Monday, 03 March 2014
Public consultation on Pesticide Derogation Procedure / Indicators and Thresholds
FSC-PRO-30-001 (Pesticide Derogation Procedure) and FSC-STD-30-001 (Indicators and thresholds for the identification of ‘highly hazardous’ pesticides) are under consultation until 30 April 2014.
FSC-PRO-30-001: Pesticide Derogation Procedure
Background: This document defines the process on how FM certificate holders can apply for a derogation to use ‘highly hazardous’ pesticides on certified lands. Please note that we consulted this procedure in the first round under the old document code FSC-PRO-01-004 more than a year ago.
Main differences between Draft 1 and 2: We introduced a mechanism for National Offices to set up an experts group and to become involved in the evaluation of derogation applications. This is in response to a request from the FSC membership expressed in GA Motion 2011:23. We further clarified the use of pesticides in the case of governmental orders and the re-application process. We also had to adjust the fees to cover the administrative costs of managing the derogation process.
Who should provide comments? This procedure is mainly developed for FM certificate holders that have a demonstrated need to use ‘highly hazardous’ pesticides on certified lands. The procedure is also relevant for FSC National Offices that are planning to set up national capacities to become involved in the evaluation of derogation applications. All other stakeholders are of course also invited to submit their comments.
FSC-STD-30-001: Indicators and thresholds for the identification of ‘highly hazardous’ pesticides (HHP)
Background: This document includes the criteria, indicators and threshold to determine ‘highly hazardous’ pesticides in the FSC system. With this draft we extracted the criteria and the list of ‘highly hazardous’ pesticides from the pesticides guideline (FSC-GUI-30-001) to give it a more formal mandatory status.
Main differences between Draft 1 and 2: we have changed to a more user-friendly format, differentiating clearly the classification systems and the categories, and including sources of information.
The following changes have been made:
Criteria 1. Acute toxicity to mammals and birds
Changes from draft 1 to draft 2: Incomplete sentence has been completed
Criteria 2. Carcinogenicity Threshold
Changes from draft 1 to draft 2: d) from draft 1 has be deleted
Criteria 3. Mutagenicity to mammals
Changes from draft 1 to draft 2: The names of the categories have been included
Criteria 4. Developmental and reproductive toxin
Changes from draft 1 to draft 2: The names of the categories have been included
Criteria 5. Endocrine disrupting chemical (EDC)
Changes from draft 1 to draft 2: “Category 2” has been deleted from the threshold a)
Criteria 9. International legislation
Changes from draft 1 to draft 2: The names of the agreements have been included
Criteria 6, 7, 8 and 10 remain unchanged from Draft 1. Criterion 11 has not changed since the 2007 version but it was accidentally missed in Draft 1 and has been reintroduced in Draft 2.
Who should provide comments? This standard mainly affects FM certificate holders in their choice of pesticides for the use on certified lands. We also invite other stakeholders to comment, especially those with technical and scientific knowledge on national or international indicators to identify pesticides hazardous to both human health and environment.
We would like to thank everyone who submitted comments on the first drafts. The feedback has been analysed and incorporated to the draft procedure where applicable.
Both documents will be under consultation until 30 April 2014. Please, use the comments templates provided, if possible.
Please get in touch with Maria P. Melero at pesticides at fsc point org for further information.
All consultations on documents comprising the FSC Normative Framework can be found here. Please note that UKWAS 4 is also currently under consultation and further information can be found here.