Image for FSC Changes Chemicals Criteria Again ... Incorrect, says FSC Australia

A so-called expert independent panel for FSC International has again changed the criteria for determining which pesticides should go on the FSC ‘highly hazardous’ or HHP list. As a result, simazine and terbuthylazine have been removed from the list and no longer require an FSC derogation for use in plantation establishment. The panel was chaired by Steven Radosevich, an Emeritus Professor at Oregon State University, who was the senior author of the FSC document that laid out the initial criteria in 2000. In a recent document (May 2013) titled ‘ List of highly hazardous pesticides based on revised criteria, indicators and thresholds and a global list of pesticides, Background report’, it is noted that ...

‘The main set of criteria and indicators was developed between 2001 and 2002, and in 2002 a first HHP list was published. In 2004, PAN (Pesticide Action Network) reviewed the FSC’s Chemicals Policy and updated the HHP list. In 2007 and December 2012 the indicators and thresholds for identifying ‘highly hazardous’ pesticides were modified’.

Other members of the panel included two of the three members of the FSC’s derogation panel, namely Lars Neumeister from PAN Germany and Professor Gerhard Verdoorn, a chemist from South Africa but originally listed as being a representative of Birdlife South Africa. Any claim to independence is fatuous given their past involvement, particularly Radosevich. The FSC’s concept of independence is strange indeed.

Further, the FSC once again did not notify their clients in Australia or New Zealand of this latest review. The FSC has form in this regard. On a previous occasion, the New Zealand clients were not notified of a review and only became aware of what was going on because the author notified them.

The author also notes that the FSC has listed online a proforma for comments on the latest parameter revisions to be submitted by early August, yet the May document is stated Final Report. That suggests that the FSC is not serious about external input, or the May document would be a Draft. This sort of behaviour and the notification failures are perfidious and arise, in the author’s opinion, from the over-riding arrogance of the FSC and their refusal to acknowledge external criticism. In this regard, the author’s paper in Australian Forestry in 2004, ‘A critique of the Forest Stewardship Council chemicals criteria for certification of plantation forestry’ and input from other sources were instrumental in the FSC’s PAN review which came out in final form in 2005. The initial attempted PAN review attracted the author’s ire with a direct response, as did the final document (McKendry et al 2005) which retained much of the initial shoddy work. No FSC documents anywhere acknowledge either the published critique or the other criticisms, or other critical material the author has from sources in the USA, for example.

As to simazine and terbuthylazine, initial problems with listing these as ‘highly hazardous’ were dealt with in the author’s 2004 critique, but were ignored. Of course, there is no acknowledgement or apology from the FSC for having blundered in this regard, with costs and time to the industry, and worse, the blunders keep on coming!

Two examples stand out. The FSC now lists haloxyfop-R-methyl (Verdict 520 Herbicide in Australia) based on a simple chemical parameter, which is the logarithm of the ratio of the solubility of the chemical in n-octanol compared to its solubility in water, usually at 25 deg C (logKow). This is supposed to be an indication of the potential of a chemical to biomagnify (move up the food chain), but it is crude because it does not take into account chemical reactivity or microbial degradation in the natural environment. Haloxyfop is a grass specific foliar active herbicide. Hence it is not going to be applied to bare soil or sparse weed situations. When applied to grasses it is rapidly (24 hours) metabolised to the parent acid or conjugates, and even if that reaches the soil, it is microbially degraded within about 9-20 days (average 14). At the earlier FSC review, an attempt to list this chemical as a chlorinated hydrocarbon was thwarted by the fact that it is not classified that way!

The second new listing example is ludicrous. The chemical is azafenidin, developed by DuPont, but it was withdrawn globally over a decade ago, when the US EPA identified a secondary metabolite harmful to female reproductive health. It is on the Superseded List in the British Crop Protection Council’s Pesticide Manual. A search did not reveal any evidence that it has been re-introduced. The FSC’s listing is not simply inane, it is insane.

There are numerous other examples in the latest listings where a single parameter is used to justify the inclusion, but often there are over-riding factors including other parameters that are ignored.

Clearly, the armchair idealogues working with the FSC have bastardized the science.

Dr Barry Tomkins is an independent consultant and an Honorary Senior Fellow of the University of Melbourne. A chemist, he has a B. Sc. and Ph. D. from the University of Melbourne. He carried out applied research in the development of new herbicides and herbicide mixes for possible use in plantation forestry for almost two decades, and established, monitored and measured over 80 herbicide trials in plantation species including Radiata pine and eucalypts. The collaborative program that he developed continues under the auspices of Forests and Wood Products Australia (FWPA) and the Australian Forest Products Association (AFPA). He is the co-author with Braden Jenkin of a major 2006 report titled ‘The use of chemical pesticides by the Australian plantation forest industry’, for the Forest and Wood Products Research and Development Corporation, the forerunner of FWPA.

• Natalie Reynolds, FSC Australia: This report is misleading and factually incorrect.

The report referred to clearly a report from a working group into pesticides to FSC International. It is NOT a policy instrument and does not refer to the removal of these chemicals.

In fact on the front page of the document the disclaimer says:

“Disclaimer: this recommendation report does not legally bind FSC IC in any whatsoever form to implement the Pesticides Expert Panel’s recommendations or parts of it in any FSC Policy, Standard or other documents.

In the interests of transparency any reports we receive are published when we go out to consultation.

FSC - GUI - 30-001 V2 Annex I is clearly in draft and out for consultation.

People should actually look at these documents before making ill informed responses. Karl, Chemicals toxic to humans feature heavily on the list.

I have contacted Dr Tomkins and given him the opportunity to review and correct his mistake. 

• Dr Barry Tomkins: The hard copy of the document ... does not carry the alleged disclaimer. Nor does the hard copy I was given, or the (same as) pdf file that I was sent.  Perhaps Natalie Reynolds could clarify which document she was referring to – it certainly is not the document I referred to.

The hard copy of the document ‘List of highly hazardous pesticides based on revised criteria, indicators and thresholds and a global list of pesticides’, Background report, FSC Policy and Standard Unit, Final Report May 2013, which I have just downloaded again from the FSC International site, does not carry the alleged disclaimer. Nor does the hard copy I was given, or the (same as) pdf file that I was sent.

Perhaps Natalie Reynolds could clarify which document she was referring to – it certainly is not the document I referred to. There is also no disclaimer attached to the Australian submission on the changes. I do not know if she has any scientific credentials, but she did not address any of the real issue, which is the pseudo-scientific FSC chemicals criteria. She did ring me, and unless I misunderstood, it would seem that the FSC will only deal with criticism if it comes from members. No organization should be impervious to external criticism.