SGS QUALIFOR
(Associated Documents)
Doc. Number:
Doc. Version date:
AD 54-G-01
01 September 2008
Page:
1 of 14
REQUIREMENTS FOR COMPANY FMU VERIFICATION PROGRAM
(Based on Annex 3 of FSC-STD-40-005 V2-1 - Company Evaluation of Controlled
Wood)
INTRODUCTION
Requirements for company verification program
There are 3 options for avoiding the purchase of wood from “unacceptable sources”:
1. Buying FSC certified material.
2. Buying FSC Controlled Wood (from a COC certified company that are certified to sell
FSC controlled wood)
3. Include wood material in the company‟s own verification program. (“self controlled
wood”)
Companies implementing an FSC Controlled Wood verification program sourcing from areas
that cannot be classified as low risk shall ensure that it is in compliance with the
requirements specified below. This must be done for each FMU from an unspecified risk
district.
NOTE: The Company can choose to develop its own verification program or authorize
another organization to do it.
As part of a verification program the (potential) district(s) of origin (where the company is
planning to buy wood from), must be determined and a documented and systematic risk
assessment performed for each district of origin (Annex 2 of FSC-STD-40-005: refer SGS
Qualifor Reference Document 16 and AD54-F).
If a district cannot be considered “low risk” for any of the “unacceptable sources” (“controlled
wood categories”) FSC requires you to carry out on-site audits at the level of the forest
management unit (FMU). The results of this audit process will be reviewed by SGS and the
company shall ensure that the required documents and other evidence as required under
Section D (below) are available for verification by SGS.
Reports or records of verification audits shall be accessible to SGS and FSC-authorized
personnel on request.
This document can be used to do the on-site audit to ensure that the requirements from FSC
are followed.
NOTE: The Company may develop alternative measures in its verification program to ensure
the compliance with the intent of this standard, which is, to avoid wood coming from the five
categories.
Any findings against these requirements will lead to the disqualification of the
supplier and the wood may not be used in an FSC certified Mixed products.
SGS South Africa (Qualifor Programme)
Systems and Services Certification Division
58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South Africa
t +27 11 681-2500
681
f +27 11 681-2543
www.sgs.com
www.sgs.com/forestry
AD 54-G-01
A
Page 2 of 14
CERTIFIED COMPANY DETAIL
Company Name:
MD Papeis Ltda
Certificate Number
SGS-COC- Non-applicable
Controlled Wood Certificate Number
SGS-CW- Non-applicable
Country:
Brazil
Company Address
Physical Address:
Postal Address:
Rodovia: Presidente Tancredo
de Almeida Neves km 34
Caieiras –SP
Contact detail:
B
Contact person:
Júlio César Tomás Alves
Telephone:
(11) 4441-7850
Fax:
(11) 4441-7800
e-mail Address
[email protected]
Assessment done by:
Rodrigo Vaz Domingues
Relation to the company:
Environment Coordinator
Date:
24/11/2008
Signature
Rodrigo Vaz Domingues
SUPPLIER DETAIL
Company Name:
Hachmann Industria e Comercio Ltda
Country:
Brazil
Company Address
Rua: Alexandre Thomazzoni,280 Centro
CAPINZAL – SC
CEP 89665-000
Type of source e.g. natural forest
or plantations and general
description of the supplier
Planted Forest in an area of 2000 hectares. Pinus Elioti, Pinus
Taeda, Araucaria Angustifólia.
Mechanical pulp producer
Summary of Results
AD 54-G-01
Categories
Illegally harvested wood;
Wood harvested in violation of
traditional and civil rights;
Wood harvested in forests where high
conservation values are threatened by
management activities;
Wood harvested in forests being
converted to plantations or non- forest
use;
Wood from forests in which genetically
modified tress are planted.
Motivation
(Low or
unspecified)
No!! The extraction is done in an area of
2000ha divided into plots. Each plot has trees of
same species.
Low
No!! The extraction of wood is done by a team of
trained drivers.
Low
The wood for the manufacture of mechanical
pulp is produced in the own company area of
2000 hectares.
Low
No!! The area is used exclusively for complying
with the industrial unit.
Low
It is not applied – As discussed in the meeting of
March 13th, 2009 with Mr. Urbano Hachmann.
Low
C
General requirements
1.
Company verification program –
REQUIREMENT
1.1. Is evidence available to confirm that wood/fibre
coming from a particular supplier has been controlled
for the category or categories of wood:
a)
forest areas where traditional or civil rights are
violated by forest management activities;
b)
forest management units having high
conservation values which are threatened;
c)
genetically modified (GM);
d)
forest management units which have been
harvested illegally;
e)
natural forest that has been converted to
plantations or non-forest.
1.2. Verification was conducted by personnel who have
sufficient expertise and knowledge to be able to fulfil
the inspection in accordance with the requirements.
1.3. For each of the five categories that cannot be
considered low risk, the company shall identify and
provide the rationale for documents and other
evidence needed to demonstrate that wood complies
with the requirements for FSC Controlled Wood for
that specific category.
a)
Illegally harvested wood;
Page 3 of 14
FINDINGS
AD 54-G-01
REQUIREMENT
b)
Wood harvested in violation of traditional and
civil rights;
c)
Wood harvested in forests where high
conservation values are threatened by
management activities;
d)
Wood harvested in forests being converted to
plantations or non- forest use;
e)
Wood from forests in which genetically modified
tress are planted.
Page 4 of 14
FINDINGS
1.4. All documents and other evidence required under
Section B (below) are available for verification by
SGS.
1.5.
1.5.1.
Are verification audits conducted on an annual
basis?
Which documents and evidence were verified
and how are they verified?
How are the authenticity of the specified
documentation and other evidence confirmed?
1.5.2.
The audit process included consultation with:
a)
relevant stakeholders,
b)
staff interviews and
c)
field visits to harvesting sites.
Guidelines:
The stakeholder consultation shall ensure at least the following:
key stakeholders (including potentially marginalized groups e.g. women) have been
identified and invited to participate in the consultation with sufficient prior notice;
the consultation process is open and transparent;
stakeholders have access to necessary information to ensure effective participation in
the consultation process.
a process for recording, evaluating and addressing stakeholders‟ concerns.
AD 54-G-01
Page 5 of 14
List of Stakeholders
Stakeholder & Contact
detail
Stakeholder’s Comments
Supplier’s Comments
List of Staff interviewed
Staff member and post
Topics and Members Comments
Supplier’s Comments
AD 54-G-01
Page 6 of 14
SAMPLING
1.6.
The number of verification audits that took place was determined according to the
sampling specified.
1.7.
The FMUs were classified as sets of „similar‟ units for the purpose of sampling. The
sets were selected to minimize variability within each set.
1.8.
For each set of „similar‟ FMUs the company shall select at least 0.8 times the square
root of the number of units for evaluation per annum.
For sets that consist entirely of FMUs that qualify as Small or Low Intensity Managed
Forests (SLIMFs), the number of units selected shall be at least 0.6 times the square
root of the number of units (y) within that group (i.e. x = 0.6 y), rounded to the upper
whole number.
The table below provides some examples of sampling intensities:
y (total number of FMUs
in set for sampling)
X (sample)=0.8 y
X (sample for sets of
SLIMFS)=0.6 y
1
1
1
2-7
2
1
8-11
3
2
12-24
3
3
25-39
4
3
40-44
5
4
45-56
5
5
n
0.8 n
0.6 n
Set Number:
Forest type (e.g. natural forest,
plantation)
Geographical location (district)
Size of operation (e.g. SLIMF)
Planted Forest in an area of
2000ha. Pinus Elioti, Pinus
Taeda, Araucaria
Angustifólia
To check in audit
2000ha
Sampling justification
according to 1.8 above.
AD 54-G-01
Page 7 of 14
Set Number:
Forest type (e.g. natural forest,
plantation)
Geographical location (district)
Size of operation (e.g. SLIMF)
Sampling justification according to
1.8 above.
REQUIREMENT
1.9.
FINDINGS
Samples for field verification were defined
randomly
To check in audit
1.10.
Verification audits were conducted before the
wood were used in FSC certified mixed products.
To check in audit
1.11.
1.12.
Any consultation with staff and workers shall take
place unaccompanied by management
representatives from the company.
All reports or records of verification audits are
maintained for at least 5 years and include:
a)
the findings of the verification,
b)
the extent to which it was possible to conduct
the verifications in the manner described
above, and
c)
the experience and qualifications of the
personnel conducting the verification.
To check in audit
To check in audit
AD 54-G-01
D
Page 8 of 14
Specific requirements
This part establishes the specific requirements that a company verification program shall
evaluate for compliance in the categories not considered as low risk in its risk assessment.
1.
Illegally harvested wood
NOTE: When looking for documentation in table 1 the company shall verify that legal
procedures have been used by their suppliers to gain permits and licenses.
Guidelines:
The forest management enterprise shall not supply as controlled, wood which has been harvested in
violation of national laws, including the acquisition of the harvesting rights and the harvesting methods
used.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance. Documented evidence shall include but is not restricted to:
concession license and/or harvesting permit (approved by appropriate government authority);
maps and/or documents showing the location of harvesting within the harvesting license or
permit area;
a forest management plan for the forest management unit; maps; documents showing
harvesting volumes and protected areas;
an up-to-date register of all statutes, guidelines and regulations;
sales contracts showing volumes sold;
evidence of payment of royalties;
an up to date list of tree species in the FMU that are listed in Appendices of the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES) and relevant
permits for their harvest and trade.
The company shall ensure that the correct procedures were used to gain permits and licenses
and species harvested are classified correctly.
REQUIREMENTS
1.1. The wood sourced was harvested in compliance with all laws applicable to harvesting in the jurisdiction in accordance with
the requirements outlined in Table 1 below.
a)
Evidence of legal authority to harvest
Answer: The lands where the wood plantations are made for the production of mechanical pulp belong to the company
since 1938.
VERIFICATION / FINDINGS
b)
Evidence of compliance with applicable management planning requirements
Answer: There is forest management plan.
VERIFICATION / FINDINGS
AD 54-G-01
c)
Page 9 of 14
Specification of applicable harvesting restrictions
Answer: The company follows the IN 38 referring to native forest species planted and the company is in process of
adaptation to IN 20 referring to exotic forests planted.
VERIFICATION / FINDINGS /
d)
Evidence that timber is harvested from areas designated to harvesting (e.g. not from protected areas where
harvesting is not allowed)
Answer: The wood planted in the area of 2000 hectares owned by the company is used by the industrial unit. The input
control of wood is done through weighing ticket of trucks in the weighing balance.
VERIFICATION / FINDINGS
e)
Evidence that harvesting rate is within the applicable limits
Answer: To check in audit.
VERIFICATION / FINDINGS
f)
Evidence of timber purchases
Answer: It is not applicable, once all the wood used for the production of mechanical pulp is own. With the reports
of wood cut from the forest unities, entrance of wood in the plant and pulp production, it will be possible to check the evidence of
non-purchase of wood.
VERIFICATION / FINDINGS
g)
Evidence of payment of royalties or other fees (i.e. fees on harvesting rights)
Answer: Not applicable.
VERIFICATION / FINDINGS
h)
Evidence of compliance with applicable CITES requirements
Answer: Not applicable, since all the wood used in the production process is planted.
VERIFICATION / FINDINGS /
i)
Evidence of compliance with timber transportation documents
Answer: The company provides copies of all trade documents (invoice) of mechanical pulp, wood for biomass
and wood. It is not issued document of transport of wood for the industrial unit, once the industrial unit is located inside the
forest ownership. It is issued only the weighing ticket from the weighing balance.
AD 54-G-01
Page 10 of 14
VERIFICATION / FINDINGS /
1.2
The Company shall demonstrate that species and qualities harvested are classified correctly.
Answer: There are three types of classification: Pinus Elioto, Pinus Taeda, Araucária Angustifólia – they are separated
by plots; however, the area is not 100% mapped.
VERIFICATION / FINDINGS
2. Wood harvested in violation of traditional and civil rights
The ILO Declaration on Fundamental Principles and Rights at Work is an expression of
commitment by governments, employers' and workers' organizations to uphold basic
human values - values that are vital to our social and economic lives.
The Declaration covers the following four areas:
Freedom of association and the right to collective bargaining;
The elimination of forced and compulsory labour;
The abolition of child labour, and;
The elimination of discrimination in the workplace.
Guidelines:
The forest management enterprise shall not supply as controlled, wood harvested from forest
management units where there are conflicts relating to long term tenure or use rights to the land and
forest resources by traditional or indigenous peoples groups and/or civil society groups which are of
substantial magnitude; which involve a significant number of interests and for which a resolution
process has not been agreed by the main parties to the dispute.
The forest management enterprise shall make available on request documented evidence to
demonstrate compliance. This shall include but is not restricted to:
documentation1 showing identification of all local communities, traditional and indigenous
peoples in the forest management unit and adjacent area;
documentation showing the forest management enterprises‟ ownership or legal right to
harvest;
documentation2 recording traditional rights as identified by the communities and peoples
groups identified in a) above;
documented evidence3 of consultation with local communities, traditional and indigenous
peoples groups identified in a) above;
documented evidence of the process by which any disputes are being resolved, which has the
broad support of the parties to the dispute, and which outlines an agreed interim process for
addressing the dispute and for the management of the forest area concerned.
1
E.g. maps
E.g. maps
3
E.g. minutes of meetings
2
AD 54-G-01
Page 11 of 14
REQUIREMENTS
2.1.
It was confirmed that there are no conflicts relating to land tenure or land use rights of traditional or indigenous peoples
groups in the FMUs from which it is sourcing wood, which are of substantial magnitude; which involve a significant
number of interests; and for which a resolution process has not been agreed by the main parties to the dispute (See
Section 2.3 below).
Answer: There are no traditional and / or indigenous people in the region of Hachmann properties.
VERIFICATION / FINDINGS
2.2. No evidence of violation of the International Labour Office Fundamental Principles and Rights at Work in the FMU nor of
the International Labour Office Convention 169 on Indigenous and Tribal Peoples were reported or detected?
Answer: There are no traditional and / or indigenous people in the region of Hachmann properties.
VERIFICATION / FINDINGS
2.3. In cases where a resolution process is in place (See Section 2.1 above), documented evidence of the process by which
any disputes are being resolved, which demonstrates the broad support of the parties to the dispute, and which outlines an
agreed interim process for addressing the dispute and for the management of the forest area concerned, are available?
Answer: There are no traditional and / or indigenous people in the region of Hachmann properties.
VERIFICATION / FINDINGS
3.
Wood harvested in forests in which high conservation values are threatened by
management activities
If local conditions or relationship with suppliers do not allow FMU level assessment to
happen, the Company shall demonstrate that forest management activities in the areas
being harvested do not threaten high conservation values in these areas. The decision of
looking at HCV only at the areas being harvested has to be adequately justified. If there is
evidence of threats to HCV elsewhere in the FMU the Company shall assess HCVs at the
FMU level.
Guidelines:
The forest management enterprise shall not supply as controlled, wood which has been
harvested from non FSC-certified forest management units where forest management
activity has the potential to cause irreversible effects on any of the high conservation values
present.
The forest management enterprise shall keep records of and make available on request
documented evidence to demonstrate compliance with Section 4.1 above. Documented
evidence shall include but is not restricted to:
a documented assessment that identifies high conservation values and confirms the
absence of threat to the biological, environmental, social and cultural high
conservation values from forest management activity in the forest management unit;
AD 54-G-01
Page 12 of 14
documented evidence4 of consultation with stakeholders, including NGOs and parties
that are involved with or have an interest in the forest area with respect of social or
environmental aspects to confirm the findings of the assessment;
documented evidence of consultation with representatives and members of
communities and indigenous peoples living in or adjacent to the forest management
unit, to confirm the findings of the assessment.
If the forest enterprise is unsure whether a forest management unit has high conservation
values present, then the precautionary approach shall be adopted and no wood shall be
supplied until the presence of high conservation values has been assessed and appropriate
management can be planned accordingly.
In countries where there is a national definition of high conservation value forests (HCVF) as
part of an FSC accredited or draft FSC national or sub-national standard, then this shall be
used as the basis of the assessment specified in Section 4.2 a) above5.
REQUIREMENTS /
It was confirmed that the forest management activities in the FMU do not threaten high conservation values in accordance
with Section 3.2 below.
Answer: The company will provide details about the forest management in the procedures and, in future, the Forest
Management Plan will contain the existent practices as regard the high values of conservation (being considered in these HCVs
(High Conservation Values) the native areas, permanent preservation areas and legal reserve areas).
VERIFICATION / FINDINGS /
3.2.
Records of evidence to demonstrate compliance with Section 3.1 above are kept for minimum period of 5 years.
Evidence includes but is not restricted to:
a)
records of an assessment (e.g. rapid ecological assessment, environmental or social impact assessment or wildlife
census) appropriate to the size of the FMU and intensity of management to identify the presence of high
conservation values;
b)
evidence6 of consultation with stakeholders, including NGOs and parties that are involved with or have an interest
in the forest area, in relation to identifying HCVs and threats to them, with respect to social or environmental
aspects. Where relevant, the assessment shall include consultation with representatives and members of
communities and indigenous peoples living in or adjacent to the FMU;
c)
a list of the high conservation values thus identified in the FMUs, together with evidence indicating that these high
conservation values are not threatened in the FMUs.
Answer: The company will provide details about the forest management in the procedures and, in future, the Forest
Management Plan will contain the existent practices as regard the high values of conservation (being considered in these HCVs
(High Conservation Values) the native areas, permanent preservation areas and legal reserve areas).
VERIFICATION / FINDINGS
4.
Wood harvested from areas being converted from forests and other wooded
ecosystems to plantations or non-forest uses
4
For example minutes of meetings, letters of invitation, photographs
5 FSC national and regional standards can be obtained from the FSC national contact person. Contact details of national contact persons are available on www.fscoax.org
6
For example minutes of meetings, letters of invitation, photographs
AD 54-G-01
Page 13 of 14
Intent Box: This category is only for wood from natural and semi natural forests that are
being converted to plantations or non-forest uses.
Guidelines:
The forest management enterprise shall not supply as controlled wood which has resulted from the
conversion of natural forest to plantations or non-forest uses, except as permitted by Section 7.3
below.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance with Section 7.1 above. Documented evidence shall include but
is not restricted to:
maps and/or documents showing the location of harvesting within the harvesting license or
permit area;
a forest management plan for the forest management unit.
Community forest areas where conversion is part of a community land use plan endorsed through a
participatory process and which is < 5 % of the forest area, may supply wood which has been
converted from natural forest to non-forest uses as controlled.
The forest management enterprise shall make available on request documented evidence to
demonstrate compliance with Section 7.3 above. Documented evidence shall include but is not
restricted to:
land use plan covering conversion of natural forest to non-forest use;
documented evidence of consultation with representatives and members of communities
endorsing the land-use planning.
REQUIREMENTS
4.1. It was confirmed that all types of natural and semi-natural forests and other wooded ecosystems such as woodlands and
savannahs in the FMUs are not being converted to plantations or non-forest uses in accordance with the requirements
outlined, except as permitted by Section 4.3 below.
Answer: Not applicable, since it refers to a planted area. It is recorded only the obligatory presentation of the mapping of
the area and compliance with the regulatory instructions IN 20 and 38 of Supervisory Environment Agency (FATMA)
VERIFICATION / FINDINGS
4.2. The Company shall keep records of evidence to demonstrate compliance with Section 4.1 above for a minimum period of 5
years.
Answer: OK
VERIFICATION / FINDINGS
4.3.
Forest conversion to plantations or non-forest land uses is not occurring, except in circumstances where conversion:
a)
entails a very limited portion of the forest management unit;
AD 54-G-01
Page 14 of 14
b)
does not occur on high conservation value forest areas; and
c)
will enable clear, substantial, additional, secure long term environmental and social benefits across the forest
management unit.
Answer: Not applicable.
VERIFICATION / FINDINGS /
5.
Wood from forest management units in which genetically modified trees are
planted
Guidelines:
Wood harvested from genetically modified (GM) trees
The forest management enterprises operating in plantations shall not supply as controlled, wood
harvested from GM trees7.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance with Section 5.1 above. Documented evidence shall include but
is not restricted to:
documentation from national regulatory bodies confirming the locations and species of GM
tree trials within the forest area;
a statement signed by the senior executive that the forest management enterprise does not
supply wood from GM trees.
REQUIREMENTS
5.1.
No genetically modified trees are present in the FMUs from which it sources FSC Controlled Wood
VERIFICATION / FINDINGS
Not applicable.
5.2.
Procedures are available to ensure that the records of evidence to demonstrate compliance with Section 5.1 above is
kept for a minimum period of 5 years.
VERIFICATION / FINDINGS
Not applicable.
End of report
7 Note, t
his provision does not exclude traditional tree-breeding programmes.
SGS QUALIFOR
(Associated Documents)
Doc. Number:
Doc. Version date:
AD 54-G-01
01 September 2008
Page:
1 of 16
REQUIREMENTS FOR COMPANY FMU VERIFICATION PROGRAM
(Based on Annex 3 of FSC-STD-40-005 V2-1 - Company Evaluation of Controlled
Wood)
INTRODUCTION
Requirements for company verification program
There are 3 options for avoiding the purchase of wood from “unacceptable sources”:
1. Buying FSC certified material.
2. Buying FSC Controlled Wood (from a COC certified company that are certified to sell
FSC controlled wood)
3. Include wood material in the company‟s own verification program. (“self controlled
wood”)
Companies implementing an FSC Controlled Wood verification program sourcing from areas
that cannot be classified as low risk shall ensure that it is in compliance with the
requirements specified below. This must be done for each FMU from an unspecified risk
district.
NOTE: The Company can choose to develop its own verification program or authorize
another organization to do it.
As part of a verification program the (potential) district(s) of origin (where the company is
planning to buy wood from), must be determined and a documented and systematic risk
assessment performed for each district of origin (Annex 2 of FSC-STD-40-005: refer SGS
Qualifor Reference Document 16 and AD54-F).
If a district cannot be considered “low risk” for any of the “unacceptable sources” (“controlled
wood categories”) FSC requires you to carry out on-site audits at the level of the forest
management unit (FMU). The results of this audit process will be reviewed by SGS and the
company shall ensure that the required documents and other evidence as required under
Section D (below) are available for verification by SGS.
Reports or records of verification audits shall be accessible to SGS and FSC-authorized
personnel on request.
This document can be used to do the on-site audit to ensure that the requirements from FSC
are followed.
NOTE: The Company may develop alternative measures in its verification program to ensure
the compliance with the intent of this standard, which is, to avoid wood coming from the five
categories.
Any findings against these requirements will lead to the disqualification of the
supplier and the wood may not be used in an FSC certified Mixed products.
SGS South Africa (Qualifor Programme)
Systems and Services Certification Division
58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South Africa
t +27 11 681-2500
681
f +27 11 681-2543
www.sgs.com
www.sgs.com/forestry
AD 54-G-01
A
Page 2 of 16
CERTIFIED COMPANY DETAIL
Company Name:
MD Papeis Ltda
Certificate Number
SGS-COC- Non-applicable
Controlled Wood Certificate Number
SGS-CW- Non-applicable
Country:
Brasil
Company Address
Physical Address:
Postal Address:
Rodovia: Presidente Tancredo
de Almeida Neves km 34
Caieiras –SP
Contact detail:
B
Contact person:
Júlio César Tomás Alves
Telephone:
(11) 4441-7850
Fax:
(11) 4441-7800
e-mail Address
[email protected]
Assessment done by:
Rodrigo Vaz Domingues
Relation to the company:
Environment Coordinator
Date:
13/11/2008
Signature
Rodrigo Vaz Domingues
SUPPLIER DETAIL
Company Name:
Celulosa Arauco y Constitución
Country:
Chile
Company Address
Physical Address: Avda El Golf 150
Type of source e.g. natural forest
or plantations and general
description of the supplier
Arauco Forest, Forestal Celco , Forestal Cholguán and Forestal
Valdivian
Summary of Results
AD 54-G-01
Categories
Page 3 of 16
Motivation
(Low or
unspecified)
It was not found in the mentioned websites for
searching, any information about this question.
Unspecified
Wood harvested in violation of
traditional and civil rights;
In the website of OIT Chile there is information
that it meets all OIT regulations.
Low
Wood harvested in forests where high
conservation values are threatened by
management activities;
Arauco ensures that in the pulp plant there is the
custody chain system which assures the nonuse of trees illegally harvested, as well as the
use of species threatened with extinction.
Low
Illegally harvested wood;
And, according to the newsletter website, we
could verify that 80% of the Chilean forests have
CERTIFOR certificate.
Wood harvested in forests being
converted to plantations or non- forest
use;
Wood from forests in which genetically
modified tress are planted.
In the worldwildlife website it was found
information that shows the wood harvesting and
conversion of the habitat in pine and eucalyptus
plantation.
High
At Arauco website it was not identified the origin
(district/forest) of wood used in the production.
This information is to be raised during the audit.
Unspecified
According to ecobloque website the species
genetically modified are being studied, once the
genetic manipulation has already shown serious
social-environment impacts.
It was not found any comments about the need
of licenses for marketing and use of genetically
modified trees.
It was not found any evidence of prohibition of
the use of genetically modified trees in Chile.
AD 54-G-01
C
General requirements
1.
Company verification program
REQUIREMENT
1.1. Is evidence available to confirm that wood/fibre
coming from a particular supplier has been controlled
for the category or categories of wood:
a)
forest areas where traditional or civil rights are
violated by forest management activities;
b)
forest management units having high
conservation values which are threatened;
c)
genetically modified (GM);
d)
forest management units which have been
harvested illegally;
e)
natural forest that has been converted to
plantations or non-forest.
1.2.
Verification was conducted by personnel who have
sufficient expertise and knowledge to be able to
fulfil the inspection in accordance with the
requirements.
Page 4 of 16
FINDINGS
Confirm that all requirements as indicated in the Annex
3 of FSC-STD-40-005 have been covered during the
on-site visit.
Person‟s Name:
Motivate why the person qualified to do the inspection
e.g. forestry training, training in FSC systems, auditor
training.
If the inspection was conducted by an FSC Accredited
CB, prove detail
1.3.
For each of the five categories that cannot be
considered low risk, the company shall identify and
provide the rationale for documents and other
evidence needed to demonstrate that wood
complies with the requirements for FSC Controlled
Wood for that specific category.
a)
For each of the five points listed below you need to
indicate what documents you used to confirm that the
specific point is low risk.
Illegally harvested wood;
b) Wood harvested in violation of traditional and
civil rights;
c) Wood harvested in forests where high
conservation values are threatened by management
activities;
d) Wood harvested in forests being converted to
plantations or non- forest use;
e) Wood from forests in which genetically modified
tress are planted.
1.4.
1.5.
All documents and other evidence required under
Section B (below) are available for verification by
SGS.
Indicate who will maintain the documents.
Are verification audits conducted on an annual
basis?
The company shall specify and implement a regular (at least
annual) verification audit process
AD 54-G-01
REQUIREMENT
1.5.1.
Page 5 of 16
FINDINGS
Which documents and evidence were verified
and how are they verified?
How are the authenticity of the specified
documentation and other evidence confirmed?
1.5.2.
The audit process included consultation with:
a)
relevant stakeholders,
b)
staff interviews and
c)
field visits to harvesting sites.
Please list the stake holders detail below.
List the staff interviewed below.
List the sampling under the “Sampling Section” below.
Guidelines:
The stakeholder consultation shall ensure at least the following:
key stakeholders (including potentially marginalized groups e.g. women) have been
identified and invited to participate in the consultation with sufficient prior notice;
the consultation process is open and transparent;
stakeholders have access to necessary information to ensure effective participation in
the consultation process.
a process for recording, evaluating and addressing stakeholders‟ concerns.
List of Stakeholders
Stakeholder & Contact
detail
Stakeholder’s Comments
Supplier’s Comments
List of Staff interviewed
Staff member and post
Topics and Members Comments
Supplier’s Comments
AD 54-G-01
Page 6 of 16
SAMPLING
1.6.
The number of verification audits that took place was determined according to the
sampling specified.
1.7.
The FMUs were classified as sets of „similar‟ units for the purpose of sampling. The
sets were selected to minimize variability within each set.
1.8.
For each set of „similar‟ FMUs the company shall select at least 0.8 times the square
root of the number of units for evaluation per annum.
For sets that consist entirely of FMUs that qualify as Small or Low Intensity Managed
Forests (SLIMFs), the number of units selected shall be at least 0.6 times the square
root of the number of units (y) within that group (i.e. x = 0.6 y), rounded to the upper
whole number.
The table below provides some examples of sampling intensities:
y (total number of FMUs
in set for sampling)
X (sample)=0.8 y
X (sample for sets of
SLIMFS)=0.6 y
1
1
1
2-7
2
1
8-11
3
2
12-24
3
3
25-39
4
3
40-44
5
4
45-56
5
5
n
0.8 n
0.6 n
Set Number:
Forest type (e.g. natural forest,
plantation)
Geographical location (district)
Size of operation (e.g. SLIMF)
Sampling justification
according to 1.8 above.
Indicate how many of the FMUs were audited and why.
AD 54-G-01
Page 7 of 16
Set Number:
Forest type (e.g. natural forest,
plantation)
Geographical location (district)
Size of operation (e.g. SLIMF)
Sampling justification according to
1.8 above.
Indicate how many of the FMUs were audited and why.
Note: More lines or more sets can be added as required.
REQUIREMENT
1.9.
FINDINGS
Samples for field verification were defined
randomly
Confirm that the audits were conducted randomly
1.10.
Verification audits were conducted before the
wood were used in FSC certified mixed products.
1.11.
Any consultation with staff and workers shall take
place unaccompanied by management
representatives from the company.
1.12.
Whom did you speak to and what was the situation
All reports or records of verification audits are
maintained for at least 5 years and include:
a)
the findings of the verification,
b)
the extent to which it was possible to conduct
the verifications in the manner described
above, and
c)
the experience and qualifications of the
personnel conducting the verification.
Indicate that procedures are available and who is
responsible for these records.
AD 54-G-01
D
Page 8 of 16
Specific requirements
This part establishes the specific requirements that a company verification program shall
evaluate for compliance in the categories not considered as low risk in its risk assessment.
1.
Illegally harvested wood
NOTE: When looking for documentation in table 1 the company shall verify that legal
procedures have been used by their suppliers to gain permits and licenses.
Guidelines:
The forest management enterprise shall not supply as controlled, wood which has been harvested in
violation of national laws, including the acquisition of the harvesting rights and the harvesting methods
used.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance. Documented evidence shall include but is not restricted to:
concession license and/or harvesting permit (approved by appropriate government authority);
maps and/or documents showing the location of harvesting within the harvesting license or
permit area;
a forest management plan for the forest management unit; maps; documents showing
harvesting volumes and protected areas;
an up-to-date register of all statutes, guidelines and regulations;
sales contracts showing volumes sold;
evidence of payment of royalties;
an up to date list of tree species in the FMU that are listed in Appendices of the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES) and relevant
permits for their harvest and trade.
The company shall ensure that the correct procedures were used to gain permits and licences
and species harvested are classified correctly.
REQUIREMENTS
1.1.
The wood sourced was harvested in compliance with all laws applicable to harvesting in the jurisdiction in accordance
with the requirements outlined in Table 1 below.
a)
Evidence of legal authority to harvest
VERIFICATION / FINDINGS
WWW.arauco.cl WWW.wrm.org.uy WWW.transparency.org WWW.eia.international.org
WWW.panda.org WWW.eldis.org WWW.cites.org
It was not found documents that demonstrate the compliance with the legislation
Arauco informs on its website that the pulp plants from Chile have custody chain system, which ensures the
tracking of product in each stage of the process and allows verification of original source of raw material
supplying; consequently, ensuring that the raw-material used does not come from endangered species or illegal
harvest.
b)
Evidence of compliance with applicable management planning requirements
VERIFICATION / FINDINGS
AD 54-G-01
Page 9 of 16
As previously mentioned Arauco ensures that there is the custody chain system in the pulp plant, ensuring the
non-use of illegally harvested trees, as well as the use of endangered species.
And, according to the newsletter website, we verified that 80% of the Chilean forests have CERTIFOR certificate.
Note: During the audit, it should be verified the origin of all wood used in this plant as well as the certificates and
forest licenses.
c)
Specification of applicable harvesting restrictions
VERIFICATION / FINDINGS
As previously mentioned Arauco ensures that there is the custody chain system in the pulp plant, ensuring the
non-use of illegally harvested trees, as well as the use of endangered species.
And, according to the newsletter website, we verified that 80% of the Chilean forests have CERTIFOR certificate.
Note: During the audit, it should be verified the origin of all wood used in this plant as well as the certificates and
forest licenses.
d)
Evidence that timber is harvested from areas designated to harvesting (e.g. not from protected areas where
harvesting is not allowed)
VERIFICATION / FINDINGS
Arauco informs on its website that the pulp plants from Chile have custody chain system, which ensures the
tracking of product in each stage of the process and allows verification of original source of raw material
supplying; consequently, ensuring that the raw-material used does not come from endangered species or illegal
harvest.
e)
Evidence that harvesting rate is within the applicable limits
VERIFICATION / FINDINGS
I was not found in the mentioned websites for searching any information about this question.
f)
Evidence of timber purchases
VERIFICATION / FINDINGS
During the audit, it should be verified the origin of all wood used in this plant as well as the certificates and forest
licenses.
g)
Evidence of payment of royalties or other fees (i.e. fees on harvesting rights)
VERIFICATION / FINDINGS
During the audit, it should be verified the origin of all wood used in this plant as well as the certificates and forest
licenses.
h)
Evidence of compliance with applicable CITES requirements
VERIFICATION / FINDINGS
WWW.arauco.cl
Arauco informs on its website that the pulp plants from Chile have custody chain system, which ensures the
tracking of product in each stage of the process and allows verification of original source of raw material
supplying; consequently, ensuring that the raw-material used does not come from endangered species or illegal
harvest.
AD 54-G-01
i)
Page 10 of 16
Evidence of compliance with timber transportation documents
VERIFICATION / FINDINGS
To verify transport documentation during the audit.
1.2
The Company shall demonstrate that species and qualities harvested are classified correctly.
VERIFICATION / FINDINGS
I was not found in the mentioned websites for searching any information about this question.
2.
Wood harvested in violation of traditional and civil rights
The ILO Declaration on Fundamental Principles and Rights at Work is an expression of
commitment by governments, employers' and workers' organizations to uphold basic
human values - values that are vital to our social and economic lives.
The Declaration covers the following four areas:
Freedom of association and the right to collective bargaining;
The elimination of forced and compulsory labour;
The abolition of child labour, and;
The elimination of discrimination in the workplace.
Guidelines:
The forest management enterprise shall not supply as controlled, wood harvested from forest
management units where there are conflicts relating to long term tenure or use rights to the land and
forest resources by traditional or indigenous peoples groups and/or civil society groups which are of
substantial magnitude; which involve a significant number of interests and for which a resolution
process has not been agreed by the main parties to the dispute.
The forest management enterprise shall make available on request documented evidence to
demonstrate compliance. This shall include but is not restricted to:
documentation1 showing identification of all local communities, traditional and indigenous
peoples in the forest management unit and adjacent area;
documentation showing the forest management enterprises‟ ownership or legal right to
harvest;
documentation2 recording traditional rights as identified by the communities and peoples
groups identified in a) above;
documented evidence3 of consultation with local communities, traditional and indigenous
peoples groups identified in a) above;
documented evidence of the process by which any disputes are being resolved, which has the
broad support of the parties to the dispute, and which outlines an agreed interim process for
addressing the dispute and for the management of the forest area concerned.
REQUIREMENTS
1
E.g. maps
E.g. maps
3
E.g. minutes of meetings
2
AD 54-G-01
2.1.
Page 11 of 16
It was confirmed that there are no conflicts relating to land tenure or land use rights of traditional or indigenous peoples
groups in the FMUs from which it is sourcing wood, which are of substantial magnitude; which involve a significant
number of interests; and for which a resolution process has not been agreed by the main parties to the dispute (See
Section 2.3 below).
VERIFICATION / FINDINGS
1) In the website there is no mention of countries of conflict zone.
Note: To check information during audit.
2) In the OIT Chile website there is information that they follow the OIT regulations.
In the FSC Chile website became clear that for areas with FSC certification all the OIT regulations are complied
with.
3) In the un.org website it was not verified any restriction as regard the export of wood from Chile.
www.un.org
www.naturalresources.org
www.usaid.gov/hum_response/oti/
www.fsc-chile.org
www.oitchile.cl
2.2.
No evidence of violation of the International Labour Office Fundamental Principles and Rights at Work in the FMU nor of
the International Labour Office Convention 169 on Indigenous and Tribal Peoples were reported or detected?
VERIFICATION / FINDINGS
According to search at OIT website, it was not found any evidence of violation of OIT Convention 169.
www.fsc-chile.org
www.oitchile.cl
2.3.
In cases where a resolution process is in place (See Section 2.1 above), documented evidence of the process by which
any disputes are being resolved, which demonstrates the broad support of the parties to the dispute, and which outlines
an agreed interim process for addressing the dispute and for the management of the forest area concerned, are
available?
VERIFICATION / FINDINGS
It was not found any comments of conflict in this area.
In December 2007, WWF launched a program with indigenous association which helps to preserve the
environment and indigenous communities through the sustainable development.
www.fsc-chile.org
www.worldwildlife.org
3.
Wood harvested in forests in which high conservation values are threatened by
management activities
If local conditions or relationship with suppliers do not allow FMU level assessment to
happen, the Company shall demonstrate that forest management activities in the areas
being harvested do not threaten high conservation values in these areas. The decision of
looking at HCV only at the areas being harvested has to be adequately justified. If there is
evidence of threats to HCV elsewhere in the FMU the Company shall assess HCVs at the
FMU level.
AD 54-G-01
Page 12 of 16
Guidelines:
The forest management enterprise shall not supply as controlled, wood which has been
harvested from non FSC-certified forest management units where forest management
activity has the potential to cause irreversible effects on any of the high conservation values
present.
The forest management enterprise shall keep records of and make available on request
documented evidence to demonstrate compliance with Section 4.1 above. Documented
evidence shall include but is not restricted to:
a documented assessment that identifies high conservation values and confirms the
absence of threat to the biological, environmental, social and cultural high
conservation values from forest management activity in the forest management unit;
documented evidence4 of consultation with stakeholders, including NGOs and parties
that are involved with or have an interest in the forest area with respect of social or
environmental aspects to confirm the findings of the assessment;
documented evidence of consultation with representatives and members of
communities and indigenous peoples living in or adjacent to the forest management
unit, to confirm the findings of the assessment.
If the forest enterprise is unsure whether a forest management unit has high conservation
values present, then the precautionary approach shall be adopted and no wood shall be
supplied until the presence of high conservation values has been assessed and appropriate
management can be planned accordingly.
In countries where there is a national definition of high conservation value forests (HCVF) as
part of an FSC accredited or draft FSC national or sub-national standard, then this shall be
used as the basis of the assessment specified in Section 4.2 a) above5.
REQUIREMENTS
3.1.
It was confirmed that the forest management activities in the FMU do not threaten high conservation values in
accordance with Section 3.2 below.
VERIFICATION / FINDINGS
In the worldwildlife was found information that evidences the wood harvesting and conversion of habitat in pine
and eucalypt plantations.
www..worldwildlife.org/what/wherewework/southernchile e www.intacforests.org/statistics/samerica.htm
4
For example minutes of meetings, letters of invitation, photographs
5 FSC national and regional standards can be obtained from the FSC national contact person. Contact details of national contact persons are available on www.fscoax.org
AD 54-G-01
3.2.
Page 13 of 16
Records of evidence to demonstrate compliance with Section 3.1 above are kept for minimum period of 5 years.
Evidence includes but is not restricted to:
a)
records of an assessment (e.g. rapid ecological assessment, environmental or social impact assessment or wildlife
census) appropriate to the size of the FMU and intensity of management to identify the presence of high
conservation values;
b)
evidence6 of consultation with stakeholders, including NGOs and parties that are involved with or have an interest
in the forest area, in relation to identifying HCVs and threats to them, with respect to social or environmental
aspects. Where relevant, the assessment shall include consultation with representatives and members of
communities and indigenous peoples living in or adjacent to the FMU;
c)
a list of the high conservation values thus identified in the FMUs, together with evidence indicating that these high
conservation values are not threatened in the FMUs.
VERIFICATION / FINDINGS
In the mentioned websites were found evidences that WWF is supporting the creation of new public and private
protected areas as well as the sustainable use of native forests.
www.worldwildlife.org/what/wherewework/southernchile e WWW.avina.net
6
For example minutes of meetings, letters of invitation, photographs
AD 54-G-01
4.
Page 14 of 16
Wood harvested from areas being converted from forests and other wooded
ecosystems to plantations or non-forest uses
Intent Box: This category is only for wood from natural and semi natural forests that are
being converted to plantations or non-forest uses.
Guidelines:
The forest management enterprise shall not supply as controlled wood which has resulted from the
conversion of natural forest to plantations or non-forest uses, except as permitted by Section 7.3
below.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance with Section 7.1 above. Documented evidence shall include but
is not restricted to:
maps and/or documents showing the location of harvesting within the harvesting license or
permit area;
a forest management plan for the forest management unit.
Community forest areas where conversion is part of a community land use plan endorsed through a
participatory process and which is < 5 % of the forest area, may supply wood which has been
converted from natural forest to non-forest uses as controlled.
The forest management enterprise shall make available on request documented evidence to
demonstrate compliance with Section 7.3 above. Documented evidence shall include but is not
restricted to:
land use plan covering conversion of natural forest to non-forest use;
documented evidence of consultation with representatives and members of communities
endorsing the land-use planning.
REQUIREMENTS
4.1.
It was confirmed that all types of natural and semi-natural forests and other wooded ecosystems such as woodlands
and savannahs in the FMUs are not being converted to plantations or non-forest uses in accordance with the
requirements outlined, except as permitted by Section 4.3 below.
VERIFICATION / FINDINGS
In the websites searched were found evidences that there are irregular cut of wood. However, it was not specified
the rate of annual loss of these forests.
www.worldwildlife.org/what/wherewework/southernchile.org
4.2.
The Company shall keep records of evidence to demonstrate compliance with Section 4.1 above for a minimum period
of 5 years.
VERIFICATION / FINDINGS
4.3.
Forest conversion to plantations or non-forest land uses is not occurring, except in circumstances where conversion:
a)
entails a very limited portion of the forest management unit;
b)
does not occur on high conservation value forest areas; and
c)
will enable clear, substantial, additional, secure long term environmental and social benefits across the forest
management unit.
AD 54-G-01
Page 15 of 16
VERIFICATION / FINDINGS
5.
Wood from forest management units in which genetically modified trees are
planted
Guidelines:
Wood harvested from genetically modified (GM) trees
The forest management enterprises operating in plantations shall not supply as controlled, wood
harvested from GM trees7.
The forest management enterprise shall keep records of and make available on request documented
evidence to demonstrate compliance with Section 5.1 above. Documented evidence shall include but
is not restricted to:
documentation from national regulatory bodies confirming the locations and species of GM
tree trials within the forest area;
a statement signed by the senior executive that the forest management enterprise does not
supply wood from GM trees.
REQUIREMENTS
5.1.
No genetically modified trees are present in the FMUs from which it sources FSC Controlled Wood
VERIFICATION / FINDINGS
At Arauco website it was not identified the origin (district/forest) of wood used in the production. This information
is to be raised during the audit.
According to ecobloque website the species genetically modified are being studied, once the genetic manipulation
has already shown serious social-environment impacts.
It was not found any comments about the need of licenses for marketing and use of genetically modified trees.
It was not found any evidence of prohibition of the use of genetically modified trees in Chile.
FAO, 2004. Revisão preliminar de biotecnologia de florestamento, incluindo modificação genética. Jornal a
Serviço dos Recursos Genéticos Florestais FGR/59E. (FAO, 2004. Preliminary revision of biotechnology in
forestry, including genetic modification. Newspaper at service of Forest Genetic Resources.)
http://www.fao.org/docrep/008/ae574e/AE574E00.HTM
http://www.ecoblogue.net
http://www.rauco.cl
5.2.
Procedures are available to ensure that the records of evidence to demonstrate compliance with Section 5.1 abov e is
kept for a minimum period of 5 years.
VERIFICATION / FINDINGS
7 Note, t
his provision does not exclude traditional tree-breeding programmes.
AD 54-G-01
Page 16 of 16
End of report
Programa de avaliação de fornecedor de Madeira controlada
MD Papéis Ltda
www.omniaonline.com.br
11 3675-5253
Descrição do fornecedor
O fornecedor, empresa Melhoramentos Papeis fornece Pasta celulósica CTMP
(Chemical Thermical Mechanical Pulp). A pasta celulósica por sua vez é produzida a partir
de madeira de reflorestamento da espécie Eucalyptus. O principal fornecedor de madeira
de eucalipto é a unidade de manejo florestal pertencente à empresa Melhoramentos
Florestal S.A.
Entretanto, durante a auditoria foi verificado que a Melhoramentos Papéis possuem
outros três fornecedores de madeira que não está sendo contemplados pela avaliação de
risco conduzida nessa avaliação de risco de madeira controlada (Pilar do Sul/Ouro
Grandis; Santa Marina – Unidade de Bragança Paulista e Salesópolis).
Para avaliação de risco, apenas as empresas Melhoramentos Papeis e
Melhoramentos Florestal S.A. foram auditadas.
OBS: A empresa Melhoramentos Papeis é de propriedade do grupo chileno CMPCCompanhia Manufatureira de Papel e Celulose.
Unidade de manejo Florestal
O imóvel denominado de Fazenda Florestal (CNPJ/MF nº 60.730.348/0001-66) é
composto pelos imóveis de propriedade da Companhia Melhoramentos de São Paulo
(CMSP). As Glebas que compõem a Fazenda Florestal auditada foram compreendidas na
Unidade Caieiras que estão localizadas nos municípios de Caieiras, Cajamar, Franco da
Rocha e São Paulo, com área total de 5.323,9951 ha, segundo levantamento planimétrico
encomendado pela CMSP.
OBS: Segundo informação do plano de manejo possui uma área total de 5.102,02
ha incluindo áreas de plantio, vegetação nativa, represas e benfeitorias.
www.omniaonline.com.br
11 3675-5253
Amostragem
A auditoria no fornecedor foi realizada no período de 05 e 06/11/2009. A
metodologia utilizada foi baseada no anexo 3 do FSC-STD-40-005 V2.1 (Requerimentos
para avaliação de fornecedor pela empresa).
A revisão de documentos, realizada por amostragem, incluiu documentação legal
relativa a requerimentos florestais, saúde e segurança, trabalhistas, previdenciários etc.
Foram realizadas entrevistas com os diretores, funcionários próprios e de empresa
prestadora de serviço. A auditoria de campo (unidade de manejo Florestal) e na unidade
da fábrica foi acompanhada por um representante da empresa.
Qualificação do auditor
Rosilene Einloft – Engenheira Floresta, Doutora em solos e Nutrição de plantas, 15 anos
de experiência profissional em área ambiental. Auditora Líder de Manejo florestal e
Cadeia de custódia, 3,5 anos de experiência em programa de certificação florestal FSC e
CERFLOR.
www.omniaonline.com.br
11 3675-5253
Requerimento 1- “Madeira colhida ilegalmente”
Evidência de autoridade legal para a colheita
A Melhoramentos planta a espécie Eucalyptus. De acordo com o Artigo 12 da Lei
nº 4.771, de 15 de setembro de 1965, as florestas plantadas, não consideradas de
preservação permanente é livre a extração. Não é exigida licença especifica para corte
nessas áreas.
A legislação do estado de São Paulo não prevê o licenciamento ambiental da
Floresta. O manejo florestal deve ser realizado atendendo ao código florestal (Lei
4771/1965).
Licenciamento Ambiental da Fábrica
Processo n 29/00144/90, Número 29002789 v.1 data de 04/10/07 validade de 04/10/09.
Verificado protocolo de renovação “Solicitação de renovação de licença de operação”
processo 24014344 em 14/07/09 enviada a CETESB.
CNEM Conselho Nacional de energia Nuclear - autorização para instalação radiativa –
operação de medidores nucleares fixos (Cs). Validade 02/03/2010. Oficio n 0831/2007
(Sisdoc 4403 de 27/03/07).
ART- Certificado de anotação de responsabilidade técnica validade 31/03/2010. Numero
1530/09. Profissional Cláudio Antonio Junior (Engenheiro químico – registro 04361148).
Cadastro técnico federal “certificado de regularidade” numero do cadastro 4605885,
validade 27/11/09. Cadastro de atividades poluidoras emitido pelo IBAMA.
www.omniaonline.com.br
11 3675-5253
Protocolo de requerimento de autorga de (barramento, captação, lançamento e travessia)
junto ao DAEE- departamento de águas e energias elétrica . protocolo numero 678/2009.
recebido em 14/07/09.
Averbação de Reserva Legal
Foram apresentados mapas de caracterização da vegetação localizando reserva
legal e áreas de APP.
A empresa não possui averbação de reserva legal. Foi apresentado “Proposta
técnica para a definição das áreas destinadas a reserva legal da CIA Melhoramentos”
datado de 28/11/2008. Proposta enviada ao DPRN - departamento de proteção de
recursos naturais (processo 18891/2008 junto ao DPRN).
Status atual da averbação de Reserva Legal: A CETESB enviou a Melhoramentos em
03/07/09 correspondência solicitando o levantamento das eventuais APP de topo de
morro, linhas cumeadas conforme especificação CONAMA 396/06 e a adequação da
proposta de averbação, APP de topo de morro caso haja.
Em 22/10/2009 enviou correspondência a CETESB pedido prorrogação do prazo.
Evidência de conformidade com plano de manejo
A Melhoramentos possui plano de manejo florestal elaborado por profissional
competente: Engenheiro André Luis dos Santos. CREA/73298 PR/D.
O documento traz informações sobre a propriedade, objetivo do manejo,
localização das áreas e uso do solo, descrição das atividades silviculturais, manejo e
dados de inventário florestal, colheita e transporte de madeira.
Especificações para restrições a colheita
A empresa não maneja mata nativa. Dessa forma, não existem restrições para
diâmetro de corte. O plano de manejo elaborado possui inventário florestal que estima
volume por meio de cubagem rigorosa. O modelo utilizado para a estimativa de volume é
o de Schumacher e Hall.
www.omniaonline.com.br
11 3675-5253
Evidência de que a colheita não ocorre em áreas de preservação
Foi apresentado um mapa da unidade de manejo florestal contendo localização dos
talhões de plantio assim como as áreas de reserva legal e áreas de preservação
permanente. A madeira utilizada na confecção da pasta celulósica é proveniente de
plantios florestais.
Áreas de plantio foram visitadas durante a auditoria. Na atividade de colheita foram
verificadas áreas de reserva e áreas de preservação permanente intactas.
Evidência de que as taxas de colheita encontra-se em um limite aceitável.
A empresa não maneja mata nativa. Dessa forma, não existem restrições quanta a
taxa colhida. Os volumes colhidos são definidos pelo inventário florestal. Verificado
valores estimados no plano de manejo. Os valores definidos são coerentes ao encontrado
em outros inventários para áreas de plantio da espécie Eucalyptus no Brasil.
Verificado por meio de entrevistas que a Melhoramentos possui equipe de
profissionais qualificados para o manejo de suas áreas de plantio florestal.
Evidência da aquisição de madeira
A empresa produz a pasta celulósica proveniente da espécie Eucalyptus. A fábrica
de pasta celulósica está localizada dentro da unidade de manejo florestal da empresa
Melhoramentos Florestal S.A.
Durante a auditoria foi visitada a portaria onde ocorre a recepção de toda a matéria
prima florestal.
A madeira proveniente da própria UMF segue para a fábrica acompanhada por
nota fiscal de transporte. Verificado no setor de recepção de matéria prima “CBI Controle
de Baldeio interno” CBI 8062 (05/11/09), CBI 8095 (06/11/09) e CBI 8080 (05/11/09)
referenciando local, ano de plantio, talhão etc.
www.omniaonline.com.br
11 3675-5253
Foi verificado que a Melhoramentos Papéis possuem outros três fornecedores de
madeira que não estão sendo contemplados pela avaliação de risco conduzida nessa
avaliação (Pilar do Sul/Ouro Grandis; Santa Marina – Unidade de Bragança Paulista e
Salesópolis).
Após o recebimento de madeira, essa é segregada por fornecedor no pátio. Ao ser
enviada para dar entrada no picador, o responsável pela central de produção se comunica
com o responsável pelo pátio para o registro da origem da matéria prima utilizada.
Entretanto, foi verificada falha na rastreabilidade de uma remessa Nº 019530-5 de
14/10/09. O checklist de abastecimento da esteira que alimenta o silo coloca como
matéria prima utilizada: Caieiras e Santa Marina e o livro de bordo na produção registrou
Caieiras e Pilar do Sul.
Evidência de pagamento de taxas, royalties entre outros
Foram apresentadas certidões negativas para as principais taxas e impostas
aplicáveis à empresa.
Certidão Nº 2087265, data de 11/09/09. Nada consta em pedido de concordata,
falência, recuperações judiciais e extrajudiciais no período de 10 anos anteriores a
04/09/09.
Certificado de regularidade do FGTS – CRF – situação regular atestada pela Caixa
econômica federal em 08/09/09 a 07/10/09.
Nada consta de tributos federais e a divida ativa da união validade de 20/12/09.
Evidência de conformidade com os requerimentos da CITES
Não se aplica. A empresa não maneja espécies nativas.
Evidência de conformidade com documentos de transportes
Foram verificadas por amostragem: notas fiscais de expedição do produto acabado
www.omniaonline.com.br
11 3675-5253
(pasta celulósica): DANFE 000.008.763 serie 1, datado de 28/10/09 e DANFE
000.007.127 serie 1, datado de 19/10/09, informando dados sobre o fornecedor, cliente,
descrição e quantidade do produto.
Verificado em campo na atividade de colheita de madeira, a nota de transporte
interna “CBI Controle de Baldeio interno” CBI 8062 (05/11/09), CBI 8095 (06/11/09) e CBI
8080 (05/11/09) refereciando local, ano de plantio, talhão etc.
Requerimento 2- “Colheita de madeira violando direitos civis e tradicionais”.
Conflitos relacionados a títulos de terras ou direitos tradicionais ou indígenas.
Foram apresentados mapas relativo a situação fundiária indígena no Estado de
São Paulo. Consultas ao site da FUNAI (www.funai.gov.br/mapas/fundirio/sp/fun_sp.htm)
em 05/11/09. Não há evidências da presença de terra indígena na área de propriedade da
empresa Melhoramentos.
Apresentado
também
mapeamento
das
comunidades
quilombolas
reconhecidas e tituladas e comunidades apontadas para o reconhecimento. Não há
evidências da presença de comunidades quilombolas na área de propriedade da empresa
Melhoramentos. Site: http://ocarete.org.br/wp-content/uploads/2009/02/mapa-quilombosp.gif
Propriedade/Posse do empreendimento
A Fazenda Florestal é compreendida por 24 glebas, adquiridas pela CMSP em
diferentes títulos, alguns há mais de cento e dez anos.
Durante a auditoria foi fornecido um memorando com a relação de todos os títulos
de aquisição de terra por parte da CMSP.
A empresa Melhoramentos Florestal S.A atua no manejo das áreas da Fazenda
Florestal sob a condição de arrendatário. Entretanto, não foi apresentado durante a
auditoria o contrato de arrendamento entre a Empresa CMSP e a Melhoramentos
www.omniaonline.com.br
11 3675-5253
Florestal S.A.
A Melhoramentos possui apoio da empresa “Letícia Gerard Tavares” para
pendências jurídicas. Não foi apresentada pela empresa Melhoramentos sobre
pendências jurídicas com relação a disputas por posse de terra.
Violação de direitos segundo a ILO.
A Melhoramentos Florestal possui 516 funcionários próprios sendo 7 funcionários
aprendizes e 164 funcionários de prestadores de serviço distribuídos entre as atividades
de restaurante, portaria, limpeza, manutenção florestal e logística.
Verificado a existência de um sistema informatizado com os dados cadastrais dos
funcionários. Além disso, todos os funcionários possuem em um arquivo físico onde
consta a documentação comprobatória.
A Melhoramentos detém informações sobre o cadastro, pagamento de salário
(incluindo encargos, recolhimentos, etc), aspectos sobre saúde e segurança para os
funcionários das empresas prestadoras de serviços. Existe um contrato estabelecido com
as prestadoras de serviço estabelecendo clausulas da documentação que deve ser
enviada mensalmente e periodicamente.
A empresa não possui uma política de contratação escrita. Para cada cargo existe
um mapa de competência incluindo conhecimento, criatividade e treinamento. Em
entrevistas no campo, não foram evidenciadas quaisquer discriminações no momento da
contratação.
Não
foi
verificado
no
sistema
informatizado
tampouco
em
entrevistas,
trabalhadores menores de 18 anos. A exceção fica pela existência de 7 aprendizes.
Verificado contrato de aprendiz “contrato para aprendizes matriculados no SENAI”, datado
de 07/08/08 com validade de 24 meses.
www.omniaonline.com.br
11 3675-5253
Foi verificada por amostragem a folha de pagamento dos funcionários (matriculas
104.159, 119628 e 115550) com os respectivos descontos e recolhimentos previstos pela
legislação.
Foi apresentação a Convenção coletiva de trabalho firmado com a Federação dos
trabalhadores nas indústrias do papel, papelão e cortiça do Estado de São Paulo Datado
de 30/10/2008 (validade 30/09/2009). O Piso salarial previsto foi de R$869,00.
Apresentado também a Convenção coletiva de trabalho firmado com o sindicato
dos trabalhadores rurais de Jundiaí datado de 21/10/2008 (validade 21/10/2009). O Piso
salarial previsto foi de R$486,00. Esse acordo apresenta-se em discussão.
As entrevistas revelam uma jornada de trabalho de 8 horas e horas extras em caso
de exceção. Verificado por amostragem que o pagamento de horas extras trabalhadas
são inseridos na folha de pagamento.
A empresa apresentou o PPRA - Programa de prevenção de riscos ambientais e o
PCMSO – Plano de controle médico e saúde ocupacional próprio e das empresas
prestadoras de serviço.
Verificado PPRA - 2009 da Melhoramentos preparado pela empresa Prot Life
Consultoria de Segurança Ltda. PCMSO – 2009. A análise do documento verificou
incoerência para a descrição do cargo “Preparador de massa”. O PPRA descreve como
risco químico o contato com soda cáustica mas, não prescreve EPI ( na preparação de
medidas de controle ou correção fala-se de exames clínicos realizado e prevê uso de
EPI). Além disso, o PCMSO não prevê a função de preparador de massa,
conseqüentemente não prevê exames.
Verificado PPRA 2009/2010 – Empresa: Antonia Donizete Martins. PCMSO –
12/11/2008. CRM 25130 (Dr. Shin E. Nohara). Ficha de controle de EPI/uniforme
verificado por amostragem para os funcionários matricula 1597 (período de 05/01/2009 a
09/05/09); matricula 1607 (período de 05/01/09 a 09/05/09) e 1596 (período - 05/01/2009
a 09/05/09).
Verificado PPRA Abril 2009 – Empresa Transine LTDA - PCMSO – Abril/2009.
CRM 9623 (Dr. Wladmir Cassalho dos Santos).
www.omniaonline.com.br
11 3675-5253
Atestado de saúde ocupacional – ASO de prestadores de serviço foram verificados por
amostragem. Não ficou claro como é a Gestão da Melhoramentos sobre o controle dos
ASOs periódicos.
Foram realizadas visitas em atividade em campo na unidade de manejo florestal –
atividades colheita semi-mecanizada (talhão 219) conduzida pelos prestadores de serviço
Transine e Jeferson Sergio Serafim e atividade de aplicação de herbicida (talhão 55)
desenvolvido pelo prestador Antonia Donizete Martins.
As empresas prestadoras de serviços fornecem equipamento de proteção
individual – EPI. Em visita de campo foram observados que os funcionários estavam
portando o EPI previsto no PPRA.
Entretanto, foi verificado na atividade de aplicação de agrotóxico que os
funcionários levam as suas roupas para serem levadas em suas residências. Não há
controle da empresa para o número de lavagens prevista no CA das roupas.
Foram verificadas estruturas de apoio previsto pela NR 31 como barraca de abrigo,
água para consumo, mesas, cadeiras, banheiro móvel com papel, água, sabão para
higiene pessoal.
Todos os trabalhadores recebem café da manhã e alimentação quente no campo.
A empresa que fornece alimentação é a Iraha refeições (Ingrid Adriane de AlmeidaFranco da Rocha SP).
Nas entrevistas com os trabalhadores não foi verificado ausência de pagamento ou
trabalho estabelecido por meio de trocas de mercadoria.
Porte de Motosserra – não foi apresentado um porte de motosserra (serie
352545155). A mesmas precisam estar nas frentes.
Os funcionários recebem treinamento para a função desempenhada. Verificada
por amostragem treinamento realizado para operador de motosserra com carga horária de
40 hs no período de 30/01/ a 02/02/2001, oferecido pela empresa Pisa Florestal S/A.
Entretanto, foi verificado treinamento para aplicadores de herbicida realizados no
dia 12/08/09 oferecido pela empresa Syngeta com carga horária inferior ao exigido pela
legislação.
Não foi apresentado Curso de operador de motosserra empresa Transcine.
A empresa possui gestão sobre pendências jurídicas trabalhistas. Foi realizada
www.omniaonline.com.br
11 3675-5253
consulta ao jurídico e foi informada a existência de 42 pendências sendo 26 trabalhadores
terceiros e 16 funcionários próprios.
Requerimento 3 – “Colheita de madeira em área de florestas de alto valor de
conservação”
Segundo informações do engenheiro responsável florestal não foi evidenciada
Floresta de alto valor de conservação dentro da unidade de manejo florestal.
A empresa está em processo de regularização da averbação de reserva legal e
áreas de preservação permanente.
Em auditoria de campo não foram verificados plantios em as áreas de preservação.
Requerimento 4 – Conversão de florestas nativas
Não há evidencias de que está ocorrendo conversão de florestas nativas para o
plantio florestal na propriedade da Melhoramentos Florestal.
Foram apresentadas fotografias aéreas da propriedade do ano de 1972 e em 2009.
De acordo com as fotografias, foi verificado que em 1972 a área já se encontrava
reflorestada.
Requerimento 5 – Manejo de arvores geneticamente modificadas
Não existem árvores geneticamente modificadas da espécie Eucalyptus autorizada
e licenciada para comércio pela Comissão técnica nacional de Biossegurança –CNTBio
(site: http://www.ctnbio.gov.br).
A Melhoramentos adquire mudas por meio do viveiro de propriedade da mesma
empresa na cidade de Camanducaia em Minas Gerais (verificado Nota fiscal: 077839
Serie 1, datada de 10/06/09) e por meio de compra de empresas terceiras. Verificado por
www.omniaonline.com.br
11 3675-5253
amostragem compra de sementes: IPEF – Instituto de pesquisa e estudos florestais (NF
033612- 29/07/09, RENASEM 01028/2006); Acesita Energética LTDA (NF 027020 –
28/01/09, RENASEM 00708/2006) e MP Administradora Florestal Ltda (NF 004479 –
26/06/09, RENASEM 00757/2006).
As notas fiscais de compra de mudas acima indicam quantidade de mudas
adquiridas, origem e o numero do Registro Nacional de Sementes e mudas, expedido pelo
Ministério da Agricultura.
Entrevistas:
André Luis dos Santos – supervisor de planejamento florestal
Edson Barbosa da Silva – supervisor de controles florestais
Cláudio Zomigman – coordenador de meio ambiente
Bruna C.Toledo – supervisora de sistema de qualidade.
Samuel Garcia – Técnico de processo industrial
Érika Cristina Chiaradia – responsável pelo setor de Recursos Humanos.
Reinaldo Cezar Santos – analista de fornecimento de madeira
Leandro de Oliveira Alves – conferente de Balança (recepção de matéria prima)
Aelson Fonseca Pereira – Técnico de segurança
Edneia Cordeiro de Paula – Recursos Humanos
Verônica Souza - Recursos Humanos.
Valdir Ferreira de souza – trabalhador florestal (prestador de serviço)
Ademilson Flor da Silva - trabalhador florestal (prestador de serviço)
Evandro Santos da Silva - trabalhador florestal (prestador de serviço)
Rubens Colombo – Transporte florestal
Edson Alves – encarregado de colheita florestal
Evidencias das informações
A MD Papeis possui cópia dos seguintes documentos:
www.omniaonline.com.br
11 3675-5253
- Lista de presença referente à reunião de abertura/encerramento.
- Plano de Manejo Florestal;
- Notas fiscais de compra de mudas de Eucalyptus.
-- Notas fiscais de venda de pasta celulósica.
- Folha de pagamento de funcionários.
- Convenção coletiva de trabalho firmado com o sindicato dos trabalhadores nas
indústrias do papel e cortiça do Estado de São Paulo.
-
RENASEM
–
registro
nacional
de
sementes
e
mudas
–
produtor/comerciante/responsabilidade técnica consta nas notas fiscais de compra de
sementes.
- Mapa da situação fundiária do Estado de São Paulo para a demarcação de reservas
indígenas.
- Mapa da situação fundiária do Estado de São Paulo para a demarcação de reservas
Quilombolas.
- Contrato de prestação de serviço de corte com a empresa Jéferson Sergio Serafim.
- Memorando com a relação de todos os títulos de aquisição de terra por parte da CMSP
www.omniaonline.com.br
11 3675-5253
SmartWood Program Headquarters
65 Millet St. Suite 201
Richmond, VT 05477 USA
Tel: 802-434-5491
Fax: 802-434-3116
www.smartwood.org
Supplier verification
Report for:
MD Papéis
Certification
Managed by:
South America Regional Office
C/ Manuel Ignacio Salvatierra # 359
Santa Cruz - Bolivia
Tel: +591 3 3325042
Fax: +591 3 3327451
Contact person: Freddy Peña
Email: [email protected]
of
Planta Laja, Provincia del Bío Bío (VIII
Región), Chile
Report Finalized:
Audit Dates:
Audit Team:
Organization Contact:
Address:
ACCREDITED
FSC-ACC-004
© 1996 Forest Stewardship Council A.C.
1 to 4 February, 2010
Ariel Zorrilla
Fernando Martínez
1343 Agustinas St., 3rd
Floor, Santiago de Chile
City, Chile
Table of Contents
1
INTRODUCTION.................................................................................................................................................................. 3
2
AUDIT CONCLUSIONS ..................................................................................................................................................... 4
3
AUDIT PROCESS................................................................................................................................................................ 5
Appendix I: Controlled Wood Field Audit Verification Checklist......................................................................................... 7
Controlled Wood Field Audit Verification Checklist................................................................................................................ 7
1
Evaluation of : Planta Laja, CMPC Co........................................................................................................................... 7
2
Evaluation Details ................................................................................................................................................................ 7
3
FMUs Audited ....................................................................................................................................................................... 8
4
Standard Checklist............................................................................................................................................................... 8
Appendix IV: LIST OF REPORT EXHIBITS – can be sent upon request...................................................................... 16
SmartWood Program
COC-33 03Apr08
Page 2
1
INTRODUCTION
The purpose of this report is to evaluate the operations of CMPC Company with the aim of providing
the audit client MD Papéis with evidence that the products delivered by Planta Laja are controlled
and do not contain any controversial material as defined in the FSC Controlled Wood standard FSCSTD-40-005 V2-1. The report presents the findings of SmartWood auditors who have evaluated
Organization systems and performance against the applicable standard. Section 2 below provides the
audit conclusions and any necessary follow-up actions by the Organization.
The contents of this SmartWood evaluation report is kept confidential and shared only with the audit
client MD Papéis and upon agreement with MD Papéis, also with the audited operation CMPC Co.
The Rainforest Alliance’s certification program, SmartWood, was founded in 1989 to certify
responsible forestry practices and now focuses on providing a variety of certification and auditing
services. Chain-of-custody refers to the complete systems and procedures that allow for the tracking
of a forest product from the logs traded by a forest manager or broker, to primary or secondary
processing, to the wholesalers or retailers who bring the final product to the marketplace. The
Rainforest Alliance SmartWood Program is accredited by the Forest Stewardship Council (FSC).
SmartWood-certified companies may purchase, process, and/or sell certified wood from other FSCcertified companies.
Dispute resolution: If SmartWood clients encounter organizations or individuals having concerns or
comments about Rainforest Alliance / SmartWood and our services, these parties are strongly
encouraged to contact SmartWood Headquarters directly. Formal complaints or concerns should be
sent in writing.
SmartWood Program
COC-33 03Apr08
Page 3
2
AUDIT CONCLUSIONS
2.1
Compliance with Controlled Wood requirements
Regarding on the audit findings, SW audit team has reached the conclusion that wood supplies
to Planta Laja facility could be consider as Controlled Material. There is enough evidence to
demonstrate that wood supplies form CMPC´s farms and third parts farms is controlled in all the
requirements this Standard presents. Due to distances and time available to complete the field
assessment, was not possible to visit a bigger number of FMUs. In accordance to FSC
requirements, the size of the sample is defined into Annex 3.A – 1.9.
The material supplied by Planta Laja (Chile) to MD Papéis (Brazil) can be classified as
shown below, based on the suppliers performance in relation to FSC Controlled Wood
standard FSC-STD-40-005 V2-1.
Overall status:
Controlled Material
Uncontrolled material
Controlled material
1. Illegally harvested wood;
Uncontrolled material
2. Wood harvested in violation of traditional
and civil rights;
3. Wood harvested in forests where high
conservation values are threatened by
management activities;
4. Wood harvested in forests being
converted to plantations or non- forest use;
5. Wood from forests in which genetically
modified tress are planted.
Controlled material
Uncontrolled material
Controlled material
Uncontrolled material
Controlled material
Uncontrolled material
Controlled material
Uncontrolled material
Additional comments:
--
Suggestions for further
supplier auditing of
Planta Laja by MD
Papéis:
Filling full assessments (field verification and and interviews) to
independent foresters that sell wood to Planta Laja would
contribute to the process.
2.2
Corrective Action Requests
During the audit, the following weaknesses were identified in relation to the Controlled Wood
system in Planta Laja facility. In order to continue sourcing the products as Controlled Wood from
the company, MD Papéis shall ensure that CMPC promptly follows up on the identified
weaknesses. It will be up to MD Papéis to ensure that the identified weaknesses will be correctly
addressed (although SmartWood may be hired to conduct a follow-up audit on these issues).
SmartWood Program
COC-33 03Apr08
Page 4
2.2.1 Corrective Action Requests (CARs)
CAR 01/08
Non-conformance:
Major X
Minor
Reference Standard & Requirement: 1.1, 1.7, 1.9
Due to lack of prior information on suppliers in the design phase of the project,
the scope of this audit did not include the evaluation of third party suppliers and
thus these sources cannot be controlled.
Corrective Action Request: MD Papéis shall provide evidence of evaluation and verification for CMPC
third party suppliers of Planta Laja, to demonstrate compliance with controlled wood requirements.
Verification audits shall meet FSC requirements.
Timeline for conformance: Prior to classification as controlled.
Evidence to close CAR:
During the present Audit independent pine suppliers were visit
accompanied with MD Papéis Representative, Mr. J. C. Alves. All of them
supplies wood to Planta Laja (independently that they provides to other
facilities, eucalyptus wood inclusive).
CMPC presented the system they applied to evaluate suppliers, and results
of the verification the technical team made on a sample. For these
verifications the company use the “Controlled Wood Risk Assessment” that
FSC Chile developed for plantations areas.
The results of the field verification where they could be consider a safe
source for Planta Laja facility in accordance to Controlled Wood
requirements.
CAR Status:
CLOSE.
Follow-up Actions (if any):
--
2.2.2 Observations
OBS 01/2010
Reference Standard & Requirement: 1.1
Findings: CMPC´s procedures determinates that the field verification is conducted just on categories
classified as Indeterminate Risk by the assessment that FSC Chile made at Comuna (immediately
higher level than Municipality) level. Therefore impacts on civil rights and high conservation values at
FMU level could not being controlled.
Observation: CMPC shall complete the field verification on all the categories that apply for Chile,
improving in that way risk verification program to avoid purchase Planta Laja mill with wood that could
come from farms where civil rights and/or high conservation values could being impact.
3
AUDIT PROCESS
3.1
Audit Team
Auditor(s)
Qualifications
Ariel Zorrilla
Argentinian. Agronomic Engeneer. Rainforest Alliance/SmartWood
Program Representative for Argentina. 7 years experience in forest
management and CoC certification in South America.
Arturo Burgos
Chilean,
Forester.
Rainforest
Alliance/SmartWood
Program
Representative for Chile since 2009. More than 6 years experience in
forest management and FSC system implementation in Chile for private
companies.
Mr. Burgos participated on this process as Observer.
SmartWood Program
COC-33 03Apr08
Page 5
3.2
Audit Overview
Note: The table below provides an overview of the audit scope and auditors.
See standard checklist appendix for specific details on people interviewed and
audit findings per site audited.
Site(s)
Date(s)
Length of Audit
Planta Laja (CMPC´s facility)
February 2 and 4,
2010
1.5 day
Independent suppliers´ forestry area
(Comunas de Los Angeles, Yumbel,
Quillón, and Mulchen, Provincia del Bío
Bío, VIII Región, Chile)
February 2 and 3,
2010
1.5 day
3.3
Description of Overall Audit Process
CMPC Co. prepared an agenda to implement the present verification audit. This document was
commented by SmartWood.
Rainforest Alliance/SmartWood Program Representative for Argentina accompanied MD Papéis´
Quality Manager, Mr. Júlio César Álves, during forestry activities verification. At that moment
camps were visited, some workers’ interviews were made and general issues were verified (road
conditions, impacts on native forests and other natural values, labor conditions, etc.).
Rainforest Alliance made reviewed and verified general documentation at CMPC´s offices and at
camps as well.
In relation to Stakeholder consultation Rainforest Alliance is working on the CMPC´s (Forestal
Mininco) Scoping process. So that a lot of information that were interchanged with local, regional,
national and international Stakeholders, represent a valuable source of information to the current
process.
SmartWood Program
COC-33 03Apr08
Page 6
Appendix I: Controlled Wood Field Audit Verification Checklist
Controlled Wood Field Audit Verification Checklist
Checklist for SW field audit verifications of FMUs in company’s field verification program for sources
with unspecified risk
1
Evaluation of Site: Planta Laja, CMPC Co.
Location Name:
Planta Laja, Laja, VIII Región, Chile.
Contact for Certification:
Fernando Martínez, CMPC´s Customer Service Manager
Address:
1343 Agustinas St., 3 Floor, Santiago de Chile.
Tel/Fax/Email:
Phone: 0056 2 4412 646
rd
Fax: 0056 2 6982 179
[email protected]
Certificate Code:
2
--
Evaluation Details
Date(s):
January 1 to 4, 2010
Auditor, Qualifications:
Ariel Zorrilla. Agronomist. Rainforest Alliance/SmartWood Program
Representative for Argentina. 7 years experience in forest management
and CoC FSC Certification in South America.
• Júlio César Álves (Quality Manager, MD Papéis),
• Fernando Martínez (CMPC´s Customer Service Manager),
• Sandra Veja (CMPC´s Customer Service Assistant),
• Alvaro Merino Lorca (CMPC´s Administration and Certification vice
Manager),
• Ramiro Peralta Aros (Planta Laja´s Production vice Manager),
• Luis Sáez Garrido (CMPC´s Integrated Management System
Engineer),
• Rodrigo Soto (CMPC´s Wood production Chief),
• Carlos Rodriguez Salinas (Forestry Supervisor),
People Interviewed, Titles:
SmartWood Program
COC-33 03Apr08
•
Álvaro Sobarzo (Independent Intermediary),
•
Osvaldo Riveros (Mr. Sobarzo Co. Field Supervisor),
•
Ramón Jara (Planta Laja´s Wood Reception Operator),
•
Germán Sepúlveda (Planta Laja facility Assistant),
•
Juan López Gutierrez (Planta Laja´s Supplier),
•
Freddy Rubio (CMPC´s Operations Chief),
•
Waldo Pérez (CMPC´s Safety Department Chief),
•
Rodrigo Cortéz (Safety Technician)
•
Mr. Bernardino (Contractor´s Machine Operator)
•
Mr. Mauricio (Contractor´s Silviculture Supervisor),
•
Alexadro Freire (Contractor´s Worker),
•
Hernán Parra (Field workers´ Chief).
Page 7
Brief Overview of Inspection
Process for this Location:
Rainforest Alliance verified documents (Agreements with independent
suppliers, Management instructions, field verification results, etc),
interviewed staff and workers, and visited harvesting areas. During the field
visit it was possible to verify road conditions after rains; harvesting impacts
on native forest and soils; and safety conditions for workers during
harvesting operations. A verification on general documents available at
farm was made.
As during the CW Assessment made on 2008 was not possible to visit
independent suppliers farms, the current Audit was focused on this.
3
FMUs Audited
FMU
Location
Subset
Bilbao Rele (Rol #25)
Comuna de Yumbel, Provincia del
Bío Bío (VIII Región), Chile
--
San Juan
Comuna de Los Angeles, Provincia
del Bío Bío (VIII Región), Chile
--
San Diego (Rol # 1103-25)
Comuna de Quillón, Provincia del
Bío Bío (VIII Región), Chile
--
Barataria
Comuna de Mulchen, Provincia del
Bío Bío (VIII Región), Chile
--
4
Standard Checklist
This checklist is used by SmartWood when performing verification of the supplier field audits performed by
certificate holders implementing their own Controlled Wood verification program including a field verification
program for sources with unspecified risk. The checklist is directly based on FSC Controlled Wood requirements
as detailed in FSC-STD-40-005 V2-1 Standard for Company Evaluation of FSC Controlled Wood, Annex 3.
Part 1: Annex 3.A Evaluation
1.1 Organization’s verification program shall provide evidence that wood coming from a
particular supplier has been controlled for the 5 unacceptable categories for FSC
Controlled Wood shown in 1.1 (annex 3, 1.1):
Yes
No
Findings: MD Papéis had developed a Risk Assessment to evaluate CMPC´s forestry operation in relations to
the 5 unacceptable categories for the FSC. At the same time, CMPC has its own risk assessment for timber
producers that sell to Planta Laja pulp mill facility.
CMPC´s procedures determinates that the field verification is conducted on categories classified as
Indeterminate Risk by the assessment that FSC Chile made at Comuna (immediately higher level than
Municipality) level.
1.2 Verification shall be conducted by personnel with sufficient expertise and knowledge for
the requirements in Annex 3 (annex 3, 1.2):
Yes
No
Findings: MD Papéis sent his Quality Chief to make the verification of Planta Laja. This person has enough
knowledge about FSC System and its Controlled Wood Standard. CMPC´s personnel that conduct field
verifications at independent suppliers farms has experience and is technically solid.
1.3 For each of the 5 unacceptable categories that cannot be considered low risk,
Organization shall identify and provide the rationale for documents and other evidence
needed to demonstrate that wood complies with the requirements for FSC Controlled Wood
for that specific category (annex 3, 1.3):
Yes
No
Findings: MD Papéis has specific documentation and evidence for each category to demonstrate that
material is controlled. See detailed findings below regarding evidence for each category. MD Papéis has also
SmartWood Program
COC-33 03Apr08
Page 8
implemented a verification program at Planta Laja facility to verify that the provided evidence is authentic. This
verification is made once a year as a formal commitment of MD Papéis.
1.4 Organization shall ensure that the required documents and other evidence as required
under Section B in Annex 3 (specific requirements for each unacceptable category) are
available for verification by SmartWood (annex 3, 1.4):
Yes
No
Findings: Both companies MD Papéis and CMPC have all the information available for verification by
Rainforest Alliance/SmartWood.
1.5 Organization shall define and implement a regular (at least annual) verification audit
process to confirm the authenticity of the specified documentation and other evidence
(annex 3, 1.5):
Yes
No
Findings: MD Papéis conducts a risk verification at Planta Laja facility annually. CMPC has its own risk
assessment for third parties that sell timber or logs to the pulp mill facility.
1.6 The audit process shall include:
a) Consultation with relevant stakeholders;
b) Staff interviews; and
Yes
No
c) Field visits to harvesting sites (annex 3, 1.5):
Findings: The SW/RA consultant that made the verification audit of Planta Laja visited harvesting areas,
interviewed some relevant stakeholders, Contractor´s Supervisors and field workers and CPMC´s Staff. MD
Papéis Quality Manager accompanied the interviews to these people.
SmartWood/Rainforest Alliance started up a wider Stakeholder Consultation during Forestal Mininco´s
Scoping, and results enriched the current Audit.
1.7 The number of verification audits that take place shall be determined by sampling in
accordance with 3.16 below (annex 3, 1.6):
Yes
No
Findings: Planta Laja facility is provided of wood from both CMPC´s farms an independent producers. CMPC
conducts field verification to all clients in relation to legal harvested wood (Category #1). For the other
categories CMPC verified a sample of producers in accordance with FSC requirements.
1.8 Organization shall classify the FMUs as sets of ‘similar’ units for the purpose of
sampling. The sets shall be selected to minimize variability within each set. “Similarity” is in
terms of (annex 3, 1.7):
No
Yes
a) Forest type (e.g., natural forest, plantation);
b) Geographical location (district);
c) Size of operation (e.g., SLIMF).
Findings: CMPC´s farms that supply Planta Laja into the VIII Region of Chile, could be consider as a single
FMU. In the other hand, each independent producers farms is consider as an FMUs, therefore the size of the
sample is bigger.
1.9 For each set of ‘similar’ units Organization shall (annex 3, 1.8, 1.9):
a) Select at least 0.8 times the square root of the number of units for evaluation per
annum (x = 0.8√y);
b) For sets that consist entirely of FMUs that qualify as Small or Low Intensity Managed
Forests (SLIMFs), select at least 0.6 times the square root of the number of units for
evaluation per annum (x = 0.6√y);
Yes
No
c) Randomly define samples for field verification;
d) Round the sample size up to the upper whole number.
Note: x = sample size; y = total number of FMUs in the set for sampling / set of similar
units.
Findings: CMPC selects the square root of the number of units that provides wood to Planta Laja, therefore
the number of farms that are visited are more than FSC requirements. None of the suppliers is considered as
SLIMF.
1.10 Verification audits should be conducted timely after receipt of the wood (annex 3,
SmartWood Program
COC-33 03Apr08
Yes
No
Page 9
1.10):
Findings: Planta Laja (Chile) is a regular supplier of MD Papéis (Brazil). At this moment MD Papéis is
conducting a controlled wood audit to confirm if Planta Laja (CMPC) could be considered as a controlled wood
supplier for its paper mill facility in San Pablo State.
1.11 Any consultation with staff and workers shall take place unaccompanied by
management representatives from the Organization (annex 3, 1.11):
Yes
No
Findings: MD Papéis made consultation with supervisors and workers unaccompanied by CMPC´s Staff.
1.12 All reports or records of verification audits shall be maintained for at least 5 years and
shall include the findings of the verification, the extent to which it was possible to conduct
the verifications in the manner described above, and the experience and qualifications of
the personnel conducting the verification (annex 3, 1.12):
Yes
No
Findings: CMPC´s forestry documents specify records will be maintained for a period of 5 years
1.13 Reports or records of verification audits shall be accessible to SmartWood and FSCauthorized personnel on request (annex 3, 1.13):
Yes
No
Findings: All the information that MD Papéis and Planta Laja have on risk verifications are available to
RA/SW and FSC authorized personnel on request.
1.14 Organization shall follow Annex 3, “Section B Specific requirements” for its verification
program in evaluation of its sources according to each of the unacceptable categories for
FSC Controlled Wood, OR Organization shall develop alternative measures in its
verification program to ensure compliance with the intent of the CW standard 40-005
(annex 3, B):
Yes
No
Findings: MD Papéis has presented a Policy to avoid buying uncontrolled wood, signed by the Industrial
Director and the Organizational Development Director.
CMPC uses as a source the risk assessment that was developed by the FSC-Chile National Initiative. The
verification program include all the specific requirements of the CW standard.
Part 2: Annex 3.B Evaluation
Please note that the supplier audits at a minimum need to cover only the categories which are classified as
unspecified risk for the district of origin. The other categories can be marked as non-applicable. Please mark
below the applicable categories:
Wood Category
1. Illegally harvested wood
1
Applicable for
this region
Yes
No
2. Wood harvested in violation of
traditional and civil rights
Yes
No
3. Wood harvested in forests where high
conservation values are threatened by
management activities
Yes
No
4. Wood harvested in forests being
converted to plantations or non-forest
use
Yes
No
5. Wood from forests in which genetically
modified trees are planted
Yes
No
Illegally harvested wood
Check if section not applicable (district is low risk for this category)
SmartWood Program
COC-33 03Apr08
Page 10
OVERALL COMPLIANCE WITH THIS CATEGORY
Yes
No
1.1 Evidence of legal authority to harvest exists.
No
Yes
Note: Most common sources of verification: Concession license and/or harvesting permit
(approved by the appropriate authority)
Findings: CMPC is a very big Chilean forestry company that work since 1920, and Planta Laja is one of their
pulp and paper facilities. Any forestry company needs to ask for legal authorization to harvest their forest and
pay a fee before do that. The Company follows legal requirements to keep normal the timber supply to Planta
Laja. At the same time, the Company makes verification to all their suppliers to assure they follow legal
requirements, does not matter if these suppliers are in a low risk area in accordance to the assessment that
FSC Chile made. Rainforest Alliance checked some of these verification to external suppliers.
1.2 There is evidence of compliance with applicable management planning requirements.
No
Yes
Note: Most common sources of verification: Approved management plan or equivalent
documentation, as required by local authorities
Findings: CMPC has its own Forestry Management Plan and as independent forester, need to present to
local authorities, a brief report describing technical prescriptions for harvesting and environment cares before
interventions occur. During the current Audit Rainforest Alliance verified this documentation from some
independent foresters that supply timber to Planta Laja. CMPC records a copy of each legal harvesting
authorization on independent foresters.
1.3 Applicable harvesting restrictions are specified and known at the level of FMU.
No
Yes
Note: Most common sources of verification: Documentation specifying legal restrictions on
harvesting (e.g. diameter limits, species restrictions, volume restrictions)
Findings: Regarding the use of timber coming from plantations, there are no restrictions on diameters or
species harvested, but just on environment protection and sites where authorizations were given for. CMPC
knows very well the national legal frame of the plantation sector.
1.4 Evidence exists that timber is harvested from areas designated for harvesting (e.g. not
from protected areas where harvesting is not allowed).
Yes
No
Note: Most common sources of verification: Maps and/or records showing the area in which
harvesting has taken place
Findings: There is no evidence of claims that the Company or external suppliers harvest areas with any
restriction. During field activities use to be a CMPC´s Supervisor, a Contractor´s Supervisor and local
authorities that verify these practices regularly. Maps and written procedures at field had high quality where
verification was made, and workers known very well their work (most of Contractor´s employees have more
than 10 years working in forestry at the same region).
1.5 Evidence exists that harvesting rate is within the legally allowed limits.
No
Yes
Note: Most common sources of verification: Records showing yield figures, volumes and
species harvested
Findings: Legal authorizations have references to forestry sites within farm under management, species and
volumes to harvest. CONAF (Coorporación Nacional Forestal) verify these activities regularly, punish and
cancel permits if un-normal practices are detected.
1.6 Sufficient evidence exists of timber purchases as required by the legislation throughout
the whole supply chain.
No
Yes
Note: Most common sources of verification: Purchasing contracts, invoices
Findings: CMPC supply timber to Planta Laja from own forests and independent producers´ forests. To get an
authorization to harvest these forests law must be follow throughout all supply chain. CMPC has records of all
the Contracts and Transportation documents produced on third parties farms. Rainforest Alliance visited some
of these areas and maintain records of legal documentation.
SmartWood Program
COC-33 03Apr08
Page 11
1.7 There is written evidence of payment of royalties or other fees (i.e. fees on harvesting
rights).
Yes
No
Note: Most common sources of verification: Official records confirming payments
Findings: There are no evidences of unpaid fees to local authorities. For each harvesting plan foresters must
pay a fee, if they do not do this they can not harvest planted forests. Chile has a strong governmental control
recognized by the international community.
1.8 There is evidence of compliance with applicable CITES requirements.
Yes
No
Note: Most common sources of verification: An up to date list of tree species harvested and
sold in the FMU. An up to date list of tree species that are listed in Appendices I to III of the
N/A
Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES). National permits for harvest or trade of any CITES-listed species, if applicable.
Findings: CMPC grows, cut and buy exotic pines to supply Planta Laja pulp mill facility. There is no native
forest logging harvesting; furthermore there is a formal policy to protect these native areas.
1.9 Evidence exists of compliance with timber transportation documents according to
applicable legislation.
Yes
No
Note: Most common sources of verification: Copies of transport or sales permits with
specification of species and volumes as applicable
Findings: Rainforest Alliance made verifications and keep records (photograph taken during the Audit) of
legal timber transportation documents. At the entrance of Planta Laja the truck drive must give to CMPC´s
entrance officer the legal documentation:
-
Ticket de Aceptación de Garita: That is a ticket given during the permanence of the truck after its
acceptation was confirmed (if the wood was not required the permit to go towards is denied);
-
Guía de Despacho: When a truck is leaving a farm to Planta Laja, the Company fill this legal document
that contain a sequential numeration, general data (site, date, owner, logger), species, volumes, etc.
At the same time through this document is possible to know if the wood is FSC Certified or if it is
Controlled Wood.
-
Guía de Movimiento de Madera: It has almost the same information than the previous document, plus
a scanned of measures (weight, length and width).
CMPC record these documents for 5 years.
1.10 Audit findings and records conform that all species and qualities harvested have been
Yes
No
classified correctly.
Findings: Since the industrial process has a high specified production to obtain specific pulp qualities that the
Company sells, Planta Laja has a strict control on species and qualities bought.
2
Wood harvested in violation of traditional and civil rights
Check if section not applicable (district is low risk for this category)
OVERALL COMPLIANCE WITH THIS CATEGORY
2.1 The supplier audit successfully demonstrates that there are no conflicts relating to land
tenure or land use rights of traditional or indigenous peoples groups in the FMUs from
which it is sourcing wood, which are of substantial magnitude; which involve a significant
number of interests; and for which a resolution process has not been agreed by the main
parties to the dispute.
Yes
No
Yes
No
Note: Stakeholder consultation with appropriate representatives of local communities
and/or indigenous peoples shall be conducted in order to verify this.
SmartWood Program
COC-33 03Apr08
Page 12
Findings: In accordance to current evidence and Stakeholders consultation process, can be assume the
Company does not has any big conflicts relating to land tenure or land use rights, and when they occur CMPC
follow legal procedures to resolve them.
Forestry operations occur on private properties and in accordance with local and national laws.
CMPC verifies this category when independent suppliers are located at a risky Comuna (District).
2.2 The supplier audit successfully demonstrates that there is no evidence of violation of
the International Labor Office Fundamental Principles and Rights at Work in the FMU nor of
the International Labor Office Convention 169 on Indigenous and Tribal Peoples.
Yes
No
Note: Field visit to ongoing harvesting sites with interviews with workers and interviews with
relevant stakeholder shall be conducted in order to verify this.
Findings: CMPC´s employees have internal committees to negotiate with the owner and no restrictions were
detected. Chile is not designated as source of conflict timber regarding to international qualification standards.
This country has a Labor Code (Código del Trabajo) and a strong governmental control system.
CMPC had achieved a local certification (CERFOR) recognized by international forestry certification system
(PEFC); and one of the properties the Company bought has its forest management certified by FSC (Forestal
Monte Águila). In accordance with this, the Company had developed a very strict frame on labor conditions.
Rainforest Alliance took some photographs at field as evidence.
CMPC verifies this category when independent suppliers are located at a risky Comuna (District) and maintain
records of these audits.
2.3 In cases where a resolution process is in place, the supplier audit checks that there is
documented evidence of the process by which any disputes are being resolved, which
demonstrates the broad support of the parties to the dispute, and which outlines an agreed
Yes
No
interim process for addressing the dispute and for the management of the forest area
concerned.
Findings: CMPC follow legal requirements to resolve claims on properties tenure. As a result of the
Stakeholder consultation process was known that these third parties believes CMPC has a very respectful
attitude and do not disturb authorities work to resolve these issues.
3
Wood harvested in forests in where high conservation values are threatened by management
activities
Check if section not applicable (district is low risk for this category)
OVERALL COMPLIANCE WITH THIS CATEGORY
Yes
No
3.1 The supplier audit demonstrates that forest management activities in the FMU do not
No
Yes
threaten high conservation values.
Findings: CMPC has a Forest Management Plan, procedures and other documents (eg: maps, field
instructions, etc) to avoid threat areas with high conservation values.
All the third parts farm visited had small stands of pine and/or eucalyptus within bigger properties. Most of the
stands visited were apart from rivers, other wetlands and native forests. The only one farm that was already
harvest a couple of weeks before, presented a well conserved river protection (riparian) area.
CMPC verifies this category when independent suppliers are located at a risky Comuna (District) and maintain
records of these audits.
3.2 The supplier successfully demonstrates that:
Records of an assessment (e.g. rapid ecological assessment, environmental or social
No
Yes
impact assessment, or wildlife census) appropriate to the size of the FMU and intensity of
management to identify the presence of high conservation values exist.
SmartWood Program
COC-33 03Apr08
Page 13
Findings: The Company works in different lines in relation to HCVs. Starting with a public environment policy,
CMPC has a public commitment to protect, study and share knowledge on native forests activities. CMPC
verifies this category when independent suppliers are located at a risky Comuna (District) and maintain
records of these audits. To determinate the size of the sample to be verified CMPC follow the current FSC
Standard requirements.
3.3 The supplier successfully demonstrates that:
Evidence of consultation exists with stakeholders, including NGOs and parties that are
No
Yes
involved with or have an interest in the forest area, in relation to identifying HCVs and
threats to them, with respect to social or environmental aspects. Where relevant, the
N/A
assessment shall include consultation with representatives and members of communities
and indigenous peoples living in or adjacent to the FMU.
Findings: CMPC has agreements with international and local NGOs to protect wild areas within the property.
Moreover, the Company participate in meetings with local Representatives of WWF and some other forestry
companies, to define and implement methodologies in relation to HCV sites. In accordance with the work the
Company is developing to achieve FSC Certification, the HCV jobs is being improving.
3.4 The supplier successfully demonstrates that:
A list of the high conservation values identified in the FMUs exists, together with evidence
Yes
No
indicating that these high conservation values are not threatened in the FMUs.
Findings: CMPC has some areas that present high conservation values within its properties. The Company
supports different projects in relation to biodiversity protection.
4
Wood harvested in forests being converted to plantations or non-forest use
Check if section not applicable (district is low risk for this category)
OVERALL COMPLIANCE WITH THIS CATEGORY
No
Yes
4.1 The supplier audit successfully demonstrates that all types of natural and semi-natural
forests and other wooded ecosystems such as woodlands and savannahs in the FMUs are
Yes
No
not being converted to plantations or non-forest uses.
Findings: The Risk Assessment document that was developed by FSC Chile determinate that this category
does not apply in the whole country when controlled wood is purchase from plantations.
4.2 Supplier has records of evidence to demonstrate compliance with this. The company
Yes
No
and supplier maintain such records for a minimum period of 5 years.
Findings: -4.3 In case any forest conversion to plantations or non-forest land uses has occurred, it is
under following circumstances:
a. entails a very limited portion of the forest management unit (less than 0,5% per
Yes
No
year and less than 5% in total); AND
N/A
b. does not occur on high conservation value forest areas; AND
c. will enable clear, substantial, additional, secure long term environmental and
social benefits across the forest management unit.
Findings: --
5
Wood from forests in which genetically modified trees are planted
Check if section not applicable (district is low risk for this category)
OVERALL COMPLIANCE WITH THIS CATEGORY
5.1 The supplier audit successfully demonstrates that no genetically modified trees are
present in the FMUs from which FSC Controlled Wood is sourced from.
Yes
No
Yes
No
Note: Potential source of verification includes passport of regeneration material.
SmartWood Program
COC-33 03Apr08
Page 14
Findings: The Risk Assessment document that was developed by FSC Chile determinate that the District
shall be considered as low risk for this category.
5.2 The supplier audit confirms that records are maintained by the supplier for at least five
Yes
No
year period to demonstrate that no GM trees are used in the FMU-s.
Findings: --
SmartWood Program
COC-33 03Apr08
Page 15
Appendix IV: LIST OF REPORT EXHIBITS – can be sent upon request
1. Controlled Wood Field Audit Verification Checklist (Lista de Verificación para Madera noCertificada FSC proveniente de zonas de riesgo no especificado);
a. External Foresters´ Forest Management Plan (approved by CONAF);
b. Wood origin control Checklist;
c. Wood purchase order,
d. Guía de Despacho;
e. Buying Form (Factura de Compra – A third part document buying pine stands to an
independent producer).
2. Qualification Records;
3. Commercialization Informative Letter (a communication between CMPC and independent
foresters);
4. Controlled Wood Internal Procedure (Instructivo Madera Certificada y Controlada de Cadena
de Custodia CMPC Celulosa, Versión 07 del 11-01-2010);
5. External Foresters List.
6. Stakeholders Consultation process (on CMPC´s FSC FM Certification process)
7 . Photographs taken during the field Audit..
SmartWood Program
COC-33 03Apr08
Page 16