What you need to know about how recent changes to the FSC Pesticide Policy will impact third-party nurseries.
INFORMATION BOX
Management Unit – a spatial area or areas submitted for FSC certification with clearly defined boundaries that are managed to a set of explicit long-term management objectives.
Certified Organisation – the person/entity holding or applying for certification and therefore responsible for demonstrating compliance.
It has been just over two years since the Forestry Stewardship Council® (FSC®) published their latest Pesticide Policy (FSC-POL-30-001 V3-0 EN), with its long-term aim of eliminating pesticide use in all certified forests. What does this mean for third party nurseries that supply the Forestry Sector?
Essentially, very little, as third-party nurseries fall outside the remit of the FSC’s Pesticide Policy, along with biological control, chemical pesticides used for purposes other than pest control in certified Management Units (MU) like fertilizers and the impurities found within these. However, certified Organisations are obliged by FSC to inform all third-party processing plants and nurseries about the FSC Pesticide Policy and the list of FSC prohibited chemical pesticides. They also are required to encourage them to avoid these pesticides in their processes and in the production of seedlings and other materials entering the MU.
It is therefore important for all third-party suppliers to have an overall understanding of the new FSC Pesticide Policy, the Highly Hazardous Pesticides (HHP) identified by FSC, and those HHP’s on the FSC’s Prohibited list.
Why a new Pesticide Policy?
The FSC Pesticide Policy has been revised to incorporate a risk-based approach that considers not only the hazards of the active ingredient but also under what circumstances chemical pesticides could be used. This is in line with the objectives of FSC’s Global Strategic Plan 2015-2020, as well as stakeholder feedback including that of South African forestry companies. Many criticized the previous hazard-based policy that only considered the intrinsic hazards of a pesticide and not the realizable risk (which is based on exposure to that hazard).
It is worth pointing out at this time that FSC defines a chemical pesticide as one that is synthetically produced.
The revised FSC Pesticides Policy is based on three main considerations:
- Highly Hazardous Pesticides (HHP’s) are broken into three categories: prohibited, highly restricted or restricted according to their intrinsic hazard value. With those deemed prohibited only being used in emergency situations or by Government order.
- Certified Organisations need to employ an Integrated Pest Management (IPM) framework to avoid, or aim to eliminate, the use of chemical pesticides and minimize the risks to human health and the environment, while maintaining economically viable management. Where IPM identifies the need to use a permitted chemical pesticide as a measure of last resort, an Environmental and Social Risk Assessment (ESRA) is conducted at different levels to identify the nature and degree of risk together with the measures for mitigation, and the monitoring requirements.
- The Policy highlights the importance of repairing and compensating for any damage to environmental values and human health and of monitoring both the use of pesticides and the impact of the Policy itself.
The use of an IPM framework is to ensure all alternative methods to chemical pesticides have been exhausted prior to their use. The ESRA then assesses those chemical pesticides available under National Legislation to address the pest problem based on their environmental, social and economic impact, with preference placed on using restricted HHP’s over highly restricted HHP’s. It is important to note, that the fact that a chemical pesticide is not included in the FSC’s lists of HHP’s, does not mean that it is safe. Before using a chemical pesticide not listed in FSC’s lists of HHP’s, the Organisations are required to undertake environmental and social risk assessment (ESRA).
TIPWG – making the FSC Pesticide Policy simpler for our members and their suppliers
To try and make life easier for our members and their suppliers, Forestry South Africa’s (FSA) Timber Industry Pesticide Working Group (TIPWG) has an Approved Pesticide List (APL) which can be downloaded from its website. The APL includes pesticides that are approved by National Legislation and are not on FSC’s Pesticide Policy Prohibited list. Beside each, in the left-hand column, there is an ‘R’ for Restricted, ‘HR’ for highly restricted or blank for those that have yet to be listed by FSC’s Pesticide Policy.
We would recommend that all third-party nurseries acquaint themselves with this list. If they are using products that are not included, please check them against FSC’s Prohibited HHP list. If you are using prohibited chemicals, please let those you supply know this, as it could impact their certification in the future. Equally, if you feel there is a chemical not on the TIPWG APL that should be added, please contact TIPWG secretariat Jacqui Meyer.
Written By: Jacqui Meyer
Source: FSA
