Task Force on Forest Management Certification Programs

Chapter 6: DIFFERENCES AMONG THE STANDARDS PROGRAMS

The various standards under consideration in this report differ in a number of respects. This chapter outlines the major categories of differences and explains how each standards program is either similar or different. With this evaluation, SAF members will have a better understanding of the programs. This chapter does not attempt to characterize or speculate on the long-term impacts of the programs or their ability to achieve their stated objectives of "well-managed," sustainable forest management, or land stewardship.

The differences among the standards programs are generally described, but due to regional and management unit-level variation, specific differences are difficult to identify. Because of different regional standards, the subjectivity of how some are interpreted, and the difficulty of applying such standards on the ground, a detailed side-by-side comparison is not possible. The major differences among the programs are outlined in a matrix in Appendix A.

INTERNATIONAL vs. DOMESTIC STANDARDS

The Forest Stewardship Council's Certification and Labeling Program and the ISO 14001 Environmental Management System standard have been developed at the international level. The FSC Principles and Criteria are general and are intended to set the framework for the development of specific national or regional standards. While developed internationally, the ISO 14001 is also a domestic US standard approved by the American National Standards Institute. The four other programs (Tree Farm, SFI, Forest Stewardship, and Green Tag) were specifically developed for use in the United States.

STANDARDS DEVELOPMENT

The standards were developed by very different interest groups and organizations. The American Tree Farm Program was initiated in 1941 as a way to recognize good forest management on the part of industry and nonindustrial landowners. In the mid-1940s, industry and landowners began to develop specific criteria and guidelines for Tree Farm recognition. These standards were modernized in 1998 by a Tree Farm committee made up of industry, landowners, federal and state agencies, and others.

The AF&PA Sustainable Forestry Initiative standard was developed by and for the forest and paper industry with the input from the full spectrum of stakeholders, based on the issues that were most important to decision-makers and the general public. In 1998, the SFI was reformulated as a formal industry standard for the use of members and licensees. Currently, the AF&PA desires to retain ownership of the SFI standard as an industry led program.

The founders of the FSC invited multi-stakeholders, including environmental groups, industry and government, to participate in the development process of the FSC International Principles and Criteria. The FSC principles and criteria are tailored for use at the regional level through a multi-stakeholder process. In the US, the FSC has defined 11 forest management regions for guideline development; nine are in various stages of development. In September of 1998, the FSC-US submitted the southwest guidelines to the FSC-AC board (International Secretariat), and they were approved. In the absence of approved regional standards, certifiers use their own generic guidelines, tailored to the region in which the certification takes place.

The Green Tag Forestry® Program of the National Forestry Association was developed by the association's membership, in cooperation with the National Woodland Owners Association and in consultation with individual members of the Association of Consulting Foresters. The original certification criteria were formulated by a national team of foresters and resource specialists. Green Tag recognizes six forest management regions in the U.S. It is the only program designed specifically for nonindustrial, private forest owners.

The ISO 14000 series of environmental standards was initiated in 1991 within the framework of the ISO Strategic Advisory Group on Environment, in which 20 countries, 11 international organizations, and more than 100 environmental experts participated in defining the basic requirements of a new approach to environment-related standards. ISO launched a new technical committee, TC-207, Environmental Management, in 1993 as a result of this process. Delegations of business and government experts from 55 countries participate actively within TC 207, and another 16 countries have observer status. These delegations are chosen by the national standards institute concerned and they are required to bring to TC 207 a national consensus on issues being addressed by the committee. This national consensus is derived from a process of consultation with interested parties. The ISO 14001 Environmental Management System was approved as an international and US standard in 1996.

In 1996, a formal work group on forestry was formed by TC 207 to develop a technical report to assist in the understanding and implementation of ISO 14001 by the forestry sector. The work group met for two years with some 60 representatives from 30 countries participating. The technical report (ISO 14061) was unanimously approved in 1998.

The Forest Stewardship Program came out of the 1990 farm bill. The National Standards and Guidelines were developed by the USDA Forest Service in consultation with state foresters. Further implementation measures were developed by individual state committees whose membership is mostly governmental, but it also included nongovernmental organizations, forest products industry, and forestland owners, among others.

MANAGEMENT SYSTEM OR PERFORMANCE-BASED STANDARDS

Some programs are based on environmental-management system guidelines and others are based on performance standards. Some are a combination of both. An environmental-management system standard defines a set of programs, processes, or policies that require an organization to assess its achievement of its stated environmental goals and objectives. Performance standards, criteria, and indicators define the level of performance expected in forest management. These specific criteria and indicators are then used to assess the organization's conformity to the standard.

The American Tree Farm Program contains forest management system and performance standards that are specifically designed for private industrial and nonindustrial lands. The SFI is also a combination of management system elements (management planning), as well as detailed performance elements (average clearcut size).

The FSC International and Regional Standards are a combination of management system and performance requirements. There are 10 international FSC principles and accompanying criteria. The regional standards are more detailed and are intended to provide auditors with enough guidance to conduct on-the-ground assessments. The Green Tag Program is also a combination of management system and performance elements. The management principles are outlined, with a more detailed set of performance indicators under development.

The ISO 14001 EMS is based on the theory that if an organization makes a commitment to environmental protection and has an effective management system in place, continuous improvement of the management system will facilitate the accomplishment of the organization's environmental objectives and targets. The ISO 14001 requires an organization to make a commitment to regulatory compliance, pollution prevention, and other performance-related programs to which it subscribes. Thus, if the forestry organization subscribes to one or more of the standards programs discussed in this report, the organization would be required to build them into the environmental management system, environmental policy, objectives, and targets.

FORESTRY PERFORMANCE REQUIREMENTS

Each of the standards programs includes some overlapping forestry and environmental performance requirements. These were discussed in Chapter 5 under the section on Criteria and Indicators. Conversely, there are some major differences between the forestry performance standards, depending on the objectives of and intended participants in the program. Because the forestry performance requirements of each of the programs are subject to regional and forest unit-level variation, it is difficult to characterize how each of the programs will be interpreted and applied on the ground. Some of the major differences between the standards programs are outlined below.

• The American Tree Farm Program is designed to recognize private landowners who are practicing "good" forest management. The landowner is required to have a management plan, actively manage the forest, protect it from fire and insects, protect water quality, and provide for wildlife and recreation.

• The American Forest & Paper Association's member companies and SFI licensees must agree to comply with seven principles of sustainable forest management and 10 objectives and related performance measures. It is also designed to broaden the practice of sustainable forestry with landowners and loggers. It accomplishes this through state implementation committees that organize logger training programs and promote education and demonstration.

• The Forest Stewardship Council International Principles and Criteria are intended to apply to all forests around the world. More specific national and regional standards are under development to address specific forest types, whether private or public. Principles 1 to 9 focus primarily on "natural" forests, and Principle 10 addresses plantations. A new Principle 11 is being developed to address nontimber products from the forest.

• The Green Tag Forestry Program has a set of 10 principles designed specifically for private, nonindustrial forests. More specific objectives and performance measures recognize regional silvicultural differences.

• The ISO 14001 Standard is a management system standard and does not contain forestry performance measures. The organization implementing the environmental management system is required to develop its own environmental policy, objectives, and targets.

• The Forest Stewardship Program focuses on promoting forest stewardship with nonindustrial private forests, particularly those that have not participated in other programs that have a production focus. Standards of performance were developed at the national and state levels through the stewardship committees. A federally funded Stewardship Incentives Program was also developed that cost-shares certain conservation practices related to wildlife, recreation, and water quality.

VERIFICATION OF CONFORMITY TO THE STANDARDS

The standards programs vary widely in their monitoring, measuring, auditing, and reporting requirements. All contain processes for organizations to assess their own conformity to the standard (first party); some contain provision for customer or affiliated organizations to assess conformity (second party); and others call for independent verification of conformity (third party) leading to certification.

The American Forest Foundation Tree Farm Program requires that a professional forester conduct an initial on-site inspection, followed by reinspections every five years, to ensure that the landowner is in conformity with the standards and guidelines. These inspections by professional foresters can be either second-party or independent third-party.

AF&PA members and licensees are required to annually self-declare (first party) their commitment to the SFI in the form of a letter from the company CEO to AF&PA. Members and licensees are also required to respond annually to a survey questionnaire about the company's SFI Program for purposes of developing an SFI annual report. An expert review panel provides oversight of the annual report and makes recommendations to the AF&PA board for improvements to the overall standard.

The AF&PA SFI voluntary verification provides a formal process whereby members and licensees can conduct first-, second-, or third-party verification of conformity with the SFI. This process is governed by a set of verification principles and procedures and qualification criteria, patterned after the ISO 14010/11/12 auditing guidelines.

FSC certification is awarded through third-party assessment of forest management practices. Assessors compare the landowner's management system to the FSC standard, then compare the landowner's system to the results achieved in the field. Landowners' systems must be in conformity with all 10 principles through an on-the-ground assessment process, or the system is not considered certifiable.

Green Tag audits are conducted by participating foresters accredited by the National Forestry Association. This is third-party certification, and the auditing protocol is similar to other certification efforts.

ISO 14001 requires organizations to conduct a monitoring program to determine if the organization is achieving its stated environmental policy, objectives, and targets. It also affords the option for organizations to self-declare (first party) conformity to the standard, send out customer or second audits, or employ an accredited registrar to conduct an independent third- party audit.

MARKETPLACE CLAIMS AND PUBLIC COMMUNICATION

All of the programs are different in the way in which participants can communicate their participation in, and conformity to, the standards of performance. Some programs award certificates of membership that can be publicized; others allow participants to communicate their participation on company letterhead, annual reports, and public communication; still others allow participants to affix a logo or label on their products. These various forms of communication with the public and customers are outlined below.

• The American Tree Farm Program awards a certificate of membership to program participants, along with a green, diamond-shaped Tree Farm sign that can be mounted at a prominent location in the forest. All participants may display promotional materials that publicize their participation in the program. Also, Tree Farmer of the Year contests and recognition are conducted at the state, regional, and national levels to further publicize the best performers in the program.

• The American Forest & Paper Association's SFI program allows members and licensees to communicate their participation through the annual SFI Report, through company communication with customers, and in corporate annual reports. The voluntary verification option also affords the opportunity for members and licensees to self-declare their conformity to the SFI requirements or receive a certificate from a third-party verifier. Implementation of the third-party voluntary verification component of the SFI may also be communicated to the public and customers through press releases, annual reports, and communication directly with customers.

• The Forest Stewardship Council both awards a certificate from the accredited certifiers and allows the organization to affix the FSC logo or label on the product. On-product labeling is the process of affixing a "green seal of approval" to identify to consumers that the wood in a product originates from a "well-managed" forest. Chain-of-custody assurance is a requirement for this type of on-product labeling. Chain of custody refers to any tracking system used to follow and identify a product throughout the distribution channel, from the forest to the marketplace. A rigorous chain of custody systematically ensures that a certified product carries legitimate marketing claims. The FSC also allows participants to utilize the logo on promotional materials, requires its use on all paperwork related to inventory and accounting, but does not permit its use on stationary and business cards.

• The Green Tag Forestry® Program awards a third-party certificate to landowners who meet the performance requirements and allows the landowner to place the Green Tag Forest sign at a prominent location in the forest. Certified landowners may also use the logo on their products as proof of chain-of-custody tracking (available for an extra charge).

• The International Standards Organization allows organizations to self-declare conformity to the standard and communicate that declaration to the public. There is the option to obtain third-party certification to the standard, and the accredited auditors may issue a certificate to the certified organization. The organization may communicate its ISO Certification on its letterhead, advertisements, and direct communication with customers. It is not a labeling program, and the ISO logo may not be used on-product.

• The Forest Stewardship Program awards a stewardship certificate to participating landowners and allows the landowner to place a Stewardship Forest sign at a prominent location in the forest.

THE ROLE OF PROFESSIONAL FORESTERS

The success of each standard-setting program depends not only on the standard it uses for evaluating forest management practices, but also on the credibility of its development team, auditors, and on-the-ground results. In all cases, it is the land itself or the management practices applied to the land that are audited and recognized for compliance. None of the programs currently evaluates the skills or competency of foresters, landowners, individuals, groups, or companies as it relates to their ability to interpret or apply a standard. Rather, the activities conducted and long-term plan earn the recognition.

All of the standard-setting programs discussed here are in evolution as they strive to become relevant in the certification marketplace. The role of professional foresters will evolve parallel to the standard-setting programs. While no individuals or organizations are awarded certification, there are several roles for foresters in the various processes. Foresters play a crucial role in the development of standards, as auditors and peer reviewers, and as implementers of the standard.

DEVELOPMENT OF STANDARDS

Foresters bring their professional experience, scientific knowledge, and personal or organizational political perspective to the standard-setting discussion that is critical to the creation of a well-balanced standard. While the proliferation of standards permits landowners and customers to choose a standard that best meets their business objectives, the continued controversy surrounding the standards themselves clearly indicates the need for more professional foresters to be involved in their development.

As described earlier in the report, each program has a well-established protocol for its standards development process that can be extremely complex. The amount of time, expenses, and political amifications of participating may be a disincentive to individuals and companies.

AUDIT OF PRACTICES AGAINST STANDARDS

Each program has established the level of forestry education or experience necessary to conduct audits, and it varies from program to program. Tree Farm, Forest Stewardship, and Green Tag programs currently require one forester to conduct an audit, whereas the FSC uses foresters as part of a multidisciplinary team. ISO and the SFI do not currently have specific requirements for the use of foresters, but it is likely that a candidate being audited under these protocols will request a forester to be involved in the process.

Some programs demand that auditors be "accredited" by an independent body. Accreditation requires an individual to be trained by an established organization having the authority to award accreditation. For example, companies that want to make marketing claims related to ISO 14001 or SFI compliance must use qualified auditors. The Green Tag Program primarily uses foresters who are members of the Association of Consulting Foresters (ACF) to conduct its audits. Green Tag approved foresters receive training, hosted by the Professional Foresters Institute on how to interpret the standard and assess compliance. No other formalized auditor training is required, although ACF has a well-established code of credentials for membership. The Forest Stewardship Program provides internal training for the state foresters who will audit landowners but does not require any other formalized training. The FSC has no auditor training requirements, but the organizations that have been accredited to conduct FSC certifications have established protocols for auditors as part of their accreditation. For example, SmartWood requires foresters to have a four-year degree and 10 years' on-the-ground experience.

Many of the standards are complicated, and the cost of undertaking an audit may be immense. Companies and landowners would like assurance that an auditor will find their systems and practices in compliance before making the investment in third-party auditing. A market is emerging for consulting foresters and management consulting firms to prepare companies for these external audits. There are no protocols or guidelines established for these consultants through the certification programs, although many have years of experience in forestry or assessing compliance to other rigorous standards, such as those used in accounting.

PEER REVIEWERS

The FSC has a protocol requiring each certification decision to be reviewed by an independent team. The peer review team is hired by the certification organization (SmartWood, SCS, SGS Inc., etc.), and its purpose is to ensure consistency in application of the FSC standard in all the certification decisions conducted by the organization. A hallmark of FSC's process is its use of foresters with regional expertise. If a certification organization conducts audits across the country or around the world, the FSC wants to ensure the standard is consistently applied, given that the certification team will likely be composed of different individuals for different projects. Foresters have been important members of peer review teams.

IMPLEMENTATION OF THE STANDARD

An obvious role for foresters is in the implementation of the standard on specified properties. Forest owners and managers who desire some form of verification will often use a forester to implement the standard and ensure ongoing compliance to the standard. This person or team may be the existing forest manager; where there is no manager, an individual or group is hired to do the managing and standard implementation. The decision to use a forester in this role is left to the landowner or manager and not defined by any of the programs.

ROLE OF SAF's CERTIFIED FORESTER® PROGRAM (CF®)

This program currently certifies the professional standards of education for an individual, not whether an individual is competent to manage or audit forestland in conformity with a particular set of agreed standards. SAF should consider expanding the Certified Forester® program to include a competency component, with the caveat that competency certification does not imply that the individual so certified is accredited by SAF to evaluate forest management under standards developed by the standard-setting programs discussed in this report. At a minimum, this would require a commitment by the SAF to establish dialogue with the various standard- setting programs to determine what competencies, if any, would be acceptable under a program's protocols. This would create a pool of professionally trained foresters that a company or certification organization could select from when seeking forestry input into the processes described above.

Continuing education of foresters is critical to the profession and to standard-setting programs. SAF can play an important role in providing continuing education that benefits foresters, standard-setting programs, and society at large. SAF should explore opportunities to provide continuing education in conjunction with standard-setting programs.