FSC Pesticides Policy

(© FSC GD)© FSC GDThis page is intended to help current and potential Forest Management certificate holders in the UK understand and comply with FSC’s Pesticides Policy. It may also be of interest to other stakeholders, and there are links to further sources of information on pesticides in the FSC system in the Resources section.


The Pesticides Policy was recently revised, and the latest version, FSC-POL-30-001 V3-0 EN, was published on 1 May 2019 and becomes effective on 1 August 2019 (but see the important note (right sidebar) on transition arrangements regarding the timescale for implementation).

If you are complying with UKWAS requirements, UK regulatory requirements, and industry best practice on the use of chemical pesticides, you are probably already meeting most of the demands of the Policy. You will just need to check that you are addressing some of the specific issues raised in the Policy in the right way.

What does the Policy aim to achieve?

The short-term objectives of the 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.

What are the main requirements of the Policy?

The first few sections (1-3) and Annex 1 of the Policy contain background and information on how FSC identifies and categorises Highly Hazardous Pesticides (HHPs). While these sections explain the principles of the Policy and may help your understanding of the Policy as a whole, they do not contain specific requirements you need to fulfil.

Annex 3 is only relevant in rare circumstances where an emergency situation or an order from a statutory authority requires you to use a HHP which is normally prohibited by FSC.

Annex 4 describes work which must be carried out by the UKWAS Steering Group, as the formally registered FSC Standard Development Group in the UK.

The most important sections for you are 4, 5 and 6, along with Annex 2. You will also need to be aware of the categorisation of any chemicals pesticides you might need to use in FSC-POL-30-001a EN FSC Lists of highly hazardous pesticides. The main requirements of the Policy which are relevant to you as an FSC Forest Management certificate holder are set out below.

General principles

You must give preference, as a matter of principle, to:

1. non-chemical methods over chemical pesticides,
2. chemical pesticides not listed in the FSC lists of HHPs over those listed in the FSC lists of HHPs, and
3. FSC restricted HHPs over FSC highly restricted HHPs.

Environmental and social risk assessment (ESRA)

As part of your integrated pest management, you must undertake a comparative 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. The ESRA should be proportionate to the scale and intensity of your work and the potential risks (see the introduction to UKWAS), but must take into account the minimum list of types of hazards, exposure elements and exposure variables described in Annex 2 of the Policy.

You must consult the online FSC database for information on alternatives and monitoring procedures. You may, if you choose, collaborate with other certificate holders with similar pest problems and forest conditions when carrying out ESRA.

On the basis of your ESRA, you 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, you must include the results of your ESRA in site operational plans, to identify site-specific risks and adapt the generic mitigation and monitoring measures you have identified previously.

You must engage with stakeholders as per the relevant requirements in UKWAS when conducting the ESRA, and you must make the completed risk assessments and associated operational plans available to affected stakeholders upon request.

Research

You must, proportionate to scale, intensity and risk, have programmes in place to research, identify and test alternatives to replace FSC highly restricted HHPs and restricted HHPs with less hazardous alternatives. These programmes must have clear actions, timelines, targets and resources allocated. You may, if you choose, collaborate with research institutions and other certificate holders on research programmes.

FSC Prohibited Highly Hazardous Pesticides

You must not use any FSC Prohibited HHPs except in an emergency situation or if ordered to do so by a statutory authority.

You must inform any third-party processing plants located within your certified area and any third-party nursery suppliers of the list of FSC Prohibited HHPs, encouraging them to avoid these pesticides in their processes and in the production of seedlings and other materials entering the forest. You must request lists of FSC Prohibited HHPs used by any such processing plants and nurseries suppliers.

Avoiding damage to environmental values and human health

When using chemical pesticides, you must prioritise risk prevention and mitigation over damage repair and compensation.

You must 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.

Monitoring

You must keep records of chemical pesticide usage, including:

  • Trade name,
  • Active ingredient,
  • Quantity of active ingredient used,
  • Period of use,
  • Number and frequency of applications,
  • Location and area of use and
  • Reason for use.

Summary

The table on page 25 of the Policy gives a useful summary of the tasks you must carry out and their purpose.

What does this mean for me in the UK?

The Policy requirements may seem onerous at first, but in reality you are probably already complying with most of them if you are meeting the requirements of UKWAS. While it is important for you to satisfy yourself that you are doing everything asked of you by the Policy, as this is what auditors will be checking, the following sections hopefully show that you may not have too much extra work to do.

General principles

UKWAS already requires you to have an integrated pest management strategy which promotes the development and application of non-chemical methods of pest and crop management by placing primary reliance on prevention (UKWAS 3.4.2(a)). The standard also states that you can’t use pesticides whose use is restricted by FSC unless there are no effective and practicable alternatives available (UKWAS 3.4.4(b)). When justifying pesticide use (UKWAS 3.4.2(c) and 3.4.4(b)), you will already almost certainly be choosing the least hazardous options available; now you will just need to make sure that you are taking into account FSC’s categorisation of Restricted and Highly Restricted HHPs.

Environmental and social risk assessment (ESRA)

If and when you are justifying pesticide usage, you should already be taking into account economic, social and environmental costs (UKWAS 3.4.2(c)). Now you will need to make sure that you take into account all of the hazards, exposure elements and exposure variables described in Annex 2 of the Pesticides Policy, although you are not obliged to use the ESRA template provided by FSC and may continue to use your own risk assessment templates if they are fit for purpose. You will now need to consult the online FSC database regarding alternatives and monitoring procedures, and remember that you may choose to collaborate with other certificate holders when carrying out ESRA.

In complying with UKWAS and industry best practice (UKWAS 3.4.3), you are probably already choosing the control option with the least potential for social and environmental damage, the greatest effectiveness, and equal or greater social and environmental benefits, and incorporating the relevant elements of ESRA in your site level operational plans.
UKWAS already requires you to engage stakeholders in your management planning and monitoring processes (UKWAS 2.3.1(c)), and to make management planning documentation available on request (UKWAS 2.2.2).

Research

Research is already underway in some cases to identify less hazardous alternatives to HHPs, particularly for weevil control. In most cases it will make sense for you to collaborate with existing, coordinated research, as the Policy allows, rather than trying to undertake your own research in isolation.

FSC Prohibited Highly Hazardous Pesticides

You will need to be aware of the list of FSC Prohibited HHPs. Hopefully you will never have any call to use any of them, but if necessary you must refer to Annex 3 of the Policy to make sure you follow the rules governing emergency use or government orders.

Rather than individual certificate holders contacting nurseries regarding FSC Prohibited HHPS, it is proposed that these requirements will be addressed via the Confor Nursery Producers’ Group.

Avoiding damage to environmental values and human health

UKWAS already requires you to avoid, mitigate and/or repair damage to environmental values from pesticide use, and to take steps to avoid recurrence (UKWAS 3.4.1(c)); you must now ensure that you prioritise avoidance and mitigation.

Minimising risks to human health is addressed in UKWAS by insisting on best practice in pesticide application (UKWAS 3.4.3) and appropriate worker competency (UKWAS 5.4.1(c)).

UKWAS already contains requirements for resolving grievances with communities (UKWAS 5.2.2) and workers (UKWAS 5.6.1(d)), and fair compensation is addressed through the requirement for adequate public liability and employer’s liability insurance (UKWAS 5.7.1).

Monitoring

UKWAS already requires you to keep records of pesticide usage as per legislation (UKWAS 3.4.3), and to monitor and record pesticides usage and any adverse impacts (UKWAS 2.15.1(c)); in complying with these requirements, you are probably already compliant with the record keeping requirements of the Pesticides Policy.

Where can I find help and information?

Hopefully the information on this page has shown that you are already close to fulfilling the requirements of the new Pesticides Policy. In due course, once international generic indicators have been produced, specific requirements for Highly Hazardous Pesticides likely to be used in the UK will be developed; you will then have to comply with these requirements in addition to the ESRA requirements. In the meantime, you may find the sources of information listed under Resources, below, useful.

Remember that the Pesticides Policy allows you to collaborate with other certificate holders facing similar problems.

The Policy also allows you to collaborate with research institutions, like Forest Research.

You can also seek the advice of your certification body, group scheme manager, or FSC UK.

Resources

A word about standards

There are a number of references on this page to specific requirements in UKWAS, the UK Woodland Assurance Standard. This is the user-friendly version of the FSC national forest stewardship standard which is familiar to most forest managers in the UK.

You should be aware, however, that the formal basis for auditing is the official FSC version of the standard, FSC-STD-GBR-03-2017 V1-0 EN; this contains the same requirements as UKWAS, but in a different order and accompanied by the text of the FSC Principles and Criteria.

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Transition arrangements

Transition arrangements are set out on page 8 of the Policy. You will need to comply with ESRA requirements even before international and national indicators have been defined.

If you want to use a Highly Hazardous Pesticide for which UK certificate holders have previously held a derogation, such as cypermethrin or alpha-cypermethrin, you will need to include the derogation conditions in your ESRA.

Interpretation INT-POL-30-001_07, which was updated on 19 June 2019, provides important additional detail and timelines for implementing the Policy. Once draft international generic indicators have been published you will need to comply with them if you are using HHPs.

You only need to comply with the ESRA requirements for newly listed HHPs (e.g. glyphosate), those HHPs that did not require a derogation under the previous regime (e.g. acetamiprid), and non-HHP chemicals from 1 August 2020, although we recommend that you start to implement the requirements sooner. If you have any doubts about the status of specific chemical pesticides, please contact FSC UK.

In due course, you will be required to conform with applicable international and national indicators and thresholds for the use of HHPs (clause 4.12.5). FSC International has not yet produced generic indicators for hazard groups, so it has not yet been possible to produce requirements tailored to specific chemicals in the UK context.

When this changes, certificate holders will be informed of the need to update their ESRAs to take into account any additional requirements. In the short term, however, UK certificate holders may find it useful to refer to draft indicators developed during a pilot project on glyphosate; see Resources below.

In addition, to help you in developing your own ESRAs, the UKWAS Steering Group has agreed to produce national level ESRAs for key pesticides likely to be used in the UK (as allowed for on page 24 of the Policy). Once these national level ESRAs are available, we will add them to the Resources section. These will be provisional, and will be updated when international and national indicators and thresholds have been produced.

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Which Highly Hazardous Pesticides are likely to be relevant to me?

Of the HHPs identified by FSC, you are most likely to need to use glyphosate for vegetation control or acetamiprid for weevil control, both FSC Restricted HHPs. ESRA requirements for these two chemicals will apply from 1 August 2020.

You are unlikely to choose to use more hazardous alternatives for weevil control, like cypermethrin or alpha-cypermethrin, both of which FSC Highly Restricted HHPs, but if you do, ESRA requirements will apply from 1 August 2019.

But don’t forget that, from 1 August 2020, ESRA requirements apply for any chemical pesticides, regardless of whether they are HHPs (clause 4.12.6 in the Pesticides Policy, and INT-POL-30-001_07).

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