FSC Pesticide Policy and end of transition period
FSC Pesticides Policy (FSC-POL-30-001 V3-0) and the end of the Transition Period 31st July 2020
The FSC Pesticides Policy version 3 came into effect on 1st August 2019, with a one year transition period, and a longer ‘interim period,’ where FSC will develop the International Generic Indicators (IGIs) for the new policy, and embed them into National Standards. On the 25th June, this transition period was then extended to 31st December 2020, due to Covid-19.
The 31st December 2020 date is the start of new requirements under the policy, most notably:
- Derogations that had expiry dates before this date had them extended up until 31st December 2020 - certificate holders should, therefore, check for expiring derogations
- From 31st December 2020:
- FSC prohibited Highly Hazardous Pesticides (HHPs) shall not be used outside emergency situations or governmental orders (any existing derogations will expire on 31st December)
- All HHPs and any other pesticides that do not have active derogations will require the certificate holder to conduct an Environmental and Social Risk Assessment (ESRA), in accordance with the policy
- Any pesticides with active derogations will need an ESRA that incorporates the conditions from the derogation
- All ESRAs will need any requirements from any published draft IGIs incorporated
FSC created a template for ESRAs within the policy, and Soil Association Certification have previously made this available in Word format. Certificate holders can either use the FSC ESRA template to create their ESRAs, or incorporate the requirements into their management systems.
The ESRA Framework and the new requirements for certificate holders to adopt are all described in the FSC policy, including the role of National Standard Development Groups, where they exist. In some countries - like the United Kingdom, for example - the role of creating example ESRAs has been taken up centrally. FSC UK and UKWAS collaborated to create a suite of resources and national level ESRAs, and all this information can be found on the FSC website. This web page gives a very good summary of the steps required, links to other FSC and international resources, and 3 ESRAs for the UK: Propyzamide, Glyphosate and Acetamiprid.
Other countries will be at different levels of progress, and some countries will not have developed any ESRAs examples. In such cases, it’s vital that certificate holders prepare now for the end of the transition period. To do this, they should contact their FSC National Office to see what initiatives are underway, consult any industry bodies to share information, and liaise with Soil Association Certification over any clarifications of policy requirements.
From 31st December 2020, Soil Association Certification and its auditors will be auditing fully to the new policy, and issuing findings where ESRAs and management systems have not been created and/or updated.