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Technical Updates

Wednesday, 24 August 2016
Public Consultation for Pesticide Derogation Renewal

August 16, 2016

On behalf of their client, Martin Timberlands, LLC dba RoyOMartin, Rainforest Alliance is seeking input from you the stakeholder for the renewal of their temporary derogation for use of Fipronil that has been identified by FSC as a highly hazardous pesticide. This is a renewal application, a previous derogation was approved by FSC in 2012. As a stakeholder, we would like your input and comments on this derogation renewal application.

All comments are due by September 30, 2016.

Renewal Derogation Application Process Overview

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.

Derogation applications 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

Derogation Renewal Application & Appendices (see download below)

  • Martin Timberlands, LLC dba RoyOMartin – derogation renewal application for Fipronil®
  • Appendix A: Martin Timberland’s Fipronil Derogation Report
  • Appendix B: Fipronil Usage
  • Appendix C: Town Ant Monitoring
  • Appendix D: Cost Benefit Analysis

Submitting Comments

All stakeholders are encouraged to submit comments on the derogation application. The application can be downloaded below. Comments should be sent via email to Jamie Overton ( at Rainforest Alliance.

Comments will be used by:

  • Forest managers, to review and potentially revise their chemical use plans and derogation applications; and
  • FSC International, in consideration of the derogation applications

Please visit FSC International's website for more information on FSC's Pesticides Program.