Approaches for forest certification System versus performance ? Presentation prepared by Pierre Hauselmann for the WWF / WB Alliance Capacity building toolkit for Multistakeholders National Working Groups 15/07/01

Links and keywords Links with other instruments –Institutional requirements for forest certification Keywords –Environmental management system (EMS) –ISO –Performance approach –System approach –Copyrights –System versus performance: © 2001 WWF/ WB Alliance –The PathFinder background picture: © WWF-Canon / Michèle Dépraz

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Two different approaches: –System - verify that a system of environmental management is in place in the organisation –Performance - verify that specific environmental performances have been met by the organisation Certification:

ISO (environmental management system) is the best-known example of system approach, including EMS for forest companies –The Canadian Standard Association (CSA) has developed a forest sector specific standard, derived from ISO This is only applicable to Canadian forests System approach

Performance approach FSC is the example of performance approach for forest certification

EMS Environmental management system: –Provide direction for an organisation’s activities insofar as they affect the environment –Divided in five categories intended to continuous improvement of the system

EMS Continual improvement Environmental policy Planning Implementation and operation Checking and Corrective actions Management review ISO 14001:1996 (E)

Each organisation define its own environmental objectives No claim on products should be made (ISO guides) ASSUMTION: if a good system is operating, it will lead to satisfactory performance EMS

Performance approach Performance’s objectives are set outside the organisation, and must be met to be awarded a certificate –So that, it is possible to claim credibly that a sufficient level of performance has been reached –The process is complex and must include participation of stakeholders ASSUMPTION: If the environmental performances are good, a satisfactory system is in place

–4.2 Top management shall define the organization’s environmental policy and ensure that it …includes a commitment to comply with relevant environmental legislation and regulations… –4.3.2 The organization shall establish and maintain a procedure to identify and have access to legal and other requirements… Example Legal Compliance under ISO 14001

–4.3.3 …When establishing and reviewing its objectives, an organization shall consider the legal and other requirements… –4.5.1 … the organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations. Legal Compliance under ISO Example

Auditors have to check that: –there is a commitment to compliance in the environmental policy –there is a procedure to identify legal requirements –the organisation has considered the legal requirements –there is a written procedure to evaluate compliance Auditors do not need to check that: –There is actual compliance on the ground Example Legal Compliance under ISO 14001

Principle 1 Forest management shall respect all national and local laws and administrative requirements Auditors have to check that there is actual compliance on the ground Example Legal Compliance under FSC

No opposition, but possible complementarity : Legal compliance under ISO 14001: the certification body will attest to the existence of the different mechanisms, not the actual compliance Legal compliance under FSC:the certification body attests that the objectives are satisfactorily reached – Forest Management certification must have components of both concepts Note: FSC includes both system and performance elements Opposition?

Numbers correspond to ISO clauses ISO and performance 4.3 Planning –4.3.1 Environmental aspects –4.3.2 Legal and other requirements –4.3.3 Objectives and targets –4.3.4 Environmental management programme(s)

4.3.3 Objectives and targets The organization shall establish and maintain documented environmental objectives and targets, at each relevant function and level within the organization. When establishing and reviewing its objectives, an organization shall consider the legal and other requirements, its significant environmental aspects, its technological options and its financial, operational and business requirements, and the views of interested parties. The objectives and targets shall be consistent with the environmental policy, including the commitment to prevention of pollution. ISO and performance

4.3.4 Environmental management programme(s) The organization shall establish and maintain (a) programme(s) for achieving its objectives and targets. It shall include a) designation of responsibility for achieving objectives and targets at each relevant function and level of the organization; b) the means and time-frame by which they are to be achieved. If a project relates to new developments and new or modified activities, products or services, programme(s) shall be amended where relevant to ensure that environmental management applies to such projects. ISO and performance

4.4 Implementation and operation –4.4.1 Structure and responsibility –4.4.2 Training, awareness and competence –4.4.3 Communication –4.4.4 Environmental management system documentation –4.4.5 Document control –4.4.6 Operational control –4.4.7 Emergency preparedness and response Numbers correspond to ISO clauses ISO and performance

4.4.6 Operational control The organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. The organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets; stipulating operating criteria in the procedures; b) establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicating relevant procedures and requirements to suppliers and contractors. ISO and performance

4.5 Checking and corrective action –4.5.1 Monitoring and measurement –4.5.2 Nonconformance and corrective and preventive actions –4.5.3 Records –4.5.4 Environmental management system audit Numbers correspond to ISO clauses ISO and performance

4.5.1 Monitoring and measurement The organization shall establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment. This shall include the recording of information to track performance, relevant operational controls and conformance with the organization's environmental objectives and targets. Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organization's procedures. The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations. ISO and performance

4.5.2 Nonconformance and corrective and preventive actions The organization shall establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive action. Any corrective or preventive action taken to eliminate the causes of actual and potential nonconformances shall be appropriate to the magnitude of problems and commensurate with the environmental impact encountered. The organization shall implement and record any changes in the documented procedures resulting from corrective and preventive action. ISO and performance

4.5.4 Environmental management system audit The organization shall establish and maintain (a) programme(s) and procedures for periodic environmental management system audits to be carried out, in order to: a) determine whether or not the EMS 1) conforms to planned arrangements for environmental management including the requirements of this international standard 2) has been properly implemented and maintained; and b) provide information on the results of audits to management. The organization's audit programme, including any schedule, shall be based on the environmental importance of the activity concerned and the results of previous audits. In order to be comprehensive, the audit procedures shall cover the audit scope, frequency and methodologies, as well as the responsibilities and re- quirements for conducting audits and reporting results ISO and performance

“A U.S. EPA Office of Enforcement and Compliance Assurance study of 133 ISO certified facilities in the United States found that approximately 20 % had significant environmental violations for 1995 to Of those significant violations the study found that 63 % were in significant violation for a period of a year or more” Morrison J, Kao Cushing K, Day Z & Speir J (2000). Managing a better environment: Opportunities and Obstacles for ISO in Public Policy and Commerce, Pacific Institute for Studies in Development, Environment, and Security, Oakland US EPA Study