Interpretations of the normative framework


This section gives you access to current standard interpretations separated by topics and related normative documents.


FSC-STD-20-011 COC Evaluations


Question

Are CBs required to verify how the CoC-CH demonstrated its commitment under the Policy for Association to not be involved in illegal logging?

Normative ReferenceFSC-STD-40-004 V2-1; FSC-STD-20-011 V2-0; FSC-PRO-20-001 V1-1
Requirement(s)Clause 1.5 of FSC-STD-40-004 V2-1; Clause 2.7d of FSC-STD-20-011 V2-0; Section 1 and 3 of FSC-PRO-20-001 V1-1
PublishedThursday, 11. February 2016

Answer

CBs have to verify (audit) the CH’s commitment to comply with the values of FSC as defined in the Policy for Association according to FSC-STD-40-004 V2-1 Clause 1.5.1. This needs to be done by evaluating the existence of the self-declaration signed by the CH (FSC-PRO-20-001 V1-1 Section 3). 

This is sufficient unless the CB witnesses objective evidence of non-conformance in the audit (FSC-PRO-20-001 V1-1 Section 1) or detects objective evidence of non-conformance when reviewing (evaluating) complaints, disputes or allegations of non-conformance received from stakeholders (FSC-STD-20-011-V2-0 Clause 2.7.d). This applies to any of the listed activities (see FSC-STD-40-004 V2-1 Clause 1.5.2), including illegal logging.

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Question

Does the requirement to review complaints, disputes or allegations of non-conformities received by the organization and/or the certification body entail an investigation of allegations made relating to issues which are not covered by FSC certification standards for certificate holders? Is the Policy for Association considered a “relevant standard” in the ISO 65 Clause 15?

As per FSC-STD-20-011 V2-0 Clause 2.7.d, what is involved in the “review of complaints, disputes, or allegations of non-conformities received” which the certification body is required to carry out?

1) Does the “review” as per FSC-STD-20-011-V2-0, 2.7(d), include a requirement that a CB investigates allegations made relating to the Policy for Association? 

2) Should the certification body investigate allegations made relating to deficiencies in products (e.g. poor quality product, albeit certified)? 

3) Is the CB required to perform independent verification of allegations by making contact with stakeholders who have submitted the allegations? 

4) In the case of a Policy for Association related allegation, is a CB required to evaluate the CHs actions with respect to the allegations?

Normative ReferenceISO Guide 65:1996; FSC-STD-20-001 V3-0; FSC-STD-20-011 V2-0; FSC-STD-40-004 V2-1
Requirement(s)Clause 7 and 15 of ISO Guide 65:1996; Clause 14 of FSC-STD-20-001 V3-0; Clause 2.7.d of FSC-STD-20-011 V2-0; Clause 1.5 of FSC-STD-40-004 V2-1
PublishedThursday, 11. February 2016

Answer

Complaints, disputes or allegations of non-conformance received from stakeholders by the certification body have to be reviewed in all cases according to FSC-STD-20-011 V2-0 Clause 2.7.d. They do however not have to be further evaluated if they are not within the scope of relevant FSC certification requirements (otherwise they would not classify as an ‘allegation of non-conformity’ by definition).
Complaints received by the CH have to be reviewed in all cases according to ISO 65 Clause 15. If they relate to compliance with relevant certification requirements, appropriate action must be taken by the CH and documented.

FSC-STD-40-004 V2-1 is the relevant standard for chain of custody certification in the context of ISO 65 Clause 15, including the requirements listed in Clause 1.5. Allegations of non-conformance against Clause 1.5 therefore need to be reviewed for any objective evidence. Such objective evidence for relevant non-conformities, even if provided only for operations or activities outside the scope of chain of custody certification, needs to be evaluated for indications of similar non-conformities within the scope of the certificate.

Regarding FSC-STD-20-011 V2-0 Clause 2.7.d:

#1: Yes, in so far that objective evidence of non-conformance in certain entities or parts of an associated organization could imply or indicate non-conformities in or even a breakdown of a certificate holder’s chain of custody or overall quality management system.

#2: The CB does not need to investigate allegations related to deficiencies in products (e.g. poor quality product). The CB needs to review allegations against CHs non-conformities against certification requirements. 
  
#3: FSC-STD-20-001 V3-0 Clause 14 in combination with ISO 65 Clause 7 requires CBs to give stakeholders the opportunity to present their case to the entity reviewing the allegation. FSC therefore considers it best practice to make contact with these stakeholders when reviewing and evaluating an allegation.

#4: ISO 65 Clause 15 requires the CB to evaluate the CH action with respect to all allegations that relate to compliance with relevant certification standards. Action taken with regards to allegations against the commitment of the CH with the Values of FSC as defined in the Policy for Association have to be investigated by the CB as they are included in a relevant certification standard, i.e. FSC-STD-40-004 V2-1 Clause 1.5.

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Question

FSC-STD-40-007 V2-0 Clause 4.1 sets out the sampling rate for organizations to apply when performing on-site audits of their suppliers included in their Supplier Audit Program. FSC-STD-20-011 V2-0 Clause 7.1 then defines the calculation for CBs to apply when selecting from those audited suppliers.

In cases where the organization voluntarily decides to conduct a higher number of on-site audits of their suppliers than required, is it acceptable for the CB to calculate their sample size on the minimum number required rather than the actual number of suppliers visited by the organization?

Normative ReferenceFSC-STD-20-011
Requirement(s)7.1
PublishedMonday, 05. October 2015

Answer

FSC does not want to discourage organizations from electing to sample suppliers at higher rates.
It is acceptable for the CB to base their sample size on the minimum number required to be included in the supplier site audits as per FSC-STD-40-007 V2-0 Clause 4.1, provided that the CB has analysed the reason(s) given by the organization for extending the sampling rate within their Supplier Audit Program and the CB has come to the conclusion that the minimum sampling rate is sufficient. 

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Question

For a company to source Controlled Wood in areas that have been designated as ‘unspecified risk’ in a National Risk Assessment or risk assessment by a company, it must include the relevant Forest Management Units (FMUs) in its company verification program according to Annex 3 of FSC-STD-40-005 V2-1. FSC-accredited Certification Bodies are then required to conduct field verification to audit the performance of the company verification program.

If an area is designated as ‘unspecified risk’ for risk assessment indicator 1.4 (relating to the perception of corruption), how would field verification by the FSC-accredited Certification Body check whether an FMU or supplier has been controlled for this indicator, and, would field verification be required when an area is designated as unspecified risk only for this indicator?

Normative ReferenceFSC-STD-20-011 V2-0
Requirement(s)5.11
PublishedTuesday, 13. January 2015

Answer

Unspecified risk designations are relevant for the whole Controlled Wood category and not only for particular indicators. Requirements for the verification of unspecified risk areas as outlined in Annex 3 of FSC-STD-40-005 and in ADVICE-40-005-19 are relevant for Controlled Wood categories and do not contain indicators relevant for risk assessment. Therefore, the Certification Body’s evaluation of verification programs in unspecified risk areas shall not focus on assessing conformance against risk assessment indicators and shall follow the relevant normative requirements.

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Question

When a nonconformity is to be graded by the Certification Body, shall the attribute ‘repeated’ (‘recurring’) be applied at the level of a 5-year certification cycle or at the level of the full lifetime of a certificate?

Normative ReferenceFSC-STD-20-007; FSC-STD-20-011;
Requirement(s)Clause 8.8 of FSC-STD-20-007; Clause 4.3.2 of FSC-STD-20-011
PublishedMonday, 19. May 2014

Answer

‘Repeated’ means that the same root cause that already resulted in a minor nonconformity in a previous audit has been re-detected as a reason for a nonconformity in a following audit within the same 5-year certification period/cycle. This is usually indicated by a nonconformity with the same indicator / requirement than in a previous audit.

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Question

How does the status of open minor nonconformities not evaluated within the 12 months timeframe affect the ability to transfer certificates to a new certification body?

Normative ReferenceFSC-STD-20-011; FSC-PRO-20-003
Requirement(s)Clause 4.6 of FSC-STD-20-011; Clause 2.2 of FSC-PRO-20-003
PublishedMonday, 19. May 2014

Answer

Minor nonconformities not evaluated by the preceding certification body within the required 12-months timeframe do not automatically upgrade to majors. The certificate may still be transferred to the succeeding certification body but the pending minor nonconformities shall be evaluated in the transfer audit and then be upgraded if not closed.

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Question

Is a certification body required to conduct consultation with stakeholders while evaluating company compliance to Annex 3 of FSC-STD-40-005 FSC standard for company evaluation of controlled wood?

Normative ReferenceFSC-STD-20-011 v 1-1
Requirement(s)Clause 10.12
PublishedTuesday, 13. May 2014

Answer

No, a certification body is not required to conduct consultation with stakeholders while evaluating company compliance to Annex 3 of FSC-STD-40-005. The company is required to conduct stakeholder consultation for relevant Categories of controlled wood and the certification body shall verify the company’s compliance with standard requirements.

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Question

FSC-STD-40-005, Annex 3 sets the minimum sampling rate for certificate holders to apply when selecting FMUs for their Annex 3 controlled wood supplier verification program. FSC-STD-20-011 defines the equation that CBs are required to use when selecting from FMUs included in the supplier verification program.

In cases where the certificate holder voluntarily decides to include a higher number of FMUs for field visits than is required by FSC-STD-40-005; is it acceptable for the CB to calculate their sample size on the minimum number required rather than the actual number of FMUs visited by the certificate holder?

For example, certificate holder is required to include 35 FMUs, but they select to increase their sample size to 60. Is the CB required to sample 5 FMUs (0.8 * √35) or 7 FMUs (0/8 * √60)?

Normative ReferenceFSC-STD-20-011-V 1-1
Requirement(s)10.10
PublishedFriday, 11. April 2014

Answer

FSC does not want to discourage certificate holders from electing to sample CW suppliers at higher rates.

It is acceptable for the CB to base their sample size on the minimum number required to be included in the supplier field visits as per FSC-STD-40-005, Annex 3, 1.8., provided the CB has analyzed the reason(s) for extending the sampling rate by the certificate holder and the CB has come to the conclusion that the minimum sampling rate is sufficient to verify unspecified risk in the given conditions.

In the example above, the CB would calculate their minimum sample size to be 5 FMUs.

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Question

According to a PSU interpretation, surveillance evaluations shall take place at least once per calendar year for FM audits and at least once per calendar year, but not later than 15 months after the last audit for CoC audits.
However, FSC-STD-20-007 and FSC-STD-20-011 require minor non-conformities in FM and CoC to be fully corrected within one year (under exceptional circumstances within two years in CoC).
If there are outstanding minor non-conformities to be evaluated, shall a surveillance evaluation take place within the next 12 months to have the CAR closed?

Normative ReferenceFSC-STD-20-007 / FSC-STD-20-011
Requirement(s)8.10.1 / 4.5.1
PublishedThursday, 20. February 2014

Answer

If an onsite surveillance evaluation is required to confirm the correction of the outstanding minor non –conformity, the audit shall take place within the 12 month period.
If an outstanding minor non-conformity can be closed by evidence not requiring an onsite evaluation, the normal audit timelines can be followed.

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Question

Can an on-site audit exceptionally be replaced by a desk audit if the organization is located in a country or region with an actual demonstrated security risk for the life or health of auditors?

Normative ReferenceFSC-STD-20-011 V1-1
Requirement(s)Clause 9.3; 19.1
PublishedThursday, 21. November 2013

Answer

In the case of a demonstrated security risk for the life or health of auditors, the CB may apply for derogation from PSU to replace an on-site audit by a desk audit. The application shall include:
a) Certificate code of the company;
b) Activities under the scope of the certificate (products and processes);
c) Evidences of security risks confirmed through verifiable public sources (e.g. an official travel warning);
d) Other additional information, as required by FSC.
Derogation applications will be evaluated on a case by case basis.

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Question

In 2012 the Corruption Perception Index (CPI) changed from a scale of 0-10 to a scale of 0-100. Shall the new 0-100 CPI scale be implemented in FSC normative documents that currently still reference the previous 0-10 scale system?

Normative ReferenceFSC-STD-40-005, FSC-STD-20-011, FSC-DIR-40-005, FSC-DIR-20-011
Requirement(s)Applies to all requirements where the CPI is mentioned.
PublishedFriday, 06. September 2013

Answer

Yes, CPI references in FSC normative documents using the 0-10 scale system shall be converted to the new scale.
A reference to a CPI index threshold ʻ5ʼ based on the old scale system becomes a CPI index ʻ50ʼ applying the new scale.

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Question

FSC considers outsourcing across national borders to countries with Corruption Perception Index (CPI) lower than 5 as high risk activity. If a company based in China establishes an outsourcing agreement with another company situated in Hong Kong, is this situation considered as cross-border outsourcing?

Normative ReferenceFSC-STD-20-011 V1-1
Requirement(s)Clause 2.1.1.f
PublishedWednesday, 29. May 2013

Answer

Recognizing that Hong Kong is a Special Administrative Region of the People's Republic of China, FSC does not consider the outsourcing activity of a company based in Hong Kong to a company based in mainland China to be cross-board outsourcing in the context of FSC-STD-20-011 V1-1 Clause 2.1.1.f

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Question

Is it acceptable to audit loggers through desk audit when the logger does not have a log yard to visit?

Normative ReferenceFSC-STD-20-011 V1-1
Requirement(s)Clause 9.4
PublishedTuesday, 23. April 2013

Answer

Yes. The desk audit is applicable to loggers holding a FSC Chain of Custody certificate and that do not have a log yard. The desk audit shall cover all applicable standard requirements of FSC-STD-40-004 V2-1, except the ones that only apply to COC certificates with physical possession of products, namely Clauses 2.2, 3.4, 5.1, Part II (8 Percentage System, 9 Credit System) and Part IV. Evaluation against the standard requirements related to labeling of products are only required when the FSC label is used by the logger.

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Question

Clause 2.2.1 of FSC-STD-20-011 specifies the criteria for high risk outsourcing. Are there any exceptions to that rule?

Normative ReferenceFSC-STD-20-011 V1-1
Requirement(s)Clause 2.2.1
PublishedTuesday, 23. April 2013

Answer

Yes. Even when one or more of the high risk indicators indicated in Clause 2.2.1 apply to the outsourced activity, the Certification Body may approve the low risk categorization if a low risk of contamination may be demonstrated through:

a) The product is permanently labelled or marked in a way that the contractor cannot alter or exchange products (e.g. heat brand, printed materials);
b) The product is palletized, or otherwise maintained as a secure unit that is not broken apart during outsourcing;
c) There is no risk of contamination, as the contractor handles exclusively the materials from the contracting organization in its facilities during outsourcing;
d) The contractor is employed for services that do not involve manufacture or transformation of certified products (e.g. warehousing, storage, distribution, logistics)

NOTE: Outsourcing across national borders to countries with Corruption Perception Index (CPI) lower than 5 is always considered high risk activity.

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Question

When does the given timeline commence for correction of non-conformities?

Normative ReferenceFSC-STD-20-011 V1-1
Requirement(s)Clause 4.5, 4.6
PublishedFriday, 15. April 2011

Answer

The given timeline commences from the moment when the corrective action request is either formally accepted by or formally presented to the certificate holder (whichever happens first).

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