FSC-US announces 45-day stakeholder consultation period for pesticide derogation applications in the US.

FSC-US is soliciting comments on the requests that we have received from a set of certificate holders to use restricted pesticides in select FSC certified forests in the US.  These certificate holders are applying for temporary use of pesticides that have been prohibted for use by an international pesticide policy.  All stakeholders are invited, and encouraged, to submit comments on these applications for exemption.

In 2007, FSC-IC explicitly restricted the use of some “highly hazardous” chemical pesticides.  Some of the pesticides on this list were being used regularly in some FSC-certified forests in the US. As a means of facilitating transition to use of alternatives (including non-restricted pesticides or non-pesticide methods), applications were accepted from forest managers for a temporary exemption (i.e. derogation) from this restriction. To qualify for a derogation, the forest manager must: 1) demonstrate sufficient rationale for why a derogation is warranted, 2) demonstrate that sufficient measures will be taken to prevent or mitigate the hazards associated with the pesticide use, 3) demonstrate that effort has been put into seeking alternative solutions, and 4) provide ample opportunity for experts and local stakeholders to voice their support or opposition to the derogation request.

FSC-US is facilitating the expert and stakeholder consultation part of the derogation applications, beginning with a 45-day comment period that begins May 5, 2009.

Comments are now being solicited and will be accepted from all interested parties. These comments will be used by: 1) the forest managers, to revise their pesticide use plans and derogation applications, 2) FSC-US, to ensure an accurate understanding of the perspectives of stakeholders in the US, and 3) FSC- International, to approve or deny the derogation applications.

Useful information for commenters, including background material, the certificate holders requesting derogations, and the chemical pesticides being considered for derogations, is found below.

Instructions for Stakeholder Comment

The most useful comments will address the central components of the derogation applications:

• The adequacy of specified controls to prevent, minimize and mitigate the hazards of the proposed use of the FSC-restricted pesticide
• Alternative solutions that should be explored by the certificate holder that don’t require use of the FSC-restricted pesticide

Comments may address the very specific use of the FSC-restricted pesticide by one of the applicants in the area where they operate or may be more general of the needs, safety, and alternatives to the use of an FSC-restricted pesticide. Comments may be in support of, in opposition to, or with additional useful information for applicants and the derogation requests.

Details of Applications for Derogation Regarding Pesticide Use in the US

Pesticide use in FSC-certified forestry is guided by the following policy and guidance documents:

• FSC-POL-30-001 FSC Pesticides Policy (2005)
• FSC-GUI-30-001 V2-0 FSC Pesticides Policy: guidance on implementation (2007)

The following FSC certificate holders have applied for the temporary use of chemical pesticides, which until 2007 were acceptable within FSC policy. Please click on the links in the final column of the table to view the revised derogation applications. All of the chemicals have been approved for use in the United States by the U.S. Environmental Protection Agency.

The chemicals that are the subject of derogation requests include:

 Sources for the above table include (see FSC-GUI-30-001 v2 for further details):

• The e-electronic Pesticide Manual (e-PM)
• US EPA Toxics Release Inventory (US TRI) Program Table 1 http://www.epa.gov/tri/index.htm?.
• FOOTPRINT: Creating tools for pesticide risk assessment and management in Europe http://www.herts.ac.uk/aeru/footprint/en/.

European Commission (EC), Endocrine disruptors (last updated on December 1, 2003), Brussels 2003 http://europa.eu.int/comm/environment/endocrine/index_en.htm