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FSC Standards Interpretations


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

FSC-STD-20-007 FM Evaluations


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 Reference FSC-STD-20-007 / FSC-STD-20-011
Requirement(s) 8.10.1 / 4.5.1
Published Thursday, 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.


Question

a) There are contradictory definitions for stratification of group members according to size:
FSC-STD-30-005 Clause 8.3 requests the group entity to separate between large members above 1000 ha and small members below 1000 ha.
At the same time, according to Clause 8.4, the group entity shall use the same stratification the certification body (CB) but FSC-STD-20-007 identifies four different size classes for stratification.

b) There is a problem with indicator 8.4 and 8.5 of FSC-STD-30-005: they request the group entity to do an internal monitoring of members different to the external monitoring. If there is only one member in one size class this is not possible and a sampling does not result in a sample, but in one member every year.

c) In addition for FMU < 100 ha, which consequently have the lowest risk, the audit intensity would be significantly higher than for larger forests.

Normative Reference FSC-STD-30-005 / FSC-STD-20-007
Requirement(s) Clauses, 8.4 and 8.5 / Clause 6.3.3
Published Wednesday, 19. February 2014
Answer

a) There is no contradiction. Clause 8.4 states that for monitoring purposes the group entity should use the same stratification into sets of ‘like’ FMUs as defined by the CB in their evaluation. Should indicates advice, it is not mandatory.
However, compliance with the requirements in FSC-STD-30-005 and FSC-STD-20-007 is possible following these steps:

1. Separating the members above and below 1000 ha.

2. Doing a further division of each group between <100 ha and 100 – 1000 ha (for members below 1000 ha) and between 1000 – 10000 ha and >10000 ha (for members >1000 ha.)

b) Clause 8.5 states that the group entity should visit different members in their annual monitoring than the ones selected for evaluation by the CB (…). Should is a recommended way, not a requirement if it is not possible because there is one member per class. If there are alternatives the group entity should not visit the same members.
c) FSC-STD-20-007 Clause 6.3.3 provides with specific sampling rules for groups or sub-groups of SLIMFs with less than 100 members that comply with the clause.


Question

a) According to 6.3.5 in the surveillance evaluation, if new FMUs have been added to the scope of the certificate since the main evaluation, the new FMUs shall be sampled at the rate of a main evaluation.
Then, if a new member has been added to a group consisting of 5 members in the size class 100-1000 ha, a sampling within the new members will result in a sample of one. This is rather a full evaluation than a sample.
In this case, would it be necessary to calculate the sample separately for old and new members or, if the number of members is below 5 per stratum, is possible to group them together in one stratum to allow sampling?
b) How long will this separate calculation be maintained after the new members joined the group? Will they remain in the new stratum until the next main evaluation? Or will they be assigned to the strata of the old members after being sampled at the rate of a main evaluation in the first year?

Normative Reference STD-20-007 V3-0
Requirement(s) 6.3.5
Published Wednesday, 19. February 2014
Answer

a) The new FMUs shall be sampled at the rate of a main evaluation, regardless of the number of members per stratum. The sampling rule can only been changed in the revision of the standard.
b) Members added to the certificate since the last main evaluation can be assigned to the strata of old members after they have been sampled at the rate of a main evaluation once.


Question

Is it allowed to reclassify the grade of a non-conformity from major to minor prior to the issuance of an initial FSC FM certificate?
Example: During the pre-evaluation of a forest organization a major non-conformity is identified. During the subsequent main assessment the audit finds that the major non-conformity is still present. During follow-up non-conformance evaluation audit prior to certificate issuance, the audit finds that the organization has implemented sufficient corrective actions such that the non-conformity is no longer considered a major non- conformity, but rather minor gaps are still present that meet the criteria of a minor non-conformity. In this situation, can the initial major non-conformity identified in the assessment be reclassified to a minor and a certificate issued?

Normative Reference FSC-STD-20-007 (V3-0)
Requirement(s) 8.13
Published Tuesday, 18. February 2014
Answer

As long as a major CAR has not been established by formal decision making process, non-conformities that are addressed in the audit process can be regraded, either to minor to major as major to minor. This does not qualify as a downgrading in the sense of our requirements.
Once a major CAR has been formally established, downgrading is no longer possible.


Question

According to FSC-STD-20-007, primary or secondary processing facilities associated with the forest management enterprise shall be inspected for conformity with the applicable CoC standard(s), and a separate report which meets the requirements of FSC-STD-20-011 Annex 1 shall be prepared.

Are there any further definitions or criteria (concerning size, number of workers, quantity of processed material, permanent vs. mobile facilities, permanent or occasional workers in charge of processing) to define the "processing facility"? If so, please specify.

Normative Reference FSC-STD-20-007
Requirement(s) Clause 1.5.
Published Thursday, 28. November 2013
Answer

No, there is no further definition or criteria in FM or CoC standards. Log cutting or de-barking units and small portable sawmills associated with the forest management enterprise are an exception to this clause and they can be evaluated as part of the ‘normal’ forest evaluation procedures. Small sawmills which are only in use temporarily or log chipping units also do not require a separate CoC evaluation and report.


Question

Can a FM/CoC certificate include primary or secondary processing facilities?

Normative Reference FSC-STD-20-007 (V3-0)
Requirement(s) Clause 1.5
Published Thursday, 28. November 2013
Answer

No, primary or secondary processing facilities associated with the forest management enterprise shall be inspected for conformity with the applicable CoC standard(s), a separate report which meets the requirements of FSC-STD-20- 011 Annex 1 shall be prepared and a separate CoC certificate shall be issued.

This does not apply to log cutting or de-barking units and small portable sawmills associated with the forest management enterprise. They can be evaluated as part of the ‘normal’ forest evaluation procedures.

Exception: It's possible to exceptionally include processing facilities in the FM/CoC certificate scope, if all of the following conditions are met:

  • it is owned or managed by the Organization holding the joint certificate;
  • the processing plant procures all its supplies from the certified FMU, i.e. it does not buy in certified timber from other certificates;
  • the processing plant is audited against the applicable CoC standard(s);
  • a separate CoC report is prepared meeting CoC reporting requirements;
  • the AAF is calculated separately for the forest area and the processing plant.


Question

A large remote plantation in Tanzania includes extensive infrastructure (housing, hospital, sawmill, processing plant).

1. What aspects of these operations should be assessed within the scope of the FM/CoC operation (as distinct from a separate CoC certificate)?
2. What if the sawmill fails to get the CoC certification?

Normative Reference FSC-STD-20-007 (V3-0)
Requirement(s) Section D, Clause 1.5
Published Thursday, 28. November 2013
Answer

1. The scope of FM/CoC certification includes the assessment of forest management and the tracking and tracing system of forest products (incl. NTFPs) within the forest management unit up to the forest gate.
If the housing and hospital are within the FMU and linked to the forest management activities and the Organization has directly or indirectly responsibility, they have to be assessed according to the FM standards.

Primary or secondary processing facilities associated with the forest management enterprise shall be assessed according to the CoC standards, with the exception of log cutting or de-barking units and small portable sawmills associated with the forest management enterprise. The sawmill and the processing plant shall be assessed according to the CoC standards.

2. If the sawmill is eligible to be included in the scope of FM/CoC certificate and fails to comply with CoC requirements, the products coming out of the sawmill are not eligible to carry the FSC Logo.
If the sawmill is not within the scope of FM/CoC certificate, it requires its own CoC certification. Failure to comply with the applicable CoC requirements would not allow issuing a CoC certificate.


Question

Regarding to special or adapted requirements for Type II groups:

1. Can CBs certify RMUs as single FMU certificate?
2. If 30-005 is applicable, which are the requirements for RMUs (group entity but also group members) if group members have almost no rights and responsibilities?

Normative Reference FSC-STD-20-007 (V3-0) / FSC-STD-30-005 (V1-0)
Requirement(s) Section D / Part 1
Published Thursday, 28. November 2013
Answer

1. No, the RMU can be used as the basis for sampling as if it were a single FMU certificate, but it has to comply with the rest of requirements for groups and be certified as a group.

2. RMUs shall comply with all the applicable requirements in FSC-STD-30-005 (V1-0).


Question

FSC-STD-20-007 requires that new FMUs (e.g. group members or newly acquired FMUs) added to the scope of the certificate since the main evaluation shall be sampled at the rate of a main evaluation.
Shall they also be sampled at the rate of a main evaluation, if they have previously been certified under another group scheme or an individual certificate?

Normative Reference FSC-STD-20-007 (V3-0)
Requirement(s) Clause 6.3.5
Published Thursday, 28. November 2013
Answer

New FMUs added to the scope of an existing certificate that have been previously certified (within the last 6 months) may be sampled at the rate as for annual surveillance, instead of the rate of the main evaluation.


Question

In an FM Group comprised of SLIMF FMUs grouped in a Resource Management Unit (RMU), what is the basis for sampling: the FMUs or the RMU?

Normative Reference FSC-STD-20-007
Requirement(s) Annex 1. Clause 3.4.
Published Wednesday, 11. September 2013
Answer

The RMU concept applies to sets of SLIMFs managed by the same managerial body applying the same forest management concept. The RMU may be used as the basis for sampling.
Sampling within an RMU shall be conducted in accordance to Clause 5.4.2 in a main- and re-evaluation and in accordance to Clause 6.3 in a surveillance evaluation. Consequently, it is up to the auditor(s) to select the sites for evaluation, provided that a sufficient variety and number of sites within the RMU are visited.


Question

How are the two step approach and the definition of levels to be implemented? If size sets within the group are obligatory, there will be one set for each size class, then how can I do a two step approach in this situation? Am I allowed to do a sample only in one size class?

Or does this apply only for different sets within the same size class, e.g. group members managing plantations and group members managing natural forest?

If a sample within each size class is required, another problem occurs: If 20 members are within the size class 1.000-10.000 ha and only 1 member is smaller, the sampling intensity will become much higher in the lower size class. I have to visit the one member every year.

The same applies the other way round: 20 members between 100 and 1.000 ha, one member 1.100 ha. The sample of 0’2 SRT one member will result in one, I have to audit this member every year instead of every five years.

Normative Reference FSC-STD-20-007
Requirement(s) Annex 1; Clause 6.3.3
Published Monday, 26. August 2013
Answer

When evaluating FM Groups made up of small size FMUs (≤ 1,000 ha), the minimum number of units to be sampled must be calculated using the 2-step approach. All FMUs shall be divided into groups, according to their size, obtaining size-sets. The 2-step approach will then be applied to each of these size-sets, obtaining the minimum number of FMUs (or set of ‘like’ FMUs) to be sampled within each of the size-sets. Therefore, it is not allowed to do a sample only in one of the size-sets.

The 2-step approach shall be applied to each size-set, whether there are other sets of ‘like’ FMUs within these size-sets or not (see examples here).

The CB shall carry out one or more FMU level site visits annually, except for groups or sub-groups of SLIMFs with less than 100 members that comply with the requirements specified in clause 6.3.3 of the FSC-STD-20-007. In these cases, the certification body shall carry out at least one FMU level site visit at the end of the first year in which the certificate was issued, and at least one additional FMU level site visit during the period of validity of the certificate. If there are no outstanding corrective actions to be evaluated and no unresolved complaints requiring evaluation the remaining surveillance evaluations may be based on review of documentation and records specified in 6.2, and do not require FMU level site visits.

Clause 6.3.3 shall be applied at the level of sets of ‘like’ FMUs, once all the FMUs have been classified according to size, forest type and applicable national or regional standard.


Question

For group certification, does the 50,000 hectare threshold (6.3.8.b) apply at the FMU level or the total area included in the certificate scope?

As an example there is a group certificate that contains both SLIMF and non-SLIMF FMUs. The certificate includes 35 FMUs, 20 FMUs are medium sized (1,000-10,000 ha) and 15 are small SLIMF FMUs. The total area in the scope is 50,786 ha and the largest FMU is 8,345 ha. In this case all of the FMUs in the scope of the certificate are small to medium sized. Is the intent of 6.3.8.b really to place the additional cost burden on small and medium enterprises in group certificates associated with the annual evaluation of the specified mandatory criteria?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clauses 6.3.8.b, 5.3.1 and 5.3.4
Published Thursday, 27. June 2013
Answer

According to Clause 5.3.1: “The CB shall classify the FMUs included in the scope of the evaluation as sets of ‘like’ FMUs for the purpose of sampling.(...)”. Once classified in sets of ‘like’ FMUs, the sampling and procedure rules are to be applied.

Therefore, Clause 6.3.8.b is to be applied at the set of ‘like’ FMUs level.

In the case described, there would be two sets of ‘like’ FMUs according to the size:

1) 20 FMUs of medium size (1,000-10,000 ha)
2) 15 small SLMIF FMUs

None of these sets of ‘like’ FMUs would have to be evaluated to be in compliance with the criteria specified in Clause 6.3.8.b.


Question

May compliance with minor non-conformities be evaluated at the next surveillance (or re-evaluation) audit, as opposed to within one year, to account for instances when the next surveillance audit will occur after the one year deadline?

Normative Reference FSC-STD-20-011 V2-0, FSC-STD-20-007 V3-0.
Requirement(s) Clauses 4.5 and 8.10.
Published Wednesday, 16. May 2012
Answer

For Forest Management:

Compliance shall be established by the Certificate Holder within the deadline established in the Corrective Action Request, which is specified by the Certification Body according to clause 8.10 in FSC-STD-20-007.

Field evaluations by the Certification Body to verify the implementation of the corrective action shall be conducted no later than 15 months after the CAR has been issued.

For Chain of Custody:

Compliance shall be established by the Certificate Holder within the deadline established in the Corrective Action Request, which is specified by the Certification Body according to clause 4.5 in FSC-STD-20-011.

Field evaluations (if needed) by the Certification Body to verify the implementation of the corrective action shall be conducted no later than 10 working days exceeding the deadline established in the CAR.


Question

Regarding the transfer of a certified forest to another proprietary, what should the new owner do to keep the certificate?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 7, Clause 5.
Published Tuesday, 15. May 2012
Answer

If the new owner wants to keep the same certificate, a surveillance audit shall be carried out by the Certification Body, following the re-evaluation process as described in Clause 7 in FSC-STD-20-007. This audit shall take place at the date of the next scheduled surveillance evaluation, but not later than 3 months after the transfer. The new owner shall be responsible for all pending conditions issued before the transfer.

If the new owner wants a new certificate with a new five year timeline, a main evaluation according to Clause 5 in FSC-STD-20-007 shall be carried out by the Certification Body.


Question

We are aware that where a main assessment had been carried out for a CoC certificate, the client may, after the certificate had been issued, sell the certified timber products that were in stock at the time of the main assessment, as certified. My first question relates to the CoC aspect of this, i.e. does this also mean the client may sell all certified timber products purchased between the time of the main assessment and the date the certificate is issued, as certified, after the certificate had been issued?

This brings me to the FM situation, i.e. would this same rule apply for FM certification? If the rule does apply, does this mean that any standing stock that is felled in the period between the main evaluation and the date the certificate is issued, may then be sold as certified after the certificate had been issued?

Normative Reference FSC-STD-20-007 V3-0; FSC-STD-40-004 V2-1
Requirement(s) Section D; Clause 5.2
Published Monday, 06. February 2012
Answer

The answer to the first question is Yes, according to FSC-STD-40-004 V2-1, which states:

Organizations in the certification process may use towards their input calculations material held in their stock at the time of the main assessment as well as material received between the date of the main assessment and the issue date of the organization’s FSC Chain of Custody certificate. However, the organization may not sell any material with FSC claims prior to holding an FSC Chain of Custody certificate.

The answer to the second question is also Yes, with the conditions specified in FSC-STD-20-007:

In the case of joint Forest Management and Chain of Custody certification, timber that had been felled prior to the issue of a certificate, but which has not yet been sold by the forest management enterprise may be sold as certified if it was felled in the same calendar year or harvesting period and if the main evaluation did not reveal any major nonconformity.


Question

Can a Certification Body (CB) certify a young plantation as Forest Management (FM) only (instead of FM/CoC (Chain of Custody))?

Normative Reference FSC-STD-20-007 (V3-0); FSC-DIR-20-007.
Requirement(s) Section D. ADVICE-20-007-05.
Published Tuesday, 31. January 2012
Answer

No, plantations must have an FM/CoC certificate. They are considered as commercial operations and the aim of the forest management is to sell timber. According to FSC-STD-20-007, “...Forest products must be covered by a valid Chain of Custody certificate, or by a joint Forest Management/Chain of Custody certificate, in order to be eligible to carry the FSC Logo and to enter into further chains of custody”.

In accordance with Advice-20-007-05 in FSC-DIR-20-007, whenever the aim of the forest management is to sell timber, non timber forest products or ecosystem services, there is need to have a CoC certificate or a joint FM/CoC certificate issued by an FSC-accredited certification body which includes the specified product(s) within its scope.


Question

What is the definition of ‘Large’ (enterprises) in FM Certification?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 3.1.1
Published Thursday, 08. December 2011
Answer

Clause 3.1.1 refers to the following as ‘large’:

a) Plantations larger than 10,000 ha;
b) All non-plantation forest types larger than 50,000 hectares, unless the whole area meets the requirements for classification as a “low intensity managed forest”.


Question

Forest types (natural/ semi-natural vs. plantation) – are these the only forest types to be used for ‘like’ FMUs?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 5.3.1
Published Thursday, 08. December 2011
Answer

Yes. These are the only forest types. However, there are other categories to consider as ‘like’ FMUs.
The categories are those mentioned in FSC-STD-20-007 V3-0 Clause 5.3.1:

- Natural/semi-natural
- Plantation
- Those defined by the national standards
- Size of FMUs


Question

In the introduction to the P&C FSC-STD-01-001 V4-0 it states ’FSC is not about perfection’. Can this be used as justification for auditors not raising Non Conformities?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 8.2
Published Thursday, 08. December 2011
Answer

No. An imperfection is a non conformity. The rules are set out in FSC-STD-20-007 for issuing certificates whilst there are non conformities and the closing out of such ‘imperfections’ is part of the certification process. Such imperfections then cannot be ignored.


Question

Can a CB claim the same field period for a surveillance and a re-evaluation and write two reports? Does it make a difference if it is a SLIMF?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 6.3.1
Published Thursday, 08. December 2011
Answer

No. A surveillance visit and a re-evaluation visit cannot take place at the same time, firstly as they have a different scope and secondly since surveillance needs to occur annually (meaning once a year) between the main audit and the re-evaluation. The main audit take place in year zero and the re-evaluation takes place in year five. A certificate can only be extended through a re-evaluation.


Question

Would a separate CoC evaluation and report be required for mobile wood chippers, where the chips are produced in the FMU?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 1.5 NOTE
Published Monday, 19. July 2010
Answer

No. This would not be required. FSC-STD-20-007 V3 does not include woodchips specifically. This should be treated the same as for ‘small portable sawmills.’


Question

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

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 8.10, 8.11
Published Friday, 04. July 2008
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).


Question

Do Pre-Evaluations require on-site visits?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Section 3
Published Friday, 04. July 2008
Answer

The implementation of the requirements listed in FSC-STD-20-007 V3-0 Section 3 (Pre-Evaluation) requires an on-site audit to credible conduct the evaluation of the management system and the gap analysis.


Question

Does Clause 8.20 cover situations where a forest owner/manager claims that compliance with FSC requirements is not possible because of allegedly dysfunctional legislation?

Normative Reference FSC-STD-20-007 V3-0
Requirement(s) Clause 8.20
Published Friday, 04. July 2008
Answer

Yes, but in this case the forest owner/manager shall support the evaluation by the certification body with a written legal opinion by an independent legally recognized attorney-at-law. This evaluation shall further include the FSC International Center and the FSC National/Regional Office. If a legal opinion cannot be provided, the non-compliance shall be treated as usual; see FSC-STD-20-007 V3-0 Section 8.