FSC-TPL-30-001 Application for a Temporary Derogation to Use a ‘Highly Hazardous’ Pesticide
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FSC-TPL-30-001 Application for a temporary derogation to use a ‘highly hazardous’ pesticide A. General Requirements Application submission date Rain Forest Alliance Name and contact details of certification body submitting the derogation: Anita Neville 0431 913 214 [email protected] Soil Association Soil Association Woodmark South Plaza, Marlborough Street BRISTOL BS1 3NX Tel: + 44 (0)117 9142435 Email: [email protected] Forest Management and Controlled wood John Rogers [email protected] SCS Global Services 2000 Powell St., Suite 600 | Emeryville, CA 94608 USA tel: 510.452.8049 | fax: (510) 452 6882 [email protected] www.SCSglobalservices.com Active ingredient for which a temporary Alphacypermethrin CAS No 67375–30–8 derogation is being requested: Trade name and formulation type of the 4farmers Alpha-Cypermethrin 100 EC Pesticide: Insecticide Fastac Duo Insecticide EC Alpha-Scud Elite Insecticide EC Fastac Xcel Insecticide SC Echem Alpha-Cyp 100 Duo Insecticide EC Cropro Buzzard Insecticide EC Dominex Duo Insecticide EC Prevail Termiticide SC Imtrade Dictate Duo 100 Insecticide EC Kenso Agcare Ken-Tac 100 Insecticide EC Biotis Alpha 100 Insecticide EC Ospray Alpha-Cypermethrin 100 Insecticide EC Trade name and formulation type of the Chemforce Alpha-Cypermethrin 100 Pesticide (continued): Insecticide EC Wsd Alphacyper 100 EC Insecticide Titan Alpha Duo 100 Insecticide EC Country Alpha-Cypermethrin 100 Insecticide EC Grass Valley Alpha-Cypermethrin 100 Insecticide EC Aw Alf 100 EC Insecticide Googly Alpha-Duo 250 SC Insecticide Rygel Alpha-Cyper 100 EC Insecticide Unichoice 100 EC Insecticide Opal Alpha Duo Insecticide EC Rygel Alpha Forte 250 SC Insecticide Acp Alphacyp 100 Insecticide EC Mission Alpha-Cypermethrin 100 EC Insecticide Rainbow Alpha-Cypermethrin 100 Insecticide EC 4farmers Alpha Cypermethrin 250SC Insecticide Chieftain Duo 100EC Insecticide Titan Alpha-Cypermethrin 250 SC Insecticide Astound Duo TASMANIA Ground based application with various vehicles that use boom sprayers to target pests when trees are young and terrain is favourable. Aerial application where trees are older (trees >2m tall) and/or terrain is unsuitable for ground based vehicles 25 g per hectare. Method of application and the application ALL OTHER STATES equipment and intended quantities: Ground based application with various vehicles using boom sprayers when targeting pests at the establishment phase. Ground based application with various vehicles using boom sprayers or misters when targeting pests post establishment. Aerial application by fixed wing or helicopter. 25 g per hectare. A range of herbivorous insects, including, but not limited to: Common or Scientific name of the pest (or Chrysomelid leaf beetles, Cadmus beetles, description of the problem/issue, as applicable) Weevils, Shot hole miner, gum leaf skeletoniser, Cup moth, Sawfly’s, Spring beetles (heteronyx), Christmas beetles, Autumn gum moth Albany Plantation Forest Company Pty Ltd Certificate code SA-FM/COC-001378 License code FSC-C023801 Large Bunbury Fibre Plantations Pty Ltd Certificate CodeSA-FM/COC-001528 License CodeFSC-C014610 Large WAPRES Certificate CodeSCS-FM/COC-004647 License CodeFSC-C117107 Name and FSC certification codes of certificate Large holders1 requesting a temporary derogation. Please indicate scale category and whether it SFM Environmental Solutions Pty Ltd T/A qualifies as a SLIMF. SFM Forest Products Certificate CodeSA-FM/COC-002984 License CodeFSC-C102996 SLIMF PF Olsen (Aus) Pty Ltd Certificate Code SCS-FM/COC-004290 License Code: FSC-C111011 Large Australian BlueGum Plantation Ltd Certificate Code RA-FM/COC-001327 License CodeFSC-C019740 Large 1 In the case of forest management enterprises applying for FSC certification, the FSC certificate holder code can be provided at a later stage, if and when the company achieves certification. Forestry Tasmania Certification Pending. SCS Global Large Forico Certification Pending SCS Global Large Scope for which a temporary derogation is All states Tasmania, Victoria, South Australia, being requested: (Please attach map is Western Australia, Queensland. possible). Type of Forestry, species and expected forest Plantation. Eucalypt species including area where use of the HHP is intended. Eucalyptus globulus and Eucalyptus nitens and Eucalyptus smithii in Western Australia DEMONSTRATED NEED a) Please describe briefly the silvicultural system (methods for site preparation, practices for harvesting, regeneration, time between rotations) in the MU(s) included in the scope of the requested derogation. b) Please describe the Integrated Pest Management (IPM) system in place, including the plan to monitor the distribution and density of the targeted pest organisms in the MU(s). c) Please indicate the thresholds above which, the damages caused by the targeted pest organisms are classified as severe and how they have been established. d) Please indicate the population size of the targeted pest organism in the MU(s). e) (Fill in only if you represent a large-scale MU) Please indicate the conclusions of the comparative Cost/Benefit Analysis of using the requested pesticide versus other non-highly hazardous control alternatives, The cost – benefit analysis shall include, at minimum, the following scenarios: • no action vs. remedial control (short-term) • no action vs. preventive practices (long-term) f) (Fill in only if you represent a large-scale MU) Please provide a review carried out by independent experts of the Cost/Benefit Analysis in e). g) (Fill in only if you represent a medium or small-scale MU) Please describe possible non HHP alternatives to the use of the requested HHP and explain why they are not considered feasible to control the targeted pest organisms. h) Please include an estimate of the amount of area over which the pesticide is to be applied and how much of the pesticide is expected to be used annually. i) (Fill in only if you are applying for the renewal of a derogation) Please attach a report on the implementation of the IPM system during the previous derogation period, covering at minimum: derogation. Quantitative data of the use of ‘highly hazardous’ pesticides per year for the full period of the existing derogation, areas of application and application method. y and test alternatives to the ‘highly hazardous’ pesticide, and the results. Response In Australia, there are a wide range of insect pests that, if left un-managed, have the potential to cause commercially significant damage to tree crops (Elliot et al. 1998). Since they are grown within their natural range, eucalypts in particular are prone to damage from a large suite of native insects (Phillips 1996; Loch & Floyd 2001). Reported impacts from pest damage include tree mortality (e.g. Loch & Floyd 2001; Matthiessen & Bulinski 2001, Jordan et al. 2002), reduced tree growth (e.g. Candy et al. 1992; Elliot et al. 1993; Stone 1993; Elek 1997, 1999; Candy & Zalucki 2002; Collett & Neumann 2002) and reduced timber value/quality (Elliot et al. 1998; Phillips 1996). There is a wealth of literature showing that insect damage can cause substantial growth losses and volume losses to plantations (Loch and Matsuki, 2010; Collett and Neumann, 2002; Elek, 1997; Quentin et al., 2010). The volume losses depend on the amount of damage done and on the frequency with which damage occurs. Despite this, the Australian forestry industry has very few insecticides available that can be legally applied to prevent commercial loss caused by insect pest outbreaks. Based on our collective experience, this is predominantly due to the fact that chemical manufacturers view the forest industry as a commercially insignificant market to them (i.e. forestry is a low-volume user of product) and that it is not commercially viable to go through the rigorous and expensive process of extending label registrations for forestry. Indeed, the few forestry registrations that exist have only come about through a sustained effort from the forest industry to encourage manufacturers to go through the process. Historically, this effort has, in addition to general lobbying efforts, included voluntary contributions of funding, data and intellectual property to manufacturers. Alpha-cypermethrin is the only insecticide that is registered for use on a wide spectrum of pest species (listed above) in forestry situations across all Australian states. A few alternative products are registered for use on a much narrower range of species. An example of these includes fipronil for grasshoppers (although this is also on the FSC Highly Hazardous list) and for Autumn Gum Moth, the biological pesticide Mimic is registered. While these may be employed as part of an integrated management program for select species, there are significant limitations to their widespread adoption. For most species there is no selective insecticide available and consequently, a non-selective insecticide is required. Alpha-cypermethrin is the only non-selective insecticide registered for the purpose of controlling a broad range of insects in plantations. The most important part of the plantation cycle is the establishment process. From direct experience, a number of insects can occur in sufficient numbers to completely eliminate newly planted seedling crops, particularly spring beetles and wingless grasshoppers. Where these insects occur in large numbers and are not controlled, the crop can suffer sufficient mortality to require complete re- establishment, from weed