A PROPOSED VOLUNTARY PROGRAM FOR
ECO-FOREST MANAGEMENT LABELING
OF SOFTWOOD LUMBER
The emergence of new and competing "green" rating systems for homebuilding, each seeking adoption in model If a grade-stamp is acceptable to document the structural strength of a piece of lumber, why not it's ecologic lineage?building codes and each specifying different proprietary eco-forest certifiers, has the potential to significantly disrupt the homebuilding product supply chain. Currently, five branded eco-forest management certification programs vie for preference and for market share in the dimension lumber product space: ATFS, CSA, FSC, PEFC, and SFI. There are no barriers to even more eco-certification schemes emerging in the future.
In addition, the United States is a signatory to the Montreal Process Criteria and Indicators for the Conservation and Sustainable Management for Temperate and Boreal (northern) Forests (67 indicators). The USDA Forest Service currently collects data on 21 criteria. The Montreal Process, of which the United States is a signatory, identifies 67 criteria and indicators for sustainable forest management.The Montreal Process and the various certification programs share the common goal of sustainable forest management, and incorporate social, economic, and environmental indicators – including biodiversity, water quality, forest cover, long-term impacts, and forest planning.
Further, each of the branded eco-forest certification regimes has its own distinct eco-forest management standard (on the requirements side), and distinct chain of custody requirements for tracking dimension lumber products from forest to consumer (on the compliance side).
Chain of custody requirements for each certification regime are summarized as follows:
- American Tree Farm System: ATFS offers chain of custody through the PEFC Annex 4, as valid and amended, referenced below.
- Canadian Standards Association: CSA PLUS 1163 Chain of Custody for Forest Products Originating from a Defined Forest Area Registered to CSA Standard, CAN/CSA-Z809. Thirteen pages covering "general requirements, management commitment, documented control system, verification of origin of wood raw material and products, inventory control and accounting of raw wood material flows, optional approaches to qualifying for chain of custody, inventory control and accounting of wood flows, physical separation and/or marking of raw materials, final inspection, record keeping, and internal checking."
- Forest Stewardship Council: FSC Standard
For Chain of Custody Certification, FSC-STD-40-004 (Version 2-0) EN, January 2008. Twenty-six pages covering "quality, scope of chain of custody system, material sourcing, material receipt and storage, volume control, and sales and delivery." - Programme for the Endorsement of Forest Certification: PEFC Chain of Custody of Forest Based Products–Requirements, Annex 4, June 2005. Thirty-five pages covering "general requirements for physical separation, identification of the origin, identification at delivery level, identification at supplier level, separation of the certified raw material, and sale of certified products."
- Sustainable Forestry Initiative: SFI Requirements for Fiber Sourcing, Chain of Custody, and Product Labels, October 2006. Fifty-one pages covering "implementation of chain of custody within ISO 9001:2000 33, within ISO 14001:2004 34, in multi-site organizations, calculation of the certification percentage, within SFIS 2005-2009, certificate requirements, and implementation of dual chain of custody certifications to meet SFI and PEFC label use requirements."
All of these requirements are administratively complex and expensive to implement, and, conceivably, may soon actually threaten the competitive sourcing of dimension lumber. [All of these requirements could also be construed to apply to an over-the-counter sale of 2X4s to an individual consumer requesting "eco-certified" lumber for a weekend project.]
Impact on Distributors
The impact of branded eco-forest certification schemes for distributors and, by inference, for all other downstream purchasers and resellers of dimension lumber products, manifests in six principal ways:
- Higher cost of goods when competition is restricted to branded (closed) supply channel.
- Obligation to verify/document all incoming supply.
- Product segregation and surveillance requirements in inventory, potentially multiplying the number and space requirements of dimension lumber SKUs in the yard by a factor of five (perhaps more over time).
- Exponential multiplication of administration in disaggregating and mixing supply shipments to meet customer needs.
- Transfer of all updated verification/documentation to an immediate purchaser.
- Obligation to archive all records related to chain-of-custody for each purchase and for each sale (5 years). Burden of documentation falls to seller of product rather than producer of goods.
Current Situation
Presently, PS-20 grade-stamping, administered through the American Lumber Standard Committee (ALSC) of NIST and the Department of Commerce, enables the distribution side of construction supply channel to treat dimension lumber with equal grade attributes as interchangeable commodity products assuring availability, fresh quality, and competitively sourced product.
Distributors turn dimension lumber on a bi-weekly to monthly cycle. This turnover of product is fundamental to the financial stability of this industry and also to the supply of competitively priced framing materials for new homes. In addition, PS-20 grade-stamping provides instant and permanent documentation of whether the product meets design specification and/or building code.
In response to the emerging disparate and complex eco-forest management certifications and chain of custody requirements, LBMI is seeking industry input regarding (consensus) development of an eco-forest management standard and has requested that ALSC consider implementation of an eco-labeling program that would parallel PS-20 grade-stamping. The attached diagram sketches how and where an eco-forest management standard and eco-labeling might best be implemented to sustain the commodity-attributes of dimension lumber products.
Purpose of Survey / Public Forum
In preparation for preliminary presentation of this request to the ALSC Administrative & Finance Subcommittee meeting on August 27, 2008, LBMI will seek to:
- Demonstrate broad based interest in the consensus development of an eco-forest standard and associated eco-labeling program, and, if broad based interest exists,
- Engage the various current certification schemes in discussion to see if there is willingness on the part of some or all to work together to define a U.S. eco-forest management standard for lumber products.
Based on this information, ALSC will determine if the proposed approach is compatible with its present operations, if it is something that can be self-funded by industry, and what the ultimate impact on industry is likely to be. LBMI will gather the needed industry perspectives through stakeholder interviews and the conduct of a public forum.
If acceptable to its full committee, ALSC will consider adopting a policy or rule governing authorization of accreditation groups to implement eco-labeling of dimension lumber at production, and before entry to a commerce channel.
LBMI will gather the needed industry perspectives through stakeholder interviews and the conduct of a public forum to answer the following questions, among others.
LBMI SURVEY OF ECO-LABELING PERSPECTIVES:
Responses must be received no later than July 18th, 2008 for inclusion survey tabulation. Survey results will be posted on LBMI website and conveyed to the American Lumber Standards Committee in August. To submit written response:
[The respondent information is requested to categorize response summaries and will not be used for any other purposes.]
Download [pdf] version of survey here
and mail completed survey to:
David B Hattis
c/o Lumber Building Materials Institute
2025 M Street NW, Suite 800
Washington, DC 20036-3309