How the FSC broke, then further weakened, its rules on pesticides

In December 2006, FSC-Watch reported on how the FSC had bowed to pressure from the plantation industry to ‘freeze’ implementation of its pesticides policy, which prohibits the use of a chemicals included on FSC’s ‘banned’ list. Under a decision taken by the International Board, FSC decided to extend until the end of June 2007 the deadline by which forestry companies had to apply for special ‘derogation’ permission to continue using banned chemicals. But FSC-Watch can now reveal that FSC has conspired to allow use of banned chemicals even where no derogation has been granted – and has now removed one of the major ‘safeguards’ that ensured that pesticide derogations were supported by local stakeholders.

Under the FSC’s rules until mid-2007, derogations could only be granted where such a derogation is supported by the relevant National or Regional FSC initiative. In 2006, a derogation for the use of ‘banned’ alpha-cypermethrin – a ‘highly toxic’ substance used to treat plantation seedlings – was sought by Soil Association WoodMark on behalf of its certified client, the Irish State forestry company, Coillte. The request was duly considered at the end of 2006 by the FSC-accredited national body, the Irish Forestry Certification Initiative – but the request was not approved, and the FSC Secretariat, in the person of Frank Katto, was informed of this.

As Coillte’s derogation request had failed to gain IFCI’s approval, the matter should have ended, and Coillte should have ceased all use of cypermethrin. However, WoodMark still forwarded the derogation request to the FSC Secretariat. In a letter to an Irish stakeholder in December 2006, FSC’s Katto confirmed that there had been no support for the derogation from IFCI, and that the derogation request was therefore not valid: *”according to the current FSC procedures for processing derogations applications, the Policy and Standards Unit cannot process an application until a written letter of support from the responsible FSC-accredited National Initiative is received. I was informed that cypermethrin application has been submitted without the letter of support from the Irish FSC-accredited National Initiative”.

Nevertheless, in September 2007, a conference on water quality issues in Ireland was told that Coillte were at that time still using cypermethrin, and that a derogation had indeed been granted by the FSC. In the same month, following an inspection of Soil Association WoodMark’s certification of Coillte, FSC-ASI reported that “Soil Association and the certificate holder have presented an official request for derogation regarding the use of alpha-cypermethrin” and that “this derogation is currently being reviewed by the FSC in line with FSC requirements” – thus ignoring the fact that the request had not been approved by IFCI, and that WoodMark had been seriously at fault for firstly submitting a ‘non-approved’ derogation request and then failing to sanction Coillte for continued use of a banned pesticide. ASI nevertheless concluded that it “did not detect any non-conformity” in Soil Association’s behaviour.

ASI did, however, find that another banned pesticide, simazin, was also in use, without a derogation, by Coillte in its tree nurseries – but noted that, for reasons that have never been explained by WoodMark, the Coillte nurseries have been excluded altogether from their certification assessment – even though it is clear that nurseries form an integral part of plantation operations, and are required to be assessed under FSC Criterion 10.7. By excluding the nurseries from their certificate, Woodmark had circumvented the need to apply for a further pesticide derogation for simazin.

Even though ASI had actually detected two major breaches of the spirit and the letter of FSC’s rules by WoodMark, their meek response was to issue a ‘Minor Corrective Action Request’ against WoodMark.

As at March 2008, Coillte continue to use cypermethrin, more than a year after their request for a derogation for its use was rejected by the Irish National FSC Initiative – a situation which is not only contrary to FSC’s requirements, but utterly unacceptable to Irish stakeholders. Once again, ASI has allowed a certifier to operate with complete disregard for FSC’s rules.

FSC-Watch invites readers to submit information about other cases of banned pesticides in use in FSC certified operations.


In May 2007, FSC changed its rules for dealing with pesticide derogations (see below). National Initiatives were stripped of their role in giving consent to derogation requests – which are now entirely the responsibility of the certification body. National initiatives will now ‘be informed’ by certifiers of derogation requests, and are charged only with ‘assisting with public consultations’ on the derogation – even though the national initiative might well have established a national FSC standard excluding precisely the pesticides for which the certifiers might be seeking a derogation.

Once again, FSC appears to have conceded to the economic interests of the certifiers, who of course have a strong vested financial interest in supporting use of pesticides (because this allows them to certify planet-poisoning companies that would otherwise be excluded from certification), whereas the multistakeholder national initiatives are reduced to merely supporting the business of the certifiers.


4.3 “For countries in which there is an FSC-accredited National Initiative, the certification body shall inform the National Initiative that it will apply for a derogation for the use of a ‘highly hazardous’ pesticide, and shall give the NI the option of assisting in the consultation with stakeholders in the country in relation to their opinions on the application and in developing the derogation application. The FSC-accredited National Initiative should endeavour to assist the certification body, within the limitations of its resources. However, the certification body is responsible for completing the derogation application, whether or not the National Initiative is able to contribute.”


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