 400 mm high column of substrate was used the best air to water ratio was established in the 100 to 300 mm layer above the surface of nutrient solution. About 70% of the total fine roots were present in this area and only 8% of the roots were found outside container, directly in the nutrient solution. Relative activity of the root system - measured by oxygen uptake was similar in substrate and in the nutrient solution. Therefore highest nutrient uptake took place in the area where root growth was most prolific.

It has been concluded that optimum salt concentration in the nutrient solution should be equal to the equivalent of 1 g KC1 per litre. Due to capillary movement inside substrate column this results in optimum concentration in most active root zone equal to c. 3 g KCl equivalent per liter of nutrient solution.


The Canadian Water and Wastewater Association (CWWA), established in 1986, is the national voice of Canada's municipal water and wastewater services. Approximately 200 municipal water services are corporate members of CWWA covering approximately 70 percent of the Canadians connected to municipal services. Most municipal wastewater services process a number of organic waste materials as part of their waste management programs - the majority do not sell these byproducts.

CWWA circulated information on the proposed amendments to the Fertilizer Regulations to the Wastewater And Stormwater Committee with a request for comments and concerns. CWWA also advised all members through a Communiqué outlining the proposed amendments.

The following represents a summary of their responses, provided under a number of self-explanatory headings. Relevant conclusions are shown in italics following each section.

Why are changes being proposed?

CWWA's members appreciate the specific concern of the Canadian Food Inspection Agency (the Agency), the cattle and livestock producing industries, and the consequent related industries and sectors for the proper management of the BSE risk in Canada through the control of the Specified Risk Material (SRM).

CWWA members further appreciate that a number of steps may be appropriate to manage the risk and to secure an appropriate level of public and animal health and safety. In principle therefore, CWWA accepts that some changes to the regulations may be appropriate.

What municipal products are affected by the proposed changes?

Essentially, the products affected by the proposed changes are:

  1. four by-products produced typically by municipalities from waste materials within the communities, that are exempted from registration by being included in Schedule II - provided they are sold:
    • organic product derived from waste household food materials,
    • composted manures,
    • processed sewage, and
    • compost; and
  2. fertilizers and supplements that are intended for export and labeled accordingly,

whether or not they actually contain any of the SRM.

CWWA surveyed a number of municipalities across the country and determined that very few actually have abattoirs within their boundaries processing animals that would be a source of SRM and, while there may be carcass processing facilities within the municipality (e.g., super markets, butchers, and even restaurants etc.) the carcasses they handle should be presumed to be free of SRM due to other activities and regulations managed by the Agency.

Who is impacted by the proposed changes?

The changes would affect all municipalities who sell the four products listed in Schedule II or who export such products.

How many municipalities may be affected?

It is not known how many of the more than 4000 municipalities in Canada would be presently affected since the majority of municipalities do not sell these products currently; however it is believed that a number, perhaps less than 200, do. Further, some municipalities export the products for disposal in US land fill sites, and some may export these products for sale. It has not been possible to establish the numbers who would be affected by the export condition, but definitely some would be, particularly those adjacent to the US border.

Of concern though is the strong potential for this to apply much more widely in the future. A number of municipalities are beginning to make major investments in processing the waste materials for beneficial uses. Municipal councils are beginning to seek cost recovery for their services and products, in order to meet their funding problems and in Ontario, legislation has been passed that would require full cost recovery for municipal infrastructure.

CWWA concludes that although the impacted number of municipalities may be currently modest, in the future many more municipalities will be affected. This will impose cost burdens on the municipalities and burdens on CFIA in term s of handling greater numbers of registrations. It is therefore appropriate to ensure that the benefit-cost relationship for these changes is greater than 1.

What is the approach being proposed?

There are two elements to this subject matter that are of concern to the members of CWWA:

  1. the proposed changes would close an exemption to part of the regulatory requirements - the exemption from registering the products typically produced by municipal wastewater services (and other agencies of the municipality), and the exemption for exported material that is labeled (it is presumed that bulk exports are labeled by the shipping documents accompanying the shipment); and
  2. the approach followed tackles the risk factor in all scenarios, but in respect to the Fertilizer Regulations covers the least likely area of risk or the area where the risk that is to be managed is at the lowest level.

In respect of the registration requirement for the four products currently listed in Schedule II, at first blush this would seem not to have a significant impact on municipalities, however when compared to the risk being managed, the likely benefit to the cost ratio is considered to be less than 1.

CWWA notes that no attempt was made in the regulatory proposal to assess the effectiveness of the proposal in terms of risk reduction, nor of the cost of compliance with it. This clearly needs to be remedied, and the cost-benefit effectiveness of the proposals evaluated.

The creation of a paper work process and burden with few projected benefits is not acceptable.

In respect to the risk element, it is clear that risk of BSE transmission is highest when dealing directly and initially with the SRM - i.e., in the abattoirs. The clear focus of the Agency's regulatory and inspection program (including those of provincially regulated abattoirs) should be on the source of the SRM and controlling the risk at that point. CWWA notes that this is a feature of changes proposed to other regulations. The further one gets from the raw material source, particularly in process sequences, the lower the risk. In a number of scientific research papers, this conclusion has been confirmed. For example:


Aims: The aim is to determine the risk of transmission of BSE to humans and cattle through the application of sewage sludge to agricultural land.

Methods and Results: A quantitative risk assessment based on the Source - Pathway - Receptor approach is developed. Central to the model is the estimation of the arithmetic mean concentration of BSE agent in sewage sludge. The main sources of uncertainty in the risk assessment are the degree to which sewage sludge treatment destroys BSE agent, whether there is a threshold dose for initiation of BSE infection in cattle, and most importantly, the amount of brain and spinal cord material which enters the sewer from the abattoir. Assuming 1% of brain and spinal cord is lost to the sewer from abattoirs, the model predicts a risk of BSE transmission of 7 1 x 10-5 cow-1 year-1 for cattle grazing on land to which sewage sludge has been applied.

Conclusions: The risks to humans through consumption of vegetable crops are acceptably low. Although the risks to cattle are higher, because of higher exposure to soil and greater susceptibility, the model demonstrates that sewage sludge alone cannot sustain the BSE epidemic in the UK cattle herd. Furthermore, the model suggests that recycling of BSE agent through sewage sludge will not sustain endemic levels of BSE in the UK cattle herd.

Significance and Impact of the Study: The conclusions are consistent with the findings from epidemiological studies which so far have not detected horizontal transmission of BSE (which would include transmission from contaminated pastures). The model demonstrates the importance of containment of brain and spinal cord within the abattoir

In considering the risk of SRM entering the food chain from animal processing activities or the animal husbandry chain, one must also recognize that there are a number of barriers which include the manner in which the SRM is handled at source, any rendering process or removal from the effluent by the treatment processes at the meat processing plant itself or of the liquid effluent (possibly containing solid material) discharged to the sewer and treated by a municipal plant, or in the treatment process of the residuals.

CWWA concludes that any risk that might be calculated in respect to the four materials for which the exemption from registration is removed, or of the materials that might be exported from municipal sources, is neglible.

What alternatives to the proposals may exist?

There are two:

  1. Not proceed with the deletion of Paragraph 3 (1) ©) and Items 1.14, 1.18, 1.19 and 5.1 in Schedule II, or
  2. Introduce the concept of "reasonable and probable" in the continued allowance of the exemption.

Not proceeding with the deletion of the paragraph and items is justifiable on the basis that the risk factor for BSE propagation in food and animals is trivial and neglible from these products (see the referenced article above).

Proceeding with a modified wording in the paragraph and Items could be justified on the basis that the concept is well-understood in legal circles and is entirely appropriate to consider in respect to the question of exemptions provided in legislation including, regulations.

The sections of the Fertilizer Regulations that are proposed for deletion could, instead of being deleted, be modified to include this concept (see the annex) allowing a modified exemption to remain.

Supporting these statement is the fact the all municipalities have sewer use by-laws and source control programs intended to protect their collection and treatment systems from harm, and to ensure that the products and effluents from these systems are safe to discharge to the environment or transfer to others for use.

This applies to the discharge into sewers of heavy metals and other toxic materials, corrosives and many other products of industrial and commercial activities taking place within their jurisdictions.

If managers had any grounds for believing that SRM were entering their area of control and responsibility, they would be the first to initiate steps to prevent it, and certainly would be cognizant of the economic and legal consequences of not acting in a precautionary manner.

CWWA concludes that from a risk management point of view, proceeding with the deletions is not justified in the first instance. However, it would be a viable alternative to reference the legal concept of reasonable and probable in the exemptions, thereby, placing an explicit responsibility where it is appropriate (the municipal manager) to determine the probability that SRM is likely to be present in waste materials collected or sent to the municipality for disposal and for taking responsible actions to eliminate the risk being further transferred.

General Conclusions

CWWA believes that the proposed deletion of the exemptions in the Fertilizer Regulations in Paragraph 3 (1) ©) and Items 1.14, 1.18, 1.19 and 5.1 in Schedule II is an action that is not justified on the grounds of the risk actually presented for the propagation of BSE and in public and environmental health.

In making these deletions the Agency is placing a large burden on some municipalities that will be extended to other municipalities in the future, where there is absolutely no risk of SRM because of the nature of business and other activities in the majority of municipalities (i.e., they do not have SRM sources within their communities).

CWWA encourages the Agency to protect these municipal activities by undertaking a vigorous regulatory and inspection campaign, in concert with the Provinces and Territories, to control the SRM at source and to ensure that it is properly managed at that point.