Implementation Challenges and Solutions for FSC Controlled Wood


Written by Gweneth Langdon, Supply Chain Specialist, Rainforest Alliance. 

The implementation of the  revised controlled wood system remains challenging, and it was an important topic during the Forest Stewardship Council’s (FSC) North American membership meeting in December 2016.  The Rainforest Alliance certification and assurance team participated in the meeting to discuss topics impacting our clients (certificate holders) and the evolution of the FSC certification system, with a focus on working together to improve the controlled wood system and help drive the success of FSC as one of the longest supporters of the system.  Controlled wood was of central importance during these discussions, and specific challenges and potential solutions have been identified.

Rainforest Alliance is one of the founders of FSC, with more than 25 years of certification experience, and continues to be a leading FSC certifying body (CB). Rainforest Alliance achieved accreditation to FSC-STD-20-011 V3 on 2 August 2016, enabling us to provide audits of the newest version of the controlled wood standard (FSC-STD-40-005 Version 3).  Our first mandatory witness assessment of high risk scope was conducted 20 September 2016 in Brazil, and since then we have conducted additional Controlled Wood Version 3 audits in Brazil, Canada, United States and New Zealand.  Based on our experience with past and present controlled wood evaluations the Rainforest Alliance team has identified specific challenges and solutions to the implementation of the new standard:

Stakeholder Consultation  The  six week stakeholder consultation period to occur “prior to the management activity that is subject to the consultation” is not a workable requirement with common business practice.  Companies with a large number of suppliers simply would not be able to meet this requirement.

Recommended Solution: Revise “prior to management activity that is subject of the consultation” to “prior to production or use.”  This allows companies to continue normal business practices, but ensure materials are not used until the consultation process is complete.

National Risk Assessment (NRA) One of the key components of Motion 51 (2011 General Assembly) was a call for FSC National Offices to complete controlled wood risk assessments.  However, the standard is in effect despite United States and Canada not yet publishing national risk assessments and in the case of United States, the NRA has not been drafted.

Recommended Solution:  FSC shall prioritize NRA development and approval to ensure a true strengthening of the Controlled Wood System, thus meeting the objectives of Motion 51.

Cost and burden  Demands for quick transition are causing significant cost and burden to fall on the certificate holders and the certification bodies (CBs).  In addition, rumors of another standard revision have encouraged certificate holders to delay implementation, with hopes of an extended transition timeline.

Recommended Solution:  This process and implementation demonstrates the need for FSC to improve the transition for future standards. Where standard revisions are significant and complex, CBs should have a minimum of 6 months to transition and certificate holders should have 18 months.

North America Rainforest Alliance has a high concentration of controlled wood certificates in North America (125 active certificates).  We began auditing the new standard in November 2016 and have identified regional challenges in meeting the new standard requirements, especially the requirements focused on supply chain knowledge and access to information

Recommended Solution:  National Initiatives provide regional guidelines or toolkits, approved by FSC Policy and Standards Unit that provide certificate holders with acceptable methods of meeting the controlled wood standard requirements.

This is a topline summary of key findings.  For our full proposal of recommended solutions for the successful implementation of the revised controlled wood standard click here.


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