FSC-Watch

An independent observer of the Forest Stewartship Council

FSC back-tracking on pesticides; Board caves in to industry pressure?Tags: Worldwide, Ireland, Pesticides

As with the development of many other FSC policies, the finalisation of its policy on the use of pesticides has been long and complicated. But at least it seemed to have come to a fairly clear result, when a new policy, and clear guidelines for implementing it, were adopted by the FSC Board at the end of 2005. But this has again all been thrown into doubt, following the most recent FSC Board meeting, which was attended and heavily lobbied by an industry delegation.

Under the rules established in 2005, substances that are defined as ‘highly hazardous’ are ‘banned’ from use in FSC-certified forests. The list of such pesticides includes 35 new substances that were not already covered by an older FSC policy on pesticide use. Under the 2005 rules, companies wishing to use these substances – or already using them at the time the new policy was adopted – have to apply to the FSC for a ‘derogation’, i.e., special permission to be exempted from the rules. Companies were given until the end of 2006 to apply for derogations for the use of the 35 newly listed pesticides.

However, the FSC Board meeting in November 2006 decided that companies could be given more time to apply for permission to use these ‘highly hazardous’ substances, and the deadline for requests was put back to June 30th, 2007. According to Frank Katto – the person in the FSC Secretariat responsible for administering pesticide derogations - the Board is actually also undertaking an ‘ongoing review’ of the pesticide policies it had taken only a year earlier. FSC-Watch wonders whether this is any way connected to the fact that an industry delegation attended the FSC Board meeting where this decision was taken, and asked FSC to ‘take a new approach to the issue of pesticides’.

In one case at least, the FSC Board’s decision to keep the doors open to the pesticide-users would seem to be very opportune for a major plantation company that is FSC-certified but reliant on the use of ‘highly hazardous’ substances. The Irish state forestry company Coillte, (the certification of which has already been reported on several times on FSC-Watch) applied earlier in 2006 for a derogation for the use of alpha-cypermethrin. This chlorinated hydrocarbon, which is ‘acutely toxic’ to aquatic ecosystems (i.e., it is very good at killing fish and other water-living wildlife) is needed by Coillte for the treatment of the roots of new seedlings of the exotic trees which it has been planting in vast monocultures over large parts of Ireland’s landscape.

Under FSC’s pesticide rules, permission can only be granted for the use of banned substances if the country’s FSC National Initiative has agreed to the derogation. But in the case of Ireland, the Irish Forestry Certification Initiative, which is officially recognised by the FSC, did not approve the use of alpha-cypermethrin when it voted on the derogation request in December 2006. The application by Coillte to use the pesticide should therefore be rejected outright by the FSC Secretariat. But the new FSC Board decision will allow more time for Coillte to try and get the derogation accepted. Perhaps the FSC Board and Secretariat is even considering dropping the requirement that derogations have to be approved by the recognised FSC National Initiative – thus freeing up the path for companies and the FSC to agree between themselves on what pesticides are, or are not, allowable.

FSC-Watch invites the FSC Secretariat and Board to make public the names of the industry delegation which attended the international Board meeting in November, as well as the names of the companies which the members of that delegation represent.

Comments


The Irish state forestry company Coillte may like to try this as an alternative to chemical control.

In Australia FSC certified Plantation company Timbercorp, in association with CSIRO and the Cooperative Research Centre for Sustainable Production Forestry, has recently developed a chemical-free method of preventing damage by the African Black Beetle, a major establishment pest of blue gum treefarms in Western Australia. A small mesh bag is placed around the seedling, reducing damage to almost zero. Chemical control for this pest has ceased as a result of this research.

This is just one of many strategies already being used by companies to reduce, remove or replace the use of chemcicals. The main thrust of the CANZUS (Canada, Australia, New Zealand and US) delegation of 57 certified companies to Bonn (which I was on) recently was to point this out to the FSC Board and also to call for FSC to collate these ideas and make them avialble to forest managers via its web site. This could then form the basis of a transparent and measured continual imporevment programme that would reduce chemical use over time. We called for such a programme to be be subject to audit under the current system i.e if ideas to reduce, replace or remove chemicals are published on the FSC website a certifeid company not using that strategy will have to explain why to their certifer and be subject to corrective action requests. We look forward to your support for this important direction.

The Delegation did not contest the 2005 policy but suggested the guidelines were in places not workable. Changes suggested included a measurable continual improvement approach. We also asked that the guidelines take into account the constraint placed on companies by regulatory systems particularly the long timeframes in bringing alternatives to market.

Thank you


As a member of the delegation that gave a presentation to the FSC Board in November, I would like to correct some mis-statements in the article and make clear the make up and purpose of the "delegation".

The delegation was not an "industry" "lobbying" group although there are some industrial companies who participate in the group being represented. The delegation represented a group of FSC certificate holders from Canada, Austrailia, New Zealand and the U.S. (aka "CANZUS") made up of a broad spectrum of forest ownerships (families, state-owned forest management agencies, industrial timber companies, timber investment groups and a non-profit conservation organization) comprising more than 90% (> 20 million hectares) of the FSC certified hectares in these 4 countries. As such we were not representing certificate holders in any other country, including Ireland, nor were we "lobbying" for "industry". For example, as a representative of the U.S. members of CANZUS, I know that the majority (65%) of the acres represented in the U.S. portion of CANZUS are owned and managed by state agencies for a wide range of public purposes.

CANZUS is an ad hoc group that was formed in a very "grass roots" manner in 2006 in response to one common and very serious concern that the resource professionals who work for all these forest management certificate holders have regarding the counter productive consequences of the recently adopted implementation and guidance documents for FSC's pesticide policy (a policy we all support). Our purpose was not to "lobby" for "industry" or to diagree with the policy, but to educate the FSC Board and Staff about the negative environmental, economic and social consequences of the recently adopted guidance and implementation documents and to suggest a superior, alternative approach that will better meet FSC's pesticide policy goals as well as the overall goals of FSC.

Thank you

Your readers might be interested in some of the background to the ongoing issue of the FSC's pesticide chemicals policy and criteria. I am a chemist, not a forester, but have been involved for over 13 years in research into chemical weed control in (Australian) plantation establishment.

In early 2003 I wrote a critique of the chemicals criteria and distributed it to Australian plantation companies then looking at FSC certification. Although this was passed back to the FSC, it was ignored. Thus I published the material in a peer-reviewed paper in Australian Forestry (Vol 67(1) pp 67-72, see www.forestry.org.au) which is a journal of the Australian Institute of Foresters. Other material was published in Australian Forest Grower which reiterated and enlarged on the formal paper.

The paper and other articles clearly demonstrated the lack of scientific validity and credibility of the parameter thresholds put forward by Radosevich, Lappe and Addlestone in their 2000 commissioned, non peer-reviewed and unpublished paper provided to the FSC. My criticisms led to the 2005 PAN/UK review, which also failed to properly address the important scientific issues.

In early 2005 I provided this material to the New Zealand FSC-certified plantation companies via mail and e-mail, and it emerged that FSC had not notified these companies of the PAN review. It later emerged that a similar situation pertained to the USA and Canada.

Should your readers request it, I could outline the essential scientific criticisms. Politically, one major criticism is that the FSC does not recognize the regulatory systems in place in highly developed countries such as the CANZAUS group. These systems are robust, scientifically based, and have evolved over decades - far longer than the FSC has existed. The FSC by comparison does not have any of the expertise of bodies such as the Australian Pesticides and Veterinary Medicines Authority, and similar regulatory bodies in the other countries. Nor does the FSC appear to have any pesticide scientists or toxicologists in its employ.

Until the FSC accepts that it must have a proper scientific basis for its chemicals criteria, there will be continued criticism. As the great Canadian chemist and Nobel Laureate John Polanyi stated "There is nothing so irredeemably irrelevant as bad science".



Correction to my previous submission:

It was in early 2006 that I provided the material to the NZ companies.

Dear Dr Tomkins

I am sure the readers would be interested to see the 'essential scientific criticisms' of the Pesticides Policy. If there is a paper summarising these, perhaps you could send it to us and we will post it.

FSC-Watch

I cannot provide the pdf file of my paper in Australian Forestry, nor the articles in Australian Forest Grower for reasons of copyright etc. However, I can give the reasons for the lack of scientific credibility of the FSC's chemicals criteria - much of this is in the Auastarlian Forestry paper, but there were later additions eg the table of logKow values I preprared (see later for description).

The basis for the FSC chemicals criteria is a paper by Radosevich, Lappe and Addlestone (2000). This was an FSC commissioned paper, and a major claim by the authors was that the material in it was 'scientifically defensible'. The paper was not and has not been peer reviewed, apart from my peer reviewed critique, and has therefore never been published in a reputable journal.

Three main parameters and other associated parameters were put forward, with threshold values to determine the acceptability or unacceptability of specific agricultural chemicals for use in forestry.

The main parameters were the half-life as a measure of persistence of a chemical in soil, defined as the time from application for half of the applied dose to be dissipated or destroyed; the Reference Dose, defined as the amount in milligram per kilogram of body weight per day below which level was unacceptable for human health, and associated with this the LD50 and LC50 and; the n-octanol/water partition coefficient or Kow, used as logKow as a measure of the potential for a chemical to bio-magnify, that is, move up the food chain.

Radosevich et al misused all of these parameters in providing the FSC with threshold values to determine acceptability of pesticide chemicals for use in forestry.

(i) Persistence

The idea of persistence as a measure of acceptability for use derives from a suggestion by Professor Michael Kamrin (1997) in a text-book titled ‘Pesticide Profiles’. Kamrin suggested that a useful division for considering persistence of a pesticide in soil was:

? up to 30 days half-life be considered as a ‘slightly persistent’ pesticide,

? between 30 and 100 days be considered as a ‘moderately persistent’ pesticide, and

? greater than 100 days be considered as a ‘strongly persistent’ pesticide

He made no reference to any other work for this suggestion, so that it must be considered as an original idea. However, Kamrin was well aware that half-lives of pesticides in soils are variable parameters, because he gave ranges for many of the pesticide entries.

Radosevich took this idea and added 'acceptability' clauses:

? 0 to 30 days soil half-life be considered an ‘acceptable’ pesticide,

? 30 to 100 days be considered a ‘marginally acceptable’ pesticide, and

? above 100 days be considered as an ‘unacceptable’ pesticide.

There is and was no scientific justification for this division. Further, as Kamrin noted, soil half-lives, which are a measure of chemical degradation rates, vary within ranges. In my paper, I noted several reasons

? Change in temperature. As a general estimate, reaction rates tend to double with each 10 degree centigrade increase in temperature, and there are diurnal, seasonal and topographical influences on temperature.

? Change in soil moisture, which is critical to many pesticide degradation processes. Rates of degradation increase in warm moist conditions, are slower in warm dry conditions, are slow in cold dry conditions and are also relatively slow in cold moist conditions.

? Change in soil organic matter, which determines soil bacterial populations, and therefore affects bacterial degradation, which is a source of energy for soil bacteria.

? Change in soil pH, which affects the stability and degradation reaction rates of many pesticides.

Radosevich et al and subsequently the FSC have made no attempt to define why a ‘strongly persistent’ chemical should be considered as ‘unacceptable’. The FSC has consistently failed to consider benefit versus potential for harm.

The FSC attitude that a persistent chemical is by its very persistence 'bad' exposes an intellectual failure to properly consider the merits or demerits of persistence. Persistence is only a 'bad' thing if there is a demonstrable lasting deleterious effect or effects to non-target organisms. Persistence may be a very 'good' thing, allowing adequate control of a pest plant, insect, fungus or animal so that the desirable crop can be grown - this applies to agriculture, horticulture, home gardening etc. It also applies to the use of pesticides to repair environmental degardation.

Pretty much everyone has fly spray in a cupboard!

The FSC clearly has failed to have an honest debate about the merits and demerits of persistence. The (Radosevich et al and) FSC’s use of Kamrin’s idea is dishonest. Kamrin (1997) gave ranges for all but one of the pesticides for which Radosevich et al gave single values, but this was ignored. Thus, Radosevich et al applied data selectively, as listed:

Simazine 28 to 149 days (Radosevich gave 60 days)
Glyphosate 1 to 174 days (Radosevich gave 47 days)
Picloram 20 to 300 days (Radosevich gave 90 days)
Hexazinone 30 to 180 days (Radosevich gave 90 days)
Dimethoate 4-122 days (Radosevich gave 20 days)
Dicofol? – exception, said to be susceptible to breakdown in moist soils (Radosevich gave 60 days)’.

This approach is NOT scientifically acceptable.

(ii) The Reference Dose
This is based on animal data and for humans is 1/100th of the No Observable Adverse Effect Limit (NOAEL) in test animals that may be rats, rabbits, mice, guinea pigs or even dogs.
It is a measure of chronic, not acute, toxicity, that is, a daily dose over a long time at which health effects are observable. The FSC insists on using RfD whereas it is usually known as the Acceptable Daily Intake or ADI - see for example 'The Pesticide Manual', BCPC (Tomlin 2003) which is the first reference attached to the FSC's list of allegedly 'highly hazardous chemicals'.

There is no consistency in the data used by the FSC. Apart from animal differences, there are gender differences (again see the ADI values for many chemicals in Tomlin 2003).

It is NOT scientifically acceptable to compare and use data from disparate determinations on different test animals. There are often several values for individual pesticides. There is no international consensus on a minimum value. The FSC arbitrarily decided that the lowest value should be accepted as the most protective, regardless of context. The approach is dishonest, yet the FSC persists, and goes even further, setting an arbitrary limit of 0.01 mg/kg/day for ALL chemicals, regardless of the listed value for a given pesticide.

(iii) The LD50

This is a measure of acute toxicity in test animals. It is defined as the dose in mg/kg of body weight that kills half of a test population in a single dose. Test animals again vary and again there are gender differences. The FSC again adopts an arbitrary limit of 200 mg/kg, so that any pesticide with an LD50 less than this is considered to be ‘highly hazardous’.

(iv) The LC50
This is a measure of acute toxicity in aquatic organisms. The test species is usually rainbow trout, but again may be other fish species. The FSC again adopts an arbitrary limit of
50 ug/L, so that any pesticide with an LC50 less than this is considered to be ‘highly hazardous’.

(v) LogKow

This parameter, known as the Hansch coefficient, has been used as a measure of the potential for a pesticide to bio-magnify. It first came to prominence in the 1960’s following the DDT story - see for example ‘Silent Spring’ by Rachel Carson.

It is defined from the solubility of a pesticide in n-octanol (CH3(CH2)7OH compared to the solubility in water. The 2 solvents are immiscible. If the ratio of the two solubilities exceeds 1000, the chemical is considered to have a potential for bio-magnification. It is usually expressed as the logarithm of the ratio, that is, for a ratio of 1000, the limiting log value is 3.

The problems include that many pesticides are weak acids or weak bases, and therefore have variable solubility depending on the pH of the aqueous medium. Soil pH varies widely so that Kow is only a constant under controlled (standard laboratory) conditions. These conditions include temperature as well as the pH of the aqueous phase. The values listed in the Radosevich et al sample tables were not measured under the same conditions of pH and temperature and therefore cannot be compared.

I prepared a Table based on data from the aforementioned 'Pesticides Manual' which was circulated and clearly demonstrated that the Radosevcih et al data was not internally consistent- that is that the data was not measured under consistent conditions. The Radosevich et al tables did not include the critical pH and temperature values. This is dishonest and unscientific. Radosevich et al also failed to give values for several pesticides, readily obtained from Tomlin (2003).

The alleged 'hazardous chemicals' may be so rapidly metabolised or excreted or non-toxic as to pose no risk at all. The use of Kow as a determinant of potential to bio-magnify has been superseded by scientific understanding of the bio-degradation pathways, and of the chemical stability and environmental toxicity of current agrichemicals. There are examples where environmental persistence is so short lived that even though logKow exceeds 3, degradation occurs before there is any possibility of significant bio-magnification. Some chemicals are so rapidly metabolised or excreted in non-target organisms as to pose no significant problem.

Even if a given chemical can bio-magnify, if there is no evidence of deleterious effects to non-target organisms (despite the myriad of testing regimes applied well before a chemical reaches the market) then responsible authorities usually do not perceive a problem.

Sources of data

Radosevich used data and references from the USA. Kamrin (1997) was the main source of data which included half-lives in soil RfD values, logKow and LD50 and LC50 values. These values do not always agree with those from Tomlin (2003). It is NOT scientifically defensible to use one data source selectively.

In summary, the Radosevich paper does not provide a sound scientific basis for determining acceptability of individual pesticides.

I have noted previously in some communications that 'Science is not some sort of plug-in service module to a social construct of plantation forestry' (my words). Plantation forestry is based on science - tree breeding, fertilization, pest plant, animal, insect and fungal control, fertilization (includes trace elements) etc. Who is to argue with that?

Recently I was the co-author of a report written for the Forest and Wood Products Research and Development Corporation (see www.fwprdc.org). The plantation area certified by the FSC in Austalia is about 600,000 ha, roughly 1/3 of the total Australian plantation estate.

Plantation forestry expenditure on pesticides is about 1% of the total Australian pesticide market, which includes agriculture, horticulture, turf, domestic and industrial sectors etc.

Thus the FSC certified companies account for around 1/3 of 1% of the Australian market. Why does the FSC bother???

Thank you

Barry Tomkins, GreenTree Forestry Services. Also Senior Fellow (an Honorary appointment) the University of Melbourne.

How do I edit? There are some dash---points which come up as question marks, and every time I try to edit, it reverts to the main page!!!

I'll get it right sooner or later. It was early in 2005 that I informed NZ companies. In September that year there was a meeting in Dayelsford, Victoria between representatives from NZ and Australian companies with FSC personell.

It is now almost 3 years since the publication of my paper in Australian Forestry, and no individual or group has yet challenged my conclusions as to the lack of scientific credibilty of the FSC's chemicals criteria.

The 2005 PAN/UK review was a disgrace. It failed to address the key criticisms, partly because of restrictive terms of reference from the FSC, partly because PAN is ideologically close to the FSC and partly because PAN have no expertise in the way in which agricultural chemicals are used in plantation forestry.

I have e-mailed the New Zealand Forest Owners Association response to the PAN review, which is available on the web. You may care to post it.

In relation to plantation pesticides, the Australian plantation forest industry has had a rather interesting past. The following webpage includes a list of issues that i have come across over the past few years. Many other examples have of course gone under anyone's radar.

http://www.hancock.forests.org.au/docs/adelaide.html

Of special concern is the matter of plantations located in domestic water supply catchments. Water authorities do not always test for the pesticides used by plantation companies. One or many rainfall events post pesticide application can lead to water pollution.

Then of course there's the historical application of 245-T which created havoc in certain communities during the 1970's.

http://www.hancock.forests.org.au/docs/yarramabnormalities.htm

Of course this issue is also of concern in many agricultural areas. But two wrongs do not make a right and FSC has caved in here.

Can someone from FSC please provide information about how plantation companies test for offsite impacts of the pesticides that they use? Are communities downstream involved in these monitoring exercises? Are the results of the testing made public? What happens if positive readings are found? As I understand it such questions are not always asked by FSC auditors.

The following information was raised not by FSC or auditors but by me doing an Freedom of Information request. Note that the company is certified by FSC, yet the auditors were never told of the pollution event even occuring.

http://www.hancock.forests.org.au/docs/BarwonWater.htm

regards

aa

So - what is the point that Mr Amis is trying to make? It does not relate to the chemicals criteria of the FSC, which he does not mention.

Yes, there have been very occasional detections of agricultural chemicals in streams. DPI W & E have a regular montioring program on 54 streams in Tasmania and a flood monitoring program on 4 streams. There have been very few detections - see DPIW & E 2004. www.dpiwe.tas.gov.au/inter.nsf/Attachments/LBUN-63GACC/$FILE/Review%20of%20Scammell%20Report%20020804.pdf

Mr Amis does not mention the Australian Drinking Water Guidelines 2004. www.nhmrc.gov.au/publications/synopses/eh19syn.htm

Mt Amis does not mention the levels detected in the Barwon Water incident in relation to these Guidelines!

Is Mr Amis merely trying to draw attention to his long-running harangue of Hancock Victorian Plantations (see his web site above)? Or demonstrate that he cleverly obtained his information through FOI?

For the record, this is the same Mr Amis who provided misleading evidence in a submission to a Victorian Civil Administrative Tribunal hearing in January last year regarding a Blue Gum plantation establishment. In his submission he provided material on a herbicide which is only used in Radiata pine and is deadly to eucalypts! When (as an expert witness) I pointed this out, Mr Amis had no option but to apologize to the Tribunal.

The same Mr Amis provided a scaremongering press release to the Portland newspaper (a town in Western Victoria) claiming that 7 different insecticides could be used in Blue Gum plantations in that part of the state. Only 2 were registered for forestry, one as a bait for wingless grasshopper, the other as a spray application. For the record there is very little insecticide use in plantations in Australia - only 1% of the expenditure on pesticides in plantation establishment (see previous comment) is on insecticides.

The same Mr Amis called me 'irresponsible' in an article to the Wombat Forest News & Views without giving any evidence for that whatsoever. In that article he used expressions such as 'the unsustainable use of agricultural chemicals', the impending disaster looming in Tasmania through the use of toxic insecticides and herbicides', 'the massive wave of complaints', 'chemicals that had been used in plantation insecticide experiments in Victoria', 'smoked out some interesting information' etc.

Mr Amis should perhaps consider the use of atrazine in canola and sorghum in Australia and corn and sorghum in the USA. 90% of the atrazine sold in Australia goes into those two crops. In the same region of Western Victoria where Blue Gum plantations are established, there is annual cropping of canola on a large scale. There are also numerous streams which cross the region. I don't know of any testing for atrazine in those waterways!

So what was your point, Mr Amis? The solution to the very occasional movement of pesticides in to streams is not to stop using them, but rather, to develop measrures to prevent such incidents. It is called risk management.



Mr Barry Tomkins has cited the Tasmanian Department of Primary Industries, Water and the Environment's (DPIWE) water testing regime and seeks to give this activity some scientific credibility.

I'm sorry to inform the public that this state department has no integrity when it comes to the practice of 'science'. The reasons:

DPIWE (and the federal APVMA) have been asked - over a period of several years now to - provide details of the spray drift risk assessment for aerial spraying operations over hilly terrain. They continue to fail to provide this critical data;

A key person in DPIWE had no qualms informing me in a phone conversation that he didn't give a .... about aerial spray drift and added that nothing he was going to do would jeopardise the forest industry;

When our community demanded DPIWE engage in the water testing of rainwater tanks due to systematic and repeated aerial sprayings by the forest industry this is what happened. The person from the Spray Complaints Unit came out and took a sample from only ONE community tank. Mine. Despite the fact that such a sampling had no scientific credibility in terms of assessing our risk. After all, we had the intake pipe disconnected from the shed roof before during after spraying (in fact all season).

DPIWE know that tens of thousands of different pesticides are sprayed in Australia. Yet they have NEVER tested for more than two or three in water tanks in Tas at any one time.

DPIWE (now DPIW) refuse to test water tanks in Tasmania at all now. The aerial spraying continues.

DPIW's current water catchment testing regime is designed merely to lull the public into a false sense of security. The testing so far has revealed that 'normal' use of pesticides has resulted in water becoming contaminated many miles from the actual application with traces found (where they usually test) in the most diluted part of the catchment.

DPIW's testing regime breaches the requirements of the World Health Authority in that "“Reliance on water quality determination alone is insufficient to protect public health. As it is neither physically nor economically feasible to test for all drinking-water quality parameters, the use of monitoring effort and resources should be carefully planned and directed at significant or key characteristics.”
Keep in mind also that DPIWE only test for a handful of chemicals out of the tens of thousands registered for use in Australia.

The Australian Pesticide and Veterinary Medicines Authority (APVMA) also engages in similar behaviour. It used the data from corrupt testing done by Forestry Tasmania (FT) and industry-funded laboratory studies of triazines to justify continued registration of these chemicals. In the first instance FT only tests the water tanks of immediate neighbours. In our community our neighbour had his pipe disconnected before, during and after the spraying. The neighbours who left their pipes connected were not subjected to water sampling/testing. Studies incorporated in the review on Atrazine were corrupted through the process of subjecting control animals to the chemical. Thus there was (predictably) no difference found between control and exposed subjects. Industry funded this laboratory.

The key characteristic is that whole district aerial and ground spraying in occuring in the town and city water catchments. Nothing is being done to stop this activity which - Nobel prize laureates - acknowledge is now threatening the survival of the human race.

For more information about this departments abuse go to:

www.yahoogroups.com/group/tascleanwaternetwork
(use the search engine for DPIWE and DPIW)

www.geocities.com/rosserbj - click on 'Pesticide Abuse in Tasmania'

Chemicals threaten our survival. Go to:
http://www.artac.info/WelcomeARTAC2006en.html

The latest development with the Tasmania Department of Primary Industries and Water:

http://tasmaniantimes.com/index.php/weblog/comments/dear-mr-llewellyn/
To be frank, I am disappointed but not surprised by your response. However it is disconcerting that in Tasmania, the Minister with responsibility for Primary Industry and Water feels unable or unwilling to engage in a forthright discourse on water quality and pesticide use in water catchments.

The June 06 flood test results (DPIW website) again showed the Duck River to be polluted with MCPA at four times the detection limit.

I would also ask which section(s) of the community you feel are satisfied with the current monitoring program, given that you state that the individual interests of every section of the community cannot be met.

Your last sentence could be interpreted as being deceptive and should perhaps include or make reference to the following points:

Only some individual parent pesticides are being sampled for during routine quarterly water grab sampling.

Pesticides that are highly adsorbed and those that adhere to glass will probably not be detected by current testing methods.

No degradation products e.g. for atrazine and simazine or excipients (wetting agents, surfactants etc) are being tested for.

The community remains unaware as to what processes are put in place to remediate river water pollution, and to prevent pollution recurrences.

Drinking water quality therefore remains in question. ..


Correction: Change "[APVMA] used the data from corrupt testing done by Forestry Tasmania (FT) and industry-funded laboratory studies of triazines to justify continued registration of these chemicals.

Change 'triazines' to 'alpha-cypermethrin'. That is the corrupt testing of FT that I have direct experience with.

However, I understand that Forestry Tasmania (FT) also engage in testing of waters for the triazines. but this government business enterprise is corrupt through and through.

Refer:
http://tasmaniantimes.com/index.php/weblog/comments/this-was-a-creek-bed/

Bill Manning's (Tasmania's long term auditor on the Forest Practices Board) testimony to the Senate enquiry into Australia's Plantation 2020 Vision, and the recent federal court decision on the Wielangta forest in Tas where the judge found Forestry Tasmania in breach of the Federal EPBC Act (http://www.on-trial.info/). Plus, of course, our community's direct experience of FT lying repeatedly including promising native forest regeneration after a clearfell but instead replacing it with monoculture alien Eucalypt Nitens.

For more see: www.geocities.com/rosserbj

Neither Anthony Amis nor Brenda Rosser address the topic 'FSC back-tracking on pesticides: Board caves in to industry pressure', nor do they address the statements by Kevin O;Grady and Rob Rynearson and my comments. Rosser dosen't mention the FSC.

If Rosser has an argument with DPIW&E in Tasmania, that's her problem. Rosser's and Amis' Chicken Little rants are irrelevant to the topic. Score both of them nought out of 10.



Hi Barry,

Thanks for the plug of the Hancock Watch website. Forums like these are most useful in attracting new people to view the site. (Now at over 178,000 visits and travelling quite nicely). Thankyou.

As usual you have appeared to overstate my position. The VCAT admission (typo) was made by me not you. It certainly wasn't misleading evidence as I informed the VCAT Board first of the typo and they thanked me for bringing it to their attention.

I am still stunned about your comments about alpha-cypemrthrin. I recall that you stated in a letter in 2005 written to the Gellibrand community that Alpha Cypermetrhin was toxic to some freshwater organisms at parts per million. I had to point out to you at VCAT that it is actually toxic to some freshwater organisms at 4 parts per trillion. How did I find this out? I read the US label. Why did you underplay the toxicity of this insecticide by sending information to a community group?

The point I was trying to make with the Barwon Water data was, why wasn't this pollution incident picked up by the FSC auditors? Surely if a herbicide is detected by a water authority by 18 months, then it isn't much to ask that FSC be informed about it. Hancock knew about the incident but decided not to forward the information on. How tight is the FSC audit process when a company can pollute water for several months and not be picked up in the audit? Why did hexazinone continue to leach from the plantation for at least 18 months? How could it get past the reservoir and still be detected 50km downstream?

I have no bone to pick with FSC other than if they continue to certify companies that are acting in environmentally damaging manner then they will be looking for trouble.

I remember at the VCAT hearing, you thumped your fist on the table and announced to all that you had destroyed FSC. Perhaps you should share with readers your thoughts on the Australian Forestry Standard, which is really the certification standard that has your full support. Can you share with us how the AFS deals with pesticide issues and how it differs from the FSC?

You must be pleased to know that Hancock are in a great deal of strife in Victoria with FSC. Pesticides haven't been their greatest headache. Rainforest definition particularly in the Strzelecki Ranges is their major problem.

In terms of thresholds, I have no problems with getting the science correct, however what happens if after the testing, the thresholds for some pesticides are significantly lowered?

Can you please inform readers about ecotoxicological data concerning pesticides used by the Australian plantation industry. This is our major concern particularly impacts on endangered species such as Macquarie Perch, Trout Cod, Ewens Pygmy Perch, Australian Grayling Strzelecki Burrowing Crayfish, Strzelecki millipedes etc etc. Where is the science to back up claims that pesticides are safe to use in the vicinity of these species?

Anthony,

At the Colac VCAT hearing, you submitted a written document in which you included hexazinone information. I still have it. I pointed out to the Tribunal that this was a pine herbicide only and deadly to eucalypts; then you stood up and apologized to the Tribunal. I was not there when you gave your evidence, which also included material that I wrote for Melbourne University courses.

As to alpha-CP, read the information in the Pesticide Manual (Tomlin). I quote 'EHC 142 notes that, although highly toxic to fish, this is not realised under field conditions where rapid loss from water allows recovery of affected populations'. Also 'LC50 (96 hr) for rainbow trout is 2.8 ug/L; due to rapid loss from water, no toxic effect to fish is observed under field conditions'.

Note that the Pesticide Manual is FSC's first reference as indicated earlier.

Also, you were not responsible for the FMC data sheet on alpha-CP; I had it long before that. I noted that it was specific to the organism (not fish but mollusc) at which it was toxic at that low level. These are usually lab measurements, not field.

The second point I have made previously (which you ignore) is that it is rapidly photolysed on leaf surfaces. The third point is that it is amongst the most soil-fast of all pesticides - as I have said previously it sticks like super glue. It doesn't move and given normal stream buffers, the chance of it entering waterways is vanishingly small. Finally it has a relatively short half-life in soil.

I know of one case where it was detected - used by a farmer to control red-legged earth mite and sprayed right up to the stream edge.

Why don't you address the Drinking Water Guidelines? In the too hard basket? Are you suggesting that thresholds should be lowered just in case future research does that? We might as well give up on science!

I repeat again, insecticide use in plantations is very minor - about 1% of all plantation expenditure on pesticides which in turn is about 1% of the total Australian market. That is perspective - see the FWPRDC report.

I did not thump my fist on the table at VCAT and announce I had destroyed the FSC. Why do you make stupid statements like this? You did the same sort of thing in the Wombat News and Views. It doesn't impress! That is a very dramatic exageration; I told the Tribunal that in my opinion, the FSC chemicals criteria lacked scientific credibility, and that I had a peer reviewed paper on the subject.

Perhaps you also should note that in 2 of the three VCAT hearings in which myself and other expert witnesses for the industry have been involved, the decision has been in favour of the companies, not the objectors. The decision in the 3rd case is pending, and any comment would be inappropriate.

The AFS sensibly recognizes the Australian regulatory sytems for pesticides. I have been through that before also.

The FSC ignores regulatory systems here, and in the other CANZUS countries.

Hancock are not in 'a great deal of strife with FSC'. Again another dramatic exageration. However, I have no direct involvement there so end of comment.

Finally, when you and other scaremongers can produce hard evidence for your claims of unacceptable risk to aquatic organisms and the environments around plantations, you may get some credibility.

You incidentally, plugged your site. I merely noted it correctly as a long runnning harangue. When you have published a few peer reviewed scientific papers (very unlikely), you may then have some claim to call yourself a 'water expert' (The Age newspaper, October last year), or a pesticide expert (VCAT hearing) etc.

There will be no more on these issues from me. I set out to outline the problems with the FSC's chemicals criteria. These other 'issues' are irrelevant to that.

END of comments from me.


Thanks for your lastest 'spray' Barry. I did hand in a document to the Colac VCAT board with one typo. I did not stand up and apologise. I wrote hexazinone when I should have stated another herbicide. I told the VCAT panel of this typo when I presented my paper to them. Listening to the tapes of your expert evidence, you started your presentation off by stating to the VCAT panel that there were a number of corrections that needed to be made in your paper and then spent about 5 minutes going over several corrections. I did the same thing, but with only one 'error'.

As you know many of the tree plantations in Victoria were planted well before the code of practice was written. At numerous locations, particularly in the Otways, we have identified plantations with no plantation buffers on Class One streams. If insecticides are to be used in a plantation that has no buffers how can the applicator guarantee that some of the insecticide will not reach the waterway through overspray or drift? On this point we are also concerned that herbicides will be used in such close proximity to streams. One large rainfall event and we could see pollution events occurring.

In terms of drinking water guidelines, why didn't you tell readers that many of the pesticides used by the plantation industry are simply not tested for by water authorities in Victoria. In Victoria major problem areas for plantations and domestic water supplies are mainly in the Otways, Strzeleckis and North East. At a meeting we arranged in Gellibrand (Otway Ranges) in 2005 we were presented a list of pesticides tested for by South West Water. They were Heptachlorepoxide, DDE, Dieldrin, DDD, DDT, Endrin, Methoxychlor, Chlordane, a-Endosulphan, b-Endosulfan, Endosulpansulphate, Endrinaldehyde, Atrazine, Propazine, Prometryn, Mevinphos, Diazinon, Malathion, Fenthion, Chlorpyrifos, Ethion, Dichlorvos, Stirofos, Ronnel, Parathion, HCB, a-BHC, Lindane, Heptachlor, Aldrin, b-BHC, d-BHC, Ametryn, Terburthyl azine, Prometon, 24-D, 245-T, MCPA.

As stated almost no testing for pesticides used in plantation forestry until Barwon Water started doing it in 2004 due to the Safe Drinking Water Act 2003.

Several thousand hectares of plantations lie in the Gellibrand catchment and up to mid 2005 no data exists from the responsible water authority about plantation pesticides because noone publicly is collecting the data. A similar problem exists with North East Water and Gippsland Water. So how can we determine the situation if the information is not even being collated in the first place? I should also point out that some residents also source water directly from creeks downstream of plantations. Who is monitoring for pesticide runoff in their water? Answer: noone.

The best in terms of water quality the plantation industry can offer is guestimates. I should point out that North East Water will now be testing for hexazinone after hearing about the Barwon Water incident, which of course hasn't fully been explained by you. Typically herbicides detected in reservoirs are thought to be diluted down to an almost neglible amount. The Hancock incident proved otherwise. Constant detections for 18 months, up to 50 km downstream of the application site and reservoir. If this occurred at Geelong surely it could also occur anywhere where Hexazinone is used. Potentially every pine plantation in the state is at risk of a similar problem, with communities dowsntream at risk. The closer the offtake to the plantation the higher the probability of risk.

I did hear you say that you have destroyed FSC, it was a moment when you were getting hot under the collar. I remember the moment very well as I thought to myself what an odd thing to say when one of the companies that was wanting your expert evidence was certified by FSC. Needless to say we were most unimpressed that an FSC certified company would want to put a small community through all of the stress of a VCAT hearing.

In terms of the three VCAT cases, I should make the following observation. To me VCAT hearings are a little bit like poker. Those with the deepest pockets usually win. All companies have to do when they have these hearings is look around for an expert witness or three. Pay the witnesses a sitting fee, sometimes several thousand dollars, which they can probably claim back on tax, and the witnesses will basically say what the company wants them to say. The objectors, usually local residents, usually don't have deep pockets and are usually intimidated by the whole process. Where will the objectors find the time to raise the several thousand dollars required for an expert witness and legal advice? Where will they find the time to research up on a complex legal case. I note that in the first case you mentioned the objectors didn't have any expert witnesses at all so of course they lost the case. The second VCAT case, had a ruling from the President of VCAT stating that the application of pesticides on the land in question was entirely legal and did not require a permit as it could not be defined as works, whereas the ploughing and mounding for plantations in the land in question probably did require a permit. So legally the question of herbicide use was a non-event. You know that VCAT will not go against existing laws and it is a sad fact that the existing law is quite dated in relation to pesticide use. Only now is the Victorian Government even contemplating granting 200 metre spray buffers around schools and hospitals, where a pesticide sprayer will have to inform the school and hospital that spraying will occur.

Hancock are in strife with FSC. I suggest you read their latest audit where if Hancock don't produce a scientifically defensible definition of rainforest by February 2007, they could be stripped of their certification. Since FSC certification Hancock have gutted two key rainforest catchments in the Strzelecki Ranges and are now jeopardising a $7 million heads of agreement only signed in October 2006 by Hancock and the state government by logging within rainforest buffers on the Morwell River. Not a good look.

I never called myself a water expert, the Age reporter did that without asking me, but I bet that the article started a few heads thinking about the sustainability of plantations.

Finally, our organisation Friends of the Earth Melbourne, has been supporting organic agricultural initiatives for some decades. Why on earth would we support organic farming principles and not do the same for forestry? FSC is opening up a pandoras box by certifying plantations.

Not many people are aware of the politics behind this pesticide problem with FSC. Alot of FSC's current problems are stemming from events unfolding in Australia and New Zealand.

Australian and New Zealand FSC certified plantation companies met in late 2005 at Bellinzona Grange Country Retreat in Victoria Australia to nut out strategies and learn what FSC was up to.

The FSC companies were most upset about FSC's pesticides policy. For companies operating in Australia and New Zealand, additional pesticides added to the FSC prohibited chemicals list, would have created enourmous problems for these companies in that many of the chemicals are a 'staple diet' for plantation companies operating in Aust and NZ. As one industry rep said 'Nearly all the pesticides you currently work with are now under threat' and that 'your growing future depends on keeping on using current pesticides'.

The FSC plantation companies were already working on their own Standard for Environmental Certification of Well Managed Plantation Forests. This would be a backstop for the companies in case that negotiations with FSC failed. If they didn't get what they wanted from FSC, the Australian and New Zealand plantation companies would leave FSC on mass creating their own standard. A line was drawn in the sand - someone also explained it as 'A gun being held to the head'.

Such a move away from FSC in Aust and NZ could have killed off any chance of FSC properly establishing itself in Australia and severely undermined FSC's credibility in New Zealand. In Australia, ENGO's in 2002 could not reach consensus about FSC certification of native forests, and since that time FSC has been limited to mainly bluegum plantation companies (and one large pine grower). In NZ FSC is dominated by companies sourcing from vast pine plantations.

Complicating factors again was for an industry addicted to chemical props (many of which were now unpopular with FSC), there were no new chemicals emerging for the industry to move into for the next decade or more. New pesticides require years of trial work and there was also pressure emerging from the US that would make it difficult to register new residual pesticides in that country (such a decision would also have global implications).

Essentially then the future of the Australian and New Zealand plantation companies was based solely on the arguement of; Dependence on the current use of pesticides. FSC threatened this dependendence and future and as a result has had to take on board criticims from companies and individuals hooked onto the plantation chemical 'gravy train'.

Essentially FSC was forced into a corner. What is disconcerting is that rumours have it that FSC certified plantation companies are planning to extend the Australian and NZ experience and will be organising a global meeting in the near future, to broaden and strengthen their influence globally.

FSC should be applauded for at least trying to get a more ecologically sound outcome in relation to pesticides, but once the economic muscles start to flex and push FSC further into corners, FSC will find it extremely difficult to counter punch. In fact it is probably too late now.

I would like to thank Anthony and Brenda for contributing a bit of sanity to this sometimes entertaining exchange of views.

Barry Tomkins appears to be a deeply entrenched supporter of the intensive chemical-use timber plantation industry in his part of the world. Also so heavily biased in his views that he is unable to see that his obsession with attacking the FSC for its alleged failure to use 'peer-reviewed' research is totally irrelevant to the actual subject of this debate!

Barry, please go back to the beginning and read the original message. This is about a political decision by FSC to extend the period for submission of pesticide derogation requests, and you have wittingly or otherwise chosen to launch into a tirade that has little bearing on the real issue.

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