FSC’s Chain of Custody system: “potential for misleading, false or fraudulent claims is very real”

FSC-Watch has received the following posting from a correspondent with “fifteen years’ experience as an auditor of FSC systems”. Like many people who have worked within the FSC system, and know first-hand the kinds of problems pointed out repeatedly on FSC-Watch, the contributor wishes to make their views known anonymously.

The contribution starts by pointing out, rightly, that the Chain of Custody system is something to which FSC-Watch has paid little attention over the last four years. The problem is simply that the CoC system is so opaque that there is almost no information available to analyse or on which to comment. The absence of the kinds of Public Summary reports which are available for Forest Management certifications means that it is not possible for a member of the public to scrutinise the validity of certificates.

Because the Chain of Custody system links forest producers with the end consumer, the entire FSC system in fact rests on an act of faith. The contribution below suggest that this faith might not be justified. Whilst there are genuine issues about commercial confidentiality, there is a critical need for greater transparency within the CoC system – as well as the kinds of specific changes which are suggested below.

FSC-Watch would particularly welcome further contributions on this subject, especially from those who have been involved in the auditing of chains of custody.

Since FSC Watch was launched in November 2006 only two comments have been tagged Chain of Custody. Up to July this year twenty one thousand FSC CoC certificates have been issued. The potential for misleading, false or fraudulent claims is very real. For the labeling system to be trusted, the consumer should expect certification bodies and their auditors to have high levels of competence and integrity.

But can the public be confident FSC standards are audited by people that meet the FSC’s own requirements? My concern, which is based on fifteen years’ experience as an auditor of FSC systems is that many auditors do not have specialist timber/paper industry knowledge. The FSC standard is performance, not systems based. Industry specific knowledge is more important than auditing skills yet some certification bodies openly advertise auditing jobs without mentioning industry specific experience as a requirement.

The General Requirements for FSC Accredited Certification Bodies prepared by the FSC Policy and Standards Unit in August 2009 defines clearly the minimum qualifications for chain of custody and controlled wood auditors. A CoC evaluation team should include “at least one member who has knowledge of the critical character of the operational processes under consideration”. For controlled wood evaluations – but only at the Forest Management Unit (FMU) level – “at least one team member should have experience and qualifications in relation to the controlled wood categories being evaluated”.

This raises some important questions. Firstly, what does “knowledge” mean? Is it one, two or ten years’ direct experience in a specific industry setting? Secondly, how does the FSC assess and monitor certification bodies to ensure auditors have the necessary specialist knowledge?

Experience of timber/paper manufacturing processes is indispensable to the chain of custody auditor and in my experience the ability to properly identify timber species should be mandatory. An auditor must be able to match timber to sales and delivery documents. A guess would not be good enough and without specialist knowledge the auditor can only guess.

In the forest and at primary processing points identification should be simpler. A standing tree will have distinguishing features such as bark and leaves. A log delivered to a mill will in most cases still have the bark on. Species identification invariably becomes more difficult further down the chain as distinguishing features are lost. This problem is further complicated by the mixing of different timbers which again is more likely to happen further along the supply chain. If the auditor cannot identify different timber species with absolute certainty how can an evaluation take place? Yet this is what is happening. In some cases FSC evaluations are being carried out by auditors that do not have the necessary specialist background and experience. In addition, if ASI assessors also do not have knowledge of the processes, including species identification how can the performance of certification body auditors be properly assessed?

Timber species identification is a very specialised skill and it is highly unlikely a run of the mill ISO systems auditor or an ASI assessor would have these skills.

What should be done? The FSC needs to explain how it ensures auditors meet the criteria for knowledge of the critical character of the operational processes. If an evaluation requires an auditor with knowledge of a particular industry/process or timber species, how does the FSC ensure a qualified auditor is always allocated to that evaluation? Given the strong possibility that unqualified auditors have been used for many years, the validity of an unknown number of certificates must be in doubt.

In order to restore confidence I believe the FSC should immediately:

  • check the experience and qualifications of all registered auditors and ensure certification bodies suspend those that don’t meet the FSC criteria;
  • identify evaluations where specialist knowledge was needed and provide documentary evidence the audit team included at least one member with the relevant specialist knowledge. This should apply to main evaluations and surveillances, specialist knowledge is required at both. If it is found the audit team did not have the relevant specialist knowledge then the certificate is in effect invalid. In these cases the certificate should be suspended and a new evaluation carried out by a team that meets the FSC requirements for CoC audit teams;
  • evaluation reports should record the auditor’s qualifications to carry out the evaluation. For audits where knowledge of a specific process is needed, it must be clear the auditor’s qualifications and industry related experience meet FSC requirements;
  • FSC should ask Certification Bodies to provide a list of CoC auditors with their qualifications and industry related experience and this should be available to the public. If, for example a CB does not have an auditor with experience of tropical timber identification then that CB cannot carry out evaluations for clients that trade or manufacture tropical timbers;
  • certification bodies should develop systems and procedures to identify which evaluations require specialist knowledge and must be able to demonstrate audit teams include at least one person with this knowledge;
  • the experience and qualifications criteria should apply equally to ASI auditing staff. ASI staff without the necessary qualifications and experience should not be allowed to monitor and evaluate certification body audits.

Until the FSC can show that every CoC audit has been carried out by a team or auditor with the relevant experience and qualifications, the validity of many FSC CoC certificates must surely be in serious doubt.


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