Changes to FSC Group Certification Rules Benefit Printers

By | August 5, 2010

For many smaller organizations, the cost as well as the amount of time required for the learning curve, procedural development and maintenance of an FSC certificate can be prohibitive. For years, the Forest Stewardship Council has had a program called Group Certification in place (FSC-POL-40-002), allowing organizations under different legal ownerships to band together under one certificate and share costs and resources by taking advantage of an economy-of-scale audit sampling program. This however this has been unworkable for most in the past.

The problem had been that program eligibility was limited to organizations having no more than 15 workers, or no more than 25 workers and annual forest product sales (i.e. printed material) of no more than $1,000,000 USD. This made certification unreasonable for many organizations as that kind of employee-to-revenue ratio was unrealistic at best. All of that has changed with a revised 5-year pilot program for group certification enacted by FSC-US which allows for any organization with less than $5,000,000 in annual revenue, regardless of employee count, to be part of a group certificate.

By utilizing a centralized group coordinator, multiple independent legal entities are able to share many of the basic procedural development and ongoing monitoring functions of certification without dealing with the learning curve and resource allocation required to do so separately. The net effect is cost and time reduction for each group member involved. This is similar to the Multi-Site certification program (FSC-STD-40-003) already employed by many organizations who legally own all of their sites. Virtually all FSC-certified mills, distributors and printers with multiple locations are currently certified under multi-site certificates and operate under the same type of framework as a group certificate.

Group certification has enormous potential benefits for at least three distinct types of groups in the printing industry. First are in-plants where the organizations do not compete with each other, yet have open lines of communication through either associations or proprietary list serves. Second are franchises in which each site is independently owned and conforms to a central office’s authority where the coordination function can be unified, and third are associations, whose members are organizationally connected and can band together for mutual benefit despite sometimes competitive relationships.

The primary requirement for any group is to first appoint a coordinator who can organize, develop, train and monitor the group’s activities. Member sites are subject to the coordinator’s oversight and must agree to adhere to an open and transparent process as a participant of the group entity. The group coordinator is responsible for developing procedural and operational templates for all of the participating sites for them to utilize and customize for their own unique usage requirements. Although each group member may have their own unique workflow and business rules, a collaborative effort can be made to develop systems that will work for the good of the all.

The group coordinator is required to perform initial internal audits of each member’s conformance as a precursor to certification to ensure workability of each site’s system, issuing corrective action requests where non-conformances are found, and working with violating member organizations to rectify and close out any outstanding issues. Once the FSC certificate has been awarded, subsequent annual internal audits occur during the course of each year, which are followed by certifying body site visits in which a representative sampling of sites (usually 20 to 25 percent of the sum) are audited every year.

For those unfamiliar, certifying bodies are the organizations accredited by the FSC to conduct day-to-day business activities on FSC’s behalf including, but not limited to, audits and trademark use approvals. Certifying bodies in the US are: American Green, Bureau Veritas, QMI, SGS, SmartWood and SCS.

As a requirement of certification, records of FSC activity must be maintained, collected and reported to the FSC through the certifying body in a summary format annually. This can be boiled down to each member organization’s total FSC activity without regard to client information should there be an issue with confidentiality.

Depending on the size of the group, the time required by the group coordinator for FSC oversight can vary. The development of procedures and data collection systems, along with training and initial internal auditing can be pretty intense, therefore the coordinator needs to be dedicated to the task. For a small group, as time goes on, the coordinator’s demands lessen. For a large group (potentially in the hundreds) the FSC coordinator’s activities can be closer to a full-time job.

Because the activities of each site affect the group as a whole, it is imperative (and required) that the coordinator has both the autonomy and authority through contractual relationships to enforce certification requirements. Each site must also have a designated site coordinator who acts on the group coordinator’s behalf, enforces FSC requirements at the site level, and complies with any requests made by the group coordinator in the course of his or her duties. Part of that authority is the ability of the group coordinator to suspend or remove any member at any time for non-resolution of conformance-based issues should they arise. The group coordinator is also responsible for collecting fees associated with certification from all participating sites, and for all coordination with the certifying body including obtaining trademark use approvals.

FSC group certification has huge potential. It’s already in use by forest land owners and other wood product manufacturing groups, sometimes with membership in the single digits (UMCFPG in Aitkin County Minnesota has 8), or the tens of thousands (Wisconsin’s MFL Program has 31,000 members) and has been proven to be a cost-effective solution across the board. The printing industry has not yet taken advantage of this system, but now that the maximum revenue level has been raised to a realistic level, the time is right to take full advantage of the situation.

Organizations no matter how loose or tight-knit who are interested in exploring this very realistic and workable option can contact me at vicbarkin@aol.com, or can contact any of the certifying bodies listed at www.fscus.org/certifiers.

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