Tuesday, 08 August 2017
Public Consultation on a Revised Pesticides Policy Now Open
All stakeholders are invited to participate in an online consultation for a revised pesticides policy (Draft 1-0). You can provide feedback until 29 October 2017
A working group has been established to revise the FSC Pesticides Policy, with the objective of identifying the best feasible approach to reduce the use of chemical pesticides in FSC-certified forests and to prevent, minimise, and mitigate the related environmental and social impacts. A first draft of the revised policy is now ready for consultation.
Although the implementing procedures have been updated as recently as 2015, the current FSC Pesticides Policy FSC-POL-30-001 (2005) EN) dates back to 2005. Some elements of this policy, such as the process for applying for ‘derogations’ to use specific highly hazardous pesticides, have proved contentious.
FSC UK urges all interested and affected stakeholders,including forest management certificate holders, to respond to the consultation after reading the consultation documents in full. The following is a brief summary of the draft revised policy (FSC-POL-30-001 V3-0 EN FSC Pesticides Policy. The overall approach to the use of chemical pesticides(draft section 1) is aligned with FSC Criterion 10.7 (in FSC-STD-01-001 V5-2 EN FSC Principles and Criteria for Forest Stewardship), which 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.
While recognising that sometimes chemical pesticides are the only feasible means of controlling pests, the FSC approach to reducing and phasing out their use and to mitigating associated impacts involves identifying and categorising highly hazardous pesticides (HHPs), regulating the use of HHP staking into account the risk they pose to human health and the environment (with risk being a function of toxicity and the local exposure to humans and the environment), repairing and compensating for damage, and monitoring the impact of the policy (draft clause 1.3).
The approach to identifying HHPs has not changed (draft section 2), but they have now been categorised into three lists – restricted,highly restricted and prohibited – according to existing criteria (draftsection 3). These lists are given in a separate document (FSC-POL-30-001a V3-0EN FSC Lists of highly hazardous pesticides).
This categorisation and the associated restrictions on the use of HHPs would replace the current derogation system.
According to the draft policy, certificate holders may only use FSC highly restricted HHPs and FSC restricted HHPs when, following an Environmental and Social Risk Assessment (ESRA), they have identified and assessed the associated risks and are controlling risk through the implementation of mitigation measures. As a minimum, these measures must include use of personal protective equipment (PPE), training, research on alternatives, warning to affected stakeholders and long term monitoring relevant to the recognized hazards (draft clause 4.5).
Certificate holders must use the least hazardous pest management alternative available, unless they can prove through ESRA that the risk mitigation measures for a more hazardous alternative are more cost-effective and have equal or greater social and environmental benefits(draft clause 4.6).
Certificate holders must prioritize risk prevention and mitigation over damage repair and compensation (draft clause 5.1).
In due course, Standard Development Groups (such as the UKWAS Steering Group) will adapt global risk assessment indicators (to be developed by FSC) to the national context and develop locally relevant thresholds for risk management of specific HHPs and forest types (draft Annex 3).
In the UK context, HHPs of interest to foresters such as acetamiprid and propyzamide are on the restricted list, so under the draft policy it would be possible to use them, subject to ESRA and suitable risk mitigation measures.
To take part in the consultation and access all of the relevant documents, register to use the FSC consultation platform at https://consultation-platform.fsc.org/.