The highly anticipated update of the Forest Stewardship Council® (FSC®) Pesticide Policy on May 2019 lived up to its pre-release hype with the reiteration taking a far stronger stance on minimising pesticide usage. TIPWG secretariat Jacqui Meyer explains, “The new policy requires certificate holders to use Integrated Pest Management (IPM) strategies and silviculture systems which avoid, or aim to eliminate, the use of chemical pesticides. FSC Certificate Holders are no longer able to use prohibited chemicals (as classified by the policy) and are required to prevent, mitigate and/or repair damage to environmental values and human health when any pesticides are used.”
Despite its firm anti-pesticide stance, FSC does recognise that in certain circumstances, after considering other available pest management strategies, the responsible use of chemical pesticides may be the only feasible option for control.
From hazard to risk-based assessment
The new policy brings a marked change in the evaluation of chemical pesticides, placing the emphasis on risk rather than hazard (or toxicity).
“This is something the South African forestry sector has pushed for,” continues Meyer, “as the impact of chemical pesticides on the environment and/or human health is as a result of both hazard and exposure (risk) and not just their inherent properties (hazard alone).”
By moving to a risk-based approach, potential hazards are no longer considered in isolation but in the context of that hazard being realised. This can be then mitigated and managed; something which could not be done using hazard-based criteria.
However, by moving to a risk-based approach, an assessment (that considers both the intrinsic environmental and social hazards and the likelihood of exposure to them) is now required.
To this end, FSC developed the Environmental, Social Risk Assessment (ESRA) system which will require implementation at three levels:
- Internationally – ESRAs conducted by FSC will identify and categorise pesticides, provide the minimum requirements of an ESRA and identify International Generic Indicators (IGIs) along with risk management strategies.
- Nationally – ESRAs will be conducted by the Standard Development Group (SDG) of that particular country. The country’s SDG will confirm the FSC pesticide listing and establish country-specific conditions for their use and IGIs, while also establishing a country-specific ESRA template for Certificate Holders.
South Africa’s SDG comprises:
- Economic Chamber – David Everard and Karin Kirkman
- Environmental Chamber – Steve Germishuizen and David Lindley
- Social Chamber – Jeanette Clarke and Cathy Sutherland
They will confirm the FSC pesticide listing and establish country-specific conditions for their use and IGIs, while also establishing a country-specific ESRA template for Certificate Holders. It is the national SDG’s responsibility to provide a list of pesticide chemicals on the Highly Restricted and Restricted Highly Hazardous Pesticide (HHP) lists which can be used in South Africa and the conditions for their use.
- Management Unit Level – Certificate Holders will conduct ESRAs, unless they can demonstrate that ESRA requirements have been met by other systems already in place. In order to identify the lowest risk option and any mitigation measures that may be required, the certificate holder is also responsible for incorporating the ESRA results into its operational plans or prescriptions for implementing mitigation measures at a site level.
ESRA – how it’s done.
The fundamentals of the ESRA concept proposed by FSC, as illustrated in the diagram below, are not dissimilar to the current IPM approach adopted by the South African Forestry Industry. There are however a number of distinct differences that need to be accounted for. These are covered in the six basic principles that guide ESRAs and their implementation:
- The assessment is risk-based, thus:
- The prioritisation of criteria and categorisation of HHPs results in the prohibition or restriction of their use according to the risk they pose to human health and the environment. In this context, risk is a function of toxicity (hazard posed – a global constant) and local exposure.
- In certain instances, a more hazardous alternative may present a lower social and environmental risk than a less hazardous option as a result of the associated exposure.
- An ESRA shall be undertaken by different stakeholders at international, national and management unit levels to identify:
- Lower risk alternatives
- Conditions for chemical pesticide use
- Adequate mitigation and monitoring measures
- As risk increases, efforts to reduce or mitigate risk shall also increase.
- Under the same conditions of effectiveness and risk, the less hazardous pest management alternative shall be selected.
- FSC considers the risks associated with using FSC prohibited HHPs to be unacceptable due to their high toxicity, even at low exposures.
- If a chemical pesticide is not included in the FSC list of HHPs, it does not mean that it is deemed safe. Before using a chemical pesticide not listed in the FSC list of HHPs, the certificate holder shall undertake an ESRA.
The role of TIPWG
The summary below highlights the various roles of FSC, the Standards Development Group (SDG) and the Certificate Holders (CHs or organisations) in the implementation of the new pesticide policy:
- Provides a control framework to ensure consistency in the development of national indicators by SDG (Work in progress; no indication of date).
- Identify Highly Restricted (HR) and Restricted (R) Highly Hazardous Pesticides (HHPs) used or likely to be used on FSC certified MU’s in RSA.
- Conduct overall risk assessment (RA) to ID and assess the risks posed by the HHPs.
- Based on the RA, determine whether or not the HR/R may be used in country.
- Develop National Indicators for use and risk management of allowed HR/R using IGI as starting point.
- SDGs may complete ESRA template to assist CHs to conduct ESRA.
- Conduct RA as part of IPM system according to SIR.
- May use ESRA template to complete ESRA at MU level OR demonstrate that ESRA requirements have been followed, if other systems are in place to meet requirements (NB: under similar conditions ESRA may be transferrable between CHs at national level).
- Conform with the applicable international and national indicators and thresholds for use of HHPs.
Role at site level (CHs):
- Incorporate ESRA results into operational plans/prescriptions.
- Implement mitigation measures.
As a collaboration of South African Forestry Industry pesticide experts, TIPWG submitted a proposal to the South African SDG and FSA’s Environmental Management Committee, proposing that TIPWG be appointed by the SDG to conduct national ESRAs.
TIPWG will fulfil the national ESRA requirements, as stipulated in the pesticide policy before going a step further and creating a TIPWG Approved Pesticide List (APL) based on the ESRA outcomes. This APL will stipulate conditions with which Certificate Holders will have to comply with at a Management Unit level. Furthermore, the APL would act as “an alternative to ESRAs at a Management Unit level, by ensuring ESRA requirements have been followed by other systems already in place.”
If the TIPWG APL is accepted by FSC as a suitable Management Unit ESRA alternative, it will make life easier for South African Certificate Holders as they will no longer need to produce individual Management Unit level ESRAs for every chemical pesticide they use, as long as they show compliance with the TIPWG APL.
So, where are we at?
With the proposal and funding approved by FSA, the process is currently under way. The initial risk assessment is complete and will be available soon for FSA members. From this and the data collected by Jonathan Roberts (a TIPWG sponsored NMU student) for his PhD (The development of an economic, environment and social pesticide risk model for plantation forests in South Africa), the pesticide list has been prioritised and ESRAs will be completed according to their FSC ranking (based on ecotox data) and volumes used in the industry.
To keep up-to-date with this process, go to www.tipwg.co.za and subscribe to our quarterly newsletters.