After more than 2 years of hard work, the Forest Stewardship Council (FSC) released a first discussion draft of its version 3 update to the important Chain of Custody standard late last year. We commented on that draft several times last winter (here, here, & here) and encouraged others to do the same.
Today, FSC released another version (FSC-STD-40-004 v.3-0 D2-0) for our review. Please download a copy and look it over.
We promise to examine this latest draft closely, consult with our network, and provide some detailed analysis in the next couple of weeks. Here are a few quick comments, based on one, brief read-through:
- It is shorter! The overall document is 30 pages in length, compared to 36 pages for the last version. We are pleased to see efforts to condense the text in Section 1 (Quality Management) and Section 12 (Compliance).
- It is still too long. In particular, Sections 2, 9, and 12 contain too much confounding and (in our view) unnecessary language. The document will not be effective without further, significant simplification.
- There is some new and significant language concerning Product Groups (Section 4). This concept is vital to CoC and needs careful treatment.
- Most of the pictures and diagrams are new. Some are good – some not. All should be moved to an informative (not normative) annex.
- Transaction Verification is still there (moved to clause 1.7). It is still a terrible and dangerous idea.
Please Help
The technical analysis and commentary of the MixedWood blog represents the collective ideas, perspectives, and wisdom of a small group of professional SFM practitioners. Please share your questions, ideas, opinions, and criticisms.
Stay tuned. We will have more soon.