By Jacqui Meyer
On 3 April 2020, the Forest Stewardship Council® (FSC®) released an update to the interpretation of ‘Implementation of the Pesticide Policy’.
The update clarifies the role of the draft ‘Highly Hazardous Pesticide – International Generic Indicators’ (HHP-IGIs) during the transition period for Scenario Two.
Scenario Two is the use of HHPs where the certificate holder has no pre-approved derogation for the use of the particular HHP. This is regardless of the HHP class – prohibited, highly-restricted, or restricted.
In Scenario Two, certificate holders are required to “incorporate to the ESRA the requirements from the most recent published draft of the HHP-IGI” for all HHPs.
The update contextually defines the use of the word ‘incorporate’: “In this context, ‘incorporate’ means that the certificate holders shall review the most recent draft of the IGIs for the use of HHPs published by FSC International to identify aspects applicable to the HHP they intend to use, and, if relevant, bring these aspects into their ESRA.”
What does this mean to the forester on the ground
It means that certificate holders will need to review the latest draft of the HHP-IGIs and consider them in the development of the ESRAs with regards to each HHP used. If there are any HHP-IGIs with which certificate holders disagree, they will need to be justified and documented to demonstrate consideration of each HHP-IGI.
Certificate holders will be required to provide this to their certification bodies as of 1 August 2020.
In addition to this, once the HHP-IGIs are finalised, the Standard Development Group will need to amend the ESRAs at the national level and submit to FSC for approval.