An independent observer of the Forest Stewartship Council

FSC certification of US public forest lands: the warnings from MichiganTags: USA, Certifier conflict of interest, Accreditation controls, SCS

Debate is growing in the US about the certification of public forests with FSC and the so-called Sustainable Forestry Initiative (SFI) being the front-running schemes. There are good reasons to question whether, in its current state, FSC is an appropriate tool for certification of the vast areas of forest which are in state and federal public ownership in the US, and which in many cases have very high values for recreational, cultural and nature protection purposes. Some of the potential problems are starkly illustrated by one of the existing major FSC certifications of public forest lands, that of the 1.6 million hectares of the Michigan state forests as managed by the Michigan Department of Natural Resources (DNR).

The Michigan DNR was certified under the FSC at the very end of 2005 by Scientific Certification Systems Inc (SCS). The certificate was soon the subject of an informal complaint to FSC by the Sierra Club, who evidently felt that DNR was non-compliant with the FSC's Principles and Criteria. As a result of this complaint, in October 2006, FSC's Accreditation Services International undertook a second look at the certificate as part of its regularly-scheduled audit of SCS.

The report of FSC's investigation, eventually published in July 2007, is very revealing (available for download below).

For example, the FSC Audit Report states (pg. 7): "concerns that a much too high proportion of the landscape managed by DNR for early successional species appears to be based on an ideal that is not practical for DNR to manage to given the multitude of stakeholder concerns that it must respond to." This statement appears to permit a forest management operation to be assessed not for compliance with FSC standards but with the 'practicality' of managing to various stakeholder concerns.

Further evidence of ASI's apparent acquiescence to an entirely different standard of 'compliance' is the following statement from the Audit Report (pg. 9): ...management is not completely ideal from an environmental perspective, but given the social and economic pressures associated with managing such a large public forest, the trend seems positive rather than negative, and generally consistent with FSC direction." This indicates that FSC-ASI - which is supposed to ensure that FSC's accredited certifiers uphold the Principles and Criteria - has, in this case, actually knowingly allowed the certifiers to issue certificates to companies that are non-compliant with specific standards, and instead on the basis of 'trends' and 'general consistency' with FSC 'direction'.

ASI seems to clearly acknowledge that MI DNR has not met FSC certification standards. Again from the Audit Report (pg. 10): "MI DNR appears to recognize the intent of the FSC standards and has gone to some length to adjust its management to conform to the standards." This obviously means that MI DNR has not complied with the standards to date, and, more disturbingly, that its management can be certified as long as DNR 'recognizes the intent of' and 'goes to some length to conform to' FSC standards, rather than achieves actual compliance with the standards.

In another statement from the report (pg. 10), ASI further implies that MI DNR should be given considerable latitude in how it manages its forest, whether or not its management is FSC-compliant, simply because MI DNR is under various 'pressures': "MI DNR has suffered from budget cuts and is under pressure from a host of stakeholder groups, which poses some real difficulty in changing direction in as timely a manner as [Sierra Club], or SCS, would prefer." The implications of this, if extended across other public forest lands, would be that sub-standard (non-compliant) forestry practices would be tolerated by FSC depending on whether it was felt that 'stakeholder pressure' or budgetary constraints were in force - making a complete mockery of FSC as a supposedly 'performance-based' certification system. (In fact this is a consistent problem with how FSC regards the issuing of non-compliant certificates, such as in Uganda and Spain).

The report further adds: "Sierra Club as well as other stakeholders should continue to apply pressure to help DNR understand its concerns about the environmental effects of its management." This is tantamount to an admission by the FSC that it itself will not control the quality of the certificates issued in its name or ensure that the auditor (SCS) deliver, substantiate, or require such compliance (as it is required to do under its accreditation to FSC), but will rely on 'other stakeholders' to "apply pressure" to ensure MI DNR compliance with FSC standards.

FSC rules do not permit relaxation of certification standards and compliance requirements, or a shifting of fundamental management responsibility, whenever a forest manager has budget problems or is under pressure. Toward the end of the Audit Report (pg. 13), ASI dismisses such compliance failures as mere "loose ends" for DNR to deal with, of little consequence because DNR is "trying very hard". DNR may well be be "trying very hard", but this is not sufficient performance within the FSC system to earn an FSC certificate. ASI notes deficiencies in SCS's stakeholder consultation procedures, but the Audit Report (pg. 12) calls these deficiencies only a "potential problem", appears to state that it is a lower-level concern because "it may be a systemic problem within SCS" (which should instead make it a higher-level concern), and also notes that it is a problem which apparently afflicts "most CBs" - but then fails to recommend any corrective action whatsoever. So the conclusion here is that FSC is well aware that there are systemic problems with some of its accredited certifiers, but is failing to do anything about it.

There is another problem because of the way that FSC's accredited certifiers are allowed to directly contract with the forest managers. Regulated forestry standards on public lands are, at least notionally, subject to democratic accountability. However, forestry 'standards' established through the FSC process are basically the result of a confidential bilateral commercial contract between the public body and the FSC certification agency, such as SCS. As we have seen above in the case of the State of Michigan, although SCS is supposedly required to apply 'multistakeholder safeguards', they might well not do so, and know that they can get away with this with impunity, because the FSC-ASI now has a long track record of 'turning a blind eye' to the certifiers' failures. The case of management of public forest lands in Ireland is a long-standing example of how the FSC has actually served to undermine national targets for improved forestry.

This means that, whilst the FSC was designed precisely so that 'multiple forest uses' are taken into account, in practice, because of the certifiers' persistent failures to uphold the Principles and Criteria, and FSC-ASI's failure to take action against such certifiers, the FSC system would be a very unreliable means of ensuring quality of management on US public forest lands; indeed, there is a real risk that FSC could serve to undermine existing forestry standards.

Download the FSC-ASI report on Michigan here: ASI2006MISCSauditpublicsummary.pdf


Information and pictures on FSC-certified clear-felling of public forests in Massachusetts can be found here:


Got to website www.credibleforestcertification.org FSC and assoiciated organizations are the most bias elitism groups they don't really care about what happens on the ground they are politically motivated by left wing nuts. They spend most of their energy tearing down other certifications and not worrying about there own. Thats why common sense people have certified SFI over 10 to 1 fsc.

Thanks for your comment, Jimmy. Unfortunately, the reason that there are more SFI certificates than FSC certificates is that SFI is a far weaker system than FSC. It's even easier to get an SFI certificate than it is to get an FSC certificate.

The organisations behind credibleforestcertification.org are right to criticise SFI. The problem is that they are not critical enough of FSC.

FSC-Watch exists to point out the flaws in the FSC system as it currently operates. That does not mean that we think that the other certification systems are better than FSC. They are all worse than FSC.

I do not know who sponsors this website, but they are not being honest with the readers. I am a graduate student in the Warner School of Natural Resources, Colorado State University. I have recently completed five case studies of FSC certification of state and county forests in Minnesota, Wisconsin, Michigan, Ohio and Pennsylvania. I have copies of the audits, to include the one in Michigan, which played a key role in my study. The statements above are not only taken out of context and given inappropriate spin, but the writer is unethical in that he fails to explain to the reader that the FSC Audit is only a first step in a five year process by which the audit team of forest scientists (and at least one social scientist) continues to dialogue with the state forest service/DNR to advance sustainability in the audited forest system. Please note that in Michigan I interviewed not only state foresters and forest/wildlife scientists, but also environmentalists, forest advocates, leaders of forest communities and wood products manufacturers. In Michigan and the other states I was hard pressed to find a forest stakeholder that did not support FSC certification. Those - to include the state foresters - who had reservations prior to the certification process were wholly convinced and committed to FSC certification as a way to improve their forest management once they saw the results. Moreover, many forest stakeholders who would be in disagreement on some fundamental forest issues were in total agreement regarding the improvement in transparency that FSC certification brings to the forest planning process. Be advised that I am not a "leftie" but a conservative Republican and former owner of a construction company who puts science first over hidden agendas and narrow ideologies. The independent Pinchot Institute for Conservation in 2006 did a comprehensive comparison of the legitimate, science based systems/programs for sustainable management of forests in the US. I direct your attention to their study at http://www.pinchot.org/results?cx=001971156044248059572%3Ay9otwb6rwt4&cof=FORID%3A10&ie=UTF-8&q=forest+stewardship+council&sa.x=8&sa.y=5 where the "quick Look" table shows just how comprehensive an audit is when using FSC principles and criteria. Moreover, please note that FSC-International found nothing wrong with the SCS audit procedures and results in the Michigan case noted above. Also, most state Sierra Clubs chapters, contrary to their National HQ in Washington DC, support FSC certification of their public forests.....I don't know who runs this blog but they certainly don't do their homework, don't do good science and appear to represent someone's vested interest with an unethical agenda..... any experienced forest stakeholder in Michigan will see right through this hubris.

PS: Chris Lang is correct to be concerned regarding the possibility of third party certification of any sustainability phenomenon being corrupted. This is certainly well documented in the case of third party certification of carbon off-sets/credits. However, in the case of SCS and the other accredited FSC auditing agencies, they hire independent foresters, forest and wildlife scientists and social scientists who are almost always well respected academics from research universities with substantial peer reviewed research experience and publications. In most cases this is a one-time contract and there is not a heavy expectation of repeat contracts by an auditor with that state. Moreover, the state does not choose their auditor team and has no control over who is picked for the team by the FSC accredited certification agency. Moreover, the audit team's approach to doing an FSC audit is not unlike their approach to doing any academic peer reviewed research. They are concerned that their work is of a scientific and ethical quality that it will be respected by their peers as good work, even if there are disagreements on findings. Based on my interviews SCS staff does not in any way influence their work. Due to their years of reserach the auditors would not take a contract that would not permit them to have the academic freedom to express their perceptions freely. Moreover, the contracts with the state DNR are normally open to public scrutiny and the way they are written does not in any way impact upon the substance of the research. In addition, due to the active engagement in the FSC certification process by all forest stakeholders in that state through public meetings and actually participating in some cases in the audit inspections of specific sites, it would not be possible for FSC auditors to accede to state influence...and in some of the SCS audits full FSC certification is clearly provisional unless state foresters and, in the case of Pennsylvania with a too large a deer population over-browsing,the governor, legislators and state policy managers, do not take appropriate corrective action. Finally, if there is any reports of mishandling the audit the FSC accredited audit agency would be placed in the untenable situation of having its accredidation withdrawn by FSC. There are just too many checks and balances, too many independent observers, too much professional oversight and too much transparency for the FSC certification process to be "gamed."

The problem is, Peter, that you seem to have fundamentally mis-understood the nature of third-party performance-based certification. You state that:

"the FSC Audit is only a first step in a five year process by which the audit team of forest scientists (and at least one social scientist) continues to dialogue with the state forest service/DNR to advance sustainability in the audited forest system"

However, the FSC audit is supposed to determine whether the certification client fully complies with the FSC's requirements *at the time of the audit*. Other than the 'Minor Corrective Action Request' system (which is frequently abused in order to pass non-compliant companies), there is no 'future improvement' system within the FSC. The concept of the 'stepwise approach' to certification has long been promoted by the certification bodies, for the obvious reason that it would potentially greatly enhance their markets. In practice, certain certification companies have continued with the practice of issuing certificates to their clients on the basis of hoped-for future improvements, and continue to claim that this is acceptable within the FSC process - but it is not something that has ever been formerly adopted by the FSC. The system is simple: pass or fail.

That is not to say that improvements in forestry practices might continue to happen after flawed certificates have been issued, which is perhaps what you have observed in various US public forests. But the point is that FSC is a scheme which issues its logos to be placed on forest products on the basis that they have complied with the FSC's requirements. Where the products come from forests that did not comply with these standards at the time of assessment, then clearly the public is being misled by the information on the product, and the labels are arguably fraudulent.

I don't know where you get the impression that "FSC-International found nothing wrong with the SCS audit procedures". The posting above clearly shows where SCS's systems were flawed. Other ASI audit reports show similar, systemic, problems.

You accuse FSC-Watch of being 'unscientific' - and yet you seem to assume that the mere existence of a 'complexity' of audit requirements, and the engagement of academics necessarily results in a truly independent and reliable certification assessment. In fact, FSC-Watch has been informed by numerous ex-certification assessors of how their respective companies manipulate audits in order to be able to issue a certificate. In the case of SCS, analysis has suggested that the number of clients *just* passing the threshold scoring of compliance is probably more than would expect statistically.

Finally, you say that "if there is (sic) any reports of mishandling the audit the FSC accredited audit agency would be placed in the untenable situation of having its accredidation withdrawn by FSC". What might not have been so apparent in your studies is the clear fact that the FSC is extremely reluctant to withdraw accreditation for the certification companies, especially in the case of the 'Big Four', which includes SCS, and which hold the 'critical mass' of FSC certificates. In fact the FSC is probably constrained from doing so by the terms of its closely-guarded contracts with the certifiers, which have contained clauses allowing the certifiers to sue the FSC in the event that it does anything to damage their business. Even where the ASI has found egregious breaches of the FSC's requirements, certifiers have only, at worst, been temporarily suspended (typically, for 6-12 months) from issuing new certificates in specific countries. This is simply not a strong enough deterrent to bad behaviour.

The overall consequence of this is that the certifiers know that they are very unlikely to be heavily sanctioned for non-compliances, whilst the incentives to issue non-compliant certificates are much stronger.

Unfortunately, the misinterpretation you have made is exactly what the FSC, sadly, now relies on: you see 'transparency', where there is actually only smoke and mirrors.

How Accreditation Services International (FSC-ASI) allows certifiers to break FSC’s rules and issue certificates to non-compliant companies | FSC-Watch
FSC Watch: How Accreditation Services International (FSC-ASI) allows certifiers to break FSC's rules and issue certificates to non-compliant companies
In the past, FSC-Watch has been welcoming towards the work of Accreditation Services International (ASI), the FSC body which is supposed to ensure that the FSC's Principles and Criteria are upheld by the accredited certifiers. There is no doubt that ...

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