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To: All FSC CoC + CW Certificate holders,
On August 1, 2011 FSC-Advice-40-005-18 came into effect for all organizations registered to the FSC CoC + CW standard. It was later revised in December of 2011 and is now effective as of January 15 2012. This Advice document has come into being as a result of suspect Controlled Wood Assessments including organizations sourcing logs from their own woodlands.
This ADVICE document has implications for any organization with a FSC CoC + CW certification that sources wood from the forest resources it owns or manages, or on the forest resources of an affiliated company. The latter would include the organization managing tenures or woodlots on behalf of 3rd parties.
On Friday January 27, 2012 QMI-SAI Global had a conference call with FSC International looking for clarification on the Advice document to provide more detail on the various options available to our clients and what expectations FSC had as desired outcomes. This is what we know for certain at this time;
FSC-ADVICE-40-005-18 provides 3 distinct options;
- Option #1 - getting certified against FSC-STD-30-010. In our opinion this would be the most amount of work and cost to the client to undertake. Therefore it should be considered as the last option.
- Option #2 - (clause 4.2.2 of the Advice doc.). The organization will hire a different Certification Body (CB) to undertake and complete (hopefully using the existing Risk Assessment as the base) Controlled Wood verification program for logs/wood fibre originating from its own private lands, forest tenures and those that it manages on behalf of others and for forest resources coming from affiliated companies. On the surface this appears to be the easiest route to take however depending on which CB the organization chooses to undertake the Risk Assessment, and depending on how much of the original Risk Assessment is used, time and cost could vary greatly. If sources of wood are found to be unspecified the company will need to apply the requirements of Annex 3 of the Controlled Wood standard. With this option sampling of FMUs will be permitted.
- Option #3 - (clause 4.2.3. of the Advice doc.). The organization can continue to use their current CB to undertake the Risk Assessment however Annex 3 of the Controlled Wood standard must be undertaken on all of the organizations FMUs. Sampling of FMUs is not permitted. For some clients this may be a preferred option especially if the number of FMUs is small due to being all within the same forest type or geographical area. This option also includes the requirement for the organization to undertake a stakeholder referral process. When FSC was asked what their expectations were on this it was unclear. The expectation that neighbors directly adjacent to the private land or managed land would be consulted was evident. Beyond this there was no clear direction. As noted in Option #2 above direct costs are currently unknown and will vary based on the intensity of auditing and information gathering within each of the FMUs. For clients with many FMUs spread over great distances and in different forest types this option may be less desirable.
Implementation of FSC-ADVICE-40-005-18 - This document has yet to be reviewed by the FSC CW Technical Committee, which must happen soon. While the Advice document may be revised by the Technical Committee, FSC does not see this as a sufficient rationale to delay the implementation of the ADVICE document.
Organizations are required to enter into an agreement with a new CB if choosing Option #2 by March 31, 2012. This agreement shall include an audit schedule that completes the process no later than December 31, 2012.
FSC International has confirmed that the requirement for this new ADVICE will disappear once a National Risk Assessment is in place For Canada and the United States both National Risk Assessment processes are underway and are to be completed by the end of 2012.
We are in constant contact with FSC International on this issue as well as many others that affect our clients. FSC International will be issuing a Q & A document in the next few days related to this Advice note. As information comes forward we will issue Bulletins to keep you informed of changes. In the interim should you have any questions or concerns we can be reached as follows;
Sylvain Frappier F.Eng.
QMI - SAI Global
Technical manager - Forestry sector
Tel.: 819-243-8016
Cel.:819-664-1236
sylvain.frappier@qmi-saiglobal.com
W. K. (Ken) Hall RFT, EP(EMSLA), CHSC
QMI-SAI Global
National Account Manager - Forestry Sector
Assurance Services (Americas)
PH: 250-594-5500
Cell: 250-667-8301
ken.hall@saiglobal.com
Daniel Martin, ing.f.
QMI-SAI Global
Account Manager - FSC® program
Phone: +1 506 736 6606
Mobile: +1 506 223 1100
daniel.martin@qmi-saiglobal.com
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