The Development and Approval of Controlled Wood National Risk Assessments

© 2012 Forest Stewardship Council A.C. All rights reserved.

Title: / The Development and Approval of Controlled Wood National Risk Assessments
Document reference code: / FSC-PRO-60-002 (V3-0) EN
Scope: / International
Approval:
Contact: / FSC International CenterGmbH
- Policy and Standards Unit -
Charles-de-Gaulle Str. 5
53113 Bonn, Germany
Phone: +49-228-367-66-0
Fax: +49-228-367-66-30
E-mail for comments: /
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THE DEVELOPMENT AND APPROVAL OF CONTROLLED WOOD NATIONAL RISK ASSESSMENTS

FSC-PRO-60-002 (V3-0) EN

DRAFT0-3

The Forest Stewardship Council® (FSC) is an independent, not for profit, non-government organization established to promote environmentally appropriate, socially beneficial, and economically viable management of the world's forests.
FSC’s vision is that the world’s forests meet the social, ecological, and economic rights and needs of the present generation without compromising those of future generations.

Introduction

The FSC Controlled Wood standard FSC-STD-40-005 aims to ensure the avoidance of unacceptable material[1] in FSC Mix products.

There are different options for an FSC-certified manufacturer or trader to avoid buying material from unacceptable sources:

1Purchase wood from Organizations verified by an FSC accredited Certification Body (CB) to meet the requirements of FSC-STD-30-010 FSC Controlled Wood standard for forest management enterprises.

2Purchase FSC Controlled Wood from suppliers holding a valid FSC Chain of Custody certificate which includes FSC Controlled Wood in its scope; and

3Internally verify its wood sources according to the requirements of FSC-STD-40-005 Company evaluation of FSC Controlled Wood.

For Option 3 above, the company must implement a verification program in order to determine whether the sources are “low risk” or “unspecified risk”.

In situations where a company is sourcing from a country without an FSC-approved National Risk Assessment, then a company-developed risk assessment of suppliers (i.e., the Annex 2 process of the Controlled Wood standard) may be used. Where FSC-approved National Risk Assessments are present, its use is mandatory in assessing the risk of supplies according to Annex 2 of the Controlled Wood standard.

Following Policy Motion 51 from the 2011 FSC General Assembly, there will be a phase-out of Annex 2 company risk assessments by 31 December 2012. After this phase-out, FSC- approved National Risk Assessments (NRA) will be used by companies seeking Controlled Wood. [Note, in areas designated as “unspecified risk”, companies will still be able to implement Annex 3 of FSC-STD-40-005 for sourcing Controlled Wood].

With this decision comes the need for slight revisions to, and further guidance on, the formal procedures for developing and maintaining National Risk Assessments. This procedure (FSC-PRO-60-002 V3) serves that goal.

Considering the phase-out of company risk assessments by the end of 2012:

• Countries without an FSC-approved National Risk Assessment will be considered “unspecified risk.”
• Regions and/or forest types within a country not designated as “low risk” will beconsidered “unspecified risk.”
• Controlled Wood categories not designated as “low risk” will beconsidered “unspecified risk.”

For all sources located in areas designated as “unspecified risk” in the National Risk Assessment, the company will be able to implement the Annex 3 company verification program of the Controlled Wood standard (FSC-STD-40-005). Only the categories designated as “unspecified risk” will need to be evaluated according to Annex 3 requirements. For example, if a district within a country is designated “unspecified risk” for HCVs and “low risk” for the other four categories, then the Annex 3 process will only need to include HCVs.

For specific Controlled Wood categories and in situations where different countries share homogeneous conditions regarding any of the Controlled Wood categories (e.g., sharing ecoregions regarding HCVs), it is possible to develop a single Controlled Wood Risk Assessment shared and applicable to the relevant countries.

Content

AObjective

BScope

CEffective and validity date

DReferences

ETerms and definitions

Part I GENERAL REQUIREMENTS

1.Responsibilities

PART II DEVELOPMENTOF NATIONAL RISK ASSESSMENTS

2.Proposal to develop National Risk Assessments

3.Drafting National Risk Assessments

4.Stakeholder consultation

5.National level decision

PART III EVALUATION AND APPROVAL OF NATIONAL RISK ASSESSMENTS

6.Evaluation of National Risk Assessments

7.Approval of National Risk Assessments

PART IV MAINTENANCE OF NATIONAL RISK ASSESSMENTS

8.Review of National Risk Assessments

9.Revision of National Risk Assessments

PART V MISCELLANEOUS

10.New evidence, complaints and disputes

11.FSC Intervention

Annex 1Guidance on developing a Controlled Wood National Risk Assessment

Annex 2Stakeholders to be included in consultation process

Annex 3Risk Assessment Evaluation template

A Objective

The objective of this procedure is to provide a clear, transparent, and unambiguous methodology to develop, maintain, revise, evaluate, and approve Controlled Wood National Risk Assessments (NRAs).

BScope

This document specifies the requirements and procedures to be followed by FSC Network Partners or other authorized entities to develop, maintain and revise Controlled Wood National Risk Assessmentsand for FSC to evaluate and approve these Risk Assessments.

All aspects of this procedure are considered to be normative, including the scope, effective date, references, terms and definitions, tables and annexes, unless otherwise stated.

CEffective and validity dates

Effective date / 01 July 2012
Mandatory date / 01 July 2012
Period of validity / Until 31 December 2016

DReferences

FSC-STD-01-002 FSC Glossary of Terms

FSC-STD-40-005 (Version 2-1) Company evaluation of FSC Controlled Wood

ETerms and definitions

For the purpose of this procedure, the terms and definitions given in FSC-STD-01-002 FSC Glossary of Terms, and the following apply:

Facilitator:In the context of this procedure, the personor group responsible for managing the development of the FSC Controlled Wood National Risk Assessment.

PART IGENERAL REQUIREMENTS

1Responsibilities

1.1The responsibility for development, maintenance and revision of Controlled Wood National Risk Assessments (NRAs) primarily lies with the FSC endorsed Network Partner (National Office, National Representative, National Focal Point).

1.2In countries where Network Partners are not established, or are not able to coordinate NRAs, FSC may authorize another entity with the implementation of this procedure, for example the FSC Standards Development Group. These decisions will be made on a case-by-case basis, in consultation with the Director of the applicable FSC Regional Office and the Director of FSC’s Network Unit, based on the following criteria:

a)Capacity to professionally implement the requirements in this procedure;

b)Ability to coordinate the process free of any conflict of interest;

c)Acceptance by key stakeholders.

PART II DEVELOPMENT OF NATIONAL RISK ASSESSMENTS

2Proposal to develop National Risk Assessments

2.1A proposal shall be submitted to FSC[2]prior to the development of aNRA, including the following elements:

a)Objective, including the scope of the work in terms of CW categories and geographic area;

b)Summarized work plan and schedule, including start date and expected date of submission;

c)Estimated budget and indication of funding needs;

d)Name and contact details of the Network Partner, Standards Development Grouporanyother entity authorizeby FSC to oversee the process;

e)Name and contact details of the Facilitator nominated to manage the development of the NRA.

NOTE: With the exception of the requirements specified above, there is no set work-plan that must be followed; flexibility is needed in order to allow a process to take place that is meaningful within the national context. For guidance and suggestions on what might be included in the work-plan, please see Annex 1.

2.2Proposals to develop a NRAshall be submittedin writing to FSCin English or Spanish.

2.3FSCshall confirm receipt of the proposal and within ten (10) working daysshall either:

a)Confirm that the proposal has been approved; or

b)Reject the proposal, communicating the reasons for rejection.

2.4Upon approval of a proposal, FSC shall update its Controlled Wood webpage with this information in order to keep stakeholders informed about the process.

3Drafting National Risk Assessments

3.1 At minimum, the following drafts shall be prepared;

a) a first draft, which shall be widely distributed to stakeholders for comment;

b) a second draft, which takes account of stakeholders comments;

c) a final draft for submission to FSC (see Section 6.2, below).

NOTE: The need for additional drafts shall be at the discretion of the oversight body (e.g., Network Partner, Standards Development Group), taking account of the number and substance of comments received.

3.2 The content of the NRA shall follow the requirements of FSC-STD-40-005 Annex 2. For the NRA evaluation template please see Annex 2 of this procedure.

3.3 In addition to defining risk designations, the NRAshould also provide detailed information to support companies sourcing from areas designated as “unspecified risk” and implementing an Annex 3 verification program. Information may include:

a)Data sets and other resources specific to the area, particularly for HCVs, which can be used to determine “low risk” or “unspecified risk” at the forest management unit (FMU) level;

b)Any issues, sub-areas and/or FMUs of concern within the area;

c)Relevant stakeholders to contact as part of the stakeholder consultation requirements.

3.4The Facilitator shall send the first draft and stakeholder comments to FSC for review.

4Stakeholder consultation

4.1The Facilitator shall be proactive in seeking input from representatives of stakeholder groups identified in Annex 3 of this procedure. Special provisions shall be taken to ensure that formal comments are received from representatives of any marginalized groups that may be affected by the NRA.

4.2The information sent to stakeholdersfor consultation shall include the following:

a)Abrief description of the FSC Controlled Wood concept (ref. FSC-STD-40-005);

b)A brief description of the purpose of the FSC Controlled Wood National Risk Assessmentand the role of stakeholders, including a request for comments;

c)The end date of the stakeholder consultation period;

d)The draft NRA;

e)The contact details of the Facilitator for further information;

f)The estimated timeline for completion of the proposed NRA;

g)A brief description of how the NRA will be maintained upon approval, including the complaints mechanism and the incorporation of new information;

h)A statement that the development process follows the requirements of this FSC procedure.

4.3The request for stakeholder comments shall also be posted on the Network Partner webpage, where existing, including the information listed in Clause 4.2.

NOTE: FSC will place this information on the FSC International Controlled Wood webpage.

4.4 A public consultation round shall consist of a period of at least thirty (30)daysfrom the date of publication.

4.5Interactive methods for engaging stakeholders should be applied. In addition to submitting draft(s) of the NRA for stakeholder comments, the Facilitator should also consider holding stakeholder workshop(s) to provide a forum for direct input and discussion.

4.6The Facilitator shall review all comments submitted by stakeholders and shall consider them, as possible, in subsequent drafts and with the goal of achieving consensus across all stakeholder groups.

4.7The Facilitator shall prepare a consultation report that includes:

a)A summary of the issues raised;

b)An analysis of the range of stakeholder groups who submitted comments;

c)A general response to the comments;

d)An indication of how they have been taken into account in subsequent public drafts; and

e)A copy of all the comments as an Annex.

4.8For consideration, all comments shall be attributed to a stakeholder.

4.9All comments shall be publicly available. Stakeholders may request that their comments be treated confidentially.

5National level decision

5.1The NRAshall first be approved at the national level prior to being submitted to FSC for final decision making.

NOTE: Where FSC National Office Boards of Directors exist, they shall assume the role of the approval body. In cases where FSC National Offices are not established, the decision-making should be done by to the Standards Development Group or any other group employed and designatedfor this purpose.

5.2 The final draft of the NRAshould be approved when it:

a)Has undergone sufficient stakeholder consultation;

b)Meets the elements in the work plan;

c)Merits the approval by FSC.

5.3If approval cannot be secured within the time specified in the workplan, then the Facilitator shall seek the advice of FSCas to how to proceed.

PART III EVALUATION AND APPROVAL OF NATIONAL RISK ASSESSMENTS

6Evaluation of National Risk Assessments

6.1Final drafts of NRAs may be sent to FSC at any time after they have been approved by the national level decision-making process.

6.2 The application for decisionshall include the following documentation:

a)A brief application letter, signed by the representative of the submitting body;

b)The final draft NRA, in English;

c)A copy of the stakeholder consultation report, including the list of stakeholders contacted, and their affiliation;

d)Any other documented evidence that the applicant deems relevant to demonstrate compliance with the requirements specified in this procedure (e.g., minutes of meetings).

6.3FSC shall evaluatethe application for compliance with formal requirements as specified in this procedure, using the PSU evaluation checklist in Annex 3.

7Approval of National Risk Assessments

7.1Within thirty (30) daysof receiving the application, the FSC Policy and Standards Director shall take a decision based on the evaluation results by either:

a)Approving the NRA; or

b)Approvingthe NRA with minor amendments; or

c)Rejecting the NRA.

NOTE: If the FSC Policy and Standards Director rejects the NRA, the reasons for the rejection will be communicated together with a suggestionon steps necessary to address the concerns.

7.2Upon approval, the NRA will be publicly announced and published on the Global Forest Registry (

PART IVMAINTENANCEOF NATIONAL RISK ASSESSMENTS

8Review of National Risk Assessments

8.1The responsibility to maintain, review and revise NRAsas well as handling complaints and other issues that arise in relation to the NRA, lies with the respective Network Partner (see Clause 1.1, above), or the entity designated by FSC to maintain the NRA (see Clause 1.2, above).

8.2If for any reason the designated Network Partner (or other designated entity)is no longer able to exercise this responsibility (e.g., if a Network Partner ceases to exist), then the FSC Policy and Standards Unit shall take direct control over the NRAuntil a new responsible person or entity is assigned.

8.3Following the approval of the NRA, all comments, proposals for revision, results from disputes and anyother information that may require a revision(e.g., changed CPI) shall be collected, evaluated and recorded.

8.4 Each NRA shall be reviewed at regular intervals (at least every 3 years), for its continued correctness and completeness.

8.5If substantial evidence (e.g., complaints, new information) is available which may affect the correctness and completeness of the current risk designation, a faster review process outside of the regular schedule shall be conducted.

8.6On the basis of the review results, a decision shall be taken to either:

a)Maintain the NRA with no required revision; or

b)Initiate a revision process according to this procedure.

8.7A brief review report, summarizing the results and conclusions of the review process shall be submitted to the FSC Policy and Standards Unit.

9Revision of National Risk Assessments

9.1A revision process shall be conducted according to Part II and III of this procedure.

9.2Administrative and typographical mistakes may be corrected at any time with formal approval by FSC. In this case, the updated NRAshall be given a new 2nd-level version number (e.g., V1-1, V1-2), together with the date of the update, and shall be sent to the FSC Policy and Standards Unit for publication on the Global Forest Register.

9.3In the case of a normal revision process, the revised NRA shall be given a new 1st-level version number (e.g., V2-0, V3-0), together with the date of the update.

PART VMISCELLANEOUS

10New evidence, complaints and disputes

10.1 New evidence, complaints or disputes related to an approved NRA shall be responded to by the designated person or entity. Should the complaint/dispute substantively affect the NRA, then it shall be considered according to Clause 5.5 of this procedure.

10.2Complaints and disputes should first be solved informally by the involved parties (see FSC-PRO-01-008). If an informal resolution is not possible, a formal complaint may be lodged with FSC according to FSC-PRO-01-009.

11FSC Intervention

11.1FSC may invalidate aNRA in part or in full as a result of a complaints process or if a review / revision process was not done according to procedures.

Annex 1: Guidance on developing a Controlled Wood National Risk Assessment [STILL UNDER DEVELOPMENT]

The following steps build off recommendations from Network Partners and lessons learned during the NRA pilot phase. These are not requirements, but rather should be taken as guidance as countries develop workplans specific to their needs.

Step 1:Project initiation

• Determine Facilitator and chamber-balanced Working Group to provide oversight, management and decision-making to the process
• Establish clear Terms of Reference
• Develop methodology and workplan
• Submit notification to FSC PSU
• Develop a communications plan to keep stakeholders informed of process

Step 2: Training

• Arrange for key personnel to receive training on the Controlled Wood standard, and the process for developing a National Risk Assessment
• See NEPCon training materials, available at: [soon to be made available]

Step 3: Data gathering (this may be implemented by technical expert consultant)

• Review existing National Risk Assessments
• Review existing company risk assessments for the sourcing country
• Analyze country-level data sets for the five Controlled Wood risk categories, as listed in FSC-STD-40-005
• See FSC Guidance document on risk designations [soon to be made available]

Step 4: Develop Baseline Risk Assessment (Draft 0) (may be done by expert consultant)