In the past, FSC-Watch has been welcoming towards the work of Accreditation Services International (ASI), the FSC body which is supposed to ensure that the FSC’s Principles and Criteria are upheld by the accredited certifiers. There is no doubt that monitoring of the certifiers has improved in recent years. But, for every audit of the certifiers carried out by ASI, there has been a failure to take meaningful action – even in cases where certifiers have been found by ASI to have issued certificates to blatantly non-compliant forest managers.

In recent weeks, FSC-Watch has had to report on ASI’s ‘toothless’ monitoring of the certifiers in the case of certificates in Uganda, Spain and the USA. In this posting, we report on how ASI has allowed the continuation of the certification of yet another major ‘forest manager’, even though ASI itself recognises that the company is not compliant with FSC’s Principles and Criteria

FSC-Watch has reported several times on the problems with FSC in Ireland and particularly the certification of the Irish state forestry company Coillte, which has around 450,000 hectares of plantations, and is the largest of all landowners in the country. In 2007, after nearly eight years of complaints about the certification of Coillte, ASI undertook an assessment of the certificate, which had been issued by Soil Association Woodmark (SAW).

In ASI’s report on the WoodMark certification of Coillte (available for download below), a total of 2 Major Corrective Action Requests, 10 Minor CARs and 7 ‘Observations’ are raised against SAW.

Amongst the most serious of these, WoodMark is found to have ‘closed out’ its own Corrective Actions against Coillte without good documented reasons for doing so. ASI found that “there was no evidence” that SAW had properly re-assessed all ‘non-conformities’ that had been identified in their certification audits – in other words, the certifier had known that Coillte was non-compliant but had allowed these possible non-compliances to continue. SAW had ‘kept open’ non-compliances after excessively long periods of time even though the FSC’s rules stipulate that persistent non-compliances should be upgraded to Major CARs and then the certificate suspended: the ASI report noted that, as a result “non-compliance with relevant FSC Criterion is likely to be ongoing for a few years. It should be noted that the same issue was raised in the previous certification period”.

ASI rightly observed that SAW’s assessment of Coillte had abused the flexibility of the FSC system which allows temporary problems in forest or plantation management standards to be resolved. It reported that the observed non-conformities in the Coillte certification “n not be considered as unusual and unsystematic and that the impacts of these unconformities are not limited in their temporal and spatial scale”. In other words, the problems which had been ‘overlooked’ by SAW were a result of systematic non-compliance of the company to which the certificate had been issued. ASI rightly reported that “the [WoodMark] SA auditors apparently have not followed SA procedures in this certification project” and that “SA accredited procedures have not been appropriately implemented and did not ensure that the certificate holder complies with all the relevant FSC standard requirements”.

Another problem identified by ASI was that WoodMark had issued the certificate not on the basis of actual performance of Coillte at the time of assessment, but on the basis of ‘improvements’ which are deemed to have happened some time later. For example, ASI found that Coillte “in many cases operated large scale clear felling”. SAW had considered suspending the certificate because of this, but instead kept it open until Coillte later provided draft new ‘evidence’ putatively showing that the company complied with FSC’s requirements. ASI concluded that Coillte “could not demonstrate compliance at the time of the audit” and that SAW “had not ensured compliance with the relevant standard requirements”. The implication in this case is also that SAW should have suspended the certificate.

In fact, however, ASI also castigated SAW for giving undue credit to Coillte for simply adopting new policies rather than changing actual forestry practices. The ASI report concluded that the“ASI team considers that in some cases the SA decision [to maintain the certificate] was based on an evaluation of the certificate holder procedures instead of the performance compliance in line with the corrective actions and/or standard requirements”. This observation confirms what Irish environmental and social stakeholders have been warning both SAW and ASI for a number of years: that whilst Coillte are adept at producing ‘paper policies’, very little in terms of forest management has actually changed on the ground. ASI rightly considered that this flaw in SAW’s approach warranted a Major Corrective Action Request against SAW.

ASI’s analysis of the problems with the WoodMark certification of Coillte is thorough, and mostly creditable. However, it also raises serious questions about the ability, and possibly the willingness, of FSC-ASI to respond appropriately in such cases and to exercise meaningful sanctions against certifiers where the analysis shows that there have been major failures on the part of the certifier. As in other ASI reports, the ‘sanctions’ against WoodMark appear to have been substantially downgraded.

For example, FSC Criterion 2.3 on land tenure states that “Disputes of substantial magnitude involving a significant number of interests will normally disqualify an operation from being certified.” One of the problems with the Coillte certificate identified by ASI was that “the certified operation’s land tenure dispute procedure is not considered appropriate by the ASI audit team, because the procedure allows Coillte to continue its activities under certain circumstances even when disputes are not resolved.” In fact, WoodMark was well aware of numerous ongoing tenure disputes, as these had repeatedly been brought to its attention by various local stakeholders. So WoodMark had clearly issued a certificate to a company that contravened one of the critical of FSC’s Criteria, and ASI had recognised this. But instead of insisting on immediate suspension of the certificate – and probably suspending WoodMark too – ASI merely issued a Minor CAR against WoodMark.

ASI also found during its audit that there was “widespread practice of premature clearfelling, Coillte is also replanting forests (sic) on raised bogs…[this] is not consistent with Principle 5 relating to efficient use of the forest and economic viability of activities”. Despite this apparent certified non-compliance at the Principle level, ASI merely issued an ‘Observation’ on this point, placing WoodMark under no obligation to reassess this issue in future. Even more seriously, ASI completely missed the point that blanket afforestation of raised peatland bogs is causing serious damage to Ireland’s biodiversity; WoodMark’s certification of this practice was therefore also in contravention of FSC Principle 9. As the Irish Peatland Conservation Council (IPCC), which campaigns for the protection of the country’s biodiverse boglands, has pointed out, “In Ireland, the ecological and regional diversity of peatlands both in terms of species and of habitats is high. At the level of individual sites the diversity is exceptional”.

Other areas where SAW’s negligence was criticised – but barely sanctioned – by ASI were in allowing Coillte to operate with inadequate mechanisms for dealing with stakeholder complaints and, bizarrely, for completely excluding Coillte’s nursery operations from the certification.

With just one exception, every one of the critical ‘stakeholder comments’ given to ASI were found to be justified – including over Coillte’s failure to plant an appropriate proportion of native broadleaves, lack of appropriate landscape planning, and failure to identify High Conservation Value Forest. However, ASI seems to have overlooked the fact that all of these concerns had consistently been brought to the attention of SAW during the preceding years, including in formal ‘consultations’: WoodMark had knowingly maintained the certificate nonetheless. ASI should have concluded from this that SAW’s ‘consultation procedures’ are, in fact, a sham. This alone should be sufficient to see the certifier suspended or ejected from the FSC.

(The one stakeholder concern that ASI did not substantiate was in relation to an unauthorised pesticide derogation, but as FSC-Watch has already reported, ASI got it’s analysis here wrong: the stakeholder concerns about this, too, were fully justified.)

It is a shocking indictment of the FSC system that, despite all the serious failures, all that ASI could do was to issue ‘Corrective Action Requests’ against Soil Association. As at March 2008 – seven months after ASI’s audit and nearly two years since SAW re-awarded its flawed certificate to Coillte – there is no evidence that Woodmark has dealt with the deficiencies of its certificate, or that the underlying non-compliances in Coillte’s operations have been rectified; the certificate remains valid, and, despite its woefully deficient performance, Soil Association WoodMark remains accredited to the FSC.

FSC-Watch believes that, if ever there was a case for immediate de-accreditation of the certifier, and immediate cancellation of the certificate, then this was it. Once again, ASI has shown that, whilst it is increasingly able to detect poor certifier behaviour, it remains a largely toothless watchdog over FSC’s credibility.

The ASi report on SAW’s certification of Coillte can be downloaded here: AsiAuditSawCoillte2007.pdf