By far the most consistent theme explored in this space has been the persistent and frustrating insistence on the part of the Forest Stewardship Council (FSC) to complicate and confuse the subject of supply chain traceability. Our principal tool for supply chain traceability is, of course, Chain of Custody (CoC) certification. And at its root, CoC is simple, or at least it ought to be.
But the FSC – as an organization – remains unable to allow anything it touches to remain simple. It’s self-described mission is to “…promote environmentally appropriate, socially beneficial, and economically viable management of the world’s forests.” A good mission, we think, and not a simple one. One of its strengths is its focus: “…management of the world’s forests.” The FSC is – after all – concerned primarily with the Stewardship of Forests. It is not called the SAEMFPM (the Society for the Assurance of Ethics in all Matters related to the Forest Product Marketplace).
What then does the core mission of the FSC have to do with Chain of Custody? We think the answer is, “not much”. Chain of Custody (CoC) is a means to an end. It is a tool designed to help accomplish the “promote” part of the FSC’s core mission. It is a useful and necessary tool, but it is just a tool. CoC provides a link between products for sale in commercial markets and the primary raw materials that come from responsibly managed forests. From the FSC-IC website:
CoC “Social Criteria”
Several years ago, some folks within the FSC staff got the idea that simple CoC was in some way insufficient. They looked at the 3-legged mission of the FSC, with its Economic, Environmental, and Social components, and they decided that CoC would be “improved” if we added some social criteria. Knowledgeable practitioners, including some founding members of the FSC “old guard”, objected strongly. They pointed out that the 3-part ethical foundation of the FSC mission was designed for forest management (FM) certification, and was ill-suited to a supply chain traceability standard. This argument limited the initial deployment of this idea, but only temporarily.
The CoC social criteria were initially introduced in 2011 through the incorporation of clause 1.5 in the FSC-STD-40-004 v.2-1, with its own procedure for implementation. Their implementation appeared simple enough: CoC companies were required to sign a simple “self-declaration” document, attesting to certain “FSC Values”. As with so many FSC stories, things quickly got complicated. You can follow the whole story by clicking here. The short version is that FSC’s “self-declaration” document included language that was objectionable to a number of influential certificate holders (CH’s). Deadlines came and went. Back room negotiations over a handful of words stretched out over 1 1/2 years before a compromise was worked out.
We hoped – at the time – that lessons had been learned. We were wrong.
CoC Social Criteria: Round 2
Last month, FSC staff released another package of documents and commentary designed to engage the communities interest in re-opening this Pandora’s Box. You can find all the relevant materials by following this link. The objectives of the “consultation” are described this way:
We find the tone-deaf arrogance of this statement extremely frustrating. The problem is this: There is no “common understanding about the application of the ILO Core Conventions principals within the FSC system”. It does not exist. And wishful thinking on the part of FSC staff will not be sufficient to create it.
The substance of the new, proposed ILO compliance process is presented in two documents. The first contains draft language for a new set of Generic Standards for incorporating into the FSC normative framework (i.e. requirements for CH’s). It includes detailed audit criteria designed for CoC auditors to verify the following:
- abolition of child labor
- elimination of forced labor
- elimination of discrimination
- freedom of association & collective bargaining
Does this sound like suitable subjects for wood product supply chain specialists to explore? Apparently the FSC thinks so. We disagree.
The second document is an “Impact Assessment”. It presents a shamelessly self-serving analysis of the case for CoC social criteria, based largely on specific interests of some trade unions (members of the social chamber) and several references to the urgent need to “strengthen the integrity” of the program. The paper details many of the objections offered by CB’s and CH’s; including cost, administrative complexity, and confusion with legal obligations. But these negative factors are largely dismissed in its conclusions. The staff conclude that the new criteria will have a “positive overall impact”. We find ourselves wondering: is this a position paper or an assessment?
FSC is soliciting stakeholder comments on this proposal. The structure of the response form, does not consider the fact that most affected companies will disagree with the concept altogether, but we are confident that the FSC will receive any constructive input that is offered. We are concerned that too few CH’s will recognize and respond to this consultation. Please help us to promote interest and feedback. We hope that certified companies will speak frankly about the unproductive and unnecessary character of this whole project.
Back to the Core Mission
The idea that companies who participate in the FSC marketplace should conform to the norms of civilized and ethical labor practices is inviting. Fair labor practices and human rights standards are important and worthy of our attention and support. But so are many things. Should CoC auditors also verify that children of factory workers receive effective public education? Perhaps our CoC audits should include routine tests for lead levels in plant drinking water. The list of worthy subjects is endless. FSC simply cannot allow itself to try and do everything.
The idea of introducing social criteria into CoC is disconnected from the stated mission of FSC, and a dangerous distraction from the real and challenging issues that the program faces. It was never subject to a consensus decision of the membership, or (just as important) the certificate holders to whom it applies. Social criteria belong in the FM standards – a key part of the FSC’s 3-legged core mission for responsible and sustainable “…management of the world’s forests”.