The FSC Pesticides Policy, a key document regulating the use of chemical pesticides in the FSC system, has just been revised. Here we give an overview of what the Policy aims to achieve, and how.
There has been no shortage of controversy surrounding the use of pesticides in recent years, from the effects of neonicotinoid insecticides on pollinators to the possible human health risks associated with the herbicide glyphosate. While pesticide usage in UK forest management may be a fraction of that in agriculture, there is no reason for complacency.
Control of pesticides is an integral part of FSC’s Principles and Criteria, which are the basis for FSC forest management standards all around the world. In version 5-2 of the Principles and Criteria, Criterion 10.7 states that:
The Organization shall use integrated pest management and silviculture systems which avoid, or aim at eliminating, the use of chemical pesticides. The Organization shall not use any chemical pesticides prohibited by FSC policy. When pesticides are used, The Organization shall prevent, mitigate, and / or repair damage to environmental values and human health.
This is reflected in the UK national forest stewardship standard, familiar to most as UKWAS, alongside national regulatory requirements. But the Criterion also makes explicit reference to FSC policy, and a revised Pesticides Policy was published on 1 May 2019.
What does the Policy set out to achieve?
The short-term objectives of the revised FSC Pesticides Policy are to:
- Promote best practices to minimise associated risks to human health and the environment when using chemical pesticides;
- Reduce the overall volume and number of chemical pesticides in use; and,
- Eliminate the use of the most hazardous chemical pesticides.
The long-term aim of the Policy is to eliminate the use of chemical pesticides in FSC certified forests.
How does it work?
A key feature of the Policy is the use of globally consistent hazard criteria, indicators and thresholds to identify lists of Prohibited, Highly Restricted and Restricted Highly Hazardous Pesticides (HHPs).
As the name suggests, certificate holders may not use Prohibited HHPs except in an emergency or if ordered to do so by government authorities.
Any use of Highly Restricted and Restricted HHPs will be dependent on an environmental and social risk assessment (ESRA) to identify the lowest risk option to control a pest, weed or disease, the conditions for its use and the generic mitigation and monitoring measures to minimise the risks.
On the basis of the ESRA, certificate holders must select the control option that has the least potential for social and environmental damage, the greatest effectiveness, and equal or greater social and environmental benefits.
Before applying any chemical pesticide, including those which are not HHPs, they must include the results of the ESRA in site operational plans, to identify site-specific risks and adapt the generic mitigation and monitoring measures they have identified previously to site conditions.
As a matter of principle, certificate holders must give preference to:
- non-chemical methods over chemical pesticides,
- chemical pesticides not listed in the FSC lists of HHPs over those listed in the FSC lists of HHPs, and
- FSC Restricted HHPs over FSC Highly Restricted HHPs.
They must also prioritise risk prevention and mitigation over damage repair and compensation, repair any damage in accordance with its magnitude, provide fair compensation when reparation is not possible, and develop mechanisms for resolving grievances and for providing fair compensation to workers and local communities.
There are also requirements for research, monitoring, and engagement with stakeholders.
What are the main issues in the UK?
Pesticide usage is highly regulated in the UK, and UKWAS already contains substantial requirements in relation to integrated pest management.
Certificate holders are going to need to change their processes in line with the Policy, however, especially to make sure they are taking into account all required aspects of ESRA and have suitable mitigation and monitoring measures in place.
They are also going to have to make sure that they take full account of the categorisation of Highly Hazardous Pesticides when choosing control options.
The HHPs most likely to be used in the UK are glyphosate for weed control and acetamiprid to prevent weevil damage on sites which have been felled and replanted; both are Restricted HHPs.
When will all this happen?
The Policy becomes effective on 1 August 2019, after which there will be a twelve month transition period. However, even after that there will be an implementation period while International Generic Indicators (IGIs) are developed and then adapted to national conditions.
So most requirements of the Policy should be met by the end of July 2020, but certificate holders will have to adapt their environmental and social risk assessments and mitigation and monitoring measures once international and then national indicators are produced.
Where can I find out more?
The definitive guide to requirements is the Policy document itself, but FSC UK has tried to summarise what the implications might be for Forest Management certificate holders in the UK. We have also tried to convey the most up-to-date information we have on the timescale for implementation of the Policy.
How can I get involved?
FSC Forest Management certificate holders should already be engaging with stakeholders in their planning and monitoring processes. As the Policy is rolled out, stakeholders should be able to request to see risk assessments and operational plans.
The process of developing International Generic Indicators will begin shortly, and FSC International has opened a call for experts to join a technical working group; the call is open until 30 June.
Once the IGIs have been developed, probably by late 2020, it will be necessary to develop national indicators. FSC UK will be discussing with the UKWAS Steering Group how best to integrate this work with the revision of the UK Woodland Assurance Standard; as with all FSC standard development processes, there will be opportunities for stakeholders to share views and evidence.
In the short term, if you have any questions please send them to FSC UK Forest Standards Manager Dr Owen Davies at firstname.lastname@example.org.