1. New Mandate to Scher
Potential risks to human health and the environment from the use of calcium cyanamide as a fertiliser

2. What does Industry (AlzChem) expect from a new mandate to SCHER?
Only calculation models and assessment methods which are suitable and approved for fertilisers have to be used. Otherwise preferably data generated in field trials have to be taken into account.
Existing limit values for human exposure to calcium cyanamide established by the SCOEL have to be respected and applied.
The physical data of the granulated form(> 98 % of the calcium cyanamide fertiliser sold!) have to be used for a risk assessment. If the use of the powdered form would be regarded as an inacceptable risk, AlzChem is open to sell exclusively the granulated form.

3. What does Industry (AlzChem) expect from a new mandate to SCHER?
Hydrogen cyanamide and calcium cyanamide are different substances with different toxicological properties. Thus only toxicological data of calcium cyanamide have to be used to characterise potential health risks of calcium cyanamide!
Realistic scenarios for the use have to be assumed. Typical application(arable crops): kg/ha ( kg/ha N). Typical application (cabbage): kg/ha ( kg/ha N).

4. What does Industry (AlzChem) expect from a new mandate to SCHER?
The principle of uniform treatment has strictly to be followed.
The methods and calculation models used for the risk assessment for calcium cyanamide have to be applicable for all other existing fertilisers too!
All fertilisers have to be assessed in the same way and if not available yet, suitable methods have to be developed.
AlzChem is not able to develop a general system for risk assessments on fertilisers.
However, AlzChem is willing to perform field studies to generate reasonable data required for this specific case.

5. What does Industry (AlzChem) expect from a new mandate to SCHER?
Calcium cyanamide has proved to be an effective and environmentally safe fertiliser (reduced nitrate leaching, reduced NOx emissions, no soil acidification and salination, increased microbial soil activity)
It is used for more than 100 years with no harmful effects on human health and the environment observed so far.
This valuable fertiliser should remain available also for future generations of farmers!