Hearings and Business Meetings
411 West 8th Street, Medford, Oregon Medford City Council Chambers 12:00 PM
Vice President of Operations, US Forest Stewardship Council
Edward J. Daly
Chief Operating Officer
Forest Stewardship Council – US
Committee on Energy and Natural Resources
Senator Wyden and Subcommittee Members,
Thank you for the opportunity to testify before the subcommittee today.
My testimony will cover how the Forest Stewardship Council supports and promotes companies with exemplary practices like the over 70 Oregon-based companies certified by FSC, what FSC is doing in China to reduce the impact of illegal and unsustainable wood and paper products on the global marketplace, and the challenges we see moving forward in China. I will address these issues in general, but they all apply to the market for hardwood plywood in the
FSC certification is a complicated system of standards, policies, principles, criteria and indicators necessary to implement and oversee a global standard for environmentally and socially responsible timber production. As a way of introduction, there is an easier way to think about FSC certification—Ebay for sustainable timber.
There are companies like Collins Pine, Warm Springs Forest Products and
At the same time there are consumers, both institutional and individual who would like to buy products that are sustainably produced, or more importantly, not from illegal or destructive practices.
There are also advocates for conservation, sustainable forest management and healthy rural communities that would like to have positive alternatives in the marketplace that they can direct consumers to.
Like Ebay, through a set of policies that legitimize the transactions in that marketplace and the establishment of a network of buyers and sellers, FSC is able to provide good producers and manufacturers a way to distinguish themselves in the marketplace, allows consumers to identify sustainable wood products and allows advocates to partner with sustainable companies to promote wood and paper products that support communities and the environment.
FSC believes that working forests are an integral and necessary component to forest conservation. With the growing impacts of conversion from sources like agricultural expansion and development, working forest a essential to provide value to standing forests and keep the forests standing.
What is FSC?
Since its inception in 1993, the Forest Stewardship Council has emerged as a globally influential system for transforming forestry around the world by reaching areas where other conservation strategies or government policies have fallen short. The Forest Stewardship Council is an independent, nonprofit organization that promotes the responsible management of the world’s working forests through the development of forest management standards, a voluntary certification system, and trademarks that provide recognition and value to products bearing the FSC label in the marketplace.
FSC standards have been applied on more than 225 million acres of actively managed forests in more than 70 countries, and growing steadily. In 1994, FSC’s members approved an international set of Principles and Criteria that define FSC’s threshold for responsible forestry practices worldwide. These standards support biodiversity, reduce chemical use, protect streams and aquatic communities, conserve old growth, ensure protection of high conservation value forests, give stakeholders a voice, and ensure long-term timber supplies. Specific regional standards are developed in countries to interpret and operationalize the original Principles and Criteria in order to manage specific, local forest compositions. The regional standards were developed through a unique consensus process that allows for and actively seeks participation from all interested parties.
Manufacturers and distributors of wood and paper products are required to have a “chain-of-custody” certification in order to label and sell FSC-certified products. Chain-of-custody certification is the process through which wood and fiber are tracked from their original point of harvest through the manufacturing process. FSC is a credible system because consumers can be confident that their purchase of wood or paper is truly linked directly back to the practice of certified forestry on the ground. FSC has 5,646 certified chain-of-custody companies in 73 countries.
With 37 national offices and representation in every major forest producing country, FSC and its partners are creating a marketplace that demands well-managed forestry practices. Moreover, NGOs, businesses, government agencies, financial institutions, and landowners increasingly use FSC standards as an important land conservation tool, a vehicle to implement corporate social responsibility practices, and a strategy for product differentiation in the marketplace. Through use of the FSC certification system, institutions of all kinds can ensure their commitments to high standards of forest management.
Demand for certified products is “pulling” acres into the FSC system. As certification gains recognition as the screen through which individual and commercial customers view their purchases, the most egregious forest practices are denied a place in the market. In short, the investment made to develop and apply FSC standards over the past decade is paying off in conservation benefits, such as protection of wildlife habitats, improved water quality, sustained availability of timber resources, and increased recognition that forestry can be practiced sustainably. With illegal logging still rampant in many parts of the world and wood and paper demands expected to grow over the next 50 years, the need for FSC standards as a conservation tool is greater than ever before.
Evidence of such demand pull are the numerous companies that have FSC procurement policies including Home Depot, Lowes, Crate and Barrel, Pier 1, Williams-Sonoma, Pottery Barn, JP Morgan, Bank of America, PNC Bank, Random House, Scholastic Publishing, Ikea, Nike, Starbucks (flooring), Staples, Office Depot, Wal-Mart, Patagonia, and the U.S. Green Building Council’s LEED program.
FSC accredited, independent, “third-party” certification bodies or “certifiers” certify forests. They assess forest management using the FSC principles, criteria, and standards, each certifier uses their own evaluative process. This allows FSC to remain outside of the assessment process, and supports the integrity of the standard, and of the FSC system. Certifiers evaluate both forest management activities (forest certification) and tracking of forest products (chain-of-custody certification).
The contract’s duration is five years, at which point a full assessment will be conducted again if the landowner wishes to continue being certified. These five-year audits are supplemented by annual audits to verify that the terms of the contract are being followed, and facilitate regular contact between the certificate holder and certifier.
For those companies who manufacture or trade certified products, a different form of certification applies. Again, to assure the credibility of claims on products, it is important to track materials as they leave the forest and become products down stream. This “chain of custody”(COC) certification process is quite simple. Like any inventory control system, COC allows products to be segregated and identified as having come from a particular source—in this case, an FSC-certified forest.
FSC’s model of certification allows products that flow from certified forests to enter the marketplace with a credential that is unique. Any FSC labeled product can be traced back to a certified source. This aspect of the system is the basis for any credible certification system and is the link between consumer preference and responsible, on the ground forest management.
FSC is in the process of establishing an office in
The FSC working group will focus on the development of national standards for timber harvesting in
Timber product imports into
So more important than developing standards for harvesting within
Since FSC sets a global standard for exemplary forestry, there are many operations across the globe that cannot meet the FSC standard. This presents a challenge: how do you create market incentives for operations that cannot meet the FSC standard, that encourage those operations to move in the right direction.
As in any country there are a number of good sustainable producers and manufacturers throughout
Fortunately, FSC does have some experience working with sectors of the timber industry that have faced similar challenges, most notably the garden furniture industry in Viet Nam and the charcoal industry in South Africa. Through partner organizations such as the Tropical Forest Trust, producers can receive selective recognition in certain markets if the commit to incremental improvement over 5 years and agree to become FSC certified at the end of the 5 year period.
Obviously change will not happen overnight, but in tandem with our environmental partners such as WWF, Environmental Investigation Agency, and others, FSC certified companies and the support of governments in producing, manufacturing and import countries we can go along way in cleaning up the international timber trade in
Establishing FSC certification in
It has been a very difficult to establish an FSC office in
For an FSC accredited certifier to legally operate in
Article 10 A certification body to be established shall meet the following requirements:
(1) having fixed premises and necessary facilities;
(2) having management system that meets the requirements for certification and accreditation;
(3) having a registered capital of not less than 3,000,000 yuan; and
(4) having not less than ten full-time certification personnel in relevant fields.
A certification body to engage in product certification activities is additionally required to have technical competence in testing or inspection commensurate with relevant product certification activities.
Article 15 Any certification personnel, when practicing certification activities, shall practice in one certification body only and shall not practice in two or more certification bodies simultaneously.
Article 76 Structural fee charts for certification and accreditation shall be in conformity with the provisions of relevant laws and administrative regulations of the State on pricing
For social issues certification (e.g. SA 8000) the Certification and Accreditation Administration of the People’s Republic of China is operating on a ‘case by case’ basis both the certification organization and the enterprise involved must submit an application to CNCA in advance, explain the reasons for certification, and cannot start the certification process until approved.
The requirements for a physical presence, staff and investment in
But the government is moving forward on a number of initiatives that would help establish FSC certification in
Since November 2003, all certification bodies issuing certificates in China need to be approved by the Certification and Accreditation Administration of the People’s Republic of China (CNCA). CNCA does not seem to have a major problem with the concept of ‘International Accreditation’ and certification bodies other than CNAB (CNAS) operating in China. Another positive sign is China is active in ENA-FLEG (Forest Law Enforcement and Governance Europe/North Asia) and shown a commitment to oppose illegal logging and associated trade.
Despite these difficulties, FSC has begun to make some inroads in
Looking Toward the Future
There are rarely simple solutions to complex problems like those related to creating transparency and oversight for the international timber trade. In most cases it is a number of tools, such as legislation, diplomacy or market pressure that help resolve such issues. I believe FSC is a tool that can help remove the worst players from the international timber market and reward the sustainable producers in the marketplace. FSC also plays a very important role for wood and paper products more generally. As this industry and many other industries have seen before, a few bad actors can tarnish the whole industry’s reputation. FSC establishes sustainably produced wood and paper products as the green, environmentally and socially beneficial products that they are. FSC can uniquely play that role because it is the only internationally recognized forest certification program that recognizes the importance of social issues—community involvement, indigenous and labor rights—in forest management.
Still there is a very difficult road ahead. There is little question that
I have included for the committee the FSC’s Principles and Criteria which guide FSC certification and a list of the FSC certified companies in
FSC’s Principles & Criteria for
Introduction to FSC's Principles & Criteria
It is widely accepted that forest resources and associated lands should be managed to meet the social, economic, ecological, cultural and spiritual needs of present and future generations. Furthermore, growing public awareness of forest destruction and degradation has led consumers to demand that their purchases of wood and other forest products will not contribute to this destruction but rather help to secure forest resources for the future. In response to these demands, certification and self-certification programs of wood products have proliferated in the marketplace.
The Forest Stewardship Council (FSC) is an international body which accredits certification organizations in order to guarantee the authenticity of their claims. In all cases the process of certification will be initiated voluntarily by forest owners and managers who request the services of a certification organization. The goal of FSC is to promote environmentally responsible, socially beneficial and economically viable management of the world's forests, by establishing a worldwide standard of recognized and respected Principles of Forest Stewardship.
The FSC's Principles and Criteria (P&C) apply to all tropical, temperate and boreal forests, as addressed in Principle #9 and the accompanying glossary. Many of these P&C apply also to plantations and partially replanted forests. More detailed standards for these and other vegetation types may be prepared at national and local levels. The P&C are to be incorporated into the evaluation systems and standards of all certification organizations seeking accreditation by FSC. While the P&C are mainly designed for forests managed for the production of wood products, they are also relevant, to varying degrees, to forests managed for non-timber products and other services. The P&C are a complete package to be considered as a whole, and their sequence does not represent an ordering of priority. This document shall be used in conjunction with the FSC's Statutes, Procedures for Accreditation and Guidelines for Certifiers.
FSC and FSC-accredited certification organizations will not insist on perfection in satisfying the P&C. However, major failures in any individual Principles will normally disqualify a candidate from certification, or will lead to decertification. These decisions will be taken by individual certifiers, and guided by the extent to which each Criterion is satisfied, and by the importance and consequences of failures. Some flexibility will be allowed to cope with local circumstances.
The scale and intensity of forest management operations, the uniqueness of the affected resources, and the relative ecological fragility of the forest will be considered in all certification assessments. Differences and difficulties of interpretation of the P&C will be addressed in national and local forest stewardship standards. These standards are to be developed in each country or region involved, and will be evaluated for purposes of certification, by certifiers and other involved and affected parties on a case by case basis. If necessary, FSC dispute resolution mechanisms may also be called upon during the course of assessment. More information and guidance about the certification and accreditation process is included in the FSC Statutes, Accreditation Procedures, and Guidelines for Certifiers.
The FSC P&C should be used in conjunction with national and international laws and regulations. FSC intends to complement, not supplant, other initiatives that support responsible forest management worldwide.
The FSC will conduct educational activities to increase public awareness of the importance of the following:
*improving forest management;
* incorporating the full costs of management and production into the price of forest products;
* promoting the highest and best use of forest resources;
* reducing damage and waste; and
* avoiding over-consumption and over-harvesting.
FSC will also provide guidance to policy makers on these issues, including improving forest management legislation and policies.
Principle 1: Compliance with Laws and FSC Principles
1.2 All applicable and legally prescribed fees, royalties, taxes and other charges shall be paid.
1.3 In signatory countries, the provisions of all binding international agreements such as CITES, ILO Conventions, ITTA, and Convention on Biological Diversity, shall be respected.
1.4 Conflicts between laws, regulations and the FSC Principles and Criteria shall be evaluated for the purposes of certification, on a case by case basis, by the certifiers and the involved or affected parties.
Principle 2: Tenure and Use Rights and Responsibilities
Long-term tenure and use rights to the land and forest resources shall be clearly defined, documented and legally established.
2.1 Clear evidence of long-term forest use rights to the land (e.g. land title, customary rights, or lease agreements) shall be demonstrated.
2.2 Local communities with legal or customary tenure or use rights shall maintain control, to the extent necessary to protect their rights or resources, over forest operations unless they delegate control with free and informed consent to other agencies.
2.3 Appropriate mechanisms shall be employed to resolve disputes over tenure claims and use rights. The circumstances and status of any outstanding disputes will be explicitly considered in the certification evaluation. Disputes of substantial magnitude involving a significant number of interests will normally disqualify an operation from being certified.
Principle 3: Indigenous People's Rights
The legal and customary rights of indigenous peoples to own, use and manage their lands, territories, and resources shall be recognized and respected.
3.1 Indigenous peoples shall control forest management on their lands and territories unless they delegate control with free and informed consent to other agencies.
3.3 Sites of special cultural, ecological, economic or religious significance to indigenous peoples shall be clearly identified in cooperation with such peoples, and recognized and protected by forest managers.
3.4 Indigenous peoples shall be compensated for the application of their traditional knowledge regarding the use of forest species or management systems in forest operations. This compensation shall be formally agreed upon with their free and informed consent before forest operations commence.
Principle 4: Community Relations and Workers' Rights
4.1 The communities within, or adjacent to, the forest management area should be given opportunities for employment, training, and other services.
4.3 The rights of workers to organize and voluntarily negotiate with their employers shall be guaranteed as outlined in Conventions 87 and 98 of the International Labour Organisation (ILO).
4.4 Management planning and operations shall incorporate the results of evaluations of social impact. Consultations shall be maintained with people and groups (both men and women) directly affected by management operations.
4.5 Appropriate mechanisms shall be employed for resolving grievances and for providing fair compensation in the case of loss or damage affecting the legal or customary rights, property, resources, or livelihoods of local peoples. Measures shall be taken to avoid such loss or damage.
Principle 5: Benefits from the
5.6 The rate of harvest of forest products shall not exceed levels which can be permanently sustained.
Principle 6: Environmental Impact
6.1 Assessment of environmental impacts shall be completed -- appropriate to the scale, intensity of forest management and the uniqueness of the affected resources -- and adequately integrated into management systems. Assessments shall include landscape level considerations as well as the impacts of on-site processing facilities. Environmental impacts shall be assessed prior to commencement of site-disturbing operations.
6.2 Safeguards shall exist which protect rare, threatened and endangered species and their habitats (e.g., nesting and feeding areas). Conservation zones and protection areas shall be established, appropriate to the scale and intensity of forest management and the uniqueness of the affected resources. Inappropriate hunting, fishing, trapping and collecting shall be controlled.
6.3 Ecological functions and values shall be maintained intact, enhanced, or restored, including: a)
6.4 Representative samples of existing ecosystems within the landscape shall be protected in their natural state and recorded on maps, appropriate to the scale and intensity of operations and the uniqueness of the affected resources.
6.5 Written guidelines shall be prepared and implemented to: control erosion; minimize forest damage during harvesting, road construction, and all other mechanical disturbances; and protect water resources.
6.6 Management systems shall promote the development and adoption of environmentally friendly non-chemical methods of pest management and strive to avoid the use of chemical pesticides. World Health Organization Type 1A and 1B and chlorinated hydrocarbon pesticides; pesticides that are persistent, toxic or whose derivatives remain biologically active and accumulate in the food chain beyond their intended use; as well as any pesticides banned by international agreement, shall be prohibited. If chemicals are used, proper equipment and training shall be provided to minimize health and environmental risks.
6.7 Chemicals, containers, liquid and solid non-organic wastes including fuel and oil shall be disposed of in an environmentally appropriate manner at off-site locations.
6.8 Use of biological control agents shall be documented, minimized, monitored and strictly controlled in accordance with national laws and internationally accepted scientific protocols. Use of genetically modified organisms shall be prohibited.
6.9 The use of exotic species shall be carefully controlled and actively monitored to avoid adverse ecological impacts.
6.10 Forest conversion to plantations or non-forest land uses shall not occur, except in circumstances where conversion: a) entails a very limited portion of the forest management unit; and b) does not occur on high conservation value forest areas; and c) will enable clear, substantial, additional, secure, long term conservation benefits across the forest management unit.
Principle 7: Management Plan
A management plan -- appropriate to the scale and intensity of the operations -- shall be written, implemented, and kept up to date. The long term objectives of management, and the means of achieving them, shall be clearly stated.
7.1 The management plan and supporting documents shall provide: a) Management objectives. b) Description of the forest resources to be managed, environmental limitations, land use and ownership status, socio-economic conditions, and a profile of adjacent lands. c) Description of silvicultural and/or other management system, based on the ecology of the forest in question and information gathered through resource inventories. d) Rationale for rate of annual harvest and species selection. e) Provisions for monitoring of forest growth and dynamics. f) Environmental safeguards based on environmental assessments. g) Plans for the identification and protection of rare, threatened and endangered species. h) Maps describing the forest resource base including protected areas, planned management activities and land ownership. i) Description and justification of harvesting techniques and equipment to be used.
7.2 The management plan shall be periodically revised to incorporate the results of monitoring or new scientific and technical information, as well as to respond to changing environmental, social and economic circumstances.
7.4 While respecting the confidentiality of information, forest managers shall make publicly available a summary of the primary elements of the management plan, including those listed in Criterion 7.1.
Principle 8: Monitoring and Assessment
Monitoring shall be conducted -- appropriate to the scale and intensity of forest management -- to assess the condition of the forest, yields of forest products, chain of custody, management activities and their social and environmental impacts.
8.1 The frequency and intensity of monitoring should be determined by the scale and intensity of forest management operations as well as the relative complexity and fragility of the affected environment. Monitoring procedures should be consistent and replicable over time to allow comparison of results and assessment of change.
8.3 Documentation shall be provided by the forest manager to enable monitoring and certifying organizations to trace each forest product from its origin, a process known as the "chain of custody."
8.4 The results of monitoring shall be incorporated into the implementation and revision of the management plan.
8.5 While respecting the confidentiality of information, forest managers shall make publicly available a summary of the results of monitoring indicators, including those listed in Criterion 8.2.
Principle 9: Maintenence of High Conservation Value Forests
Management activities in high conservation value forests shall maintain or enhance the attributes which define such forests. Decisions regarding high conservation value forests shall always be considered in the context of a precautionary approach.
9.1 Assessment to determine the presence of the attributes consistent with High Conservation Value Forests will be completed, appropriate to scale and intensity of forest management.
9.2 The consultative portion of the certification process must place emphasis on the identified conservation attributes, and options for the maintenance thereof.
9.3 The management plan shall include and implement specific measures that ensure the maintenance and/or enhancement of the applicable conservation attributes consistent with the precautionary approach. These measures shall be specifically included in the publicly available management plan summary.
9.4 Annual monitoring shall be conducted to assess the effectiveness of the measures employed to maintain or enhance the applicable conservation attributes.
Principle 10: Plantations
Plantations shall be planned and managed in accordance with Principles and Criteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide an array of social and economic benefits, and can contribute to satisfying the world's needs for forest products, they should complement the management of, reduce pressures on, and promote the restoration and conservation of natural forests.
10.1 The management objectives of the plantation, including natural forest conservation and restoration objectives, shall be explicitly stated in the management plan, and clearly demonstrated in the implementation of the plan.
10.2 The design and layout of plantations should promote the protection, restoration and conservation of natural forests, and not increase pressures on natural forests. Wildlife corridors, streamside zones and a mosaic of stands of different ages and rotation periods, shall be used in the layout of the plantation, consistent with the scale of the operation. The scale and layout of plantation blocks shall be consistent with the patterns of forest stands found within the natural landscape.
10.3 Diversity in the composition of plantations is preferred, so as to enhance economic, ecological and social stability. Such diversity may include the size and spatial distribution of management units within the landscape, number and genetic composition of species, age classes and structures.
10.4 The selection of species for planting shall be based on their overall suitability for the site and their appropriateness to the management objectives. In order to enhance the conservation of biological diversity, native species are preferred over exotic species in the establishment of plantations and the restoration of degraded ecosystems. Exotic species, which shall be used only when their performance is greater than that of native species, shall be carefully monitored to detect unusual mortality, disease, or insect outbreaks and adverse ecological impacts.
10.5 A proportion of the overall forest management area, appropriate to the scale of the plantation and to be determined in regional standards, shall be managed so as to restore the site to a natural forest cover. 10.6 Measures shall be taken to maintain or improve soil structure, fertility, and biological activity. The techniques and rate of harvesting, road and trail construction and maintenance, and the choice of species shall not result in long term soil degradation or adverse impacts on water quality, quantity or substantial deviation from stream course drainage patterns.
10.7 Measures shall be taken to prevent and minimize outbreaks of pests, diseases, fire and invasive plant introductions. Integrated pest management shall form an essential part of the management plan, with primary reliance on prevention and biological control methods rather than chemical pesticides and fertilizers.
10.8 Appropriate to the scale and diversity of the operation, monitoring of plantations shall include regular assessment of potential on-site and off-site ecological and social impacts, (e.g. natural regeneration, effects on water resources and soil fertility, and impacts on local welfare and social well-being), in addition to those elements addressed in principles 8, 6 and 4. No species should be planted on a large scale until local trials and/or experience have shown that they are ecologically well-adapted to the site, are not invasive, and do not have significant negative ecological impacts on other ecosystems. Special attention will be paid to social issues of land acquisition for plantations, especially the protection of local rights of ownership, use or access.
10.9 Plantations established in areas converted from natural forests after November 1994 normally shall not qualify for certification. Certification may be allowed in circumstances where sufficient evidence is submitted to the certification body that the manager/owner is not responsible directly or indirectly of such conversion.
Along with FSC partners in Oregon like Ecotrust, Sustainable Northwest, and Metafore, the following companies hold FSC certificates.