Pesticides and Forestry: A hairy, scary rollercoaster of a ride
An article by Ms Jacqui Meyer, Secretariat of the Timber Industry Pesticide Working Group
The last two years have seen two major changes in the way pesticides are used in forestry. One has arrived with much fanfare, protest and noise, while the other has slipped in with few people taking much heed but both are likely to change the way we view and use pesticides. The first, Forest Stewardship Council’s® (FSC®) updated Pesticide Policy, with its ESRA’s and IGIs that have thrown the 80% of FSC certified forestry owners into a tailspin. The other is the Global Harmonised System (GHS) that South Africa has only recently adopted and will impact pesticide manufacturers and distributors more than end-users like the Forestry Industry, but will still bring about certain changes that will need implementing.
As my life for the past two years has felt like it has revolved around ESRA’s and IGIs, I will start with the changes being brought about by GHS, as these provide far less of a speed bump for our sector. GHS came in response to the United Nations (UN) concerns that the chemical industry was an international business manufacturing, shipping and selling pesticides across the world with no standardised system for communicating the hazardous nature of the product. The result, a newly formulated 1-size fits all label that is heavily reliant on pictograms to communicate hazards and combatting literacy issues.
The impact of this for our industry is at a handling level, where those involved with the use of pesticides will need to be retrained to interpret the new labels and understand the new PPE requirements. Due to South Africa holding back and only adopting GHS in the second wave of implementation, we are at an advantage due to the fact that we’ve been able to learn from other countries. Countries that have had a relatively smooth adoption of GHS are those who have done it in a step-by-step fashion, a route South Africa is following. The first step was at a regulatory level, putting in place the Hazardous Chemical Substance (HCS) Act, OSH Act and PPE regulations, and ensuring both employer and employee rights were not impacted and placing training high on the agenda. Only then will we see label changes. One of the big initial concerns for the Forestry Sector centred around PPE requirements. However, what we have seen is that for the end-user there will be little or no change. It is only at the manufacturing level, where chemical concentrations are higher, volumes are bulkier and risks are therefore multiplied that big changes are likely. So aside from having to get our heads around a new look label, there is very little to fear.
Next for the ESRAs and here there are a few things worthy of getting worked up over. When the updated FSC Pesticide Policy was released I think plantation foresters around the world collectively gasped. Their sentiment was clear, certified forestry needs to aim for 0% chemical pesticide reliance. An impossible task, especially for those ‘farming trees commercially’ who have legislative obligations to fulfil that require chemical control, like the burning of tracer belts and dealing with invasive species. For those who need to use chemicals, the very academic exercise of completing an Environmental and Social Risk Assessment (ESRA) needed to be undertaken for every product used and ideally in every setting. I think the huge implications of this and the onerous task ahead for everyone, meant ESRAs were placed in the spotlight and seen as the ultimate objective rather than just a tool in the bigger scheme of things. The bigger scheme being, the formal adoption of an Integrated Pest Management (IPM) framework which provided FSC with all the evidence as to why the pesticide route was chosen in that particular circumstance. While most companies are following an IPM framework in some manner, for most this is not formally developed which is what FSC and their auditors will be looking for. While there has been a bit of pushback about this, on the whole, the Forestry Industry understands the benefit of following an IPM approach and that it should not be an afterthought. In this respect, being made to formalise the process is going to benefit the industry and help ensure sustainability, by ensuring we stay responsive to change and proactive when it comes to incorporating new technologies and approaches that could lessen our environmental footprint. I also see the direct benefits for the industry too, if we have IPM frameworks for dealing with a wide range of established pests then we can use these as starting points when it comes to dealing with new and emerging threats.
Since our sector is reliant on certification, the reality was we have had to roll with the punches and integrate an IPM framework and ESRA into our pesticide use decision-making process. The challenge was to bridge the gap from the very academic International ESRA to the ground level application of it. The way the South African Forestry Sector has done this is through collaboration, funding TIPWG to produce a National ESRA, that can be applied by companies and adapted to their situation and circumstances.
We now have an 181 page document, which has been incorporated into the TIPWG APL for FSA members to readily identify the ESRA mitigation steps they need to follow. The benefit of this collaborative approach is we have an industry-standard, which makes auditors lives easier, provides a benchmark for the corporate forestry companies to add to and is a document for small and medium scale growers, who do not have the technical capacity to produce their own, to follow. The ESRA process has been in force since 1 January 2021, and reports coming back from those who have been audited are positive with auditors happy if companies show they are following the approach and mitigation steps laid down in the national ESRA. Whether this continues once auditors become more familiar with ERSA requirements and FSC develop their training programme is yet to be seen.
So what does the future hold, except for the auditors who are likely to probe the ESRA steps put in place? Perhaps an even more daunting prospect – the publishing of the IGIs. With all chances to comment on the second version now over, we can just sit and wait and hope that some of the reservations the global commercial Forestry Sector had over the inclusion of biomonitoring, have been heard. Certainly, the biomonitoring requirements as they stood in version two would be practically impossible to implement in South Africa where testing facilities are not available. This is one of the reasons Brazil, and many other developing forestry nations, pushed back so hard. For other tests that are available in South Africa, the fact they are in urban centres far away from afforested areas would make them incredibly costly and impractical to utilise. We can only see what this final revision of the IGIs has in store, then proceed appropriately.
The future is not all doom and gloom. While this year, the ban on paraquat had everyone reeling as the alternatives were either not available or more hazardous, environmentally at least, than the chemical that had been banned. This year, global availability of glufosinate looks more promising and TIPWG’s pelargonic acid research is concluding and we have CropLife on board to drive through an emergency registration – albeit a more expensive option. So fingers crossed next year’s fire break season is a less stressful.
What I have learnt from the last two years is how resilient the industry is, how we can adapt and evolve to change even when we are resistant to it. It has shown me there are few limitations if we collaborate and work together and this is not just the case for pesticide use in the industry, it is across the board. This is why, for me, forestry is such an attractive and exciting industry and one I look forward to leaving my mark on. In this respect, I would encourage any woman wanting a career where there are no boundaries, to consider forestry. Women are now occupying key roles across the industry and its value chain, shaping the way the sector moves forward. In FSA, we have a woman chairing the Environmental Management Committee and another as the Chairperson of the Executive Committee. To me, there is no obvious gender limitations, it’s about the individual and the skills and experience they bring. That makes me proud to be part of this sector.
Meet Ms Jacqui Meyer, Secretariat of the Timber Industry Pesticide Working Group
Jacqui is currently FSA: TIPWG Secretariat, as well as a consultant to the Forestry Industry. Prior to this, she worked for Mondi in various roles including Crop Protection Specialist, IMS Support Specialist, Nursery Manager, Research Facility Manager and Research Scientist. These provided her with the skillset needed to specialize in Integrated Pest Management, Compliance and Auditing, Systems Development and Nurseries.