Monday, 17. October 2011
Clarification about new social requirements in CoC
As recently communicated, FSC is preparing a Questions & Answers (Q&A) document in order to clarify the implementation of the FSC Policy for Association in CoC. However, considering that the new version of the CoC standard is effective for new COC certificate holders since 01 October 2011, it is important to clarify some relevant aspects before the Q&A is published.
Is it possible to issue a CAR based on FSC-PRO-20-001 (see document attached)?
FSC-PRO-20-001 is a procedure for Certification Bodies and not for Certificate Holders. This document provides the procedures that shall be followed by Certification Bodies when assessing companies against Clauses 1.5 and 1.6 of FSC-STD-40-004 V2-1. It means that CARs against FSC-PRO-20-001 could only be issued by ASI against a CB, but not by a CB against a certificate holder. Any nonconformity detected by a CB in a certificate holder’s company regarding the commitments to the Policy for Association or Occupational Health and Safety shall be issued against Clauses 1.5 and 1.6 of FSC-STD-40-004 V2-1 respectively.
Does the Policy for Association also cover unacceptable activities performed by companies supplying the certificate holder (e.g., a company that is buying wood from a supplier involved in illegal logging)?
The Policy for Association does not cover unacceptable activities performed by suppliers and other parties where the FSC certificate holder is not directly or indirectly involved in. A revised version of the Policy for Association was recently approved by the FSC Board, which now contains a more explicit explanation of the terms “direct” and “indirect” involvement (Please see the document attached). These definitions aim to clarify that the Policy for Association only covers situations in which the organization or individual is firsthand responsible for the unacceptable activities (direct involvement) or is involved as a parent or sister company, subsidiary, shareholder or Board of Directors with a minimum ownership or voting power of 51% to an organization directly involved in unacceptable activities (indirect involvement). It also includes situations in which the organization or individual hires a subcontractor to perform unacceptable activities on its behalf.
Do companies based in countries that have not ratified the ILO Conventions also have to sign the self-declaration?
Yes. FSC certificate holders shall commit to the fundamental principles and rights at work even if they are based in countries which have not ratified the convention.
Does the Policy for Association also cover outsourced activities? Are contractors also required to sign the self-declaration?
All activities covered by the scope of the company’s certificate are subject to the Policy for Association whether outsourced or not. However, only FSC certificate holders are required to sign the self-declaration form, but they have to take the responsibility that all outsourced activities are conducted in line with all applicable FSC requirements which also includes Clauses 1.5 and 1.6 of FSC-STD-40-004 V2-1.
Does the self-declaration also cover Occupational Health & Safety?
No. The self-declaration relates exclusively to the FSC Policy for Association. It means that companies signing this document are only declaring their commitment to comply with the values of FSC as stated in the Policy for Association. The Occupational Health & Safety relates to the clause 1.6 of FSC-STD-40-004 V2-1, which requires no company declaration, but the implementation of quality management procedures for Health & Safety.
Can a Certification Body issue a Major CAR to a company that has not signed the self-declaration before 01 October 2012?
According to FSC-STD-40-004 V2-1, certification applicants shall be assessed against this standard as of 01 October 2011 and all compliance with this standard by 01 October 2012. It means that the self-declaration is a pre-requisite for new CoC certificates. However, for companies that were already certified before 01 October 2011, a Major download document here endownload document here es
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