Cooperative Program in Forest Certification

Project 01. Pesticide Policy

Condition: FSC sent in April 2010 the document “Recommendations regarding Derogations to use alpha-Cypermethrin, Deltamethrin, Fenitrothion, Fipronil and Sulfluramid in FSC Certified Forests in Brazil” with the recommendations regarding the derogations requested by Brazil. This document is being examined by CPFC along with work in partnership with Equilíbrio Proteção Florestal company, to comply with the recommendations specified by FSC and indications of how these conditions can be treated and enforced by the companies has approved their derogation procedures.

Figura 1
Figure 1
. Damage caused by leaf-cutting ant attack in Eucalyptus spp plantation.

Performance of CPFC: The program was largely due to demand arising in 2007 when FSC published an update of its list of pesticides prohibited from use in certified forests. Due to the input of active ingredients (a.i) present in many of the products used to combat pests and diseases which are common to the reality of forest plantations in Brazil, it was necessary to ask permissions for using these products by the companies through a process known as Derogation Process. This process allows the company to ask FSC the use of an active ingredient banned by FSC, since it is proven the significance of the pesticide use. From there, was held a first meeting with interested companies in forming a cooperative program that would act in this process, which required great effort to compile various data required, including public consultations with interested parties (or stakeholers). The first step was to hold consultations with the FSC International Center on the procedure for derogation of various pesticides. In order to consolidate the information needed to process, meetings were held between researchers and technical suppliers of chemicals to define the description of the pesticides which were requested derogations. From this initiative, an official meeting was held to creating a program..

Figura 2
Figure 2
. Meeting the Program´s Inception.

The program worked with companies in the informations gathering about the management (use) of all pesticides that would be requested by derogation. For more articulation on the subject, meetings were also held with the certification companies to define a strategy for public consultation regarding the derogation process of pesticides established as restricted use by FSC. The public consultation was carried out via registered letters, emails, interviews, direct contacts and through the website of IPEF. At the same time the CPFC facilitated meetings between researchers and chemical companies for the elaboration of technical justifications for derogation process, as well as a detailed description of products and management adopted by these companies.

At the end of the public consultation were performed analysis, result compilation and translation of documents that were filed with the FSC International, to request the derogation for the temporary use of pesticides that have usage restrictions.

Although the proceedings have been referred in November 2007, FSC International has postponed its position regarding the derogations requested by February 2009. During this period the CPFC actively participated in monitoring the process, demanding positions and sending additional information requested by the FSC-International.

The results of the derogations process came with some recommendations (e.g., alternative products and methods, training, monitoring, etc.), which were analyzed by the program along with EquilíbrioProteção Florestal company in order to organize these informations and indicate actions that aim help companies deal with these constraints. This cooperative program had an opportunity to consolidate this work to representatives of major Certification Bodies operating in the country as a way to show the efforts of companies to fulfill this requirement. And is constantly has been looking for updates to respond the FSC Recommendations regarding Derogations.

The CPFC also works technically and politically into the FSC system for changes in the way that the actives ingredients are evaluated to be consider “highly hazardous pesticides”, because we believe that are science tools and indicators more efficiently to analyses the pesticides, where it´s considered more elements in the hazardous pesticides, as the environmental where they are used, dosage, forms of application, etc. This analyses approachwas proposed by IPEF, as CPFC, in the last General Assembly of FSC (2011), where we proposed the Environmental Risk Assessment should be considered in the derogationprocess of FSC. This motion was approved and the CPFC still have been working to develop new methods for pesticide assessment in the FSC Pesticide Policy.

Recently, the program has worked with the FSC legal procedures (via Motion – General Assembly) to changes in the way of identifying active ingredients considered “highly dangerous” by FSC, and, therefore in the list of pesticides banned from use.

Results: The derogation is a mechanism provided in the FSC Pesticide Policy that ensures the extension of the use of certain pesticides for an additional period of five years. This period allows companies to develop further studies to plead the using of these restricted products or for testing and adoption of alternative products to control pests and diseases.

Figura 3
Figure 3
. Cover FSC Pesticide Policy (a) and cover of the Procedures for Pesticide Derogation Applications (b).

The CPFC has complied the six-month deadline set by FSC-International from May 2007 to the procedures for derogation were filed and a public consultation was held for 45 days aimed at identifying the impressions that the various segments of society have in relation to pesticides listed by FSC International as restricted use.

This public consultation received approximately 24 000 responses, covering various segments of society such as education and research institutions, government agencies, NGOs, officials and residents of the surrounding forest companies, and manufacturers and suppliers of inputs.

As a result of the action sponsored by CPFC, stakeholders in the derogation process of certain pesticides listed as restricted use by the new FSC Pesticide Policy were able to act in an integrated manner, with more clout and credibility in pursuit of a common goal.

In February (2012), FSC IC issued an updated list of approved derogations, where can be found informations about approved Brazilian Derogations.




Instituto de Pesquisas e Estudos Florestais
Via Comendador Pedro Morganti, 3500 - Bairro Monte Alegre
CEP: 13415-000 - Piracicaba, SP - Brasil
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