2005 (1st) Annual Audit FSC Chain-of-Custody Certification Report
for
Potlatch Corporation – Clearwater Lumber

807 Mill Road, P.O. Box 1323

Lewiston, Idaho 83501, USA

Chain-of-Custody Registration Number SCS-COC-00624

Scientific Certification Systems

2000 Powell Street, Suite 1350

Emeryville, California 94608, USA

Report completed: April 30, 2005

Auditor and Author:

Wolfram R. Pinker, Ph.D.

Site evaluation conducted: April 28, 2005

Scope: The certificate covers manufacturing of softwood lumber products.

Certification against FSC Policy on Percentage-based Claims from May 2000.

TABLE OF CONTENTS

1. Summary

1.1 Scope

1.2 Results of inspection

1.2.1 Weaknesses identified in the control

1.2.2 Recommendations or conditions attached to certification

1.2.3 The certification recommendation

2. Background

2.1 Auditor

2.2 Previous assessments

2.3 Field visits

2.3.1 Itinerary

2.3.2 Items and places inspected

2.3.3 Names and affiliations of people consulted

3. Scope of the assessment

4. Supplier’s control system

4.1 Register of suppliers

4.2 Ordering of certified goods

4.3 Receipt of certified goods

4.4 Inventory control

4.5 Sale of goods

5. Observations of the system for controlling chain-of-custody

5.1 Principle 1: Documented control system

5.2 Principle 2: Confirmation of inputs

5.3 Principle 3: Separation and/or demarcation of certified and non-certified inputs

5.4 Principle 4: Secure product labeling

5.5 Principle 5: Identification of certified outputs

5.6 Principle 6: Record keeping

6. Risk assessment

6.1 Risk of contamination or confusion in product status

7. Monitoring

8. Decision

9. Acknowledgement and Agreement

signature date

Appendix A – Summary table of report requirements

Appendix B – Additional general guidelines

Appendix C – Documented Control System

Appendix D – Input/output Calculations

CONTACT PERSON INFORMATION

Legal company name (as it will appear on the chain of custody certificate): Potlatch Corporation – Clearwater Lumber

Name of Contact Person: Bill Highsmith

Address: 807 Mill Road, P.O. Box 1323, Lewiston, Idaho 83501, USA

Telephone: 208-799-1275

FAX: 208-799-1018

E-mail:

Approximate Annual FSC Product Quantity: 103,000 BF

Species covered: various

Previous certificates in Chain of Custody: SCS-FM/COC-00067N

AAF category: 75 Mil

Chain of Custody Certification Report: Potlatch Corporation – Clearwater Lumber Page 1 of 14

1. Summary

This report describes Potlatch Corporation – Clearwater Lumber’s (hereafter Clearwater Lumber) 2005 (1st) annual monitoring audit.

1.1 Scope

Potlatch Corporation – Clearwater Lumber is one of several sawmills owned by Potlatch Corporation. The sawmill includes both large log and small log sawing capacity, planer, and dry kilns. The scope of this certificate covers Clearwater Lumber’s log sourcing, sawmilling/manufacturing (including log yard, sawmill and dry kilns), and sales operations for softwood lumber products. Clearwater Lumber sources certified wood from its own forest lands.

1.2 Results of inspection

The first production of certified wood after additional employee training started late summer 2004. The total NET BFT of FSC logs purchased since the initial evaluation is approximately 74,883. Since the initial evaluation, only four orders have been processed for FSC sales resulting in a total of approximately 103,000 NET BF of sold lumber. The potential to sell more certified lumber after conversion (log BF to lumber BF) is high since an enormous amount of certified wood input is available and was processed, but not sold as certified (124,000 MBF of lumber could have been sold from processed FSC wood). See also Appendix D.

The evaluation revealed that Clearwater Lumber continues to have an effective control system for tracking, purchasing, inventory and sales. The company has a well-structured, computerized, and reliable documentation system that allows detailed and accurate tracking of wood products, from receipt of logs, through manufacturing, warehousing, invoicing, transport, and delivery. All responsible people have been sufficiently trained and understand all relevant FSC requirements. As a preparation for Clearwater Lumber’s 2006 audit, key people have been introduced by the auditor in the new FSC COC standards and understand their corresponding requirements (note certification took place against the FSC Policy on Percentage-based Claims from May 2000). Invoices, input/output documentation/calculations of FSC wood have been checked and the auditor confirms that all FSC requirements have been fully met.

1.2.1 Weaknesses identified in the control

Invoices send out to customers did not contain the phrase “FSC-certified” resulting in one Corrective Action Request.

1.2.2 Recommendations or conditions attached to certification

CAR 2005.1:

The phrase “FSC-certified” needs to be clearly printed on all sales documents, including invoices for certified product sold to customers.

Deadline: with immediate effect (corresponding instructions have already been forwarded to key people by the responsible manager Bill Highsmith during the audit).

1.2.3 The certification recommendation

The auditor recommends maintenance of certification, with one CAR, subject to acceptance by Clearwater Lumber of the CAR and schedule for reaching conformity contained in this report.

2. Background

Clearwater Lumber is a sawmill that purchases FSC logs from its own forestlands. In addition, the mill purchases one third of its logs on the open market.

2.1 Auditor

The auditor and author of this report is Dr. Wolfram R. Pinker, entrepreneur and former Director Chain-of-Custody Programs, Scientific Certification Systems. Dr. Pinker conducts audits as an independent contractor for SCS.

Wolfram Pinker headed SCS’ Chain-of-Custody division for more than 5 years until April 1, 2005 and has conducted numerous chain-of-custody certification evaluations and monitoring audits throughout the world over the past 5 years. He holds the following degrees:

  • Ph.D., Wood Industry Industrial Science, University of Freiburg, Germany
  • M.S., Forest Engineering, University of Freiburg, Germany
  • Licensed Environmental-Consultant, DEKRA Academy, Kaiserslautern, Germany

Before working in the certification field (for TFP/Germany and Scientific Certification Systems, Germany and USA), Dr. Pinker had extensive experience working in wood wholesaling as well as as a project manager responsible for the preparations to establish an environmental management system conferring to the EU-Eco(logical)-Audit-System for a sawmill/manufacturing and particleboard plant.

2.2 Previous assessments

This is the first annual monitoring audit of Clearwater Lumber. The first evaluation audit took place on April 12, 2004.

2.3 Field visits

2.3.1 Itinerary

April 28, 2005

09:15 AMIntroductions and overview

09:30 Discussion of chain-of-custody requirements

09:45 Discussion of control system and new FSC standards

10:15 Tour of mill

11:00 Continued discussion of key topics such as the new FSC standards

11:30Adjourn

2.3.2 Items and places inspected

The evaluation was conducted at the following location:

Clearwater Lumber Forest Products Industries

807 Mill Road, P.O. Box 1323, Lewiston, Idaho 83501, USA

2.3.3 Names and affiliations of people consulted

Mike McAllister – Regional Wood Flow and Marketing Manager

Bill Highsmith – Manufacturing Manager

Bryce Coulter - Supply Stream Manager (Log Yard Superintendent)

3. Scope of the assessment

The assessment addressed the effectiveness of the company’s control system for tracking, identifying and separating certified and non-certified materials through its manufacturing operations.

4. Supplier’s control system

4.1 Register of suppliers

Clearwater Lumber maintains a register of FSC-certified suppliers, and will request a copy of the valid chain-of-custody certificate from each FSC-certified supplier with which they choose to do business. These certificates will be kept on file. The company has their own forestlands as the solely supplier currently.

4.2 Ordering of certified goods

All purchase orders for certified product covered under this chain-of-custody certificate specify that the products be FSC-certified and that the supplier provides a valid chain-of-custody certificate number. Orders for certified product will have unique reference numbers, will be coded in the computer system as “FSC-certified,” and will be entered in the inventory system such that certified orders are clearly distinguishable from non-certified orders.

4.3 Receipt of certified goods

Clearwater Lumber receives delivery receipts and invoices from supplier(s) for certified goods that the company purchases. These documents are cross-checked to confirm that they match the order.

4.4 Inventory control

Clearwater Lumber has a computerized inventory control system. Logs received into inventory are based on species and sort. All incoming logs are clearly identifiable. The current plan is to further use 100 % certified input and to produce 100 % certified products. If percentage claims are desired, Clearwater Lumber will need to notify SCS and an extension audit may need to be conducted.

4.5 Sale of goods

A control system for the sale of certified goods has been established.

  • Cleawater Lumber’ valid chain-of-custody certificate number issued by SCS is clearly printed on all sales documents for certified product sold to customers.

Invoices send out to customers did not contain the phrase “FSC-certified” resulting in one Corrective Action Request:

  • The phrase “FSC-certified” needs to be clearly printed on all sales documents, including invoices for certified product sold to customers.

5. Observations of the system for controlling chain-of-custody

Below are observations made based on statements given and evidence presented during the site visit.

5.1 Principle 1: Documented control system

Clearwater Lumber has an effective control system for tracking purchases, inventory, and sales. The company has a well-structured, computerized, and reliable documentation system that allows detailed and accurate tracking/identifying of certified orders.

Valuation: The company meets the requirements of this criterion.

5.2 Principle 2: Confirmation of inputs

Certified products purchased by Clearwater Lumber are entered into the computerized inventory system as certified.

Valuation: The company meets the requirements of this criterion.

5.3 Principle 3: Separation and/or demarcation of certified and non-certified inputs

The company’s inventory control system is adequate for ensuring separation and demarcation of certified and non-certified inputs. The company has abundant yard space to create separate log decks for physical separation.

Valuation: The company will meet the requirements of this criterion.

5.4 Principle 4: Secure product labeling

Clearwater Lumber uses on-product labeling including the use of the FSC logo. All FSC logo usage requires prior approval by SCS. The company has done so in the past year for the old label and recently also received approval for the new FSC label.

5.5 Principle 5: Identification of certified outputs

A control system for the sale of certified goods has been established.

  • Clearwater Lumber’ valid chain-of-custody certificate number issued by SCS is clearly printed on all sales documents for certified product sold to customers.

Invoices send out to customers did not contain the phrase “FSC-certified” resulting in one Corrective Action Request:

  • The phrase “FSC-certified” needs to be clearly printed on all sales documents, including invoices for certified product sold to customers.

Valuation: The company meets the requirements of this criterion once CAR.2005.1 is addressed.

5.6 Principle 6: Record keeping

The current system of record-keeping appears to be reasonable and operational.

Valuation: The company meets the requirements of this criterion.

6. Risk assessment

6.1 Risk of contamination or confusion in product status

Based on the evaluation, the risk of contamination or confusion in product status appears very low. The company has a very pro-active attitude concerning inventory control and has state-of-the-art software for this purpose. Because of the company’s commitment to FSC, and the fact that the company cleans all production areas before producing FSC wood and solely runs FSC wood in batches plus its longtime experience to run batches with different species, the risk that non-qualifying material will be incorrectly treated as FSC-certified is insignificant.

7. Monitoring

Annual monitoring is required in order to maintain a valid chain-of-custody certificate. At the time of the second annual audit, SCS will evaluate progress made by Clearwater Lumber in meeting the CAR specified above.

8. Decision

This auditor recommends that Clearwater Lumber’s FSC/SCS certificate be maintained, with CAR, as stated in Section 1.2.2 above.

9. Acknowledgement and Agreement

I, Wolfram Pinker, representing Scientific Certification Systems, have executed the above evaluation and believe it to be accurate.

Wolfram Pinker04/30/05

______

signaturedate

I, Bill Highsmith, representing Clearwater Lumber Forest Products Industries, have read the preceding report and find it to be accurate. I also agree to fulfill the CAR for maintenance of certification according to issued decision.

______

signaturedate

Appendix A – Summary table of report requirements

Topic / Either Yes/No (if applicable) / Explanatory (short) answer (if applicable)
Manufacturing or distribution facility? / Manufacturing
Number of locations/facilities covered by the certificate? / One
1st evaluation or annual monitoring audit? / 1st annual monitoring audit
Solid wood products? / Yes
Chip and fibre products? / No
Collection products? / No
Assembled products? / No
All products 100% certified? / Yes
Percentage-based products? / No
If assembled products, calculation follows Section 1.3.2, Option 1 OR 2 OR Section 1.3.3. in Addendum II, Option3 in FSC COC Policy? / NA
Chip and fibre products with less than 70%? / NA
Use of % claim batch (i.e., not X% in product, but X% of the wood/fibre used in the manufacturing line comes from FSC-certified forests)? / No
Batch length (if applicable) (according to 1.4.1 in FSC COC Policy)? / NA
Contingency Plan required (according to 1.4.3 in FSC COC Policy)? / NA / Condition 2003.2 issued
Action Plan required (according to 1.5.2 in FSC COC Policy)? / NA
Policy on Controversial Sources required (according to 3.1 – 3.4 in FSC COC Policy)? / NA
Accurate use of FSC Trademarks and adherence of FSC Trademark claims to FSC Logo Guide? / Yes
On-product use of logos? / Yes
Off-product use of logos? / Yes
Existence of appropriate Documented Control System? / Yes
CAR in report? / Yes
Former conditions fulfilled? / Yes
Processing of certified wood during time of audit? / No
Additional use of environmental claims (e.g., for recycled/recovered wood/fibre)? / No
Report with appendices? / Yes
Existence of Outsourcing Agreements? / No
Appendix attached and/or sent via mail to SCS office? / NA

Appendix B – Additional general guidelines

The following sections are intended to provide detailed but generic guidance to all companies seeking COC certification.

I)

The company was advised and understands that Scientific Certification Systems must be immediately notified about any requested information plus changes in management circumstances and/or resource conditions that could materially impact the continued validity of the certification such as:

Fulfillment of Corrective Action Requests (CARS) / Conditions

Change in company name

Change in ownership

Change in contact name and address

Change in product name/category

Adding of new facility(ies) or termination of facility(ies) covered by the certificate

Commencement of new production line / wood species

Commencement of new wood species

Interruption of production for longer period

New production of %-based product or change of % content in product when not in range of certificate

New supplier name with certificate number

FSC/SCS logo and/or claims approval request

Incident report of incorrect claim or deviation from FSC regulations

FSC logo misuse by suppliers

Date of production start of certified products if initial audit was conducted during absence of certified material

Outsourcing

If applicable, change of batch length when different from length as described in report

Significant change in documented control procedures

Termination

etc.

II.a)

Furthermore, the company is requested to adhere to the following "general guidelines":

Invoices of certified wood sold to customers must include certificate registration code of certificate.

The design and use of on- or off-product labels must be coordinated and approved with SCS prior to use.

Mill managers, supervisors and employees working with certified materials, must be trained regarding the handling of certified products.

II.b)

The following guidelines must be followed only in individual circumstances (e.g., when manufacturing/distribution of percentage-based products, sales to retailers, no production during audit):

If production of percentage-based material (i.e., when less than 100% of the wood or fiber in the product(s) is certified), the minimum percentage of certified material in the product must be clearly stated not only on the on-product label, but also on any invoices and product descriptions.

In case the company produces percentage-based assembled products or uses percentage-based MDF/particleboard/hardboard material or other percentage-based materials, before labeling of the product, company staff must specify the percentage of certified content for all wood-based products to be included in a certified final product, and calculate the aggregate percentage, based on the rules outlined in the FSC Policy on Percentage-Based Claims, May 15, 2000. These calculations must be made available to SCS on request.

If the company intends to use percentage-based chip and fiber products (MDF, particleboard, etc.) with less than 70%-certified content or other products described under 3.1 and 3.3 of the FSC Policy on Percentage Based claims dated 15 May 2000, the company must have a policy, publicly available on request, to avoid wood from controversial sources described in section 3.1 to 3.3 of the FSC Policy on Percentage Based claims dated 15 May 2000 (Tracking and Monitoring System).

If production with batch system, the company must establish an effective system which measures and records reliable data to confirm the volumes and / or weight of certified and non-certified inputs over a specified production period. Additionally, an appropriate contingency plan must be in place in order to ensure that the rolling mean (average) will be maintained above the minimum threshold over time and to prevent the application of the FSC trademarks to products produced after the rolling mean drops below the threshold. (Principle 3.3 of FSC Chain of Custody certification standard and 1.4.3 of FSC policy on percentage based claims May 15, 2000).

Products must be individually labeled if the product is sold to a retailer. Retailers sell to end-consumers and end-consumers may not see the difference between cert. and non-certified products if not labeled. [Trademark Policy Manual 3.1.2: "The FSC Trademarks may be used by Non-Certificate holders, such as retailers, and others, to promote the sale of products that have already been labeled with the FSC Logo and are covered by a Chain-of-Custody invoice from the Certificate Holder (Vendor)."]