Forest Stewardship Council

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1 Forest Stewardship Council FSC Controlled Wood Field Tests 2014 Summary of field tests of the draft revised FSC Controlled Wood standards in 2014 All rights reserved FSC International (FSC F000100) Controlled Wood Field Tests 2014

2 Bonn, March 2015 FSC Controlled Wood Field Tests 2014 Summary of field tests of the draft revised FSC Controlled Wood standards in 2014 Contents 1. Introduction 2. Feedback and observations from the field tests 2.1. Australia 2.2. Vietnam 2.3. Romania 3. Implementation of the outcomes of the field tests Contact for comments: Joanna Nowakowska Page 2 of 7

3 1. Introduction The purpose of this report is to provide a summary of the feedback gained through the field testing of draft revised Controlled Wood standards (2 nd drafts) carried out in 2014, as well as how that feedback has been used in the continuous revision of the standards, leading towards their finalization. Three separate field tests of Controlled Wood standards were conducted in different countries in These field tests involved the implementation and evaluation of the standard in whole or in part in different conditions. The field testing activities were performed based on the 2 nd drafts of the standards that were released for stakeholder consultation (first drafts in the case of accreditation standards). Prior to the field testing, certification bodies were invited to submit proposals for field testing, based on the Terms of Reference released to Certification Body Forum (fsccb@fsc.org). Only a small number of proposals were submitted, which determined the final locations of the field tests as Australia, Vietnam and Romania. In Australia, the standard FSC-STD was tested, along with elements of FSC-STD for verification of conformance with Controlled Wood categories at the forest level, as the revised draft of FSC-STD contained references to FSC-STD in case field verification is conducted. In Vietnam the standard FSC- STD was tested, and in Romania, both FSC-STD and FSC-STD were tested. Below, a summary of feedback gained from each of the field tests is presented, along with observations of Controlled Wood Program Manager Joanna Nowakowska, and is followed by notes on how all feedback has been used in the revision of the standards. Specific details of each of the field tests is available in the separate reports. 2. Feedback and observations from the field tests 2.1 Australia Certificate holder: Certification Body: Auditor: Other participants: Standards field-tested: WA Chip & Pulp Co. Pty Ltd, trading as WAPRES SCS Global Graeme Lea Staff of WAPRES, Dr Joanna Nowakowska (observer) FSC-STD and FSC-STD , as well as the cross-referenced elements of FSC-STD and FSC-STD The certificate holder is sourcing from South-West Western Australia (SWWA) incorporating the Jarrah Forest, Swan Coastal Plain and Warren IBRA regions. The functional scale applied is Eucalyptus plantations (mainly E. globulus) established on previously cleared land. FSC-STD The certification body reported a general lack of clarity in the standard for the certificate holder in terms of keeping/changing key concepts present in the current system (e.g., documentation of district of origin, and field verification), and the cross-referencing of other standards. Regarding the accreditation standard the certification body recommended that reporting requirements be clarified, especially where there is cross-referencing between the standards. A recommendation was made to delegate stakeholder engagement to the FSC National Office, but this has not been accepted as FSC does not take part in the certification process. The stakeholder engagement carried out by both the CB and CH was assessed as un-sufficient. Page 3 of 7

4 In addition to the above, the following is a list of issues raised by the field test: Unclear and confusing requirements for stakeholder consultation; Unclear and confusing requirements for field verification (cross referencing the standard FSC-STD , decision making when field verification is performed by the CB in unassessed risk areas); Lack of clarity and consistency in reporting requirements for CBs; Unclear sourcing possibilities in unassessed risk areas; Lack of clarity regarding methodology for verifying effectiveness of Control Measures; Lack of definition for the term precautionary principle ; Lack of clarity on internal verification of DDS by the Organization (whether internal auditing is needed, timing for addressing non-conformities), Documentation required to demonstrate the harvest location ( district of origin in the current version of the standard). FSC-STD During the field test the standard FSC-STD was only used for field verification as a Control Measure in plantation areas. For the most part, relevant FSC International Generic Indicators for the criteria proposed in the standard were used by the certification body for evaluation. A number of these was deemed irrelevant for the scope of Controlled wood and their use was therefore not supported by PSU. The issue was discussed with the auditor during the evaluation. As per the recommendations for the standard FSC-STD , the crossreferences with the standard FSC-STD were assessed as confusing and unclear Vietnam Certificate holder: Certification Body: Auditors: Other participants: Standards field-tested: Huong Son Forestry Company, Tay Son town, Huong Son District, Ha Tinh Province GFA Certification Thorsten Specht, Dr Tuan Staff of Huong Song, Dr Joanna Nowakowska (Program Manager (Controlled Wood), FSC IC), Joern Struwe (FSC IC), Ms Hue (SNV), Mr. Hong (translator) FSC-STD and FSC-STD The Organization is managing one MU which was the subject of the evaluation. Although the evaluation had the formal status of surveillance audit, all elements of the standard were tested. Page 4 of 7

5 FSC-STD The field test of the revised standard followed the surveillance audit of the current standard however all elements required for a main evaluation were covered. The implementation was thoroughly discussed in the field, including different perspectives for the future CW strategy and use of the standard in in FSC s Modular Approach Program. The certificate holder, the auditor team, and observers that participated are also involved in a project conducted by the Ecosystem Services Program of FSC IC, which allowed for thoughtful discussion on the standard. Additionally, recommendations were obtained from the auditor in written form, although not all of them have been used to revise the standard. The main issues that arose during the field test were related to a need to provide generic indicators, elaborate CoC elements and references to the FSC Policy for Association in the standard, and to address the issue of partial certification. Additional comments from the auditor on the strategic role of the standard were included, which will be considered as feedback in the CW strategy process. List of issues submitted by the lead auditor: Modify/clarify wording in several clauses (identification of personnel, references to other documents, specific activities of the Organization), Add a link between the tested standard and the policy for partial certification (the policy for partial certification was additionally studied in consideration of the suggestion, however it refers mainly to full forest management certification). The requirements for both the standard and the policy do not exclude each other and the reference to the Policy for Association serves as an additional safeguard for the implementation of the standard, irrespective of the relationship between ownership of the forest and FSC membership. It was therefore decided that including the link is not necessary for meeting policy objectives and it was not added; Terminology describing Management Unit (and not using Supply Unit), conflict timber (lack of clarity), and best available information used for HCV assessments (lack of clarity), Remarks on indicators developed by GFA (IGI were used directly, without modification and were seen to be outside the scope of CW), Lack of trademark requirements (causing confusion). 2.3 Romania Certificate holder: Certification Body: Auditors: Other participants: Standards field-tested: Ocolul Silvic Soimi RA Soil Association Woodmark Iliviu Iorgu Staff of Ocolul Silvic Soimi RA FSC-STD and FSC-STD , as well as FSC-STD and FSC-STD The Field Test of FSC-STD V3-0 was conducted for the MU Ocolul Silvic Soimi, in Bihor County, Romania. Page 5 of 7

6 The field test for FSC-STD conducted for the organization SC Carpat Sticks SRL (certificate SA-CW , issued 16 May 2011) with the supply area of Bihor County, Romania. FSC-STD The certification body actively consulted relevant stakeholders, including the Romanian Standard Development Group. From the field test, as well as from the consultation process, the following issues were raised: Cross-referencing with other documents is confusing and difficult to understand; Traceability requirements for material are unclear (e.g., how much further processing is accepted considering requirements related to CW and traceability); Minimum requirements for the qualification of experts were considered too restrictive for the organizations interested in purchasing CW. Additionally, it was stated that there was a lack of clarity on legal expertise (wide range of domains that would require separate expertise) and expertise needed for conducting field visits according to CW Category 3 requirements; Lack of clarity regarding (potential) conflicts of interest when experts are involved to: o conduct the interim risk assessment; o develop Control Measures; and o carry out field visits to assess compliance. Special concerns were raised regarding the amount of data/information required to be collected and inspected by the Organization on supply units and the supply chain. Sensitivity of data and information may cause problems with collecting/assessing the following: o evidence of compliance with legislation relating to health and safety o evidence of compliance with legislation relating to legal employment (employees data personal folders, etc.) o evidence of timely payment of royalties and harvesting fees, income taxes, etc. o information related to volumes, species, sub-suppliers, etc. (especially in the case of companies along the supply chain). FSC-STD The test was performed for group certification and did not reveal any issues or difficulties regarding the implementing the standard. The certification body verified criteria directly, without developing dedicated indicators, which confirms the need to provide generic indicators in the standard. Page 6 of 7

7 3. Implementation of the outcomes of the field tests The following amendments were made in the current drafts of the Controlled Wood standards based on field testing, which will be further discussed within the Controlled Wood Technical Committee before the final versions are produced. FSC-STD and FSC-STD Cross-references in the standards have been removed or reduced in order to clarify the requirements. This has caused an increase in the length of the standards; The requirements for stakeholder consultation have been clarified (redrafted in terms of timelines and adjusted to the particular processes (e.g., for the certification process conducted by the CB, or the consultation process conducted by the Organization); Options for sourcing from unassessed risk areas have been re-drafted to improve clarity; Sections containing requirements for the composition of the organization s due diligence system and internal verification have been redrafted to remove redundancy and to clarify the requirements; The required means of verification of the effectiveness of Control Measures have been added for some CW categories; Requirements for documentation have been redrafted for more clarity (documentation required to confirm an area is homogenous in terms of risk designations, and documentation to confirm the supply unit when field verification takes place); Conflict of interest will be additionally discussed within FSC to ensure a uniform approach is taken in Controlled Wood and other FSC standards. The above documents are being subject to further testing in 2015 ( Pilot testing the controlled wood standard: Improving workability and auditability ). FSC-STD and FSC-STD The field tests clearly demonstrated a need for generic indicators in the requirements. These have been added for all requirements to ensure they are interpreted consistently by certification bodies, which would otherwise develop their own separately. The indicators that have been added to the standard are a combination of those taken from FSC s International Generic Indicators, and suggestions from the field test; CoC elements have been added to the standard Page 7 of 7