A simple case study: ‘Suburban Printing Company’
About a month ago, MixedWood was contacted by one of our clients – a small, commercial printer, located in the northeastern US. We had assisted this company with a new Chain of Custody (CoC) certification only last year. With our help, they had completed their dual FSC/SFI certification in the spring of 2023. For us, the project could not have been easier. A well-organized and collaborative client. A simple, transfer-based system. Quick and easy.
When we saw the email in September of 2024, with the subject line “a little help please”, we were not surprised. It has always been common for newly certified companies to need a bit of coaching and support during their first year of certification. When we read the details, though, we realized things were a bit more complicated. Our client had had their initial certification audit in April of 2023. They should have been scheduled for a first surveillance audit about a year later. Instead, their Certification Body (CB) contacted them in September, with a note telling them:
Due to scheduling difficulties, we have not yet scheduled your annual surveillance audit, as required by FSC and SFI. For that reason, we have suspended your certificates until the audit is completed. Please advise us on a suitable date to schedule your audit.
Our client was understandably shocked and confused. They had been slightly puzzled at the delay in hearing from their CB but assumed that someone would contact them to arrange the scheduling. Now they were suspended? How could that happen?
If we had received this news from a client just 2 years ago, we would have been shocked and dismayed. Until about 2 years ago, this sort of thing simply never happened. Certificates were occasionally suspended. And audit schedules were sometimes mixed up. But these were rare and embarrassing screw-ups. Suddenly they have become very common.
Our advice to this client was simple. We advised them first, to ignore their suspension. It wasn’t their fault, and should not be allowed interrupt their ongoing business. Secondly, we encouraged them to secure an audit date as soon as possible. This required a bit of creative scheduling but was completed in a couple weeks. The auditor was briefed (by us) on the need for expedited report processing, and the CoC certificates were able to be re-issued before the end of the month. Little damage was done, but our client was left a bit shaken, and wondering just what had happened and why.
So are we.
Who and What are Certification Bodies (CBs)?
It’s worth taking a minute to remind ourselves about how Third Party Certification works, and who the key players are. FSC, SFI, and PEFC designed their programs to provide independent, verified assurances about responsible sourcing and traceability of wood products in the marketplace. This is done by borrowing from other, independent verification and assurance programs utilizing a common, three-party system:
- The First Party is a company who brings products to the market and wishes to provide its customers with independent assurance guarantees, such as the responsible production and sourcing of forest-based commodities like wood and paper. We often call these companies Certificate Holders – abbreviated CH.
- The Second Party is an organization – commonly an international non-profit – who creates a designed to provide the sort of assurances we described above. The program includes implementable performance standards that can be adopted and verified. This describes FSC, SFI, and PEFC. We typically refer to them as Standard Owners.
- The Third Party is a specialized service provider, who is ‘accredited’ (i.e. recognized & authorized) by the Standard Owner. They provide a formalized process for evaluation, verification, and ‘certification’ of the First Party, with reference to the standard requirements provided by the Standard Owner. We call these companies Certification Bodies or ‘CBs’.
Obviously, a three-party process will only work if all three parties do their job. And of the three parties, the CB is usually the key. Without a CB, there is no audit and no certificate. In other words, no certification.
CBs are business to business service providers. They don’t manufacture, ship, or provide tangible products to their customers. They provide services for a fee. While some of them specialize in forest product Chain of Custody (CoC), most are generalists, providing similar services in a variety of business sectors like automotive, aerospace, and food safety. They tend to be rather big companies, with wide ranging infrastructure and staffing; often spread around the world. And there aren’t very many of them. FSC-US provides a list of 10 CBs currently providing services in North America. This contrasts with over 3700 CoC Certificate Holders.
The work of the CBs isn’t very exciting or inspiring, but it is essential. Without CBs, there would be no audits, no audit reports, no certificates, and no certified products. FSC, SFI, and PEFC would not be the major market influences that they have become. The whole things would just unravel and come apart.
More Case Studies: A Pattern of Disfunction
At this point, readers might imagine that the example we describe at the top of this article is just an isolated and unfortunate incident. Unfortunately, that’s not the case. Here are several other examples to show what we mean. Each of these incidents happened in the US and Canada in the past 12 months:
‘Sneezy Tissue’
Early in 2024, the MixedWood office got a call from a longtime client in the commodity tissue business. This company is a Fortune 100 corporation with a global reach and a leading role in promoting FSC certification. Their certified, brand name products are widely recognized around the world. ‘Sneezy’ had their recertification audit scheduled last winter, which included visits to manufacturing plants in several countries. One of the auditors found errors in sales invoice formats and raised a major non-conformance. The auditor presented this finding at a local closing meeting, but the issue was not communicated clearly to the lead auditor or the ‘Sneezy’ home office.
It took almost 2 months for the audit reports to be finalized and reviewed, during which several CB staff failed to take note of the fact that their biggest CoC client was quietly proceeding towards a suspended certificate. Everything came to a head when an automated form letter was sent to the ‘Sneezy’ certification manager on the same day that their FSC certificate was suspended. The situation was eventually resolved, but only after a frantic 6 weeks of dropped calls, forwarded emails, confused correspondence, and general frustration. All the while, millions of dollar’s worth of FSC-labeled products were sold from store shelves around the world without a valid certificate.
‘Windy Paper Converting’
Windy is a custom paper converting company who specializes in slitting, re-sizing, and coating light weight paper grades widely used for wrapping, labeling, and other uses. They hold FSC, SFI, and PEFC CoC certification and process paper from a wide variety of established manufacturers. They have maintained their certification program for over 12 years, preparing for annual audits in a routine way without difficulty. This year, Windy’s certification manager noticed that her usual audit date was fast approaching and contacted her CB to inquire about scheduling. She received no reply. She inquired again 2 weeks later, and twice more over the next two months, with the same result. Then she received a form letter similar to the one sent to Suburban Printing above (paraphrasing freely):
We neglected to schedule your annual audit, so we are suspending your certificate. Stay tuned and we will try and find an auditor for you.
The folks at Windy (with our help) responded promptly and assertively, pointing out that the CB had failed to respect its contract. We requested an extension to the certificate while an audit was planned. It took 3 weeks, but the CB finally added 60 days to the certificate expiration. Sadly, communication did not improve. Windy spent the next 60+ days trying to schedule their audit. In the meantime, their certificate was suspended and then extended a second time. When they finally were offered an audit date, it was with only 4 days notice! The report is now complete and in review. We are hopeful that their certificate will be renewed before the scheduled expiration next week.
‘Northeastern Brown Box’
MixedWood assisted a corrugated container company, preparing a multi-site CoC system for their network of 4 plants, certified for FSC & SFI. We were on-site for a 2-day audit that finished on leap day, February 29, 2024. We didn’t get a report back, though, until the end of April (almost 2 months later), with no less than twelve non-conformities recorded. An unpleasant and embarrassing surprise.
It became quickly clear that the auditor had a very poor understanding of both the CoC and the Multi-site standards (FSC & SFI). The technical reviewer – instead of returning an inadequate report back to the auditor for revision – simply inferred a long list of non-conformities. In the end, we essentially re-audited much of the Multi-site standard, providing a package of explanations and references to the CB to clarify and address all the recorded findings. It was a lot of work and expense, but was completed in less than 3 days. It took another 6 weeks to get a response – and a certificate – from the CB. In all, about 14 weeks from start to finish.
Real Stories with Real Facts
It may be obvious, but we want to emphasize that these company names are fictitious. There is no Windy Converting, Suburban Printing, or Sneezy Tissue. But the stories are not fictitious. They are real events that were experienced by real companies in the last year. And our descriptions are based on direct, first hand, knowledge of the details.
A Systemwide Breakdown
Prior to about 2022, we can think of only one or two examples of certified companies who were surprised by having their certificates suspended. Yet, this happened to three of the four companies we have profiled here. And we have stories, from colleagues and friends in the business, of many, many other examples. In addition to major breakdowns, there are also many examples of minor breakdowns. Missed schedules, ignored emails, neglected reports, mis-directed questions, incorrect bills, untrained auditors. The list goes on.
In short, we are convinced that the quality of service delivery by CoC-accredited Certification Bodies, now working in the US and Canada, is the worst that we have ever seen. The worst in the 20-year history of our programs.
What Now?
When we founded the MixedWood blog 14 years ago, we made a promise to ourselves – and all of you – to always remain constructive. This article might seem like just a lot of complaining, without any constructive suggestions. That’s a fair criticism. The truth is that, while we have some ideas about what has caused this, we are far from sure that we understand just what is going on. And still less confidence that we have a solution to offer.
What do you think? Have you seen some of the same breakdown in CB services? Do you have ideas about what we should about it? Please drop us a line or give us a call.
P.S. Some of you will be attending the FSC North America meeting in Nashville, TN next week. If you are, please look for Dan.