Compiled Public Consultation comments of: FSC-STD-20-011 V1-2 D1-1 Accreditation Standard for Chain of Custody Evaluations Type of contributor Standard Reference Comment Proposed change (Optional) PSU observation (e.g. “Introduction”; clause 3.1; Justification / rationale for change Suggested new wording (additions, modifications, Filled by FSC p. 8, line 3) deletions) FSC Network partner Part 1 General The formal competence of CB New paragraph has to be added to This is already specified in the requirements auditing team has to be assessed, secure sufficient competence of general CB requirements (see FSC- particularly when the company is the auditing team STD-20-001 V3-0). sourcing controlled wood from unspecified risk areas. Auditors must show special ecological and social competence to assess the relevant CW risk categories. FSC Network partner In addition, CB must have New paragraph has to be added to Auditor qualifications are specified competence to assess the secure sufficient competence of in another standard (FSC-STD-20- commitment of the company to the auditing team 001). According to that standard, FSC values listed in 1.5.2 FSC-STD- auditors must be qualified for the 40-004 V2-1 EN, as well as evaluation of all standards occupational health and safety. applicable to the organization being evaluated. FSC Network partner Principles 1.4 Line numbering at 1.4. does not We recommend to replace lines Recommendation accepted make logic 1.4.3 and 1.4.4. by alphabets a) and b)
FSC Network partner Documented Term outsourcing is unclear. Definition for outsourcing has to Recommendation accepted procedures 2.2. be added to Terms and definitions FSC Network partner 4 Certification 'sufficient' is unclear expression. Our recommendation for 4.2.2.e: Recommendation accepted decision-making Whole paragraph needs to be 'Repeated failure of the company 4.2.2.e revised. Line e) should also end up to demonstrate that organizational with 'or' to complete the list a)..f) control is operating properly, or; Certificate Holder Annex I: Chain of The fullfillment of this Deletion of requirement Recommendation accepted Custdoy Certification requirement creates a huge Reports Part II: Main treshold for both the Certification Evaluation Reports Body and the Certificate Holder Box 1: 1.1d whereas this information is not used for any pupose Certificate Holder Annex I: Chain of The fullfillment of this Deletion of requirement Recommendation accepted Custdoy Certification requirement creates a huge Reports Part II: Main treshold for both the Certification Evaluation Reports Body and the Certificate Holder Box 1: 1.1e whereas this information is not used for any pupose Certificate Holder Annex I: Chain of The fullfillment of this Deletion of requirement Recommendation accepted Custdoy Certification requirement creates a huge Reports Part III: treshold for both the Certification Surveillance Audit Body and the Certificate Holder Reports Box 2: 5.2b whereas this information is not used for any pupose
Certificate Holder Annex I: Chain of The fullfillment of this Deletion of requirement Recommendation accepted Custdoy Certification requirement creates a huge Reports Part III: treshold for both the Certification Surveillance Audit Body and the Certificate Holder Reports Box 2: 5.2d whereas this information is not used for any pupose Certification Body Terms and FSC COC certificate type that only In Spain, there are also inscriptions Recommendation accepted definitions: covers one single legal entity. of freelance persons(Autónomos) Individual COC that can sell materials, are not certificate inscribed as companies, are inscribed with their own names, they also can hired personnel. This "autónomos" can sell material and some of them shows interest in coc certification. This can also be consider as legal entities? if so,can the standard specified further that legal entiries can be consider company names and personal names inscribed in a merchants register? Certification Body FSC-STD-20-001 should be FSC- FSC-STD-20-011 (Version 1-2) EN Recommendation accepted STD-20-011
Certification Body D Terms and The definition says FSC COC Recommendation accepted definitions certificate type that only covers Individual COC one single legal entity. However, certificate: AnnexII specifies conditions where an individual COC certificate can have more than on legal entities. Therefore the definition is contradictory to AnnexII. Certification Body Clause 2.2.2 d) It is unclear what 'exclusively' Exclusive means temporally and means. Temporally or physically? If physically. If the processor has outsourced company handles certified and non-certified certified materials at temporal materials in the same physical designated space without physical location, then this option is not boundaries within a factory, is this applicable. considered as exclusive? Certification Body Clause 7.3 e) and, Clause 7.3 e) says the company's The Clause was revised to address Caluse 7.4 complexity and scale of the the inconsistency. activities are used to determine the company's annual growth limits. Whereas clause 7.4 clearly specifies the rule to be followed to determin annual growth limits. How does clause 7.3 e) work when there is a concrete rule specified in clause 7.4?
Certification Body Caluse 7.4 What is the rational for the The number was proposed by the number 40? working group responsible for the revision of this standard. The new draft standard no longer includes this requirement. Certification Body Clause 8 Table A includes information Sections 8 and 15 should be Recommendation accepted about audit type (i.e.surveillance, removed and integrated into a Re-evaluation, Main evaluation new annex. etc). Then this table should not be included in Part II Main Evaluation. The standard looks poorly structed. Certification Body Clause 8 Complexity mentions about having High risk outsourcing, CW Table A high risk contractors. But high risk verification program and contractors are sampled and Reclaimed material verification visited anyway and so should not program need to be included in be deal with here. the risk table in order to ensure If complexity is the subject, that these high risk Participating sourcing reclaimed material Sites are evaluated by CBs. should be included here. Certification Body Clause 15 Sections 8 and 15 should be Recommendation accepted removed and integrated into a new annex. Certification Body Clause 19.2 If there was no outsourcing of FSC I suggest adding a NOTE like Recommendation accepted. The activity, there is not much to see, following:High risk contractors revised clause specifies "since the even if a contractor is high risk. which have not had any FSC previous audit". activity since the previous audit do not need to be included in the population from which the sample is drawn.
Certification Body Clause 19 Many certificate holders wish to If new contractors should be Recommendation accepted. add high risk contractors at the separated from existing ones, time of surveillance and Re- description like clause 15.2 is very evaluation. helpful here. So it is helpful if there is a clear rule about if new high risk contractors need be sampled from a separate set to existing high risk contractors. Certification Body Clause 21.2.3 This should be consistent with being added … at the time of … -> Recommendation accepted. 15.2. have been added … by the time of … Certification Body Front page - Incorrect standard number FSC- Should read: FSC-STD-20-011 Corrected. standard number STD-20-001 FSC-STD-20-001 Certification Body Page 7, Definitions, The definition of evaluation does Additional audit types: Recommendation accepted. definition of not include full list of all types of - Non-conformity closure Evaluation audits Evaluation - Certificate Transfer Evaluation
Certification Body Paragraph 20.1 , FSC certificate suspension should Wording: "b) Tthe company’s Recommendation rejected. The page 28 not be a reason for extra on-site certificate is currently suspended." new audit is not required because audit if the company wishes to should be removed the company wants to reistate reinstate their certificate. Simply their certificate, but because the the suspension is not always company is required to comply related with full breakdown in COC with a new standard version and system and can be caused by other the CB should confirm that the issues such as: one Major NCR company has adjusted its COC overdue or non-payment for system to the new standard certification services. If the version. company has closed outstanding certification and financial issues the Certificaition Body should not authomatically require extra inspection to confirm that and should go back to regular surveillance audits cycle. Still the decision about the eventual extra audit is at CB's discretion and may be executed in practice.
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