Pesticides Policy

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.

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.

This flow chart, drafted by the working group which is developing international generic indicators for the use of Highly Hazardous Pesticides (HHPs), shows how the Pesticides Policy fits into the wider framework of integrated pest management as set out in the FSC Principles and Criteria and associated guidance. Terms in italics and followed by an asterisk are defined in the Principles and Criteria.

If a pest, disease or weed problem is identified, forest managers should always consider whether they can tolerate the problem or change their management to avoid it. If that is not possible and it is necessary to take remedial action, the Pesticides Policy requires managers to carry out a comparative environmental and social risk assessment (ESRA) to identify the most appropriate control option. The Policy instructs managers to select the control option ‘that demonstrates least social and environmental damages, more effectiveness and equal or greater social and environmental benefits’, though as a matter of principle managers should give preference to non-chemical methods over chemical pesticides, and if using chemical pesticides should preferentially use the least hazardous option. The most hazardous chemical pesticides may only be used in an emergency or by government order.

The findings of the ESRA process must inform operational plans as part of the overarching requirement to prevent, mitigate, and/or repair damage to environmental values and human health (although some findings of an ESRA might be applied at a different level, for example in the overall design of a forest). In due course, international and national indicators and thresholds will impose further controls on the use and risk management of Highly Hazardous Pesticides; for now, managers must take into account draft international indicators and may be guided by national level ESRAs for specific HHPs.

A downloadable version of the summary flow chart is available in the Resources section, below, along with FSC guidance on integrated pest management; note that this guidance is heavily influenced by Forestry Commission Practice Guide 15 Reducing Pesticide Use in Forestry, also available in the Resources section.

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, FSC UK has addressed these requirements via the Confor Nursery Producers’ Group. At a meeting of the Nursery Producers’ Group in November 2020, FSC UK presented the list of FSC Prohibited HHPs as per clause 4.12.12 of the Policy, and asked the members of the Group to share lists of any such chemicals they might use as per clause 4.12.13. Although nurseries have declined to share information on pesticide use, the requirements of the Policy have been met, and certification bodies have confirmed that there is no need for certificate holders to take any further action in relation to these clauses.

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.