1. DOCUMENTATION UPDATE

The documented written procedures (i.e. CoC manual) maintained for overall conformance to FSC requirements should be updated and/or revised, as needed, to reflect current practice.  The manual should include a “Due Diligence System” which can exist either as a stand-alone document or be incorporated into the manual.

Specific items requiring attention during adaptation to the US-NRA include:

• Adoption of the FSC-approved National Risk Assessment for the US (US-NRA) – replacing earlier company-based Risk Assessments (#3 below)
• Update of the required DDS Public Summary. We recommend using a template provided by MixedWood
• Records of mitigation activities sufficient to show the appropriate implementation of required Control Measures detailed below (#5)

2. SUPPLY CHAIN RISK ASSESSMENT

How ongoing integrity of the Supply Chain is managed:

Each CW company must prepare, implement, maintain, and document a Supply Chain Risk Assessment for its entire procurement program.  A typical Supply Chain Risk Assessment will consist of the following information.

• Chain of Custody receiving checks: the CoC Procedures manual includes procedures that provide controls and verification checks for all incoming material.  This includes (at a minimum) the identity of the supplier, and the type of material purchased (e.g. species, grade, etc.).  It may also include additional, useful information like location, buyer, etc.
• Regular supplier visits, observations, and general market intelligence by purchasing staff.
• Maintenance of a Supply Chain Risk Matrix (or similar documentary system) to summarize information about suppliers and record a conclusion about “Supply Chain Risk” (i.e. the risk of mixing illegal or ethically unacceptable sources into the supply chain).
• The working assumption of Supply Chain Risk Assessments in the US is typically “negligible risk”. Any information discovered that is contrary to that assumption requires prompt action to address.

NOTE:  Supply Chain Risk Assessment is not required for materials purchased as FSC-certified, or with FSC Controlled Wood claims provided by a certified supplier.

3. FSC NATIONAL RISK ASSESSMENT –
GEOGRAPHIC REGIONS, CONCLUSIONS,
AND REQUIREMENTS 

Each CW company must adopt and implement the FSC-approved National Risk Assessment for the USA (FSC-NRA-USA v.1-0).  A simple statement to this effect should be included in the CoC written procedures manual, or some other written record.

NOTE:  Company-based Risk Assessments (CRA’s) are now fully obsolete and should not be referred to in your procedures manual.

The NRA conclusions, by region, are summarized in the table below.  Each CW company should compare the geography of their wood procurement with the regional boundaries used in the US-NRA (click the map for a closer look).

For sourcing regions where findings of Specified Risk are identified, FSC requires the implementation of mitigation actions, termed Control Measures.

6. CONTROL MEASURES – AVOIDANCE

Narrow-scope Specified Risk Subjects

For some Specified Risk subjects, a strategy of avoidance may be practical.  Consult the Specified Risk maps and descriptions for the subjects noted below.  Consider whether practical limits to procurement may exclude the designated area.

West (Rocky Mountains & Pacific Coast)

• Lesser Slender Salamander (California)

⇒ NOTE: Documented Rational

If any Specified Risk subject is to be managed through avoidance it is important that an objective rationale be recorded and included in the DDS documentation – reviewed and revised annually as required.