Wednesday, 09 February 2022
Policy and Standards: The Year Ahead
By: Justin Meier
Three key policy and standards activities for 2022 include the National Forest Stewardship Standard (NFSS) revision, FSC Pesticides Policy, and FSC Core Labor Requirements. This article discusses their timeframes, impact on certificate holders, and implementation tools and resources developed by FSC US staff.
The NFSS revision process updates the FSC US Forest Management Standard to the new version of Principles and Criteria (P&C) for Forest Management (V5.2). The revision includes base indicators applicable to most FSC US Forest Management (FM) certificate holders, as well as requirements for family forest owners, Federal Lands, and ownerships with plantations. Revision topics include climate change, Indigenous Peoples’ rights, Representative Sample Areas, workers, and regional requirements.
To date, two public consultations have been held – one associated with the base indicators applicable to most FM certificate holders and one for the separate sets of requirements for family forests, Federal Lands, and ownerships with FSC plantations.
Information on each of the previous consultations, including issue briefs and current drafts, can be found at engage.us.fsc.org. We greatly appreciate the feedback received during the consultations. FSC US intends to complete the revision process by the end of 2022.
2022 NFSS TIMELINE
Draft 2 Public Consultation & Testing: March-May 2022
Development of Draft 3: May-October 2022
Submission for Approval: November 2022
Final Approval & Publication: 2023
FSC Pesticides Policy
The FSC Pesticides Policy provides FSC’s expectations for the use of chemical pesticides in FSC-certified forest management units. Where feasible, FSC’s long-term aspiration is to reduce or phase out the use of highly hazardous pesticides (HHP). The policy recognizes that reducing or phasing out pesticide use in US forest management is not always practical and, accordingly, it lays out a framework for demonstrating that the pesticide with the least risk to environmental and social values is prioritized. The policy became applicable to all US FM certificate holders as of December 31, 2020.
A core component of the new policy is the requirement for an environmental and social risk assessment (ESRA). The ESRA requirement recognizes that chemical pesticide use is an integral component of current forest management – and instead of eliminating the use of common HHPs, it requires certificate holders to demonstrate social and environmental responsibility during their use. In most scenarios, this means building on the Material Safety Data Sheet or Safety Data Sheet label by considering the environmental and social values that could be impacted by their use and mitigating those impacts where possible.
To help certificate holders comply, FSC US published national guidance ESRAs for some of the most common chemical pesticides used in US forestry (see list below). The guidance ESRAs explain where and how the ESRA process fits into the new Pesticides Policy. They are designed so certificate holders can adapt the ESRAs to their management unit.
Please note that these ESRAs are guidance, and their use is not required (i.e., certificate holders may choose to develop and present their ESRA using different methods and formats).
FSC US List of National Guidance ESRAs:
FSC Core Labor Requirements
In early 2021, FSC published the revised Chain of Custody (CoC) standard (FSC-STD-40-004 V3-1) and the revised Chain of Custody Evaluations standard (FSC-STD-20-011 V4-2). The transition period for the new version of the CoC standard is from September 2021 through December 31, 2022. During this time, both versions of the standard (3-1 and 3-0) are valid. After December 31, 2022, all CoC certificate holders must be audited to the new standard. Any CoC certificate that has not been audited to the new standard by June 30, 2023, will no longer be valid.
The revised CoC standard incorporated FSC Core Labor Requirements – basic workers’ rights and protections – into the chain of custody system (considerations for workers have always been a component of FSC certification for forest management certificate holders).
The new expectations for CoC certificate holders include abolition of child labor, elimination of all forms of forced or compulsory labor, elimination of discrimination with respect to employment and occupation, upholding freedom of association, and the effective recognition of the right to collective bargaining.
While many nations around the world still struggle with these basic worker rights, the United States has a rigorous legal framework that addresses these requirements. Accordingly, FSC US worked with certification bodies (CBs) to confirm that CoC certificate holders in the US are low risk for non-conformance. This means that CBs in the US can use a risk-based approach when assessing US certificate holders to the FSC Core Labor Requirements. Unless there is evidence that a company is not complying with US laws, US certificate holders will experience a reduced level of required effort for both providing evidence that demonstrates conformance and auditing.
FSC US, in alignment with CBs in the US, has finalized a self-assessment that is specifically for certificate holders in the United States. The self-assessment will point certificate holders to information that will help them to demonstrate conformance. The US-specific self-assessment is available on a new FSC US web page dedicated to the Core Labor Requirements.