FSC Chain-of-Custody Certification Report
for
Potlatch Corporation – St. Maries Plywood

2200 Railroad Avenue, St. Maries,

Idaho 83861, USA

Chain-of-Custody Registration Number SCS-COC-00623

Scientific Certification Systems

2000 Powell Street, Suite 1350

Emeryville, California 94608, USA

Report completed: April 14, 2004

Auditor and Author:

Wolfram R. Pinker, Ph.D.

Site evaluation conducted: April 13, 2004

Scope: The certificate covers manufacturing of veneer and plywood products.

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......

Appendix A – Summary table of report requirements......

Appendix B – Additional general guidelines......

CONTACT PERSON INFORMATION

Legal company name: Potlatch Corporation – St. Maries Plywood

Name of Contact Person: Greg Cooperrider

Address: 2200 Railroad Avenue, St. Maries, Idaho 83861, USA

Telephone: 208-245-7535

FAX: 208-245-7542

E-mail:

Approximate Annual FSC Product Quantity: NA

Species covered: dougfir, hemfir, larch, poplar

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

AAF: 43 Million

Chain of Custody Certification Report: Potlach Corporation – St. Maries Plywood Page 1 of 10

1. Summary

1.1 Scope

Potlach Corporation – St. Maries Plywood (hereafter St. Maries Plywood) is a custom manufacturer of veneer and plywood. The scope of this certificate covers St. Maries Plywood’s sourcing, warehousing, manufacturing, and sales functions.

1.2 Results of inspection

The evaluation revealed that St. Maries Plywood has an effective control system for sourcing, tracking, manufacturing, inventory and sales. The company has a well-structured, computerized, and reliable documentation system that allows detailed and accurate tracking of orders, from issuance of purchase/delivery orders, through warehousing and manufacturing, to invoicing, transport, and delivery.

1.2.1 Weaknesses identified in the control

The company has finalized a written procedures document that details its procedures for tracking and separating/identifying FSC products (see Appendix C). Additional staff training to familiarize staff with FSC requirements however will need to be done short before the first run of FSC products.

1.2.2 Recommendations or conditions attached to certification

Condition 2004.1:

Employees working with certified materials, must be additionally trained regarding the handling of certified products. The education program need not be extensive; however, it should focus on informing all pertinent employees of the procedures for maintaining FSC protocol.

Deadline: Before start of production of FSC products.

1.2.3 The certification recommendation

The auditor recommends certification, with one condition.

2. Background

St. Maries Plywood is a veneer and plywood manufacturer. St. Maries Plywood will purchase FSC logs from its own forestlands. In addition, the mill purchases one third of its logs on the open market. Because the own forestland has undergone FSC forest management certification (certification announcement will be in the 3rd week of April 2004) the mill will be able to process and sell FSC certified products to its customers once the FM/COC certificate is awarded soon.

2.1 Auditor

The auditor and author of this report is Wolfram R. Pinker, Director Chain-of-Custody, Scientific Certification Systems.

Wolfram Pinker heads SCS’ Chain-of-Custody division and has conducted numerous chain-of-custody certification evaluations 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 assessment of St. Maries Plywood.

2.3 Field visits

2.3.1 Itinerary

April 13, 2004 – Audit and review of procedures at plant

7:30 amFlight from Lewiston to St. Maries

8:45 Introductions and overview

9:15Discussion of chain-of-custody requirements

9:45Discussion of control system

10:15Tour of mill

12:00Continued discussion of key topics

01:30 pmAdjourn

2.3.2 Items and places inspected

St. Maries Plywood Forest Products Industries

2200 Railroad Avenue, St. Maries, Idaho 83861, USA

Areas inspected: Log yard, Plywood Plant, (Dry Kilns, Planer Mill, Sawmill)

2.3.3 Names and affiliations of people consulted

Mike McAllister – Regional Wood Flow and Marketing Manager

Greg Cooperrider – Plant Manager

Bill Kopp – Plywood Superintendent

Bernie Wilmarth – Log Yard Superintendent

Tony Flagor – Sawmill Superintendent / Maintenance Dept.

3. Scope of the assessment

The assessment addressed the effectiveness of the company’s control system for tracking and separating certified and non-certified materials in its veneer and plywood manufacturing operations in St. Maries, Idaho. At the time of the evaluation, no certified orders were in process, and the company had recently established procedures that address the FSC chain-of-custody requirements.

4. Supplier’s control system

4.1 Register of suppliers

St. Maries Plywood will maintain 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 in the unlikely event that wood is sourced from other than their own forestlands. These certificates will be kept on file. Otherwise, delivery papers will indicate the certified status.

4.2 Ordering of certified goods

All purchase orders for certified product covered under this chain-of-custody certificate will specify that the products be FSC-certified and that the supplier provide 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

St. Maries Plywood will receive delivery receipts and if applicable invoices from suppliers for certified goods that the company purchases. These documents will be cross-checked to confirm that they match the order.

4.4 Inventory control

St. Maries Plywood has a computerized inventory control system. All purchased materials are entered into the computerized inventory system at the time they are received. The company has adequate yard space to dedicate an area for exclusive storage of FSC products. At the time of receipt, special labels designating FSC status will be affixed to units of FSC lumber or other instruments for identification apply (see also Appendix C). The company will maintain computer files to track FSC inventory and orders. In addition, the company will place all paperwork related to FSC purchases and sales in clearly marked file.

4.5 Sale of goods

A control system for the sale of certified goods has already been tentatively established. The following procedures were agreed upon by St. Maries Plywood staff at the time of the evaluation.

  • The phrase “FSC-certified” will be clearly printed on all sales documents, including invoices, for certified product sold to customers.
  • St. Maries Plywood’s valid chain-of-custody certificate number issued by SCS will be clearly printed on all sales documents 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

St. Maries Plywood 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. Training of staff will need to be executed to additionally familiarize staff with FSC requirements short before the first run of FSC products. Therefore, Condition 2004.1 has been issued.

Valuation: By meeting the terms of Condition 2004.1, the company will meet the requirements of this criterion.

5.2 Principle 2: Confirmation of inputs

Certified products purchased by St. Maries Plywood will be 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 and in-factory space to create separate log decks and semi and fished product stacks for physical separation.

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

5.4 Principle 4: Secure product labeling

St. Maries Plywood will be using on-product labeling including the use of the FSC logo. All FSC logo usage requires prior approval by SCS, which the company has been informed of and agreed to.

Valuation: The company meets the requirements of this criterion.

5.5 Principle 5: Identification of certified outputs

Certified product sales will be tracked using the company’s computerized documentation system, which allows for ready identification of certified outputs.

Valuation: The company meets the requirements of this criterion.

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 is already quite familiar with the FSC requirements for chain of custody. Because the company currently processes all orders on a custom, batch basis, there is no reason to believe the company will have any difficulties in adhering to the FSC requirements for ensuring FSC-certified products are properly tracked and separated throughout handling and storage.

7. Monitoring

Annual monitoring is required in order to maintain a valid chain-of-custody certificate. .

8. Decision

This auditor recommends that St. Maries Plywood be awarded certification, with one condition.

9. Acknowledgement and Agreement

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

Wolfram Pinker04/15/04

______

signaturedate

I, Greg Cooperrider, representing St. Maries Plywood, have read the preceding report and find it to be accurate. I also agree to fulfill the conditions (if applicable) for 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? / Yes / Manufacturing
Number of locations/facilities covered by the certificate? / One
1st evaluation or annual monitoring audit? / 1st evaluation
Solid wood products? / Yes
Chip and fibre products? / No
Collection products? / No
Assembled products? / Yes
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 / All products produced on a custom basis
Contingency Plan required (according to 1.4.3 in FSC COC Policy)? / No
Action Plan required (according to 1.5.2 in FSC COC Policy)? / No / No chip and fiber products
Policy on Controversial Sources required (according to 3.1 – 3.4 in FSC COC Policy)? / No
Accurate use of FSC Trademarks and adherence of FSC Trademark claims to FSC Logo Guide? / Yes
On-product use of logos? / Yes / Planned
Off-product use of logos? / Yes / Planned
Existence of appropriate Documented Control System? / Yes
Conditions in report? / Yes
CARs, former conditions fulfilled? / NA
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? / Yes

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)."]

If no purchasing, storing and production of FSC-certified material will take place before issuance of the certificate, the company must notify Scientific Certification Systems with start of any purchasing, storing, and production processes. Scientific Certification Systems reserves the right to consider an additional monitoring audit at the time of commencing the FSC production process to confirm adherence to FSC protocol. Before the materials used in the process are FSC certified, the company is only permitted to make claims directly with the possible suppliers of FSC certified products in order to establish commercial links. The company can also communicate to their commercial clients in a business to business communication to show their progress and commitment for FSC certification. Those claims must not be exaggerated. In all cases; information shall not imply by fact or omission that products are already FSC certified before materials used in the process are FSC certified. These permitted claims must be checked by SCS to ensure that the claims are not exaggerated, confusing or misleading. The use of the FSC Logo is NOT allowed to accompany any of these claims before the materials used in the process are FSC certified.