FSC-Watch

An independent observer of the Forest Stewartship Council

How the FSC broke, then further weakened, its rules on pesticidesTags: Ireland, Pesticides, Accreditation controls, national initiatives, Plantations, Soil Association Woodmark

In December 2006, FSC-Watch reported on how the FSC had bowed to pressure from the plantation industry to 'freeze' implementation of its pesticides policy, which prohibits the use of a chemicals included on FSC's 'banned' list. Under a decision taken by the International Board, FSC decided to extend until the end of June 2007 the deadline by which forestry companies had to apply for special 'derogation' permission to continue using banned chemicals. But FSC-Watch can now reveal that FSC has conspired to allow use of banned chemicals even where no derogation has been granted - and has now removed one of the major 'safeguards' that ensured that pesticide derogations were supported by local stakeholders.

Under the FSC's rules until mid-2007, derogations could only be granted where such a derogation is supported by the relevant National or Regional FSC initiative. In 2006, a derogation for the use of 'banned' alpha-cypermethrin - a 'highly toxic' substance used to treat plantation seedlings - was sought by Soil Association WoodMark on behalf of its certified client, the Irish State forestry company, Coillte. The request was duly considered at the end of 2006 by the FSC-accredited national body, the Irish Forestry Certification Initiative - but the request was not approved, and the FSC Secretariat, in the person of Frank Katto, was informed of this.

As Coillte's derogation request had failed to gain IFCI's approval, the matter should have ended, and Coillte should have ceased all use of cypermethrin. However, WoodMark still forwarded the derogation request to the FSC Secretariat. In a letter to an Irish stakeholder in December 2006, FSC's Katto confirmed that there had been no support for the derogation from IFCI, and that the derogation request was therefore not valid: *"according to the current FSC procedures for processing derogations applications, the Policy and Standards Unit cannot process an application until a written letter of support from the responsible FSC-accredited National Initiative is received. I was informed that cypermethrin application has been submitted without the letter of support from the Irish FSC-accredited National Initiative".

Nevertheless, in September 2007, a conference on water quality issues in Ireland was told that Coillte were at that time still using cypermethrin, and that a derogation had indeed been granted by the FSC. In the same month, following an inspection of Soil Association WoodMark's certification of Coillte, FSC-ASI reported that "Soil Association and the certificate holder have presented an official request for derogation regarding the use of alpha-cypermethrin" and that "this derogation is currently being reviewed by the FSC in line with FSC requirements" - thus ignoring the fact that the request had not been approved by IFCI, and that WoodMark had been seriously at fault for firstly submitting a 'non-approved' derogation request and then failing to sanction Coillte for continued use of a banned pesticide. ASI nevertheless concluded that it "did not detect any non-conformity" in Soil Association's behaviour.

ASI did, however, find that another banned pesticide, simazin, was also in use, without a derogation, by Coillte in its tree nurseries - but noted that, for reasons that have never been explained by WoodMark, the Coillte nurseries have been excluded altogether from their certification assessment - even though it is clear that nurseries form an integral part of plantation operations, and are required to be assessed under FSC Criterion 10.7. By excluding the nurseries from their certificate, Woodmark had circumvented the need to apply for a further pesticide derogation for simazin.

Even though ASI had actually detected two major breaches of the spirit and the letter of FSC's rules by WoodMark, their meek response was to issue a 'Minor Corrective Action Request' against WoodMark.

As at March 2008, Coillte continue to use cypermethrin, more than a year after their request for a derogation for its use was rejected by the Irish National FSC Initiative - a situation which is not only contrary to FSC's requirements, but utterly unacceptable to Irish stakeholders. Once again, ASI has allowed a certifier to operate with complete disregard for FSC's rules.

FSC-Watch invites readers to submit information about other cases of banned pesticides in use in FSC certified operations.


POSTSCRIPT

In May 2007, FSC changed its rules for dealing with pesticide derogations (see below). National Initiatives were stripped of their role in giving consent to derogation requests - which are now entirely the responsibility of the certification body. National initiatives will now 'be informed' by certifiers of derogation requests, and are charged only with 'assisting with public consultations' on the derogation - even though the national initiative might well have established a national FSC standard excluding precisely the pesticides for which the certifiers might be seeking a derogation.

Once again, FSC appears to have conceded to the economic interests of the certifiers, who of course have a strong vested financial interest in supporting use of pesticides (because this allows them to certify planet-poisoning companies that would otherwise be excluded from certification), whereas the multistakeholder national initiatives are reduced to merely supporting the business of the certifiers.

PROCESSING PESTICIDE DEROGATION APPLICATIONS FSC-PRO-01-004 (V2-1) EN

4.3 "For countries in which there is an FSC-accredited National Initiative, the certification body shall inform the National Initiative that it will apply for a derogation for the use of a 'highly hazardous' pesticide, and shall give the NI the option of assisting in the consultation with stakeholders in the country in relation to their opinions on the application and in developing the derogation application. The FSC-accredited National Initiative should endeavour to assist the certification body, within the limitations of its resources. However, the certification body is responsible for completing the derogation application, whether or not the National Initiative is able to contribute."

Comments

As an initial response to the above from someone who did some of the research behind this posting I can only say that this news as it emerged over the last week or so has evoked a response among Irish stakeholders ranging from shock to fury.

Allow me if I may to quote from the usage instructions from a bottle of pet shampoo that contains permethrin which I came across recently:
"The product is harmful to fish and crustacea. Do not contaminate ponds, streams, aquaria or fishbowls with the product. Dispose of any waste water onto soil not used for growing vegetables... Avoid contact with skin. Wear protective gloves... and wash any exposed skin after use... In case of contact, rinse immediately with water and seek medical advice..."

Further, the US FDA think this stuff is probably carcinogenic.

AND it wipes out invertebrates of all kinds, including the earthworms essential for soil health.

AND it bioaccumulates in mammals. Mammals means YOU and ME. It also means badgers and bats and hares and deer that can't read signs warning of recent spraying.

FSC decided to change the rules, not one but TWICE in six months to allow this chemical be sprayed on areas which are not only open to the public but where the landholders actively ENCOURAGE public access.

We have only discovered this through the collection of scraps of information and odd references from a diversity of sources NONE of which came from FSC.

WHAT THE *** H E L L *** IS GOING ON HERE???

I am struggling with my anger while I write, and the reasons for this are plain. My children have been unknowingly subject to contact with cypermethrin for over a year. Not just my children but the children of every family in Ireland.

Over a year. That is how long it has been since Frank Katto confirmed to Irish stakeholders that this derogation request was incomplete. Understandably, looking at FSC's own rules on the matter, we felt confident that cypermethrin use would then cease. They have been put in this position not through carelessness on the part of their parents and teachers but through a sequence of what we must for now presume to be planned deceptions by FSC. The process ran something like this:

- Coillte submitted their derogation request via Soil Association

- IFCI, the Irish National Initiative, refused to support this request

- Soil Association sent the request to FSC regardless

- FSC saw it was invalid

- FSC extended the closing date for derogation requests at the last minute

- IFCI now had another six months to state their support

- Coillte had another six months to use cypermethrin

- This support was not forthcoming

- Again at the last minute, FSC changed the rules

- Now, the missing support from IFCI was not needed

- Coillte could again continue to use cypermethrin

- Nine months later FSC are still 'considering' the derogation request

- And... a request for clarification from FSC remains unanswered over a week after it was issued

Throughout this process, NONE of the Irish stakeholders was advised of the shifting goalposts. As far as I can determine NONE of the members of the National Initiative were advised either.

Elsewhere on this site I have recently likened FSC's approach to that of a multinational corporation bludgeoning their way through the rights and views and needs of the local populace in pursuit of profit. At the time the analogy was supportable. Now, it seems it is basically a perfect description of FSC's methods.

WHY???

Is it the ongoing battle for 'territory' between FSC and PEFC? Has it come to this? Are the health and welfare, not to mention the rights... not to mention the very rules FSC itself purports to uphold... as nothing in this battle?

If so, how is it that the likes of Greenpeace continue to play a key role in FSC? Is it all lies?

For the first time, I have begun to see FSC as an enemy rather than a friend that needs our help.

This is NOT how it was supposed to be, is it? This is NOT what FSC was set up to achieve. Until now I have avoided using phrases like 'greenwashing' when discussing FSC's activities.

I now have no choice because that is EXACTLY what this is.

Stiof MacAmhalghaidh

Stiof,

I am not an apologist for FSC.

However I think that you are somewhat over reacting to the effect that you believe permethrin and other forestry chemicals may have on you.

I write from the UK, south Scotland in fact, where the landscape and plantation forestry is similar to Ireland, and there are parallels.

The experience in the UK is that remote, desolate and treeless landscapes were transformed by plantations in the 1960’s. Initially these were pretty much monocultures (and there were plenty of critics of them), however the last couple of decades have seen these monocultures transformed by clear felling and replanting with a broader diversity of species.

The robust pioneer tree species have created micro climates where more sensitive flora and fauna can thrive.

As to the typical chemical inputs of these plantations:

At planting (of the treeless land) each plant would receive about one handful (say 50 gm) of unground phosphate rock (= 125 Kg per ha).

Thereafter there would be no chemical input until after felling.

25 to 35 years later after the crop is felled and replanted one or two sprays of glyphosphate (by hand application) to remove nutrient competition by grasses (with a patch of about 1m2 = 1.25 litres per ha per application) to allow the transplant to establish itself.

Fertiliser is unnecessary at restocking, as the soil has been improved by the previous crop.

Prior to planting the transplant may be treated by the electrodyne process where it passes through an electric current and a very fine spray of permethrin, in order to use the minimum chemical necessary to prevent it’s death by Hylobius abietis, an insect pest. In addition it may receive one or two applications of alphacypermethrin (about 0.2 ml [0.5litres per ha] per plant per application).

Repeat this every 25 to 35 years (about the life of a typical plantation in these parts), and you have chemical load of 35 to 50 ml per ha per annum, or in other words, three tablespoons of chemical, spread on 10 000 sq metres per annum. Equate that with, say a petrol spill on the forecourt, or perhaps the chemical one might use to keep a driveway clear of weeds.

This dilution effect is considerable.

Plantation forestry is hardly pesticide soaked, especially if one compares it with the chemical inputs of agriculture aquaculture and horticulture.

You and your children and the children in all of Ireland have other things which are probably more dangerous to you than such tiny quantities of chemical.

One thing I am fairly sure of is that plantation foresters are all in the same boat - management with minimal costs. We do not use expensive chemicals without good reason, therefore we minimise the use of it. FSC insist upon this (FSC STD 001 6.6) and their insistence is generally interpreted as using reducing quantities. It is a pity that there appears to be a dichotomy between the stated rules and the practice where you are.

Of course we are dealing with a poison.

However it is also worth remembering that a huge number of people in the tropics each night sleep under mosquito nets. Generally they have been treated with permethrin.

Alternatives to permethrin as treatments against Hylobius abietis do exist, and they are likely to grow in popularity as organisations such as the FSC (and public outcry) raise doubts about them.

I hope this is some reassurance.

Mark

Memo to Stiof: If you haven't already realized it, permethrin and alpha-cypermethrin are related but different chemicals. At one part of the molecule, permethrin has a -CH2- group but alpha-CP has a -CH(CN)- or nitrile group.

Alpha-CP but not permethrin is used in plantations in Australia occasionally on an as-needed basis. Mark's comment about the minimal extent of pesticide useage in plantations also applies here. In A$ terms, the plantation use of pesticides accounts for less than 1% of the total Australian pesticide market, regulated under Commonwealth legislation by the Australian Pesticides and Veterinary Medicines Authority (APVMA). Of that 1%, insecticides for plantations account for just 1% again, or 0.01% of the total Australian expenditure.

By comparison, household pesticide expenditure here is about 10 times that of the total plantation expenditure!

I often wonder why the FSC bothers about forestry use of pesticides, particularly in advanced countries with rigorous regulatory systems developed over decades and long before the FSC was formed. Of course, the answer is obvious - the FSC operates on a belief system which is no basis for a pragmatic, scientific approach to pesticide use.

The FSC does not recognize the APVMA or other national regulatory authorities in New Zealand, Canada, USA etc - more comment on that situation below.

As to your pet shampoo, you would be better using a product containing imidacloprid - an insecticide also widely available in garden products and not proscribed by the FSC.

Imidacloprid has been developed here for plantation use as an insecticide/fertilizer pill called Initiator (Bayer product) applied at planting under the seedling roots of eucalypts, and provides about 18 months of protection against many chewing insects.

To FSC-Watch, it is simazine, not simazin! Other critics on this web-site have mis-spelled it simizine, which brings to mind the following quote "The trouble with ignorance is that it picks up confidence as it goes along".

As to the FSC 'rules' relating to pesticides - this has been a long and continuing saga. The original 'rules' were set up in a commissioned, unpublished, and non-refereed 'paper' by Radosevich, Lappe and Addlestone (2000). In a refereed paper in Australian Forestry in 2004, I showed that the parameter based approach was pseudo-scientific; I'd prefer to use the term junk science but that is not acceptable in a sober, peer-reviewed paper.

That led to the equally appalling 2005 PAN-UK review of the FSC pesticide policy and criteria, senior authored by Roslyn McKendry (a co-author was Richard Isenring). When that proved unpalatable, the FSC agreed to set up a 'Pesticides Expert Panel' (PEP), and nominated Radosevich, McKendry and Gerhard Verdoorn (Birdlife South Africa), who had also had previous commissioned input to the FSC, to again review the issue.

By this time the CANZUS group had been formed, consisting of FSC certified plantation/forestry organizations in Canada, Australia, New Zealand and the US all concerned about the FSC's pesticides criteria and policy. That group represented about 21% of the FSC certified area worldwide.

That group nominated 3 representatives to the PEP: Emeritus Professor Frank Dost, recently retired, Toxicology and Agricultural Chemistry, Oregon Sate University: Dr Stefan Gous, ENSIS Rotorua, NZ, with expertise in both pine plantation herbicide use and application technology and Prof. Shepard Zedaker, Professor at Virginia Tech, with extensive experience in forestry pesticide use and silviculture.

Frank Katto chaired this PEP. A word about his 'expertise' - when he took over from Matthew Wenban-Smith, he reviewed the FSC 'prohibited' and other pesticide lists and decided that, on the basis that 2,4-D isopropylamine was 'prohibited', glyphosate isopropylamine should also be 'prohibited'. In short, Katto did not understand that the isopropylamine was actually isopropylammonium cation, and that the herbicide was the anion.

The PEP met in January of 2007, after all 6 FSC and CANZUS (independent) members had submitted material.

Note that Radosevich, McKendry and Verdoorn were NOT independent, and the first two were 'reviewing' their own work! Note also that the Chair lacked expertise and was not independent.

In May 2007, the FSC posted the PEP report on the FSC Pesticides Review site. However, it was NOT seen by the independents prior to posting, and it contained material NOT discussed and agreed on at the January meeting!

It turned out that the FSC had obtained comment on the PEP's deliberations from Richard Isenring (PAN-UK) and Lars Neumeister (PAN-Germany) behind the backs of the independents.

Dost and Gous sent a strongly worded letter to Heiko Leideker objecting to this disgraceful behaviour; the letter contains much scientific crtiticism of the FSC's chemicals criteria etc. The CANZUS group also sent a similarly strong letter. Liedeker replied (eventually) - a letter that I consider to be pathetic.

The FSC' duplicity was obvious; the whole process was compromised from the start by the appointments of Radosevich, McKendry and Verdoorn.

In the meantime, FSC Australia has set up a Pesticides Advisory Group (PAG) which has called for comments on 8 pesticides which the FSC avers require derogations (see fscaustralia.org). These chemicals are now 'FSC- highly hazardous'. (Terminolgy is no longer 'prohibited' but rather 'FSC highly hazardous' - terminolgy strongly opposed by the CANZUS group and scientists alike)). This PAG apparently can only make recommendations to a similar group set up by FSC in Bonn, who will decide on the derogations. That group consists of Richard Isenring, Lars Neumeister and Gerhard Verdoorn!

Each FSC certified Australian company has to put in separate derogation requests - a process that looks as if it will bog down through weight of numbers of requests. Basically it appears to unworkable.

Further, there has now been a 'continuous improvement' group set up by the FSC, consisting of largely uncompromised individuals and the intention apparently is to shift the pesticide 'issue' into the FSC plantations review. Details on this group are on the FSC site.

However, and I quote from their first meeting:
'The committee expressed all the same concerns that the CANZUS group did on the current guidance to the pesticide policy in relation to thresholds, hazards vs. risk and the lack of acknowledgement of regulatory authorities. However, the group agreed that it was not their role to revisit these issues but to develop a better way forward’.

No-one could look at this and say that it is not a mess. The FSC has demonstrably been guilty of deceit, unscientific deliberations, unprofessional behaviour and complete disrespect for persons such as the 3 independents on the PEP.

A quasi-religious belief system ('all chemicals are bad') is no basis for deciding on pesticide use in any situation. The 'highly hazardous' notation is ludicrous and not used by creditable organizations including government regulatory authorities.

Yours etc

Barry Tomkins

An interesting media release from the Tasmanian Greens 28 February 2008. Note that no plantation companies in Tasmania are as yet FSC certified. No surprises there, but some do wear the Australian Forestry Standard as a 'badge of honour'. If plantations are clean and green and require few pesticide inputs why is this pollution still happening? Please note that according to Prof Tyrone Hayes (University of California) both Simazine and Atrazine can chemically castrate frogs at doses as low as 0.1ppb. Australian Health Guideline for atrazine is 40ppb and simazine 20ppb

aa


The Tasmanian Greens today accused the State Labor government of covering-up the true state of agricultural chemical contamination of the state’s waterways, saying that since 2001 there have been at least 246 instances where chemicals were detected, but of that total, 130 instances of chemical detection were not published by the government as part of their chemical testing regime. Simazine and Atrazine, both of the controversial triazine family, dominate the unreported results with a further 92 occurrences.

Greens Shadow Water spokesperson Tim Morris MP said that it is unacceptable and dishonest for the government to allow its current partial publication of water test results to be presented, and interpreted, as a full and comprehensive portrayal of the state of the rivers at that given time, and has demanded that the Minister comes clean and provides the public with an explanation, and also now has the full data placed on the government website.

Mr Morris also said that there are serious questions about whether the government is deliberately distorting the results contained in its most recent public notification of its water testing results, saying that a departmental letter obtained by the Greens had cited two instances of simazine being detected in the Macquarie River during January of that testing period, yet the results available on the government website do not record any detection of simazine for the Macquarie River.

Mr Morris’ analysis, that he released today, was based on data received from a Greens’ Freedom of Information request, plus reports from Water Authorities, and other government correspondence.

“The Greens analysis of documentation obtained under FoI, other water authorities, and also departmental correspondence, paint an extremely alarming picture of the chemical contamination of our rivers and waterways, with there being at least 246 chemical test coming back positive that I have been able to glean from available documentation, but it is most likely that there have been more,” Mr Morris said.

“As if that is not bad enough, on top of that it is apparent that the Labor government has been hiding the extent of this ongoing chemical contamination from the Tasmanian public for years, with at least 130 instances of chemical detection going unpublished, and 92 of those detecting triazines.”

“There is a chemical cocktail in our rivers. The frequency of contamination is unacceptable, and the secrecy about that level of contamination is dishonest and must stop.”

“Also of serious concern is why the most recent public update posted on the DPIW website states that simazine was not detected in the Macquarie River during January this year – when I have a Departmental letter which reports detections of simazine in the Macquarie River when tested during January?”

“I am calling on the Minister, David Llewellyn, to explain this discrepancy in reporting the January results immediately and correct the public record.”

“Minister Llewellyn must explain the blatant contradiction between the documentation available on his department’s website, and the correspondence issued by his department.” (see attached).

The Greens’ Freedom of Information request provided chemical testing reports for the last three years, which were assessed in conjunction with other results sourced from the Water Authorities, such as Esk Water and Hobart Water, which has provided data stretching back to 2001.

“The Greens analysis is just the start as what our FoI has told us is that there is probably many more chemicals in rivers detection results that we do not know about, especially covering the 1990s and the first half of this decade which were not covered by our FoI request.”

“This cover up must be stripped away. The Minister must apologise to the public, and require that all water testing results are made public in a comprehensive and uniform manner, and include all tests conducted by the department or a Regional water authority.”

“It is also very significant that the majority of unpublished chemical detection results involved Simazine and Atrazine, predominantly used by the plantation and forestry industries, with there being at least a combined 92 unpublished detection results of these triazines.”

“Is this why these results have not been published?”

“Chemical Trespass legislation must also be implemented as a matter of urgency, to make illegal the unauthorised contamination by agricultural chemicals of land and waterways an offence,”

“There must be an end to the chemical cocktail in our rivers, not a cover-up,” Mr Morris said.



The Greens’ analysis shows:

In the documentation available from November 2001 to January 2008, at least:

· 246 – Samples that showed chemicals in the water

· 130 – Instances that the government did NOT publish

· 3 – Discrepancies between published results and FoI documentation



Unreported Contamination Occurrences – Chemical-type breakdown

· Simazine – 78 extra occurrences NOT published by the government

· MCPA – 33 extra occurrences NOT published by the government

· Atrazine – 14 extra occurrences NOT published by the government

· Terbacil – 2 extra occurrences NOT published by the government

· Metsulfuron-methyl – 2 extra occurrences NOT published by the government

· 24-D – 1 extra occurrence NOT published by the government

· Desisrporpyl Atrizine - 1 ? extra occurrence NOT published by the government



January 2008 – Serious Contradiction that Must be Explained

Test Results published on Department website on 27th of February 2008 indicate that none of the samples taken at the 3 sites on the Macquarie River, on the 16th of January, detected Simazine.

Greens’ documents show that for the 16th of January this year - Macquarie River samples DID detect Simazine:

· Sample detected Simazine at 0.29 ug/L

· Sample detected Simazine at 0.36 ug/L



Chemical Detection levels that Exceed Guideline Levels

47 = Total number of instances that exceed Guideline values. Only 11 of these have been published, including 1 by media release.



Triazines Dominate Results that Exceed Guideline Levels

· 29 Simazine instances that exceed Guideline values is over half of the total number (47) that exceed guidelines

· 43 of the total of 48 instances of results exceeding Guidelines is the combined result for Atrazine and Simazine.

The Triazines are heavily used by the forestry and plantation industries, despite community calls to have their use banned.



Too Many Pesticides In Our Rivers

Documents Analysed by the Greens Show:

· 2001 – 1 known instance of published detected chemical occurrence.

· 2002 – no data examined.

· 2003 – 3 known instances of published detected chemical occurrences.

· 2004 – 1 known instance Published. 10 Unpublished.

· 2005 – 18 Published occurrences. 27 Unpublished.

· 2006 – 14 Published occurrences. 29 Unpublished.

· 2007 – 77 Published occurrences. 62 Unpublished.

· 2008 – bad track record already! At least 2 Unpublished occurrences.

The triazines are also used by agricultural industries, particularly tt-canola (triazine tolerant). I was well aware of the Greens press release, having been sent it within a day or two of its release. The additional detections were successive to the first; that is, the initial detection was reported, then testing was reported at monthly intervals until there was no further instances, but tests in between on the time sequence were not reported. Thus these so-called new detections actually largely relate to initial detections. In the flood data collected on 4 streams during rising water levels, even the times are given, which demonstrate the point. Nevertheless, I understand that all detections will now be reported, in time sequence.

There were a large number of non-forestry detections, particularly of MCPA, and some 2,4-D, which should not be glossed over. This matter does not concern the FSC (chemophobia rules OK!) because it is not represented in Tasmania.

As to Tyrone Hayes, the US EPA issued a white paper in October:

The following is the link to the USEPA white paper on the potential effects of atrazine on amphibian gonadal development - this was considered at a meeting of their Science advisrot panel on October 9-12, 2007:- http://www.epa.gov/scipoly/sap/meetings/2007/october/2007_amphibian_white_paper.pdf

Here is a copy of their 'CONCLUSIONS FROM LABORATORY AND FIELD STUDIES'

The Agency has reviewed 36 open literature and registrant-submitted studies related to the potential effects of atrazine on gonadal development in amphibians. Overall, the weight-of-evidence based on these studies does not show that atrazine produces consistent, reproducible effects across the range of exposure concentrations and amphibian species tested. In laboratory studies where environmental and animal husbandry factors were controlled, atrazine exposures (0.01 - 100 μg/L) did not affect time to or size at metamorphosis, sex ratio, or gonadal development. While there were several effects on secondary gross and histological endpoints that were statistically significant, their relationship to apical endpoints of intersex and/or gonadal development effects is not considered relevant.

Because of the uncertainties associated with all the laboratory and field studies conducted prior to 2003, the 2003 SAP recommended that additional studies be conducted to determine if exposure to atrazine affects amphibian gonadal development. In their report, the SAP recommended using X. laevis as the test species as well as indigenous species. Because the SAP report did not identify what benefits the indigenous species would provide, the Agency concluded that testing with X. laevis would be sufficient for a Tier 1 study. Based on the recent nineteen studies reviewed, including the recently submitted DCI studies showing no effects of atrazine on amphibian gonadal development, the Agency has further concluded that the higher tiers of testing proposed in the 2003 White Paper (USEPA 2003) are not needed at this time.

(The 2003 White Paper may be found at: http://www.epa.gov/oscpmont/sap/meetings/2003/june/finaljune2002telconfreport.pdf )

Barry Tomkins

Mark and Barry and Anthony,

Interesting technical reading from you guys. Thanks. While I'm neither a chemical engineer nor a forester, this type of reading is right up my street.

However, the primary point that I take from Stiof's posting is that FSC have changed their rules to suit Coillte Teoranta. This is just not feasible.

Whatever you think about the chemicals used, they are banned by FSC (except under dertogation). Under the rules at the time, Coillte's application for derogation HAD TO BE REFUSED. The National Initiative did not support it. So how is it that Coillte can and are still using these chemicals?

Regards

Ciaran Hughes
Ireland

Please note above in my previous material - somehow, in copying the EPA conclusion, the numbers 0.01-100 ug/L came out as μg/L. The mysteries of computers can be confounding.

Barry Tomkins

Barry can you please clarify your earlier email where you said;
"There were a large number of non-forestry detections..."

Can you please let readers know how many forestry detections there were and how you determined that these detections came from forestry re: plantations.

This issue is very relevant to FSC, as FSC allows derogations for simazine (amongst others). There have been moves by Tasmanian plantation companies to join FSC and they are also likely to be using some of these herbicides. Why should FSC allow continued use of herbicides if these herbicides are already being found in waterways and domestic water supplies?


aa

Dr Tomkins

Our use of the word 'simazin' instead of, as you point out, the correct word 'simazine', is as used by the FSC itself in the ASI report on Coillte. Your correction on the terminology should be taken up with FSC.

FSC-Watch

The simazin vs simazine issue just goes to further show the ignorance of the FSC on pesticides, which I have been pointing out for over 5 years. Other examples include the initial FSC prohibition on 2,4-D esters - the fact is that 2.4-D salts and esters behave almost identically once they hit foliage or soil, because the esters are immediately hydrolysed to the acid. Another example was haloxyfop which the FSC has had to concede is not a chlorinated hydrocarbon by international definition. As a result, these are now off the 'highly hazardous' list, all bar one 2,4-D ester which is again curious.

As to Tasmania, I actually took the time to go right through the data on the DPIE data base of the water monitoring program. In the flood monitoring program some 53 or 55 initial detections out of around 83 to 85 were MCPA, plus a couple of 2,4-D detections. These are non-forestry herbicides. Some others may or may not have been forestry related. Whilst there were a small number of initial detections above the GLV (Guideline Value) for drinking water, all were way below the HLV (Health Level Value). Chemicals in water destined for human consumption are subject to dilution, and to degradation by photolysis, oxidation, bacterial degradation and treatment prior to reticulation.

As I have pointed out many times before, the major use of atrazine is in canola; the Australian market is about 2000-2500 tonnes a.i. p.a. with only about 30-35 tonnes going into forestry. Yet there is no fuss kicked up about that - or any monitoring. Simazine is also used quite widely for canola. Atrazine is also used in sugar cane, cotton, sorghum, and corn, and other minor uses.

Barry Tomkins



Hi Barry -

Just a little confused by your statement -

<<Fertiliser is unnecessary at restocking, as the soil has been improved by the previous crop.>>

Are you talking about Sitka spruce as the previous crop on peaty soils, the situation here in Ireland?

How exactly has this crop imporved the soil?

Tony


Tony,

Fair question.

On the better quality sandy soils in the SW of Victoria and SE of South Australia, slash retention of the branches and stripped bark at harvesting and chopper rolling of all this residue, when it dries out sufficiently, is practised. Edge trees with large outside branches are usually heaped in small heaps around the coupe and burned, although the current practise is often pruning of outside trees. The crop tree is Radiata pine, grown for sawlogs on about a 30 year rotation, with thinning at about age 12-13 and again at about 22 years. The mulching (and any residue from thinning) returns 90% plus of the nutrient. That is sufficient for about the first 4 years of the new crop, which is then fertilised, and the crop may also receive a mid-rotation fertilisation.

Forestry South Australia long ago developed a site quality index for these soils, and have demonstrated that these practises improve site quality over rotations. The retention/chopper rolling practise developed after the first rotation of plantations, pit planted on cleared ex-native forest/scrub (this ceased in the 70's!) on these sandy sites but without other intervention, which resulted in long rotations up to 50 or more years, and a lot of quality/yield problems. The initial second rotation establishment practise then was to broadcast burn the residue from the first rotation, but this resulted in slower growth of the second crop, which was termed 'second rotation decline'. The basic reason was removal of the water retention properties associated with soil organic matter, and to a lesser extent nutrient losses through volatilisation (N) and leaching (Na, K, Ca, Mg, P etc).

From the research that was done, slash retention and mulching was developed as a better approach. It also has allowed reduction in herbicide use rates through suppression of competitive weeds.

Slash retention in pine is also practised on many other soil types.

I hope that clarifies the issue. I think that on Ireland's peaty soils, even heap burning of edge trees would be a risk?!

Cheers,

Barry Tomkins

Now, Ciaron's query:

I am not familiar with the situation in Ireland, but I offer the following comment:

If you put your faith in Environmental Non-Government Organizations (ENGO's) and ignore national regulatory systems, there isn't room to complain when these ENGO's don't behave as you expect. FSC refuses to acknowledge national regulatory authorities, as I have repeatedly pointed out.

Far more can be achieved by working within systems. Here, for example, public comment is often invited by our APVMA on various issues, for example, the recent material on the review of atrazine use and of spray drift (see apvma.gov.au).

We elect parliaments to deal with such issues, by setting up appropriate bodies under legislation. The FSC ignores this, yet demonstrably lacks the resources attached to such authorities, and lacks the appropriate knowledge. Hence the fumbling and mess that is the FSC's policy and criteria on pesticides, which is predicated on a belief system, not on good science.

Sites like this are sometimes useful to people like me, but more often provide a forum for bellyaching by disaffected parties with an axe to grind, operating of course from outside the forestry industry. That is a negative approach, whereas operating from within the system is far more productive.

I recently conducted a (fifth since 2000) plantation pest control seminar and workshop attended by over 100 people from the industry, chemical companies, APVMA etc. The industry is very active in developing better methods of pest and weed control, but the disaffected give the industry no credit for this, although this process of improvement has been going on for decades.

Barry Tomkins

Barry,

According to the PTA there are 254,000 ha of tree plantations in Tasmania. (23,000ha going in on private land in 2006!)

According to the DPIW, in 04/05 there were 800 ha of canola grown in Tasmania increasing to 1750 ha in 06/07.

Therefore Canola grown in Tasmania has only 0.3% and 0.7% of the land mass that the plantation industry has.

If plantations are sprayed with herbicides after being logged in a 20 year rotation, that still leaves plantation spraying occurring on 12,700 ha of land in Tasmania each year. (that brings canola up to 6.3% and 13.8% of the sprayed area in comparison to plantations).

It certainly is not a good look for the Tasmanian plantation industry to be anywhere associated with water pollution via Simazine, Terbacil, Metsulfuron Methyl and Atrazine. A very bad look indeed and FSC would be well advised not to get involved in this polluting industry in Tasmania.

I am no fan of FSC, but at least it is trying to grapple with this issue, unlike the Australian Forestry Standard which appears to support a business as usual approach. Given that the Atrazine and Simazine pollution is most likely to have come from plantations, why have these plantation companies retained their AFS certificates? What leverage does AFS have to help stop the pollution of Tasmanian waterways by plantation companies?

aa



Quotes from B Tomkins and my comments underneath,
"I was well aware of the Greens press release, having been sent it within a day or two of its release. The additional detections were successive to the first; that is, the initial detection was reported, then testing was reported at monthly intervals until there was no further instances, but tests in between on the time sequence were not reported. Thus these so-called new detections actually largely relate to initial detections. In the flood data collected on 4 streams during rising water levels, even the times are given, which demonstrate the point. Nevertheless, I understand that all detections will now be reported, in time sequence."
The additional detections - many were reported by the Greens from FOI information, they were not followed monthly and they were not folloed until there were negative results. They are non-reporting by DPIW of contamination results and are not on DPIW website. The flood reporting is inaccuate as there are only a limited number of bottles on the automatic samplers and so contamination levels do not get followed to below detection levels, and many floods are not reported at all. Even values above guideline values(GV) do not get publicly notified or investigated and reported. Water sampling is haphazard,tests are only for water soluble peasticides ie not total load of pesticides and will not detect alpha-cypermethrin, and does not follow spraying events or notify consumers in a timely fashion of contamination events.
'Water' in Tasmania is the responsibility of the Dept of the Premier who delegates that responsibility to the Dept of Primary Industry and Water. In general terms DPIW is responsible for water until it reaches the water intake pipes for that town, or potable water supply. Then the 'water body'
be it Esk Water or the local council takes over that responsibility. They are responsible - legally - under the Dept of Public Health for the drinking water. By law it is supposed to be 'clean, safe and non-toxic'. Nobody should accept having pesticides in their drinking water.
DPIW is also the Dept that regulates the use of pesticides; what can be used, by whom, where and when. This includes using 1080.
It is that simple.

"There were a large number of non-forestry detections," - how do you know this as these matters have not been fully investigated or publicised? Forestry companies do use these chemicals in Tasmania.

Atrazine and Prof Tyrone Hayes
The US EPA has not always been correct and their summary and conclusions have not stood up to scientific rigourous review- we all know why, but all will eventually be revealed. Until then we have waterways and ground water contamination with endocrine disruptors at effect causing concentrations. See aa remarks above re comparison between areas planted with trees and canola- we have no cotton- in Tasmania. The Macquarie River has been permantly contaminated with simazine since 7/2007 and still no public advice to water users.
Since 2005, atrazine has been found in the Duck River, Rubicon Rver, Liffey River, Derwent River and simazine has been found in the Brid, Montague, Prosser, Rubicon, South Esk and Trevallyn Dam, Macquarie, Brumbys Creek, Western Creek. Launcestons water supply reported simazine in 2003 and 2004 at above GV, and atrazine at above GV in 2001.
Alpha- cypermethrin is acutely toxic to aquatic life, and 5 ml will kill all aquatic life in approximately 50 million cubic litres.
In humans it is an immunotoxic, an endocrine disruptor and causes epigenetic changes ie will change gene functioning.

Fertility issues are increasing and IVF is now considered to be potentially required for 1 in 6 Tasmanian couples.

Why has Tasmania one of the highest rates of cancer - age-standardised - in Australia?

All forestry - especially 'clean and green' FSC - needs to be accountable to those affected by their practices.

Dr Alison Bleaney
Tasmania (ex north of Scotland)

Tony,

You asked 'Are you talking about Sitka spruce as the previous crop on peaty soils, the situation here in Ireland?

How exactly has this crop imporved the soil?'

The action of the cultivation, fertiliser and previous crop of trees drying out the peat will generally allow the release of the nutrients to the second rotation.

Some peaty soils are inherently fertile - it is merely the anaerobic conditions over years that have prevented the organic material from breaking down, and releasing it’s nutrients. The fenlands of East England are highly fertile, due in part to the peaty nature of the soils.

This is not true in all circumstances, of course. You have probably realised from the conflicting views presented on this site by knowledgeable and articulate correspondents that there are few uniform situations, and no universal truths.

Some flushed peats, for example, have a dire nutrient level and will never support well anything planted on them, other than what is there already - mosses etc.

Upland soils in south Scotland are predominantly surface water gleys and peaty gleys; once dried out (by the previous crop) the nutrients are more readily available for the second rotation. With adequate cultivation and drainage there is no need for fertiliser. Sitka is the commercial species of choice.

Lodgepole pine (much planted in the UK) is a fascinating tree in that it can grow in such anaerobic conditions as there is a channel in the root that takes air down to the root tips. The drying out of peat (and thus soil improvement) on these sites is quite remarkable.

After the LP is removed more valuable trees can be planted and do well.

Sitka spruce doesn’t have such good soil improvement qualities, but nevertheless even on all but the worst of peats there is some benefit.

Mark


Perspectives#1

Belief systems are wonderful, no doubt! Alison Bleaney's belief system allows her to state quote "The US EPA has not always been correct and their summary and conclusions have not stood up to scientific rigourous review- we all know why, but all will eventually be revealed". It is that easy for her to dismiss the US EPA's conclusions based on 38 studies as I outlined with the review's conclusion earlier.

The same belief system allowed her to present a graph about 3 years ago which was published in the Melbourne 'Age' newsapaper which purported to show an increasing incidence in cancers in Tasmania. Professor David Hill, Director of the Cancer Council of Victoria, was sufficiently annoyed to point out in response that the graph was spurious because it was cumulative, that is, each year's incidence was added on to the previous year, to give an almost straight line increase. The data from individual years showed no increase (as did the slopes of the component years in Bleaney's graph which were the same within normal statistical variation).

At about the same time, the Menzies Institute published a survey of the incidence of cancer in Tasmania over the previous two decades (if I recall correctly). Not surprisingly, the report confirmed that there had been an apparent increase in the incidence, but concluded that this was largely due to the development of better methods of detection, with co-factors such as the aging of the Tasmanian population (exodus of young people to the mainland) with consequent increases in eg prostate cancer. Chemicals were considered (not just pesticides) but the report concluded that there was no evidence to support a contention that these played a significant role.

No doubt, Bleaney's belief would allow her to dismiss this work also.

The point is, Hayes work has been DISCREDITED.

Perspective#2

I have calculated some water volumes based on 1, 2 and 5 ug/L (microgram per litre) which would need to be consumed daily in order for an average 70 kg adult to take in their Acceptable Daily Intake (ADI) of the herbicides detected in the Tasmanian monitoring program.

The ADI is based on the No Observable Adverse Effect Level or NOAEL, usually determined using test rats but sometimes mice, and in the past dogs. The rats are fed a daily diet including the pesticide until a level is reached where there is an observable effect. This is a simple explanation which will suffice.

The NOAEL is measured in terms of mg/kg (milligram/kilogram) of bodyweight.

The ADI which is for humans is 1% or 0.01 x NOAEL. I have used the ADI values or NOAEL's from The Pesticide Manual, British Crop Protection Council.

These are the results for the DAILY volumes:

Atrazine, ADI 0.05 mg/kg = 3.5 mg for a 70 kg person.
Volume of water at 1 ug/L = 3500 L
At 2 ug/L, 1750 L and 5 ug/L 700 L

Simazine, ADI 0.005 mg/kg = 0.35 mg for 70 kg
Volume a 1 ug/L = 350 L
At 2 & 5 ug/L, 175 and 70 L

Hexazinone, ADI 0.05 mg/kg, same as for atrazine.
Note: Tracer studies using radioactively labelled hexazinone have shown that in rats, 100% is excreted as mainly metabolites within 72 hours, most within the first 24 hours. It is NOT cumulative in mammalian tissue.

Terbacil, ADI 2.5 mg/kg, 175 mg for 70 kg
Volume at 1 ug/L 175,000 L
At 2 & 5 ug/L, 87,500 and 35,000 L

Sulfometuron methyl, ADI 0.5 mg/kg = 35 mg for 70 kg
Volume at 1 ug/L, 35,000 L
At 2 & 5 ug/L, 17,500 and 7000 L

Metsulfuron methyl, ADI 0.22 mg/kg = 15.4 mg for 70 kg
Volume at 1 ug/L 15,400 L
At 2 & 5 ug/L, 7.700 and 3080 L

2,4-D, there are 2 values for the ADI of 0.01 or 0.05 mg/kg; the latter is the EEC value.
For 0.05 mg/L, volumes are the same as for atrazine, 5 times that for 0.01 mg/L

MCPA, ADI 1.33 mg/kg = 93.1 mg for 70 kg
Volume at 1 ug/L = 93,100 L
At 2 & 5 ug/L, 46,500 and 18,600 L

A normal human being of 70 kg would drink 1-2 L (??) tap water per day maximum.

Perspective #3

Anthony Amis has made some disparaging remarks about the Australian Forestry Standard.
Fact: The AFS has not only been recognized by the Australian Standards Organization, it has also been recognized by the International Standards Organization (ISO). Mr Amis is a bit too cute in saying that he is not a great fan of the FSC whilst disparaging the AFS. The AFS recognizes the APVMA, so does not seek to impose additional pesticide regulation over and above that already regulated under Commonwealth legislation.

Of course, Mr Amis' remarks are aimed at the much larger (in area certified) PEFC because it recognizes the AFS.

Mr Amis also appears to have changed his views - he made submissions to the FSC which they acknowledged, even complimented him on. I seem to recall that he was quite a fan of the FSC previously.

Perspective #4

In an earlier item on this site, Mt Amis attacked Smartwood after an audit of HVP plantations (formerly Hancock Victorian Plantations). These audits have been regular as required by the FSC, and in the past, Smartwood have examined Mr Amis' complaints (more anon). However, HVP have been justifiably annoyed in the past that correct agreed protocols were not followed by Smartwood, in that the complaints were not put to Hancock, but rather were direct. At this last audit, I believe HVP were not issued with any CAR's (Corrective Actions). An alternative explanation to Mr Amis' tirade against Smartwood is that having investigated his complaints on previous occasions and found them to be unsubstantiated, Smartwood have finally concluded that his complaints were a waste of time. However, this web-site provided an outlet for his spleen, particularly since the idealogues who contribute to this site have repeatedly attacked Smartwood.

Mr Amis has spent years running around taking photos of Hancock's operations and posting them with his particular explanation of what they mean.

He, and others paint an unremittingly bleak, black picture of the plantation industry in this country. Has he ever had anything positive to say about the industry? Of course, readers in other countries may get the impression that he has a major influence, but the truth is much more banal. He is largely ingnored, and that is what I intend to do henceforth.

To FSC-watch - keep up the 'good' work! I can't see that the site is having any impact on the FSC but it at least allows the disaffected their say.

In the meantime, I have work to do which is aimed at positive outcomes and improvements.

Barry Tomkins



Barry, another tiresome tirade from the major plantation pesticide apologist in Australia. Are you still blaming canola for all of the pesticide run off in Tasmania? Sorry that arguement is not at all convincing, so why say it in the first place? Diversionary tactic perhaps?

Is science really objective when scientists, such as yourself get paid by the very companies they are studying? ie Golden Rule No 1: Never bite the breast that feeds! The history of science is littered with the corpses of scientists too lazy, scared and comfy to jump off the 'funding gravy train' (ie tobacco lobby perhaps) and we are all the poorer for it. Whatever happened to ethics?

If you want a good belly laugh (I think you need one), before bagging me again, have a look at what Accreditation Services International said about Smartwood and Hancock in their recently released (Jan 08) report;
http://www.accreditation-services.com/res/PublicSummaries/asirep54sw2007ausps.pdf

I'd say ASI are backing up my concerns. Wouldn't you? Neither Smartwood or Hancock come up looking any good. A point your previous note completely fails to acknowledge.

I think that plantation lobbyists such as yourself need some serious work done on their PR skills and anger management. You keep kicking own goals and making your industry look really bad! I appear to have hit a raw nerve with you by mentioning AFS. Deliberate of course.

regards

aa

The sole shareholder of Accreditation Services International is the FSC. Wheels within wheels, not independent.

Barry Tomkins

Dr Tomkins, you have not answered my questions on your original statements.
"There were a large number of non-forestry detections," - how do you know this as these matters have not been fully investigated or publicised? Forestry companies do use these chemicals in Tasmania.
How can you sound-off about the pesticide monitoring in Tasmania when you did not know the facts? But how exactly do you account for all these pesticides in the waterways, results that the water-using consumers had no idea about? And how do we know that the groundwater is not polluted? And no-one should be drinking pesticides unwittingly. I would not want my children to be drinking pesticide laden water. In fact I could be charged for deliberately poisoning them if I served up pesticide laced drinks and rightly so.
Age-standardised does mean just that, and please check out www.aihw.gov.au, Australian Institute of Health and Welfare, Cancer series No 37 (2007). Prostate cancer in Australia has now overtaken colorectal cancer as the most common cancer diagnosed. Between 1993 and 2003, the increase in cancers in Australia were thyroid 106%, myeloma 44%, melanoma 41%, kidney 39% and non-Hodgkin lymphoma 36%. The Tasmanian cancer stats are alarming, Tasmania scores (compared to the rest of Australia and age-standardised) a 1st for colorectal cancer, and 2nd in prostate, lung and all cancers. Not my figures and no-one from Tasmanian public health or Menzies has been to look at our full data set. I am sure we all agree that environmental toxins can and do cause cancer.
The fallacy in your position on pesticides is borne out by your presentation. You do not allow for the most susceptible members of society ie the pregnant mothers and their unborn children and the children themselves. Their immune systems are unprotected to chemical attack, as is their hormonal and enzyme systems and their gene functioning. None of these are fully accounted for in NOAEL (these criteria are not fully quantified for in the Australian toxicity regualatory framework). Most of the pesticides listed are endocrine disruptors (EDS) (REACH - EDS in water, list atrazine and simazine as biocides, oestogenically active)and immunotoxic. You specify an average 70 kg adult, so what about children and those more genetically susceptible to thes pesticides? And what about the effects of mixtures? Pesticides and fertilisers? Water soluble and lipid soluble pesticides and those toxic 'inerts' as they like to be called? Lots of peer reviewed papers out there showing harm -eg the recent international meeting in 2007 with THE FAROES STATEMENT ... on Fetal Programming and Developmental Toxicity.
Prof Hayes work has been disregarded by some. That is all you or I can say, as there are others who firmly believe in what he has shown. The arguement that if lots of scientists say someting, then it must be right(or wrong)can no longer be upheld. How then would we have found out that the Earth was round?
So be careful in stridently shooting the messenger, I have no axe to grind other than caring for ecosystem and human health, and I see that as positive action. My motto is 'First do no harm', and that extends to the ecosystems that includes us humans, as we are all inter-conncted.
Dr Alison Bleaney

Folks may be interested in how the pesticides used in forestry (and elsewhere)are tested with regard to their toxicity; one of the myths often stated is 'the dose makes the poison'
Well- it ain't necessarily so!
A substantial body of scientific evidence published in the peer-reviewed literature challenges the central tenet of regulatory toxicology, which assumes 'the dose makes the poison.' Experimental data now conclusively show that some endocrine-disrupting contaminants can cause adverse effects at low levels that are qualitatively different from those caused by high level exposures. Regulatory toxicology has assumed that high dose experiments can be used to predict low-dose results. These findings invalidate that assumption. As a result, it is highly likely that health standards established using standard toxicological procedures are too weak.
http://www.ourstolenfuture.org/New/newstuff.htm
Dr Alison Bleaney

FYI re EPA and issues with independant research and results.
PANUPS 24-4-2008
EPA scientists complain about political pressure
Hundreds of Environmental Protection Agency scientists say they have been pressured by superiors to skew their findings, according to a survey released Wednesday by an advocacy group. The Union of Concerned Scientists said more than half of the nearly 1,600 EPA staff scientists who responded online to a detailed questionnaire reported they had experienced incidents of political interference in their work.
EPA scientists complain about political pressure <http://www.enn.com/sci-tech/article/35267>

All pesticides are poison. FSC is a complete sham and should be opposed where ever it rears its ugly head. Stop playing their game and just become an uncompromising advocate for our world's forests.

Earlier comments here, before this became a battleground for chemists, pointed out that I was in error in associating Permethrin and Alpha-Cypermethrin. Nothing in what I quoted about Permethrin is at variance with the reasons noted by FSC itself about why they banned Alpha-Cypermethrin. Further (re: mosquito nets), that a chemical is in use does not mean it is safe. Both DDT and Lindane were 'safe' once upon a time.

As regards Mark's assurances that chemicals are applied to the trees only on widely spaced occasions... not in Ireland, they're not. Further, when those chemicals are applied to trees planted on lands with public water supplies running THROUGH them, not to mention my own household drinking water supply, I feel deeply unhappy that others (ie Coillte & FSC) choose to err on the side of arrogance and risk the health of my children and myself.

It was not so long ago that Coillte were flying helicopters over the homes of rural dwellers living next to plantations *at night* (so as to avoid bad publicity) and spraying them from the air with various chemicals, Lindane included. I do not trust them. They do not care. As a state agency they have access to vast legal resources and most people simply will not try to take legal action against them as they know the outcome. For an example of how the Irish state treats those cases where they *are* actually defeated in court, consider the case - just one of many examples - of the groups protesting the government's determination to build a motorway through the remains of a medieval castle (Carrickmines). The site was rich in archaeology and contains human remains from the last battle fought on the site. Finally defeated in court, the government just called an emergency session and force d through legislation allowing the minister in question the right to make a unilateral decision on whether a site is worthy of preservation. He immediately declared Carrickmines unworthy and the motorway went ahead, even though the proposed re-routing would have cost less than the legal costs already incurred.

There are no real environmental or social rights in cases like this. What suits the moneymakers gets railroaded through. What supposed rights exist are ignored until a court upholds them. We have to fight for EVERYTHING. There is NO funding for organisations or individuals that fight for our rights.

While this sounds like whingeing, it is in fact how things are here. Ireland has gained a reputation for being all lovely and green and clean, and more recently for leading the way in economic success. Behind this veneer is a society that is rotten, where people often do not even try and fight for rights because they know they will almost certainly end up in court ten years later, and likely have to foot legal costs running to hundreds of thousands of euros. That is the environment in which we are operating.

All such issues aside, though, the fact remains that FSC decided that Alpha-Cypermethrin was not permissible without a derogation. Coillte didn't get that derogation and two years later they are still using it AND are still certified. FSC have done nothing to pervent this. ASI have done nothing to prevent this. Soil Asociation have done nothing to prevent this.

In the initial postings it was noted that a week after demanding some sort of response from FSC about how they felt justified in allowing Coillte continue like this, we still had had no response. That was a couple of months ago. We still have had NO communication from FSC whatsoever.

I do not trust organisations that act like this. I think I am justified. The obligation lies with FSC to justify THEIR actions in taking risks with MY health, not with me to prove that my concerns are justified. FSC themselves have already done that by baning Alpha-Cypermethrin.

Now they need to justify the about-turn.

This they have failed to do, and they show no sign at all of rectifying this.

I think my concerns are reasonable in this case. All I am doing is applying the cautionary principle and asking those who placed themselves in a position of authority (and therefore responsibility) to do the same.

I hope that helps clarify where I and others in Ireland are coming from on this matter.

All the best,

Stiof

The continued exposure of community's to chemical's (such as those named above)by the government constitutes Willful Neglect by the government, supposedly committed to what is a Basic Human Right, the right to a Healthy Living Environment!!!!!!!!!!!!!

The Government members namely

Brian Cowen, ...........Taoiseach
Mary Coughlan,..........Dept. Prime minister
Mary Harney,............Minister for Health
John Gormley,...........Environment,Heritage and Local gov.
Dermot Ahern,...........Justice minister
Mary Hanafin,...........Tourism,Culture&sports
Micheal Martin,.........
Eamonn ó Cuiv......Social protection?????????
Pat Carey,..............Community, Equality, Gaeltacht
Eamonn Ryan,............Communications,Energy&Natural resources
Brendan Smith,..........Agriculture, Fisheries and Food
Batt O Keeffe,..........Enterprise, Trade&innovation ?????

Now stand accused of

"Willful Neglect" by the Government of it's people!!!!!!!!!!!


Will we have to take this to EU courts or what???????????

I'm in possession of a document sent out by FSC to South Africa's Seedling Growers Association where Benomyl / Benlate is now UN-BANNED and allowed to be used again - 14 June 2010 - can you believe it - just shows the arrogance of this farcical organisation called FSC - their salaries are obviously paid by DuPont because the 'boss' (bless his heart) does not have the guts to reply to my e-mails - shameful and disgraceful - why do we put up with this nonsense - lets get militant, it's the only way!!!!

What is the context? What is the UN ban for? What has FSC allowed it to be used for?

How Accreditation Services International (FSC-ASI) allows certifiers to break FSC’s rules and issue certificates to non-compliant companies | FSC-Watch
FSC Watch: How Accreditation Services International (FSC-ASI) allows certifiers to break FSC's rules and issue certificates to non-compliant companies
In the past, FSC-Watch has been welcoming towards the work of Accreditation Services International (ASI), the FSC body which is supposed to ensure that the FSC's Principles and Criteria are upheld by the accredited certifiers. There is no doubt that ...

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