The Sustainable Forestry Initiative Program is currently engaged on a very important update to its entire set of standards. The process began earlier this year, was kicked into high gear yesterday with the release of the first discussion drafts for the 2015-19 standard, followed by a series of workshops and listening sessions held at a locations all over the US and Canada. The folks at SFI, Inc. deserve a lot of credit for their extraordinary efforts to ensure transparency and open discuss in this important process. It will only be worthwhile, though, if stakeholders like us make an effort to participate.
MixedWood has hopes that this update process will provide SFI, Inc. with some healthy and challenging perspectives on the strengths and weaknesses of its program. This should include a hard, critical look at the Certified Sourcing program which many consider to be the heart and sole of SFI and which we have described as both SFI’s greatest strength and its greatest weakness.
To illustrate the strange, two-sided nature of SFI Certified Sourcing, consider the story of these two certified companies.
Riverbend Pulp and Paper Co. (RPP)
RPP is a medium-sized, privately-owned manufacturer of specialty paper products, located in a small, rural mill town in the Northeast. RPP’s raw material supply is a mixture of roundwood purchased directly from local loggers and landowners, and sawmill residues – all purchased within a radius of about 100 miles of the plant. They operate an integrated mill which includes pulp digesters and several, small paper machines. Their customers, who include a number of prominent paper merchants and specialty product manufacturers place a high value on “green” certification. To satisfy this interest, RPP has maintained a FSC Chain of Custody (CoC) and Controlled Wood (CW) certification for several years and recently added SFI Certified Sourcing to its program.
The fact that RPP sources its raw materials in the form of roundwood and chips means that it is categorized as a “Primary Producer”. SFI requires that Primary Producers seeking certification implement the requirements found in Section 2 of the SFI standard. For RPP this meant that they had to do the following:
- Objectives 1-7 and 18 apply only to companies who own and manage forest lands. RPP is not a landowner, so these requirements do not apply to them. Similarly Objectives 11-13 apply only to companies sourcing fiber from outside the US & Canada, something RPP doesn’t do.
- Objective 8 requires that they implement a program of outreach to landowners in their area. This program is required to encourage the use of Sustainable Forestry systems (like SFI).
- Objective 9 requires that they promote and track the use of Certified Logging professionals.
- Objective 10 requires that they both ensure and monitor the use of Best Management Practices (BMP) designed to protect water quality in timber harvesting operations. This includes mandatory contractual requirements with suppliers, a written sourcing policy, and specific programs to manage adverse weather. They also must conduct monitoring and evaluate BMP use over time.
- Objective 14 requires a systematic program of legal compliance, including environmental, social, and labor laws.
- Objective 15 requires specific support of reasearch programs.
- Objective 16 specifies standards for staff and contractor training, including required support of logger recognition programs.
- Objective 17 requires participation and support of the SFI community network system, organized at the state (or provincial) level as SFI Implementation Committees (SIC). SIC activities include a variety of collaborative actions aimed at the specifics in other parts of the standard.
- Objective 19 specifies the public reporting requirements of the standard.
- Objective 20 requires a program of management review and continuous improvement.
Taken together, these requirements consitute an ambitous undertaking for any company. This is especially true when you take into account that the whole program is subject to regular audit review by a third party certifier. The whole process is rigorous, time-consuming, and expensive. The result is that RPP acquires the privilege to promote itself as a SFI-certified company and to label its paper products with the SFI Certified Sourcing label.
Double-Z Packaging, Inc. (ZZP)
ZZP is a medium-sized manufacturer and supplier of customized retail packaging products, located in an industrial urban city in the Midwest. They specialize in paper-based packing materials for the food product industry and their clientelle includes a number of high-value, brand name companies eager to promote sustainablity and environmental responsibility. ZZP acquires most of its raw material in the form of commodity-grade paperboard which it purchases regularly from three, large, nationally-known paper manufacturers – all founding members of the SFI program. They also buy regularly in the spot market as a way to keep their costs down.
Like many similar companies, ZZP started green certification by getting CoC certified against all three of the major programs: SFI, FSC, and PEFC. This allowed them to brand themselves as “Tri-certified”, but they found it difficult to purchase enough FSC or PEFC paperboard at competitive prices to make a practical business. In addition, the complex and detailed rules – just a bit different for each program – ended up costing too much time, energy, and money to maintain. They decided to drop all three of their CoC certificates in favor of a single SFI Certified Sourcing certificate. Here’s how it works:
- As a “Secondary Producer” (not buying roundwood or chips) ZZP can certify against a very simple set of requirements found in Section 4 of the SFI standard.
- Element 3.2 requires that at least 66% of their raw materials meet SFI’s definition of “certified sourcing”.
- Elements 3.4.2 & 3.4.3 allows them to calculate this using a simple percentage, which they do once per year (generally the week before their audit). Unlike CoC, there are no specific record-keeping or verification requirements.
- The definition of “certified sourcing” (Paragraph 5) allows them to include all of the paperboard they buy from their primary suppliers, most recycled content, and any other sources that can be shown to be “Non-controversial”.
- Element 5.5 defines “Non-controversial sources” in a way that includes anything sourced in the US and Canada. Since ZZP buys all of its paperboard domestically, their calculated percentage is always 100%.
By dropping CoC certification, ZZP eliminated a lot of administration costs. Maintaining their Certified Sourcing certification requires no more than a annual supply summary from their purchasing department and a quick painless audit. Best of all, they now can apply the SFI Certified Sourcing to all of their product lines.
So what is Certified Sourcing? It depends on who you ask:
If you ask my friends at RPP, they will point with pride to their active and rigorous engagement with their supply network. They will also call attention to the good work being done at the regional and national level by the state SIC networks – promoting and supporting responsible wood product markets, funding applied research, and providing incentives for professionalism in the industry. They will refer to regular
If you ask the folks at ZZP, they will tell a very different story. For them, SFI Certified Sourcing is a simple little program that allows them to put a pretty label on their products. It doesn’t cost much, and the customers seem to like it.
The problem is that SFI Certified Sourcing is both of these things. It is a unique, ambitious, and potentially powerful certification standard for wood product procurement. And it is a embarassingly weak, relatively meaningless program for putting labels on North American-made wood and paper products.
This needs to be fixed, and now – while SFI is re-writing its standards – is the time to get it done. A quick look at the proposed draft of SFI Section 4, released just yesterday, includes some positive changes, but the basic framework behind my story here remains essentially intact. This is a mistake.
If you agree with me, please look back at my opening paragraph and make sure SFI hears from you. If you disagree, please use the comments below to share why. You can also find me on LinkedIn and Twitter.