FSC Pesticide Derogation 2015
September 25, 2015
Invitation to participate in the FSC Highly Hazardous Pesticide Derogation stakeholder
consultation process
As an important stakeholder to Bunbury Fibre Plantations Pty Ltd (Bunbury Fibre) we would
like to invite you to participate in the consultation process regarding the development of
pesticide derogation applications.
Bunbury Fibre is committed to ensuring all forest operations are conducted in a responsible
manner and is proud to be certified by the Forest Stewardship Council (FSC). As part of this
commitment to FSC forest management standards, Bunbury Fibre is developing applications
seeking permission from the FSC to use pesticides which have been classified by FSC as
highly hazardous (FSC-HH).
Our company is making applications to use the following chemicals:
1. 1080 (Sodium Fluoroacetate) – fox and rabbit baits
2. Amitrole – herbicide product
3. Alpha Cypermethrin – insecticide product
4. Cuprous oxide – fertiliser product
FSC restricts the use of these chemicals in FSC certified forests. However, where a FSC-HH
pesticide is the only tool available to the forest manager, FSC acknowledges that its
controlled use may be preferable to alternatives. In these situations, forest managers may
apply for permission (a derogation) to use the pesticide under specific conditions. Each of
the derogation applications prepared provide details on the demonstrated need for the
pesticide, controls to mitigate potential hazards, a program to identify potential alternatives
to the pesticide and the stakeholder consultation process.
In collaboration with other forest managers, Bunbury Fibre is currently developing
derogation applications and is seeking feedback from our stakeholders on these
applications. Understanding the diversity of interests our stakeholders present, a range of
consultation opportunities are available until 16 November 2015:

A survey that provides information regarding the derogation applications and
enables stakeholders to advise Bunbury Fibre of their preferred engagement
opportunities, their attitudes towards the application, and provide comment. The
survey can be completed online here, or a hardcopy can be requested from Mr
Steven Pickering on (08) 9781 4500 or at [email protected]
We apologise if you have received this letter from another forest manager. The
online survey is a common resource so you only need to complete it once and your
comments will be considered by all of the companies who are part of this
application.

Meet with Bunbury Fibre representatives to discuss the derogation applications and
provide feedback. Please contact Mr steve Pickering at Bunbury Fibre to arrange a
meeting on (08) 9781 4500 or at [email protected]

Stakeholders can provide comment on the derogation application using template
available on the website and emailing to Bunbury Fibre representative
[email protected] or to the National Coordinator Kevin O’Grady at
[email protected]. Alternatively comment can be posted directly to the
derogation National Coordinator Kevin O’Grady at PO Box 41 Eltham VIC 3095.

If sufficient interest is identified in the survey, public and/or online forums will be
held with interested stakeholders at a time and place to be determined. Those
stakeholders who advise they would like this opportunity will be contacted regarding
these opportunities.
Further detail regarding the consultation opportunities is presented in the Stakeholder
Engagement Plan and Summary available on the FSC Australia website. Stakeholders are
encouraged to include comments on the overall support for the derogation requests, as well
as include comments on the additional controls and programs to identify alternatives.
Please note that this consultation is with regards to the FSC-HH pesticides being sought for
derogation only, comments regarding non FSC-HH pesticides or broader forest operations
are not able to be duly considered in this consultation process and stakeholders should
direct these comments to FSC International.
Stakeholder comments will be used by:
1. Bunbury Fibre to inform their chemical use plans and derogation application
2. Pesticide Derogation Advisory Group to ensure an accurate understanding of the
perspectives of stakeholders and to develop draft controls, and
3. FSC International, in consideration of the derogation application.
Please note this is a 52-day comment period, all comments are due by 16 November,
2015.
If you have any questions regarding the derogation applications please do not hesitate to
contact Mr Steve Pickering on (08) 9781 4500 or at [email protected].