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FOREST STEWARDSHIP COUNCIL INTERNATIONAL CENTER

FSC DISCUSSION PAPER

FSC-DIS-01-006

FSC Pesticides Policy:

Proposed revisions

Forest Stewardship Council A.C. 1996 All rights reserved

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FSC-DIS-01-006 FSC Pesticides Policy: proposed revisions ii

Discussion Paper

Title: FSC Pesticides Policy: proposed revisions

FSC reference code: FSC-DIS-01-006

Type of document: Discussion paper

Status of document: For comment

Date: 27 September 2005

Deadline for comments: 31 October 2005

Body responsible for drafting: Policy and Standards Unit

Contact person: Matthew Wenban-Smith

Contact email: [email protected]

Published by Forest Stewardship Council, A.C. No part of this work covered by the publisher’s copyright may be reproduced or copied in any form or by any means (graphic, electronic or mechanical, including photocopying, recording, recording taping or information or retrieval systems) without the written permission of the publisher.

The Forest Stewardship Council (FSC) is an independent, not for profit, non-government organisation based in Bonn, Germany.

The mission of the Forest Stewardship Council is to support environmentally appropriate, socially

beneficial, and economically viable management of the world's forests.

FSC develops, supports and promotes international, national and provincial standards in line with its mission; evaluates, accredits and monitors certification bodies which verify the use of FSC

standards; provides training and information; and promotes the use of products that carry the FSC logo.

FSC-DIS-01-006 FSC Pesticides Policy: proposed revisions 1

Summary FSC's current policy on pesticides (FSC-POL-30-601 FSC Chemical Pesticides Policy) was approved by the FSC Board of Directors in July 2002. The policy is designed to implement the relevant requirements of the FSC Principles and Criteria for Forest Stewardship and has three main elements:

- The identification and avoidance of highly hazardous1 pesticides; - Promotion of ‘non-chemical’ methods of pest management as an element of

an integrated pest and vegetation management strategy;

- Appropriate use of the pesticides that are used. The policy established indicators and thresholds for the identification of pesticides recognised by the FSC Principles and Criteria as being particularly hazardous, based on their active ingredients. The policy lists the most hazardous pesticides and prohibits their use in FSC-certified forest management units unless justified on specified grounds and supported by a broad range of national stakeholders (social, enviromental and economic). In these circumstances the FSC Board of Directors may approve a 'derogation' for specific use in a defined geographical area (usually national or sub-national). Since the approval of the policy a number of questions have been raised in relation to implementation, which require clarification. The policy has also attracted some criticism in relation to the technical specifications for identifying hazardous pesticides. In 2004 FSC therefore commissioned the Pesticides Action Network UK (PAN-UK) to carry out a detailed review of the indicators and thresholds, and if necessary to propose revisions. The review and recommendations were finalised in April 2005 (Review of the Forest Stewardship Council’s Pesticide Indicators and Thresholds, PAN-UK, April 2005). In May 2005 FSC published a discussion paper providing an initial response (FSC-DIS-01-003 PAN-UK Review of FSC Pesticides Indicators and Thresholds: FSC initial response). This further discussion paper takes accounts of comments on the earlier papers, and proposes that the current FSC policy now be revised in two steps. In the first step, it is proposed to clarify and streamline the current policy, but to leave the overall framework and the existing indicators and thresholds for the identification of highly hazardous pesticides unchanged. The FSC list of ‘highly hazardous’ pesticides (previously referred to as ‘FSC-prohibited’ pesticides) will be updated to include active ingredients identified in accordance with the indicators and thresholds approved in 2002. It is proposed to implement this revised policy with effect from 1st January 2006. In the second step further guidance will be developed on the implementation of the general policy framework, and the indicators and thresholds for the identification of highly hazardous pesticides will be reviewed and may be revised. It is proposed that this work should take place during 2006, with the objective of implementing any resulting guidance and/or revisions with effect from 1st January 2007. This paper presents the background to these proposals, and describes the proposals themselves in more detail.

1 The term ‘highly hazardous’ is also the term used by the World Health Organisation (WHO) for class 1b pesticides (class 1a pesticides are described as ‘extremely hazardous’. Other terms that have been proposed include “prescribed pesticides’ and ‘environmentally hazardous pesticides’. Comments are welcome


Comments on these proposals are now sought prior to finalisation and presentation to the FSC Committee on Chemical Pesticides for approval.

Notes on drafting This paper proposes revisions to FSC-POL-30-601 FSC Chemical Pesticides Policy 2002-07). It takes account of:

- Review of the Forest Stewardship Council’s Pesticide Indicators and Thresholds, PAN-UK, April 2005

- FSC-DIS-01-003 PAN-UK Review of FSC Pesticides Indicators and Thresholds: FSC initial response

The circulation of these papers elicited detailed responses from many stakeholders, and from economic stakeholders in particular. These comments have all been reviewed, and have been taken into account in this draft document. The original documents and all comments are available on request (please send an email to [email protected]). To date comments have been received from: Craig Anderson, Managing Director, Rewards Group, Australia Roger Banks, FSC Coordinator, ITC, Australia Greg Blomstrom, Forest Analyst, FSC-US, USA Tim Browning, General Manager, Forestry, Timbercorp, Australia Gavin Ellis, General Manager, Forestry, Great Southern Plantations Ltd, Australia Graeme Manley, Forest Manager for Southland Plantation Forest Company, New Zealand Carlos Jose Mendes, Forest Manager, Klabin S.A., Brazil New Zealand Forest Owners Association Colin Palmer, UK consultant Steven Radosevich, Oregon State University, USA Geoff Rolland, Forest Manager, Albany Plantation Forest Company, Australia Andrew Rouse, WWF Australia Dr Timothy Synnott, Estudios Forestales Synnott, Mexico Barry Tomkins, University of Melbourne Malcolm Tonkin, Manager Environmental Services, Hancock Victorian Plantations, Australia Professor Gerhard Verdoorn, agrochemical-environmental consultant, South Africa Stefan Wirten, Director of Forestry, Swedish Forest Industries Federation Notes on content: The intent of this paper is not to change the substantive impact of the policy approved by the FSC Board of Directors in May 2002, but rather to improve its clarity and implementation. The main changes are:

- Use of the term ‘chemical pesticides’ has been discontinued, except where this term is used in the FSC Criteria themselves. The proposed policy refers simply to ‘pesticides’.

- The informal expression ‘FSC-prohibited list’ has been replaced with the (also

informal) expression ‘FSC list of highly hazardous pesticides’. The new term emphasises the basis for inclusion on the list, and aims to avoid confusion about the authorised use of ‘prohibited’ pesticides in FSC-certified forests and plantations.


- It is proposed that for the purpose of FSC-certification the list of active ingredients considered by FSC to be ‘highly hazardous’ should be considered definitive. FSC will continue to evaluate pesticides on the basis of the specified indicators and thresholds, and will add new pesticides to the list as required. However, until and unless the active ingredient of a pesticide has been included on the list its use will not constitute a major non-compliance with the requirements of FSC standards. The FSC list will be regularly reviewed, and if an active ingredient is added to the list forest managers will have 12 months to phase out the use of any pesticides containing this active ingredient, or to receive a derogation for its use.

- The requirement to evaluate formulations and their impacts on thresholds has

been eliminated. If particular formulations are demonstrated to exceed the specified thresholds, then such formulations may be added to the list of highly hazardous pesticides. The impacts of formulations may also be considered in the context of derogations.

- The requirements and procedures for the issue of ‘derogations’ for the use of

highly hazardous pesticides in FSC-certified forests and plantations have been clarified. The overall intent is to improve the quality and to streamline applications for and evaluations of derogation requests, without introducing major changes to the overall burden or intent. Changes include clarification of the requirements relating to stakeholder consultation, a requirement for a programme of reduction to be in place, and the introduction of a default five-year period for the application of approved derogations, with a presumption against renewal.

- The list of pesticides which fail the thresholds that were established in 2002

has been updated to include pesticides which were not evaluated at that time. As a result 35 active ingredients have been added to the list. It should be emphasised that this does not represent any change of policy or tightening of implementation. The current policy obliges certification bodies to identify pesticides with active ingredients that meet or exceed the specified thresholds. The 35 pesticides to be added to the list fail the thresholds that have been specified in the approved FSC policy since 2002. By providing a definitive list of such pesticides the proposed revision would relieve certification bodies and their clients of the burden and uncertainty of carrying out these evaluations themselves.

Some proposals suggested by PAN-UK or stakeholders have not been implemented at this time:

- Many of the comments received from imply the need for changes to the threshold levels for the identification of ‘highly hazardous’ (previously referred to as ‘FSC prohibited’) pesticides. Some comments imply the need to make thresholds more demanding, others less demanding. This paper has not proposed changes to the threshold levels, but rather proposes that any such changes be discussed in consultation with stakeholders from all FSC chambers, and as a second step after the general framework itself has been clarified. If, as a result of this subsequent review there is broad agreement that the thresholds should be revised (with the possibility of the thresholds becoming either more or less demanding), then it is proposed to implement such changes with effect from 1st January 2007.


- The paper does not cover the use of biological control methods, or the use of pesticides or preservatives in manufactured products. FSC recognises the importance of these issues, but also recognises their complexity. The aim of this paper is mainly to simplify and clarify existing policy in relation to the use of pesticides in the forest – these other issues will need to be addressed in future processes.

References In addition to the documents referenced above, earlier drafts of the FSC policy have drawn heavily on a number of sources. A key reference is the study by Radosevich et al., commissioned by FSC in 1999 and published in 2000. This and other sources used in the development of the current FSC policy are listed below: Briggs, S. (1992) Basic Guide to Pesticides: Their Characteristics and Hazards. Washington, Taylor & Francis Publishers. Rachel Carson Council. British Crop Protection Council (1997) The Pesticide Manual. Hampel, C. & G. Hawley (1976) Glossary of Chemical Terms. New York, Van Nostrand Reinhold. Jenkins, A. (1998) Chemical use in UK Forestry. FSC UK Working Group Report. 70p Kamrin, M.A. (Ed.) (1997) Pesticide Profiles: Toxicity, environmental impact and fate. USA, Lewis Publishers / CRC Press. Pesticides Trust (1994) Pesticides in Forestry. London. 55 p. Radosevich, S., M.Lappé & B.Addlestone (2000) Use of Chemical Pesticides in Certified Forests: clarification of FSC criteria 6.6, 6.7 and 10.7. FSC-USA. UKWAS (2000) UK Woodland Assurance Scheme Guidance on Pest and Weed Control and the correction of Nutrient Deficiencies in Forestry (draft). World Health Organization (1998) The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification 1998 - 1999. WHO/PCS/98.21/Rev.1. 61 p. WHO Table 1, Class Ia, classified as "Extremely Hazardous" WHO Table 2, Class Ib, classified as "Highly Hazardous". WHO Table 3, Class II, "Moderately Hazardous". WHO Table 4, Class III, "Slightly Hazardous". WHO Table 5, Active ingredients unlikely to present acute hazard in normal use.


FSC Pesticides Policy: proposed revisions FSC-DIS-01-006, September 2005

Contents 1 Introduction 2 The FSC Principles and Criteria of Forest Stewardship 3 The FSC approach to the use of pesticides 4 Identification, avoidance and control of highly hazardous pesticides

4.1 FSC indicators and thresholds for ‘highly hazardous’ pesticides 4.2 FSC list of highly hazardous pesticides 4.3 Derogations and major non-compliances 4.4 National and sub-national FSC standards 4.5 Emergencies 4.6 Implementation 4.7 Monitoring

5 Decision support and integrated pest and vegetation management 6 General requirements for use of pesticides 7 Proposed FSC international policy 8 Next steps 9 Temporary derogations for newly identified ‘highly hazardous’

pesticides Annex 1 Draft FSC list of highly hazardous pesticides, August 2005 Annex 2 Template for the presentation and evaluation of derogation requests


Introduction FSC’s mission is to promote environmentally appropriate, socially beneficial and economically viable management of the world’s forests.

“Environmentally appropriate forest management ensures that the harvest of timber and non-timber products maintains the forest's biodiversity, productivity, and ecological processes. “Socially beneficial forest management helps both local people and society at large to enjoy long term benefits and also provides strong incentives to local people to sustain the forest resources and adhere to long-term management plans. “Economically viable forest management means that forest operations are structured and managed so as to be sufficiently profitable, without generating financial profit at the expense of the forest resource, the ecosystem, or affected communities. The tension between the need to generate adequate financial returns and the principles of responsible forest operations can be reduced through efforts to market forest products for their best value”. (extract from FSC By-laws, 1994)

As a tool to achieve its mission FSC has developed and implements an international, voluntary conformance assessment scheme applicable to forest management. FSC’s Principles and Criteria of Forest Stewardship (FSC-STD-01-001) is the international standard against which all FSC-certified forests and plantations are evaluated. The FSC Principles and Criteria provide the international ‘level playing field’ to which all FSC-certified forest and plantation managers operate. Specific indicators and means of verification may then be developed at the national or sub-national levels in order to take account of variations in ecological, social, environmental and institutional conditions within this consistent international framework. Products from forests which are certified as meeting the requirements of the FSC Principles and Criteria can be marketed to businesses and consumers as ‘FSC-certified’, and through the use of FSC’s internationally recognised labels. In relation to pesticides, the FSC Principles and Criteria aim to minimise the negative environmental and social impacts of pesticides use whilst promoting economically viable management of the world’s forests. The FSC label is a ‘green’ label, indicating high levels of social and environmental performance. FSC requirements commonly exceed the minimum legal obligations applicable to every company within a particular jurisdiction. FSC takes a precautionary approach to pesticide use, in part because experience has repeatedly shown the difficulty of ensuring consistent proper use, and the limits of knowledge of the ecological and environmental impacts of pesticides and the consequent unforseen consequences of their use. The proposals in this paper aim to further clarify the correct implementation of the FSC Principles and Criteria as applicable to pesticide use, for the benefit of certification bodies, their clients, and other stakeholders. The proposals aim to streamline and simplify the policy approved by the FSC Board of Directors in May 2002, without changing its substantive aspects.


2. The FSC Principles and Criteria of Forest Stewardship The FSC Principles and Criteria were developed through a multi-stakeholder consultative process incorporating the views and concerns of forest companies, environmental and social NGOs, academics and others. They are approved by the FSC membership. They may be revised on the basis of a vote of the FSC General Assembly, requiring the consensus support of the members of the three FSC chambers (social, environmental and economic), North and South. Definitions In May 2002 the FSC Board of Directors approved the following definitions of the terms ‘pest’ and ‘pesticide’:

Pest: Organisms, which are harmful or perceived as harmful and as prejudicing the achievement of management goals or the desired yields or profits. Some pests, especially introduced exotics, may also pose serious ecological threats, and suppression may be recommended. They include animal pests, plant weeds, pathogenic fungi and other micro-organisms. Pesticide (including fungicide and herbicide): Any substance, preparation or organism prepared or used in protecting plants or wood or other plant products from harmful organisms; in rendering such organisms harmless; and controlling organisms with harmful or unwanted effects. (The term pesticide is used here (instead of e.g. biocide) because (1) it is used in the FSC P&C and (2) the term biocide has other legal definitions and restrictions, and includes some household cleansing products)

The FSC Principles & Criteria of Forest Stewardship (approved in 1994, revised in 2000) include the following criteria relating to the use of pesticides:

Criterion 6.6 (1) Management systems shall promote the development and adoption of environmentally friendly non-chemical methods of pest management and strive to avoid the use of chemical pesticides. (2) World Health Organization Type IA and IB and chlorinated hydrocarbon pesticides; pesticides that are persistent, toxic or whose derivatives remain biologically active and accumulate in the food chain beyond their intended use; as well as any pesticides banned by international agreement, shall be prohibited. (3) If chemicals are used, proper equipment and training shall be provided to minimize health and environmental risks. Criterion 10.7 (1) Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions. (2) Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers. (3) Plantation management shall make every effort to move away from chemical pesticides and fertilizers, including their use in nurseries.

(FSC-STD-01-001 FSC Principles and Criteria for Forest Stewardship)


This FSC discussion paper proposes modifications to FSC’s current policy, in order to provide clear, definitive guidance on the implementation of the FSC Principles and Criteria, following the approach established by the FSC Board of Directors in May 2002. 3 The FSC approach to the use of pesticides FSC’s approach to the implementation of the applicable FSC Criteria was developed through a series of draft proposals and background papers between December 1999 and May 2002. The FSC Criteria include three core elements:

- The avoidance of highly hazardous pesticides; - Promotion of ‘non-chemical’ methods of pest management as an element of

an integrated pest management strategy;

- Appropriate use of the pesticides that are used. To date, FSC policy has focused primarily on the first of these elements: the avoidance of highly hazardous pesticides. This discussion paper follows this precedent, since it is this element that has attracted most comment. The remaining elements are introduced briefly in Sections 5 and 6 of this paper but are not covered in detail. FSC recognises that further guidance needs to be developed focussing on the remaining elements. 4 Identification, avoidance and control of highly hazardous pesticides 4.1 Overview FSC pesticides policy recognises the distinction between hazard and risk. Hazard refers to the inherent danger in a situation. Risk recognises that the inherent danger may be limited by specific controls. The overall risk may be reduced both by identifying and avoiding hazard, and also by taking steps to control hazards which have been identified. FSC policy follows this two-step approach. The chemical properties of pesticides are generally hazardous, but some are more hazardous than others. FSC Criterion 6.6 lists the aspects of hazard that FSC considers (e.g. persistence, toxicity, etc). FSC has then specified technical indicators by which each identified element of hazard may be objectively evaluated (e.g. LD50 value as an indicator of toxicity) and specified a threshold above which a particular pesticide is considered ‘highly hazardous’ and below which it is considered ‘less hazardous’ (e.g. . LD50 < 200 mg/kg for mammals is ‘highly hazardous’, LD50 > 200 mg/kg for mammals is ‘less hazardous’). This evaluation results in a list of pesticides that FSC considers to be ‘highly hazardous2’. Previously, this list has been referred to as the ‘FSC-prohibited’ list. In this paper it is referred to as ‘the FSC list of highly hazardous pesticides’. Section 4.2 of this paper (see table 2) specifies the complete set of indicators and thresholds used for the identification of highly hazardous pesticides, and approved in July 2002. Annex I: FSC list of highly hazardous pesticides, August 2005 lists the pesticides which have now been identified as exceeding these previously defined thresholds.

2 The term ‘highly hazardous’ is also the term used by the World Health Organisation (WHO) for class 1b pesticides (class 1a pesticides are described as ‘extremely hazardous’. Other terms tha t have been proposed include “prescribed pesticides’ and ‘environmentally hazardous pesticides’. Comments are welcome.


The listing of a pesticide on the FSC list of highly hazardous pesticides does not mean that the pesticide cannot be used under any circumstances. Nor does the fact that a pesticide is not on this list mean that it is ‘safe’. Inclusion on the list means that FSC considers the pesticide as highly hazardous in relation to one or more of the specified indicators. In order to reduce the risk of negative environmental or social impacts these pesticides should be avoided if possible, and should only be used in FSC-certified forests and plantations if there is no viable alternative. This implies that less hazardous (or no) pesticides should be preferred, and that ultimately, if possible, use of the most hazardous pesticides should be eliminated. Pesticides that are included on the FSC list of highly hazardous pesticides may not therefore be used in FSC-certified forests unless there is no viable alternative and such use is recognised by social and environmental as well as economic stakeholders at the national and/or sub-national levels as being necessary for the effective promotion of forest stewardship. In order to implement this, FSC requires that managers wishing to use these highly hazardous pesticides must justify such use through a specific process which includes consultation with social, environmental and economic stakeholders. This is the ‘derogation’ process, described in more detail in Section 4.3 of this paper. In summary the FSC approach to the use of highly hazardous pesticides is as follows: STEP ONE STEP TWO

IF YES: Do not use the pesticide, OR, if there is no viable alternative, justify a derogation with the support of national and/or sub-national social and environmental, as well as economic, stakeholders.

If a derogation is approved, the pesticide may be used under the conditions specified in the derogation. Other FSC and national requirements (e.g. safe use, training of operatives) continue to apply.

Is a pesticide highly hazardous for one or more of the elements specified? (i.e. is it included on the FSC list of highly hazardous pesticides?).

IF NO: The pesticide may be used without a specific derogation, so long as the other FSC requirements (e.g. consideration of alternatives, safe use, training, disposal, etc.) are met, AND the pesticide is used in accordance with national legislation and regulations for its use.

Table 1.

This two-step description is a simple illustration of FSC’s overall approach in relation to one aspect of pesticide use, based on evaluation of hazard. It is NOT intended to act as a full decision support framework for the use of pesticides and should not be used as such. The following sections specify the indicators and thresholds that have been used by FSC to identify the list of highly hazardous pesticides, and then describe in more detail the elements


that need to be addressed in order to justify a derogation for the use of these pesticides in an FSC-certified forest or plantation. 4.2 Indicators and thresholds for highly hazardous pesticides Criterion 6.6 of the FSC Principles and Criteria identifies the general properties of pesticides that should be evaluated in the determination of hazard. These properties are: - Persistence - Toxicity (chronic or acute toxicity to non-target organisms) - Biological activity and accumulation in the the food chain In order to evaluate these properties effectively FSC considers the following aspects: - Carcinogenicity - Mutagenicity - Endocrine disruption - Presence of heavy metals - Presence of dioxins (including dioxins in the by-products of burning) In addition, FSC Criterion 6.6 identifies as highly hazardous pesticides which are, or include: - Chlorinated hyrocarbons - Chemicals identified by the World Health Organization (WHO) as either "Extremely

Hazardous" (Class 1A) or “Highly Hazardous" (Class 1B) - Pesticides which are banned by international agreement. FSC’s 2002 policy on the use of chemical pesticides specified objective indicators and thresholds for the identification of particularly hazardous pesticides in relation to each of these aspects. The basis for selection of these indicators and thresholds was discussed in detail in the paper Use of Chemical Pesticides in Certified Forests: clarification of FSC criteria 6.6, 6.7 and 10.7 (Radosevich, S., M.Lappé & B.Addlestone (2000) FSC-USA). The FSC Board of Directors emphasised in its 2002 policy decision that the thresholds should be regularly reviewed and if necessary revised. In 2004 FSC commissioned the Pesticides Action Network – UK (PAN-UK) to review the indicators and thresholds, confirm whether or not they are technically valid, and if necessary propose improvements. The detailed study by PAN-UK has been widely circulated and is available on request (Review of the Forest Stewardship Council’s Pesticide Indicators and Thresholds (2005) PAN-UK). Review and revision of Indicators and thresholds The PAN-UK review notes that the choice of thresholds is a socially determined decision, and in this sense is arbitrary. It should be emphasised that arbitrary does not mean ‘non-objective’. A similar observation can be made about speed limits: there is a general correlation between speed and road accidents. Imposing speed limits is a recognised way to reduce fatalities. Whether the maximum speed limit is 100 km/hour, 110 km/hour or some other speed is arbitrary and is a socially determined decision. But the specification of speed as an indicator of hazard and the specification of 100km/hour (for example) as a threshold, are clearly objective and rational elements of a policy for road safety. No one needs to claim that speed is the only relevant factor in road accidents – clearly it is not. But a speed limit is a simple, practical and rational way of reducing deaths on the roads. In the case of FSC policy the choices of indicators and thresholds were specified in 2002 after consideration of existing norms used by organisations such as the WHO and US Environmental Protection Agency (EPA) followed by extensive consultation with social, environmental and economic stakeholders.


The PAN-UK review identified a number of aspects of the indicators and thresholds used by FSC since 2002 which could be improved. However, in order to avoid confusion or misrepresentation of the proposed changes to FSC policy, the table below uses the same indicators and thresholds as for the 2002 policy. In this table, therefore, NO PESTICIDES HAVE BEEN ADDED TO THE ‘FSC-PROHIBITED’ LIST ON THE BASIS OF CHANGES TO THE CHOICE OF INDICATORS OR THRESHOLDS.

Criterion (derived from FSC

Principles and Criteria, 2002)

Indicator Threshold for inclusion on FSC list of ‘highly hazardous pesticides’

Quantitative or semi-quantitative Acute toxicity to mammals

WHO toxicity class (active ingredients) Acute toxicity (oral LD50 for rats) (Acute) reference dose (RfD)

If acute oral LD50 for rats ��

b.w. WHO toxicity class 1a, 1b.

Acute toxicity to aquatic organisms

Aquatic toxicity (LC50) If LC50 < 50 ug/l (microgrammes per liter)

Chronic toxicity to mammals

Reference dose If RfD < 0.01 mg/kg day

Persistence in soil or water

Half-life in soil or water (DT50) If DT50 �� "! #�$&%��'�( ��%��)

Bio-magnification, bio-accumulation

Octanol-water partition coefficient (KOW) or bio-concentration factor (BCF) or bio-accumulation factor (BAF)

If KOW > 1000 i.e. log(KOW) > 3

Carcinogenicity IARC carcinogen; US EPA carcinogen

If listed in any category below (a) International Agency for Research on Cancer (IARC) within Group 1: ‘The agent (mixture) is carcinogenic to humans’, or within Group 2A: ‘The agent (mixture) is probably carcinogenic to humans’ (IARC 2004); (b) US Environmental Protection Agency (EPA) defined as a chemical that is within Group A: ‘Human carcinogen’ (US EPA 1986); (c) US EPA defined as a chemical that can ‘reasonably be expected to be carcinogenic to humans’ (chemicals categorised by EPA into Group B2, see below)

Endocrine disrupting chemical (EDC)

EDC listed by the US EPA and NTP If classified as EDC by US NTP or EPA

Mutagenicity to mammals

(not specified any further) If mutagenic to any species of mammals

Qualitative Specific chemical class

Chlorinated hydrocarbon (definition from Radosevich et al, 2002): Compounds which contain only

If chemical meets definition from Radosevich et al, 2002. Note: the 2002 policy includes the


Criterion (derived from FSC

Principles and Criteria, 2002)

Indicator Threshold for inclusion on FSC list of ‘highly hazardous pesticides’

carbon, hydrogen and one or more halogen, AND/OR organic molecules with hydrogen and carbon atoms in a linear or ring carbon structure, containing carbon-bonded chlorine, which may also contain oxygen and/or sulphur, but which do not contain phosphorus or nitrogen.

statement that “not all organochlorines exceed the stated thresholds for toxicity, persistence or bioaccumulation, and they are not included in this list of prohibited pesticides, but they should be avoided”. However, the current list of ‘highly hazardous’ pesticides does not include organochlorines unless they are excluded on the basis of other indicators.

Heavy metals: Lead (Pb), cadmium (Cd), arsenic (As) and mercury (Hg)

If pesticide contains any heavy metal as listed

Dioxins (residues or emissions)

Equivalents of 2,3,7,8-TCDD If contaminated with any dioxins at a level of 10 part per trillion (corresponding to10 ng/kg) or greater of tetrachlorodibenzo-p-dioxin (TCDD) equivalent, or if it produces such an amount of] dioxin[s] when burned

International legislation

Banned by international agreement If banned by international agreement

Table 2. It is proposed to prepare a separate discussion paper in 2006 in which possible changes to the current FSC indicators and thresholds may be considered, if this is considered necessary once the current proposals have been finalised. 4.3 FSC list of highly hazardous pesticides FSC has attempted to identify the active ingredients of all the pesticides which are commonly used in forest, plantation and nursery use worldwide. These active ingredients have then been evaluated against the indicators and thresholds specified in table 2, above. The resulting FSC list of highly hazardous pesticides is presented in Annex I. This list now includes pesticides which were not in wide use in forestry or were not evaluated for other reasons at the time that the previous FSC policy was approved. However, the indicators and thresholds used for the evaluation have not changed. This list will continue to be reviewed and updated. Comments are welcome. It is proposed that from 1st January 2006 the most recently published version of this list should be considered definitive at any point in time. If this proposal is approved certification bodies would not, in future, be expected to carry out their own evaluations of pesticides used by applicant or certified clients to determine whether the active ingredients or formulations exceed the thresholds specified by FSC. Certification bodies would be required to check whether the active ingredient of any pesticide in use in a forest applying for certification is included on the FSC list of highly hazardous pesticides, but would be able to assume that if a pesticide is not on the list then a derogation is not currently required. The list would be regularly reviewed and updated by FSC, and if an active ingredient or particular formulation (see below) is added to the list, then the managers


would be permitted a minimum 12 month period to phase out their use of any pesticides containing this ingredient or formulation. The intention is that this would simplify and clarify the work of certification bodies. Formulations Pesticide formulations including the use of wetting agents, propellants, surfactants, solvents, etc. can all affect the value of the indicators specified in the table above, either positively or negatively. However reliable information on the effects of these variables on particular formulations is not widely and publicly available. The FSC list of highly hazardous pesticides has therefore been based on an evaluation of active ingredients only. It is proposed that the impacts of formulations should in future be accounted for as follows:

Formulations that reduce the level of hazard may be taken into account through the derogations process described in Section 4.4, below. If a derogation application clearly demonstrates that the formulation reduces the value of an indicator to below the specified threshold, then a derogation for the use of the active ingredient in such a formulation may be approved. Advice that specified formulations increase the level of hazard should be reviewed, and specific formulations may be added to the list of highly hazardous pesticides in future revisions, as described in 4.3, above.

Mitigating factors Specific factors such as soil type in the area of application, distance from water courses, rate, method and frequency of application are factors which may reduce the risk associated with the application of hazardous pesticides. These factors may be taken into account in the consideration of requests for derogations (see Section 4.4, below), but do not affect the hazard classification of the active ingredients themselves. 4.4 Derogations and major non-compliances In accordance with the current FSC policy FSC-certified forest and plantation managers may not use pesticides containing the active ingredients listed on the FSC list of highly hazardous pesticides except in specific circumstances authorised by the FSC Board of Directors through the issue of a formal derogation, or through the approval of a national or sub-national FSC Forest Stewardship Standard. In the absence of an approved derogation the use of a pesticide on the FSC list of highly hazardous pesticides shall be considered as a major non-compliance with the requirements of FSC-STD-01-001 FSC Principles and Criteria of Forest Stewardship. The current procedures for applying for a formal derogation are summarised in Section 4.7, below. It is not proposed to change this general framework. However, the PAN-UK review made a number of specific recommendations to improve the basis for issuing derogations. In response, the following basis is proposed: Derogations for use of a ‘highly hazardous’ pesticide may be issued for a specified territory where:

- there is a demonstrated need;


- there are specified controls in place to mitigate the associated hazard, and/or the formulation has been clearly demonstrated to reduce any indicators of concern to a level below the associated threshold for the indicator;

- there is an ongoing programme in place to identify alternatives;

- the requested derogation is supported by stakeholders representing social,

environmental and economic interests in the specified territory; If approved, derogations would normally be applicable for a five-year period. There would be a presumption against renewal at the end of this five-year period. Therefore, forest managers using a derogated pesticide would need to demonstrate that:

- there is a plan in place for the elimination of the pesticide’s use at the forest management unit level before the expiry of the derogation period.

Demonstrated need Need may be demonstrated where:

- The pesticide is used for protecting native species and forests against damage caused by introduced species or for protecting human health against dangerous diseases, OR

- Use of the pesticide is obligatory under national laws or regulations, OR

- Use of the pesticide is the only economically, environmentally, socially and technically feasible way of controlling specific organisms which are causing severe damage in natural forests or plantations in the specified country (as indicated by consideration, assessments and preferably field-trials of alternative non-chemical or less toxic pest-management methods)

Specified controls to mitigate the hazard The derogation would be required to specify the controls that would be implemented to mitigate the hazard associated with the use of the pesticide, for example restrictions related to weather conditions, soil types, application method, water courses, etc.. If the specified formulation is considered to reduce the level of hazard then the information on which this claim is based would have to be presented, and the applicant would have to provide credible independent, third party support for the claimed reduction of hazard. Programme to identify alternatives The application would have to describe the programme(s) which are in place in the territory concerned or which would be put in place during the period over which the derogation would be applicable, designed to identify alternative pest control methods which do not use highly hazardous pesticides.

Stakeholder support All applications for derogations would (as at present) require evidence to be submitted that the application is supported by social, environmental and economic stakeholders in the best interests of promoting FSC’s goals in the territory concerned. It would continue to be the responsibility of the applicant to present this evidence in support of their application (see summary of procedures in Section 4.7, below).


The level of stakeholder support required would be evaluated taking account of the geographical scope of the derogation, the justification of need, and other factors include in the application such as the strength of the programme to identify alternatives, and the level of controls to mitigate the identified hazards. A written letter of support by the Board of Directors of the FSC National Initiative for the territory concerned would normally be considered sufficient evidence of national stakeholder support for the application. Plan to eliminate use of the pesticide during the derogation period It is proposed that derogations would normally be issued for a five-year period. There would be a presumption against renewal of a derogation after the expiry of the five-year period. Forest managers seeking certification under an approved derogation would therefore have to ensure that they have a plan in place to eliminate use of the pesticide prior to the end of the derogation period. If a derogation is not renewed, the continued use of a highly hazardous pesticide after the expiry of the derogation would be considered a major non-compliance and would lead to the withdrawal of the certificate.

As a condition of use of a derogated pesticide, forest managers would be required to record quantitative and qualitative information about their use of such a pesticide, and this information should be included in the certification body’s evaluation reports and in all subsequent surveillance reports (see Section 4.8, below). Compliance with these requirements would need to be demonstrated by an applicant for certification at the Forest Management Unit (FMU) level and be verified by the certification body prior to the issue of a certificate. However, this evaluation is independent of the decision to issue a derogation for use of a pesticide over a geographical area.

A template for the presentation and evaluation of derogation requests in accordance with these proposalis is presented in Annex 1. The current list of approved derogations would be published separately as FSC-POL-30-601c Approved derogations for the use of highly hazardous pesticides in FSC-certified forests and plantations. 4.5 National and sub-national FSC standards The system for the issue of derogations emphasises the need for national or sub-national stakeholder consultation and support to justify an exception to the usual implementation of the requirements of the FSC Principles and Criteria. Where national or sub-national FSC standards are in development, the national or sub-national standards development process provides the most appropriate mechanism for such consultation and decisions on derogations. Therefore, it is proposed that in future National FSC bodies would be required to consider the possible use of highly hazardous chemicals within the geographical scope of an FSC national or sub-national standard, and if necessary seek derogations at the time that such a standard is developed. In geographical areas in which a national or sub-national standard is being developed it would therefore be the responsibility of the FSC National Initiative to consider the issue of FSC-prohibited chemicals and to include any requests for derogations, if required, within the national or sub-national standard when it is submitted to the FSC International Center for accreditation.


The criteria for justifying use of a highly hazardous chemical would be the same as those specified above for territory-specific applications for approval by the FSC Board of Directors. If standards are submitted for approval without specific requests for derogations for the use of FSC-prohibited chemicals, it would be assumed that all stakeholders party to the standard agree that FSC-prohibited chemicals shall not be used within the geographical scope of the standard unless a derogation is subsequently submitted to FSC-IC with the written support of the Board of Directors of the relevant FSC National Initiative. 4.6 Emergencies. Emergencies may include invasions or infestations of animal pests, weed plants, certain fungal diseases, or dramatic changes in vegetation composition, which threaten ecological stability, where they cannot feasibly be controlled by conventional means. The current system for approving derogations in the case of emergencies is unclear. The following proposals are made to clarify and streamline the arrangements: In the case of emergencies (as specified above) certification bodies may permit FSC certificate holders temporary permission to use pesticides that are included on the FSC list of highly hazardous pesticides, without the prior permission of the FSC Board of Directors. The certification body would be required immediately to inform the FSC International Center of the situation, including an explanation of the nature of the emergency and the justification for the use of a highly hazardous pesticide in response. The FSC Board of Directors would reserve the right to determine that the use of highly hazardous pesticide is not justified in the absence of an approved derogation, following the normal processes. In this case the continued use of the pesticide by the forest or plantation manager would constitute a major non-compliance, and would lead to the withdrawal of the certificate by the certification body unless discontinued (or unless a derogation is subsequently approved in accordance with the normal procedures). 4.7 Implementation. The FSC International Center has developed a specific procedure for the review and approval of derogations for the use of highly hazardous pesticides in FSC certified forests (FSC-PRO-01-002). The following provides a brief overview of the main elements. The FSC International Center has responsibility for evaluating derogation requests and making a recommendation as to whether the application complies or does not comply with the requirements specified in this policy for consideration by the FSC Board Pesticides Committee. In geographical areas in which there is already an FSC-accredited or preliminarily accredited national or sub-national standard, requests for derogations for the use of 'FSC-prohibited' chemical pesticides must only be subsequently submitted to the ABU by the accredited FSC National Initiative with responsibility for that geographical area. In geographical areas in which there is no FSC-accredited or preliminarily-accredited national or sub-national standard, requests for derogations for the use of 'FSC-prohibited' chemical pesticides must be submitted to the ABU by the certification body whose client(s) request the derogation. In all cases, derogation applications are evaluated on the basis of documented evidence of compliance with the requirements of the current policy. In all cases it is the responsibility of the certification body seeking the derogation on behalf of a client or clients to submit application materials that demonstrate compliance with these requirements. Such materials


must include evidence of stakeholder consultation and support. It is the responsibility of the certification body and not of FSC to carry out stakeholder consultation in support of a requested derogation. Further detail is included in FSC-PRO-01-002, available on request. 4.8 Monitoring It is essential to the credibility of the system for issuing derogations that the continuing use of pesticides is monitored both by the certification body and by FSC. The PAN-UK report notes that collection of basic data would allow FSC to evaluate the impacts of its policy over time, and if necessary propose modifications. FSC policy should therefore require that forest managers maintain records of their use of pesticides, and certification bodies should be required to include basic quantitative and qualitative data on such use in evaluation and surveillance reports on FSC-certified forests and plantations. Monitoring the use of pesticides listed as ‘highly hazardous’ as well as other pesticides not on the list would allow FSC to ensure that the list can be readily updated. It should also allow FSC to monitor the overall impact of its policy, for example to indicate whether the avoidance of ‘highly hazardous’ pesticides is leading to an increased use of other pesticides. Forest managers should therefore be required to record at least the following information for all pesticides used:

- the brand name and the active ingredient(s) of the pesticide - the area to which the pesticide has been applied in the previous 12 months

- the quantity of the active ingredient applied in the previous 12 months

- the reason for the application(s)

The certification body should include a copy of this information in its evaluation report, and in all subsequent surveillance reports. FSC should then include this information in its certificate database, allowing the international monitoring of the use of such pesticides in FSC-certified forests. 5 Decision support, and integrated pest and vegetation management FSC’s requirement to avoid the use of highly hazardous pesticides should be considered in the context of the more general support for ‘non-chemical’ methods of pest management as an element of an integrated pest and vegetation management strategy. General requirements are specified in both FSC Criterion 6.6 and 10.7:

Criterion 6.6 (1) Management systems shall promote the development and adoption of environmentally friendly non-chemical methods of pest management and strive to avoid the use of chemical pesticides. Criterion 10.7 (1) Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions.


(2) Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers.

A lot of attention has been focussed over the past years on the identification and avoidance of highly hazardous pesticides. Much less attention has been devoted to the development of indicators and means of verification for recognising effective integrated pest management strategies, and methodologies for promoting non-chemical methods. In the UK, work to implement forest certification standards has led to the development of a ‘decision support framework’ that might provide a model for use in other countries. Well-designed integrated pest and vegetation management should be an essential part of implementing FSC standards in relation to pesticide use. FSC should provide guidance on the development of appropriate indicators and means of verification for inclusion in generic and national or sub-national Forest Stewardship Standards. 6 General requirements for use of pesticides Finally, it should not be forgotten that the FSC Principles and Criteria include basic requirements for the proper use of pesticides when they are accepted as the most appropriate choice for pest management.

Criterion 6.6 (3) If chemicals are used, proper equipment and training shall be provided to minimize health and environmental risks.

The FSC International Center may develop guidance on the development of indicators and means of verification for the implementation of these requirements. 7 Proposed simplification of FSC policy The current FSC policy document is quite long and complex. It is proposed that it should be greatly simplified and shortened, with the detail of its application being presented in the form of a formal FSC guidance document, rather than a policy document. The guidance would remain the basis by which the FSC Accreditation Business Unit would evaluate compliance with FSC policy and standards, so whilst this change would clarify the presentation of the policy, it would not change its implementation. The following draft policy is presented for discussion and comment, prior to presentation to the FSC Board of Directors for approval: “FSC policy in relation to the use of pesticides in FSC-certified forests and plantations aims to minimise the negative environmental and social impacts of pesticide use whilst promoting economically viable management. This policy is implemented through compliance with the requirements of FSC-STD-01-001 FSC Principles and Criteria of Forest Stewardship and the associated national or sub-national indicators and means of verification. The key elements for implementation of these requirements include:

- The avoidance of highly hazardous pesticides; - Promotion of ‘non-chemical’ methods of pest management as an

element of an integrated pest management strategy;


- Appropriate use of the pesticides that are used. In order to facilitate implementation of these requirements:

The FSC International Center shall publish and regularly update a list of pesticides that FSC considers to be ‘highly hazardous’ based on published technical indicators derived from the FSC-STD-01-001 FSC Principles and Criteria of Forest Stewardship and associated thresholds approved by the FSC Board of Directors. The use of any pesticide containing an active ingredient included on the current FSC list of ‘highly hazardous’ pesticides shall constitute a major non-compliance with the requirements of FSC-STD-01-001 FSC Principles and Criteria of Forest Stewardship, unless a derogation for such use in the applicable territory has previously been approved by the FSC Board of Directors. Such derogations may be approved on application by an FSC-accredited certification body, or, preferably, through inclusion in a national or sub-national Forest Stewardship Standard. The FSC International Center shall publish clear guidelines and procedures for the evaluation of requests for derogations, including guidance on the justification for the issue of derogations, and on the content of derogations. Derogations shall normally be applicable for a five-year period. Demonstration of an appropriate level of stakeholder consultation and support shall be a requirement for the approval of any requested derogation. The FSC International Center shall develop guidance on appropriate indicators and means of verification for the promotion of ‘non-chemical’ methods of pest management as an element of an integrated pest management strategy, and for the equipment and training that shall be provided by forest managers to minimize health and environmental risks.

Forest Stewardship Standards shall require forest managers to record quantitative data on their use of pesticides. Summary data shall be collected by certification bodies and included in their evaluation and surveillance reports of FSC-certified forests, and shall be collated and analysed by the FSC International Center on an ongoing basis.

The FSC Board of Directors may delegate review and approval of the lists, guidance, standards and procedures required in order to implement this policy to a committee established for the purpose”. 8 Next steps This discussion paper will be circulated as widely as possible for review and comment. The proposed policy (Section 7, above) will be modified to take account of the comments received, and will be presented to the FSC Board of Directors for approval in December 2005. If approved, the policy will replace FSC-POL-30-601 which shall be withdrawn. Associated guidance required to implement the policy based on the proposals contained in this discussion paper and taking account of comments received, together with Annex 1 “FSC list of highly hazardous pesticides”; Annex 2: “Template for the presentation and evaluation of derogation requests”; and FSC-PRO-01-002 Handling applications for derogations for the use of ‘highly hazardous’ pesticides will be presented to the FSC Pesticides Committee in December 2005 for review and approval, to take effect from 1st January 2006.


The following elements will be included in the 2006 workplan of the FSC Policy and Standards Unit:

- The indicators and thresholds specified in Table 2. of this discussion paper will be reviewed, and may subsequently be revised. If changes are made, then the FSC list of highly hazardous pesticides will be revised accordingly, for implementation from 1st January 2007.

- Guidance will be developed, in consultation with stakeholders, on appropriate

indicators and means of verification for the promotion of ‘non-chemical’ methods of pest management as an element of an integrated pest management strategy, and for the equipment and training that shall be provided by forest managers to minimize health and environmental risks.

- Staff will be allocated as necessary to implement the procedures for evaluating

derogations, and for the steps specified above, with the costs covered though the Annual Accreditation Fee (AAF).


Annex I: FSC list of highly hazardous pesticides, August 2005 The chemicals listed below are used as pesticides in forestry and qualify as highly hazardous in relation to one or more indicators. Their use is prohibited in FSC-certified forests unless a formal derogation has been approved for the use of the pesticide within the applicable territory. The chemicals listed either previously identified in FSC-POL-30-601, or were identified in Review of the Forest Stewardship Council’s Pesticide Indicators and Thresholds, PAN-UK, April 2005. Assessment in the PAN-UK review was based on data from 'Pesticide Manual' (PM 2003) and 'Pesticides Database' (PANNA 2002). The acute aquatic toxicity was assessed on the basis of data from the 'Pesticide Manual' (PM). Data used for assessing persistence is based on the 'Pesticide Manual'. Persistence refers to soil where not specified otherwise and to the mean or median value. For a few chemicals, no half-life values were available. Bio-accumulation was examined on a qualitative basis and the corresponding studies referred to in the source (PANNA 2002) need to be consulted for deciding if the bio-concentration factor (BCF) meets the required standard. However, no pesticide is included on the list solely on account of BCF. All those pesticides that are suggested to fail the bioaccumulation requirement would be included on the basis of other indicators. Chemicals rated by the US EPA as 'Developmental Toxin' within the Toxics Release Inventory (TRI) program are identified as endocrine disrupting chemicals (see paragraph 3.2.9 of PAN-UK review for explanation) therefore these are unacceptable on the basis of the current policy. A chemical that is a 'chlorinated hydrocarbon' is treated as being ‘highly hazardous’ when no exemption can be given on the basis of current policy. A compound that contains no nitrogen within a ring structure (and is therefore not a pyridine, which differ from chlorinated hydrocarbons toxicologically) is not given an exemption in line with Radosevich et al 2000, p.7. The indicator(s) for which these chemicals have been identified as highly hazardous is (are) also listed.

Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list aldicarb WHO Table 1, Class Ia.

aldrin Chlorinated hydrocarbon

Aluminium phosphide

Toxicity similar to sodium cyanide. WHO Table 7.

amitrole

Carcinogenicity (Group B2, US EPA)

benomyl

Persistence: 6 - 12 months. Toxicity: LD50 100 mg/kg. LC50 60 - 140 microg/l. Mutagen

brodifacoum

WHO Table 1, Class Ia.

bromadialone WHO Table 1, Class Ia.

Carbaryl Toxicity: LD50 of 100 mg/kg in mice.


Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list chlordane

Organochlorine Persistence: half-life of 4 years. Toxicity: oral LD50 in rabbits approx. 20-300 mg/kg.

chloropicrin

Acute aquatic toxicity (PM) Chlorinated hydrocarbon containing nitrogen but not a pyridine (PM) (no exemption)

chlorothalonil

Acute aquatic toxicity (PM) Chlorinated hydrocarbon (chlorinated aromatic) (PM) [BCF (molluscs, phytoplankton)?]

cyfluthrin

Acute aquatic toxicity (PM) Chlorinated hydrocarbon (PM)

cypermethrin

Acute aquatic toxicity (PM) Chlorinated hydrocarbon (PM) [BCF (aquatic plants, fish, insects, phytoplankton)?]

alpha-cypermethrin

Acute aquatic toxicity (PM) Chlorinated hydrocarbon (PM) [BCF (aquatic plants, fish, insects, phytoplankton)?]

zeta-cypermethrin

Acute toxicity to mammals (WHO) Acute aquatic toxicity (PM) Chlorinated hydrocarbon (PM)

2,4-D, butoxyethanol ester

Chlorinated hydrocarbon (PM) [BCF (aquatic plants, fish)?]

2,4-D, diethanolamine salt

Chlorinated hydrocarbon(PM)

2,4-D, dimethylamine (dma) salt

Chlorinated hydrocarbon(PM) [BCF (aquatic plants, fish)?]

2,4-D, 2-ethylhexyl ester


2,4-D, isopropylamine salt


2,4-D, triisopropanolamine salt


2-(2,4-DP), dma salt (= dichlorprop, dma salt)

Chlorinated hydrocarbon(PM) Endocrine disrupting chemical (TRI Developmental toxin)

DDT

Chlorinated hydrocarbon

diazinon

Toxicity: 0.0009 mg/kg/day. LD50 2.75 - 40.8 mg/kg.

dicamba, dma salt

Chlorinated hydrocarbon(PM) Endocrine disrupting chemical (TRI Developmental toxin)


Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list dichlobenil

Persistence (PM) Chlorinated hydrocarbon (PM) [BCF (aquatic plants, fish, insects, molluscs, phytoplankton, zooplankton)?]

dicofol

Persistence: 60 days. Biomagnification: log Kow 4.28.

dieldrin


dienochlor

Organochlorine. Toxicity: LC50 of 50 microg/l in aquatic environments.

difethialone


diflubenzuron

Acute aquatic toxicity (PM) Chlorinated hydrocarbon (PM) [BCF (aquatic plants, terrestrial plants, phytoplankton, zooplankton)?]

dimethoate

Toxicity: RfD 0.0002 mg/kg/day. LD50: 20 mg/kg in pheasants.

diquat dibromide

Reference dose (chronic), as the acceptable daily intake (see 3.1) (WHO 2003) [BCF (aquatic plants, fish, zooplankton)?]

diuron

Persistence (PM) Endocrine disrupting chemical (US EPA, TRI Developmental toxin) Chlorinated hydrocarbon (PM) [BCF (molluscs, phytoplankton, zooplankton)?]

endosulfan

Organochlorine. Toxicity: LD50 much less than 200 mg/kg in several mammals. RfD 0.00005 mg/kg/day.

endrin

Organochlorine. Persistence: half-life >100 days. Toxicity: LD50 <200 mg/kg. Biomagnification high in fish.

esfenvalerate

Acute aquatic toxicity (PM) Persistence (PM) Chlorinated hydrocarbon (PM) [BCF (aquatic plants, fish, molluscs, phytoplankton, zooplankton)?]

gamma-HCH, lindane


haloxyfop

Chlorinated hydrocarbon (PM)

heptachlor

organochlorine. Persistence: half-life 250 days.


Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list Toxicity: LD50 100-220 mg/kg in rats, 30-68 mg/kg in mice.

RfD 0.005 mg/kg/day. Biomagnification: Log Kow 5.44.

hexachlorobenzene


hexazinone

Persistence (PM) [BCF (fish)?]

hydramethylnon

Acute aquatic toxicity (PM) Endocrine disrupting chemical (TRI Developmental toxin, TRI Reproductive Toxin)

imazapyr

Persistence (PM)

imazapyr, isopropylamine salt

Persistence (PM)

mancozeb

Toxicity: RfD 0.003 mg/kg/day.

metam sodium

Carcinogenicity (Group 2B, EPA) Endocrine disrupting chemical (TRI Developmental toxin)

methoxychlor

Persistence: half-life 60 days. Toxicity: RfD 0.005 mg/kg/day. LC50 <0.020 mg/l for trout.

methylarsonic acid (monosodium methanearsenate, MSMA)

Chemical class (heavy metals) [BCF (aquatic plants, crustaceans, fish, molluscs, phytoplankton, zooplankton)?]

methylbromide

reference dose (US EPA 1993)

metolachlor

Biomagnification: log Kow 3.45.

mirex Organochlorine. Persistence: half-life > 100 days. Toxicity: LD50 50-5000 mg/kg. Carcinogen. Bioaccumulation high.

naled

Acute aquatic toxicity (PM) Endocrine disrupting chemical (TRI Developmental toxin)

oryzalin

Persistence: Half-life 20-128 days. Toxicity: LD50 100 mg/kg in birds.

oxydemeton-methyl, Metasystox

WHO Table 2, Class Ib.

oxyfluorfen

Toxicity: RfD 0.003 mg/kg/day Log Kow 4.47

paraquat Persistence: > 1000 days.


Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list Toxicity: RfD 0.0045 mg/kg/day. Log Kow 4.47. Reference dose (US EPA 1993) [BCF (aquatic plants, fish, phytoplankton)?]

parathion WHO Table 1, Class Ia.

pendimethalin

Persistence (PM) The log Kow of pendimethalin is 5.2, above the threshold, although it is a root-contact herbicide and thus has no systemic activity, bio-magnification is likely to be small, however, the potential for bio-accumulation of a pesticide is assessed independently of persistence. Persistent chemicals may be transferred to plants, to ground water and surface waters where they can be absorbed by other organisms. The US EPA rates Pendimethalin as a persistent, bio-accumulative and toxic (PBT) chemical3.

pentachlorophenol WHO Table 2, Class Ib.

permethrin Toxicity: Log Kow 6.10. LC50 0.0125 mg/litre in rainbow trout.

quintozene Organochlorine. Persistence: 1 - 18 months. Toxicity: high. Biomagnification: Log Kow 4.46.

simazine Toxicity: RfD 0.005 mg/kg/day

sodium cyanide WHO Table 2, Class Ib. Acute toxicity to mammals (WHO) Acute aquatic toxicity (PANNA 2002) [BCF (fish)?]

sodium fluoroacetate, 1080


2,4,5-T Organochlorine Toxicity: medium to high in mammals. Often contaminated with dioxin.

tebufenozide

Persistence (PM)

terbumeton

Persistence (PM) Reference dose (US EPA 1993)

terbuthylazine

Reference dose (US EPA, Reregistration Eligibility Decision, p. 13, 1995) Chlorinated triazine: exemption

3 US Environmental Protection Agency (EPA) 2004: Toxics Release Inventory (TRI) Program, TRI PBT chemical list, http://www.epa.gov/tri/chemical/pbt_chem_list.htm


Name of chemical Basis for inclusion on FSC ‘highly hazardous’ list [BCF (phytoplankton, zooplankton)?]

terbutryn

Reference dose (US EPA 1993) [BCF (aquatic plants, insects, phytoplankton)?]

trifluralin

Toxicity: RfD 0.0075 mg/kg/day. Log Kow 5.07. LC50 0.02 mg/litre. (under review, to be clarified)

toxaphene (camphechlor) Organochlorine. Persistence: > 100 days, high. Bioaccumulation high.

warfarin

WHO Table 2, Class Ib.

zinc phosphide

Acute toxicity to mammals (PM) Reference dose (US EPA, Reregistration Eligibility Decision, 1998):


ANNEX 2 Template for the presentation and evaluation of derogation requests Name and contact details of certification body requesting derogation:

Active ingredient for which derogation requested:

Geographical scope of requested derogation:

Is there an accredited or preliminarily accredited FSC Forest Stewardship Standard applicable to the territory concerned?

Requested time period for derogation: (nb Derogations shall normally be issued for a five-year period. There will be a presumption against renewal of a derogation after the expiry of the five-year period).

1. Demonstrated need

Need may be demonstrated where:

- The pesticide is used for protecting

native species and forests against damage caused by introduced species or for protecting human health against dangerous diseases, OR

- Use of the pesticide is obligatory under national laws or regulations, OR

- Use of the pesticide is the only economically, environmentally, socially and technically feasible way of controlling specific organisms which are causing severe damage in natural forests or plantations in the specified country (as indicated by consideration, assessments and preferably field-trials of alternative non-chemical or less toxic pest-management methods)

Explain how the proposed use complies with the specified criteria for need, including the consideration of alternatives which do not require the use of pesticides on the FSC list of ‘highly hazardous pesticides’:


2. Specified controls to mitigate the hazard The derogation shall specify the controls that will be implemented to mitigate the hazard associated with the use of the pesticide, for example restrictions related to weather conditions, soil types, application method, water courses, etc.. If the specified formulation is considered to reduce the level of hazard then the information on which this claim is based shall be presented, and the applicant shall provide credible independent, third party support for the claimed reduction of hazard.

Specify the controls that will be implemented to mitigate the hazard:

3. Programme to identify alternatives

The application shall describe the programme(s) which are in place in the territory concerned or which will be put in place during the period over which the derogation will be applicable, designed to identify alternative pest control methods which do not use highly hazardous pesticides.

Describe the programme(s) that are in place to identify alternatives:

4. Stakeholder support

All applications for derogations shall include evidence that the application is supported by social, environmental and economic stakeholders in the best interests of promoting FSC’s goals in the territory concerned. It is the responsibility of the applicant to present this evidence in support of their application (see summary of procedures in Section 8, below). The level of stakeholder support required will be evaluated taking account of the geographical scope of the derogation, the justification of need, and other factors include in the application such as the strength of the programme to identify alternatives, and the level of controls to mitigate the identified hazards. A written letter of support by the Board of Directors of the FSC National Initiative for

Describe the consultation that has taken place and summarise the results:


the territory concerned shall normally be considered sufficient evidence of national stakeholder support for the application. Plan to eliminate use of the pesticide during the derogation period Derogations shall normally be issued for a five-year period. There will be a presumption against renewal of a derogation after the expiry of the five-year period. Forest managers seeking certification under an approved derogation should therefore ensure that they have a plan in place to eliminate use of the pesticide prior to the end of the derogation period. If a derogation is not renewed, the continued use of a highly hazardous pesticide after the expiry of the derogation would be considered a major non-compliance and would lead to the withdrawal of the certificate. As a condition of use of a derogated pesticide, forest managers shall record quantitative and qualitative information about their use of such a pesticide, and this information shall be included in the certification body’s evaluation reports and in all subsequent surveillance reports. Compliance with these requirements would need to be demonstrated by an applicant for certification at the Forest Management Unit (FMU) level and be verified by the certification body prior to the issue of a certificate. However, this evaluation is independent of the decision to issue a derogation for use of a pesticide over a geographical area.

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