Significantly Reducing and Eliminating Illegal Timber
5/17/2012
2
HPVA Board Lacey Due Care Act Work Group • Tim Schallich Chairman, Vice President, Columbia Forest Products • Stacey Kapushy Customs Compliance Manager, Armstrong World Industries • Reggie Hubbard Vice President, Darlington Veneer • Anthony Lynchesky Import/Export Coordinator, Veneer Technologies • Don Finkell CEO, Shaw Hardwood • Cathy Lynn Danzer Principa,l Danzer • Dan Natkin Director of Wood and Laminate,s Mannington • Tim Heidt President, St-Raymond Veneers, A Penrod Company 5/17/2012
3
Lacey Work Group OBJECTIVE: • Develop a consensus of what are the requirements to verify the legality of timber and define a set of guidelines consistent with those requirements 5/17/2012
Lacey Work Group • Completed a legal analysis of the Lacey Act timber amendments which does not require legal certification or sustainability certification • Shared best practices of member’s systems which are the flow charts discussed next 5/17/2012
5
Decision Flow Chart - simplified WOD PRODUCT SUPLY or SUPLIER
3rd party audit of procurement policy and procedures to verify consistency and effectivene ss YES
Timber is a) CoC and Legality Verified or b) SFM certified? NO 1. Spatial Risk assessment Risk of Country/region & legal Medium, Highrequirements? Very High: off limit .2 Preliminary risk assessment by Env. Coordinator based on killing factors Positive
3. Extend risk assessment (collect documents on origin, questionnaire and signature of Legality declaration) Positive 4. Targeted visits and audits of suppliers, based on risk assessment Positive
BUY WOD PRODUCT 5/17/2012
Negative
Negative Negative
X Don’t buy Inform higher hierarchy and environmental coordinator
6
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • Purpose of the standard is to facilitate compliance with legal requirements in the U.S., E.U., Japan, Australia, and elsewhere • Common understanding of best practices • Self certify or 3rd Party audited 5/17/2012
7
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • This standard is intended to assist companies in establishing a qualitycontrolled system to significantly reduce or eliminate the risk of illegal timber products entering their supply chain and demonstrate due diligence in controlling that risk 5/17/2012
8
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • REQUIREMENTS: • Procurement Policy Statement • Infrastructure and Control Systems – Coordinator Responsibilities – Quality Control System – Document Control System 5/17/2012
9
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • Preliminary Determinations – SFM certified timber (FSC, SFI, PEFC, ATFS, etc.) – 3rd party legally verified – Independent inspection organization declaration
• Due Diligence Evaluation of Legality • Spatial Risk Assessment of Country and Region 5/17/2012
10
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • Preliminary Risk Assessment of Suppliers • Secondary Risk Assessment of Suppliers identifies risk levels of supplying illegal timber • Legality Requirements Determination of Country/Region/Forest Management Unit (FMU) 5/17/2012
11
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • Collection of Documentation – Familiarity with evidence of fraud and other falsehoods
• Establishment of Control Procedures • Improvement programs • Inspection and verification Procedures 5/17/2012
12
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber
• Appendices provide useful information • Non-binding to the standard
5/17/2012
1. Policy Statements 2. Resources for Country Risk Assessments 3. SFM and 3rd Party Legality Verifications 4. Declarations of Legality and Origin 5.Supplier Questionnaire 6. Timber species references 7. Industry standards for Coordinator competency 8. Examples of false documentation 13
ANSI Standard for Due Diligence in Procuring/Sourcing Legal Timber • Submit PINS to ANSI in May • Draft standard completed in June • Canvass Committee organized in July and briefed • Standard out for first ballot September 5/17/2012
14
Decision Flow chart - detailed
5/17/2012
15
Proving Legality
5/17/2012
16
Progress toward Sustainability and SFM certification
5/17/2012
17
How do you know it’s legal? Trust your suppliers. 5/17/2012
18
HPVA Board Lacey Due Care Act Work Group • Thank you for listening • Please – are there any questions?