SECOND ROUND OF STAKEHOLDER CONSULTATION ON THE REVISED CONTROLLED WOOD NORMATIVE DOCUMENTS (CLOSED)
FSC’s Controlled Wood (CW) system is currently being revised, as mandated by the 2011 FSC General Assembly, in Membership Motion 51.
This revision requires changes to a number of documents, which have been determined through input from a chamber-balanced CW Technical Committee (CWTC), guidance from the FSC Board of Directors, and stakeholder consultations.
These changes include:
- The phase-out of company-developed risk assessments for sourcing CW,and their replacement by National Risk Assessments (NRAs) that determine the risk for all controlled wood categories in a particular area;
- New categories of risk (‘low risk’ and ‘specified risk’), along with flexible and robust risk mitigation measures (‘Control Measures’ (CMs)), which are to be developed by Organizations if not provided as mandatory in the NRA;
- Assessment of these CMs for their effectiveness in mitigating risk, to be carried out by Certification Bodies, according to the appropriate accreditation standard;
- Strengthened transparency, including requirements for the public reporting of CMs and a complaints mechanism to allow stakeholders to challenge the efficiency and other aspects of the Organization’s performance.
Implementation of the revised system will be supported by the Centralized NRA project Centralized NRA project and the temporary option for companies to conduct Interim Risk assessments.
Documents consulted earlier
During the first round of stakeholder consultation, comments were invited on the following four documents:
- FSC-PRO-60-002 (V3-0) The Development and Approval of Controlled Wood National Risk Assessments, and its addendum FSC-PRO-60-002b National Risk Assessment Framework. These documents regulate NRA development and they were opened to public consultation from 28 June to 15 September 2013.
- FSC-STD-40-005 (V3-0) Requirements for sourcing Controlled Wood. This document provides requirements for Chain of Custody (CoC) certified organizations to avoid material from unacceptable sources, and was opened to public consultation from 18 September to 24 November 2013.
- FSC-STD-30-010 (V3-0) Forest management requirements for Controlled Wood certification. This document provides requirements for forest managers wishing to supply controlled wood, and was opened to public consultation from 18 September to 24 November 2013.
The documents have again been revised, and the second drafts are open for stakeholder consultation.
In addition to these documents, relevant accreditation standards are also being developed for Certification Bodies (see ‘Accreditation standards’ below).
Contents of the Controlled Wood Requirements
The content of the revised drafts was influenced by two main factors:
- stakeholder feedback received during the first consultation periods
- guidance from the FSC Board of Directors, and CWTC agreement on the revised requirements.
Thanks to the active engagement of stakeholders, FSC gratefully received and carefully analyzed a large number of comments on the documents under consultation.
A synopsis and detailed analysis of the stakeholder feedback are available in the ‘Download’ section, below. For additional information about this analysis, please contact Joanna Nowakowska (firstname.lastname@example.org)
Polarized feedback received during stakeholder consultation, as well as different expectations for the revised system expressed by CWTC members increased the need for strategic direction. To obtain further strategic guidance, the CWTC and CW Steering Committee prepared a paper for the FSC Board of Directors, which requested the development of a CW strategy, as well as direction for the current revision process.
Due to the absence of an approved NRA in many countries, Board acceptance was requested for an international risk assessment to streamline the transition between the current and revised CW systems, as well as to initiate national processes. The Centralized National Risk Assessment (CNRA) process resulted from this.
The CNRA focuses on the identification of ‘low risk’ areas for each of the five CW categories in CW priority countries, in order to bridge the gap between the current and revised risk assessment processes. This is intended to reduce the effort needed by certified organizations to source CW from ‘low risk’ areas and improve certainty in the planning of CW sourcing, as well as initiate and stimulate NRA development.
The FSC Board of Directors agreed to begin developing a CW strategy (read more here),but only once the current CW revision is finalized. This will ensure that the documents currently under revision reflect the purpose of Motion 51 and that the new CW framework becomes operational as soon as possible. As Motion 51 focuses on the current scope of CW, the second drafts were prepared to reflect this.
Major Changes Between Draft Versions
The main differences between the first and second drafts of the documents are summarized below. Please explore the second drafts to get a full understanding of the changes made.
Proposals have been kept or added for:
- the allowance of external chamber-balanced working groups to develop NRAs under FSC supervision;
- the regular review of NRAs to be required at least every five years, but with provisions for technical changes, and risk designation changes when they are obviously needed (through an ‘urgent review’ process), to be made outside of the regular revision process; and
- an intervention mechanism for FSC International to proceed with risk determination across different countries.
- The structure of the document has been changed to align with other FSC normative documents;
- Thresholds for ‘low’ and ‘specified risk’ have been determined for each indicator under assessment;
- The maximum (national/regional) scale of the assessment for CW and high conservation value (HCV) categories has been determined;
- Scale, intensity and risk considerations have been added to the risk assessment process;
- Mandatory requirements have been included for engaging experts in risk assessment for categories 2 and 3, as well as minimum qualification for experts involved in risk assessment processes;
- Implementation of free prior and informed consent is no longer required for low risk designation, but will be achieved through CMs in cases of specified risk;
- Threats to HCV values that need to be considered in a risk assessment were determined;
- NRAs may provide mandatory or recommended CMs. In the latter case, or when no CMs are provided, Organizations are responsible for developing them;
- Minimum outcomes that need to be achieved by CMs were determined for some of the indicators and risks.
*Please note that code of the FSC National Risk Assessment Framework was changed from FSC-PRO-60-002b to FSC-PRO-60-002a
This addendum, which replaces the current List of approved National and Regional Controlled Wood Risk Assessments, will include all approved CW documents, such as approved NRAs and national-specific requirements.
- The major change in this document is the proposed allowance for Organizations to develop Interim Risk Assessments (IRA) in areas of unassessed risk, based on the methodology presented in the NRAF, until 31 Dec 2017. After this datea, FSC will ensure NRA development;
- Proposed requirements and guidance for the development of CMs were added, along with an annex of CM examples previously included in the NRA framework;
- New procedural requirements were added for stakeholder consultation in situations when consultation is established as a CM;
- Public summaries were extended with IRA outcomes;
- Contents and stakeholder feedback on Advice Notes consulted in 2013 have been included;
- A template for IRA is proposed in order to strengthen consistency between the IRAs carried out by different organizations.
- Requirements in this standard have been kept at the criteria level;
- Proposed criteria were reduced in number and adapted to reflect the current CW scope. Language from the FSC Principles and Criteria (P&C) has been used only when directly relevant to this scope;
- Conversion requirements that consider past conversion practices are addressed by elements of FSC-POL-01-004 V2-0 Policy for the Association of Organizations;
- This Standard is still considered to be used in the FSC Modular Approach Program, however differences between the Standard and P&C will not be addressed in the CW revision process.
Special note about IRA and NRA coverage
CWTC members made the very difficult decision to propose that the possibility of risk assessments by Organizations should be extended. The arguments taken into account in making this decision were:
- The current lack of approved NRAs. The CWTC acknowledged that in many cases NRAs have not been delivered as planned because FSC Network Partners were waiting for revised CW requirements;
- The safeguard of using strengthened requirements for risk assessment and transparency. According to Motion 51, company risk assessments should be replaced by NRAs developed under the current system, based on the same risk assessment requirements as for company risk assessments. The new possibility for Organizations to develop IRAs assumes using new, strengthened risk assessment requirements. Moreover, the transparency of the risk assessment and certification processes has also been strengthened;
- The forthcoming development of a CW strategy. This will involve multi-stakeholder engagement to discuss the future of the CW system and address polarized stakeholder expectations towards CW goals and performance. This is beyond the scope and mandate of Motion 51;
- FSC commitment to deliver NRAs by 31 Dec 2017.
CWTC members and the CW Steering Committee have been stressing the need for NRA prioritization, and FSC is investing a great deal of effort in delivering approved NRAs. For the rest of 2014 FSC will provide updates on the progress of NRA development and the expected dates of NRA delivery through webinars, with a focus on the top 20 priority countries.
What about approved NRAs?
Low risk designations in approved NRAs will remain valid until 31 Dec 2017. By this time entities responsible for NRAs will revise risk designations according to the revised CW requirements.
FSC once again kindly invites comments from all interested stakeholders on the above documents during the second round of consultation. Stakeholder feedback is crucial for refining drafts and producing final requirements to ensure the most robust system possible under the current CW scope.
Please provide your comments using the attached comment form and send them to Darren Brown at email@example.com.
The deadline for comments on English versions is 30th June 2014.
The deadline for comments on Spanish versions is 20th August 2014.
Furthermore, to ensure stakeholder engagement, FSC would like to invite you to participate in webinars organized in English and Spanish. There will be three webinar topics:
• NRA/CNRA development
• Revised CW requirements
• Accreditation standards and transition rules for the revised
Webinars on each topic will be held at least twice during the consultation period. Dates and times of these will be communicated once they have been set.
Webinar recordings will be available here
The relevant accreditation standards have been modified to reflect the revised CW requirements and have now also been released for further consultation. For information and documents to download, please click here.
The first draft of the NRAF was field tested in Lithuania. The report from the field test is available here
Alongside the current round of consultation, FSC is planning field testing of FSC-STD-40-005 and FSC-STD-30-010, in cooperation with certification bodies, and using revised accreditation standards.
A Controlled Wood Strategy
FSC has announced the future development of a formal strategy for Controlled Wood to outline the scope and goals of the system for the next 10 years. Read more!
Now in high gear, the Controlled Wood revision process offers many opportunities for your participation – including two rounds of stakeholder consultation on the standard drafts.
Contact Joanna Nowakowska at firstname.lastname@example.org