Chain of Custody Simplified
Readers will, by now, be very aware of the important update and revision that FSC has begun for its central Chain of Custody (CoC) standard – FSC-STD-40-004. If you have not yet contributed to the discuss and provided FSC with your own feedback, we urge you to do so soon. The official 1st public consultation period ends on 29 February 2015.
MixedWood provided some initial feedback late last year when the discussion draft was first released – including an annotated copy of the discussion draft highlighting a variety of areas that (in our view) need reconsideration or more work. Please download a copy here and tell us what you think.
As we prepare to finalize our own commentary and feedback to the FSC staff, we have been considering that finding fault with a bloated and overly complex standard document, is not very helpful. Everyone seems to agree that CoC is too complicated. But simplifying it still seem to elude us. We thought that it might be helpful to offer an alternative.
What would a simple CoC standard look like?
We considered trying to draft a clean and simple Chain of Custody standard of our own. But that would have been a lot of work, and rather easy to ignore. Instead, we sat down this week and went to work on the current discussion draft of FSC-STD-40-004 v.3-0. We went through it carefully, line by line, and removed as much text as possible, without changing any of the core requirements. We did remove a great deal of duplication and confounding detail. And we removed several specific requirements (like repeating CoC claims on sales documents) that have been proven to be unnecessary in practice. The result is – we think – a standard that accomplishes everything that a CoC standard should accomplish: credible and verifiable traceability within the context of a formal management system. It accomplishes this in a document that is about 1/3 the length (6 vs. 23 pages of requirements), and has about 1/2 the number of audit-able clauses (66 vs. 123). Despite this, we were retained the familiar structure of the document, and (with one exception) every single specific requirement. It is far from a perfect document, but we believe it is a significant improvement over either the current standard (v.2-1) or the proposed new draft (v.3-0).
The one requirement we did omit in our simplified draft, is the new Transaction Verification section. We do not think it has any place in a Chain of Custody system at all, and it certainly has not place in a system that calls itself simple. Please take a look at our last post for more on this subject.
Please download and read MixedWood’s simplified 40-004, and let us know what you think. If you like our version of STD-40-004 v.3-0, please make sure that FSC hears from you. If you prefer FSC’s longer draft, that is OK too. Either way, it is important that you provide them with your feedback. If they do not hear from us, they will be left to continue as that have been, and the business community will have to live with the result.
Update (26 Feb 2015):
Here is a copy of MixedWood’s comments to FSC. It took just a few minutes to do.
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