synopsis of the 2nd public consultation on the standard

Synopsis of the 2nd public

consultation on the standard

FSC-STD-40-005 V3-0

Requirements for sourcing FSC

Controlled Wood

SYNOPSIS OF THE 2ND PUBLIC CONSULTATION ON THE STANDARD FSC-STD-40-005 V3-0 REQUIREMENTS FOR SOURCING FSC CONTROLLED WOODINSERT TITLE

2015 – 2 of 13 –

Synopsis of the 2nd public consultation on the standard FSC-STD-40-005 V3-0

Requirements for sourcing FSC® Controlled Wood

Bonn, September 2015

Consultation period

English version: 30 April – 30 June 2014

Spanish version: 20 June – 20 August 2014

This document has been prepared in accordance with FSC-PRO-01-001 (V 3-0)1, and contains

an analysis of the range of Stakeholder groups who have submitted comments, as well as a

summary of the issues raised (in relation to the requirements) and a general response to the

comments and an indication as to how the issues raised were addressed in finalizing the

standard.

Contents:

1. Purpose of the report

2. Range of stakeholder consultation participants

3. Analysis of comments and summary of follow up actions

Contact for comments: Joanna Nowakowska ([email protected])

1 Please consult clause 5.12 of FSC-PRO-01-001 V 3-0.

mailto:[email protected]


2015 – 3 of 13 –

Purpose of the report

The purpose of this report is to provide a summary of the outcomes of the second round of

stakeholder consultation on the revised draft of FSC-40-005 V3-0 Requirements for sourcing

FSC Controlled Wood.

It provides a basic analysis of the range of stakeholder groups that have commented on the

draft standard, a summary of the main issues raised by stakeholders that submitted feedback

to the process, and an overview of how those issues have been addressed in the redrafting

and finalization of the standard.

The factors influencing the final version of the standard were:

Stakeholder feedback received during the stakeholder consultation

Outcomes of the field testing of this standard

Work by the Controlled Wood Technical Committee after the consultation and field

tests

Outcomes from the approval of the FSC Procedures for the development of National

Risk Assessments

Decisions made by the Board of Directors

Range of stakeholder consultation participants

57 forms containing comments on the stander were received on behalf of 69 stakeholders

(individuals or organizations). 39 (57%) of these stakeholders were FSC International

members. These 40 members were from the following FSC membership chambers and sub

chambers:

- Economic North: 13

- Economic South: 12

- Environmental North: 11

- Social South: 3

Four of the member of Economic North were FSC-accredited certification bodies. Of the non-

members, 4 were FSC Network Partners, and the rest were comprised by certificate holders or

industry associations (19), or Environmental organizations (7).

7 of the 69 stakeholders submitted comments in Spanish. The rest of the comments were

submitted in English. All Spanish comments came from members of South sub chambers. Four

were Economic chamber members, and three were Social chamber members.

Analysis of comments and summary of follow up actions

Scope of the standard regarding forests the organization owns or manages

A number of certificate holders, and one FSC Network Partner, provided comments arguing

that companies should be allowed to include forests they own or manage within the scope of

certification of this standard, and not have to undergo certification using the Controlled Wood

forest management standard (FSC-STD-30-010). Some of these comments stated that this

should at least be the case for areas of low risk, while others made no distinction.


2015 – 4 of 13 –

Changes have not been made to the final draft standard regarding the scope

Effective and validity dates

A number of stakeholders, primarily Economic (certificate holders and certification bodies) and

FSC Network Partners commented that the proposed effective dates were not realistic due to

the need for NRA development and approval. Due to a lack of NRAs, more time would be

needed for the development of Interim Risk Assessments by certificate holders, and for

updating the auditing systems of certification bodies. There was also criticism of the period of

time between the publication and effective dates (contained in FSC-PRO-01-001).

The effective and validity dates that were proposed in the second draft of the revised standard

have since changed considerably, due to time taken for extra field testing. It is currently planned

that the standard will be published by 1 January 2016, with an effective date of 1 July 2017.

This extends the period that all stakeholders have to become familiar with the revised

requirements and to update systems or operations accordingly.

Terms and definitions in the standard

Among comments received on the terms and definitions contained in the draft, were requests

for definitions of “Precautionary principle”, “Stakeholder” and “Intact forest landscapes”. In the

final draft of the standard, these terms have not been included, as these definitions are provided

in the documents referenced in the section providing definitions.

Definitions of "low risk area", "specified risk area", and "unassessed risk area" were described

as in need of a definition of “area” in order to be understood, and the definition of "supply unit"

was criticized as convoluted and hard to understand. No definition was added for “area” – it is

considered to be easily understood as a geographical area, however an explanatory figure has

been included with the standard to visually demonstrate how the terms and definitions relate to

each other. The definition of "supply unit" was changed to better reflect the scope of the CW.

A request to ensure that the definition of "Illegally harvested wood" is in line with EUTR, was

received, due to a perception that the FSC definition was perceived to be narrower. In practice,

alignment is ensured, as the definition of legality is consistent throughout the FSC system, and

uses a number of indicators that cover a broad spectrum of laws relevant to the forest sector,

that align with the EUTR. It was also noted in a comment that there is a note in the definition

clarifying that low risk is synonymous with negligible risk under the EUTR, but no similar note

about terminology for the similar legality legislation in the US and Australia. Additionally, there

was a question about why FSC does not use the term “negligible risk” instead of low risk. There

is no note about alignment with other illegal logging legislation because the note only refers to

the EUTR context. The term low risk maintains consistency with the terminology used since the

Controlled Wood standard was first introduced.

Questions were received about the definition of controlled material vs assessed material

between the CW and CoC standards. Definitions of material, controlled material and FSC

Controlled Wood have been revised in tandem with the revision of the CoC standard, to ensure

they are clear, and are consistent with use of the terms throughout the FSC system.


2015 – 5 of 13 –

Conversion

Criticism was received on the definition of forest conversion, as it used the term “semi-natural

forest”, which is not defined. It was also recommended (from the Economic chamber) that the

criteria for the threshold in the definition of “Significant conversion” be 10% or 10,000 hectares,

to allow for organizations that manage millions of hectares of forest. The use of percentages

rather than absolute thresholds was recommended, so that small and large organizations are

treated similarly (following that many small organizations could result in more conversion than

one large organization). There was also a suggestion to expand the definition to define and

“ecoregionally permissible threshold for all lands”. Opinion from the Environment chamber was

that the definition of conversion is too broad, and should rather be based on the thresholds

used in the indicator for conversion in FSC-PRO-60-002a (0.02% or 5000ha, whichever is less).

A comment from the Economic chamber stated that these thresholds may result in an automatic

designation of specified risk where there is a lack of fine-scale data – determining a small

threshold on a five-year basis, even with excellent data in the US would be extremely difficult.

In the revised standard, the definition for forest conversion has been updated to that which was

approved in FSC-PRO-60-002a. The use of and reference to “significant conversion” has been

removed from the standard, because field verification requirements that referred to significant

conversion were removed from the standard. The thresholds for significant conversions are still

relevant because they are used in the risk assessment of conversion (by FSC risk assessments

and the “Extended risk assessment”), which is used by the organization to implement the

standard.

Documentation and records

Requirements for documentation and records were either endorsed by stakeholders, or

minor/specific issues were raised. Some comments were received on the redundancy of

requirements for documentation within the standard, either through a double up with other

requirements in the standard or with the FSC Chain of Custody standard. Such comments were

taken into account when producing the final draft to ensure that requirements are clear and

consistent, while avoiding redundancy.

The majority of comments were received on a clause related to including the claim ‘FSC

Controlled Wood’ on invoices and shipping documents. Such a clause/requirements are no

longer included in the standard, as they are covered by both the CoC standard and the standard

for the use of FSC trademarks. A section on sales (which focusses on information on sales and

delivery documentation) has been tentatively included, but will be removed if the standard is

made effective at the same time as the CoC standard, as is planned.

Reporting by the Organization to the certification body

Environmental stakeholders were strongly in favor of requirements that increase transparency

of the certification process and stated that requirements for public summaries are critical for

this. Some stated that the requirements presented should be a bare minimum of what is

required, others deemed the requirements for the summaries as inadequate. Social

stakeholders supported this section, stating the need for public summaries. Economic

stakeholders did not object to the requirements, but were against the release of sensitive or

confidential business information.


2015 – 6 of 13 –

A number of stakeholders stated that there was either a need for clarity on the “publicly

available certification report” or that the report should not be referred to in this standard, as it is

the responsibility of the Certification Body and is therefore more relevant only to the

accreditation standard, while the information required to be given to the Certification Body

should be stated in FSC-STD-40-005.

Similar requirements remain in the latest draft version of the standard – minimal changes have

been made. The changes that have been made were mainly to align the section to changes

made elsewhere in the standard, as well as address stakeholder comments on specific issues.

It is clarified that the Organization must produce a report, and that this shall be submitted to the

certification body (to later be included in the certification report). The requirements are clear in

terms of the information that shall be submitted to the certification body, and an explanatory

note is included that states this information will be included in the public certification report.

Complaints mechanism

Environmental and Social stakeholders endorsed this section, and Environmental members

described it as a significant improvement compared to the previous draft of the standard. Some

Economic stakeholders complained that the requirements were too bureaucratic and needed

simplification. A request was also made for a definition of a “substantial” complaint, to ensure

consistency in application, suggesting “validity” as a criterion. In the final draft requirements,

substantial relates to the level of evidence provided by the complainant and an assessment of

this against the risk of material from unacceptable sources entering supply chain.

FSC Network Partners and Economic stakeholders noted that the complaints mechanism

should refer to non-certified “supplies” or “supply areas” rather than the proposed “non-certified

suppliers” as it is the actual material that is the issue, not necessarily the organizations trading

it, and requirements were changed to reflect this. Some comments were received from various

stakeholders on requirements related to time periods with respect to processing or dealing with

complaints, verification of complaints, and the treatment of supplies that are subject to

complaints. Economic stakeholders saw the two-week period, within which the Organization

shall respond to the complainant informing them of the complaints procedure, and forward

substantial complaints to the certification body, and relevant FSC National Office, as too short.

The two week time period has remained in the final draft of the standard because it was agreed

by the Controlled Wood Technical Committee.

On a requirement for a precautionary approach to be employed regarding the continued

sourcing of material that is subject to a complaint, a certificate holder expressed concern that

stakeholders could intentionally stall a process by making repeated complaints. An

Environmental chamber member stated that this requirements would be difficult and probably

not auditable. An Environmental chamber member expressed dissatisfaction with a

requirement that stated that the Organization shall implement a verification process for a

substantial complaint within two months of its receipt, arguing that the time must be much

shorter, and that requirements are needed to restrict how long the verification process can take.

Requirements were not changed based on these comments, as the requirements reflect

agreements made by the Controlled Wood Technical Committee.


2015 – 7 of 13 –

Establishment and implementation of a Due Diligence System

The section containing requirements for the Establishment and implementation of a Due

Diligence System were endorsed by respondents from the Environmental chamber and the

Social chamber, as well as the Network Partner that provided comments on it. Comments from

other stakeholders did not state support or opposition, but mainly focused on small, technical

issues.

Two comments were received on whether an organization’s DDS may be developed by the

certification body that audits its conformity with the standard. An Environmental chamber

member supported this possibility, while a certificate holder was against it, stating it to be a

clear conflict of interest. In the revised requirements, any external party can develop the

organization’s DDS, except the certification body that audits the organization’s conformity with

the standard.

A comment was received that the DDS should not just be reviewed annually, but also when

any changes occur. This was included in the final draft of the standard – it is now required that

the DDS shall be reviewed whenever changes in supplies occur that affect the relevance,

effectiveness or adequacy of the DDS.

Requirements for follow up actions by the organization based on its internal audit of its DDS

were rewritten in consideration of comments that highlighted a lack of clarity of the consulted

requirements, and on the period of time allowed for an organization to correct faults it finds in

its DDS when conducting an internal audit of its effectiveness. The three month timeline was

increased to twelve months, however it is made clear that the organization shall not use material

from supply chains affected by any ineffectiveness of the DDS that leads, or may lead to, non-

eligible inputs entering production, until the ineffectiveness is corrected.

Identification of supplies

Requirements for identifying supplies and maintaining records were endorsed by the

Environmental and Social chamber members that commented on the relevant sections in the

standard, as well as one FSC Network Partner. Separate comments from the Economic

chamber stated that supply area could not be identified (as required) for products purchased

“at the gate” and that a list of possible species should be possible for co-products (information

on species contained in the supply was required). It was also asked if scientific or common

name is acceptable for identifying species.

Comments received on difficulty to identify the supply area were not used as justification for

changes to any relevant requirements – the identification of the source of material to the level

of supply area (area with homogenous risk designation) is key to the due diligence approach

of the standard. Regarding co-products (now by-products), a note now exists stating that for all

paper, composite board, and other fiber products, that a list of possible species is acceptable.

In revised requirements, species can be given by common name, if it ensures identification of

the species – if not, scientific name shall be provided.


2015 – 8 of 13 –

Risk assessment of supplies

The main issues commented upon by stakeholders regarding risk assessment of supplies, were

requirements for the organization to have access to information that allows it to confirm and

document the supply area(s) of material, and requirements relating to co-products/by-products.

Access to information to confirm the origin of material (low risk/specified risk area, or previously

certified material)

A certification body commented that some of the requirements in this section were more

relevant to the section on information on supplies. Recognizing this, some clauses were moved

so that they clearly related to either information on supplies, or risk assessment. Clarification

on “access to information” was sought, and suggestions were provided to make the

requirements more easily auditable. References to the need for “access to information” have

been clarified so that it is clear that the organization shall document and maintain the relevant

information, so that the requirements for the organization to have the required information can

be audited.

Environmental chamber members supported the relevant requirements, while Certificate

holders and Network Partners stated that the requirements are very complex and would be

costly to implement, particularly for companies further down the supply chain. This was argued

to be because tracing material back to the source is very difficult, due to supplier rights to

confidentiality and proprietary information of their supply sources. These stakeholders wanted

flexibility regarding the information needed to verify the supply area, based on scale and scope

of an operation and where it operates that will allow for more options. It was stated that the

listed requirements will violate US anti-competition law - companies cannot access wood

purchase contracts of their suppliers (with previous suppliers) as the documents are

confidential.

Recommendations included an agreement specifying the species and geographical origin of

the material, loading bill, the loading place, and the destination of the load. The use of a

“hauling radius” calculation was suggested as a way to verify that material is sourced from a

low risk area, similar to the allowance for co-products – if the supply radius falls within a

‘specified risk’ area then the supply radius should not be accepted, as it would be impossible

to identify the origin of the logs within the hauling radius, and the use of supplier declarations

and agreements. Similar requirements to those recommended already existed in the consulted

standard, and remain in the final draft, but only for by-products, where it is recognized that there

can be mixing of material. All other material shall be traced back to the supply area, due to the

need for a complete due diligence system.

Co-products/By-products

Some Environmental stakeholders described the section on co-products as unsatisfactory,

wanting co-products to undergo a risk assessment like other material. These stakeholders

stated that the “issue” needs to be addressed during the development of the Controlled Wood

strategy. Other Environmental stakeholders commented that the relevant requirements were

good and pragmatic. Social members approved the whole section related to the risk

assessment of supplies, but like some Environmental chamber members, wanted the treatment

of co-products reviewed during the development of the Controlled Wood strategy.

Some Economic stakeholders were supportive of the requirement to document the supply area

with proof of purchase from the Supply Unit or by a legally effective and enforceable agreement

with the supplier of the co-products that includes a statement on the sources of origin, and


2015 – 9 of 13 –

some questioned why this was only relevant to co-products, and not, for example other virgin

wood fibre sourced and delivered from suppliers that have sourced the material directly from

supply units such as residual sawmill chips (a co-product), chip mill chips, or roundwood/logs

from wood yards.

In the final draft of the standard, it is important to note that the terminology has changed from

“co-product” to “by-product”, in line with the revision of the FSC CoC standard. The definition

of by-product sets the scope of material that can be included under requirements for by-

products: “Output produced during the process of primary manufacturing of another (principal)

product from the same inputs (e.g., sawdust, chips generated during lumber processing)”.

Therefore, roundwood would not be included, and neither would products made from by-

products, as the material is no longer the primary material included in the definition.

There were concerns regarding the ability of an Organization to trace co-product inputs back

to the supply area where the organization may be two to three steps removed from the forest

management unit, and that it is impossible to trace co-products purchased from sawmills back

to the supply unit and to have the information of forest owner. There was also concern from

certificate holders in North America about requirements for written supply agreements to state

the geographical origin due to antitrust or other regulatory restrictions, but also due to

competition issues.

Such issues are well recognized. The requirements only require that material can be traced

back to an area with a homogenous risk designation in the applicable risk assessment, and not

to the supply unit itself. The size of the area with a homogenous risk designation will depend

on the risk assessment and heterogeneity of risk within the relevant area(s).

Risk mitigation (sourcing from specified risk areas)

Environmental and Social stakeholders generally endorsed this section of the draft standard

that was consulted. Specific comments stated that control measures developed by

organizations should be consulted with stakeholders, mandatory control measures were

wanted for significant conversion, and stakeholders should be informed about any field

verification to take place, and given an opportunity to provide relevant information.

Some certificate holders saw the requirements for control measures in general to be

burdensome. There was some confusion among, and requests for clarification from, certificate

holders and certification bodies, regarding the treatment of “mandatory” control measures in an

NRA. Many certificate holders were against the required use of independent experts in the

development of control measures for some types of risk, stating that this adds unnecessary

burden. Some comments from the Economic chamber included statements that the size of the

organization should be considered for whether independent organizations must be used, while

others stated that the requirement would be burdensome for certificate holders of all sizes. A

Network Partner stated that the requirement for experts is reasonable, but independent experts

are unnecessarily expensive for companies that may have in-house expertise that may be

better suited to the particular situation. It was stated that certification bodies should be able to

audit the level of expertise, and the appropriateness of control measures during audit.

Certificate holders raised issues concerning access to the land or operations of suppliers for

control measures and competition and confidentiality laws, and whether other landowners


2015 – 10 of 13 –

would want to grant access to other companies. It was also stated that subjecting suppliers to

part of an FSC audit mean a competitive disadvantage for certified companies.

In the final draft of the standard, requirements for using mandatory control measures in the

NRA remain very similar to those that were consulted. In terms of the use of independent

experts, the organization is no longer expected to engage independent experts in the

development of control measures for CW categories 2 and 3, but rather, obtain the opinion of

at least one expert on the relevance of control measures used. Independent experts are also

required specifically for implementing requirements related to FPIC, but there was not

consensus on the scope of the expert opinion that shall be sought.

All requirements relating to field verification have been removed from the section, as previous

requirements for it were not relevant to the due diligence approach of the revised standard.

Field verification may be implemented as a control measure by the organization, as necessary

to mitigate risk. Under requirements relating to the establishment and implementation of a DDS,

final draft requirements state that the organization shall ensure that it and its FSC-accredited

certification body are granted access to evidence (from suppliers) of conformance with

applicable requirements of this standard and access to conduct supply chain audits and field

verification where relevant;

Sourcing from unassessed areas

Comments from the Environmental chamber either didn’t support the possibility for an

organization to conduct a risk assessment in areas not assessed by FSC, or supported the

requirements as they were consulted, while underlying the importance of safeguard

requirements for CW categories 2 and 3 being kept, and stating that it is vital that companies

shall not be able to conduct risk assessments after the 31 December 2017 deadline.

Furthermore, it was stated that in conducting the risk assessment, Organizations should have

to consult stakeholders to obtain information.

Comments from certificate holders stated that the responsibility to produce NRAs lies with FSC,

and that obligations to conduct a risk assessment are a burden for organizations. It was stated

that the requirements for conducting a risk assessment will be a disincentive for companies to

source CW from areas uncovered by an FSC risk assessment. Certification bodies made a

number of comments, also suggesting that a risk assessment by companies will be too

demanding, suggesting that current risk assessments be allowed to continue while NRAs are

still being developed, or asking why certification according to FSC-STD-30-010 shouldn’t be

the only option.

Extensive changes were made to this section since the consultation took place. Requirements

for an “interim risk assessment” still exist, however the requirements for when an organization

should conduct one in unassessed areas have changed dramatically. Due to the lack of

approved FSC risk assessments (NRAs or the CNRA), new requirements have been developed

that provide separate rules for what companies can do to source CW from an unassessed area,

depending on whether or not FSC plans to have a NRA or CNRA approved (for all CW

categories) for the country by 31 December 2017. If a risk assessment is planned, organizations

may conduct a “Simplified risk Assessment” which is in essence a continuation of risk

assessments conducted by companies following the current version of the standard,

strengthened by general requirements in the revised standard. If an FSC risk assessment is

not scheduled to be completed for a country before 2018, organizations must implement an


2015 – 11 of 13 –

extended risk assessment, which is an assessment according to the FSC National Risk

Assessment framework (revised risk assessment requirements), which was termed “Interim

Risk Assessment” in the consulted version of the draft standard.

Assessment and risk mitigation of mixing material

Few comments were received on this section, and most contained suggestions for clarifying

requirements. Environmental stakeholders endorsed requirements for the assessment and risk

mitigation of mixing material, but noted that like co-products, they wanted the mixing of material

treated as a separate exercise.

It was suggested that use of the term “risk assessment” for activities regarding the mixing of

material in the supply chain is confusing as the term is mainly used for the risk assessment of

the source of materials in terms of unacceptable sources. In the final draft requirements the

term “risk assessment” is not used, but there is reference to assessing risk and it is made clear

that this is in reference to the supply chain itself.

An FSC Network Partner wanted more guidance to be included in this section, in terms of the

type/level of information that shall be provided by the Organization to the certification body to

conform to requirements, in order to avoid variation between organizations and certification

bodies. A certification body stated that there are no requirements for what “mitigation

measures” for avoiding mixing assessed material with non-eligible inputs shall be, and argued

that FSC CoC was developed to ensure this and anything less would be a second party audit

at best, noting that this is not accepted by the EUTR, which requires 3rd party audit. No

guidance has been included in the standard, and neither have any requirements. The mitigation

measures will depend on the Organization’s particular operations and the risk present. The

requirements within the section were added to the standard to align with the requirements of

the EUTR.

A certificate holder questioned whether the risk of mixing in the supply chain must be assessed

and justified for every supply chain and product group – noting that organizations may have

thousands of supply chains. In the final draft requirements, there is no specific reference to

“every” supply chain or product group, however, the Organization shall assess and document

the risk of mixing material in the supply chain(s) originating from areas with different risk

designations or specifications, and/or the risk of mixing material with non-eligible inputs, during

transport, processing or storage.

There was a request for “non-eligible inputs” to be defined, and this was done in the final draft

standard.

Stakeholder consultation

“Minimum requirements for stakeholder consultation”, as included in Annex A of the consulted

draft were strongly endorsed by Environmental stakeholders. Economic stakeholders saw the

approach as inflexible, as the timelines in the requirements would require the sourcing of

material to be planned several months in advance.

In the final draft of the standard, the Annex remains, but it is specified in the standard when

stakeholder consultation may be conducted, as this was not stated in the consulted draft. It is


2015 – 12 of 13 –

clarified in the standard and in the title of the annex that the requirements for stakeholder

consultation when conducted by the organization that consultation may be conducted as a

control measure, and when it is, the requirements in the Annex apply. The requirement that

stakeholders shall be provided with information and invited to participate in the consultation at

least 6 weeks before the management activity that is the subject of consultation remains. A list

of stakeholder types or interests to be identified and notified of the consultation has been

included.

Minimum outcomes for control measures

Much of the feedback received during the stakeholder consultation of the second draft of the

standard focused on requirements relating to “minimum outcomes for control measures”, which

existed for risks pertaining to the rights of indigenous peoples and high conservation values.

The minimum outcomes stated what was required of control measures implemented to mitigate

the relevant risks.

Environmental stakeholders strongly endorsed the requirements, referring to them as the most

critical safeguards in the revised Controlled Wood system. Other comments stated that there

should be a minimum outcome for HCV1 as well (they only existed for HCV2-6), and that the

minimum outcomes related to HCV5 and 6 should be made stronger and aligned with

requirements for FPIC. One Environmental chamber member stated that while the safeguards

are critical, they will not have the desired impact if they are not regionally appropriate, ineffective

or cost efficient. It was stated that the “vague” definition for IFL, and unclear implications for

requirements HCV 2, 5 and 6, could present unintended barriers to the broader FSC system.

Certificate holders were against the requirements as they had been presented in the standard.

Some stated that the requirements were unnecessary, overly onerous, and in excess of

requirements for forest management certification, and argued that they should be removed.

Others expressed a desire for flexibility in the system through NRAs (also echoed by a Network

Partner and a certification body). FPIC was said to be difficult to implement within the scope of

forest management certification and impracticable for Controlled Wood certification. There was

concern regarding the definition of intact forest landscapes (IFL) and fragmentation for the

minimum outcome for HCV2. Similar concerns were expressed by an Environmental chamber

member. An FSC Network partner was concerned about the impacts of the requirement for IFL

in Canada, and flow-on effects that would have for the FSC system in North America.

Due to similar feedback that was received on the National Risk Assessment Framework (FSC-

PRO-60-002a), this document was approved in November 2014 without requirements for

minimum outcomes. The FSC Board of Directors requested that the standard FSC-STD-40-

005 undergo further field testing, focused on requirements related to minimum outcomes, which

was undertaken in the first half of 2015, in Canada and Russia. These tests focused on the

workability of the requirements, and resulted in feedback from the certification bodies involved,

as well as cross-chamber feedback from a workshop in Canada.

Broadly speaking, requirements in question exist in the final draft of the standard. They are not

referred to minimum outcomes, but relevant requirements were added to the section on risk

mitigation (Section 4). Regarding the rights of indigenous and traditional peoples, the

requirements were expanded to include three steps to either ensure that material is not sourced

from where rights are violated, is sourced where there are conflicts regarding rights, but fair,

equitable and recognized processes are underway to resolve conflicts, or is sourced where


2015 – 13 of 13 –

FPIC has been given by the affected indigenous or traditional peoples for management

activities. Such an approach was an outcome from the field test workshop in Canada. Expert

involvement is also required in the treatment of such issues.

Regarding HCV2 and IFL, the scope of the requirement was narrowed so that only

fragmentation of IFL shall be avoided, and IFL was better defined with references to spatial

thresholds and international maps. Wording for requirements for other HCV was improved

during the drafting process, based on working group feedback.

Requirements in the final draft of the standard are made specific for stakeholders sourcing from

areas not covered by FSC risk assessments. This is because based on stakeholder feedback

and decisions made during the drafting of this standard, The National Risk Assessment

Framework will be amended (as was the plan for these requirements) so that National Risk

Assessment processes may provide national interpretations of requirements related to the

mitigation of risks associated with the rights of indigenous or traditional peoples, and risks

associated with threats to high conservation values. National level requirements would be able

to set agreed requirements that are applicable to national conditions, through a chamber

balanced process.

synopsis of the 2nd public consultation on the standard

Documents