We hope you found the time and attention to take a look at the latest proposal from FSC concerning the addition of labor rights criteria to their Chain of Custody standard. If this subject is new to you, please take a look here at our last article on the subject. You can also visit the original material online here.
This remains an important concern for many in our network and has stimulated quite a lot of discussion and debate recently. Among our correspondents, opinions seem to fall into two groups. The “get over it” group, who regard this as inevitable; and the “I can’t believe it” group who take a more cynical view. Whatever group you fall in, we’d like to call your attention to some of the finer details contained in this. We think the practical consequences of this proposal are still poorly understood – even by the folks closest to the proposal. We hope that you will help us call attention to a few of these key problems.
The Standard and the Audit
Whenever a performance standard, like the FSC-STD-40-004 is modified or updated, those of us who work with and implement the standard need to think about two kinds of consequences.
- What new or different requirements do certified companies need to meet?
- What changes happen in the auditing and certification?
The Standard
The FSC proposal to incorporate Labor indicators into the CoC standard will require certified companies to do three new things:
- Adopt a policy document that covers the FSC Core Labor principles,
- Make the policy statement available to their stakeholders, and
- Complete and document an annual self-assessment of their performance in respecting the Core Labor principals.
If you think these new requirements are fairly straightforward, we generally agree. A self-assessment addressing topics as complex and challenging as workplace discrimination and freedom of association is not a small matter, but CoC companies can probably scale their efforts to reflect their own circumstances and keep things practical and meaningful.
The Audit
When Certification Bodies (CB’s) begin to conduct audits under this new format, they will also be required to do three new things:
- Verify that their clients have adopted and implemented the Core Labor principles policy statement,
- Verify that the policy statement is appropriately available to stakeholders, and
- Design and implement a system to evaluate the relevant, effectiveness, and adequacies of certified company’s self-assessments. The evaluation must include:
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- Verifying self-assessments against available sources of information & applicable requirements,
- Identifying related legal requirements,
- Verifying independent corroborating evidence, that includes interviews with a sufficient variety and number of employees, employee representatives, and worker’s organizations.
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I think we can agree that the first two bullets are fairly minor. The third (including the sub-bullets) is a very big deal. In essence, what is specified here looks to us to be equivalent to an entirely new auditing requirement that will require quite a lot of time, effort, and cost.
The Modifier
Among the folks we have discussed this with recently, are quite a few who disagree with MixedWood about the likely consequence of all this. Their opinion is based largely on some modifying language found in the standard. It is found in the 20-011 standard, clause 11.3 which reads this way:
11.3 The certification body shall design and implement a system for evaluating the relevance, effectiveness, and adequacy of the organization’s self-assessment and conformity to Section 7 (FSC-STD-40-004), according to the scope, scale, intensity and risk of the organization’s operation….
We highlighted the key phrase: “according to the scope, scale, intensity, and risk of the organization’s operation”. The argument is that, because the CB is free to design its evaluation system in a way that considers risk, companies in western nations (North America, Western Europe) can expect very cursory review of their self-assessments and little or no additional auditing effort. We remain unconvinced, in part because of the obvious fact that the west is far from immune from social challenges. Also because of the plain language of the standard.
We sincerely wish that the admirable values expressed in FSC’s Core Labor principles could be taken from granted. Sadly, they cannot. The question before us is not whether we want to make the world a better place. Of course we do. The question is whether the FSC Chain of Custody standard is a suitable tool.
Speaking Up
If you agree that Chain of Custody should be about Chain of Custody, it is not too late to tell FSC. This link will take you to the open consultation forum where anyone can provide input and advice. FSC policy on subjects like this is typically decided by an astonishingly narrow group of people. Please take a few minutes and broaden their perspective.