Thoughts on the New FSC Standards – A Step Too Far?
The FSC have brought out a new draft Standard, which is currently in the consultation period. Have they gone too far in their demands for admin input? Our environmental officer Roger Warwick discusses this in detail…
The draft of the new FSC Standard (FSC-STD-40-004.v3) currently out for consultation. Once again the FSC seemed to have lost sight of the fact that for the paper/print & publishing business sectors they represent an added value option to support sales, not to control it.
Perhaps this draft standard is an indication that they now, increasingly want to dictate how we actually run our businesses by requiring an increasingly larger amount of administration to be completed?
The draft Standard is now almost 40 pages long and includes a selection of words that may require the use of a dictionary or thesaurus to understand it.
The use of cartoon-like illustrations to demonstrate some basic principles of procedures is perhaps an indication that they realise the wording is too complex? The bottom line is that the administrative burden of being certified is increasing disproportionately to its needs.
There are a number of key points our customers and suppliers might like to pay close attention to:
In particular, we would highlight the new definition of claim period. This relates to limiting the ‘shelf- life’ of certified products in the context of length of time you can continue to claim the product is certified for. In other words if you buy certified material, and it is a slow-moving item, beware of how long your FSC certification will last on that product.
According to the standard, an as-yet-to-be-defined clock will count down from the moment the product is bought and beyond that time line you cannot claim the product as certified anymore. This is an unjustifiable use of an un-necessary administrative control.*
Return of the Online Claims Platform
A more significant issue is the resurrection of the Online Claims Platform (OCP), which the FSC had to back-pedal on last year, making it voluntary instead of mandatory.
In the new draft, there is a choice - although perhaps not really?
Certificate holders can opt to still use OCP if desired, or ‘create their own manual or IT based validation process,’ which will provide the FSC with the same information. If this process serves to validate volumes, then it raises the question as to whether annual surveillance audits are really necessary.
They have clearly failed to acknowledge the argument that put this project on the back foot last year, which is that across paper-merchanting at least, there has been a loss of more than 25% of personnel in the past 5 years, as a result of which companies no longer have the staff to run this administrative leviathan as well as concentrate on their core business.
We would urge you to take a thorough look at and then respond to the draft, since numbers will count towards any re-consideration or re-drafting of the standards. Otherwise all of the new items will be imposed on certificate holders.
For more information please contact Roger Warwick, Environmental Officer on: firstname.lastname@example.org