The Last Word on Wood:
Chain-of-Custody Certification: (COC)
by Terry Campbell, Forest Products Solutions
Part 1: Why, Who & How
I am commonly asked, “Do I need to be COC certified to sell FSC product to a LEED project?” or “As a contractor how do I know that the FSC wood products that I am buying are actually FSC?” These are very common questions that are part of the process of developing a more responsible, accountable and credible green products industry. This three part series will explore why Chain-of-Custody (COC) certification programs were developed and their importance in the marketplace; who needs to be certified; and how a company would go about earning an FSC Chain-of-Custody certificate.
The concept of certifying that products or service providers are legitimate and able to actually provide the services that they claim goes back decades. The need for end-users to be confident of a company's product claim is very important to ensuring that the customer gets what the customer wants. The history of our country is full of instances when the people and government required more oversight of businesses to ensure that end-users were being protected and were well informed about the products they are buying.
For close to 100 years the US federal government, through a number of different agencies, has inspected meat and poultry processing facilities to ensure that practices meet the law and the food is prepared in a healthy manner. These inspections result in a product claim that is quite common in the marketplace, “USDA Approved.” This provides a baseline level of assurance that rules are being followed and laws are not being broken, but it does not reward those who are leaders in their industry for going above and beyond.
The flip-side of government mandated inspections that attempt to keep an entire industry above a minimum set of regulations (the stick) is an independent voluntary certification program that, if accepted by the market, will provide economic benefits to the leadership companies for exceeding the market's expectation (the carrot). This is where the Forest Stewardship Council (FSC) certification program fits in.
FSC is an independent organization that sets standards and accredits third-party auditing agencies to carry out forest management and chain-of-custody certification audits. FSC was first to the market in the early '90s and it benefits from a broad membership structure.
Since FSC's inception many other forest certification systems have been developed to compete with FSC. This competitive ‘certified wood' industry has required all systems to improve their standards to provide the end-users with continued assurance that the industry would rather participate in a voluntary, market-based system for promoting sound forestry over government regulation. An analogous situation has developed within the building industry over the past 10 years and the US Green Building Council's LEED program has been the leader in that industry.
Some of the initial concerns about these emerging certification programs, whether it's for forest products or buildings, are that they cost money, they often promote new concepts that are foreign to business, and there is a learning curve to making profits. These concerns have driven many in the forest products manufacturing and distribution sectors to clamor for a one size fits all eco-label for all third-party certified wood products. The same proponents of this approach regularly speak of the need for more ‘free enterprise' in North America.
According to the Merriam-Webster Dictionary, free enterprise is defined as, “the freedom of private business to organize and operate for profit in a competitive system without interference by government beyond regulation necessary to protect public interest and keep the national economy in balance.” If these opponents to an open, competitive certified wood market were such advocates of ‘free enterprise' they would not be looking for a one size fits all solution that resembles government intervention or a baseline standard. They would instead embrace the new business concepts and create new business alliances for future growth.
With the expansion of the green and eco labeled building products industry and the very serious potential for end-users to become skeptical about product claims, it is critical that the forest certification systems continue to compete, to improve themselves, and to allow end-users to make the choice as to which products they buy.
Chain-of-Custody Certification: (COC)
Part 2: Who needs to be FSC COC certified?
According to the Forest Stewardship Council the answer is quite clear: "Any operation making, changing, trading, re-labeling, or repackaging FSC-certified products needs to be COC certified in order to use the FSC trademarks and to enable its customers to make an FSC claim about these products." (Source - FSC International at www.fsc.org)
The last part of this statement is quite important for manufacturers, distributors, and dealers selling (invoicing) to green building project managers who expect to earn a credit for using FSC-certified wood. That customer is making a claim about those products, so the need for robust documention of the chain-of-custody is vitally important. It is the very practice of having a chain-of-custody in place to track FSC material from the forest floor to the retail floor that has given FSC its credibility in the market. If you look at the history of other forest certification systems, you will find that they only implemented a COC as an afterthought due to the market's lack of trust in products derived from their systems.
In the past, unfortunately, not all market driven initiatives had set their requirements to dovetail with FSC standards. This led to a tremendous amount of confusion and frustration in the secondary manufacturing and distribution sectors. And when programs such as LEED – that assign credit for the use of FSC-certified products – change their reporting requirements to better reflect the FSC standards, frustration can set in for companies that have designed sales and marketing strategies around the current standards, only to have them changed.
However, change in any environment – business or natural – is inevitable. In the newly developed green building and certified forest products industries, standards and policies have changed only in order to insure that the systems continue their leadership role and protect their credibility.
Now it would be great if a standard setting organization such as FSC could develop a rule for each sector and niche of a specific industry, and then spend millions of dollars explaining that program to everyone in that industry. Sadly, that is unrealistic for a non-profit group that is developing standards to improve the method in which we manage forests and process certified products.
FSC is challenged with developing standards that are specific enough to achieve its mission without being so complex that they intimidate too many organizations from participating. A balancing act for sure, especially when working in an industry that is global in size, with centuries of history, and fragmented into dozens of sectors and niches. The confusion around who needs to be COC certified for green building projects has evolved over time but the USGBC, which administers LEED, has recently announced who they will now require to be FSC COC certified.
"All vendor invoices for permanently-installed wood products, both FSC certified and not, purchased by the project contractor and subcontractors must be compiled. Vendors are defined as those companies that sell products to the project contractor or subcontractors.
Note that this means that each wood products vendor that invoices FSC certified products must be COC certified by an FSC accredited certifier." (Source - USGBC MR TAG Memo, 4/7/2008)
News of this change in LEED project documentation has been slower to get out in the market, but essentially it says that if you sell a product(s) on your company's invoice to a general or subcontractor for a LEED job, you must have your own FSC Chain of Custody code, the format being: the certification body's initials, followed by COC, and then a set of numerals (SCS-COC-XXXXXX) which are unique to your business – whether it is a manufacturer, distributor, dealer, or retailer. The old, sneaky way of simply putting your supplier's COC code on your invoice is not legitimate under FSC or USGBC rules.
I get calls all the time from colleagues asking me if one company or another needs to become FSC Chain of Custody certified. My answer is always the same and it can be summarized in three points:
1) I will ask them, “Is the company installing the finished products or issuing the final invoice?”
2) If they are unsure, I recommend that they should go ahead and earn the FSC Chain of Custody certificate because it will ensure that their customers are satisfied about working with them, plus they will gain the right to use the FSC logo for marketing purposes.
3) In the end, FSC Chain of Custody certification could settle down to ‘risk management' for a product vendor. If they choose to forego COC but then sell FSC products to a LEED project, that project will not earn their expected FSC credit, and the vendor will suffer from lost credibility in a very young growth industry.
Chain-of-Custody Certification: (COC)
Part 3: How to earn your FSC COC Certificate
So you realize now that as a secondary manufacturer, distributor, dealer, or retailer, you may have been operating outside of the FSC and USGBC rules. Have no fear, because the process towards earning your FSC Chain of Custody certificate (COC) is much easier than your colleagues or peers tell you.
The COC certification has two over-arching goals: 1) to insure that you are not selling more FSC products than you are buying raw material and 2) to insure the proper use of the FSC restricted trademarks and logo. There are concerns that some companies would knowingly or unknowingly ‘game the system' to their advantage through breaking one of these two rules, or both.
The first thing any company should do is contact one of the FSC accrediting certifiers or certification bodies (CBs) to request an application. A full list of the CBs that operate in North America is available on the FSC-US or FSC Canada websites. Since FSC is a third-party certification system you will not be visited by an employee of FSC, but instead your initial visit will be made by an employee of a CB or one of their regional contractors.
I normally recommend applying with more than one FSC certification body so that you can receive competitive quotes for the auditing and reporting writing process. Once you have selected a CB, they will send you what seems like a ton of information to work with, and this can be quite overwhelming. The key document will be a template from your CB instructing you how to develop your Documented Control System (DCS), which is the written set of procedures you will apply in-house. The basic sections of the written procedures include: Quality Management, Scope of Chain-of-Custody system, Material Sourcing, Material Receipt and Storage, Volume Control, Picking a system to control your FSC claims, Sales & Delivery, Logo Use (on-product & off-product), and Outsourcing (where applicable).
Following your selection of a certification body, the CB either assigns one of their employees or selects a regional contractor to make the initial visit and submit a COC report. This person will probably contact you rather quickly to answer any basic questions and schedule their onsite visit – unless you are a broker, in which case a phone audit is adequate.
On your end, it's a good idea to schedule the visit far enough into the future that you have time to complete a draft of your DCS. If you are particularly eager to speed the process, you should draft a DCS and send it to your auditor in advance of their arrival so they have already reviewed before they step foot into your office.
Once the auditor arrives at your facility the actual onsite visit can vary in time depending on the size and complexity of your facility or operation; this should be determined during your initial call. Following the onsite visit the auditor will complete a report and submit that to your selected certification body.
The CB will then review the report and supporting documents (typically the DCS, Product Group Schedule, List of Suppliers, Training Records, and Mock-Up Invoice with correct FSC claim). Once you have been approved, they will issue you an FSC Chain of Custody certificate with your unique FSC COC code. An FSC COC code starts with your CB's initials followed by the letters COC and then your unique set of numerals. That could be, for example, SCS-COC-123456. At this point, you are ready to produce and sell products with FSC documentation that your customer can repeat for their own certification purposes, plus you will have your own FSC COC code to integrate into your invoices.
This outline on the certification process is quite brief, of course. If you'd like more assistance, please contact my company, Forest Product Solutions, for our concise guidebook titled FSC Manufacturing & Sales Guide. The guidebook provides a simple to follow plan on how to earn FSC COC certification and become a part of this emerging industry.
Forest Products Solutions provides companies with the services and tools to improve the manufacturing, distribution and marketing of FSC-certified and related green building products. To learn more about Terry Campbell and Forest Products Solutions go to: www.forestproductssolutions.com.

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The USGBC & Market Transformation
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