OLB certification process for Forestry Companies GP01

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1 OLB certification process for Forestry Companies GP01 Reference: GP01 OLB FC 1.2 version, 22/03/2013 Bureau Veritas Certification France 60 Général de Gaulle Avenue Paris - La Défense Cedex - France Phone: 33 (0) Fax: 33 (0)

2 Table of contents 1 - General presentation of the OLB certification system Origin of forest certification OLB presentation OLB system requirements Certification process Description of the certification process Definitions Application for certification Review of the application Contract Audit preparation Auditors of Bureau Veritas Certification, Wood and Forestry department Auditors qualification Audit team composition: Participation of observers Pre-audit Value added of pre-audit and realization Implementing corrective actions Initial audit Initial audit programme Initial audit Opening meeting The audit s proceeding Synthesis meeting Closing meeting Draft audit report revision Non-conformities and corrective actions Non-conformities Corrective actions...12 Bureau Veritas Certification / April published on 27/03/13 Page 2 out of 17

3 7 - Certification Certification decision Awarding of certificate List of documents to be provided for application For an individual application for certification For an application for group certification List of documents to be prepared for the first audit List of information and documents to be available to the public Management of disputes related to the certification process Maintenance of a OLB Certificate Surveillance audits Extension of Certificate Reduction of Certificate Renewal Audit Suspension or withdrawal of the certificate Bureau Veritas Certification / April published on 27/03/13 Page 3 out of 17

4 1 - General presentation of the OLB certification system Origin of forest certification In response to civil society s concerns regarding the origin and legality of forest products and wood supplies, voluntary certification schemes for forests and their management were set up in the 1990s. Certification is an assessment process by which an independent third party attests that a product, a process or a service, is in conformity with predefined standard requirements or a referential. The aim of OLB certification is to demonstrate that management is in conformity with national and other relevant legal requirements from the country where the forest is situated and the company registered. The general purpose of this certification system is to certify that the forest management is legal and to control the origin of the forest products, and then to ensure the transfer of the certificate all along the supply chain including all steps in the manufacturing process up to the final consumer. That status of the forest products can only be ensured if all the links in the chain of custody (from the forest to the retailer) are certified, each link in the chain being based on the transfer of property. It is the certification process of the Chain of Custody OLB presentation The OLB standard ( Origine et Légalité du Bois ) has been developed in 2004 by Eurocertifor 1, a certification body based in Paris, France. This standard was developed to respond to the concerns of the public opinion and provide forest companies with an independent mean to demonstrate the legality of their activities and of their forest products, mainly for tropical regions. Eurocertifor developed the first version of it OLB standard based on its experience in Central Africa and its knowledge of forest management and legality requirements in this region. Since then the standard has been maintained, reviewed and updated using Bureau Veritas global experience and network. The Bureau Veritas OLB standard is now applicable internationally. In December 2010, the OLB standard has been updated in order to respond to new international and national requirements on timber procurement. Following the FLEGT process in the Congo Bassin, Bureau Veritas Certification decided in march 2013 to create a specific checklist for OLB auditors in order to verify documents of legality required by the country according to its FLEGT process ; this document, by country, will be updated according to the country laws and FLEGT requirements from the country. 1 Eurocertifor was a certification body for the timber and forest industres. In 2005, the company was taken over by Bureau Veritas Certification (BVQI at that time) and all Eurocertifor s certification programmes were then included as Bureau Veritas certification products. Bureau Veritas Certification / April published on 27/03/13 Page 4 out of 17

5 1.3 - OLB system requirements The OLB system requirements are defined in the OLB standard for Forestry Companies and in the OLB Chain of Custody standard. The former includes legality elements to be evaluated in each field related to forestry activities. For each field of activities, indicators have been developed and are applicable to any forestry situation, but are not exhaustive 2. Conformity with the requirements has to be evaluated in the field. The latter includes the system requirements and the elements to be evaluated in order to ensure the control of the traceability of the OLB certified wood products 3. At the end of Bureau Veritas OLB audit, Bureau Veritas Certification can provide an independent guarantee that all the OLB requirements are respected and can deliver a certificate which allows the use of the OLB trademark. 2 - Certification process Description of the certification process This document presents Bureau Veritas Certification process for the certification of forestry companies against the requirements of the OLB standard. The OLB forest company certificates awarded by Bureau Veritas Certification demonstrate the legal compliance of certified forestry companies for all their forestry activities Definitions Standard: Bureau Veritas Certification developed an OLB forest management standard based on the OLB Principles and Criteria. This standard defines the requirements that the applicant for certification must meet and serves as the basis of Bureau Veritas assessment during the audits. Forest entity: Forest production area and associated management system at the level of a management unit; a forest property; a group of owners or a group of properties having the same manager. Stakeholders: Any third party (association, group, community, company ) implicated or having an interest in forest management; including particularly forest users, associations for environmental protection, forest management organizations and consultants, forest research and training organizations, and relevant local administration... 2 For further information please consult the standard ref RF03 OLB FC 3 For further information consult the standard ref RF03 OLB COC Bureau Veritas Certification / April published on 27/03/13 Page 5 out of 17

6 The stakeholders as a whole must represent a wide range of environmental, ecological, social, legal and economic interest in forest management Application for certification Any entity expressing an interest in OLB certification receives on request an RFQ form (Request For Quotation) and the OLB standard for Forestry Companies Review of the application On return of the RFQ duly filled in, Bureau Veritas Certification prepares a commercial offer. The RFQ allows also Bureau Veritas Certification to receive enough information to ensure that the entity is in a position to enter the certification process and to maintain the appropriate level of performance afterwards. Together with the commercial offer, the present document and Bureau Veritas general and specific terms of sales are sent Contract When the applicant accepts Bureau Veritas Certification s commercial offer, it shall sign it and send it back to Bureau Veritas. The offer then establishes a contractual relationship between the applicant and Bureau Veritas Certification. Then the company can present itself as an applicant for OLB certification and indicate as such the forest production area to be evaluated. Bureau Veritas must also check and confirm whether a pre-audit is required Audit preparation Bureau Veritas Certification and the applicant for certification shall agree on the audit schedule proposed and the audit team s composition in order to prepare for the pre-audit or the initial audit. The applicant can request a revision of the audit team composition to avoid any risks of conflict of interests between the forest entity and one or several audit team members. The final choice of the audit team composition is nevertheless the prerogative of Bureau Veritas Certification. The audit program is finalized and presented to the applicant. The documents that will have to be examined by the auditors to prepare for the audit are then requested from the applicant. Bureau Veritas Certification / April published on 27/03/13 Page 6 out of 17

7 3 - Auditors of Bureau Veritas Certification, Wood and Forestry department Auditors qualification Bureau Veritas Certification recruits as auditors only Forest-Wood industry specialists, in order to ensure the following: A professional knowledge of the industry Expertise in forest management techniques and processes Bureau Veritas Certification lead auditors must: prove technical competence and professional experience in the forest industry; have followed a specific auditor s training program for auditing techniques and the evaluation of OLB standard; have performed at least three field audits. Finally, Bureau Veritas Certification auditors are selected for specific certification audits based on the following criteria: Competence in the type of forest under evaluation Availability for the audit as scheduled Independence Bureau Veritas Certification auditors favour a pragmatic and practical approach. Their priority is to assess the OLB system put in place in the company as a tool allowing the applicant entity to improve its activities Audit team composition: An audit team is formed of at least one Bureau Veritas Certification Lead Auditor, most of the time assisted by other auditors or consultants (1 to 6 people for the pre-audit and the surveillance audit: 2 to 8 people for the initial audit). If necessary, Bureau Veritas Certification calls upon consultants who come with a specific competence in a field or a particular region. Thus the qualifications we will find within the audit team are: a qualified Lead Auditor someone fluent in the local language (or an interpreter) someone who lives in the country or the region someone who has experience or the required qualifications concerning legal, social, economic, environmental and forest management problems in the region. Bureau Veritas Certification / April published on 27/03/13 Page 7 out of 17

8 3.3 - Participation of observers Bureau Veritas Certification France can associate observers to its Certification or monitoring audits. These observers can be: Bureau Veritas Certification France internal auditors (within the scope of internal audit activities of Bureau Veritas Certification France) Bureau Veritas Certification International internal auditors (internal audit of Bureau Veritas Certification France by Bureau Veritas Certification International network) Bureau Veritas Certification auditors undergoing training Any other observer in order to raise awareness and increase the credibility of the standard The applicant has to agree with the presence of an observer during Bureau Veritas Certification audits and the observer s presence is submitted to the Applicant s agreement prior to the audit. 4 - Pre-audit Value added of pre-audit and realization The pre-audit stage consists in performing a gap analysis of the applicant against the OLB requirements and to establish whether the applicant is ready to undergo a complete assessment (carried out during the initial audit). The pre-audit represents an opportunity to analyse the particularities of the forest entity, to clearly define the scope of certification, to check that the standard requirements are understood by the applicant (questions generated by the standard, process details, label use...) and to define corrective actions needed before the initial audit, if any. A pre-audit is not necessarily compulsory in the certification process, however it is a requirement when forest management operations are complex, when the production area to be assessed is important and when there is a particularly sensitive environment (social as well as environmental). Furthermore, a pre-audit allows the applicant to ensure that the organization s system does not present any major nonconformities. A pre-audit is based on a document review and, depending on circumstances (size of the forest production area, complexity of forest management), a visit in the forest will be organized as well as a stakeholder consultation process. At the end of the pre-audit, a pre-audit report is provided to the applicant that specifies the preliminary corrective actions required and to be implemented before the initial audit, in agreement with the applicant. Bureau Veritas Certification / April published on 27/03/13 Page 8 out of 17

9 Furthermore, a pre-audit is important to facilitate the stakeholder consultation process and ensure the success of the process. Before the pre-audit, the applicant entity and Bureau Veritas team must prepare with the identification of relevant stakeholders in order to contact them and organise an initial meeting that can take place during the pre-audit. NB: It is strongly recommended that an applicant identifies and contact relevant stakeholders even before the beginning of the certification process. Applicants not having taken such step are invited to do so Implementing corrective actions Based on the findings of the pre-audit report, the applicant for certification needs to identify weaknesses in its organisation and implement appropriate corrective actions in order to ensure conformity with the standard s requirements. Bureau Veritas team is required to contact identified stakeholders in the previous month of the initial audit, present them with the certification processes, and record potential observations regarding the activities of the forest entity. Then a team of auditors is selected by Bureau Veritas Certification to prepare for and perform the initial audit. A period of about one month is necessary for the audit preparation, but this may vary depending on the level of preparation of the company and on the specific situation of the forest entity. Bureau Veritas Certification requires the applicant to notify by mail when appropriate corrective actions have been implemented so that the dates for an initial audit can be set. 5 - Initial audit Initial audit programme At least 2 weeks before the audit, Bureau Veritas Certification provides the applicant with a provisional audit programme that specifies the scope of the assessment as well as a detailed schedule for the evaluation. The proposed schedule is only indicative and can be adjusted prior to or during the audit, so as to minimize disturbance to the company s activities Initial audit The initial audit consists in evaluating the conformity of the applicant company against the requirements of the OLB standard, so as to make a recommendation, either positive or negative, regarding the issuance of a certificate. Bureau Veritas Certification / April published on 27/03/13 Page 9 out of 17

10 Opening meeting Bureau Veritas audits start with a meeting during which the Lead Auditor confirms the scope of the evaluation, presents the procedures for the audit and confirm the schedule of the audit programme together with the applicant entity in order to adjust the program proposed as needed. The presence of the Company s managers and heads of departments is required during this opening meeting so that they can better understand the schedule, objectives and procedures of the audit and can inform relevant staff members The audit s proceeding The activities of the audit team starts with a document review of the Applicant s documented system, followed by field inspections and interviews of employees, outside contributors, and stakeholders representatives. The principal objectives of the initial audit are as follows: To evaluate conformity with the local and international legal requirements; To meet with the stakeholder representatives; To perform an on site visit at the applicant s offices. The audit team carries out an assessment of the company s system in place for ensuring that all its activities are being performed in compliance with legal requirements, from planning, to forest management activities, management of human resources, documentation records and monitoring as described in a management plan. It will also collect detailed and relevant information on site. To evaluate conformity of the forests and meet the site managers (workers, markers, forest wardens, woodmen, skidders, subcontractors, and so on). To report on the non-conformities identified and present them to the forest entity managers and the staff concerned Synthesis meeting At the end of each audit day, meetings are organized by Bureau Veritas audit team to sum up the audit progress and synthesize the first audit results. The non-conformities identified during the day are analyzed and presented to the Applicant to ensure that the nonconformities identified are clearly understood. Bureau Veritas Certification / April published on 27/03/13 Page 10 out of 17

11 Closing meeting The Lead Auditor organizes a closing meeting at the end of the audit. If possible, the closing meeting should involve the same people as those who were present at the opening meeting. The closing meeting allows Bureau Veritas team to present the audit results and its conclusions, as well as handing in the nonconformity reports. The Lead Auditor shall print the nonconformity reports and ask the applicant to sign them to show that the audit results have been understood and accepted. A copy of the nonconformity reports signed by both the applicant and lead auditor shall be given to the applicant. The audit team produces a temporary initial audit report with a clear recommendation and submits it to the Bureau Veritas technical manager for revision Draft audit report revision After revision, Bureau Veritas Certification submits the initial audit report for comments to the applicant entity. Only after having received the comments from the applicant and after Bureau Veritas Certification technical manager has taken an incorporated the Applicant s comments, the certification decision can be taken by Bureau Veritas. 6 - Non-conformities and corrective actions Non-conformities The nonconformities identified during the audit are presented and commented to the applicant by the Lead Auditor. The company can then provide additional information required to demonstrate conformity, if available. The non-conformities shall always meet the 3 following criteria: Be objective and motivated by failure to meet a specific standard requirement. Be based on facts and documented evidence. Be understood and accepted by the Applicant. According to their importance, non-conformities can be raised as minor corrective actions requests or major corrective actions requests. Bureau Veritas Certification / April published on 27/03/13 Page 11 out of 17

12 6.2 - Corrective actions There are two types of corrective action: Minor corrective actions requests (minor CAR): the entity can be certified but it must demonstrate conformity with the standard s requirements within 12 months following the initial audit and at the latest before the following surveillance audit; Major corrective actions requests (major CAR): the entity cannot be certified as long as the major nonconformity has not been corrected. A complementary audit focused on an evaluation of the major nonconformity and corrective actions implemented shall take place before any certification decision. If a major nonconformity is detected during a surveillance audit, the applicant entity shall demonstrate that the nonconformity has been addressed within a relatively short time frame (maximum of three months). Observations can also be presented: Observations: remarks concerning either dysfunctions, or a threat which is not dealt with by the standard, or potential improvements detected by the auditors, but for an element which, however, meets the standard requirements. The entity can be certified but it has to take into consideration the weakness highlighted; The entity can propose a corrective action plan, if it wishes to do so, and send it to Bureau Veritas auditors and Technical manager so as to have it approved before implementation. Nonetheless, the Applicant can also start implementing corrective actions to solve the nonconformities as soon as the nonconformity reports have been signed. The original nonconformity reports must be filled in by the Company with a description of the corrective action implemented and returned to the Lead Auditor. The actions taken will be assessed and validated during the following surveillance/complementary audit by the auditors and the Bureau Veritas Certification Technical manager. 7 - Certification Certification decision The certification decision is made by the Wood and Forestry Department Manager based on the audit findings as reported in the final audit report and after having received evidence that all major nonconformities have been closed and that the company is in conformity with the standard requirements. Bureau Veritas Forest Certification Committee meets once a year and all OLB certificates are submitted for evaluation and comments in order to improve Bureau Veritas performance. Bureau Veritas Certification Committee is made of personalities from all fields related to certification and responsible forest management (environmental and social NGOs, associations, companies, etc). The role of the Committee is to ensure the performance, integrity and credibility of Bureau Veritas Certification Wood and Forestry Department s system. Bureau Veritas Certification / April published on 27/03/13 Page 12 out of 17

13 7.2 - Awarding of certificate Following a positive certification decision, the certification is granted for a period of five years. A certificate number is awarded to the applicant entity which becomes a certified organization. The company can then use the OLB trademark - while respecting the conditions of use and after validation by Bureau Veritas Certification. Bureau Veritas Certification prepares a public summary (general and non confidential data) of the certification process with the certification decision and date of certification. This public summary will be submitted for two weeks to the applicant for validation, and will be published on Bureau Veritas website. 8 - List of documents to be provided for application For the audit team to prepare the first assessment and, in some cases to provide a personalized service, the applicant forest entity shall transmit to Bureau Veritas Certification, at the time of the official application, the following elements: For an individual application for certification large scale map showing location of the forests (map excerpt at minimum 1:25,000); forest cartography, presenting if possible the road systems and stream network; valid forests management document (such as a management plan); documented procedures dealing with the management of environmental and social aspects, for example: identification of remarkable sites, sensitive zones, protected species; environmental and social impact surveys, chemical agents use; stakeholders consultation It can be the management document or an appendix if these elements are not dealt with in the management document; Any documented procedures developed specifically for OLB certification, for example: OLB products monitoring or traceability procedures in the forest entity, personnel training documents, specifications, post sheets, good practices guide, procedures to be implemented For an application for group certification Group certification concerns forest entities, legally independent from one another, situated within the same country, and which certification conformity will be managed by a Group Entity. This Group Entity may have different level of responsibility in the implementation of the certification requirements, but will always be responsible for the compliance against the OLB standard for the whole group. Bureau Veritas Certification / April published on 27/03/13 Page 13 out of 17

14 Entities wishing to implement a group certification must apply the requirement describe in the RF03 OLB Multi-site. The entities will be requested to send at the application stage its documented system and procedures, including the group s management and monitoring procedures, agreements between the Group Entity and the Forest Owner/Manager and all documents and procedures related to the management of the group. For a group certification application, it is preferable to contact Bureau Veritas Certification before sending the application List of documents to be prepared for the first audit After having sent the documents indicated in section 8.1, and once the application has been accepted by Bureau Veritas, some documents will have to be prepared and to be available to the audit team in order to proceed with the first audit (pre-audit or initial audit) : Records of stakeholder consultation process ; information relating to environmental, social and landscape constraints; relevant elements related to the loggers, contractors or other forest workers; any information concerning the land rights and land uses (mandates, leases, uses, legal constraints...); records of volumes (in round timber equivalent if there was a transformation) of timber harvested by the forest entity, volumes of timber sold by the forest entity and turnover during the last three years List of information and documents to be available to the public Within the scope of certification, certain elements must be made public. That requirement applies as soon as the forest entity receives a certificate: name and address of the forest entity; certificate number; scope of the certificate; last name and first name of the person to be contacted within the scope of the certification; the OLB public summary: which is a summary of the report without any confidential information. Bureau Veritas Certification / April published on 27/03/13 Page 14 out of 17

15 9 - Management of disputes related to the certification process Bureau Veritas Certification developed within the scope of the OLB certification system, a process based on consultation and cooperation with third parties. Cooperation shall be based on the forest entity s information and consultation processes required at the different stages of the certification process, but also through the consultation of all the stakeholders being impacted by or having a relation with the forest management activities. These consultation with third parties and relevant stakeholders ensure that the risk of disputes and complaints is minimized. Nevertheless, if a conflict appears within the scope of a certification process, Bureau Veritas Certification has developed and implements disputes resolution procedures to ensure maximum independence and according to the following principles: Bureau Veritas Certification will ensure that everything is done to solve the conflict in a professional and satisfactory manner for all parties involved. When the conflict concerns a certification decision, Bureau Veritas Certification Committee is involved in the resolution Maintenance of a OLB Certificate Surveillance audits Surveillance audits will take place at least annually but may be more frequent depending on the complexity of the operation and of the certificate holder s level of conformity, and on the time needed to resolve the non-conformities detected. In addition to the normal annual surveillance audit, Bureau Veritas Certification may carry out unannounced audits of the certified organization or follow-up audits in order to ensure that the non-conformities detected have been addressed and resolved in due time Surveillance audits allow Bureau Veritas to monitor: The conformity of the organisation as assessed during the initial audit; The implementation of corrective actions to address minor non conformities and eventual recommendations; The correct use of the OLB trademark by the certified organization After each surveillance audit, the public summary will be updated with the new observation and findings made during the audit. This summary will be sent for comments to the company for two weeks. The report will be published once it has been validated by the company. If Bureau Veritas Certification identifies significant nonconformities leading to one or several major corrective action requests during the period of validity of the certificate (maximum 5 years), the company is given a specific timeline determined by Bureau Veritas audit team Bureau Veritas Certification / April published on 27/03/13 Page 15 out of 17

16 (3 months maximum) to implement the necessary corrective actions. At the end of that period, a complementary audit is carried out (through a document review and/or field audit). Depending on the outcome of this new evaluation, the certificate is maintained or suspended for a period of time which will allow the company to correct the identified nonconformity(ies) and achieve compliance. Each year, the certified organization shall provide Bureau Veritas Certification with the list of the products harvested from the certified forests and sold. The organization specifies the species, the type and volume of products sold and the name, address and contact details of the clients. This information should allow Bureau Veritas to follow the OLB products after the transfer of property Extension of Certificate Certificate extension can be requested to review and extend the scope of a certificate: a forest owner or manager wishing to include new forests or new forest plots to the field of application of his certificate, or, a manufacturer or a dealer wishing to include new units to the field of application of his certificate. In any case, an extension audit must be performed to cover the new scope, comparable to the initial audit, and includes an evaluation of all the new elements added to the certificate, in conformity with the requirements defined in the OLB standard. Based on the audit findings reported in the extension audit report, the extension of scope of the certificate is approved or not through the normal procedure (see paragraph 7 above) Reduction of Certificate Considering the very long periods of application of forest management policies, the OLB certification system does not allow any reduction of the field of application of a certificate. In exceptional circumstances and on the basis of well-documented justification, the Wood and Forestry Department of Bureau Veritas Certification may allow a reduction of the scope of the certificate Renewal Audit At the end of the five years certification period, the certification contract can be renewed. To do so, Bureau Veritas Certification proceeds with a complete new assessment of the certified organization (comparable to the initial audit). Afterwards, the certification process is carried out as indicated in the sections above. Bureau Veritas Certification / April published on 27/03/13 Page 16 out of 17

17 11 - Suspension or withdrawal of the certificate The Bureau Veritas Certification OLB Manager or the Certification committee take a decision to suspend or withdraw a certificate if major non-conformities have been detected and are not addressed within the appropriate timeframe: If the non-conformity is due to an involuntary action, this may justify the maintenance of the certificate. The certificate is maintained subject to the appropriate corrective action(s) being implemented within a specific timeline. If the non-conformity is due to a deliberate action of the company, it may result, depending on the seriousness of the nonconformity, a temporary suspension or a definitive withdrawal of the certificate. In case of a serious failure to comply with the requirements of the OLB standard or the OLB label s condition of use, Bureau Veritas Certification can decide to suspend the certificate temporarily. In case of suspension, the certified company has one week to appeal the decision and provide additional information or clarification if relevant. In order to lift a suspension, a complementary audit (through a document review or a field audit) shall take place in order to check the implementation of appropriate corrective action to address the nonconformities identified. If appropriate corrective action requests have not been implemented and conformity cannot be demonstrated, then the certificate is withdrawn. A certificate cannot remain suspended for more than two years. In case of suspension or withdrawal of the certificate, the entity shall cease any use of the OLB trademark, or to sell any products that the supplier has previously labelled or marked using the OLB trademark, or to make any claims that imply that they comply with the OLB requirements and shall remove all OLB trademark uses within 12 months after the termination of the certificate at its own expenses. The company shall formally inform Bureau Veritas Certification when this has been done. Bureau Veritas Certification / April published on 27/03/13 Page 17 out of 17

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