Thursday, 14 May 2020
Helping our certificate holders to comply with the FSC Pesticides Policy
As forest management certificate holders transition to the requirements of the revised FSC Pesticides Policy, FSC UK and the UKWAS Steering Group have joined forces to produce national level guidance documents.
The latest version of the FSC Pesticides Policy was published in May 2019. It sets out FSC’s overall approach to controlling the use of pesticides in the context of integrated pest management,and specific restrictions on the use of Highly Hazardous Pesticides (HHPs). In particular, it replaces the previous system of derogations with an approach based on environmental and social risk assessment (ESRA).
The Policy requires certificate holders, as part of their integrated pest management, to undertake a comparative 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 this ESRA, they 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,certificate holders must include the results of their ESRA in site operational plans, to identify site-specific risks and adapt the generic mitigation and monitoring measures they have identified previously. They must engage with stakeholders when conducting the ESRA, and must make the completed risk assessments and associated operational plans available to affected stakeholders upon request.
To help certificate holders to comply with these requirements, the Policy allows for national level ESRAs to be carried out,which forest managers can then refer to when developing their own ESRAs. Working with the UKWAS Steering Group, FSC UK has produced three national level ESRAs for key chemical pesticides used in UK forestry:
- Acetamiprid, an insecticide classified by FSC as a Restricted HHP
- Glyphosate, a herbicide classified by FSC as a Restricted HHP
- Propyzamide, a herbicide classified by FSC as a non-HHP
These are freely available via the Resources section of FSCUK’s Pesticides Policy webpage.
“We hope forest managers will find these national level ESRAs useful,” says FSC UK Forest Standards Manager Dr Owen Davies. “There is no compulsion to use them – just as certificate holders are not obliged to use FSC’s ESRA template, and may use their existing risk assessment templates as long as they fulfil all of the requirements of the Policy – but they should offer useful guidance, and will provide a baseline for auditors to ensure consistent implementation of the Policy.”
“It’s really important to be clear about the intended use of these environmental and social risks assessments,” adds Owen. “They are absolutely not operational level documents – and there is certainly no expectation that contractors will be presented with these weighty risk assessments in the field, for example! But they are necessary to ensure that managers take into account the full range of potential environmental and human health impacts of chemical pesticide usage, and take appropriate steps to mitigate those risks in their operational plans.”
FSC International is in the process of developing a set of International Generic Indicators for the use and risk management of HHPs, although the first public consultation has ended and the next stages of this process are on pause as part of the organisation’s response to the COVID-19 pandemic. In due course,these will be adapted into national indicators for specific chemicals –compliance with these indicators will be compulsory for FSC forest management certificate holders in the UK. For more guidance on transition arrangements for the Pesticides Policy, see the FSC UK website. We hope to produce further national level ESRAs for the benefit of UK certificate holders, but this is also likely to be subject to delay as lockdown limits engagement with some key stakeholders. If you have any questions, please don’t hesitate to contact Owen at firstname.lastname@example.org.