FSC-STD-40-005 (V3-1)

 

  • Date of approval: 11 November 2015
  • Date of publishing: 18 December 2015
  • Date of entry into force: 01 July 2016
  • End of transition period: 31 december 2017

Transition to the new standard

What is new?

 

The need to align to the European requirements from the forest sector – EU Timber Regulation (EUTR), as well as the comments sent over time by certificate holders or various stakeholders, has led the Forest Stewardship Council (FSC) to develop a new standard regarding the supply of Controlled Wood. Unlike the previous standard (FSC-STD-40-005 V2-1) designed to be a verification program, the new standard FSC-STD-40-005 V3-0 (V3-1) essentially requires the adoption of a Due Diligence (DDS) prevention system that companies have to put in place to define the measures and the procedures to be taken to assess and reduce the risks regarding the supply with wood material from unacceptable sources.

Note: The changes between the two versions are shown in ANNEX HThe matrix of changes between versions 2-1 and 3-1 of the standard.

What type of risk assessment do we apply?

According to the new controlled wood standard, the risk assessment related to the origin of wood for a particular supply area can only be achieved by the companies concerned unless there is already a risk assessment approved by FSC (i.e. the National Risk Assessment for Controlled Wood – NRA or the Centralized Risk Assessment at National Level – CNRA).
The hierarchy of risk assessments that can be used to implement this standard is shown below:


The FSC is currently developing the Centralized Risk Assessment at National Level for Romania, the approval of the document being estimated to take place at the end of September, 2017. While waiting for the CNRA, the Romanian companies shall use the National Risk Assessment (NRA) drawn up in accordance with FSC-PRO-60-002 V2-0, plus a risk assessment made by each company.
For more details on the CNRA process, go to the Risk Assessment – About CNRA menu.

Part I: Due Dilligence System [DDS]

Implementing and maintaining a due diligence system:
The organization must have, implement and maintain a documented due diligence system (DDS) [prior checks system] for the material procurement without FSC statement, to be used as controlled material or marketed with the FSC Controlled Wood statement

  • The organization can choose to draw up its own DDS or apply one drawn up by an external party.
  • The organization must include in its own DDS all suppliers and sub-suppliers of material assessed in accordance with this standard.
  • The organization must provide access to evidence of compliance with the applicable requirements of this standard, including access to documents, prosecutors’ offices, premises of suppliers and sub-suppliers, where relevant.
  • The organization must analyse and, if necessary, revise its DDS system at least annually and whenever changes that affect its relevance, effectiveness, or suitability occur.
  • The organization must conduct internal audits of its own DDS system at least once a year to ensure that it is properly implemented.
  • The organization must document the scope, data and personnel involved in the internal audits.

 

The key elements of the DDS system to be implemented according to the standard are:

1. Obtaining information on the material (species) and its origin (supply area)
The organization must have access to information on its supply chains (including sub-suppliers) at a level that allows it to confirm and document:
a) The origin of the material;
b) The risk of the origin and the risk of mixing with ineligible raw materials in the supply chain; and
c) The risk reduction.

2. Assessing the risks of placing wood material from unacceptable sources on the market
The risk is analysed from the following perspectives:
a) Origin – this involves the risk of buying from unacceptable sources, where unacceptable management practices or related activities occur. This risk is assessed for a particular geographical area in accordance with the applicable risk assessment requirements through the NRA (National Risk Assessment), CNRA (Centralized Risk Assessment) or the organization’s own risk assessment.
b) Supply chain through which the material is purchased – this risk involves analysing what is happening with the material (which was harvested in an area where a particular risk according to point ‘a’ above was identified) in the chain(s) of supply. This includes the risk that the material is mixed with ineligible purchases or material of different origins, which does not allow the confirmation of the origin risk. This risk is specific to the organization and additional to point ‘a’ above.

In order to reduce the risk effectively, both perspectives have to be taken into account and risk reduction measures should be applied at the appropriate level of the supply chain.

In practical terms and from the perspective of the organization, a risk assessment is a careful analysis of its supply chain to identify situations, processes, etc. that may result in purchases of unacceptable or ineligible material in the supply chains. After the risk assessment, the organization assesses the probability and severity of the risk in its operations and then decides which control measures are necessary to prevent and implements them.

3. Establishing the control measures to reduce each identified specific risk.
The organization must have and implement appropriate control measures to reduce the identified risk regarding the origin and/or the risk of mixing with ineligible material in the supply chain.

NOTE: The examples of control measures and guidance for their development are presented in Annex E.
IMPORTANT: To comply with EUTR requirements, the implementation of risk reduction measures is made BEFORE the placing on the market of the wood material.

Part II: Management Quality System

1. Competence, documentation and records
The organization must nominate a management representative responsible for the compliance by the organization with all applicable requirements of this standard.

All those employees must demonstrate knowledge of the procedures of the organization and competence in the implementation of the applicable requirements of this standard.

The organization must keep records and documents demonstrating compliance with this standard and ensure that they are readily available to the certification body.

The organization must keep all relevant records for at least five (5) years.

2. Publicly available information
The organization must provide a written summary of its DDS system to the certification body.

3. Stakeholder participation and complaints
The organization must draw up and implement a documented procedure for the comments and complaints related to the DDS system received from stakeholders.
The procedure should include mechanisms for:

  • Confirming the receipt of complaints;
  • Informing stakeholders about the complaints procedure and sending an initial response to the complainers within two (2) weeks;
  • Dialogue with the complainers in order to resolve the complaints assessed as substantial before taking other measures;
  • Transmitting the substantive complaints to the certification body and the FSC National Bureau relevant to the supplying area within two (2) weeks of receiving the complaint;
  • Using cautious approach in continuing to acquire relevant material as long as the complaint is active;
  • Establishing the corrective action to be taken by the suppliers and their means of enforcement if a complaint has been assessed and verified as substantial;
  • Exclusion of the material and suppliers from the supply chain if no corrective action has been taken;
  • Registration and ranking of all complaints received and the measures taken.

NOTE: The minimum requirements for consultation of stakeholders to be complied with are found in ANNEX B.