# Application for Pesticide Derogation



## Hamilton Reef (Jan 20, 2000)

Good afternoon,

As part of the Michigan Department of Natural Resources' forest certification activities, we are in the process of requesting a chemical derogation for pesticides used on State Forests from the Forest Stewardship Council. A part of this process is providing the opportunity for comments from stakeholders. Information on the derogation process and DNR application is on the DNR website: www.michigan.gov/dnr. 

The letter below provides addition information.

We would appreciate your comments.

Regards,

Cara A. Boucher, Manager
Forest Resource Management Section
Forest, Mineral, and Fire Management Division
Michigan Department of Natural Resources

Dear Stakeholder:

SUBJECT: Opportunity to Comment on Department of Natural Resources Application for Pesticide Derogation (Temporary Exemption) to the Forest Stewardship Council International

The 3.9 million acre Michigan State Forest System is certified by two forest certification systems, the Sustainable Forestry Initiative (SFI) and the Forest Stewardship Council (FSC). The FSC closely scrutinizes the use of pesticide products on certified land, and maintains a list of chemicals that are prohibited from use unless special temporary permission is requested from and granted by the FSC (this is referred to as derogation) to use them. 

The Department of Natural Resources (DNR) is requesting derogation to utilize five pesticides currently on the FSC list. Consistent with FSC policy requirements, we are seeking comments from interested parties on our request for pesticide derogation. 

The formal derogation requests, which include detailed information about proposed use of the chemical, are posted on the DNR Forest Certification web site at: http://www.michigan.gov/dnr/0,1607,7-153-30301_33360---,00.html. The following five chemicals are in our derogation request to the FSC:

1. Hexazinone (Velpar) - one of the most widely used forestry herbicides in the United States. It has been in use for more than 30 years to control brush and weeds during the establishment of new stands of trees. 
2. 2,4-D, 2-ethylhexyl ester - used for habitat restoration and control of invasive exotic plants. It provides a management tool for some difficult to control species.
3. 2-(2,4-DP), dma salt (= dichlorprop, dma salt) - used for habitat restoration and control of invasive exotic plants. It provides a management tool for some difficult to control species.
4. Dicamba, dma salt - used for habitat restoration and control of invasive exotic plants. It provides a management tool for some difficult to control species.
5. Diflybenzuron (Dimlin) - used on a limited scale to protect young red pine plantings from Red-headed pine sawfly. 

All five of these pesticides have been approved for use by the Environmental Protection Agency, and if used, would be applied according to label guidelines and only by licensed applicators. The use of these chemicals will be minimized, applied on a limited number or acres, and only used when necessary as part of an integrated pest management program to achieve defined management objectives. When use of chemical pesticides is necessary, we select the least toxic, least environmentally persistent, narrowest spectrum products that provide cost effective control and are labeled for the target species.

The DNR invites your comments on use of these pesticides. Please submit your comments by September 16, 2007 to Dennis Nezich, Forest Certification Specialist at Marquette Operations Service Center, 1990 US 41 South, Marquette, MI 49855 or by email at [email protected]. We will compile all comments, include them in the derogation requests, and forward them to the FSC. If you have questions, please feel free to contact Mr. Nezich at 906-228-5245.

Sincerely,

Lynne Boyd, Chief
Forest, Mineral, and Fire Management
517-373-1246


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## Hamilton Reef (Jan 20, 2000)

Defining DNR's derogation

Several readers e-mailed to ask about an item on the Department of Natural Resources Web site that asks for public comment on the "derogation" of five chemicals for use in forestry.

Derogation simply means deviating from a standard and using something in a way that it is not used normally or hasn't been used before.

The chemicals to be derogated are hexazinone, Dimilin, dicamba, 2,4-D dimethylamine salt and 2,4-D 2-ethylexter ester. Members of the public can comment by writing Nezich at the DNR, Marquette Operation Center, 1990 U.S. 41 South, Marquette, MI 49855, or by sending e-mail to him at [email protected].

http://www.freep.com/apps/pbcs.dll/article?AID=/20070906/SPORTS10/709060405/1058


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## Hamilton Reef (Jan 20, 2000)

Emailed to HR:

Folks,

An Enviro-mich subscriber asked for some additional information about why Department of Natural Resources (DNR) is going through the Forest Stewardship Council (FSC) derogation process and asked that it be sent to the listserv.

The action that prompted the DNR move toward derogation on the five chemicals is a recent FSC reevaluation and subsequent change in the FSC pesticide policy. At the time of DNR certification, FSC prohibited use of World Health Organization (WHO) Type 1A and 1B pesticides; chlorinated hydrocarbon pesticides; pesticides that are persistent, toxic or whose derivatives remain biologically active and accumulate in the food chain beyond their intended use; as well as any pesticides banned by international agreement. Participants were required to evaluate many chemicals (those other than WHO Type 1A and 1B, chlorinated hydrocarbons, or banned by international agreement) to determine whether they exceeded certain thresholds (toxicity, persistence, solubility, etc) for the locations and conditions where they were to be applied. This process was difficult and confusing for participants, especially if they did not have qualified staff available to make such an analysis. 

The FSC reevaluated its pesticide policy in 2006, and in May, 2007 a new policy was approved and published. The new policy and procedure included a list of FSC prohibited chemicals. These chemicals can not be used by FSC certified bodies unless derogation is sought and granted. Although the new FSC policy provides a simplified international procedure for chemical use for certified organizations, it also resulted in some EPA labeled chemicals appearing on the FSC list of prohibited chemicals. 

The DNR is seeking consent from FSC to use five pesticides on the FSC list for the purposes written into the derogation application. All five pesticides are approved for use by the Environmental Protection Agency, and if used would be applied according to label guidelines and only by licensed applicators. The use of these chemicals will be minimized, applied only on a limited number of acres, and only used when necessary as part of an integrated pest management program to achieve defined objectives. When use of chemical pesticides is necessary, we select the least toxic, least environmentally persistent, narrowest spectrum products that provide cost effective control and are labeled for the target species. 

The tactical purpose for requesting derogations relates to maintaining a range of options for treatment due to the increasing occurrence of some invasive species, the resistance some species have to FSC approved pesticides, and the importance of timing (advance approval will avoid delay in treatments. 

Information about the FSC process and DNR's application can be found on the DNR website: www.michigan.gov/dnr 

The deadline for comments is listed on the website is September 16, 2007. Mr. Nezich will be compiling the DNR application next week and anticipates being able to include comments received by Thursday, September 20, 2007 in the application. 

Comments may be e-mailed to Dennis Nezich at [email protected] 

Thank you.

Cara A. Boucher, Manager
Forest Resource Management Section
Forest, Mineral & Fire Management Division
Michigan Department of Natural Resources

Michigan Registered Forester #543
SAF Certified Forester #3388
517.335.3354 voice
517.373.2443 fax


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