What does the Policy aim to achieve?
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.
FSC Pesticides Policy
The FSC Pesticides Policy lays out FSC's position for managing the use of chemical pesticides in FSC-certified management units in consistency with Criterion 10.7 of FSC-STD-01-001 V5-2 FSC Principles and Criteria, which requires, inter alia, the use of integrated pest management.
The addendum (FSC-POL-30-001a) lists chemical pesticides that meet the indicators and thresholds set out in Annex 1 of FSC-POL-30-001 V3-0 FSC Pesticides Policy, and therefore are considered to be highly hazardous in the FSC system and classifies them as prohibited, highly restricted or restricted. The addendum (FSC-PRO-30-001a) lists temporary derogations for the use of pesticides that are considered by FSC to be ‘highly hazardous'.
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.
What are the main requirements of the policy?
The first few sections (1-3) and Annex 1 of the Policy contain background and information on how FSC identifies and categorises Highly Hazardous Pesticides (HHPs). While these sections explain the principles of the Policy and may help your understanding of the Policy as a whole, they do not contain specific requirements you need to fulfil.
Annex 3 is only relevant in rare circumstances where an emergency situation or an order from a statutory authority requires you to use a HHP which is normally prohibited by FSC.
Annex 4 describes work which must be carried out by the UKWAS Steering Group, as the formally registered FSC Standard Development Group in the UK.
The most important sections for you are 4, 5 and 6, along with Annex 2. You will also need to be aware of the categorisation of any chemicals pesticides you might need to use in FSC-POL-30-001a EN FSC Lists of highly hazardous pesticides. The main requirements of the Policy which are relevant to you as an FSC Forest Management certificate holder are set out below.
You must give preference, as a matter of principle, to:
1. non-chemical methods over chemical pesticides,
2. chemical pesticides not listed in the FSC lists of HHPs over those listed in the FSC lists of HHPs, and
3. FSC restricted HHPs over FSC highly restricted HHPs.
Environmental and social risk assessment (ESRA)
As part of your integrated pest management, you must undertake a comparative environmental and social risk assessment (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. The ESRA should be proportionate to the scale and intensity of your work and the potential risks (see the introduction to UKWAS), but must take into account the minimum list of types of hazards, exposure elements and exposure variables described in Annex 2 of the Policy.
You must consult the online FSC database for information on alternatives and monitoring procedures. You may, if you choose, collaborate with other certificate holders with similar pest problems and forest conditions when carrying out ESRA.
On the basis of your ESRA, you 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, you must include the results of your ESRA in site operational plans, to identify site-specific risks and adapt the generic mitigation and monitoring measures you have identified previously.
You must engage with stakeholders as per the relevant requirements in UKWAS when conducting the ESRA, and you must make the completed risk assessments and associated operational plans available to affected stakeholders upon request.
You must, proportionate to scale, intensity and risk, have programmes in place to research, identify and test alternatives to replace FSC highly restricted HHPs and restricted HHPs with less hazardous alternatives. These programmes must have clear actions, timelines, targets and resources allocated. You may, if you choose, collaborate with research institutions and other certificate holders on research programmes.
FSC Prohibited Highly Hazardous Pesticides
You must not use any FSC Prohibited HHPs except in an emergency situation or if ordered to do so by a statutory authority.
You must inform any third-party processing plants located within your certified area and any third-party nursery suppliers of the list of FSC Prohibited HHPs, encouraging them to avoid these pesticides in their processes and in the production of seedlings and other materials entering the forest. You must request lists of FSC Prohibited HHPs used by any such processing plants and nurseries suppliers.
Avoiding damage to environmental values and human health
When using chemical pesticides, you must prioritise risk prevention and mitigation over damage repair and compensation.
You must repair any damage in accordance with its magnitude, provide fair compensation when reparation is not possible, and develop mechanisms for resolving grievances and for providing fair compensation to workers and local communities.
You must keep records of chemical pesticide usage, including:
- Trade name,
- Active ingredient,
- Quantity of active ingredient used,
- Period of use,
- Number and frequency of applications,
- Location and area of use and
- Reason for use.
The table on page 25 of the Policy gives a useful summary of the tasks you must carry out and their purpose.
What does this mean for me in the UK?
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.
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 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).
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.
Where can I find help and information?
Hopefully the information on this page has shown that you are already close to fulfilling the requirements of the new Pesticides Policy. In due course, once international generic indicators have been produced, specific requirements for Highly Hazardous Pesticides likely to be used in the UK will be developed; you will then have to comply with these requirements in addition to the ESRA requirements. In the meantime, you may find the sources of information listed under Resources, below, useful.
To help you comply with ESRA requirements, FSC UK and the UKWAS Steering Group have produced national level ESRAs for key active ingredients likely to be used in UK forest management; risk assessments are currently available in the Resources section for acetamiprid, glyphosate and propyzamide. You are not obliged to rely on the guidance in these national level documents, although doing so will make it easier for auditors to determine that you are taking an appropriate approach to your own ESRA. Also, bear in mind that you are not obliged to use FSC’s template for ESRAs, and may use your own template for risk assessments, provided you cover all of the content requirements of the Policy. We suggest that you use the contents of these national level ESRAs to guide your own work on any pesticides you consider using; you’ll see that there is quite a lot of overlap between the ESRAs in terms of basic protections for workers and the environment, but also specific controls tailored to the particular risks presented by specific chemicals.
Remember that the ESRA process, as part of an integrated pest management approach, is intended 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 at the management unit level. Neither national level nor management unit level ESRAs are intended for use in the field, but your ESRA must inform your operational level planning. Scottish Woodlands have very kindly provided an example of an operational document, which you can find in the Resources section below.
The national level ESRAs for acetamiprid and glyphosate reference the latest draft of the HHP international generic indicators. Interpretation INT-POL-30-001_07 was updated on 25 June 2020 to further clarify how these draft HHP indicators should be taken into account in environmental and social risk assessments.
The Pesticides Policy allows you to collaborate with other certificate holders facing similar problems.
The Policy also allows you to collaborate with research institutions, like Forest Research.
You can also seek the advice of your certification body, group scheme manager, or FSC UK.