After four years, and countless rounds of deliberations, the newly revised Pesticide Policy by the Forest Stewardship Council^® (FSC^®) has been published, a little earlier than expected!

So what does this mean for the forestry industry in South Africa?

The FSC^® stamp has become the accepted ‘norm’, rather than a mark that sets your brand above the rest, with consumers and retailers across the globe demanding certified wood. With 80% of South Africa’s wood FSC certified, policy changes are almost certain to affect the sector.

This is why TIPWG secretariat and industry consultant Jacqui Meyer has been keeping abreast of the changes, representing both TIPWG and the industry during the stakeholder feedback sessions. TIPWG has been heavily involved in the formation, testing and development of the ESRA (Environmental and Social Risk Assessment) and IGIs (International Generic Indicators).

Why did the FSC’s Pesticide Policy need updating?

Jacqui – The previous version of the FSC^® Pesticide Policy is 14 years old with huge advances in pesticide research, development and understanding during this time. We are also far more aware of the potential implications of pesticides on the environment and human health and are much better at measuring these. For that reason alone the current policy needed updating.

Then there is the fact that globally as an industry, many plantation members were not happy with the 2005 policy because of how it was based on “potential hazard” rather than “realized risk”, and have pushed for a review of the policy.

What is the problem with the 2005 hazard-based approach?

Jacqui – The 2005 hazard-based approach often meant that foresters were prevented from using a product based on a theoretical hazard that would never become a realised risk when put into practice. This has its own associated risks (i.e. the risk(s) involved from not using the product), which were never considered but often realised. In some cases, this had equally detrimental effects.

Let’s take the placement of ‘paraquat’ on the FSC^® highly hazardous pesticide list, due to its associated human health implications (which can be mitigated against with correct PPE and operating procedures). This saw some certificate holders resorting to glyphosate products instead to prepare their tracer belts for mandatory fire breaks. The environmental footprint of glyphosate is far greater than paraquat; the latter is better suited to this operation as it acts as a desiccant.

In this case, the human health hazard posed by paraquat is minimal compared with the environmental impact associated with an alternative. Worse still, there are the greater environmental and safety risks of fire-breaks not being maintained.

The South African forestry sector was certainly one of the voices behind a revision of the 2005 pesticide policy, calling for a change from hazard-based to a risk-based policy. The sector has always advocated that ‘scale, intensity and risk’ need to be taken into consideration before applying any pesticide. So, in principle, we welcome the revision and believe it to be long overdue.

Are there then no concerns regarding the revision of the pesticide policy by FSC^®?

Jacqui – With every policy revision that has the potential to greatly affect your industry, there are concerns.

The two greatest being: 1) whether the elected working group were suitably qualified to carry out this task and would understand the frustrations of the plantation members; and, 2) FSC^® advocates reducing the amount of pesticides being used in forestry across the board, in both natural and plantation forests – to what end? Would they push to end the use of pesticides completely?

Certainly the initial remit does raise eyebrows: “best feasible approach to reducing the use of chemical pesticides in FSC^® certified forests and plantations and to prevent, minimize and mitigated the related environmental and social impacts”. This is especially if the two statements are seen to be mutually exclusive, and thus the only way to prevent, minimise and mitigate the related environmental and social impacts is to reduce the use of chemical pesticides.

As an industry we are always striving to prevent, minimise and mitigate the environmental and social impacts of every aspect of forestry, not just our pesticide use. But we also believe that a blanket ban on pesticides is not the only way to achieve this, especially if there is no plan B in place to address the reason for pesticide use in the first place.

How has the forestry industry been represented during the formulation of the new pesticide policy?

Jacqui – We have had several opportunities to comment on draft versions of the policy and there have been a series of webinars that explain proposals with the opportunity to pass further comment. Feedback to the Pesticide Policy Working Group (PPWG) by the industry in South Africa, and the African continent as a whole, has provided a strong, united presence and voice.

We are not entirely certain if all our concerns have been taking into account in the final version. There has also been limited feedback during the commenting round, and about the ESRA document and IGIs in which TIPWG participated.

So has the industry’s voice been heard?

Jacqui – Yes, and no. Certainly there has been a move towards regionalisation when it comes to evaluating the risks posed by pesticides; this is something the sector pushed for. However, the change of emphasis towards a reduction to the point where pesticides are removed altogether, without a clear plan B is a big concern.

Below are the major changes we believe members should be made aware of and upon which TIPWG is acting:

1. A change in emphasis: the policy has shifted from “a reduction in the use of pesticides” to “a reduction to the point where pesticides are removed altogether”.

2. The Highly Hazardous List has been replaced with three lists:

   1. Prohibited – these cannot be used and there are no exceptions. Companies found to be using any products from the prohibited list will have their certificate suspended or taken away.

   2. Highly-restricted

   3. Restricted

ESRAs will be required for use of pesticides on both the highly-restricted and restricted lists. The list will determine how rigorous the ESRA needs to be. Certificate holders may collaborate on the development of generic ESRAs but unfortunately the process itself is highly academic and very tedious and will make pesticide use notably more complicated. That said, because of South Africa’s strict legislation (Act 36 of 1947), much of the ESRA has already been completed through the registration process. However, we will only know the full implications of the ESRA system once the Standards Development Group (SDG) has developed a final template for use and it has been approved by FSC.

3. There are no more derogations. This is very welcome as the derogation process was flawed and tedious. Often the emphasis was on the wrong information and use of certain pesticides was not understood at an international level. The new policy will place the focus on the ESRA’s, which will be conducted at a regional level using local experts with a local understanding of legislation etc. This will see more meaningful decisions being made.

4. The country’s SDG (made up of industry members, social and environmental chamber members) will need to update current IGIs

5. All private and third party nurseries will be encouraged to conform to the FSC^® Pesticide Policy and encouraged to keep records of pesticide use. TIPWG and SGASA have already been in communication and are currently collaborating on research projects going forward, including the one outlined above.

6. It is now going to be of the utmost importance to have a formalised IPM programme in place. The FSC^® Pesticide Policy refers to the use of pesticides as part of an IPM programme. Certificate holders will no longer be able to spray pesticides without sound evidence i.e why they have chosen pesticides over other non-chemical methods.

7. Monitoring is going to be a huge factor going forward, not just as part of IPM but also monitoring of the impact of the FSC^® Pesticide Policy itself! Certificate holders are going to have to think quite strategically.

What happens now?
Jacqui – Once the SDG has developed the IGIs and these have been approved, certificate holders will have one year to implement the required changes. As far as we understand, all derogations will be extended for this year.

Once TIPWG has thoroughly reviewed the newly published policy, we will be in contact with the SDG. We will also develop the required standard operating procedures (SOPs) and communicate with members in terms of the implications of the policy changes.

It is going to be a busy few months, while we get to grips with all of this.