With just 2 weeks remaining in the public comment period for the Forest Stewardship Council’s (FSC) important update to it’s Chain of Custody (CoC) standard, many stakeholders are trying to squeeze time into their busy schedules to consider the proposed new language and provide constructive feedback. MixedWood has completed a preliminary review – pointing out a number of areas that still need work. We intend to have some additional analysis posted quite soon.
While waiting for stakeholders to respond to their work on the version 3 of STD-40-004, FSC staff have been busy with other initiatives. They are related to the CoC update, but promise to go far beyond the proposed changes in the discussion draft. We think they deserve more attention than they are getting. Is FSC trying to re-invent Chain of Custody?
What is “Transaction Verification”?
The proposed new CoC standard includes this new language:
Viewed in isolation, this sentence looks simple enough. It promises, however to completely change the nature of CoC certification. Let’s look more closely at the language.
Clause 3.4.1 will require a “mechanism” that provides “verification that … recorded FSC input claims match … output claims of … suppliers”. We think that this essentially requires every FSC certified company to independently audit the books of its suppliers.
Currently, a certified company can purchase a certified product from a certified supplier and be assured that the official certification claim statement – generally found on an invoice – is sufficient to establish a valid chain of custody. FSC now proposes an additional “mechanism” to verify that suppliers invoice is – in fact – correct.
To date, FSC has not yet told us what will be recognized as a valid “mechanism”. But they have given a whole lot of hints. The first hint is found in the “NOTE TO STAKEHOLDERS” in the v.3-0 discussion draft:
This little paragraph tells us a great deal. First of all, it tells us to expect another update to the key CoC Accreditation Standard (STD-20-011). A quick look at the history of this standard reminds us that the current version (v.2-0) became effective on 1 Jan 2015 – just last month. Apparently another re-write is planned before the ink is even dry! We also see that new risk-based criteria are being contemplated. Will these new criteria apply to certified companies or only to certification bodies? We will have to wait and see.
The OCP is back!
It has been over 2 years since FSC first began promoting the cloud-based, central transaction database system that it calls the Online Claims Platform (OCP). When we first wrote about the OCP in January 2013, we called it “a big mistake”. We still think so. We have followed its evolution from obscurity to unpopular notoriety to apparent irrelevance. It appears now that the rumors of its demise have been exaggerated.
A new promotional document published in December (before the updated CoC was even available) makes it very clear which “mechanism” the FSC staff intend to be used when we apply the new “Transaction Verification” requirement. Please take a moment to read through it – it is short. We find the title kind of amusing: Creating Solutions? It reads like an advertisement. What are they selling us? Why the OCP, of course.
Today, a webinar presentation was presented by FSC-IC on Transaction Verification and the OCP. This document is quite a lot longer, but worth a look nonetheless. Its content is very revealing:
- 8 pages of introduction and justification: why they think we need this thing,
- 14 pages outlining “5 key elements” that begin to define the acceptable “mechanisms” for meeting the proposed new requirement, and
- 79 pages devoted to demonstrating just how wonderful the OCP is.
A solution just in time for a non-existent problem
FSC staff began the OCP project by dreaming up a very bad idea without bothering to discuss it with the people who would be most affected by it. Now they seem to be focused on generating an artificial need for the very expensive machine that they have built.
The OCP is still a very bad idea.
Making CoC certification more complex, more expensive, and more confusing does NOT make FSC stronger. The time has come to turn the corner. If you agree, please make sure FSC hears from you. It is important.