Environmental Auditors Approve Green Labels for Products Linked to

Some disturbing news about certification of green products.

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Thanks for sharing this around, Will. It’s important to maintain a healthy skepticism of all environmental claims, and to remember that even the best EPDs are still modeled data describing (as ISO puts it) potential environmental impacts. There can be a startling gulf between modeled and actual performance, and between potential and real impacts.

Re: the content of the article you shared, I wanted to add to the conversation by highlighting the work of the new-ish Climate Smart Wood Group. They’re a third-party nonprofit working to guide the industry on how and when one might claim upstream environmental benefits from timber. I’ve found their work a breath of fresh air and enormously productive in a conversation that often runs aground in the narrows between industry propaganda and good intentions.

I’d also offer that while it’s important to maintain high expectations from any certification bodies, I’m very surprised that the article calls out FSC rather than other timber certification bodies. Among certification systems for sustainable timber, FSC is among the best we got. Others, such as SFI, have no verification of forest practices (only verification of submitted documents). NRDC has written about SFI falling short of its sustinability claims here, here, and here (pdf).

That said, the best SFI-certified fiber might still be more sustainable than the worst certified FSC. And using short-rotation biogenic materials like ag waste is almost always preferable to timber when compared on a functional basis (e.g., for insulation)–but emissions from ag is only slightly less fraught with accounting challenges. The article is right to sound an alarm, but I hope we can move with a little more subtlety as we advocate for low-carbon construction in conversations with clients and manufacturers.

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Hi All,

A bit of a correction @jackrusk, Sustainable Forestry Initiative (SFI) most definitely requires verification, well beyond documents including onsite audits, of forest practices as audited annually by an independent third party certification body. Please take a look at the Full SFI 2022 Standards and Rules for clarification on that. I would be happy to schedule a call to address any questions and/or concerns you may have.
With only 13% of the world’s forests having any certification at all, let’s not lose sight of the positive impact we can all make.
Annie

Great to hear the standard is evolving in response to feedback, and I’m happy to stand corrected.

And I certainly second your excitement about onsite audits! This point comes up often when we compare certification systems and I’d love to have more insight into SFI in this regards. But I have to admit, I’m still a bit confused.

Can you clarify Appendix 4 of Section 10 (audit procedures) of the most recent SFI standard? It says that remote (“desk”) audits can be allowed by a CB when a forest meets just one of a number of criteria (such as maintaining a remotely accessible data management system). Many CBs made similar adaptations at the height of Covid-19, but this latest SFI standard extends this practice into the future. Would love to hear more about this, and correct any potential ways that I (and my colleagues) may be misinterpreting it.

In other parts of section 10, on-site audits are referenced but never strictly required. Perhaps the requirement is called out in another section?

Thanks for engaging and you’re absolutely right–the potential for positive impact is enormous.

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Yes, the following is the language requiring on-site audits. Let’s connect off-line if you have further questions, thanks.

SFI Section 10 - SFI Audit Procedures and Auditor Qualification and Accreditation
· Audit teams must assess on-the ground (i.e., in woods) compliance with SFI standard requirements.

5.1.1 DETERMINATION OF CONFORMANCE

• …. Evidence shall be compiled by examining operating procedures, materials relating to forestry practices and on-the-ground field performance, and through meetings or correspondence with employees, contractors and other third parties (e.g., government agencies, community groups, affected Indigenous Peoples, conservation organizations), as appropriate, to determine conformance to the SFI 2022 Forest Management Standard, the SFI 2022 Fiber Sourcing Standard, the SFI Small Lands Group Certification Module and the SFI Small Scale Forest Management Module for Indigenous Peoples and Families

· Audit teams must have team members that are qualified to assess on-the ground (i.e., in woods) compliance with SFI standard requirements.

6.1 COMPETENCE OF AUDIT TEAMS
…… For audits of SFI 2022 Sections 2 and 3… at least one member of the audit team shall have knowledge of forestry operations in the region undergoing the audit, at least one member shall have knowledge of applicable laws and regulations, at least one member shall have knowledge of the socio- demographics and cultural issues in the region, and at least one member shall be a professional forester as defined by the Society of American Foresters (SAF), the Canadian Institute of Forestry (CIF-IFC), or licensed or registered by the state(s) or province(s) in which the certification is conducted where applicable. For forest management audits, the audit team shall have expertise that includes plant and wildlife ecology, silviculture, forest modeling, forest operations, occupational safety and health, international labor standards, and hydrology.

In-person, on-the-ground audits are the expectation. Remote audits are the exception and only after a previous audit without non-conformance.

APPENDIX 3 - USE OF REMOTE AUDITING TECHNIQUES FOR SFI AUDITS

PART 3: PRECONDITIONS FOR REMOTE AUDITS

…. The certification body should identify and document all risks associated with ICT that may impact audit effectiveness, including the selection of the technologies, and how they are used. This review should ensure that the Certified Organization has the necessary infrastructure to support the use of ICT and is a viable candidate for remote audit.

Where a Certified Organization demonstrates a history of conformance at the system implementation level (or for the locations being assessed), audits using ICT may be considered for use when one of more of the following applies:

vi. For Certified Organizations with an SFI 2022 Forest Management Standard or an SFI 2022 Fiber Sourcing certificate, the surveillance audit can be conducted remotely using ICT where:

a. the certification body can justify that the audit techniques used deliver sufficient confidence in the *Certified Organization’*s compliance with the standard(s) requirements; and

b. no nonconformity was raised during the previous initial, surveillance or recertification audit, or the corrective action for the nonconformity can be clearly verified by other audit techniques.

PART 4: PLANNING AND SCHEDULING REMOTE AUDITS

The certification body should define criteria for determining when it is appropriate to perform part, or all, of an audit remotely. Criteria to consider include identification of the standard requirements appropriate for remote audit using ICT, and the eligibility of the Certified Organization for remote assessment (e.g., availability of records in electronic format, suitable internet connectivity, teleconferencing platforms, etc.).

…. Where the planning process identifies audit risks or opportunities, the audit plan should define how and to what extent ICT can be used for remote audit purposes to optimize audit effectiveness and efficiency while maintaining the integrity of the audit process. When ICT is used, it contributes to the total audit time, as additional planning may be necessary which may impact audit duration.

For Certified Organizations with an SFI 2022 Forest Management Standard or an SFI 2022 Fiber Sourcing Standard certificate, the surveillance and remote audits using ICT techniques may be considered, where:

i. the certification body can justify that the audit techniques used deliver sufficient confidence in the Certified Organization’s conformance with the standard(s) requirements; and
ii. no nonconformity was raised during the previous initial, surveillance or recertification audit or the corrective action for the nonconformity can be clearly verified by other audit techniques.

Thanks Jack - the issue is that the ‘independent certifiers’ have been found to be providing certificates even when logging practices are clearly not in the spirit of sustainability. One big issue is that the voluntary certification schemes have been written by the industry. You should read this related article for more information: How Auditing Giant KPMG Became a Global Sustainability Leader While Serving Companies Accused of Forest Destruction - Inside Climate News

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Thanks so much for the thorough reply! I appreciate you taking the time to help us all understand SFI’s verification and auditing process.

One important point to distinguish in the material you provided: the certification language makes a distinction between “on-the-ground compliance” (compliant forestry practices in use) and the method used to audit and confirm those practices: on-the-ground auditing of the claims of compliant forestry practices.

In the language you provided, SFI seeks to ensure “on-the-ground compliance” with remote (i.e., off-site) auditing. Allowing remote audits after a conforming audit is a low bar to set, especially when other certification schemes require recurring on-site auditing.

To Will’s point—there is a healthy skepticism about environmental claims made about timber products. To allay these concerns, deep transparency and strict regulation is necessary, moreso when certification schemes receive money from industry groups.

Personally, I look forward to a day where SFI’s regulations have evolved to a point where they can be celebrated by colleagues at NRDC as best-in-class sustainable forestry practices! With your reach and influence, this could be globally transformative. We’re not there yet, but it’s exciting to see serious engagement with these issues, and I’m looking forward to seeing your standards continue to evolve.

Thanks Jack. Yes, we are in agreement on full transparency. To that point, all certification standards allow remote auditing: FSC, PEFC, and SFI (Appendix 4). FSC addressed this with a session at their General Assembly last October. PEFC is in the process of revising its Certification Body processes for auditing Forest Management and will have enhanced requirements addressing the use of remote auding.

We all believe in the value and merit of the use of remote audit techniques given today’s environment and the technology available. Happy to answer any other questions on the credibility of SFI, but also check out our key facts on our website at Key Facts About SFI - forests.org

It would be great to continue the discussion on these and any other concerns you may have. Let’s schedule a time next week annie.perkins@forests.org

Thanks!
Annie

Thanks for the back-and-forth, Annie! The ambiguity in your message is a tad misleading. You are right to say that FSC addressed remote auditing in their 2021 general assembly, but they voted down the motion that would have allowed it. All FSC provisions for remote auditing that I’ve seen are very narrowly limited to cases where auditors cannot visit forests due to Covid-related travel restrictions (example here) or as a supplement (not a replacement) for in-person auditing. As the article Will shared points out–all certifications (FSC included) need to go farther and do better, but material distinctions between certifications still exist.

Certainly did not intend for that to be confusing or misleading. To clarify, FSC GA discussed and then voted down the use of remote auditing for initial FM certifications – not the use of remote auditing for existing certs. Remote auditing for initial certifications is not a current practice for either FSC or SFI, while both do allow remote audits (for existing and previously conforming certificate holders) on a limited basis. Again, please reach out directly with any other concerns, thanks!
Annie
annie.perkins@forests.org