Controlled Wood Verification Audit Procedure
Version 1.2
Owner: GM Technical & Environment
Approved 30th June 2014
Printed: 09/02/2016
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Table of Contents
1
2
3
4
Introduction .................................................................................................................................... 3
Scope of Verification Audit Procedure............................................................................................ 3
General Requirements .................................................................................................................... 3
Risk Assessment .............................................................................................................................. 4
4.1
Wood Harvested from Forest in which High Conservation Values are Threatened by
Management Activities - Verification for Unspecified Risk ................................................................ 5
4.1.1
HCV Assessment Undertaken by the Supplier ................................................................ 5
4.2
Wood Harvested from Areas Being Converted from Forests and Other Wooded Ecosystems
to Plantations or Non-forest Uses (Tasmania Only) - Verification for Unspecified Risk ..................... 6
5 Procedures ...................................................................................................................................... 6
5.1
Planning................................................................................................................................... 6
5.2
Determining the Number of Verification Audits ..................................................................... 7
6 Preparing the Audit Plan ................................................................................................................. 8
7 Operational Requirements.............................................................................................................. 9
7.1
Conducting the Audit .............................................................................................................. 9
7.2
Audit Report ............................................................................................................................ 9
Owner: GM Technical & Environment
Approved 30th June 2014
Printed: 09/02/2016
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1
Introduction
The purpose of this document is to outline the procedure for Timberlink Australia employees to
undertake verification audits for supplied Controlled material in accordance with FSC Standard for
Company Evaluation of FSC Controlled Wood (FSC-STD-40-005).
Verification audits are required for confirming the origin of Controlled material and to confirm that
wood or fibre is not traded in, or sourced from:
1. Illegally harvested wood;
2. Wood harvested in violation of traditional and civil rights;
3. Wood harvested from forests in which high conservation values are threatened by
management activities;
4. Wood harvested from areas being converted from forests and other wooded ecosystems to
plantations or non-forest use;
5. Wood from forests in which genetically modified trees are planted.
An initial verification audit is required for Controlled material first supplied, and subsequent annual
verification audits of the Suppliers.
Refer to the Timberlink FSC Controlled Wood Multi-site Chain of Custody Manual for further details.
2 Scope of Verification Audit Procedure
This procedure applies to all Controlled material entering the Timberlink FSC Chain of Custody
programme within each of the Timberlink regions at:
1. Tasmania;
2. Green Triangle.
Verification of Supplier input materials will include:
1. Deliveries direct from plantation sources;
2. Material or coproducts from processing facilities (including those facilities engaged in
outsourcing);
3. Purchased materials.
3 General Requirements
Company verification must provide evidence that wood/fibre originating from a particular supplier
has been controlled for the categories of wood outlined in the Timberlink CoC Policy.
Verification shall be undertaken by individuals with sufficient expertise and knowledge to be able to
fulfil inspection.
For each of the five categories that cannot be considered low risk, Timberlink must identify and
provide the rationale for documents and other evidence needed to demonstrate that wood/fibre
complies with the requirements for FSC Controlled for that specific category.
Timberlink must ensure that the required documents and other evidence are available for
verification by the Certification Body.
Timberlink must specify and implement a regular (at least annual) verification audit process to
confirm the authenticity of the specified documentation and other evidence. The audit process
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must include consultation with relevant stakeholders, staff interview and field visits to harvesting
sites.
The number of verification audits shall be determined as detailed in Section 5 below.
Timberlink must classify the Forest Management Units (FMU’s) as sets of “similar” units for the
purpose of sampling as detailed in Section 5.
For each set of “similar” FMU’s – the number of units evaluated per annum is tabulated in section 5.
Samples for field verification shall be defined randomly as far as practicable.
Verification audits must be conducted in a timely manner after receipt of wood/fibre.
Consultation with staff and workers must take place unaccompanied by management
representatives from the company (as detailed in Section 7).
All reports or records of verification audits shall be maintained for at least 5 years and must include
the findings of the verification, the extent to which it was possible to conduct the verifications, and
the experience and qualifications of the personnel conducting the verification.
Reports or records of verification audits must be accessible to the accredited Certification Body and
FSC-authorised personnel on request.
4 Risk Assessment
Timberlink uses a National Controlled Wood Risk Assessment for operations. This document must
be reviewed at least annually (before the annual surveillance by the Certification Body) to evaluate
the potential risk of purchasing materials that may compromise the Chain of Custody system.
If “Low Risk” cannot be established at the national level, the scale moves down to State, Bioregional,
District and Forest Management Unit level. Where “Low Risk” cannot be established, the risk is
declared “Unspecified Risk”.
Timberlink CoC Risk Assessments have been developed to address the criteria of the FSC Chain of
Custody standard.
A low risk determination at a national, district, or FMU scale against each of the Controlled Wood
categories means that the companies do not need to implement the procedure of Annex 3 in FSCSTD-40-005.
Categories that have been assessed as low risk:
1.
2.
3.
4.
Illegally harvested wood.
Areas where traditional and civil rights are being violated.
Wood from areas being converted from forests to plantations (VIC, NSW, QLD, WA & SA).
Wood from forests in which genetically modified trees were planted.
Categories that have been assessed as > low risk (unspecified risk classification):
1. Where high conservation value forests (HCVF) are threatened.
2. Wood from areas being converted from forests to plantations (TAS).
HCVF has been assessed as an “Unspecified Risk” at a bioregional level for all Timberlink regions, and
as a result verification of HCVF is required. With respect to areas which convert native forest to
plantations or non-forest use, this Controlled Wood criteria is classified as a low risk within the
Green Triangle region, but an unspecified risk in Tasmania.
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4.1 Wood Harvested from Forest in which High Conservation Values are
Threatened by Management Activities - Verification for Unspecified
Risk
4.1.1 HCV Assessment Undertaken by the Supplier
The Supplier should disclose all available evidence to Timberlink concerning their HCV assessment
programme. Where HCVF have been identified within the forest management units, management
activities must not threaten the high conservation values.
Documentation to demonstrate compliance must be made available to Timberlink by the respective
Supplier. Examples of an acceptable HCV assessment would include Special Values documentation
and a certified Forest Practices Plan (Tasmania).
4.1.2 HCV Assessment Undertaken by Timberlink
Where Suppliers do not conduct FMU level assessments or the assessment completed does not
conform to assessment criteria listed in the ‘HCV assessment evidence’ section as detailed below,
Timberlink must demonstrate that forest management activities in the areas being harvested do not
threaten high conservation values.
HCV Assessment Evidence:
The decision to address high conservation values only at the areas being harvested must be
adequately justified.
Evidence to demonstrate that assessment of high conservation values has been adequately
undertaken includes, but is not limited to:
1. Flora and Fauna - records of assessment through NatureMap (GT), EPBC Species Profile and
Threats (SPRAT) database (GT/TAS), International Union for Conservation of Nature (IUCN)
Red List (GT/TAS), Biodiversity Interactive Map (VIC), Biological Database of South Australia,
Natural Values Atlas (TAS), Conserve database (TAS), Fauna Values database (TAS),
Flora/fauna Technical Notes (TAS), Forest Botany Manuals (TAS),
2. Earth Science - Geomorphological Manual (TAS), Tasmanian Geoconservation database
(TAS), Forest Sinkhole Manual (TAS), Karst Atlas Maps (TAS);
3. Aboriginal Affairs Victoria, Aboriginal Affairs and Reconciliation Division (SA), Forest
Practices Authority (TAS);
4. High Conservation Values (HCVs) Evaluation Framework (FSC Australia). For use in the
context of implementing FSC Controlled Wood standards Draft 2.1. Version 3.4 March 2013.
5. Regional GIS registers/datasets (incorporated in the Regional High Conservation Assessment
and Management Plans);
6. Harvest Planning, Timber Harvesting Plans (GT), Forest Practices Plans (TAS);
7. HCV Assessment Records (GT), Special Values Assessments (TAS);
8. Harvesting Inspection Monitoring Reports;
9. Verification Audits of Coproduct Suppliers;
10. Stakeholder Registers/Databases (Consultation Manager Database);
11. Regional Forest Codes of Practice.
Following the desk top assessment process, infield assessment must be undertaken (in practice this
should be incorporated into the general harvest planning due diligence process). Once the values of
the site have been assessed and the status determined, consultation with stakeholders needs to be
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undertaken (sites/species/value identified, threats to them, how should they be protected/
managed?).
Consultation with stakeholders includes government and non-government organizations,
neighbours, indigenous communities – parties that are involved with or have an interest in the forest
area.
Areas containing high conservation values must be identified on harvesting maps and included in the
Timber Harvesting Plans (GT) and Forest Practices Plan (TAS) prepared by forest managers, together
with special instructions to ensure the values are not threatened. Harvesting and operational
inspections need to record that the values are protected.
4.1.3 Timberlink Verification That HCV are not Threatened:
Timberlink is responsible to undertake verification audits of Suppliers as outlined in Section 5 below
and use the Timberlink Controlled Wood Verification Audit template.
4.2 Wood Harvested from Areas Being Converted from Forests and Other
Wooded Ecosystems to Plantations or Non-forest Uses (Tasmania
Only) - Verification for Unspecified Risk
Timberlink will demonstrate that all types of natural and semi-natural forests and other wooded
ecosystems in FMUs forming their supply are not being converted to plantations or non-forest uses.
Evidence includes, but is not limited to the following:
1. Verification Audits of Coproduct, log and woodchip Suppliers;
2. A Forest Practices Plan and the accompanying Special Values assessment will provide
quantifiable information as to the type of material being harvested and processed. The
document will state the subsequent land use proposed on the particular site.
5 Procedures
5.1 Planning
Following an initial verification audit inspection to assess the origin of the material, verification
audits will be undertaken annually of a sample of Timberlink Suppliers to ensure material is correctly
classified as certified, controlled or uncontrolled.
5.1.1 Suppliers Who Hold a Current Certificate:
Where material supplied is covered by an existing FSC (certified or FSC Controlled Wood), annual
assessment of the validity and currency of the certificate is sufficient to ensure compliance.
Verification of the validity and scope of the Suppliers certificate is achieved via www.fsc-info.org.
5.1.2 Suppliers Who do not Hold a Current FSC Certificate:
Where material originates from Suppliers who do not hold an existing and current FSC certificate,
verification audits will be conducted to quantify whether the material is either controlled or
uncontrolled. A verification audit is required to confirm the origin of material from Timberlink
Supplier Lists, and provide verifiable evidence of purchase contracts or agreements.
The FSC CW Multi-site CoC Manual describes the procedures of managing material which falls into
the different certification categories.
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A verification audit involves inspection of specified documentation to confirm authenticity,
consultation with relevant stakeholders, staff interview, and field inspections of the harvesting
operation.
5.2 Determining the Number of Verification Audits
Initially, any Supplier of material (whether from another forest company, private grower, or sawmill)
into the Timberlink CoC process, must have a verification audit undertaken prior to material being
accepted (the scheduling will be managed by the General Manager Resources during normal due
diligence processes).
The number of subsequent verification audits required is dependent on the number of Controlled
material operations that are being carried out. This is determined through the quantity of:
1. Forest Management Units (FMU) harvested in a year by either suppliers or Timberlink, and
2. Suppliers of coproducts (sawlogs and woodchips/residue) from sawmills.
The total number of Controlled material harvested operational areas can be determined by each
Company’s Harvesting Schedule, which is to be made available to the Timberlink region.
With respect to material provided from sawmill Suppliers to a Timberlink processing site, on
completion of the initial verification audit, annual surveillance audits will be undertaken. Using third
party consultants may be considered.
Timberlink shall classify the audited Company by grouping sets of “similar” units for the purpose of
sampling. Similarity is defined as:
1. Forest type (natural forest, plantation);
2. Geographical location (district);
By default, it is assumed that a single supplier has a single FMU in either area (Green Triangle or
Tasmania). However, GM Resources or delegate may decide that a particular area within a supplier’s
overall operational area is not “similar” to the remainder of their supply in terms of factor 1 and/or
2. In this case, the area that is not “similar” shall be regarded as an additional FMU.
The minimum number of verification audits required is then determined by the following table:
Total FMU
Number of Audits Required
(total number of FMU’s Controlled
material being harvested from)
1
1
2-7
2
8-11
3
12-24
3
25-39
4
It is the responsibility of GM Resources to ensure that an adequate number of verification audits is
performed in each audit year.
It is important that, as far as practicable, random sampling occurs when selecting field verification
audit sites.
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6 Preparing for the audit
Prior to receiving any material from a Supplier, an initial verification audit is required to ensure
transparency is maintained.
After receipt of Controlled material from a registered Supplier, the General Manager Resources or
delegate will decide when to undertake a verification audit.
6.1 Stakeholder notification
Timberlink’s verification audit procedure must gather evidence of consultation with relevant
stakeholders on the presence and threats to HCV identified as threated by management activated in
the FMU. Stakeholder consultation is a critical part of the validation and identification of HCVs and
associated threats at the FMU level.
Stakeholder notification of Timberlink Controlled Wood verification audits shall follow a two-stage
process:
1. Soon after an external surveillance or recertification audit, the GM Technical & Environment
shall notify FSC Australia of our CW verification program. This notification is to appear on the
FSC Australia Internet site. At the same time, stakeholders specifically identified on the list
contained in this document will be directly provided the same notification. The notification
may include documents attached.
Note that no verification audits may take place unless stakeholders have been advised no
less than a clear 30 days prior to a verification audit (60 days for the first audit).
2. When Resources personnel or others are planning to perform a verification audit on a
supplier to Timberlink, they must identify specific stakeholders to the planned audited and
notify them directly prior to the audit.
6.2 Planning the audit
In preparing the plan:
1. Identify the scope of the audit being conducted (confirming origin and confirming that HCVF
are/are not threatened);
2. Identify if:
a. a field visit is required,
b. the Company is to provide stakeholder names (including NGO’s and
interested/involved parties),
c. interviews with staff are required.
3. List the specified documentation to be audited. For a verification audit of origin this will
include the Company’s Suppliers List and Proof of Purchase documentation and contracts.
For a verification audit to confirm HCVF, documentation will also include:
a. Records of assessment for the presence of HCVF at the operational level,
b. Records of stakeholder engagement in determining the classification and presence
of HCVF,
c. Harvesting Plans,
d. Harvesting inspection records.
4. Name the Timberlink staff member(s) (audit team) or external contractor responsible for
undertaking verification programs to be audited.
5. Identify the Company office and/or operations to be inspected.
6. Detail meeting requests for Company staff and Company stakeholders.
7. Detail the audit report distribution.
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7 Operational Requirements
7.1 Conducting the Audit
The audit is divided into four components:
1.
2.
3.
4.
office meeting, document review, and staff interview,
field inspections,
stakeholder interview, and
report writing.
The audit team may be required to meet with Supplier staff at the office to allow inspection of
specified documentation, as identified in the Audit Plan.
Where possible, the audit team is to be accompanied by Supplier representatives to undertake field
verification of operations regardless of whether HCVF have been identified or not. The intent is to
audit the documentation with what is identified in the field during the inspection audit.
When interviewing harvesting contractors and other stakeholders, the audit team should undertake
it independently of Supplier representatives.
Identified stakeholders will be interviewed using the verification audit template as a guide.
7.2 Audit Report
The audit report should include the overall findings of the verification audit. A summary of findings
must be included at the front of the report. It should address the overall result of the verification
audit and the extent to which it was possible to conduct the assessment and include the experience
and qualifications of the personnel conducting the verification.
The verification audit identifies whether compliance has been achieved and includes an observation
column to detail findings of the question, including what evidence was sighted.
Once the draft report is finalized, if a negative assessment of compliance is made, it is distributed to
relevant parties. The Suppliers have a period of two weeks to accept or reject the findings of the
audit.
Any suggestions for improvement to the audit checklist or procedure should be communicated to
the General Manager Resources.
The Suppliers are responsible for developing and implementing corrective actions to issues identified
in the audit report and feedback is to be provided to the General Manager Resources to ensure they
are adequately addressed.
Owner: GM Technical & Environment
Approved 30th June 2014
Printed: 09/02/2016
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