Social issues in the FSC supply chain: real change in sight?

This is a result of a recent revision of the standard (see our related article with an overview of key changes).

“We welcome the inclusion of social issues in the chain of custody system very much. However, the wording of the standard and the related guidance leave some serious question marks”, says CSR Manager at NEPCon Kjell-Owe Ahlskog.

"Contrary to what was recently decided at the FSC General Assembly, FSC is relying on paper documents for the verification of these new requirements such as compliance with the ILO core conventions on workers’ rights. Unless the auditors notice obvious violations of these conventions by chance when touring  the facilitaties, FSC clearly does not expect certification bodies to conduct interviews with workers or seek other evidence in order to verify that workers’ rights are indeed respected”.

Workers’ rights assured through self-declarations

Clause 1.5 in the new standard effectively incorporates FSC’s ‘Policy of Association’ into the standard. In a related guidance document, FSC advises the certification bodies to verify companies’ compliance based on self-declarations, stating that the company is not directly or indirectly involved in any of the unacceptable activities covered by the policy, such as violation of the ILO core conventions on workers’ rights. FSC stresses that no further assessments are required to verify compliance with this clause. Similarly, auditing against Clause 1.6 on occupational health and safety will be exclusively focused on written documents.

Peter K. Kristensen, Vice President of Environment and CSR at DLH, which holds six FSC certificates worldwide, comments: “The new standard is likely to miss its mark if the aim is to ensure reasonable conditions for workers in the FSC supply chain. The standard and current guidance don’t focus on checking the reality. I can imagine that the less responsible companies, who don’t care too much about workers’ rights, would be the first to sign the self-declaration without giving it a second thought”.

“At DLH we don’t mind fulfilling additional social requirements, but they need to add real value to the system - and that hinges on requirements that are auditable and rigorously audited against. At the FSC General Assembly, the vast majority of stakeholders voted for a motion that asked FSC to focus more on field performance rather than on systems. It is rather disappointing that this is coming from FSC right after the General Assembly”.

In its guidance document, FSC states that over the next years it “will further develop detailed auditable requirements". A list of indicators is provided, currently only for use in cases where the auditors incidentally become aware of violations of the social requirements while touring the company facilities.

Policy Manager at FSC International Center Lucia Massaroth explains to Certified Wood Update that FSC has opted for a phased approach in order to avoid a situation where companies face new and challenging requirements too quickly. “These requirements apply to organisations located in different regions; in some countries compliance with local legislation may suffice while in others, several changes may be needed. They also apply to a wide range of very different organisations, where the auditing of social requirements may differ significantly. It is pretty clear that the entire system is not ready to take this big step from one day to another”, she says.

Mr. Kristensen however questions this approach: “The question is, why is this rushed through, considering the credibility issues that may arise from pure ‘paper auditing’? I would prefer to know the full requirements from the beginning, and to be given a reasonable timeline for adapting to those requirements, instead of living with a standard that keeps changing at unpredictable intervals and where you never know where it is going to end up”.
 

Stakeholders ignored

Mr. Kristensen also wonders why the revision process for this core standard has not involved a full stakeholder consultation process, allowing certificate holders and other stakeholders to provide their feedback and inputs. “At the FSC General Assembly, it was decided that FSC needs to ensure a better consultation process for core policies and standards. I don’t understand why FSC has not taken this into account before launching this standard. As we say in Danish, ‘he who wears the shoe knows where it hurts’. Certificate holders have a lot to contribute to these processes from a user aspect”.

Ms. Massaroth says: “FSC received and considered several stakeholder comments regarding the incorporation of the Policy for Association and Health and Safety issues before the standard was changed. FSC as a multi-stakeholder organisation will never be able to fulfill everybody’s expectations - any direction we choose on this subject will result in criticism. Since the publication of the new standard and procedure, we received several positive and negative comments and will consider all feedback received as input for the further development of this standard”.

However, the fact remains that FSC did not consult this landslide revision in a transparent process. Most stakeholders were not aware of the revision process and did not get the chance to make any comments. This does not appear to be in line with FSC’s own standard for the development of standards (FSC-PRO-01-001 Version 2-0). 

It may also be at odds with the ISEAL Code of Good Practice for Standard-Setting, which FSC claims to follow. The ISEAL code recommends two rounds of public stakeholder comment as the norm, and public stakeholder consultation can only be entirely omitted in special cases, such as administrative or non-substantive changes. Is the inclusion of social issues in the global FSC Chain of Custody standard to be considered a minor change?