Update on Pesticide Derogations 2016

Key Points

  • FSC restricts use of Highly Hazardous pesticides in certified forests subject to approvals called derogations
  • 10 forest companies FSC certified, or seeking certification, developed derogation applications in November 2015 to enable continued use of four restricted pesticides
  • In total 129 stakeholders provided feedback on the derogations applications
  • On 24 November 2016, FSC International approved subject to conditions, 3 of the 4 pesticide derogations (sodium fluoroacetate, amitrole and alpha-cypermethrin) and rejected 1 (fipronil).

Background to derogation applications

Where a FSC Highly Hazardous pesticide is the only viable tool available to the forest manager, FSC acknowledges that its controlled use may be warranted. In these instances, FSC invites forest managers to submit a derogation application outlining why use of this chemicalis required.

In 2015, a group of 10 Australian forest companies currently FSC certified, or seeking FSC certification, developed derogation applications to enable the continued use pesticides listed as FSC Highly Hazardous.

Derogations were sought on four pesticides; Sodium Fluroacetate (1080), Alpha-Cypermethrin, Fipronyl and Amitrole. It should be noted that all these chemicals are registered for use in Australia by the Australian Pesticides and Veterinary Medicines Authority.

FSC International Decision

On 24 November 2016, the FSC International Pesticides Committee made a final decision on the pesticide derogation applications submitted by Australian certificate holders and concluded the following:

  • Approved with conditions a derogation to use Sodium Fluoroacetate (1080) to control: European Fox (Vulpes vulpers), FeralCats (Felis catus), Wild Dog (Canis familiaris), Wild pig (Susscrofa), Rabbit (Oryctolagus cuniculus) (Western Australia only) and Pale Field Rat (Rattus tunneyi var culmorum) (Queensland only)
  • Approved with conditions a derogation to use Amitrole to control various grasses and broadleaved weeds
  • Approved with conditions a derogation to use Alpha-Cypermethrin to control a range of herbivorous insects including; Chrysomelid leaf beetles (Paropis spp. And Paropsisterna spp.), Weevils (Gonipterus spp.), Shot hole miner (Perthisa spp.), Gumleaf skeletoniser (Urabalugens ), Cup moth (Doratifera spp.), Sawfly’s (Perga spp.), Scarab beetles (Heteronyx spp., Liparetrusspp., Cadmus spp.), Christmas beetles (Anoplognathus spp.) and Autumn gum moth (Mnesampela privata)
  • Rejected a derogation to use Fipronil to control European wasp (Vespula germanica)

The conditions for use for sodium fluoroacetate, amitrole and alpha-cypermethrin, and reasons for rejecting fipronil’s application are contained in the attached documents.

Overview of the consultation process

A key part of the process was for Forest Managers to run a consultation process that sought input from stakeholders on derogation applications and demonstrate to FSC International how feedback had been considered.

An engagement plan was developed by independent engagement expert, Dr Lain Dare.
The plan is available at https://au.fsc.org/preview.3-1summarystakeholderen […].

The consultation process included the establishment of an independent Pesticide Derogation Advisory Group who were tasked with reviewing stakeholder feedback on derogation applications. The first round of stakeholder feedback occurred between 25 September and closed on16 November 2015.

The original derogation documents are available here - https://au.fsc.org/en-au/standards/seeking-comment […].

The original consultation was on a total of nine derogations, however changes by FSC International in November 2015 meant that five of the nine pesticide derogation applications were no longer required to be submitted as part of this derogation current process.


Details of the changes to the FSC process are available here - https://au.fsc.org/en-au/newsroom/id/225.

A second round of stakeholder feedback opened on the remaining four pesticides between 24 December and 24 January 2016.

A Stakeholder Feedback Report was developed by Dr Lain Dare and can be downloaded as a summary and full report below. The report provides a summary of the outcomes of the FSC Highly Hazardous Pesticide Derogation stakeholder feedback, including survey responses, feedback received from public comments, communication with forest company representatives and feedback from certifying bodies.


Supporting Documents

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