Two email communications were circulated this week by the Forest Stewardship Council – International (FSC-IC) staff. They seem, at first, to address different topics. But on further examination, we can see that they are closely related and very interesting.
Both relate closely to the ongoing, and seemingly endless, update to the primary FSC Chain of Custody Standard (FSC-STD-40-004). This update process has been underway for over 3 years and the 3rd round of public consultation is currently open. MixedWood posted some short comments on this lastest consultation round in June. You can also find commentary on earlier rounds by following these links.
Two Messages from FSC-IC
The first of this week’s FSC-IC communications was waiting in North American inboxes first thing on Monday morning. As is common for FSC-IC membership communication, it originated from Kim Carstensen, the Director General. Mr. Carstensen’s message introduces and describes a report describing a survey conducted last year concerning the subject of “misleading claims”.
The second communication arrived on Friday, from the Lucia Mayer Massaroth the global Program Manager for Chain of Custody. Ms. Massaroth’s message is brief, but very interesting. It serves as a reminder of the need for interested stakeholders to respond to FSC’s request for comment on the outstanding update draft for their main CoC standard. We applaud this process, and encourage all of our readers to respond.
FSC Misleading Claims Survey
The staff of FSC-IC in Bonn have been advocating for a number of year’s in favor of a rather radical restructuring of the concept of Chain of Custody. This restructuring has been based largely on the idea of replacing the large and diverse process of independent, third-party verification of standard conformance with a centrally-managed transaction database.
The idea is deeply flawed in many ways – a concept we have discussed here many times before. The reason for this is the fact that it was conceived entire backwards. When FSC staff first conceived of the idea, they made the key mistake of designing a solution before they really understood their problem. When challenged by stakeholders on this point, FSC promised to gather the evidence needed to demonstrate the need for the solution they had already decided they needed. A step in the right direction, we suppose.
It appears that we finally have the promised results: a 5 page paper entitled FSC misleading claims survey: a summary of findings. We are sorry to find them rather disappointing. The principal problem with the FSC report is that it contains very little information. The information is does report is entirely second- or third-hand. There appears to be no direct evidence of Misleading Claims at all.
The report is merely a summary of 384 survey respondents who responded to an online questionnaire. The respondents included many readers and correspondents to the MixedWood blog, so we know its style and content. It’s purpose was clear: to “prove” the need for the Online Claims Platform. Its authors appear to think they were successful. We disagree.
The survey falls short on two counts. Firstly, it reports only opinion and hearsay. Enough to give you an idea about a problem, but not enough to define it. Secondly, it was doomed by prior bias. The terminology and language mixed and confused the very different concepts of “misleading claims” (mostly innocent mistakes and mis-applications within an overly complex system) and outright fraud. The results – sadly – are largely useless.
It is clear that FSC staff do not agree with our last point. They remain keenly interested in finding a use for their expensive new toy (the OCP), but appear to be listening with respect to the overwhelming opinion of CoC companies in Europe and North America. Carstensen includes in intriguing paragraph in his email: It is hard to disagree with any of this. We are encouraged that senior FSC staff continue to talk about “simplifying” the FSC system, but discouraged that everywhere we look, we continue to see more complexity.
FSC’s Other Message
The other email from FSC-IC this week is short and also quite interesting. It makes two points.
Its primary intent is to remind stakeholders of the still-open consultation period on Round 3 of the Chain of Custody standard update. We are all weary of this process, but it remains important. MixedWood will be sharing its feedback here quite soon. We encourage everyone else to do the same.
The other interesting bit of information is that, to date, FSC-IC has only received comment from 55 stakeholders, almost half of whom are non-members. The non-member number serves as a reminder that, of the 30,000+ CoC certified companies, only a small fraction are active members of the FSC organization. Their voice still counts, however. It is also worth noting that over 80% of the input so far seems to come companies who actually use the CoC standard in their business. Not so surprising when you think about.
We are very certain that Transaction Verification, False Claims, and the dreaded OCP will remain the principal topics of comment. We hope that the FSC staff and Board of Directors will be sensible enough to listen respectfully and thoughtfully to what the community has to say.
As we have said for years: Chain of Custody Should Be Easy! Is it not time to stop talking about simplicity and give it a try?