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FSC US Controlled Wood National Risk Assessment (US NRA)

The FSC US Controlled Wood National Risk Assessment (US NRA) for the conterminous United States is now available.

Published on April 5, 2019, the US NRA will be used by all companies that wish to control uncertified forest materials from the assessed area so that those materials may be mixed with FSC-certified materials and used in products that carry the FSC Mix label. Certificate holders with Controlled Wood within the scope of their FSC Chain of Custody certificate must incorporate the US NRA into their due diligence system by October 5, 2019.

For more information and resources to help with implementing the US NRA, visit the US NRA Implementation Resources webpage.

NOTE: At this time, the US NRA does not include assessments for Alaska or Hawaii.

Summary of the Risk Designations within the US NRA:
Category 1 - Illegally harvested wood: Low Risk
Category 2 - Wood harvested in violation of traditional and human rights: Low Risk
Category 3 - Wood from forests in which high conservation values are threatened by management activities: Specified Risk in portions of the Pacific Coast, Rocky Mountain, Mississippi Alluvial Valley, Appalachian and Southeast Regions
Category 4 - Wood from forests being converted to plantations or non-forest use: Specified Risk for specific counties within the Pacific Coast and Southeast Regions
Category 5 - Wood from forests in which genetically modified trees are planted: Low Risk

Certificate holders that source uncertified materials from areas of specified risk and wish to control these materials must implement control measures. The control measures in the US NRA require that certificate holders implement one or more of a limited set of mitigation options within each specified risk area from which they source materials.

The premise behind this approach is that concentrated effort by numerous certificate holders on a limited range of activities within a landscape scale is more likely to result in on the ground change than certificate holders implementing a myriad of actions - the kind of change that will reduce (i.e., mitigate) the risk of sourcing non-certified materials from specified risk areas. The mitigation options were developed through an extensive consultation process designed to identify activities that are more likely to effectively mitigate risk and are viable for certificate holders to implement. The mitigation options, and an overview of the process by which they were developed, are included in the Regional Meeting Reports (available to download below).

Documents available to download:
1. FSC US Controlled Wood Risk Assessment - the full US NRA is available as a single pdf document which includes the standard risk assessment template, along with a number of annexes that provide additional details that informed the risk designations.

2. Spatial information - FSC US has created a number of map-related resources to assist a certificate holder in determining if their supply area overlaps an area of specified risk. These resources include:

3. Controlled Wood Regional Meeting Reports - these reports contain the final mitigation options, along with background information on the Regional Meetings and the mitigation option development process. They are meant to assist a certificate holder in implementing control measures and mitigation options.

4. Controlled Wood Advice Note 24 - this advice note clarifies that auditors are not required to verify the effectiveness of mitigation actions implemented by individual certificate holders, as FSC US will be responsible for completing this verification at a landscape scale. The advice note is on p.11 of the Controlled Wood Directive.

5. National Risk Assessment Guidance Documents

Landscape Approach to Effectiveness Verification:
Per Controlled Wood Advice Note 24, FSC US will undertake the verification of mitigation effectiveness in lieu of individual verification. FSC US will monitor changes on the ground within the areas of specified risk, primarily through information sharing with expert stakeholder organizations active within these landscapes, and data collection from various sources.

The FSC US framework for monitoring and effectiveness evaluation utilizes a three-tiered approach to measuring how the risk of sourcing unacceptable materials within each area of identified risk is changing and the relationship with implementation of risk mitigation actions. This approach leverages a partnership with American Forests Foundation and relies on both public and private data as well as strategic partnerships with other organizations close to the NRA. This framework will yield both annual and periodic information that will be used to evaluate the effectiveness of the US NRA. The three tiers are described below.

Tier 1 – Use public data and coarse metrics to evaluate landscape-level change in forest ecoregions in a consistent manner for all areas of identified risk. This will facilitate contextualizing specified risk areas for Tier 2 and Tier 3assessments by using data that is currently available, highly regarded as dependable, and commonly used in similar analyses.

Tier 2 – This tier has two steps. The first is a spatial component that will identify high sourcing pressure regions and forest ownership categories to focus monitoring and effectiveness evaluation effort. Using identified high sourcing pressure regions and associated forest ownerships categories, the second step will determine baselines, monitor, and evaluate change in forest ecosystems and forest management in those wood baskets.

Tier3 – Characterize and conduct in-depth analyses of impact and effectiveness of the risk mitigation actions, identified by an FSC-US 2020 survey, as the most frequently selected by certificate holders, e.g., Education and Outreach, Conservation Initiatives, and Procurement Policies.

More details regarding the expansion of the US NRA to include Alaska and Hawaii can be found here.

Please contact FSC US with any questions you have about the FSC US Controlled Wood National Risk Assessment.