Environmental and Social Risk Assessments (ESRA)
Prior to the revision of FSC’s Pesticides Policy, FSC used a hazard approach to identify whether a pesticide should be prohibited or used only with specific safeguards in place (i.e., through a derogation). FSC’s revised Pesticides Policy now incorporates a risk-based approach to identify whether a pesticide is toxic to the environment and humans in the local environment. The FSC Pesticides Policy makes this assessment a requirement for all organizations that intend to use any chemical pesticide on FSC-certified land.
The new risk-based approach requires organizations to complete an environmental and social risk assessment (ESRA). The assessment considers both the hazard of the chemical’s active ingredient as well as the exposure to humans and the environment that results from its use.
PLEASE NOTE: The draft International Generic Indicators for the Use of Highly Hazardous Pesticides (draft HHP-IGIs) have not been incorporated into these national guidance ESRAs. FSC US is actively working with FSC International to better understand the expectations of certificate holders following release of the recently revised Interpretation regarding the incorporation of draft HHP-IGI into certificate holders’ ESRA. FSC US will share any new information about updated interpretations and incorporation of draft HHP-IGIs through emails to our Policy and Standards Forum and updates on our Pesticides webpage. To join the forum, please email email@example.com.
FSC US Support
To support US Certificate Holders, FSC-US and a small technical working group have developed a set of national guidance ESRAs for six of the most commonly used pesticides in US forest management.
This product is available for download via the links, below. The links include the full guidance document, individual links to unique ESRAs, and a link to an ESRA template. Please note that these ESRAs are guidance, and their use is not required (i.e., certificate holders may choose to develop and present their ESRA using different methods and format).
Using the National Guidance ESRAs
As a first step, FSC-US highly recommends that users familiarize themselves with the full guidance document. This comprehensive product was prepared with input from FSC members and stakeholders as a tool for certificate holders and auditors to better understand the Policy and the ESRA component. This document also contains the instructions for using the national guidance ESRAs.
These ESRAs are national in scope and were intended to address most of the risks and mitigation measures germane to chemical pesticide use in typical US forest management. As such, for most management units, certificate holders who use these ESRAs will be able to focus on assessing the characteristics that are unique to their management unit (e.g., extreme topography, unique tank mixtures, etc.).
Once familiar with the full guidance document, individual national guidance ESRAs and a template for adoption or adaptation of these ESRAs are provided for download. As indicated above, FSC US has not incorporated elements of the most recent draft HHP-IGI into these ESRAs. However, depending on the chemical pesticide and timing of application, CHs may need to incorporate relevant portions of the draft HHP-IGI into their MU ESRA by December 31, 2020 (see the Interpretation and additional information on the FSC US Pesticides Webpage).
As of July 2020, FSC International has provided further clarification on the role of the draft HHP-IGI when conducting ESRAs. Specifically, CH are not required to conform with the draft IGIs for all HHPs, but they are required to review the draft IGIs and use them as guidance for their ESRA, if applicable and relevant. Please see the Interpretation (beginning on p. 12 of the above linked document) for further details, particularly the note associated with ‘FSC highly restricted HHP and FSC restricted HHPs, Scenario 2’ at the bottom of p. 13.