Pesticides are a feature of many parts of our lives, and as time goes by, we are learning more about less obvious, chronic, cumulative and interacting effects of their use. Sadly, global average pesticide use per area of cropland is much higher now than it was in the 1990s. Agriculture may be the major player in pesticide usage, but how can we in the forestry sector contribute to turning the tide? How can we ensure that our forests remain full of life, and that they support livelihoods without invisible threats to the health of forest workers?
Surely very few forest managers use pesticides uncritically – even if our motivations were purely financial, pesticides might be cheaper than some other control options, but they still cost money. Maybe there are a few people out there who apply pesticides just because that’s what they’ve always done, but on the most part, those applying chemical control agents are going through some sort of thought process beforehand, even if only to decide whether it is worth incurring the cost. With responsible forest managers already thinking far more broadly about environmental and social costs. The challenge is how we take that thinking to the next level, and make sure that all foresters are thinking along the same lines?
The revised FSC pesticides policy is intended to facilitate this, by changing the way we think about pesticides.
Principles and policies – what are they for?
The FSC Principles and Criteria already require forest managers to use integrated pest management and silviculture which avoids, or aims at eliminating, the use of chemical pesticides. They forbid the use of any chemical pesticides prohibited by FSC policy, and when pesticides are used, they require forest managers to prevent, mitigate, and/or repair damage to environmental values and human health. There is a clear role for the FSC pesticides policy here, but what else does it bring to the mix?
An important emphasis of the policy was, and remains, on the control of the use of Highly Hazardous Pesticides (HHPs). It is worth noting that this is not a concept unique to FSC – both the Food and Agriculture Organization (FAO) of the United Nations and the World Health Organization (WHO) refer to HHPs – but, through the pesticides policy, FSC aims to ensure that the concept is applied consistently and robustly in FSC-certified forests across the world. The aims of the policy go further, the stated short-term objectives are to:
• Promote best practices to minimise associated risks to human health and the environment when using chemical pesticides.
• Reduce the overall volume and number of chemical pesticides in use; and,
• Eliminate the use of the most hazardous chemical pesticides.
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Not all pesticides are equal…
In the previous iteration of FSC’s policy and procedures, a HHP was a HHP was a HHP – there was no distinction between them, and all were subject to the same controls. The revised policy recognises three different categories of Highly Hazardous Pesticides i.e.: restricted, highly restricted, and prohibited.
Prohibited HHPs are the worst of the worst – chemical pesticides so dangerous that the risks associated with them cannot be realistically managed. Using international conventions regulating global pesticide use, they have been identified on the basis of their inherent properties: if they are acutely toxic and can induce cancer, if they contain dioxins, or if they contain heavy metals. FSC permits their use only in emergency situations or if mandated by a government order.
Restricted and highly restricted HHPs can be used in FSC-certified forests if the requirements of the Policy are met. Restricted HHPs fall into one of the hazard groups acute toxicity, chronic toxicity, or environmental toxicity – highly restricted HHPs fall into two or three of these groups.
This categorisation recognises that there is considerable variation among Highly Hazardous Pesticides, and allows us to take a more nuanced approach to manage the risks they present – this should steer us towards the least hazardous options, and to the most effective management of risk.
No more derogations? Thank goodness!
The revised policy does away with the previous system of derogations, whereby anyone who wanted to use a Highly Hazardous Pesticide had to apply to FSC International for temporary permission to deviate from FSC’s rules – a derogation. It is fair to say that this system was pretty unpopular. There was a charge for the processing of derogation applications, and decisions were made by a central committee which realistically could not be aware of all the subtleties of every national situation. New policy requirements remove the need for charges and shift a lot of decision making to the national level.
A consistent approach to risk
To replace the centralised derogation system, the revised policy introduced a framework of environmental and social risk assessment (ESRA), with elements operating at international, national and management unit levels.
Broad rules are set by FSC International, including what factors should be considered, and how. The South African Standard Development Group, with support from the Timber Industry Pesticides Working Group (TIPWG), will adapt the finalised international generic indicators for HHPs and assist with the development and roll-out of the ESRAs (www.tipwg.co.za).
The Policy requires the identification and assessment of key environmental and social risks associated with each restricted or highly restricted HHP used or likely to be used in the country. Thankfully, the bulk of this work has already been completed by TIPWG for South Africa. Once the approved international generic indicators are released by FSC, standard developers will undergo an assessment of each HHP utilised in South Africa and will engage with stakeholders in this process, which represents the key shift from international to national deliberation.
Individual certificate holders will eventually have to comply with these national indicators and thresholds, alongside the policy ESRA requirements. TIPWG has developed environmental and social risk assessments for South Africa to identify the lowest risk option to control a given pest, weed or disease, giving preference to non-chemical methods over chemical pesticides, non-HHPs over HHPs, and restricted HHPs over highly restricted HHPs. Before foresters apply any chemical pesticide, they must incorporate the results of the ESRA into operational plans, identifying site-specific risks and adapting generic mitigation and monitoring measures accordingly.
Risk assessments might sound bland, but this is powerful stuff, bringing new and consistent thinking to integrated pest management. Every one of us will have to think in terms of hazard levels, and in terms of a broad range of environmental and social risks. We’ll even have to discuss those issues at a national level, making informed decisions about what Highly Hazardous Pesticides we think it is acceptable to use in our country. The revised policy might not bring about wholesale change overnight, but it will at least ensure that we are all thinking the right thoughts and moving in the right direction.
But will it really change the way we think in South Africa?
In short, yes, I hope so. We are already seeing change within the sector with greater levels of risk-based thinking being integrated into Certificate holder’s integrated pest management strategies and operational activities. This accompanied with the research into alternatives for restricted chemicals and other HHPs will hopefully yield long term positive results for the foresters, workers and the environment.
We all need to see pesticides from a new perspective
If 2020 has taught us anything, it is that nothing can be taken for granted. A pandemic is just one symptom of the profound influence we have on the natural environment. Pesticides have revolutionised the way we interact with that environment, and while we have gained from their use, we also now face problems entirely of our own making, including threats to our own health. It is likely that some of the damage we have caused cannot now be undone. Are you ready to change your perspective on pesticides before things get worse?