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Wednesday, 20 January 2016
Public Consultation for Pesticide Derogation Applications

January 20, 2016


FSC US has received three pesticide derogation applications for the proposed use of chemicals that have been identified by FSC as highly hazardous pesticides. As an FSC US stakeholder, we would like your input and comment on these derogation applications. This comment period will be open for 45 days and all comments are due by March 5, 2016.

Applications were received from the following forest managers and are available below:

  • Roseburg Resource Company - derogation application for Oxyfluorfen
  • Red River Forests and Shasta Forests - derogation application for Oxyfluorfen
  • Michigan Department of Natural Resources - derogation application for Permethrin

FSC’s forest management program recognizes a list of highly hazardous pesticides that are restricted for use in FSC certified forests. The forest management program also acknowledges that there are situations where the use of a highly hazardous pesticide may be the most economically, environmentally, and socially preferable tool available for the forest manager. In this situation, a forest management certificate holder may apply for a derogation to use a specific pesticide under certain conditions on their certified forest operations. Additionally, FSC categorizes pesticides as highly hazardous due to intrinsic properties of the chemicals such as toxicity, soil persistence, and bioaccumulation, and does not take into account measures such as application methods, formulations, and other safety measures that potentially mitigate hazards.

The derogation application must include justification from the forest manager for multiple considerations, including:

  • Description of the demonstrated need
  • Controls to mitigate hazards
  • Program to identify alternatives
  • Stakeholder engagement 

All stakeholders are encouraged to submit comments on these derogation applications. The applications and comment form can be found below. Comments should be sent via email to Jenny Wood (j.wood@us.fsc.org) at FSC US.

The comment period will be open for 45 days and all comments are due by March 5, 2016.  

Stakeholders should use the comment form provided below and comment on each application independently. Stakeholders are encouraged to include comments on the overall support for the derogation requests, as well as include comments on the sections related to additional controls and programs to identify alternatives.  

Comments will be used by:

  • Forest managers, to review and potentially revise their chemical use plans and derogation applications
  • FSC US, to ensure an accurate understanding of the perspectives of stakeholders, and
  • FSC International, in consideration of the derogation applications 

For more information on FSC’s Pesticides Program, please visit the website HERE.