The US affiliate of the Forest Stewardship Council (FSC-US) released the latest version of its Controlled Wood National Risk Assessment (NRA) for the United States just before the Christmas holidays, we wasted no time in calling attention to it with our brief posting on December 16. This document is very important to the whole FSC program, for reasons that we have discussed at length before, and surely will again. As is typical with FSC, the NRA document had been in the works for a very long time: over 5 years! And its consequence has been increased by the ongoing mayhem associated with the Controlled Wood program this year.
In spite of our quick response to the December 16 posting, the fact remained that FSC-US had provided us with a great deal of material to review (7 documents and more than 250 pages of text) just before the end of year holiday season. Family obligations and the necessary interruptions of ordinary business mean that we are only now able to share some detailed information. The MixedWood team appreciates your patience.
This is Important
We understand that for many folks – including those with major business exposure in the FSC system – the task of reviewing and providing feedback on a 244-page technical document is not likely to get high priority. We think this is a mistake, and we will try to why below. We will also provide access to our own, heavily digested analysis and some focused suggestions for getting involved in an efficient way that we hope you will find helpful.
The bottom line is this: FSC-US staff have completed and proposed a draft policy document that is likely to have major consequences for the immediate future of the FSC program across North America – and by extension, the rest of the world. They had some help, but not much. The document we have before us represents the work of a vanishingly small group of people and is badly in need of thoughtful and critical review. MixedWood intends to do our best to make this happen, but we will need a lot of help.
What is a “FSC Risk Assessment”?
This may sound like a silly question. A Risk Assessment is surely an assessment of risk, right? That means that a “National Risk Assessment” (NRA) is nothing more than an assessment of national risk. Unfortunately it is not that simple.
The FSC-US National Risk Assessment is best understood as a key policy document for conducting Due Diligence. Due Diligence (which FSC calls Controlled Wood) is a necessary mechanism for defining the minimum ethical standards for mixing of fully-certified wood products (those that actually come from a fully-certified forest) with other, non-certified wood products. In a world where no more than 10% of commercial forests are certified, this process is indispensable. Without it, FSC would be entirely irrelevant in commodity markets. There would be no labels, no Trademark Licenses, no license fees, no budget, no program. In other words, FSC needs Due Diligence to survive. FSC-certified companies need it to do their business.
But this doesn’t answer the basic question: what exactly is an FSC Risk Assessment? In the old world (still functioning today, but approaching collapse), a Risk Assessment was a fairly simple, pro-forma document produced by every company buying non-certified wood to mix into FSC supply chains. There are still about 200 of these Risk Assessments in the US and a couple thousand around the world. For the most part, they are all the same. And – for all practical purposes – they are a bit of a joke. If everything is “Low Risk”, what is the point of 200 (or 2000) Risk Assessments?
FSC correctly decided to fix this about 6 years ago by substituting (in the US) one meaningful Risk Assessment for the 200 meaningless ones. Deciding to do this was easy. Actually doing it has proven more difficult. The staff at FSC-US worked very hard for about 2 years and released their first attempt in early 2015. It was a disaster. Essentially everyone hated it, and for good reasons. So the project was put on hold for awhile. Key staff left, others stepped into place. Another effort got underway early last year and their work is what we are looking at today.
The FSC-US Nat’l Risk Assessment – version 2
It is clear that FSC-US are sincere in their desire for transparency and open consultation around this project. The new discussion draft is presented on a dedicated webpage and accompanied by a number of supporting documents. The result, unfortunately, is likely to be rather overwhelming for a lot of folks. We recommend strongly that all of our readers take a look for themselves. If you have taken the time to follow this blog, you owe yourself a look.
If you find it all too much, however, take heart! We are here to help.
During our careful review of the new FSC NRA draft, several things became clear:
- This document is very important, but still needs work;
- FSC-US staff badly need feedback from the user community;
- The length and complexity of the NRA package will prevent most folks from participating.
To help with this situation, MixedWood has produced a document that we call the User’s Guide. It is just that: a guide to the US-NRA draft, written specifically for Users of the Controlled Wood program. We attempted to summarize the NRA in a manner that highlights the portions that are consequential to certified companies, and those that are not. We have also inserted our own comments and suggested areas where stakeholders (that’s us) can and should provide feedback to FSC-US. We have formatted the guide in a simple way, highlighting what we think are the essentials that will be interesting to our readers:
- What We Found
- What We Think
- What You Should Do
The answer to that last bullet is – in many cases – nothing at all. But there are several areas that deserve some attention and where FSC really needs our feedback.
One of these areas is the “Control Measures” that FSC-US is proposing as mitigation for the areas where the Risk Assessment has identified specific risks that need addressing. You’ll find a short summary of these Control Measures at the end of the User’s Guide.
Our guide is only 10 pages in length. Ideally it will be read side-by-side with the 244-page NRA, but it can be viewed on it’s own or (better) with occasional quick references back to the big document. We hope you will find it helpful. If you agree with our comments and suggestions – and also if you do not – please take the time to let FSC-US know. We are interested your perspective, but most importantly, it is FSC that badly needs your feedback and collaboration. Let’s all pitch in and make this better.
Please feel free to copy and share our User’s Guide and this post with colleagues. If you have suggestions, comments, or ideas; we’d be most grateful for those as well. We expect this conversation to continue.