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.
Summary of requirements for certificate holders
Sections 1-3 and Annex 1 of the Policy contain background and information on how FSC identifies and categorises highly hazardous pesticides. While these sections explain the principles of the Policy, they do not contain specific requirements for certificate holders.
Annex 3 is only relevant in rare circumstances where an emergency situation or an order from a statutory authority requires the use of a HHP which is normally prohibited by FSC.
Annex 4 describes work which must be carried out by standard developers – see the information on HHP indicators, below.
Requirements for FSC Forest Management certificate holders are set out in sections 4, 5 and 6, along with Annex 2, and are summarised below.
According to clause 4.12.1 of the Policy, managers of FSC-certified forests must give preference, as a matter of principle, to:
- non-chemical methods over chemical pesticides,
- chemical pesticides not listed in the FSC lists of HHPs over those listed in the FSC lists of HHPs, and
- FSC restricted HHPs over FSC highly restricted HHPs.
Environmental and social risk assessment (ESRA)
As part of their integrated pest management, certificate holders 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 (clause 4.12.2). The ESRA should be proportionate to the scale and intensity of their work and the potential risks, but must take into account the minimum list of types of hazards, exposure elements and exposure variables described in Annex 2 of the Policy (clauses 4.12.2 and 4.12.3).
Certificate holders must consult the online FSC pest management alternatives database for information on alternatives and monitoring procedures (clause 4.12.8). They may, if they choose, collaborate with other certificate holders with similar pest problems and forest conditions when carrying out ESRA (clause 4.13.1).
On the basis of their ESRA, certificate holders 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 (clause 4.12.4).
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 (clause 4.12.6).
Certificate holders 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 (clauses 4.12.7 and 4.12.10).
Certificate holders 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 (clause 4.12.9). These programmes must have clear actions, timelines, targets and resources allocated. Certificate holders may, if they choose, collaborate with research institutions and other certificate holders on research programmes (clause 4.13.2).
FSC Prohibited Highly Hazardous Pesticides
Certificate holders must not use any FSC prohibited HHPs except in an emergency situation or if ordered to do so by a statutory authority (clause 4.12.11).
They must inform any third-party processing plants located within their 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 (clause 4.12.12). They must request lists of FSC prohibited HHPs used by any such processing plants and nurseries suppliers (clause 4.12.13).
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 and asked the members of the Group to share lists of any such chemicals they might use. 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
When using chemical pesticides, certificate holders must prioritise risk prevention and mitigation over damage repair and compensation (clause 5.1.1).
They 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 (clauses 5.1.2, 5.1.3 and 5.1.4).
Certificate holders must keep records of chemical pesticide usage (clause 6.1).
The table on page 25 of the Policy gives a useful summary of the tasks certificate holders must carry out and their purpose.
In the Resources section below, there is a flowchart which 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.
Integrated pest management in UKWAS
The FSC Forest Stewardship Standard for the UK is familiar to most forest managers as the UK Woodland Assurance Standard, or UKWAS.
The current standard, UKWAS 4, came into effect when the previous version of the FSC Pesticides Policy was in force. The previous version of the Policy took a very different approach, controlling the use of highly hazardous pesticides through a system of derogations – essentially, permission to use a particular HHP in a given country had to be granted by FSC International. UKWAS 4 refers in very general terms to certification scheme restrictions on permissible use of pesticides (requirement 3.4.4). It also sets great store by an integrated pest management strategy (requirement 3.4.2), but does not give much of a steer on what IPM means in practice.
The pre-approval draft of UKWAS 5, currently awaiting assessment and approval by FSC, goes much further in incorporating specific requirements of the Pesticides Policy, including environmental and social risk assessment. In keeping with the aim of the standard to apply to woodlands of all types and sizes, and to reduce unnecessary paperwork for smaller woods, the explicit requirement for an IPM strategy has been removed, although it remains a recommendation for larger organisations. However, there is a greater emphasis on IPM in the way requirements are presented (and the whole section covering pesticides and biological control agents is titled ‘Integrated pest management’), and more guidance is provided.
In April 2023, FSC International published FSC-STD-60-004 V2-1 EN International Generic Indicators (IGIs), which includes Annex J: International Generic Indicators for the use and risk management of highly hazardous pesticides. This version of the IGIs will come into effect on 1 July 2023. The development of these IGIs was mandated by the Pesticides Policy (clauses 4.8 and 4.9), and incorporating them into Forest Stewardship Standards (clauses 4.10 and 4.11) will be the last stage in implementing the Policy.
On the basis of environmental and social risk assessment, standard developers will have to consider each restricted or highly restricted HHP currently used or likely to be used in the country, and determine whether or not its use is permissible (FSC Pesticides Policy Annex 4, clauses 1 and 2). For each HHP permitted for use, standard developers must develop indicators and locally relevant thresholds, using the IGIs as a starting point (Annex 4, clauses 3 and 4).
As UKWAS 5 had already been submitted for approval before the HHP IGIs will come into effect, the identification of specific HHPs which may be used in the UK, and any requirements and thresholds for their use and risk management, will be deferred until the development of UKWAS 6. In the meantime, HHPs may be used in FSC-certified forests as long as the requirements of the Pesticides Policy are met.
Clause 4.12.5 of the Policy requires certificate holders to conform with the applicable international and national indicators and thresholds for the use of HHPs. As we are still in a transitional stage until UK indicators and thresholds have been developed, certificate holders are advised to incorporate the HHP indicators in their environmental and social risk assessments as per interpretation INT-POL-30-001_07.
To help certificate holders comply with ESRA requirements, FSC UK and the UKWAS Steering Group have produced national level ESRAs for acetamiprid, glyphosate and propyzamide. Readers should note that these predate the final version of the HHP IGIs. Certificate holders are not obliged to rely on the guidance in these national level documents.
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 ESRA must inform operational level planning. Scottish Woodlands have very kindly provided an example of an operational document.