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Version: Sep 30 2008. FSC Controlled Wood standard FSC-STD-40-005 V2-1. Standard used in Conjunction with Chain-of-Custody Certification. TOPICS. Controlled Wood Concept. The Standard Quality System Supply Requirements Verification Program Sales & Promotion. Definition Why?
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Version: Sep 30 2008 FSC Controlled Wood standardFSC-STD-40-005 V2-1 Standard used in Conjunction withChain-of-Custody Certification
TOPICS Controlled Wood Concept The Standard • Quality System • Supply Requirements • Verification Program • Sales & Promotion • Definition • Why? • Applicability • Background 1 2 3 CW Evaluation Guidance
Controlled Wood Concept • What is Controlled Wood? Materials that: • the forest origin is known, and • avoid wood from categories defined as unacceptable for use in FSC product groups
Controlled Wood Concept Controlled Wood avoids: 1. Illegally harvested wood; 2. Wood harvested in violation of traditional and civil rights; 3. Wood harvested in forests where high conservation values are threatened by management activities; 4. Wood harvested in forests being converted to plantations or non-forest use; 5. Wood from forests in which genetically modified trees are planted.
Controlled Wood Concept Why Controlled Wood? For mixing FSC-certified and non- FSC virgin material in one product To exclude “unacceptable” materials in products sold with FSC claims To ensure the on-product FSC claim is true
CW Concept: Applicability Primary manufacturers Distributors Paper Merchants Secondary manufacturers Brokers / traders Printers CW evaluation is required when • An FSC-certified company wants to produce FSC Mixed products using FSC-certified/reclaimed material and non-certified virgin material • Non-certified sources shall be controlled according to 40-005 • A company wants to buy and/or sell FSC Controlled Wood • Company shall comply with the purchase and sales requirements according to 40-005 (part 4 & Annex 4)
Controlled Wood Concept Standards required for certificate scopes that include Controlled Wood:(for CoC operations) FSC-STD-40-004 FSC standard for Chain of Custody Certification (version 2-0) FSC-STD-40-005 Standard for Company Evaluation of FSC Controlled Wood (version 2-1) & Note: All COC companies that need to have CW in the certificate scope, SHALL also be certified against 40-004 (even if only selling FSC Controlled Wood products)
Controlled Wood Concept 40-005 V2-1 issued with slight revisions Second version approved by FSC board Final public consultation TWG agrees on version 2 of the CW standard First public consultations of draft standard Controlled Wood Technical Working Group (TWG) established for revision of the standard First version approved by FSC board in conjunction with CoC 40-004V1 History of the CW Standards
Controlled Wood Concept CW effective dates (Version 2-1) • CW requirements apply to ALL applicable companies during 2008 • For secondary manufacturers/ brokers, CBs shall evaluate compliance at latest during 2008 annual audits regardless of CoC standard (for primary manufacturers it was with 2007 annual audits) • CW is compulsory for all new, applicable assessments
FSC-STD-40-005 V2-1 Standard for Company Evaluation of FSC Controlled Wood
CW system overview Compliance Controlled Material Uncontrolled INPUT FSC FSC-CW Verification Program Check district of origin Check sales documents and certificate validity Risk Assessment CERIFICATION PROCESS Unspecified risk Low risk Field audit Non-compliance Uncontrolled FSC Mixed or FSC controlled Wood OUTPUT
FSC-STD-40-005 V2 Contents Part 2: FSC Controlled Wood Supply Requirements References Standard effective date Scope Terms and definitions Part 3: Risk Assessment and Verification Program Part 4: Sale of FSC Controlled Wood Part 1: Quality System Requirements Annex 1 Annex 2 Annex 3 Annex 4 Provisions for claims related to FSC Controlled Wood Requirements for company verification program (Field audits for non-low risk) Criteria for assessing risk (Risk Assessments) Glossary Of terms
Part 1: Quality System Requirements 4. Records Quality System Requirements 3. Training 2. Procedures 1. Policy • All relevant records shall be kept for • 5 years (4.1) • Specify and implement • training requirements for all • relevant staff; record training • Events (3.1, 3.2, 3.3) • Procedures or work instructions • covering all applicable requirements • and identifying responsible personnel • for implementing each procedure • (2.1, 2.2) • Policy commitment to avoid wood from the 5 unacceptable • categories of materials for FSC • product groups (1.1)
Part 1: Quality System Requirements 1.1 Written, publicly available policy The Policy shall: • include a clear commitment to implement best efforts to avoid trading & sourcing unacceptable materials • clearly list the 5 unacceptable categories (vague or general language is NOT acceptable) • be made publicly available • be endorsed by the most senior management level NB! The policy is a pre-condition for companies implementing their own verification program.
Part 2: Supply Requirements Company can purchase and use the following material types • FSC-certified material from certified suppliers(need to check required info on purchase documents) • Reclaimed materials verified against FSC-STD-40-007 • FSC Controlled Wood material from suppliers certified to deliver FSC Controlled Wood(need to check required info on purchase documents) • Wood which is controlled by the company itself. In such case company is implementing its own verification program according to 40-005. NB! Companies who do not use the 4th category above and only buy from the first three categories, do not need to have a verification program, including risk assessments.
Uncontrolled material (9.1) • Companies MAY also buy material which is not certified and where the origin is not known/controlled. • All such material SHALL be maintained physically separate from materials for FSC products. • Separation and tracking system of uncontrolled material shall be carefully audited if company uses uncontrolled material.
Part 2: Supply Requirements FSC-Certified from FSC Suppliers FSC-certified inputs may be used as FSC CW; CB-COC-00XXXX required FSC Controlled Wood from FSC Suppliers “FSC Controlled Wood”; CB-CW/FM-00XXXX or CB-CW-00XXXX required Controlled material from Company’s own Verification Program Non-FSC virgin inputs verified through company verification program Uncontrolled wood Keep it separate from all inputs to FSC product groups! 5. Supplier identification Categorize supplies (5.1): Wood certified by other certification systems such as PEFC or SFI cannot be accepted as FSC CW without verification.
Part 2: Supply Requirements 5.2 Maintain list of suppliers of controlled material that includes: • name and address of suppliers (5.2a) • a description of the inputs (5.2b) • species and volume of the inputs (5.2b) • relevant purchase documents (5.2c)
Part 2: Supply Requirements 7. FSC Controlled Wood from FSC-certified Suppliers • Supplydocumentation shall include (7.1): • “FSC Controlled Wood” product description • FSC Controlled Wood code (e.g. SW-CW-123456) • Inputs received, shipping documents, and invoice can be cross-referenced (7.1) • FSC-certified supplier certificate scope shall include sales of “FSC Controlled Wood” products (www.fsc-info.org)
Part 2: Supply Requirements 7. FSC Controlled Wood from FSC-certified Suppliers • FSC-certified supplier certificate scope shall include sales of “FSC Controlled Wood” products (7.2): www.fsc-info.org
Verification Program Overview NB: Verification program is not applicable when the company only purchases “FSC Controlled Wood”
Verification Program Compliance Controlled Material Uncontrolled INPUT FSC FSC-CW Verification Program Check district of origin Check sales documents and certificate validity Risk Assessment CERIFICATION PROCESS Unspecified risk Low risk Field audit Non-compliance Uncontrolled FSC Mixed or FSC controlled Wood OUTPUT
8. District of Origin 1. Determine country & district of origin (8.1a) 2. Maintain records of country & district of origin (8.1a, b) 3. Implement audit process to verify authenticity (8.1c) • For each controlled material input the company shall be able • to determine its origin to the forest district level • Supplier declaration is not satisfactory • Ensure documentation is maintained to demonstrate • district of origin (8.1b) • May include: • Legally required transport documents through supply chain • Proof of purchase documents for FMU • Specify the audit process to verify authenticity of specified documentation to confirm district of origin • Conduct the audits based on frequency defined
FSC-ADV-40-016 & Supply Requirements FSC Advice Note: Implementation of FSC Controlled Wood requirements in FSC-STD-40-005 V2-1 and FSC-STD-20-011 V1-1, 24 June 2008 F. District shall be defined at the forest level (not supplier site) H. Demonstrate to the CB that the CW supply chain is identifiable and traceable down to the district. I. Demonstrate the origin of the wood and that it has not been mixed with uncontrolled through the supply chain.
8. District of Origin • NB! The requirement to confirm district of origin makes implementation of a verification program practicallyunrealistic to meet CW for secondary manufacturers and companies further downstream: • Proof of origin is usually not possible; • Assurances needed for supply chain systems
11. Risk Assessment Conduct risk assessment per Annex 2 for each district (11.1) In case of doubt, Classify district as unspecified risk (11.3, 12.2) Allow risk assessment results to be publicly available (11.2) www.fsc-info.org Low risk (12.1) FSC Controlled Wood
11. Risk Assessment Conducting risk assessments • First – does the district already have a risk designation? • Check for FSC-approved designations • FSC National Initiatives or other FSC parties may conduct risk assessments and have approved and published by FSC IC • Check the FSC CW Resource Center: www.fsccontrolledwood.org • If not – conduct your own risk assessment • Start at country level for each category • If not low risk – go to lower level, e.g. region, county, • municipality • If district cannot be confirmed to be low risk – there are 2 options: a) classify as uncontrolled and keep separate, b) implement field auditing per annex 3 NB: Once FSC approves designations, companies are allowed 6-months to align their results
Annex 2: Risk Assessments • Risk assessment shall include sources of information used;clearrisk designation (“low risk or “unspecified risk”);clear and relevant justificationfor risk designation (why and on which basis); • Risk assessment shall cover all five categories and shall address all indicators in Annex 2 • Risk assessment shall be conducted for each district of origin (from where controlled materials are sourced)
FSC-ADV-40-016 & Risk Assessments FSC Advice Note: Implementation of FSC Controlled Wood requirements in FSC-STD-40-005 V2-1 and FSC-STD-20-011 V1-1, 24 June 2008 B. CB shall verify the adequacy of the results & shall post the risk assessment public summary at fsc-info within 7-days of issuing the CW code. C. Minimum content of the risk assessment public summary (see inserted Word document). G. New districts require CB approval of a new risk assessment and posting at fsc-info PRIOR to use of the input as controlled material.
Risk Assessment Public Summary www.fsc-info.org screen shot to show where risk assessment public summaries are posted:
13. Field Audit Verification Program • Applicable if company is sourcing from areas with “unspecified risk” and wish to use this material in FSC product groups (13.1). • Include FMUs in field audits according to Annex 3 (13.1). • Provide field audit findings including non-conformances withAnnex 3, section B to CB (13.2). • Default to FSC guidance/ interpretation (FSC IC, FSC RO, FSC NI) when it exists (13.3).
Annex 3: Field Audit Verification Program Requirements applicable to those categories not confirmed as low risk • Sources with unspecified risk require FMUs to be in a field audit verification program to provide evidence that the material has been controlled for the non-low risk categories • Identify and provide rationale for documents / other evidence to demonstrate CW • Specify and implement audits to confirm authenticity of evidence, including stakeholder consultation, staff interviews, and visits to harvesting sites
Annex 3: Field Audit Verification Program Conduct field verification audits: • Performed by qualified personnel • Audit should be conducted timely after receipt of wood • Consultation with workers shall take place without management representatives • Reports of the verification shall be kept for 5 years and available to SW CB shall conduct field verifications of company verification program
Annex 3: Field Audit Verification Program FMU field audit sampling: • Identify the total number of FMUs. • Classify FMUs into sets of similar units for audit sampling: forest type, location (district), size of operation. • Apply sampling equation to each set of FMUs. • Select the FMUs for auditing randomly. • Conduct annual FMU audits in each set: x = 0.8√y x = 0.6√y (SLIMF) E.g., district includes 136 FMUs, audit sample: x = 0.8(√136) = 0.8X11.66 = 9.33 = 10 NB! Company shall conduct field audits based on sampling BEFORE CB approval of the sources for use as controlled inputs
FSC-ADV-40-016 & Field Audits FSC Advice Note: Implementation of FSC Controlled Wood requirements in FSC-STD-40-005 V2-1 and FSC-STD-20-011 V1-1, 24 June 2008 L. Any FMU in the audit sampling that does not fulfill the requirements in Annex 3B shall be removed from the CW sources and another FMU from that set shall be randomly selected for an audit within that same year.
14. Complaints Mechanism 14.1 Procedures shall be in place in case of complaints: • Assess the evidence within 2 weeks • Field verification if evidence is considered relevant, within 2 months • Exclude the supplier if non-compliances found • Supplier may only be used for FSC CW once it demonstrates compliance • Maintain records of all complaints and actions taken
14. Complaints Mechanism • Company shall inform the FSC NI / FSC RO & CB when there is a non-compliance in areas designated as low risk (14.2) • If there are frequent non-compliances from low risk areas – the risk assessment shall be reviewed (14.3)
FSC Controlled Woodclaims and sales forFSC CW product groups
Part 4: Sale of FSC Controlled Wood 15. Supplying FSC Controlled Wood • An FSC CoC certificate is required (15.1) • Sales and shipping documents shall include: • Statement “FSC Controlled Wood” (15.3); • FSC CW code, e.g. SW-CW-123456 (15.2)
SW-CW-00XXXX Issuance • FSC CoC certificate required with CW approved in the scope; • Company may or may not have FSC-certified product groups; • Company may or may not have FSC CW product groups; • CoC tracking and handling standard requirements apply to any FSC CW product groups; • CoC and CW codes match, e.g., SW-COC-001234, SW-CW-001234; • 40-005 V2 evaluation required for assessments and upcoming audits.
Annex 4: Claims Related to FSC CW • FSC CW sales shall only be to FSC CoC certificate holders • “FSC Controlled Wood” shall not be used on-product or in promotional items • Segregation marks may include “Controlled Wood” when not reaching final points of sale; CW code is required • FSC label and CoC code shall not be used in conjunction with FSC CW
Relevant Documents • CoC-01 Supplementary Guide to Evaluation, includes Annex L, which is focused exclusively on CW 40-005 evaluation. • CoC-33 Master Report Template shall be used including the FSC-STD-40-005 checklist appendix. • CW-13 Risk Assessment Public Summary template can be provided to companies; the header table is required. • CW-14Field Audit Verification Checklist- For SW’s audits of FMUs with unspecified risk.
Risk Assessment Evaluation • Risk assessment evaluation is part of the RRA process, but may require regional expertise • RRA quality reviewers shall ensure the certificate scope correctly identifies CW in the RRA. This is critical for issuing and maintaining the CW code. • Upon approval, task manager is responsible to ensure the risk assessment public summary is sent to the certification administrator (for upload to FSC database).