Vice President, Mountain States Printing Education Foundation
The U.S. Department of Labor’s Bureau of Labor Statistics had promised it was finally going to post many of our industry’s real production-related job titles/occupations on July 15th after almost a decade of work, initiated by Mountain States Printing Education Foundation. They are now saying that the “16.0 Database will come out the end of July/beginning of August. New O*NET online with 16.0 database will be released in September.” This continues to be one of the most frustrating endeavors that those of us who have been working on it have ever encountered.
In 2001 we (Mountain States Printing Education Foundation and Printing & Imaging Association Mountain States) were approached by the City & County of Denver to begin a funded training program for our industry, which they considered one of their largest and most important industries. The impetus changed after the tragedy of 9/11, but the following year we began working with them again.
What came to light at the time was a major discrepancy with what we and the City knew to be true and what the Department of Labor (DOL)/Bureau of Labor Statistics (BLS) had to say about our industry. We learned that all of the Federal industry data was completely incorrect and most of the information that they were reporting about the industry was 30-50 years old, although there were a few current job titles/occupations listed. We were extremely fortunate that our information prevailed at the time and we began training programs for current and potential industry employees. The funding underwrote training for 36 employees, one of which is now a member of Mountain States Printing Education Foundation – Melissa Rogers.
Prior to starting the classroom training, we assembled a number of Colorado printing related firms to review the job descriptions/occ upations that were posted on the Department of Labor’s Occupational Information Network (O*NET). Once that was accomplished (changes made to existing job information, very outdated jobs listed for removal and new jobs added) we hired an intern to gather and prepare a list of all current industry-related jobs and submitted them to our first contact person at the Department of Labor. That process took until early 2004. At the same time, a gentleman who had been hired as a consultant by DOL’s Employment & Training Administration (ETA) contacted Ben Cooper, former VP of Government Affairs at Printing Industries of America, to get his approval of the printing industry information posted on O*NET. By then, Cooper was aware of what the Foundation had discovered and sent the gentleman to work with us. With the approval of all the PIA Affiliates around the U.S., the Foundation took on the task of being the voice of the industry to “fix” the misinformation that was being purported about the industry.
Part of the “fixing” process was to have our intern, Nelson Alfred who was attending Platt College at the time, collect a list and short job description of every job in the industry and prepare a brochure which was sent to BLS noting every job that “Requires Industry Related Education or Formal on-the-Job Training”. That information was basically rejected by BLS since it was industry generated. We then partnered with the Colorado Department of Labor to generate a survey (in government manner and lingo) which confirmed our information, forwarded it to BLS and again the information was disregarded. At the same time Jim Kyger and Ron Davis from Printing Industries of America sent their surveys of job information (wages, job titles and The Print Market Atlas) to their contacts at the DOL – same result.
There were many theories about why the government information was wrong, one of which was that because there were no current apprenticeship programs, it was suggested that by writing new, modern apprenticeships – the information would be updated. We worked with the Colorado representatives from DOL’s Bureau of Apprenticeship & Training (BAT) to write the needed programs which were approved by DOL and the Union only to have them listed under classifications that no longer exist in the industry. At that point we pulled the apprenticeships until changes were made to the “job titles/occupations”.
Throughout the process former PIAMS president and Foundation secretary/treasurer Kathy Lauerman had ongoing dialog with various BLS/ETA/BAT representatives. One of the BLS representatives was also on an international SOC Code group (Standard Occupational Classification codes) that adopted our updated titles on an international level – but not in the U.S. This gentleman also took it upon himself to informally confirm our information in the Washington DC area, and of course it was confirmed.
Requests for approval and input continued from the BLS and at that time Carol Hurlburt of NPES and Kathy Lauerman of PIAMS, who have both since retired, were both heavily involved in the dialog. Promises were made over the years from various DOL departments to update the information but none came to fruition. In 2007 the Education Summit Group for Graphic Communications, a group sponsored by the Print & Graphics Scholarship Foundation (PGSF) adopted the cause as one of their action items. By then many Graphic Communications programs around the country were being closed – Most of which because of the misinformation being purported by the BLS about our industry. In addition the number of industry employees generated by the Department of Labor was also underreported because they only count production related numbers not full industry employment numbers.
The Education Summit Group active sub-committee members who continued the effort under the chairmanship of Mark Nuzzaco of NPES included Pat Klarecki from Ferris State University and Kathy Lauerman with tremendous support from Jim Kyger at Printing Industries of America, who ultimately took the reins to continue pestering BLS (and still does) to get correct industry information posted.
There are so many people to give credit to for helping with this decade long project and the list is far too long to cover – but you all know who you are. Thank you for your input and persistence. We would be remiss though in not thanking the woman who first came to us from the City & County of Denver who believes strongly in our industry and is a great proponent of what we do – Priscilla Bohl, not your typical bureaucrat. And, an additional “thank you” to Alexandra Hall and Joe Winter of the Colorado Department of Labor, who we can’t wait to eventually send a note to when the Feds finally update our information. Having correct job title/occupation information will also help them collect proper statistics on a state level.
Now all we can do is sit, wait, and continue to pester the DOL to get what has been approved and posted in the O*NET/SOC taxonomy placed on the actual O*NET website that is used by schools, economists, and all government agencies.
When do two seemingly similar-sounding service offerings present completely different business models? When comparing Managed Print Services to Print Management Services. These sound the same, and in a certain situations can be used interchangeably, however the industry definitions are quite distinct and different.
Managed Print Services (aka; MPS), Managed Document Services, Enterprise Printing Services, or any other variation on this theme refers to the active management of fleets or groups of hardcopy output devices and by extension the digital output, capture and/or dissemination of data and/or images which are a by-product of such technology, all of which should be a strategic component of an organization’s (enterprise) document management strategy.
Of the many goals this service represents, that of cost-effectively controlling how, when and where organizationally necessary enterprise printing is accomplished rises to the top of the heap. This is closely followed by operational efficiency, productivity, storage, retrieval and security.
Depending on the model employed, this can either be a boon or a disaster waiting to happen for an organization with a widely distributed fleet of desktop laser or inkjet printers, faxes, scanners and small-to medium MFPs (or MFDs) where the task at hand is deemed unmanageable.
The premise of MPS is that through an initial discovery phase, an entity, either internal or external to the organization can root out every localized ineffective, underutilized or overutilized print culprit, assess their individual efficiencies or inefficiencies, and implement wholesale positive change in the way the organization manages how they print on an enterprise level. This is accomplished through mandates, decommission and installation of appropriate devices, actively monitoring usage, and in some cases, outsourcing or shifting higher-quantity work to devices or outsourced facilities utilizing appropriate cost and time-effective technology.
That’s the simple explanation and it sounds great in theory, however in practice the promise may not ring so true. Just about every OEM and/or their regional resellers offer one flavor or another of this kind of service. They all tout amazing savings with the ability for the organization to concentrate on their core business activities without having to worry about managing documents. Their profit motive should be seriously considered with a cost-benefit analysis. Quite frankly in some cases it makes sense.
For the organization that does not consider enterprise document management to be strategic to their core mission, the out-of-sight, out-of-mind approach MPS provides may seem perfect. After all, the provider of this service will always do what’s in the best interest of the organization, right?
This wholesale technology alignment/replacement strategy can even extend to in-house services where “copy” centers are present organizationally or departmentally. An adept MPS provider can be very convincing, again where enterprise document management is not considered mission-critical, with reasons why they should outsource this service.
Quite frankly, this may be true where an organization doesn’t have (or anecdotally doesn’t believe they have) the economy of scale to dedicate staff to research, identify, negotiate and implement the best solution for the best interests of the enterprise, or where little or no fiscal oversight or responsibility is required or deemed to be necessary for this segment of the organization’s business for whatever reason. What a perfect customer to have! On the other hand, a well managed operation will always know where their true, fully budgeted costs are for all facets of their hard-copy output needs, and this extends to knowing what is best printed when, and where.
Depending on the complexity of the enterprise this could be all encompassing enough to include micro-run desktop-applicable printing (both monochrome and color) where local office printers or MFPs are appropriate technologies, to medium-to-large production runs (also either monochrome and/or color) where CRDs (central reproduction departments aka copy centers) are more appropriate for given run lengths, to print runs which have no business being run locally and are outsourced by the individual department or the enterprise to either an in-plant possessing the appropriate technology or to an appropriate outsourced facility.
This is where Print Management Services (which for some reason I’ve never seen the complete acronym used for, so we’ll just call it PM Services) comes in to the picture. Now not only does the enterprise have the opportunity to “control” costs through either internal or external service providers for their enterprise document needs, but they can extend this process, again either internally or externally to encompass all printed material including digital printing, offset printing, wide format, apparel, specialty, novelty, etc.
PM Services, like MPS, can be implemented by an external service provider who purports to have the resources necessary to answer any need within a certain scope of work, or by an internal (in-plant) resource, without the organization necessarily having the ability to produce everything in-house while keeping the faith to serve the organization’s core mission.
In either case the PM Services provided for should be in the best interests of the organization. Not based on the service the provider has available. The question then comes down to how the enterprise decides what is best for their needs. It is only in rare cases that an outsource vendor can provide all of the services most medium-to-large enterprises require, so multiple service providers are the usual order of the day.
The best approach however is to integrate all the document needs of the organization under one roof, even if it means outsourcing some services while retaining others. True MPS on the one hand, which can include printer and MFP fleets, CRDs and print centers, and PM Services which can encompass high-speed digital, conventional sheet-fed and web offset, and all of the other print-mediums out there, in a perfect world should be centrally controlled from a cost-and-operational efficiency procurement standpoint with capable internal enterprise-level oversight and expertise in place.
It is only then that the organization, whether we’re talking about you specifically, or your customer, can effectively manage (or have you help manage with integrity and trust) what arguably should be considered a strategic, core, mission-critical business activity.
Over the past few years, discussions surrounding how legal paper sourcing decisions are made by print buyers have received less and less attention from the press. This doesn’t mean that the issue has melted away; it merely means normalization of the process has relegated it to the board room and to the senate committee. However that could change based on worldwide activities of a similar fashion. In other words, the race is on.
In a mere 22 months if you print on paper anywhere in the European Union (EU), there will no longer be a choice. Verified legal timber product sourcing, including pulp and paper, will become law.
Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 lays down the obligations of operators who place timber and timber products on the market – also known as the (Illegal) Timber Regulation counters the trade in illegally harvested timber and timber products through three key obligations:
1. It prohibits the placing on the EU market for the first time of illegally harvested timber and products derived from such timber;
2. It requires EU traders who place timber products on the EU market for the first time to exercise ‘due diligence’;
3. Keep records of their suppliers and customers.
The Regulation covers a broad range of timber products including solid wood products, flooring, plywood, pulp and paper. Interestingly though, not included among a few other products such as rattan and bamboo are recycled products and printed papers such as books, magazines and newspapers.
The EU has chosen their battles just as the US has with the now familiar US Lacey Act. By excluding printed matter (for now) but including pulp and paper, the EU’s Timber Regulation leapfrogs Lacey in that European printers will no longer be at will to purchase paper without regard for legal harvests, specifically aimed at imports as of March 2013.
The Parliament of the Commonwealth of Australia Illegal Logging Prohibition Bill 2011 is still in the consultation phase, but is written so vaguely that if passed in its present form, is sure to create a (common) wealth of issues. For now, we have to take a wait and see approach. Taking their Bill with a grain of Aussie salt, I wouldn’t expect to see it passed anytime soon.
As a side note in its “Comments from the Government of Canada on Australia’s Draft Illegal Logging Prohibition Bill 2011”, the Canadian government is not amused. On May 6, 2011 the Secretary of the Senate Standing Committees on Rural Affairs and Transport wrote; “In particular, Canada is concerned that the Bill may lead to a requirement (whether explicitly stated or implied) for Australian importers to conduct risk assessments (or the ‘timber industry certifiers’ to do so on their behalf) on any unprocessed or processed timber products imported into Australia. Such a requirement would be particularly onerous for complex processed products made of timber sourced from multiple suppliers…” (like paper merchants and printers).
Which brings us back to the Lacey Act and its implications in the paper and printing industry here in the US. For the time being it seems like no movement on implementation pertaining to US-based paper mills and printers is imminent. That said, with all of the activity on other continents, one has to wonder.
Recently, the Forest Stewardship Council released their revised FSC-DIR-40-004 document, containing a series of advice notes which every certified printer (and converter, and merchant, and broker) “should have” received through their certifying body (CB). Included in this document is Advice Note ADVICE-40-004-03 which deals with the ability for printers to FSC-Label certain classifications of paper.
A synopsis of the official background for ADVICE-40-004-03 which is contained in FSC-DIR-40-004 and is titled: “Reduced labelling threshold of 50% for chip and fibre based products” states in effect that when the new Chain of Custody standard was approved in November 2007, a labeling exemption threshold of 50% (certified material, the balance being “controlled”) for chip and fibre based products under a percentage (or transfer) system was maintained by means of an Advice Note. (All solid wood products such as or made from lumber, plywood or veneer had to implement a 70% minimum at that time which is still in force today).
The FSC would have loved to enforce the conformance for all chip and fiber products which includes all paper and paperboard to the 70% minimum back in 2007, but the mills pushed back and reduced labeling threshold was born. This advice note now the latest twist added to the existing requirement as a way to definitively force the mills to conform with the intended 70% minimum within five years (their other option being to move to a Credit System).
The official advice note can seem quite cryptic:
- FSC certificate holders may request authorization from their certification bodies to continue labelling chip and fibre products based on a reduced labelling threshold of 50% until 31 December 2015
- Authorization shall only be granted for those product groups with chip and fibre components registered as being commercially produced based on a labelling threshold of 50% before 01 April 2011.
- Certificate holders operating a transfer system that have not registered their product groups can also label products based on a labelling threshold of 50% in case they are able to demonstrate to their Certification Body that the material they receive has already been registered by a previous company or the material was received with an FSC on-product label.
a. In the first case, sales and delivery documents issued by the supplier shall include the additional claim “registered” (e.g. “FSC Mixed 50% registered”);
b. In the second case, the certificate holder shall retain evidence that the product was received with an on-product FSC label (e.g. packaging or product sample).
- Certificate holders interested in the product registration shall submit the following documentation to their Certification Body until 31 March 2011:
a. A list of product groups with products labelled on the basis of a 50% threshold, using the template provided in Annex A of this Directive;
b. Copies of sales invoices for the registered products in each listed product group as evidence that they have been commercially produced.
- Certification bodies shall upload the approved registration form into the FSC database following the procedures to make it publicly available. No new product groups can be added to this list after 31 March 2011.
- Product groups registered by certification bodies according to this advice shall be in compliance with a labelling threshold of 70% as of 01 January 2016.
NOTE: Companies that do not comply with the requirements of this advice are not eligible to label FSC products based on a 50% threshold as of 01 April 2011, and therefore shall apply a labelling threshold of 70% from this date onwards.
“So what does this mean to me?” is a natural question that every FSC certified printer should be asking their CB if they don’t know already.
Let me put it in real-life terms most printers can understand. The majority of paper mills use the Credit System which effectively renders a product the equivalent of 100% certified. This advice note does not pertain to any inputs purchased from these mills or their merchants which are received with a claim of “FSC Mixed Credit”.
There are however a handful of paper mills using the Percentage System for calculating certified content for their products. Generally speaking, none historically have been consistently sold at a minimum 70% level, which necessitates conformance with this requirement in order to maintain the status quo for the next five years. (Most on the market today range between 50% and 60% certified material, sold for example as “FSC Mixed 50%”).
This “transitory” exemption allows for paper that contains at least 50% certified fiber (but less than 70%) to still be eligible for the FSC label up until January 1, 2016. The way the advice is worded in item 3 (above), you the printer are dependent on your supplier’s complete conformance. As long as your supplier either passes along the phrase “Registered” as part of the FSC Mixed XX% claim and/or; the product is received by you as an FSC labeled input; the product remains eligible for you to apply the FSC label. You may however have to provide evidence to your CB in order to gain labeling approval, which becomes another hoop to jump through.
Things to take into consideration are that first, there is a note within the advice note which states: “The exemption detailed in this advice is specifically related to the eligibility for labelling FSC products and not to the eligibility of producing or selling products with an FSC claim on invoices.” Therefore because not all merchants may apply for this exemption because it technically doesn’t affect them, the product could be rendered ineligible if sold by them without them registering and without an FSC label (FSC labels, even for paper in cartons, are an option, not a requirement).
The easier way is to register for the exemption with your CB. This is a one-time deal and should be a very simple process for most printers. The information required is to simply furnish your Product Group as defined on your Product Group Schedule for FSC Mixed Products (i.e.;FSC Mixed Printed Materials) on the form (which should have been) provided by your CB along with an X in the appropriate space denoting “Use of the labelling threshold of 50% until 31/12/2015” along with a few copies of invoices for said Product Groups that you have sold (i.e.;FSC Mixed Printed Materials).
Do it now and save yourself a headache in the future.
If you were in the storefront printing industry in the early-to-mid Eighties, the sign “We Accept Disks” means something to you. It was the beginning of the digital and “desktop” printing revolution. “We Accept Disks”. It meant you had a PC and/or maybe a MAC, and would accept customer floppys in order to print out copies to paste up and shoot to a neg or output an analog poly plate, or maybe run copies (not files) on your copier. But it didn’t mean there was any compatibility with what your clients were bringing in. All you knew was that you had to do it because everybody else was.
Let’s get one thing out of the way right now. This is not going to be a crystal ball article. The rhetoric surrounding “green”, “sustainability” and “corporate social responsibility” has cooled a bit. This means we are now in the normalization phase. Between 2005 and 2008, literally everything gained a greenish tinge. It’s the same with every standard business practice bubble. First there were the early adopters, and then market acceptance comes along. This is typically followed by market saturation, and finally normalization. Many shops claimed to be a “Green Printer”. Maybe you got FSC certified, increased your recycling efforts, switched to low VOC chemistry or replaced or upgraded offset equipment, or implemented higher efficiency digital.
2009 capped the trend by becoming the year of the “green printing trade show”. Again, everything had a greenish tinge to it. It didn’t matter what the product or service was. It was either “green” or “sustainable”. Then the inevitable happened. The Six (or Seven) Sins of Greenwashing hit the print industry airwaves and uncertainty about the message and its credibility crept in. Trade shows in 2010 had a diminished green presence. Not that it completely disappeared; Green now has earned a secured place in Print’s message. Now the FTC is releasing new green claim guidelines.
So here we are in 2011. Responsible sourcing/procurement is fast becoming the driving realization that encompasses everything green and sustainable. Business Green offers 11 (as in 2011) things to look for in the next 12 months. Number 7 is “Ethical consumer spending will keep rising”. To quote a portion of the Business Green statement: “Every indication suggests this market will grow substantially this year even as other areas of the economy falter. It is time to stop treating green industries as a niche and appreciate them for the robust and fast-growing success stories they are”.
Let’s take a closer look at what this means to the printing industry.
Paper is most likely to be thought of first. Chain of Custody certification, whether it’s FSC, SFI or PEFC puts third-part verification of at the very least legal and ethical sourcing. The credibility of the certifying bodies, who themselves are validated by independent accreditation organizations provides transparency as well as credibility. Supplies, whether for offset, digital, or for infrastructure (janitorial, facilities) also have their certification and third-party certifying body counterparts.
Green computing is going to have a large presence this year as the IT industry takes sustainable computing mainstream. The Climate Savers Computing Initiative is a nonprofit group of consumers, businesses and conservation organizations dedicated to promoting smart technologies that can improve the power efficiency and reduce the energy consumption of computers.
Formalized waste-stream reduction strategies have become profit centers for many organizations. Harmon Recycling, a division of Georgia Pacific is one of many organizations offering full-service programs to both manufacturing and office environments. Everything that can be recycled should, including strapping, containers of all types and other shipping material. In short, a zero manufacturing and office waste program is more of a reality now than ever as the reclamation industry matures.
A life cycle assessment (LCA, also known as life cycle analysis, ecobalance, and cradle-to-grave analysis) is a technique used by organizations to assess each and every impact associated with all the stages of a particular process from raw material sourcing through materials processing, manufacture, distribution, use, repair and maintenance, and disposal or recycling). LCA’s can help avoid a narrow outlook on environmental, social and economic concerns which can validate both responsible sourcing and responsible disposal methodology.
Then there are all the other infrastructure improvements that also have their ethical, responsible and or sustainable components. This includes everything from buildings, HVAC, lighting, logistics and production equipment, to transportation and facilities management operations.
The end-game is that professional purchasers are embracing responsible sourcing. Organizations like The National Association of State Procurement Officials, the Responsible Purchasing Network, and The International Society of Sustainability Professionals are serious about responsible sourcing and many options are considered in choosing suppliers, based at least in part on their ethical sourcing policies. Don’t be caught out in the cold because you cannot quantify and provide objective evidence pertaining to where your raw materials, products and services came from, and where your waste and by-products are going.
Responsible sourcing is the new green.
For this post, I’m offering my own unscientific perspectives based on a unique window I get to peek into through – my experience actively consulting with or for organizations of all sizes and in all sectors of the industry. This includes everyone from pulp and paper mills to paper merchants to printers to print brokers and finally, print buyers.
My travels take me from coast to coast and north to south here in North America working with over 100 clients in 200 locations per year. From ten-employee in-plants to billion dollar corporations, there are common themes that seem from my perspective to permeate every facet of the paper and print-space.
Necessity may be the Mother of invention, but it’s also the Mother of reduction, the Mother of consolidation and ultimately, the Mother of efficiency. The past few years of recessionary behavior has proven to be a Petri dish of sorts that prove this hypothesis.
Common to every nearly enterprise is the realization that certain functions have had to be reduced or eliminated in order to survive. On the M&A level this means economy of scale and centralization of management, marketing, accounting and human resource functions. Within the same organization, lower level elimination of redundant or non-value added positions has become the norm. I’ve walked in the door of many a facility where “ring the bell/buzzer/phone” for front desk service is now in force where before, the duty of the receptionist was just that; to receive.
If there is a front desk person it is frequently a CSR or AR/AP employee whose new workspace happens to be visibly at the front door of the establishment. The same goes with many other positions where value is perceived as being intangible and can therefore be eliminated and delegated internally to the wearers of many hats who are any enterprise’s new survivor class.
The other trend I’ve seen is that along with staff reduction coinciding with the amount of work coming through the door, where say a full 3 shift operation has been forced down to 2, a new and interesting problem has arisen. When the workload is steady, which is a lowered expectation these days, the available labor pool is being tailored to be able to handle the volume, however now there seems to be more of an optimistic trend among print buyers and advertisers.
It’s what I call the “loosening of the purse-strings syndrome.” As the economy and consumer confidence levels elevate slightly, print buyers are a bit more confident and optimistic. Over the past six to twelve months, my clients, generically now have the problem of not having labor available for those spikes in volume when they occur. In a way this is a good problem to have, since they now feel like they have weathered the economic storm and are now emerging as a more efficient enterprise through all their tribulations.
In some markets an interesting phenomenon is taking place. Where similar facilities with similar capabilities and equipment have either survived or failed, there is a glut of skilled labor. In some cases these spikes are handled by employees working for more than one company- not that this hasn’t always happened to some degree. It just seems that now there are a lot more skilled operators willing and/or able to be engaged on-call. The problem here is that this is usually more of a mature labor pool, so with regard to longevity, an arrangement such as this is not self-sustaining. No one seems to want to be so optimistic as to ramp back up to former levels, so this conundrum will continue for the foreseeable future.
I don’t pretend to be an economist. I’ll leave that job to Dr. Joe. That said, I do ask the same basic questions wherever I go. How’s business? Have you had layoffs or reductions in the past year and if so, by how much? Have things stabilized? Are you bringing staff back on? Are your customers a bit more optimistic? Are you?
Of course the answers vary, but on average they are: tolerable; yes; yes; yes; yes; yes. It is encouraging if anything, that there is a pervasive optimism out there. In my book optimism equals confidence. Confidence equals risk-taking, albeit cautiously, risk-taking equals spending. Spending of course raises the economic tide overall, and a rising tide lifts all boats.
So ultimately in the printing industry, especially in the areas of growth such as digital printing and integrated media, I’d like to believe that because of all this spending on infrastructure, equipment and new labor, i.e. emerging skill sets, are about to take a quantum leap based on the demand for printing in our brave new world. A renaissance if you will.
To move forward and be the cause of change, mills, merchants, printers and brokers must again refocus their marketing efforts on a now more optimistic print-buying public, who will have a bit more money to spend as long as they are convinced of the ROI once they have been educated, again, by their vendors of the benefits of print.
So, in the end, you can talk about GDP, unemployment, print shipments and the calculated risks of either doing or not doing something to change the game all day long. All I’m saying to sum this all up is that anecdotally, we seem to collectively be climbing out of a casualty-ridden hole, a bit wiser, a bit stronger, but non-the-less gun-shy. In many cases the casualties have been necessary. It got rid of some of the low-ballers to hopefully create a more level playing field where the survivors can compete fairly on a level playing field, charge a fair price and continue to continue on now that the ball is rolling again.
What do you think?
Ever heard this one before? A print buyer sends the specs for a job specifying “recycled paper”.
We’re talking about recycled “content” here, which is simply any percentage of the paper made from fiber (paper) that has been diverted from a waste stream. This is further broken down into pre- and post-consumer waste components. Commonly, but not always, it’s only the post-consumer portion that’s reported on invoices or printed on the piece its self.
Now, especially since the FTC’s proposals for their new Green Guides have hit the streets, many potentially-effected entities are waiting for the storm concerning the definition of post-consumer waste. This may not seem like a big thing, but it is.
It’s more important than ever now to define “recycled content”. For instance, did you know that under the FTC’s current as well as their proposed guideline, a specific edition of printed matter, say a magazine issue, can be considered either pre-or post-consumer waste depending on where it lives when it’s recycled?
Post-consumer reclaimed/recycled/recovered waste/fiber (PCW or PCRF) definitions are going to become a touchy issue in the coming months. Once the FTC codifies their definition, it will become the de facto standard, and no matter which way the wind blows, the FTC will wind up continuing to put their definition at odds with the interests of others.
The current FTC Guides provide that marketers may make a recycled content claim from materials which have been reclaimed either during the manufacturing process (pre-consumer) or after consumer use (post-consumer). This sounds pretty straight-forward.
Furthermore, the FTC aligns their definition of PCW with that of the EPA’s: “Fiber such as paper, paperboard, and fibrous materials from retail stores, office buildings, homes, and so forth, after they have passed through their end-use as a consumer item; all paper, paperboard, and fibrous materials that enter and are collected from municipal solid waste.”
ISO 14021 however defines post-consumer as: “Material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product, which can no longer be used for its intended purpose. This includes returns of material from the distribution chain.” A definite difference of opinion.
When it comes to paper certification schemes, under current standards, both FSC and SFI subscribe to the FTC/EPA definitions (SFI actually requires alignment with the FTC rulings no matter what), however PEFC adheres to the ISO definition. That’s where the fun begins.
In response to the new FTC draft, many mills, recyclers and other groups have commented on the wisdom of the ISO definition noting that the FTC Guides should incorporate those definitions of post-consumer recycled content because competing definitions currently cause consumer confusion.
The reality can be summed up to intent. Is the intent that all material in its finished form has an equal recycled value no matter whether it has reached the end user/point of intended use or not? One can certainly argue that a publication which is remaindered (i.e.; never distributed) being exactly the same product as one that was read by the end-user, has exactly the same value in the recovery stream.
We don’t know as of yet which way the FTC will decide to go, but one thing is certain. Somebody’s not going to be happy. If the Guides are published as proposed, does it mean that merchants and printers need to watch all imports for the stated PCW content because they adhere to the ISO definition? Or will international mills have to adjust their PCW standards for exports to the US? It does present an interesting conundrum.
If FTC does adopt the ISO definition what happens to the FSC standards? Will they lower them to fit? Probably not, partially because of one interesting development; FSC released new trademark standards this past spring. The recycled mobius which used to convey the PCW content now conveys all recycled content. I find this a highly interesting development in conveying the message that reclaimed materials as a whole are equally valued.
As a final comment and case study, NewLeaf Reincarnation Matte was first released as a 50% pre and 50% post-consumer waste product (now 60% PCW). Under FSC standards both then and now, in order to use an FSC Recycled label there had to be at least 85% PCW, which meant that although 100% recycled, the FSC Mixed label with a 50% in the mobius had to be used for this product. Now under the new standard, though it’s still an FSC Mixed product, the mobius can state 100%. As Arte Johnson used to say, “Verrry Interesting…”
This is an open letter to all the wearers of many hats out there.
If your organization happens to be ISO, SGP, FSC or SFI certified, or even if you’re not formally certified to anything, but still subscribe to some type of formalized quality management system framework, you may think this article’s not for you, however hear me out before you decide.
If your organization doesn’t formally subscribe to a quality management system of some type, this article’s definitely for you as the benefits are infinite. It ultimately saves the organization time, money, effort, money, energy, money, resources, money and money.
Quite frankly, like so many other things, the 80/20 rule applies here. In this case, eighty percent of the organizations I visit do not implement internal audit (IA) protocols for their processes, and of the twenty that do, eighty percent of them have no clue how to do it correctly.
Regardless of whether there is an external certifying body that requires it or not, the only way to truly validate conformance to any process is to impartially audit it. Like a financial audit, process auditing is a skill using a rules-based approach. The key is to ask the right questions in a consistent, controlled and meaningful manner in order to discover any underlying nonconformities which may either consciously or unconsciously exist.
The first step is to be able to measure any process from a procedural perspective. No standard? No measurement. No procedures? No control. Anything can be evaluated, verified, validated and/or measured. A procedure can be as simple as how to answer a phone to how to produce a job by breaking down each component part, to how to measure customer satisfaction. It can be statistical, empirical or documentary.
Also, let’s not confuse process or product development, realization, verification and validation with internal auditing. Management and staff directly involved or affected by or from any process activity should always be involved with the procedurally-related activities pertaining to that process. That’s not what we’re talking about here.
Internal auditing is an intermittent activity that should be planned to be enacted at least annually to evaluate every process in the enterprise. Some processes which are more critical than others should be internally audited more frequently, sometimes quarterly, and of course immediately upon reoccurring issue identification such as multiple product non-conformities or customer complaints.
Management needs to ensure that objective guidelines are established based on procedural requirements. Any procedure can be turned into a question for these purposes. A procedure stating that “All Author Alterations shall be reviewed by the CSR in charge” can be turned into the question “Have all AA’s been reviewed by the CSR in charge?” In this way a manageable set of questions applicable to the process can be asked in an objectively interpretable manner.
Audit sampling is also an important aspect of meaningful IA’s. They should be random, yet should represent the breadth of range of the products involved. In cases where a repeatable process is in play, a smaller sampling which is representative of the overall volume is sufficient. Where more variables exist, the audit sample should be larger. It could be as much as 20%. Some auditing standards also use the 8/10 of the square root of the sum total rule. As an example, if you have 1000 unique orders, you would internally audit 25 of them.
Now let’s talk about internal auditors. They should first and foremost be “detail oriented”, articulate and diligent. There’s another term for this kind of person in general use, but this is a family-oriented column. Second and equally as important is that the internal auditor should have no responsibility within the process or system being audited. Case in point is that the CFO of an organization is a prime candidate to perform purchasing department IA’s (unless of course one of the hats the CFO wears is that of purchasing manager). The last point is one of objectivity. With a well-crafted internal audit checklist in hand, internal auditors should be able to validate any process in the organization impartially and with total objectivity. “Just the facts, ma’am”.
Once the IA has been completed, any non-conformances should be expressed in the form of a corrective action request (CAR). CAR’s should reference the specific procedure along with a description of the non-conformant issue(s). From there, management should investigate the causes by performing a root cause analysis (RCA). RCA’s in their simplest form ask why, five times, just like when a child asks why the sky is blue.
And finally, once the IA’s, CAR’s and RCA’s have been completed, it’s time to put together an action plan along with a resolution timeline which is followed up on my management. For issues needing immediate attention due to systematic failure, the timeline should be rather short. For procedural non-conformities which do not directly affect the outcome, a longer period of time is acceptable, but no longer than to be part of the review process during the next scheduled IA. In all cases the CAR should be re-evaluated and either formally closed or elevated.
These are the tops of the waves. IA implementation is just one tool in a total quality management/ continuous process improvement program. Implemented effectively, the end result is always an improvement over the status quo.