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Alpha Cypermethrin and Cypermethrin South Africa 010316 Rejection

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Alpha Cypermethrin and Cypermethrin South Africa 010316 Rejection Type of document: Rejection Confidentiality: No restrictions Approved by: FSC Pesticides Committee Effective Date: 01 March 2016 Expiration Date: ------------- Related Documents: FSC-POL-30-001 FSC Pesticides Policy FSC-STD-30-001 Indicators and thresholds for PESTICIDE the identification of ‘highly hazardous’ pesticides (HHP) DEROGATION FSC-PRO-30-001 Pesticide Derogation Procedure Pesticide derogation: Use of Alpha-Cypermethrin and Cypermethrin in South Africa FSC reference code: FSC-DER-30-V1-0 EN Alpha Cypermethrin and Cypermethrin South Africa 010316_rejection Date: 01 March 2016. FSC Board Committee decision: The Pesticides Committee has rejected a derogation to use alpha-cypermethrin and cypermethrin against Pine tree emperor moth (Imbrasia cytherea), Willow tree emperor moth (Gonimbrasia tyrrhea), Brown wattle mirid (Lygidolon laevigatum Reut.), Wattle bagworm (Chaliopsis (Kotochalia) junodi (Heyl.), Brown Tail Moth (Euproctis terminalis) and Eucalyptus snout beetle (Gonipterus scutellatus) in certified plantations in South Africa for the following reasons: 1. a need for using pyrethroids was not shown sufficiently as evidence is lacking that alpha-Cypermethrin and Cypermethrin were used on the target species in the past seven years, nor that this is the only feasible way of controlling lepidopteran caterpillars or other pest insects and that these cause severe damage regularly or annually,1 which makes it appear highly questionable if there are ‘exceptional circumstances’ requiring an extension of the derogation; 2. FSC’s Derogation Procedure requires the full implementation of an alternative programme as a condition to grant an extension. In the past derogation period of seven years no alternative programme was implemented to replace the use of 1 If a population outbreak of insects results in a sudden infestation this may present an ‘emergency situation’ and then certificate holders could use a HHP – with the requirement to inform the certifier within 30 days of starting use, including an explanation on the nature of the emergency, a timeline, and a justification for use of the HHP, in accordance with section 8 of FSC’s Pesticide Derogation Procedure (FSC-PRO-30-001 V1-0, June 2015 FSC-DER-30-V1-0 EN Alpha-Cypermethrin and Cypermethrin South Africa 010316 1 of 2 FOREST STEWARDSHIP COUNCIL® INTERNATIONAL CENTER ‘highly hazardous’ pesticides for controlling the pine tree emperor moth (Imbrasia cytherea), willow tree emperor moth (Gonimbrasia tyrrhea), wattle bagworm (Chaliopsis (Kotochalia) junodi), brown tail moth (Euproctis terminalis) (Lepidoptera), brown wattle mirid (Lygidolon laevigatum) (Hemiptera), eucalyptus snout beetle (Coleoptera). 3. Key target species of alpha-Cypermethrin and Cypermethrin (mostly lepidopteran species) can also be controlled with Bacillus thuringiensis (subspecies kurstaki), a non-HH biopesticide, and most likely wattle mirids can also be controlled with non- HH insecticides such as tebufenozide or spinosad; using these alternatives reduces the very high risks to non-target species and natural enemies which would result from aerial spraying of large areas and could lead to pest emergence, and also prevents the risk of resistance in case of repeated use of a pyrethroid in successive years. 4. The stakeholder consultation was not sufficient. None of the stakeholder letters sent by the CHs applying for an extension mentioned the fact that no research on alternatives for the control the target species of alpha-Cypermethrin and Cypermethrin was conducted in the past seven years of derogation. Some CHs did not inform the stakeholders that the companies are asking for an extension of a derogation after seven years. Some letters to stakeholders contained very little information, and in general the number of responses was small. List of FSC certified forestry units affected by this rejection: Derogation applicants Date of Company Certificate Number inclusion Mondi Ltd., South Africa SGS-FM/COC-000084 SiyaQhubeka Forests SGS-FM/COC-000870 Paradise Falls Candidate NCT Forestry Co-operative Ltd SGS-FM/COC-000348 TWK Agri (Pty) Ltd. SA-FM/COC-001353 01 March 2016 York Timbers (Pty) Ltd SGS-FM/COC 000809 Komatiland Forest (Pty) Ltd SGS-FM/COC-0068 Sappi Southern Africa Limited SA-FM/COC-001230 Sappi Out-growers scheme SA-FM/COC/1363 FSC-DER-30-V1-0 EN Alpha-Cypermethrin and Cypermethrin South Africa 010316 2 of 2 .
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