Cypermethrin Derogation application from Coillte Teoranta, the State Forestry Board

Earlier this year (2006) Coillte Teoranta, the State Forestry Board, applied to their certifiers under the FSC (Forest Stewardship Council) for a ‘derogation’ on the banning of Cypermethrin, a powerful pesticide, in their plantation forests. Below is the submission which An Taisce made to the certifiers, Woodmark Soil Association, against the derogation application.

According to the chemical product and company identification product name, Cypermethrin is ‘highly toxic to fish and aquatic organisms’.  According to the US NPTN, it is highly toxic to fish, highly toxic to bees, and has a very high toxicity to water insects.  In addition, it is deemed sufficiently toxic for the FSC to ban it from their list of permitted chemicals in sustainable forest practices.

The use of Cypermethrin in Ireland upholds unsustainable forestry practices, in particular the clearfelling of large tracts of exotic monoculture plantations.  Such environmentally harmful operational practices in monoculture plantations of exotic species should be addressed, rather than allowing continued dependence on environmentally damaging practices by allowing this derogation to be granted.   Most of the plantations where these practices occur are on peaty soils in upland environments, and have high levels of aquatic interaction with headwaters of river catchments through the extensive drainage channels required to drain water off these upland former wetland habitats.  The very wet conditions in such sites combined with the aquatic toxicity of this pesticide make its use too risky to legitimately pass as ‘sustainable’.  Despite low bio-concentration factor of cypermethrin, the high toxicity to fish is completely incompatible with this aquatic interaction with river headwaters which are often important for spawning salmon and trout.  The relatively clean waters of these upland streams and rivers are also valuable for a range of freshwater invertebrates, including several protected by Irish and European Environmental Law. 

The replanting requirement of the 1946 Irish Forestry Act, quoted by Coillte and others as one of the factors deeming continued use necessary, is widely acknowledged to lead to unsustainable forest practices, and as such is currently being reviewed.  The review almost complete, consultation has been completed, and the law is about to be changed.  If the derogation application is refused, An Taisce are confident that the review will be completed and the law updated without any further delay.  In intervening very narrow time period, the existence of this almost defunct and environmentally damaging law is not reasonable justification of the continued use of cypermethrin, nor are economic arguments against the alternative (leaving land fallow) valid when such significant environmental and ecological risks exist. 

In addition, An Taisce are very concerned that Coillte have not demonstrated significant efforts to reduce their use of toxic pesticides, as required under FSC principle 6.   The corrective action on this matter in 2000 has never been never proactively or completely addressed by Coillte, and an integrated pest management system has still not been implemented, despite the certification standing for 6 years and the issue being raised on several occasions by the certifiers.

In the light of these facts, and the clear reluctance of Coillte to fulfill sustainability criteria outlined in principle 6, An Taisce consider that under no circumstances should a derogation be granted to Coillte.