Thursday, 20 February 2020
Consultation: How should risks from Highly Hazardous Pesticides be managed in FSC-certified forests?
As part of the implementation of our revised Pesticides Policy, FSC has launched a public consultation on International Generic Indicators (IGIs) for the use of Highly Hazardous Pesticides (HHPs).
The revised Policy imposes restrictions on the use of particular chemical pesticides which FSC considers, on the basis of international criteria and indicators, to be highly hazardous. We are in a transitional period at present, but once the Policy is fully implemented it will only be possible to use a Highly Hazardous Pesticide if the relevant forest stewardship standard contains indicators for that specific chemical (although there are also provisions for emergency use and use of chemicals by government order). Those pesticide-specific indicators must be based on the IGIs for all HHPs (section 1 in the consultation draft) and the HHPs for the relevant hazard criterion (sections 2 to 11 in the consultation draft).
For countries like Australia that already have a forest stewardship standard, the IGIs will be adapted to local conditions and incorporated into the standard. Stakeholders will, of course, have the opportunity to comment on pesticide-specific indicators developed for Australia. Right now, though, you can comment on the draft international framework for those indicators.
The consultation draft might look daunting at first. However, the structure is logical, with terms and definitions followed by proposed changes to indicators governing the use of all chemical pesticides, followed by indicators governing the use of all Highly Hazardous Pesticides, followed by indicators governing the use of HHPs by specific hazard criterion. The indicators themselves are quite short, but there are extensive instructions for standard developers describing the sources of information which must be considered when adapting indicators to specific chemicals and national circumstances, as well as examples of medical biomonitoring or trigger values which may be appropriate for different hazard criteria, and an appendix summarising appropriate personal protective equipment and biomonitoring for each hazard criterion.
You are free to comment on any aspect of the draft IGIs, but the consultation includes specific questions on issues such as definitions, recording requirements, and the availability and feasibility of medical biomonitoring methods. You may answer as many or as few questions as you wish.
The revised FSC Pesticides Policy signifies a big step forward in how FSC regulates the use of pesticides in forests, and the IGIs are an important part of that. They represent a fine balance between the needs of countries without a national standard development group, where they must be adopted as written, and countries where there is such a group, where they can be adapted to specific national conditions. They also need to provide enough concrete guidance on issues such as biomonitoring to ensure that they can be applied consistently. But the views of all stakeholders on whether the right balance has been struck will be very important in refining the draft, and FSC Australia would encourage everyone to take the opportunity to express their views.
FSC International will be running a number of webinars to present the draft IGIs and to give you the opportunity to ask questions directly. We will let you know once dates have been announced.
The consultation is open until 1 April 2020 CET.
What makes a pesticide ‘highly hazardous’?
FSC’s definition of Highly Hazardous Pesticides (HHPs) is based on the FAO/WHO International Code of Conduct on Pesticide Management. This defines Highly Hazardous Pesticides as:
‘Pesticides that are acknowledged to present particularly high levels of acute or chronic hazards to health or environment according to internationally accepted classification systems such as the World Health Organization (WHO) or the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) or their listing in relevant binding international agreements or conventions. In addition, pesticides that appear to cause severe or irreversible harm to health or the environment under conditions of use in a country may be considered to be and treated as highly hazardous.’
FSC builds on this definition by also explicitly including dioxins and heavy metals.
FSC distinguishes between FSC prohibited HHPs, FSC highly restricted HHPs and FSC restricted HHPs:
- FSC prohibited HHPs: chemical pesticides that: a) are listed or recommended for listing under Annex A (elimination) of the Stockholm Convention on Persistent Organic Pollutants or Annex III of the Rotterdam Convention on the Prior Informed Consent Procedure, or listed under the Montreal Protocol on Substances that Deplete the Ozone Layer, or b) are acutely toxic and that can induce cancer (carcinogenic and likely to be carcinogenic), or c) contain dioxins or d) contain heavy metals).
- FSC highly restricted HHPs: chemical pesticide presenting two or three out of the following hazards: acute toxicity, chronic toxicity and environmental toxicity.
- FSC restricted HHPs: chemical pesticide presenting one out of three of the following hazards: acute toxicity, chronic toxicity and environmental toxicity.
All of these classifications are based on clearly defined indicators and thresholds, and relevant published data. You can read about the indicators and thresholds in detail in annex 1 of the FSC Pesticides Policy, and see all of the currently identified prohibited, highly restricted and restricted HHPs in the FSC Lists of highly hazardous pesticides.