The FSC Policy and Standard Unit is currently finalizing the new FSC Pesticide Derogation application procedure (FSC-PRO-01-004) Version 3-0. The new procedure should be approved in February-March 2012.

Background

The FSC policy regarding Integrated Pest Management implementation ensures that the relevant requirements of the FSC Principles and Criteria for Forest Stewardship are applied and has three main elements:

- The identification and avoidance of ‘highly hazardous’ pesticides;
-  Promotion of ‘non-chemical’ methods of pest management;
- Appropriate use of the pesticides that are used.

The policy requires the establishment of indicators and thresholds for the identification of pesticides recognised by FSC as being particularly hazardous, based on their active ingredients. These indicators and thresholds and the resulting list of pesticides recognised by FSC as being ‘highly hazardous’ are listed in the FSC Guidance document (FSC-GUI-30-001 VERSION 2-0).

The FSC Pesticides policy prohibits the use of these ‘highly hazardous’ pesticides in FSC-certified forest management units unless such use has been explicitly justified on specified grounds (including stakeholder consultation), adequate provisions to preferably prevent, otherwise minimize or mitigate their negative impacts and a program in place to identify alternatives. In these circumstances the FSC Board of Directors may approve a ' temporary derogation' for the specified use in a defined geographical area (usually national or sub-national).

The FSC pesticide derogation procedure specifies the requirements and procedures to be followed by FSC certified forest managers and their FSC-accredited certification body for requesting temporary derogations for the use of FSC ‘highly hazardous’ pesticides.

The objective of this procedure is to ensure that applications for temporary derogations to FSC Pesticides Policy are handled transparently, consistently, efficiently, timely and in compliance with the policy.

A National approach

This Version 3-0 introduces the option of national derogation processes in the context of National Forest Stewardship Standards as proposed by the FSC Pesticides Policy (FSC-POL-30-001 Clause 2.1 b).

As requested by many stakeholders, agreed conditions for derogation will apply nationally rather than on an individual basis, whilst still requiring certificate holders and applicants to apply individually for derogation.

Where derogations are currently granted, these will form the basis of the agreed conditions that will apply nationally instead of to the individual certificate holder. This way FSC will use all of the work done to date and save new applicants from repeating this work as is the current situation.

Where there are no derogations in place at present there will be the option for an FSC National Office (NO) to appoint a ‘National Pest Management Group’ to analyze which pesticides on the Highly Hazardous list are needed, if any, and to submit nationally agreed conditions for the derogation request to FSC.

Individual applications from certificate holders or applicants will still be required in order to demonstrate they meet the eligibility criteria and conditions of the derogation to ensure that these conditions are applied at the FMU level and the implementation is evaluated by certification bodies on a case by case basis.
The current process for individual applications will still remain an option in cases where no nationally agreed conditions for a derogation request exist.

If you have any questions or issues you would like to raise concerning the Pesticide derogation procedure or FSC Pesticide Policy in general, please contact Gregory Jean (g.jean @fsc.org).