Environmental and Social Risk Assessment (ESRA)

“A process to predict, assess and review the likely or actual environmental and social effects of a well-defined action, evaluate alternatives, and design appropriate mitigation, management and monitoring measures. In the context of the Forest Stewardship Council® (FSC®) Pesticide Policy, it relates to chemical pesticide use.” – FSC-POL-30-001 V3-0 EN

The new FSC pesticide policy requires ESRAs to be conducted − at a national, regional and management unit scale − before the application of any chemical pesticide. In doing so, ESRAs have become integral to FSC’s Integrated Pest Management (IPM) strategies, and are a fundamental requirement for any FSC certificate holder wishing to use chemical pest management options.

IPM FSC Pesticide Policy

The fundamentals of the ESRA concept proposed by FSC, as illustrated in the above diagram, are not dissimilar to the current IPM approach adopted by the South African forestry industry. There are however some distinct differences.

Conducting an ESRA
There are six basic principles that guide ESRAs and their implementation:

  1. The assessment is risk-based, thus:
    1. The prioritisation of criteria and categorisation of Highly Hazardous Pesticides (HHPs) results in the prohibition or restriction of their use according to the risk they pose to human health and the environment. Risk in this context being a function of the toxicity (hazard posed), which is both a global constant and the local exposure.
    2. In certain instances, a more hazardous alternative may present a lower social and environmental risk than a less hazardous option.
  2. An ESRA shall be undertaken by different stakeholders at international, national and management unit levels to identify:
    1. Lower risk alternatives.
    2. Conditions for chemical pesticide use.
    3. Adequate mitigation and monitoring measures.
  3. As risk increases, efforts to reduce or mitigate risk shall also increase.
  4. Under the same conditions of effectiveness and risk, the less hazardous pest management alternative shall be selected.
  5. FSC considers the risks associated with using FSC prohibited HHPs to be unacceptable due to their high toxicity even at low exposures.
  6. If a chemical pesticide is not included in the FSC list of HHPs, it does not mean that it deemed safe. Before using a chemical pesticide not listed in the FSC list of HHPs, the certificate holder shall undertake an ESRA.

Emphasis placed on risk
Understanding the elements of RISK considered in the ESRA is crucial when evaluating a pesticide:

LEGISLATION SIMPLIFIED FINAL_LARGE WEB
Hazard identification

The first step in a risk assessment is to identify the type and nature of the adverse effects associated with chemical pesticide use. Once the hazards are identified, proper measures can be taken to eliminate them.

Acute toxicity – to mammals and birds

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is:

  • ‘Extremely hazardous’ (Class 1a) or ‘highly hazardous’ (class 1b) according to the World Health Organisation (WHO) recommended classifications of pesticides by hazard.
  • Acutely toxic for rats and birds: acute oral LD50 for rats/birds ≤200mg/kg body weight (or most sensitive mammal/bird).
  • Fatal if inhaled (H330 according to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) as classified by national/international authorities.

Information sources:

Chronic toxicity – Carcinogenicity

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is in any of the following categories by classification systems:

  • Group 1: ‘The agent (mixture) is carcinogen to humans’ or Group 2A: ‘ The agent (mixture) is probably carcinogenic to humans’, according to the International Agency for Research on Cancer (IARC).
  • Group A (Carcinogens to Humans) (1986 Guidelines) or Group B (Probably Carcinogenic to Humans) (1986 Guidelines) or Known/Likely human carcinogen (1996 Guidelines) or Carcinogenic to humans (1999 and 2005 Guidelines-current) or Likely to be carcinogenic to humans (1999 or 2005 Guidelines – current), according to the US Environmental Protection Agency (EPA) Carcinogenicity Classification.
  • Category 1A (Known to have carcinogenic potential for humans) or category 1B (Presumed to have carcinogenic potential for humans), as classified by National/International authorities according to classification for carcinogens of the GHS.

Information sources

Chronic toxicity – Mutagenicity to mammals

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is in any of the following categories:

  • Category 1A (substances known to induce heritable mutation in germ cells of humans) or Category 1B (substances which should be regarded as if they induce heritable mutations in the germ cells of humans), as classified by national/international authorities according to the classification for mutagenicity of the GHS.

Information source:

Chronic toxicity – Developmental and reproductive toxicity

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is in any of the following categories:

  • Category 1A (known human reproductive toxicant) or Category 1B (presumed human reproductive toxicant), as classified by national/international authorities according to the classification for reproductive toxicants of the GHS.

Information source:

Chronic toxicity – Endocrine disrupting chemicals (EDC)

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is classified as:

  • Category 1 (substances for which endocrine activity have been documented in at least one study of a living organism) according to the EU list of potential endocrine disrupters.
  • Category 2 (suspected human carcinogens) of the classification for carcinogens of the GHS and Category 2 (suspected human reproductive toxicants) of the classification for reproductive toxicants of the GHS.

Information sources:

Environmental toxicity – Acute toxicity to aquatic organisms

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that:

  • Has aquatic toxicity LC50/EC50 <50 μg/l, using Daphnia as the test organism or other invertebrate or vertebrate aquatic organisms that show greater sensitivity than Daphnia. Acute test duration up to 96 hours.

Information sources:

Environmental toxicity – Persistence in soil or water and low sorption potential and bio-magnification, bio-accumulation

A pesticide is considered ‘highly hazardous’ if it contains any active ingredient that is considered:

  • Persistent (DT50>90 days), combined with
  • Low soil sorption coefficient (Kco <300ml/g), and/or
  • High water solubility (> 30mg/l).

It has the potential to accumulate in animal/human tissue:

  • Bio-concentration factor (BCF) for the active ingredient is ≥1000, or
  • Octanol-water partition coefficient (KOW) for the active ingredient >1000 u.e. logP (KOW) >3
  • NOTE: BCF data shall supersede the logP(KOW) data.

Information sources:

Dioxins

A pesticide is considered ‘highly hazardous’ if:

  • It is contaminated with any dioxins at a level of 10 part per trillion (corresponding to 10 ng/kg) or greater of tetrachlorodibenzo-pdioxin (TCDD) equivalent (TEQ), or it produces such an amount of dioxin(s) when burned.

Information source:

  • Stockholm Convention and national monitoring data.
Heavy metals

A pesticide is considered ‘highly hazardous’ if it contains any of the following heavy metals as active ingredient, inert or known impurity:

  • Lead (Pb)
  • Cadmium (Cd)
  • Arsenic (As)
  • Mercury (Hg)

Information source:

Exposure characteristics

Once the hazards have been identified, the second step is to conduct the exposure characterisation which analyses how different values are affected by chemical pesticide use. The exposure characteristics consider:

  1. Environmental and social values that can be affected by exposure to chemical pesticides.
  2. Exposure variables that influence the level of exposure.
Exposure elements

These are the types of values that may be negatively affected by chemical pesticide use.

At a minimum, the following environmental values shall be considered:

  • Soil (erosion, degradation, biota, carbon storage).
  • Water (ground water supplies, surface water and water supplies).
  • Atmosphere (air quality, greenhouse gases).
  • Non-target species (vegetation, wildlife, bees and other pollinators, pets).
  • Non-timber forest products – refer to FSC-STD-01-001 V5-2 FSC Principles and Criteria, criterion 5.1.
  • High conservation values – in particular HCV 1-4.
  • Landscape (aesthetics and cumulative impacts).
  • Ecosystem services (water, soil, carbon sequestration and tourism).

At a minimum the following social values should be considered, with regard to workers (migrant and seasonal), their families, neighbours, local communities, indigenous people and visitors to the forest:

  • High conservation values – in particular HCV 5-6.
  • Health (fertility, reproductive health, respiratory health, dermatologic health, neurological and gastrointestinal problems, cancer and hormonal imbalance).
  • Welfare.
  • Food and water.
  • Social infrastructure (schools and hospitals, recreational infrastructure, infrastructure adjacent to the management unit).
  • Economic viability (agriculture, livestock, tourism).
  • Rights (legal and customary).
Local exposure elements

The conditions of chemical pesticide use affect the level of exposure. To reduce the risk of chemical pesticide use, the following variables, at a minimum, shall be considered:

  • Formulation (type and components).
  • Mixture of active ingredients (composition and mixing process).
  • Concentration of the active ingredient(s).
  • Dose of the active ingredient(s).
  • Scale of treatment area.
  • Method of application (e.g. spot, foliar spray, aerial, broadcast).
  • Application system and equipment (e.g. knapsack sprayer, helicopter, drone plane).
  • Number of previous applications.
  • Metabolites of the active ingredient.
  • Capacity and skills of workers (license to handle pesticides, training, ability to read and understand labels and instructions).
  • Personal protective equipment
  • Emergency related equipment (e.g. first aid and spills kits).
  • Site conditions (e.g. soil type, topography of the area).
  • Predicted weather and climate conditions (e.g. wind speed and direction, temperature, humidity).
  • Spray drift.
  • Waste management systems.
  • Information available to neighbours about pesticide application (e.g. risks associated with pesticide use, re-entry period after application).

Multi-level ESRAs
ESRAs will be conducted on three levels:

  1. Internationally – To identify and categories HHPs; provide the minimum requirements for ESRA; and develop International Generic Indicators (IGI) for use and risk management of HHPs. This will be the responsibility of FSC in order to provide a control framework that will ensure consistency in the development of national indicators by Standard Development Group (SDG). For countries with no SDG, international IGIs will be the indicators used.
  2. Nationally – To identify highly restricted and restricted HHPs used or likely to be used in the country; conduct an overall risk assessment to identify and assess their risks; determine whether or not a highly restricted or restricted may be used; develop national indicators based on international IGIs; and the production of a country specific ESRA template. This will be done by the national SDG. It will be the SDG’s responsibility to provide a list of highly restricted and restricted HHPs which can be used in South Africa, the conditions of use and an ESRA template to aid certificate holders. In South Africa the national SDG is:
    • Economic Chamber – Dave Everard and Karin Kirkman
    • Environmental Chamber – Steve Germishuizen and David Lindley
    • Social Chamber – Jeanette Clarke and Cathy Sutherland
  3. Management unit – as part of an IPM strategy, a risk assessment at a management unit level must be conducted. The ESRA can be used, unless it can be demonstrated that ESRA requirements have been followed should other systems be in place to meet the ESRA requirements. It should be noted that, under similar conditions, management unit ESRAs may be transferable at a national level. At a management unit level, ESRAs will be done by the certificate holder, in order to identify the lowest risk option and any additional mitigation measures.The certificate holder is also responsible for incorporating ESRA results into operational plans or prescriptions for implementing mitigation measures at a site level.

Undertaking and interpreting ESRAs

  • Collaboration is allowed between certificate holders, who have similar forest conditions and pest problems.
  • Collaboration is encouraged among research institutes, and other organisations to identify and develop less hazardous alternatives.
When undertaking an ESRA, the certificate holder shall:
  • Perform comparative ESRA according to scale, intensity and risk (SIR) as part of its IPM strategy to identify the lowest risk option for a pest, weed or disease control, the conditions for its use and the generic mitigation and monitoring measures to minimise the risks.
  • Consider in their ESRA the minimum list of types of hazard and exposure elements and exposure variables (above). Annex 2 FSC-POL-30-001 v3-0 En
  • Conform with the applicable international and national indicators and thresholds for the use of HHPs.
  • Engage with stakeholders in conformance with the requirements in the applicable National Forest Stewardship Standard or Interim National Standard when conducting the ESRA.
When interpreting the ESRA findings, the certificate holder shall:

Give preference, as a matter of principle, to:

  • Non-chemical methods over chemical pesticides.
  • Chemical pesticides not listed in the FSC list of HHP over those listed in the FSC list of HHPs.
  • FSC restricted HHPs over FSC highly restricted HHPs.

Select the option that demonstrates the least social and environmental damage, more effectiveness and equal or greater social and environmental benefits.

Before applying any chemical pesticide, incorporate the results of their ESRA to site operational plans, to identify site-specific risks and adapt the generic mitigation and monitoring measures previously identified in the IPM ESRA (clause 4:12.2).

Make the ESRAs and incorporation to the operational plans available to affected stakeholders upon request.

Consult the online FSC database for information exchange on alternatives and monitoring procedures.

In addition:

  • Certificate holders need to have programmes in place, according to SIR, to research, identify and test alternatives to replace FSC highly restricted HHPs and restricted HHPs with less hazardous alternatives. Programmes shall have clear actions, timelines, targets and resources allocated.
  • Inform third party processing plants located in the spatial area of the management unit and third party nursery suppliers of the list of FSC prohibited chemical pesticides, encouraging them to avoid these pesticides in their processes and in the production of seedlings and other materials entering the management unit.
  • Request the list of FSC prohibited chemical pesticides used by processing plants and nurseries suppliers described above.
When monitoring the use of chemical pesticides, the certificate holder must:

Maintain records of chemical pesticide usage, including:

  • Trade name
  • Active ingredients
  • Quality of active ingredient used
  • Period of use
  • Number and frequency of applications
  • Location and area of use
  • Reason for use
When repairing damages to environmental values and human health from the use of chemical pesticides, the certificate holder shall:

Prioritise risk prevention and mitigation over damage repair and compensation.

Repair damages according to their magnitude, in consistency with Criterion 6.3 of FSC-STD-01-001 FSC Principles and Criteria v5-2, regarding environmental damage and Criterion 2.6 regarding occupational injuries.

FSC’s change in stance on chemical use

The new FSC Pesticide Policy takes a far stronger stance with regards to minimising pesticide usage than any of the previous versions:

The organisation shall use IPM and Silviculture systems which avoid, or aim at eliminating, the use of chemical pesticides. The Organisation shall not use any chemical pesticides prohibited by FSC policy when pesticides are used, the organisation shall prevent, mitigate and or repair damage to environmental values and human health.FSC-POL-30-001 V3-0 EN

They do however recognise that in certain circumstances, and after having considered other available pest management strategies, the use of chemical pesticides may be the only feasible way of controlling the pest problem.

FSC moving from a hazard to risk-based approach

The new policy brings a marked change in the way chemical pesticides are evaluated, placing the emphasis on risk rather than hazard (toxicity).

As the South African forestry sector, this is something we have pushed for, as the impact chemical pesticides on the environment or human health is as a result of a risk (hazard and exposure) being realised and not as a result of their inherent properties (hazard alone).

Moving to a risk-based approach ensures potential hazards are not viewed in isolation, but rather consider the context and the likelihood of that hazard being realised. It does mean that at an international, national and local level environmental and social risk assessments (ESRAs) will need to be conducted.

The ESRA system developed by FSC, has been implemented at an international level by FSC to identify and categorise pesticides and provide for the minimum requirements of an ESRA. Once the International Generic Indicators (IGIs) and risk management strategies have been developed at a global level, national level ESRAs can be conducted by the Standard Development Group (SDG). These will confirm the FSC pesticide listing, establish the country-specific conditions for their use and help establish a country-specific ESRA template for certificate holders, who can then begin to conduct ESRAs at a management unit level.

A new way of looking at Highly Hazardous Pesticides (HHPs)

One of the biggest changes is the way the new FSC Pesticide Policy categorises chemical pesticides.

It groups pesticides into four categories:

  1. Prohibited – listed in Annex A of the Stockholm Convention, Annex III of the Rotterdam Convention, or in the Montreal Protocol. These are:

    1. Acutely toxic and can induce cancer (carcinogenic or likely to be)
    2. Contain dioxins
    3. Contain heavy metals
  2. Highly restricted – fall into two or more of the following hazard groupings:
    1. Acute toxicity
    2. Chronic toxicity
    3. Environmental toxicity
  3. Restricted – fall into any of the following hazard groupings:
    1. Acute toxicity
    2. Chronic toxicity
    3. Environmental toxicity
  4. Other – chemical pesticides not within a category above (including biopesticides) are not considered highly hazardous.

By doing this, FSC have essentially done away with derogations with prohibited pesticides only permitted in emergency situations and as a result of a government order. Click here – for Annex 3 (FSC Pesticide Policy) that governs the use of prohibited pesticides in emergency situations and under government order.

Pesticide use during the transition period up to interim implementation 1 August 2020

Prohibited HHP
Those with approved derogations, such as Paraquat, can be used as per derogation conditions until the 1 August 2020 cut off, after which they will be banned from use, unless in an emergency situation or under government order.

Those with no approved derogation are banned from use – effective 1 August 2019 – unless in an emergency situation or under government order. An example of this is Trichlorfon which was on the TIPWG approved list and is now prohibited as of 1 August 2019.

Highly restricted and restricted HHP
Those with approved derogations can be used until 31 July 2020, after which an ESRA will need to be performed.

Those with no approved derogation will need to undergo an ESRA before use; the ESRA should incorporate:

  • Information from the country’s most recent approved derogation.
  • Requirements from the most recently published draft of the HHP – International General Indicators (IGIs)

NOTE: Newly listed HHPs and those not previously listed will only need ESRAs from the 1 August 2020 although certificate holders are encouraged to implement ESRAs ahead of this cut-off time. All pesticides listed on the TIPWG APL will only require an ESRA from 1 August 2020. However, certificate holders wanting to use HHP not on the TIPWG approved list will need to conduct ESRAs as of 1 August 2019.

Other
These can be used freely until the 1 August 2020 cut-off date, after which they will require ESRAs.

Developing IGIs

FSC is currently developing international IGIs (refer to the implementation timeline). Once the international IGIs have been published, South Africa’s SDG will have to translate these into applicable national IGIs and which can be tested nationally. Only then can ESRAs begin to comply with the FSC requirement.

ESRA at a National Level

For each restricted and highly restricted HHP used, or likely to be used, SDGs shall conduct an overall environmental and social risk assessment considering Annex 2 (minimum list of hazards, elements and variables to consider in the assessment of environmental and social risks) to identify and assess key risks.

Based on the ESRA’s risk characterisation, SDGs shall determine whether or not the HHP may be used at the national level.

For each highly restricted and restricted HHP permitted for use, the SDGs shall develop indicators and locally relevant thresholds for its use at the national level.

As a starting point, SDGs shall consider the IGIs which are currently under development by FSC.

The indicators shall consider the scale, intensity and risk (SIR) of the pesticide use. As the risk to social and environmental values increases, so too shall the frequency and intensity of stakeholder engagement, monitoring, research activities and mitigation measures.

To conduct the assessment and develop indicators, SDGs shall consider:

  1. Information in chemical labels.
  2. Material Safety Data Sheets (MSDS).
  3. Existing national, or regional, risk assessments undertaken by regulatory agencies.
  4. Conditions for derogations approved in the country when applicable.

The national indicators shall:

  1. When possible, define circumstances where highly restricted HHP may be used instead of a restricted HHP.
  2. Be submitted to FSC for decision making in accordance with FSC-STD-60-006 Process Requirements for the Development and Maintenance of National Forest Stewardship Standards.
FSC ESRA Template

Click here – the ESRA Template pgs 40-42