Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global

Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global

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Conformity assessment of the Uruguayan Forest Certification Scheme against the requirements of the PEFC Council ITS Global Final Report 20 October 2010

Conformity assessment of the

Uruguayan Forest Certification

Scheme against the requirements

of the PEFC Council

ITS Global

Final Report

20 October 2010

ITS GLOBAL

International Trade Strategies Pty Ltd, trading as ITS Global

Level 26, 35 Collins Street, Melbourne, 3000

Tel: (61) 3 9654 8323

Fax: (61) 3 9654 4922

http://www.itsglobal.net

Commercial-in-confidence. The views expressed in this publication are those of its authors. The consultant takes no

liability for commercial decisions taken on the basis of information in this report. The information is accurate to the

best of the consultant’s knowledge, however the consultant advises that no decision with commercial implications

which depends upon government law or regulation or executive discretion should be taken by any person or entity

without that party’s having secured direct advice from the government agency concerned in writing.

Evaluation and assessment of Uruguayan Forest Certification scheme against the requirements of the PEFC Council

Preface

The Programme for the Endorsement of Forest Certification Schemes Council (PEFCC) engaged

ITS Global on 14 April 2010, to evaluate and assess the Uruguayan Forest Certification Scheme

(UFCS) against requirements of the PEFC Council.

The UFCS was submitted for assessment to the PEFCC by President (Dr Gerardo Barios) and Vice-

President (Dr Alvaro Molinari) of PEFC Uruguay on 8 January 2010.

This conformity assessment report has been prepared consistent with PEFCC’s guidelines in

PEFC Council Technical Document 6/2007 (Content of the Consultant’s Assessment Report for

Forest Certification Schemes). The following report details the findings of the evaluation, public

comments and field visit, identifying areas of compliance and non compliance with PEFC

requirements.

Contact details for Consultants:

Mr Zak Levick

Dr Bob Smith

ITS Global

(International Trade Strategies P/L)

Level 1, 34 Queen Street

Melbourne VIC 3000 Melbourne VIC 3000

Australia

z.levick@itsglobal.net

bobsmith12@ozemail.com.au

Ph: +61 – 418 648 228

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Contents

Preface ............................................................................................................ 3

Contents ........................................................................................................... 4

Acronyms .......................................................................................................... 6

Executive Summary .............................................................................................. 7

Recommendation to PEFC Council Board of Directors ................................................. 7

Summary of findings ......................................................................................... 7

1. Introduction ................................................................................................... 9

Scope of assessment ......................................................................................... 9

Assessment process and methodology for Report ...................................................... 9

2. History and Structure of the Uruguayan Forest Certification Scheme (UFCS) .................... 10

2.1 Development of Sustainable Forest Management Standard ..................................... 10

2.2 Organisational structure of UFCS .................................................................... 12

2.3 Documentation .......................................................................................... 12

3. Assessment of the standard setting process for UFCS against PEFCC requirements ............. 14

3.1 Standard setting process for forest management certification ................................ 14

3.1.1 Independence...................................................................................... 14

3.1.2 Participatory process ............................................................................. 15

3.2 Standards for chain of custody certification ....................................................... 20

3.3 Pilot testing .............................................................................................. 20

3.4 Review of standards .................................................................................... 21

3.4.1 Periodic review .................................................................................... 21

4. Assessment of the implementation of UFCS against PEFCC requirements ........................ 23

4.1 Criteria for forest certification ...................................................................... 24

4.1.1 General requirements ............................................................................ 24

4.1.2 Other requirements for forest management criteria ....................................... 24

4.1.3 Laws and regulations ............................................................................. 25

4.1.4 International Labour Organization (ILO) conventions ...................................... 25

4.1.5 Other international conventions ............................................................... 26

4.2 Level of application and implementation (Annex 3, 4) .......................................... 26

4.2.1 General ............................................................................................. 26

4.2.2 Regional Certification ............................................................................ 27

4.2.3 Group Certification ............................................................................... 27

4.2.4 Individual Certification .......................................................................... 29

4.2.5 Implementation of changes to the scheme................................................... 29

4.3 Appeals, complaints and dispute procedures (Annex 3, 6) ...................................... 29

4.4 Overall Assessment ..................................................................................... 30

5. Assessment of UFCS forest management standards against PEOLG ................................ 31

5.1 Assessment Framework ................................................................................ 31

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5.2 Compatibility of the UNIT 1152: 2009 Standard with PEOLG ................................... 31

5.2.1 Criterion 1 – Maintenance and appropriate enhancement of forest resources and their

contribution to global carbon cycles .......................................................... 31

5.2.2 Criterion 2 – Maintenance of forest ecosystem health and vitality ...................... 32

5.2.3 Criterion 3 – Maintenance and encouragement of productive functions of forests

(wood and non-wood) ............................................................................ 34

5.2.4 Criterion 4 – Maintenance, conservation and appropriate enhancement of biological

diversity in forest ecosystems .................................................................. 35

5.2.5 Criterion 5 – Maintenance and appropriate enhancement of protective functions in

forest management (notably soil and water) ................................................ 36

5.2.6 Criterion 6 – Maintenance of other socio-economic functions and conditions ......... 37

5.7 Overall assessment ..................................................................................... 38

6. Assessment of UFCS chain of custody standard against PEFCC requirements .................... 39

7. Assessment of the logo usage rules against PEFCC requirements ................................... 40

8. Assessment of UFCS certification and accreditation arrangements against PEFCC requirements

..................................................................................................................... 41

8.1 Certification bodies .................................................................................... 41

8.1.1 Competence of certification bodies ........................................................... 41

8.1.2 Auditors ............................................................................................. 42

8.2 Certification procedures .............................................................................. 42

8.3 Accreditation ............................................................................................ 44

8.4 PEFC Notification of Certification Bodies .......................................................... 45

8.5 Overall Assessment ..................................................................................... 45

Annex 1. Comments submitted to ITS Global during public consultation period .................... 47

Annex 2. Report on the field visit ........................................................................... 48

Annex 3. PEFC Council minimum requirements checklist ............................................... 51

Annex 4. Panel of Expert Review 71

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Acronyms

Chain of custody

CoC

Convention on Biological Diversity

CBD

General Document

GD

Instituto Uruguayo de Normas Técnicas

UNIT

International Accreditation Forum

IAF

International Electrotechnical Commission

IEC

International Organisation for Standardisation

ISO

International Labour Organization

ILO

Memorandum of Understanding

MOU

National Governing Body

NGB

Non-government Organisation

NGO

Not applicable

NA

Pan European Operational Level Guidelines for Sustainable Forest Management PEOLG

Programme for Endorsement of Forest Certification Schemes

PEFC

Programme for Endorsement of Forest Certification Schemes Council

PEFCC

Quality Management Systems

QMS

Specialized Technical Committee on Sustainable Forest Management

STC-SFM

Sustainable Forest Management

SFM

Systems Document

SD

Uruguayan Forestry Certification Scheme

UFCS

Uruguayan Organisation of Accreditation

OUA

Uruguayan Society of Forestry Producers

SPF

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Executive Summary

Recommendation to PEFC Council Board of Directors

The Uruguayan Forest Certification Scheme (UFCS), as presented by PEFC Uruguay on 8 January

2010, together with supporting documentation (refer to 2.3 of this Report), does not meet the

requirements of the Programme for the Endorsement of Forest Certification (PEFC) Scheme.

The UFCS has several incidences of non-conformity, further detailed in parts 1(b), 1(c), 2(b),

5(c) and 5(d) of Summary of Findings.

The consultants consider that the identified non-conformities, with exception of 1(b), do not

hamper creditable and reliable UFCS implementation consistent with PEFCC requirements. The

consultants base this conclusion on detailed commentary included in the body of the following

report. The consultants recommend that PEFCC consider the option of conditional endorsement

of the UFCS, subject to PEFCC approval of the organisational and individual participation

arrangements implemented by Instituto Uruguayo De Normas Técnicas (UNIT) to develop and

approve forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009).

Summary of Findings

The justification for endorsement is based on the following findings:

1. For standard setting processes – initiated by the Uruguayan Society of Forestry Producers

and managed by Instituto Uruguayo de Normas Técnicas (UNIT) - against PEFCC

requirements:

a. Independence processes conform with PEFCC requirements (refer to Section 3.1.1);

b. Participatory processes do not conform to PEFCC requirements. Documentation

presented by PEFC Uruguay and the Instituto Uruguayo De Normas Técnicas (UNIT) does

not provide evidence that environmental non-government organisations were formally

invited to participate in development and approval of forest management standards (as

detailed in Section 3.1.2 and 3.5 of Report);

c. Public consultation processes do not conform to PEFCC requirements. The public

consultation processes implemented by UNIT for final draft of forest management

standards (as detailed in Sections 3.1.2 and 3.5 of Report) was less than 60 days

specified in PEFCC requirements;

d. Pilot testing practices conform with PEFCC requirements (refer Section 3.3);

e. Review of standard documentation conforms to PEFCC requirements (refer to Section

3.4).

2. For implementation of the UFCS against PEFCC requirements:

a. General requirements of the UFCS in areas such as types of forests, management

systems, auditing verification, property and land tenure, and customary and traditional

rights conform with requirements of PEFCC (refer to Sections 4.1.1 and 4.1.2);

b. Documented process for the UFCS do not conform with PEFCC requirements for making

a summary of forest management plan publicly available (as detailed in Section 4.1.2 of

Report);

c. Required compliance with laws and regulations conform to PEFCC requirements (refer

to Section 4.1.3);

d. Level of implementation for individual and group forest certification processes for the

UFCS conform with PEFCC requirements (refer to Section 4.2);

e. Appeals, complaints and dispute procedures documented for the UFCS conform to

PEFCC requirements (refer to 4.3).

3. The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) conform to

PEFCC requirements for compliance with Pan European Operational Level Guidelines for

Sustainable Forest Management (PEOLG) (refer to Section 5).

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4. The chain of custody (utilizes requirements of PEFC Annex 4) and logo use (utilizes

requirements of PEFC Annex 5) arrangements for the UFCS conform to PEFC requirements

(refer to Sections 6 and 7).

5. For certification and accreditation arrangements used by the UFCS:

a. Competencies required for certification bodies conform to PEFCC requirements. (Refer

to Section 8.1.1)

b. Competencies required of auditors conform to PEFCC requirements (Refer to Section

8.1.2).

c. Accreditation arrangements do not conform to PEFCC requirements. Currently there is

no explicit requirement for the accreditation symbol of OUA, the Uruguayan

organisation with authority to accredit certification bodies in the UFCS, to appear on

accredited certificates from certification bodies (refer to Section 8.3).

d. PEFC notification of certification bodies do not conform to PEFCC requirements.

Current UFCS documentation does not include all notification requirements of PEFCC.

(Refer to Section 8.4)

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1. Introduction

In a letter dated 8 January 2010, the President and Vice President of PEFC Uruguay submitted

an application to PEFCC (Programme for the Endorsement of Forest Certification Council) for

the conformity assessment of the Uruguayan Forest Certification Scheme (UFCS).

On 14 April 2010 the PEFCC appointed ITS Global to undertake an independent conformity

assessment of the UFCS against the requirements of PEFCC.

Scope of Assessment

The conformity assessment of the UFCS was undertaken consistent with PEFCC minimum

requirements for national and sub-national schemes as detailed in PEFCC Technical Document,

Annex 7.

Following a summary of the development and evolution of the UFCS (Chapter 2) the report

assesses the conformity of UFCS against the framework relevant to:

• Standard setting process (Chapter 3);

• Implementation levels and organisation arrangement of the certification scheme (Chapter

4);

• Forest management standard (Chapter 5);

• Chain of custody standard (Chapter 6);

• Implementation of the PEFC logo usage rights (Chapter 7);

• Certification and accreditation arrangements (Chapter 8).

The report also includes:

• Evaluation of the comments received from stakeholders resulting from the public

consultation period (Annex 1);

• Intelligence and insight gained from a Field Visit and meeting with stakeholders who have

been involved in the development and/or use of the UFCS (Annex 2);

• PEFCC Minimum Requirements Checklist (Annex 3); and

• Evaluation of the comments from the Panel of Experts (which are provided in Annex 4 of the

• report)

Assessment Process and Methodology for Report

Evidence and assessments detailed in the report are generated by benchmarking PEFCC’s

requirements against the standards, processes and accountabilities detailed in the UFCS’s

application documentation together with documentation and records reviewed during Field

Visit.

The following conformance definitions were applied in assessing the conformity of the UFCS

with requirements of PEFCC:

• Conforms – the criteria and requirements of the UFCS are assessed as equivalent to PEFCC

requirements;

• Partly conforms – the criteria and requirement of the UFCS are assessed as being, in

principle, equivalent to PEFCC requirements but with minor inconsistencies or gaps when

compared to PEFCC requirements;

• Does not conform – the criteria and requirement in the UFCS are assessed as having

substantial differences to the PEFCC requirements;

• Not applicable (NA).

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2. History and Structure of the Uruguayan Forest Certification

Scheme (UFCS)

The development of THE UFCS (a certification scheme for plantation forests) was undertaken in

two parts. The first component was the development – at request of Uruguayan Society of

Forest Producers in 2007 – and approval of forest management standard and chain of custody

standard (CoC) by STC-SFM (Specialised Technical Committee on Sustainable Forest

Management). This component was undertaken between 2007 and 2009, consistent with

processes of Uruguayan Institute of Technical Norms (UNIT).

The second part saw the development of the organisational structures and implementation

processes (including accreditation and certification procedures) for the application of the UFCS

by PEFC Uruguay during 2009.

It is noted that both the certification of forest management standard (covering forest

management and CoC), and organisational processes and implementation procedures were

undertaken with a view to aligning the UFCS procedures and processes with PEFCC

requirements.

2.1 Development of Sustainable Forest Management Standard

The evolution of sustainable forest management standard can be tracked over two phases

between 2006 and 2009.

Phase 1

The first phase commenced in late 2006 when the Uruguayan Institute of Technical Norms

(Instituto Uruguayo de Normas Técnicas, UNIT), at request of Uruguayan Society of Forestry

Producers, committed to developing a sustainable forest management standard for plantations

under the project - “Access to markets and the integration through technical normalization”.

UNIT is the internationally recognised national standardization body responsible for

development of Uruguayan technical standards and guides.

Consistent with their methodologies and internationally recognised processes, UNIT coordinated

the establishment of the Specialized Technical Committee for the Sustainable Forest

Management (STC-SFM) in 2006, with the aim to develop standards for Uruguayan sustainable

forest management and chain of custody. The STC-SFM is the equivalent of standard setting

body in PEFC documentation.

The STC-SFM, as required by UNIT processes, formally requested the participation of 36

individuals and organisations and was constituted with diverse membership including forest

industry, forest growers, academia, technical expert, social interests and environmental

interests (refer to GD05 and www.unit.org.uy).

The STC-SFM - the body solely responsible for the content of forest management standard

(Norm) and operating by consensus (as defined by ISO Guide 2) - utilized the “Conservation of

Temperate and Boreal Forests” (Montreal Process), National (Uruguayan) Code of Good Forest

Practice (2004) and Uruguayan Government forestry policies ratified in 1995, as reference

documents to develop sustainable forest management standard.

The STC-SFM also had the objective of constructing Uruguayan forest management standards in

a format similar to Standard UNE 162002: 2001 (Spanish forest management standard which is

endorsed under the Spanish scheme).

Following their deliberations between 2006 and 2009, the STC-SFM approved the National

(Uruguayan) Norms of Certification for forest management. These Norms included:

• UNIT 1151 (Sustainable Forest Management. Glossary of Terms). This document

specifies the definitions to be applied in Uruguay when applying UNIT 1152 (Sustainable

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Forest Management. Criteria and Indicators). UNIT 1151 was approved by STC-SFM on 24

April 2006 and subsequently approved by UNIT’s General Norm Committee on 10 May

2006.

• UNIT 1152 (Sustainable Forest Management. Criteria and Indicators). This

document specifies the indicators, justifications, objectives and parameters for

evaluating social, environmental and economic outcomes to be delivered from forest

management units for each of the Montreal Process Criteria. The initial edition of UNIT

1152 was approved by STC-SFM on 24 April 2006 and subsequently by UNIT’s Norms

General Committee on 10 May 2006. Following a review by STC-SFM of “Conservation

and maintenance of soil and water resources” (Criteria 4, Item 6.4), a revised edition of

UNIT 1152 was approved by STC-SFM on 18 December 2006 and approved by UNIT’s

General Norm Committee on 7 March 2007.

• UNIT 1153 (Sustainable Forest Management. Chain of Custody). The STC-SFM,

following deliberations on appropriate CoC systems for Uruguay, recommended the use

of the requirements specified in PEFCC Annex 4 (Chain of Custody of Forest Based

Products) for firms seeking CoC certification under the UFCS. This recommendation was

approved by STC-SFM on 18 December 2006 and subsequently approved by UNIT’s

General Committee of Norms on 7 March 2007.

Phase 2

Following the Uruguayan Society of Forestry Producers (SPF) gaining PEFC Council membership

in 2009, and their subsequent endorsement as PEFC National Governing Body for Uruguay, the

Uruguayan Forest Management Standards (UNIT 1151:2006 and UNIT 1152:2006) were placed on

public consultation from 1 April to 23 May 2009 with aim of meeting PEFCC requirements for

public consultation.

The STC-SFM – after considering the five comments resulting from public consultation processes

in April-May 2009 and results of pilot testing - approved a revised edition of UNIT 1151 and UNIT

1152 on 10 December 2009 (refer to GD12 and GD13 respectively). The revised edition of UNIT

1151:2009 and UNIT 1152:2009 were subsequently approved by UNIT’s General Norm Committee

on 14 December 2009 and PEFC Uruguayan General Assembly on 18 December 2009 (refer to

GD05).

As a consequence of the above process, the UFCS comprises of the following scheme specific

sustainable forest management standards:

• UNIT 1151:2009. Sustainable Forest Management. Glossary of Terms.

• UNIT 1152:2009. Sustainable Forest Management. Criteria and Indicators.

For chain of custody certification the UFCS utilizes the requirements of PEFCC’s Annex 4: Chain

of Custody of Forest Based Products.

The consultant’s assessment notes that the original Scheme Documentation submitted by PEFC

Uruguay was incorrectly numbered as UNIT 1151 (2006) and UNIT 1152 (2006) (refer to GD10 and

GD11 respectively).

Revised numbered editions of forest management standards were received following subsequent

discussions with PEFC Uruguay. The revised editions are identified as:

• UNIT 1151: 2009 (Edition 2009-12-15). Sustainable Forest Management – Glossary of

Terms (included as Document GD12),

• UNIT 1152: 2009 (Edition 2009-12-15). Sustainable Forest Management – Criteria and

Indicators (included as Document GD13).

The revised numbered editions represent the documents approved by PEFC Uruguay General

Assembly on 18 December 2009. These documents are consistent with the documentation for

UNIT 1151 (2009) and UNIT 1152 (2009) on UNIT’s website (www.unit.org.uy).

For the purpose of evaluating the conformity of sustainable forest management standard

against PEFC requirements, the (English) edition of UNIT 1151: (2009) (referred to as GD12),

and UNIT 1152 (2009) (referred to as GD13) were used.

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As documented above, the UFCS uses these forest management standards together with PEFCC’s

Annex 4 Chain of Custody and other UFCS documentation as approved by PEFC Uruguay General

Assembly on 18 December 2009.

2.2 Organisational Structure of the UFCS

Concurrent with the finalisation of forest management standards, PEFC Uruguay developed legal

arrangements and organisational structures and processes with purpose of aligning UFCS with

the requirement of PEFCC. PEFC Uruguay General Assembly approved the UFCS (forest

management standards and organisational processes) on 18 December 2009 (refer to GD01).

In a letter dated 8 January 2010 PEFC Uruguay formally submitted documentation for

Conformity Assessment of Revised Uruguay Forest Certification Scheme to PEFCC.

2.3 Documentation

The documents detailed below were used in conducting the conformity assessment. Please note

that the general documentation presented by PEFC Uruguay (no number) has been referenced

as GD documents (including UNIT 1151:2009 and UNIT 1152:2009) by the Consultant while

system documents forming part of PEFC Uruguay’s document register procedures are referred to

as SD documents.

Accordingly, PEFC Uruguay’s forest certification scheme includes the following documentation:

General Documents (GD)

(Note: These documents were not numbered in documentation submitted by PEFC Uruguay)

GD01 Letter of Application for Conformity Assessment by PEFC Uruguay of revised

Uruguayan Forest Certification Scheme (dated 8 January 2010).

GD02 Uruguayan Forest Certification Scheme (UFCS) – PEFC Uruguay (2009).

GD03 Proceedings (18 December 2009) PEFC Uruguay Assembly (undated).

GD04 “Statues” Civil Association – PEFC Uruguay

GD05 Unit Norms about Sustainable Forest Management including Project Process

meetings (6 November 2009).

GD06 Annex 2. SGS – Management System Certification – Audit Report, UNIT 1152

(2006).

GD07

GD08

PEFC Council Minimum Requirements Checklist and Annexes.

UNIT 1151: 2009 – Report Corresponding to Unit Norm 1151: 2006. Sustainable

Forest Management. Glossary of Terms.

GD09 UNIT 1152: 2009 – Report Corresponding to the Norm UNIT 1152: 2009.

Sustainable Forest Management. Criteria and Indicators.

GD10 Institute Uruguayu de Norms Tecnicas; (Amended Version) UNIT 1151: 2006.

Sustainable Forest Management – Glossary of Terms. Reference Number UNIT

1151: 2006.

GD11

GD12

GD13

Amended Version UNIT 1152: 2006. Sustainable Forest Management. Criteria

and Indicators.

UNIT 1151: 2009 (Edition 2009-12-15). Sustainable Forest Management. Glossary

of Terms. (Instituto Uruguayo De Norms Tecnicas).

UNIT 1152: 2009 (Edition 2009-12-15). Sustainable Forest Management. Criteria

and Indicators. (Instituto Uruguayo De Norms Tecnicas).

Please note that documents GD12 and GD13 were not part of original documentation

submitted by PEFC Uruguay.

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System Documents (SD) – PEFC Uruguay

(Note: These documents were referenced as GD documents in PEFC Uruguay documentation)

SD01

SD02

SD03

SD04

SD05

SD06

SD07

SD08

SD09

Current Documents Listing (Register)

Procedure of Elaboration and Control of Documents

Organism (Organisation) of Forest Certification

Criteria for Auditors Qualifications

Use of PEFC Logo in Uruguay

Settlement of Disagreements

Requirements for Group Certification

Standard Setting Process

Chain of Custody

It should be noted that the UFCS also refers to documentation from other sources which are

referenced to support UFCS documentation. This includes:

• PEFCC Statutes, Annexes and Guides

• Institute Uruguayo de Norms Tecnicas’ (UNIT) control procedures and processes

for standard setting (refer to Unit website – www.unit.org.uy)

• Institute Uruguayo de Norms Tecnicas – Estatutos (1945)

• Organismo Uruguayo de Acreditacion’s procedures and processes (refer to

www.organismouruguayodeacreditacion.org)

• ISO 19011: 2002

• ISO Guides 61 and 65

• ISO 17021

• Core International Labour Organisation (ILO) Conventions

• Montreal Process – Criteria and Indicators for the Conservation and Sustainable

Management of Temperate and Boreal Forests

• National (Uruguayan) Code of Good Forest Practice (2004)

In a meeting with Instituto Uruguayo De Norms Tecnicas (UNIT) held during the Field Visit

(detailed in Annex 2), the statutes and standard operating procedures employed by UNIT to

develop and approve technical standards, together with records specific to operation of STC-

SFM (including initial letters requesting participation of organisations, minutes of meetings and

letters to organisations requesting input during public consultation period) were made available

for inspection. UNIT documents were utilized in forming opinions regarding level of conformity

of the UFCS against the requirements of PEFCC.

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3. Assessment of the standard setting process for the UFCS

against PEFCC requirements

An assessment of the rules for standard setting for the UFCS against the requirements for

endorsement and mutual recognition by PEFCC is documented in this Chapter.

3.1 Standard Setting Process for Forest Management Certification

3.1.1 Independence

1) Has the development of the certification standards been independent from the

certification and accreditation processes? (Annex 2, 3.2)

Documentation

The forest certification standards – UNIT 1151: (2009) (GD12) and UNIT 1152: (2009) (GD13)

were developed and approved by Specialized Technical Committee on Sustainable Forest

Management (STC-SFM). The STC-SFM operated consistent with the processes required by

Uruguayan Institute of Technical Norms (UNIT). UNIT is the internationally recognised standards

body for Uruguay (refer to Section 7 of GD02 and www.unit.org.uy).

Accreditation of certification bodies for the UFCS is undertaken by Uruguayan Organisation of

Accreditation (OUA), an organisation independent of UNIT and PEFC Uruguay (refer to SD03,

Section 3a).

Conforms

Practice

The STC-SFM was solely responsible for developing and approving the content of sustainable

forest management standards (UNIT 1151: 2009; and UNIT 1152: 2009).

Consistent with the processes of UNIT, the General Committee of Norms (UNIT) formally

approved the sustainable forest management standard developed by STC-SFM on 14 December

2009 (refer GD03). PEFC Uruguay adopted the forest management standards approved by UNIT

at meeting on 18 December 2009.

Conforms

2) Has the standard setting process been carried out at national and/or sub-national

levels? (Annex 2, 3.3)

Documentation

The standard setting process was carried out at national level (refer to GD02).

Conforms

Practice

The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) are applied for all

plantation forests applying for certification under the UFCS (refer to GD02).

Conforms

3) Has the standard setting process been co-ordinated by the PEFC National Governing

Body? (Annex 2, 3.3)

Documentation

The standard setting process was initiated by predecessor to PEFC Uruguay but developed and

approved by STC-SFM consistent with technical standard setting processes required by UNIT. On

the 18 December 2009 PEFC Uruguay approved the forest management standards adopted by

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Norms General Committee (UNIT) on 14 December 2009. On the basis of these arrangements it

is assessed that PEFC Uruguay co-ordinated the standard setting process (refer to GD02 and

GD03).

Conforms

Practice

The forest management standards developed by STC-SFM were approved by UNIT’s General

Committee of Norms on 14 December 2009 and subsequently adopted by PEFC Uruguay on 18

December 2009 (refer to GD02 and GD03).

Conforms

4) Has the certification standard been drafted to be applied at individual and/or group

and/or regional level? (Annex 2, 3.3)

Documentation

The UFCS provides for individual certification and group certification (refer to GD02).

Conforms

Practice

The UFCS has not been implemented to date.

Not applicable

5) Has the development of certification criteria been initiated by national forest owners’

organisations or national forestry sector organisations having support of the major forest

owners’ organisations in that country? (Annex 2, 3.4.1)

The UFCS was initiated by a request to UNIT from Uruguayan Society of Forestry Producers, an

organisation with membership representing over 90 percent of forest plantation owners in

Uruguay to develop a sustainable forest management standard for plantations. UNIT, consistent

with their procedures, subsequently established the Project “Access to markets and the

integration through technical normalization” to manage the standard development process.

Conforms

3.1.2 Participatory Process

6) Have all relevant interested parties representing the different aspects of sustainable

forest management been invited to participate in the standard setting process and a

created Forum? (Annex 2, 3.4.1)

Documentation

The STC-SFM, as required by UNIT processes, was appointed consistent with requirements of

ISO/IEC Directive Part 1 (Standard Development, Process and Procedures).

Consistent with UNIT operating procedures, the STC-SFM was formed in 2006 with a diverse

range of institutions and individuals requested to participate (refer to GD02, Section 7 for list of

organisations and individuals asked to participate).

Invitations, as required by UNIT processes, covered economic, social and environmental

interests in Uruguay, including forest owners, forest industry, government (environmental,

agricultural and forestry agencies), non-government organisations (such as Asociacion National

de ONG-ANOG), academia and unions. This was confirmed by a review of letters of invitation to

participate on the STC-SFM and minutes of meetings of STC-SFM as well as discussion with

relevant stakeholders held during Field Visit.

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Notwithstanding the diverse range of institutions and individuals requested to participate, the

documentation presented by PEFC Uruguay and UNIT does not demonstrate that environmental

non-government organisations (ENGOs) were asked to formally participate in the work of STC-

SFM.

Does not Conform

Practice

In establishing the STC-SFM, UNIT formally invited 36 organisations and individuals -

representing social, economic and environmental interests in Uruguay - to participate in

standard setting process. The list of institutions and individuals invited to participate in STC-

SFM is maintained by UNIT, and was sighted by the consultants during Field Visit.

However, as noted above, from the information presented by UNIT and PEFC Uruguay there is

no evidence to support a conclusion that environmental non-government organisations (ENGOs)

were invited to participate in work of STC-SFM.

Does not Conform

7) Do consensus-building procedures of the Forum provide for balanced representation of

interest categories? (Annex 2; 3.4.1)

Documentation

The STC-SFM, as required by UNIT’s processes, seeks to achieve consensus amongst the

participants and interest groups consistent with the framework specified by ISO Guide 2 (refer

to GD05 and SD08).

Conforms

Practice

The minutes of STC-SFM meetings between 2006 and 2009 (maintained by UNIT) provide

evidence that STC-SFM operated by consensus.

Conforms

8) Have the views of all relevant parties been documented and considered in an open and

transparent way? (Annex 2, 3.4.1)

Documentation

Procedures for operation of STC-SFM require the views of all members to be documented and

considered in an open and transparent manner (refer to SD08).

Conforms

Practice

A review of STC-SFM minutes of meetings (maintained by UNIT) during Field Visit and discussion

with participants in STC-SFM indicates the views of all members were documented and

considered in open and transparent manner. (Refer to Annex 2, Section 3)

Conforms

9) Has the formal approval of standards been based on evidence of consensus? (Annex 2,

3.4.1)

Documentation

UNIT operating procedures, which are consistent with requirements of ISO/IEC Directive Part 1,

require the STC-SFM to formally recommend forest management standards based on consensus

outcomes for UNIT’s formal approval (refer to GD09 and SD08).

Conforms

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Practice

PEFC Uruguay on 18 December 2009 formally adopted without change the forest management

standards approved by UNIT’s Norms General Committee 14 December 2009 (GD02 and GD13,

Section 4).

Conforms

10) Does the implementation of the consensus based approach comply with Guideline GL

5/2006?

Documentation

The STC-SFM, consistent with UNIT’s standard setting processes (refer to www.iso.org for

standard development processes and procedures implemented by UNIT), is required to make

decisions by consensus consistent with intent of ISO Guide 2 and Guideline GL 5/2006.

Conforms

Practice

The minutes of meetings of STC-SFM between 2006 and 2009 (retained electronically by UNIT

and reviewed on Field Visit) provide evidence that STC-SFM made decisions based on consensus

(consistent with intent of Guideline GL 5/2006) during the development and approval of

sustainable forest management standards.

Conforms

11) Has the Forum defined its own written procedures which have been made available to

interested parties on request? (Annex 2, 3.4.1)

Documentation

The procedures of STC-SFM (the Forum) are documented by UNIT. Procedures are available to

interested parties on UNIT’s website www.unit.org.uy (refer GD03).

Conforms

Practice

The STC-SFM followed the documented procedures specified by UNIT in developing and

approving forest management standards.

Conforms

12) Do the written procedures for standard setting contain an appeal mechanism for

impartial handling of any substantive and procedural complaints? (Annex 2, 3.4.1)

Documentation

UNIT statutes (Estatutos, 1945) detail appeal procedures for the impartial handling of

complaints submitted in relation to STC-SFM’s standard setting procedures.

Conforms

Practice

If UNIT or STC-SFM had received complaints regarding the standard setting issues, the process

specified by UNIT statutes would have been implemented.

Conforms

13) Has the start of the standard setting process been communicated to the public? (Annex

2, 3.4.2)

Documentation

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UNIT’s procedures require the commencement of standard setting process be communicated by

placing information of commencement of Project on UNIT’s website supplemented by press

release.

Conforms

Practice

The commencement of standard setting process was communicated to the public by UNIT

announcement on their website of Project “Access to markets and the integration through

technical normalization” in 2006. This is UNIT’s standard operating practice.

Conforms

14) Has the information on the development process been distributed and discussed?

(Annex 2, 3.4.2)

Documentation

The development process for standard setting used by UNIT require the STC-SFM to conduct its

work consistent with rules and processes specified by UNIT. UNIT’s processes require standard

development processes to be undertaken consistent with ISO/IEC Directives, Part 1 (SD08).

Conforms

Practice

UNIT distributed information via its website on the standard setting development process.

Members of the STC-SFM interviewed during Field Visit stated that UNIT explained and discussed

the processes required to be implemented in developing and approving the SFM standards.

Conforms

15) Has the final draft standard been available to all interested parties, e.g. by posting it

on the internet? (Annex 2, 3.4.2)

Documentation

The final drafts of UNIT 1151:2009 (Sustainable Forest Management. Glossary of Terms) and

UNIT 1152:2009 (Sustainable Forest Management. Criteria and Indicators) were approved by the

General Norms Committee of UNIT in May 2006 and March 2007 respectively. They were made

available on UNIT’s website (www.unit.org.uy/gfs) during public consultation period (April/May

2009) (refer to GD02 and GD05).

Conforms

Practice

The final draft standard was available on UNIT’s web-site from 1 April 2009 to 28 June 2009.

Conforms

16) Has the final draft standard been sent out for a formal national consultation process?

(Annex 2, 3.4.3)

Documentation

With the purpose of meeting PEFCC requirements the final draft standards (UNIT 1151:2006 and

UNIT 1152:2006) were made available for public review and comment from 1 April to 23 May

2009 with public notification via UNIT’s website and print media advertisements (refer to

GD05).

Conforms

Practice

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Formal national consultation was undertaken between April and May 2009 (refer to GD02, GD05,

GD12 and GD13).

Conforms

17) Have the views of interested parties been discussed? (Annex 2, 3.4.3)

Documentation

Standard setting rules require the views of interested parties to be discussed (SD08).

Conforms

Practice

The STC-SFM documented and considered the submissions received from five organisations

generated by public consultation processes at three meetings held in October 2009. The revised

editions of UNIT 1151:2009 and UNIT 1152:2009 were finalised after consideration of these

comments. The revised STC-SFM standards were approved by UNIT’s Norms General Committee

on 14 December 2009 (refer to GD01, GD05, GD12 and GD13).

Conforms

18) Has the Forum given general information on the changes made as a result of a

consultation process? (Annex 2, 3.4.3)

Documentation

UNIT’s rules and operating processes require that STC-SFM maintain records of all changes to

standards as they develop. This information is held by UNIT and is publicly available.

Conforms

Practice

The STC-SFM documented in minutes of meetings the changes made to final draft versions of

forest management standards (UNIT 1151:2009 and UNIT 1152:2009) emanating from results of

consultations and results of pilot testing programs in second half of 2009 (refer to GD05).

Conforms

19) Had the consultation process been at least 60 days? (Annex 2, 3.4.3)

Documentation

UFCS documentation does not explicitly state the consultation process will span at least 60

days. However documentation (GD02 and SD08) does state the standards will be developed in

accordance with PEFC requirements. PEFC requirements specify a 60 day consultation period.

Conforms

Practice

Formal consultation process for UNIT 1151:2009 and 1152:2009 was from 1 April to 23 May 2009,

a period of 53 days (refer to GD03). Discussions with UNIT executives during the Field Visit

indicated that it was planned to place media advertisements covering 60 day period required by

PEFCC consultation process. However media advertisements were incorrectly placed reducing

the period to less than 60 days.

Although the media notification for consultation was less than 60 days it is noted that final

drafts of UNIT 1151:2009 and UNIT 1152:2009 were available on UNIT’s website from 1 April

2009 to 28 June 2009. The media notification referred interested persons to this website.

It is also noted that STC-SFM did not consider the issues raised from submissions received

following public consultation until October 2009, a period of over 3 months from withdrawal of

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final drafts of standards on UNIT’s website. Consequently there would have been time for STC-

SFM to incorporate any late submissions on standards in their deliberations.

Does not conform

3.2 Standards for Chain of Custody Certification

PEFC Uruguay, on the advice of UNIT, adopted the PEFCC’s Technical Document Annex 4 as the

system for CoC certification under the UFCS on 18 December 2009 (refer to GD01, GD02 and

SD09).

Conforms

3.3 Pilot Testing

35) Have the first results on the testing of the final drafts for national/sub-national forest

certification standards and their implementation arrangements been available prior to

submission of the scheme for the PEFC Council endorsement and mutual recognition?

(Annex 2, 5)

Documentation

UFCS documentation (refer to GD02) states that a validation audit of implementation

arrangements for UNIT 1151:2006 and UNIT 1152:2006 was undertaken by SGS in February 2009.

The SGS audit used UNIT 1151 (2006) and UNIT 1152 (2006) as reference. Results of the audit

are included in GD06.

Furthermore, GD02 states that Forestry Department of Faculty of Agronomy (University of

Uruguay) undertook a document and field audit of UNIT 1152: 2006. This work was undertaken

in March/April 2009.

The results of audit were available to STC-SFM prior to submission of the UFCS by PEFC Uruguay

to PEFCC.

Conforms

Practice

Based on documentation presented during Field Visit it was observed that UNIT 1151 (2006) and

UNIT 1152 (2006) were subject to three pilot tests. These included the two pilot tests sighted

above, plus a third pilot audit by a consultant in May 2009 focusing on verification of

documentation and implementation arrangements for draft forest management standards. The

results of third audit were sighted during Field Visit.

The experiences learnt from three pilot tests were available and used by STC-SFM in

determining final edition of UNIT 1151: 2009 (refer to GD12) and UNIT 1152: 2009 (refer to

GD13).

Conforms

36) Has appropriate action been taken to incorporate improvements and recommendations

prior to submission of the scheme for the PEFC Council endorsement and mutual

recognition process? (Annex 2, 5)

Documentation

Minutes of STC-SFM deliberations during the second half of 2009 (electronically retained by

UNIT) demonstrate that STC-SFM incorporated the findings of pilot testing in the final approved

standard for sustainable forest management, namely UNIT 1151:2009 (GD12) and UNIT

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1152:2009 (GD13). Changes were made in areas of community recognition and engagement, soil

and water management, landscape and protected lands.

Conforms

Practice

Refer to above response.

Conforms

3.4 Review of Standards

3.4.1 Periodic Review

37) Have the standards on forest and chain of custody certification been reviewed at least

every 5 years or it is foreseen to review these standards at least every 5 years? (Annex 2,

6.1)

Documentation

UFCS documentation (SD08 and GD02) requires that forest certification standards and

implementation arrangements must be reviewed at least every five years.

For chain of custody certification the UFCS has adopted PEFCC Annex 4 requirements and it will

be PEFCC’s responsibility to review this standard.

Conforms

Practice

Not applicable at this time.

Not applicable

38) Does the scheme documentation indicate which organisation is responsible to initiate

the revision work? (Annex 2, 6.1)

Scheme documentation specifies that PEFC Uruguay is responsible for initiating required

revisions (refer to GD02, Section 7).

Conforms

39) Has the revision procedures been participatory, fair and transparent? (Annex 2, 6.1)

Not applicable at this time as this is the initial assessment for mutual recognition.

Not Applicable

40) Has the PEFC National Governing Body appropriately considered the revisions of the

general PEFC requirements for standard setting and implementation in the national

standards? (Annex 2, 6.2)

Not applicable at this time as this is the initial assessment for mutual recognition.

Not Applicable

41) Has the PEFC National Governing Body indicated to the PEFC Council the appropriate

considerations of the revisions induced by the PEFC Council in national standards? (Annex

2, 6.2)

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Not applicable at this time as this is the initial assessment for mutual recognition.

Not Applicable

3.5 Overall Assessment

The standard setting process for UFCS does not meet PEFC Scheme requirements due to nonconformities

associated with i) a lack of evidence to demonstrate environmental nongovernment

organisations were formally invited to participate in work of STC-SFM; and ii) the

public consultation process for the final draft spanning a period of less than 60 days. Additional

commentary is presented below to assist in evaluating the significance of these nonconformities.

The first assessed non-conformity relates to the lack of evidence indicating environmental nongovernment

organisations were invited to participate in deliberations of STC-SFM. As noted in

Field Visit Report (Annex 2) the umbrella ENGO in Uruguay is ‘Group Guayubira’

(www.guayubira.org.uy) which strongly advocates a policy of no expansion of introduced and/or

monoculture forest plantations in Uruguay. While Group Guayubira or other environmentally

focused non-government organisations did not formally participate in deliberations of STC-SFM,

it is noted that many specific issues of concern to ENGOs were discussed and addressed during

the development of forest management standards. It is also noted that representatives of

Department of Environment (Uruguay) formally participated in deliberations and approvals of

forest management standards.

On a procedural point the processes used to develop forest management standards (UNIT 1151:

2009) and UNIT 1152: 2009) were approved by UNIT - the internationally recognised national

standardization body for developing technical (national) standards in Uruguay.

The second non-conformity relates to the announced public consultation process for final draft

of forest management standards (UNIT 1151: 2006 and UNIT 1152: 2006) co-ordinated by UNIT

spanning a period of 53 days (1 April 2009 to 23 May 2009). This is less than the 60 days

consultation period specified by PEFCC (refer to Question 19). The intent of PEFC Uruguay and

UNIT was that the formal public consultation period was to be a period of 60 days to meet

PEFCC requirements. The reduced public consultation process occurred due to

miscommunication in placing media advertisements for period of public consultation.

As noted in the response to Question 19, the final draft of forest management standards were

available on UNIT’s website from 1 April 2009 to 28 June 2009. Furthermore, letters informing

organisations of public consultation for UNIT 1151: 2006 and UNIT 1152: 2006 were forwarded

by UNIT on behalf of STC-SFM.

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4. Assessment of the Implementation of the UFCS against PEFCC

Requirements

Performance requirements for the UFCS are detailed in PEFC Uruguay system documents (SD01

to SD09) and GD02.

The UFCS provide for:

• Individual Forest Certification for a person or legal entity (organisation) acting as

Applicant Entity for forest areas that the applicant manages and voluntarily seeks to

include in the certification process; and

• Group Forest Certification for forest managers who form a group through a legally

constituted Association which is designated as the Applicant Entity. The UFCS also

provides for forest managers to be grouped through a legally documented agreement

with designated person(s) acting as an Applicant Entity.

The requirements for Group Forest Certification are detailed in document SD07. The

requirements for Individual Forest Certification are specified in Document GD02 (Section 5.1).

The implementation of the UFCS requires the Applicant Entity applying for Forest Management

Certification to construct a Forest Management System (referred to as SD03, Section 5.4). The

Forest Management System should detail the policies, organisational structure and processes

the Applicant Entity is implementing in forests and/or chain of custody to demonstrate

compliance with requirements of the UFCS.

The Forest Management System also incorporates a requirement for General Plan of

Management for forest management units undertaking certification. The General Plan of

Management must be constructed consistent with the concept of Sustainable Forest

Management, “seeking a balance between the conservation of the natural resources, historiccultural

and socio-economic aspects, productivity (technical, economic and financial) and the

general society’s well being”. UFCS documentation details the economic, social and

environmental goals to be addressed in General Plan of Management. (Refer to GD13, Section

4).

The standard (Norm) for sustainable forest management under the UFCS is UNIT 1152: 2009

(refer to GD13)(Sustainable Forest Management. Criteria and Indicators) and supported by UNIT

1151: 2009 (Sustainable Forest Management. Glossary of Terms) (referred to GD12). These were

approved by PEFC Uruguay General Assembly on 18 December 2009. The Norm UNIT 1152: 2009

is based on the Montreal Process (“Criteria and indicators for the conservation and sustainable

management of temperate and boreal forests”), the National (Uruguayan) Code of Good

Forestry Practices (2004) and other Uruguayan legislative and regulatory requirements for

conducting forestry activities.

The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) utilize the seven

criteria of the Montreal Process to state the outcomes required to demonstrate sustainable

forest management for Uruguayan plantation forests. For each Montreal Process criterion the

standard for sustainable forest management for the UFCS (UNIT 1152: 2009) specifies indicators

– variables which are monitored – to provide evidence of attaining the outcome targeted by

criterion. Success in delivering each indicator is evaluated by evidence produced by

justification statements (i.e. outlines the importance of the relevant indicator); objective (i.e.

output the forest manager is expected to deliver to demonstrate compliance with the

indicator); parameters (i.e. framework of variables to be monitored); procedure (i.e. specific

actions to implement parameters); documents (i.e. information and records to verify actions);

and register (i.e. evaluation from monitoring of parameters that analyse and track degree of

compliance in attaining objective and indicator).

The UFCS utilizes PEFCC requirements for chain of custody certification as detailed in Annex 4

(Chain of Custody of Forest Based Products – Requirements).

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4.1 Criteria for Forest Certification

4.1.1 General Requirements

1) Are the criteria relevant to all types of forests and management systems, which exist in

the nation/region and have they been elaborated for? (Annex 3, 3.6)

The criteria for forest certification in the UFCS are relevant to all plantation forests and

management systems in the unit of forest management (refer to GD01 and GD13, Section 1).

Conforms

2) Do the criteria clearly express the objectives for forest management that can be

unambiguously verified by different auditors? (Annex 3, 3.6)

The UFCS Criteria and Indicators as detailed in UNIT 1152:2009 (refer to GD13) clearly state the

objectives for forest management and are supported by explicit justifications, objectives and

means of verification. The UFCS requirements can be implemented and unambiguously audited by

different auditors based on the justification as the normative requirements.

Conforms

3) Are management and performance requirements applicable at the level of a forest

management unit? (Annex 3, 3.6)

Management and performance requirements of the UFCS are applicable at the level of a forest

management unit (FMU) (refer to GD13, Section 4.1).

Conforms

4) Are management and performance requirements applicable optionally also at group and

regional levels? (Annex 3, 3.6)

Management and performance requirements for the UFCS are applicable at group and individual

levels (refer to GD02).

Conforms

4.1.2 Other Requirements for Forest Management Criteria

5) Does the scheme require that property rights and land tenure arrangements shall be

clearly defined, documented and established for the relevant forest area? (Annex 3, 3.5)

As a component of forest owner demonstrating legal compliance for forest management

activities, Criteria 7 (UNIT 1152: 2009) requires property rights and land tenure to be defined,

documented and legally established for all forest areas being assessed for certification.

Conforms

6) Does the scheme require the clarification, recognition and respect of legal, customary

and traditional rights related to the forest land in compliance with chapter 3.5 of Annex?

(Annex 3, 3.5)

UNIT 1152: 2009 requires the forest owner applying for certification to identify, recognise and

respect legal, customary and traditional rights to forest land (Criteria 6, Indicator 6.6.3 and

Criteria 7).

Conforms

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7) Does the scheme require that a summary of the forest management plan or its

equivalent, which contains information about the forest management measures to be

applied, is publicly available, except for confidential business and personal information?

(Annex 3, 3.5)

Scheme documentation as presented does not provide for copies of forest management plans to

be made publicly available. During Field Visit representatives of forest companies indicated

that current practice was to make available forest management plans to individuals and

organisations who request copies.

Does not Conform

4.1.3 Laws and Regulations

8) Are the national certification criteria in compliance with national laws, programs and

policies? (Annex 3, 3.2, 3.6)

The UFCS require compliance with national forest policy, legislation and relevant regulations as

detailed in GD02, Section 5 and requirements of Criteria 7, UNIT 1152: 2009 (refer to GD13).

Conforms

9) Are the references to national laws, programs and policies indicated in the scheme

documentation when relevant, e.g. if the requirement of the PEOLG is not addressed in the

certification criteria but is included in normative regulations? (Annex 3, 3.6)

The UFCS documentation (UNIT 1152:2009, Criteria 7) requires groups or individuals seeking

certification to compile a register of compliance with relevant policies, legislation and

regulations (refer to GD13).

Conforms

10) Does the scheme include the requirement that any apparent violation of the legislation

shall be taken into consideration in internal and external audits? (Annex 3, 3.2)

The UFCS requires the Applicant Entity to conform to relevant legislation. Conformity is to be

verified in Conformity Audit (Criterion 7 – UNIT 1152) - “Any apparent violation of the

legislation shall be considered during the auditing and certification processes” (GD02, Section

2).

Conforms

4.1.4 International Labour Organization (ILO) Conventions

11) Are the Fundamental ILO Conventions ratified by the country and implemented through

the legislative framework? (Annex 3, 3.3)

Uruguay has ratified core ILO conventions as detailed below:

ILO Convention

Action

No: 29 Forced Labour, 1930 Ratified – 6/9/1995

No 87: Freedom of Association and Protection of the Right to Ratified – 18/3/1954

Organise, 1948

No 98: Right to Organise and Collective Bargaining, 1949 Ratified – 18/3/1954

No 100: Equal Remuneration, 1951 Ratified – 16/11/1989

No 105: Abolition of Forced Labour 1957 Ratified - 22.11.1968

No 111: Discrimination (Employment and Occupation), 1958 Ratified – 16/11/1989

No 138: Minimum Age for Admission to Employment, 1973 Ratified – 2/6/1977

No 182: Worst Forms of Child Labour, 1999 Ratified – 3/8/2001

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The requirements of the ratified ILO conventions can be enforced through the legislative

framework for Uruguay.

Conforms

12) Do the national certification criteria address the core elements of those Fundamental

ILO Conventions which have not been ratified by the country? (Annex 3, 3.3)

As noted previously, all core ILO Conventions have been ratified by Uruguay.

Conforms

13) Has the ILO Code of Practise on Safety and Health in Forestry Work been considered in

development of national and regional certification criteria? (Annex 3, 3.3)

The ILO Code of Practice on Safety and Health in Forestry Work was considered in development

of forest management standard and is captured by requirements of Criteria 6, Indicator 6.6.1 of

UNIT 1152: 2009.

Conforms

4.1.5 Other International Conventions

14) Are the international conventions relevant to forest management and ratified by the

country respected through the legislative framework? (Annex 3, 3.4)

Uruguay has implemented the following actions in relation to international conventions relevant

to forest management:

International Convention

Convention on Biological Diversity Ratified – 5/11/1993

Kyoto Protocol and Carbon Sinks Ratified – 5/2/2001

Convention on International Trade in Endangered Species Ratified – 2/4/1975

Cartagena Protocol on Biosafety Signed - 1/2/2001

The requirements of ratified conventions can be enforced through the legislative framework for

Uruguay.

The intent of the Cartagena Protocol on Biosafety is repeated in Criteria 3, Indicator 6.3.2 of

UNIT 1152: 2009.

Conforms

15) Are the requirements agreed upon in the conventions, even if they are not ratified by

the country, respected in the certification criteria to the degree that they are covered in

PEOLG or other reference documents basis approved by the PEFC Council? (Annex 3, 3.4)

The requirements in the international conventions (protocols) detailed in question 14 are

respected in the forest management standard UNIT 1152: 2009.

Conforms

4.2 Level of Application and Implementation (Annex 3, 4)

4.2.1 General

The UFCS provides options for individual and group certificates (either an organisation or legally

appointed individuals who undertake responsibilities of Applicant Entity for the management of

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forest for a number of owners). The UFCS details the rules for individual certification (GD02)

and group certification (SD07) including responsibilities and authorities for all participants

seeking certification.

16) Are the applicants, the certified areas and participating forest owners / managers /

others actors clearly identified in the scheme documentation? (Annex 3, 4.1)

UFCS documentation (refer to SD07 and GD02) clearly identifies the applicant, certified areas,

forest owners/managers for each category of certification.

Conforms

17) Does the scheme documentation require that all actors involved in or operating on the

certified area comply with the certification requirements? (Annex 3, 4.1)

UFCS documentation (refer to SD07 for Group Certification and GD02, Section 5.1 for Individual

certification).

Conforms

18) Does the scheme documentation require that all actors individually certified or

participating in regional/group certification are responsible for ensuring that contractors’

activities and operations meet the respective forest management criteria? (Annex 3, 3.4)

UFCS documentation requires that contractors (third parties) perform duties according to

requirement of “Sustainable Forestry Certification System” (refer to SD07 and GD02).

Conforms

4.2.2 Regional Certification

Not Applicable (No. 19 – 34)

4.2.3 Group Certification

35) Does the national definition for group certification comply with the PEFC Council

definition? (Annex 3, 4.1 b)

The criteria and requirements for group certification within the UFCS as set out in SD07 comply

with PEFCC requirements.

Conforms

36) Does the scheme documentation clearly define who the applicant is for group

certification? (Annex 3, 4.1 b)

The UFCS clearly identifies the Applicant Entity (Group Administrator) for group certification

(refer to GD02, Section 5.2 and SD07).

Conforms

37) Does the scheme documentation describe the applicant’s responsibility to assure the

compliance of all participants with the certification requirements? (Annex 3, 4.1 b)

UFCS documentation (refer to SD07) requires all members in group certification to “commit to

comply with the obligations imposed by Sustainable Forest Management System”. It is the

responsibility of Group Administrator (Applicant Entity), who acts on behalf of group members,

to ensure all members comply with forest management requirements.

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Conforms

38) Does the scheme documentation describe the applicant’s responsibility to ensure that

credible registers are kept of participants to certification and certified forest area?

(Annex 3, 4.1 b)

UFCS documentation (refer to SD07, Section 4) requires the Group Administrator to “maintain a

owner, manager and area”.

Conforms

39) Does the scheme documentation describe the applicant’s responsibility to implement

the rules for group certification? (Annex 3, 4.1 b)

UFCS documentation (refer to SD07, Section 4) requires the Group Administrator “to guarantee

that all activities related with the certificate take place according to the requirement of the

Sustainable Forestry Management System”.

Conforms

40) Does the scheme documentation require that total forest area participating in group

certification is recorded? (Annex 3, 4.1 b)

The UFCS documentation (refer to SD07) requires that Group Administrator keep a register of all

forested areas included those participating in group certification.

Conforms

41) Does the scheme documentation describe that forest owners should submit all the

forest area under his management in the catchment area for the group certification? (Not

obligatory to be met but should be aimed at) (Annex 3, 4.1 b)

UFCS documentation (refer to SD07, Section 7) recommends that forest owners “include the

totality of the forest areas” for group certification.

Conforms

42) Does the scheme documentation define the responsibilities and authorities of the

applicant and participating forest owners / managers for the inclusion of new participants

and to inform the certification body thereof? (Annex 3, 4.1 b)

UFCS documentation (refer to SD07, Section 4 and 5) details the responsibility and authority for

inclusion of new members and notification of certification bodies.

Conforms

43) Does the scheme documentation define the responsibilities and authorities of the

applicant and participating forest owners/managers for the internal control of conformity

and follow up corrective and/or preventive measures? (Annex 3, 4.1 b)

The UFCS documentation details the responsibilities and authorities of applicants and

participants to comply with certification requirements identified during audit. Documentation

further requires applicants to commit to correct non-conformities and implement preventive

and corrective measures (refer to SD07).

Conforms

44) Does the scheme documentation describe that the forest management certificate is

issued to the applicant (certificate holder)? (Annex 3, 4.1 b)

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UFCS documentation (refer to SD07) requires the Group Administrator to hold Group Certificate

issued by certification body.

Conforms

45) Does the scheme documentation describe that participants in group certification shall

receive either a copy of the regional certificate including the appendix (when applicable)

listing all participating forest owners or an individual attestation issued by the

certification body or the applicant which refers to the main certificate? (Annex 3, 4.1 b)

Group members will receive from Group Administrator a “document accrediting their

participation in the Group Certificate” (refer to SD07).

Conforms

4.2.4 Individual Certification

46) Does the scheme documentation describe that forest owner should submit all the

forest area under his management in the catchment area of the certification scheme in the

certification? (Not obligatory to be met but should be aimed at) (Annex 3, 4.1 c)

UFCS documentation (refer to GD02, Section 5.1) recommends that the applicant for individual

certification include all forests that are managed in certification process.

Conforms

4.2.5 Implementation of changes to the scheme

47) Does the scheme documentation define transition period(s) for implementation of

changes to the endorsed scheme in compliance with chapter 5 of Annex 3? (This is not

applicable to the initial endorsement of a scheme) (Annex 3, 5)

Not relevant at this time as the UFCS is applying for initial conformity assessment.

Not Applicable

4.3 Appeals, Complaints and Dispute Procedures (Annex 3, 6)

48) Has the PEFC National Governing Body set up or appointed an impartial and

independent dispute settlement body on a permanent basis or does it have written

procedures for the establishment of a dispute settlement body on an ad hoc basis?

(Annex 3, 6.1)

PEFC Uruguay has rules to establish on an ad hoc basis (as required) a Settlement and

Disagreement Commission to handle complaints that cannot be resolved by procedures of

certification body (refer to GD06).

Conforms

49) Has the PEFC National Governing Body established and documented procedures for an

independent dispute settlement body, either permanent of ad hoc, that takes care of

those complaints arising from forest management or chain of custody scheme

implementation that cannot be addressed in the dispute settlement procedures of the

relevant certification or accreditation body? (Annex 3, 6.1)

PEFC Uruguay has rules for establishment on an ad hoc basis a Settlement of Disagreements

Commission to address complaints arising from forest management, chain of custody and

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implementation issues that cannot be addressed by certification body or accreditation body

(refer to GD06).

Conforms

50) Can the dispute settlement body also resolve possible grievances in chain of custody

certification that do not exclusively concern an applicant and a certification body? (Annex

3, 6.1)

The Settlements of Disagreement Commission (refer to SD06) has charter to resolve grievances

in CoC certification that do not inclusively concern an applicant and certification body.

Conforms

51) Does the scheme documentation require that the accredited certification body has

procedures for dispute settlement for all grievances between the applicant and the

certification body? (Annex 3, 6.2)

UFCS documentation (refer to SD03, Section 5(v) and Section 13) requires the accredited

certification body to have “policies and procedures for resolution of claims, disputes and

litigation received by any interested party (includes applicant) in the certification”.

Conforms

52) Does the scheme documentation require that the relevant accreditation body, whose

accreditation covers the certification, deals with disputes and complaints concerning

observance of the accreditation requirements? (Annex 3, 6.2)

UFCS documentation (refer to SD03, Section 13) requires the accredited certification body to

“take proper corrective and preventative actions” in relation to accreditation requirements and

maintain required registers of actions taken.

Conforms

4.4 Overall Assessment

The implementation processes for UFCS do not meet PEFCC requirements due to nonconformity

associated with the requirement that summaries of forest management plans are

made publically available.

The UFCS is assessed as meeting all other implementation process requirements for forest

certification and chain of custody certification.

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5. Assessment of the UFCS Forest Management Standards against

PEOLG

5.1 Assessment Framework

The UFCS utilizes Norm (Standard) 1152: 2009 (Sustainable Forest Management. Criteria and

Indicators) (GD13), supported by Norm UNIT 1151: 2009 (Sustainable Forest Management.

Glossary of Definitions) (GD12) for evaluating the creditability and reliability of forest

management of plantations.

The forest management standard is structured to be internationally credible, practical and

audible to certify forest owners under individual or group certification arrangements.

The Criteria and Indicators of the Standard (UNIT 1152: 2009 and UNIT 1151: 2009) are

evaluated below for equivalence with the PEOLG. In evaluating the indicators, it is relevant to

note that the requirements for justification, objective, parameters, procedures, documents and

registers will be implemented to demonstrate meeting indicators.

5.2 Compatibility of the UNIT 1152: 2009 Standard with PEOLG

All references referred to in the following table are to Criteria and associated Indicators

specified in UNIT 1152: 2009. For the guidance of readers Criteria in UNIT 1152:2009 relevant to

demonstrating equivalence with PEOLG Criterion are coded as C (e.g. C 1) and associated

relevant Indicators coded as I (e.g. I 6.1.1).

5.2.1 Criterion 1 – Maintenance and appropriate enhancement of forest

resources and their contribution to global carbon cycles

PEOLG

Criterion

Evidence

Reference to UNIT

1152: 2009

1.1 Guidelines for forest management planning

General: Section 4.1

(Requirements for

Plantification)

Specific:

C1: I6.1.1, I 6.1.2,

I6.1.3.

C2: I6.2.1, I6.2.2,

I6.2.3, I6.2.4

C4: I6.4.1, I6.4.2,

I6.4.3, I6.4.4

C6: I6.6.1, I6.6.3,

I6.6.4

1.1 a The Standard requires forest owners to

practice sustainable forest

management (SFM) documented in

Forest Management Plan to deliver a

“balance between conservation of

natural resources, historic-cultural and

socio-economic aspects, productivity

(technical, economic and financial)

and general society’s well being”.

Land-use planning to achieve

sustainable development values is an

explicit requirement of Standard.

1.1 b The Standard requires forest owners to

undertake “territory inventory” and

mapping covering conservation of

biological diversity and maintenance

and improvement of forest ecosystems

(including soil and water).

1.1 c The Standard requires forest owners to

prepare and periodically review

management plans. The management

plans are to be based on relevant laws,

consistent with the scale of forestry on

the property.

General: Section 4.1

(Requirements for

Plantification)

Specific:

C1: I6.1.1; I6.1.2,

I6.1.3

C2: I6.2.1 I6.2.2,

I6.2.3, I6.2.4

General: Section 4.2

(General Plan for

Management)

Specific:

C1 – 7 and Indicators

Assessment

Conforms

1.1 d A core requirement in application of General: Section 4 Conforms

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the Standard (UNIT 1152: 2009) is the

monitoring and evaluation of

parameters to provide evidence (as

documented in registers) in

achievement of objectives defined for

each indicator.

(Requirements for

Plantification)

Specific: The

Parameters and

associated Registers

for each Indicator.

1.2 Guidelines for forest management practices

1.2 a The Standard requires forest owners to

prepare General Plans of Management

(consistent with the scale of forestry

operations) which delivers in the

context of SFM protection of water and

soil resources and balances harvesting

and growth rates. Silvicultural “tasks

must reduce to a minimum the

mechanical damage to the forest

population”.

1.2 b The Standard requires the General Plan

of Management to detail silvicultural

treatment to deliver sustainable

development.

1.2 c The Standard facilitates the expansion

of plantations on land designated by

Uruguayan legislation. It is noted that

Uruguay has long established

regulations specifying the soil types

and landscapes where forest

plantations can be established. All

plantations established in Uruguay are

on agricultural lands.

Plantation projects are required to be

approved by Ministry of Forestry

(Agriculture) and Ministry for

Environment. These arrangements in

Standard and Uruguayan regulatory

requirements are assessed as meeting

the PEOLG’s requirements of taking

into consideration the conversion of

abandoned agricultural and treeless

land.

General: Section 4

(Requirement for

Plantification)

Specific:

C2: I6.2.1, I6.2.2,

I6.2.3

C3: I6.3.1

C4: I6.4.1, I6.4.2,

I6.4.3, I6.4.4

General: Section 4

(Requirement for The

Plantification);

Specific:

C1: I6.1.2

C2: I6.2.2, I6.2.3,

I6.2.4

C3: I6.3.1, I6.3.2

General: Section 4

(Plantification);

Specific:

C2: I6.2.2

C7: I6.7.1

Conforms

5.2.2 Criterion 2 – Maintenance of Forest Ecosystem Health and Vitality

PEOLG

Criterion

Evidence Reference Assessment

2.1 Guidelines for forest management planning

2.1 a The Standard requires forest

management planning to maintain and

improve the health and vitality of

forest ecosystems against fire, climatic

agents, mechanical damage, pests and

diseases and rehabilitate damaged

ecosystems where possible by

General: Section 4

(Requirement for The

Plantification)

Specific:

C1: I6.1.2

C2: I6.2.1

C3: I6.3.1, I6.3.2

Conforms

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silvicultural means.

2.1 b The Standard requires managers to

monitor the health and vitality of

forest ecosystems including pests and

diseases, overgrazing and overstocking

(animal loads), fire, climatic agents

and forest management activities.

2.1 c The Standard requires forest

management plans to include

procedures to minimise the risks of

degradation and damage to forest

ecosystems and be consistent with

Uruguayan regulations relevant to

plantation management.

General: Section 4

(Requirement for The

Plantification)

Specific:

C2: I6.2.1

C3: I6.3.1, I6.3.2

C4: I6.4.2, I6.4.3

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C2: I6.2.1

C3: I6.3.2, I6.3.3

C7: I6.7.1

2.2 Guidelines for forest management practices

2.2 a The Standard requires forest

management practices to describe,

evaluate and plan the management of

natural ecosystems to increase their

genetic and structural diversity with

the purpose of enhancing the stability

and vitality of the combined plantation

and natural ecosystem to resist

“adverse environmental factors and to

strengthen the natural mechanisms of

regulation”.

2.2 b The Standard requires plantations be

established with appropriate species

for the site and assessment of impacts

on ecosystems and genetic integrity of

native species. Silviculture, harvesting

and transport techniques must

minimise damage to trees, soil and

water resources. The use of fuels and

lubricants must be undertaken to

prevent soil contamination.

2.2 c The Standard requires forest

management practices to use

agrochemicals consistent with

integrated control systems

incorporating economic, silvicultural

and biological considerations to

protect forest, soil and water

resources.

2.2 d The Standard requires managers to

implement procedures for “storage,

manipulation, application and

management of agrochemicals”

(interpreted to include fertilizers) to

prevent soil and water contamination.

The use of fertilizers is captured under

the requirement that use of

agrochemicals (interpreted to include

fertilizer) must be at levels to prevent

soil and water contamination.

General: Section 4

(Requirement for The

Plantification)

Specific:

C1: I6.1.2, I6.1.3

General: Section 4

(Requirement for The

Plantification)

Specific:

C1: I6.1.2

C2: I6.2.1

C3: I6.3.1

C4: I6.4.3, I6.4.4

Specific:

C3: I6.3.2

C4: I6.4.3

Specific:

C4: I6.4.3, I6.4.4

Conforms

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5.2.3 Criterion 3 – Maintenance and Encouragement of Productive Functions

of Forests (wood and non-wood)

PEOLG

Criterion

Evidence Reference Assessment

3.1 Guidelines for forest management planning

3.1 a The Standard’s primary goal is the

implementation of auditable actions by

forest owners to maintain the

capability of forests to produce a range

of wood and non-wood products and

services on a sustainable basis.

3.1 b The Standard requires that forest

management planning “must be

formulated, documented and reviewed

periodically, in the short and long term

for the achievement of sustainable

economic development, in

consideration of new markets and

economical activities in relation to all

the products and relevant services in

management unit”.

3.1 c The Standard requires forest

management plans to account for the

different uses and functions of forest

areas covering merchantable and nonmerchantable

forest goods and services

for the socio-cultural content including

the experience and traditional

knowledge of local community and

other interested parties in using

forests.

General: Section 4

(Requirement for The

Plantification)

Specific:

C2: I6.2.1, I6.2.3,

I6.2.4

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C2: I6.2.2, I6.2.3

C6: I6.6.3

General: Section 4

(Requirement for The

Plantification)

Specific:

C2: I6.2.3, I6.2.4

C6: I6.6.3, I6.6.4

3.2 Guidelines for forest management practices

UNIT 1152 (2009).

3.2 a The Standard requires forest

management practices to be

implemented to improve forest

resources and encourage the

production of a diversified output of

goods and services. The evidence for

quality is demonstrated in the

justification, objectives, parameters,

procedures, documentation and

indicator.

3.2 b The Standard specifies practices to

maintain productive capacity of

plantation forests during planting

(regeneration), tending and harvesting

activities with aim of reducing damage

to retained stands and soil and water

resources.

3.2 c Standard requires owners’ commitment

to practice sustainable forestry,

incorporating both wood and non-wood

forest products. The Standard requires

optimum commercial use of harvested

forest products. The Standard requires

General: Section 4

(Requirement for The

Plantification)

Specific:

C2: I6.2.2, I6.2.3,

I6.2.4

C3: I6.3.1

C4: I6.4.1, I6.4.3, I

6.4.4

General: Section 4

(Requirement for The

Plantification)

Specific:

C2: I6.2.2, I6.2.3,

I6.2.4

Conforms

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forest practices to maintain the

capacity of soils.

3.2 d The Standard requires the planning

construction and maintenance of

infrastructure to achieve Sustainable

Forest Management.

C4: I6.4.1, I6.4.3

General: Section 4.2

(General Plan of

Management)

Specific:

C1: I6.1.2

C2: I6.2.1

C4: I6.4.3, I6.4.4

Conforms

5.2.4 Criterion 4 – Maintenance, Conservation and Appropriate Enhancement

of Biological Diversity in Forest Ecosystems

PEOLG

Criterion

Evidence Reference Assessment

4.1 Guidelines for forest management planning

4.1 a The Standard requires management

planning to maintain and enhance

biodiversity at ecosystem, species and

genetic level, and where appropriate

at landscape level.

4.1 b The Standard requires forest

management planning to incorporate

terrestrial inventory and mapping of

national ecosystems and species and

their condition and importance, using

published and in-situ resources.

4.2 Guidelines for forest management practices

4.2 a The Standard relates to plantation

management. The Standard requires

the use of species and varieties

appropriate to site with an evaluation

of the impact of species (variety) on

the ecosystems and genetic integrity of

native species.

4.2 b The Standard requires an account, for

each site, of the origins of species (and

varieties) with goal of identifying

appropriate species as well as “the

impact on the ecosystems and genetic

integrity of the native species and

local origins”.

4.2 c The Standard requires forest

management practices to increase the

genetic, species and structural

diversity of natural ecosystems.

4.2 d The Standard requires that the

traditional management systems and

knowledge associated with the use of

forests by local communities and other

interested parties must be considered

and respected in forest management

practices. Also the Standard requires

the tracking of level of wood and nonwood

resources produced from forest

to demonstrate the maintenance and

improvement of socio-economic

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C1: I6.1.2, I6.1.3

C2: I6.2.1

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C1: I6.1.1, I6.1.2,

I6.1.3

Specific:

C1: I6.1.1, I6.1.2,

I6.1.3

C2: I6.2.1

Specific:

C2: I6.2.1

Specific:

C1: I6.1.2, I6.1.3

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C2: I6.2.4

C6: I6.6.4

Conforms

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benefit to society.

4.2 e The Standard requires the protection

of natural forests, water and soil

resources and biodiversity during forest

management and harvesting.

4.2 f The Standard requires infrastructure to

be planned, constructed and

maintained to “accomplish a

Sustainable Forest Management”.

Delivery of sustainable forest

management explicitly requires

damage minimisation to ecosystems.

4.2 g The Standard requires forest

management practices to conserve

native plant and animal species,

control exotic animal and plant species

that might represent a threat or pest

and control animal load in areas under

husbandry and/or joint use.

4.2 h The Standard requires silvicultural

practices to include procedures for

conservation of biological diversity

through retention of dead and fallen

and standing for fauna habitats and

maintenance of ageing forests of “rare

or singular species”. The Standard also

requires forest management practices

to consider “the potential effects of

these measures on the safety of people

and the protection and stability of

forests and surrounding ecosystems

simultaneously”.

4.2 i The Standard requires the conservation

of sites of special biotypes (including

catchment, wetlands and rocky

surfaces) and their restoration if

appropriate.

General: Section 4

(Requirement for The

Plantification)

Specific:

C1: I6.1.2, I6.1.3

C2: I6.2.1

C3: I6.3.1

C4: I6.4.2, I6.4.3,

I6.4.4

Specific:

C1: I6.1.2

C2: I6.2.1

C3: I6.3.1

C4: I6.4.2, I6.4.3,

I6.4.4

Specific:

C1: I6.1.2

C4: I6.4.2

Specific:

C1: I6.1.2

Specific:

C1: I6.1.2

Conforms

5.2.5 Criterion 5 – Maintenance and Appropriate Enhancement of Protective

Functions in Forest Management (notably soil and water)

PEOLG

Criterion

Evidence Reference Assessment

5.1 Guidelines for forest management planning

5.1 a The Standard requires forest

management planning to maintain and

improve the protective functions of

forests by “seeking a balance between

conservation of natural resources,

historic-cultural and socio-economic

aspects, productivity (technical,

economic and financial) and general

society’s well being”. Key components

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C1: I6.1.2

C4: I6.4.3, I6.4.4

Conforms

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for maintaining and enhancing

protective functions of forests for

society include conservation of

biodiversity to improve the capability

of plantations in responding to

“adverse environmental factors and to

strengthen natural systems of

regulation”; infrastructure protection

and conservation and maintenance of

soil and water resources.

5.1 b The Standard requires the forest

management plans to take full account

of areas that fulfil specific or

recognised protective functions for

society.

5.2 a The Standard requires forest

management practices to undertake

risk assessment of the potential soil

erosion and degradation and

preventive actions which will be

implemented. The Standard requires

procedures to control animal “load in

areas under husbandry and/or joint

use”

5.2 b The Standard requires that all forest

management units be considered a

water resource with an objective of

preventing contamination of water

resources from forest management

activities, agrochemicals, fuels and

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C6: I6.6.4

5.2 Guidelines for forest management practices

Specific:

C4: I6.4.2

lubricants.

5.2 c The Standard requires the installation

and maintenance of infrastructure

(roads and bridges) to ensure minimum

impact of forest management on soil

and water resources in the landscape.

Specific:

C4: I6.4.4

Specific:

C1: I6.1.2

C4: I6.4.2, I6.4.3,

I6.4.4

Conforms

5.2.6 Criterion 6 – Maintenance of Other Socio-economic Functions and

Conditions

PEOLG

Criterion

Evidence Reference Assessment

6.1 Guidelines for forest management planning

6.1 a The Standard contains requirements

for forest management planning to

respect the multiple functions of

forests to society with explicit

recognition of role of forestry in rural

development and new opportunities for

employment.

6.1 b The Standard requires property rights

and tenure arrangements to be

included in the management plans.

Legal, customary and traditional rights

of local community must be identified

and incorporated into management

plans.

General: Section 4.1

(Requirement for The

Plantification)

Specific:

C2: I6.2.2, I6.2.3,

I6.2.4

C6: I6.6.3, I6.6.4

Specific:

C6: I6.6.3, I6.6.4

C7: I6.,7.1

Conforms

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6.1 c The forest owner has responsibility to Specific:

provide for access to forests for C6: I6.6.3, 6.6.4

specific purposes (e.g. recreation). C7: I6.7.1

6.1 d The Standard requires forest Specific:

management plans to identify and C6: I6.6.4

conserve historical, cultural, spiritual

and recreational values of significance

to deliver the socio-economic and

multiple use functions of forests.

6.1 e The Standard requires forest Specific:

management plans to specify C6: I6.6.2

activities, including on-going training,

to be implemented to demonstrate

that workers (forest managers,

contractors, employees and forest

owners) are qualified for “activities

they do”.

6.2 Guidelines for forest management practices

6.2 a The Standard requires forest General: Section 4.1

management practices to incorporate (Requirement for The

the experiences and traditional Plantification)

knowledge of local communities and Specific:

other interested parties.

C6: I6.6.3, I6.6.4

6.2 b The Standard requires forest

management practices to achieve safe

working conditions for workers and

contractors.

6.2 c The Standard requires forest

management operations to take into

account all socio-economic functions of

forests including employment, safety,

training, rural development, and

recreational and aesthetic values

operating at landscape level.

Specific:

C6: I6.6.1

Specific:

C6: I6.6.1, I6.6.2,

I6.6.3, I6.6.4

Conforms

5.7 Overall Assessment

The UFCS Standard for SFM (UNIT 1152: 2009 and UNIT 1151: 2009) is in compliance with the

requirements of PEOLG.

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6. Assessment of the UFCS Chain of Custody Standard against

PEFCC Requirements

UFCS documentation (refer to GD02, GD08 and SD09) requires organisations who desire chain of

custody certification under the UFCS to demonstrate compliance with requirements of PEFCC’s

Annex 4 (Chain of Custody of Forest Based Products – 17/6/2005) and associated appendices.

Conforms

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7. Assessment of the Logo Usage Rules against PEFCC

Requirements

PEFC Uruguay has rules and monitoring procedures (refer to SD05) requiring certified

organisations to use PEFC logo consistent with requirements of PEFCC GL 1/2006 (Issuance of

PEFC Logo Use Licence by PEFCC).

Conforms

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8. Assessment of the UFCS Certification and Accreditation

Arrangements against PEFCC Requirements

8.1 Certification Bodies

8.1.1 Competence of Certification Bodies

1) Does the scheme documentation require that certification shall be carried out by

impartial, independent third parties that cannot be involved in the standard-setting

process as governing or decision making bodies, or in the forest management and are

independent of the certified entity? (Annex 6, 3.1)

UFCS documentation (refer to Section 5, SD03) requires that certification be performed by

organisations that are “impartial and independent” and not involved in any process of

normalisation (standard setting) or part of PEFC Uruguay.

Conforms

2) Does the scheme documentation require that a certification body for forest

management certification or chain of custody certification against a scheme specific chain

of custody standard shall fulfil requirements defined in ISO 17021 or ISO Guide 65?

(Annex 6, 3.1)

UFCS documentation (refer to SD03, Section 3) requires a certification body to have

documented procedures “compatible with the requirements of ISO 17021 or ISO Guide 65”.

Conforms

3) Does the scheme documentation require that certification bodies carrying out chain of

custody certification against PEFC Annex 4 fulfil requirements defined in ISO Guide 65?

(Annex 6, 3.1)

UFCS documentation (refer to SD03, Section 3) requires certification bodies undertaking CoC

certification to have a “system that complies with requirements of ISO 65 Guide”.

Conforms

4) Does the scheme documentation require that certification bodies carrying out forest

certification shall have the technical competence in forest management on its economic,

social and environmental impacts, and on the forest certification criteria? (Annex 6, 3.1)

UFCS documentation requires certification bodies to have competencies in UNIT 1152:2009

(Sustainable Forest Management – Criteria and Indicators) (refer to SD03, Section 3); and

require personnel to have competence in the field of forest management and related social,

economic and environmental impacts (refer to SD03, Section 5 (m)).

Conforms

5) Does the scheme documentation require that certification bodies carrying out chain of

custody certification have technical competence in forest based product procurement and

processing, material flows in different stages of processing and trading? (Annex 6, 3.1)

UFCS documentation requires certification bodies to have competencies in Chain of Custody

(PEFC – Annex 4) (refer to SD03, Section 3); and personnel with required competencies in forest

based chain of custody processes (refer to SD03, Section 5 (m)).

Conforms

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6) Does the scheme documentation require that certification bodies have a good

understanding of the national PEFC system against which it carries out forest or chain of

custody certification? (Annex 6, 3.1)

UFCS documentation (refer to SD03, Section 3) requires certification bodies “be informed on

the PEFC Uruguay Scheme for the certification of Forest Management or Chain of Custody”.

Conforms

8.1.2 Auditors

7) Does the scheme documentation require certification bodies have the responsibility to

use competent auditors that have adequate technical know-how on the certification

process and issues related to forest management or chain of custody respectively? (Annex

6, 3.2)

UFCS documentation (refer to SD04, Sections 4, 5 and 8) requires certification bodies to use

auditors that have specified qualifications, “knowledge and experience from Uruguayan forestry

sector” and capabilities in audit techniques to competently perform audits.

Conforms

8) Does the scheme documentation require that auditors fulfill general criteria of ISO

19011 for Quality Management Systems auditors or for Environmental Management

Systems auditors? (Annex 6, 3.2)

UFCS documentation (refer to SD04, Section 4) requires auditors to meet criteria defined in

“ISO/ICC 19011:2002 Norm”.

Conforms

9) Does the scheme documentation include additional qualification requirements for

auditors carrying out forest management or chain of custody audits? (Annex 6, 3.2)

UFCS documentation (refer to SD04, Sections 5 and 8) details additional criteria for auditors,

required by PEFC Uruguay, in order to undertake forest management and chain of custody

certification. The criteria relates to education, work experience, competence and training.

Conforms

8.2 Certification Procedures

10) Does the scheme documentation require that certification bodies shall have

established internal procedures for forest management and/or chain of custody

certification? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have internal

procedures for forest management and/or chain of custody certification.

Conforms

11) Does the scheme documentation require that applied certification procedures for

forest management certification or chain of custody certification against a scheme

specific chain of custody standard shall fulfil or be compatible with requirements defined

in ISO 17021 or ISO Guide 65? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to establish and

document internal procedures compatible with the requirements of ISO 17021 or ISO Guide 65

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for forest management standard. As UFCS uses Annex 4 requirements for chain of custody

certification (this is not a scheme specific CoC standard) the consultants’ response refers only

to forest management standard.

Conforms

12) Does the scheme documentation require that applied certification procedures for chain

of custody certification against Annex 4 shall fulfil or be compatible with the

requirements defined in ISO Guide 65? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 3 and 5(n)) requires certification bodies

undertaking chain of custody certification (to PEFCC Annex 4 requirements) to have quality

systems consistent with requirements of ISO Guide 65 adjusted to the type, range and volume

of work.

Conforms

13) Does the scheme documentation require that applied auditing procedures shall fulfil or

be compatible with the requirements of ISO 19011? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(q)) requires certification bodies to “have audit

procedures according to the ISO 19011 requirements”.

Conforms

14) Does the scheme documentation require that the certification body informs the

relevant PEFC NGB about all issued forest management and chain of custody certifications

and changes concerning validity and scope of these certificates? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(w)) requires certification bodies to inform PEFC

Uruguay about all certifications and changes to the scope and validity of certification

certificates.

Conforms

15) Does the scheme documentation require that the certification body carries out

controls of PEFC logo usage if the certified entity is a PEFC logo user? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(e)) requires certification bodies to “control the

proper use of PEFC logo by the certified entities”.

Conforms

16) Does the scheme documentation require that the maximum period for surveillance

audits not exceed one year? (Annex 6)

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have followup

audits (surveillance audits) not exceeding one year.

Conforms

17) Does a maximum period for assessment audit not exceed five years for both forest

management and chain of custody certifications? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have

reassessment audits (renovation audits) for forest management or CoC not exceeding 5 years.

Conforms

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18) Does the scheme documentation include requirements for public availability of

certification report summaries? (Annex 6, 4)

UFCS documentation (refer to SD03, Section 9(g)) includes requirements for public availability

of certification report summaries.

Conforms

19) Does the scheme documentation include requirements for usage of information from

external parties as the audit evidence? (Annex 6, 4)

UFCS documentation provides for usage of information from external parties as audit evidence.

The UFCS documentation requires certification bodies to have procedures that allow

participation by all parties in the control and function of the certification system (refer to

SD03, Section 5(f)).

Conforms

20) Does the scheme documentation include additional requirements for certification

procedures? (Annex 6, 4)

UFCS documentation (refer to SD03) specifies procedures consistent with requirements of

PEFCC’s Annex 6, Section 4.

Conforms

8.3 Accreditation

21) Does the scheme documentation require that certification bodies carrying out forest

management or chain of custody certification are accredited by a national accreditation

body? (Annex 6, 5)

Certification bodies must be “endorsed by the Uruguayan Organisation of Accreditation (OUA) or

other organisation recognised by IAF” (refer to SD03 Section 3(a)). The OUA is the national

accreditation body for certification bodies (www.organismouruguayodeacreditacion.org)

Conforms

22) Does the scheme documentation require that an accredited certificate bears an

accreditation symbol of the relevant accreditation body? (Annex 6, 5)

UFCS documentation does not explicitly require that accredited certificates issued by

certification body must bear the accreditation symbol of the relevant accreditation body.

Does not conform

23) Does the scheme documentation require that the accreditation shall be issued by an

accreditation body which is a part of the International Accreditation Forum (IAF) umbrella

or a member of IAF’s special recognition regional groups and which implement procedures

described in ISO 17011 and other documents recognised by the above mentioned

organisations? (Annex 6, 5)

UFCS documentation (refer to SD03, Section 3(a)) requires that accreditation of certification

bodies is performed by OUA or accreditation body which is recognised by IAF. The OAU is a

member of regional groups recognised by IAF.

Conforms

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24) Does the scheme documentation require that certification body undertake forest

management or/and chain of custody certification against a scheme specific chain of

custody standard as “accredited certification” based on ISO 17021 or ISO Guide 65 and

the relevant forest management or chain of custody standard(s) shall be covered by the

accreditation scope? (Annex 6, 5)

UFCS documentation (refer to SD03, Section 3) requires certification bodies to be accredited

specific to UNIT 1152 (Sustainable Forest Management and CoC) and PEFC Annex 4 for CoC and

have quality systems in place that are consistent with requirement of ISO 17021 or ISO Guide

65.

Conforms

25) Does the scheme documentation require that a certification body undertaking chain of

custody certification against PEFC Annex 4 as “accredited certification” based on ISO

Guide 65? (Annex 6, 5)

UFCS documentation (refer to SD03, Section 3) requires that CoC certification bodies must have

quality systems which meet requirements of ISO Guide 65.

Conforms

8.4 PEFC Notification of Certification Bodies

26) Does the scheme documentation provide for PEFC notification of certification bodies?

(Annex 6, 6)

UFCS documentation (refer to SD03, Section 3(e)) requires that certification bodies must have

received notification from PEFC Uruguay or PEFC International of their endorsement. UFCS

documentation does not explicitly detail requirements for notification conditions to cover

administration conditions, financial conditions and compliance with accreditation conditions.

Partly Conforms

27) Are the procedures for PEFC notification of certification bodies non-discriminatory?

(Annex 6, 6)

UFCS documentation does not contain explicit procedures for PEFC notification of certification

bodies in a non-discriminatory manner. The UFCS documentation refers to policies and

procedures of certification bodies not being discriminatory (refer to SD03, Section 4).

Does not conform

8.5 Overall Assessment

Utilizing the information presented above, the consultants assessed that the UFCS certification

and accreditation arrangement does not meet PEFC Scheme requirements due to nonconformities.

These non conformities are associated with i) a lack of specific requirements for

accreditation certificates issued by certification bodies to include the accreditation symbol of

OUA, and ii) and lack of explicit procedures for PEFC notification of certification bodies in a non

discriminatory manner.

Regarding i) (Section 8.3, question 22) discussions during Field Visit with representatives of OUA

indicated they would consider this requirement in finalising procedures for the accreditation of

certification bodies under the UFCS.

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Regarding ii) (Section 8.4. question 27) PEFC Uruguay commented during Field Visit that while

current UFCS documentation does not fully cover PEFC requirements, the practice of PEFC

Uruguay would be to inform certificate bodies of information detailed by PEFCC in a nondiscriminatory

manner.

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Annex 1. Comments Submitted to ITS Global during Public

Consultation Period

One submission was received as a result of public consultation period for UFCS.

The submission was from Cassie Phillips, Vice President, Sustainable Forests and Products,

Corporate Headquarters, Weyerhaeuser dated 24 September 2010.

The general theme of the Weyerhaeuser submission is to express support of PEFCC’s assessment

and recognition of UFCS. The submission specifically makes the following comments:

1) Uruguay’s policy for forest industry development is concentrated exclusively on renewable

forestry plantations;

2) Uruguay’s policies of identifying “forestry priority soils” underpin the regulatory structure

for the establishment of plantations. These soils are assessed as having limitations for

commercial crops and intensive animal production, but are particularly suitable for forest

plantations;

3) Regulatory approvals are required from Uruguayan Ministry of Agriculture and Ministry of

Environment to establish plantations;

4) The importance of expanding forest products industry in terms of Uruguayan sustainable

and development initiatives and exports;

5) The importance of forest certification to generate market confidence, specifically to show

that Uruguay plantation practices are consistent with SFM principles;

6) The independence of UNIT in developing and approving forest management standards.

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Annex 2. Report on the Field Visit

A Field Visit was undertaken by Dr Bob Smith from 23 to 27 August 2010, with the purpose of

gaining additional information to support the conformity assessment of the UFCS against the

requirements of PEFCC.

Detailed below are the results of meetings with various groups involved in the development and

approval of the UFCS.

1) Meeting with PEFC Uruguay

Attendees:

Mr Gerardo Barrios (President)

Mr Civil Alvaro Molinari (Vice President)

Mr Oscar Regueira

Dr Ricardo Methol

Mr Edgardo Cardozo (Society of Forestry Producers)

Ms Andrea Regusci (Society of Forestry Producers)

Discussions:

The meeting covered the following issues:

i) Explanation of the importance of PEFC recognition of the UFCS, specifically in regard to

maintaining market access (in particular, markets in the USA and Europe).

ii)

The evolution and processes followed in the formation of PEFC Uruguay, and the goal of

aligning the UFCS with requirements of PEFCC.

iii) The development and co-ordination of forest management standards (UNIT 1151:2009

and UNIT 1152: 2009) by Specialized Technical Committee for Sustainable Forest

Management (STC-SFM) which operated consistent with requirements of UNIT. The STC-

SFM operated independently from PEFC Uruguay.

iv)

Clarification of issues raised in Interim Report on the conformity of the UFCS against

PEFCC requirements.

v) Levels of participation by diversity of groups in development of forest management

standards (UNIT 1151:2009 and UNIT 1152:2009). Consensus that wide diversity of groups

representing government (forestry and environment departments), academia, industry,

social/environmental issues and unions participated. PEFC Uruguay noted that, although

invited, no environmental NGO participated in development of Standard. PEFC Uruguay

noted that peak environmental NGO in Uruguay, Group GUAYUBIRA

(www.guayubira.org.uy) has a national initiative against establishment of monoculture

plantations in Uruguay.

vi)

PEFC Uruguay considers the UFCS to be a challenge to implement. The implementation of

the UFCS will lead to significant gains in the economic, social and environmental

outcomes sought from plantation forests in Uruguay.

2) Meeting with Instituto Uruguayo de Normas Técnicas (UNIT)

Attendee: Mr Ferdando Gomez (Executive Director Norms)

Discussion:

The meeting covered the following issues:

i) The history of UNIT in developing and approving technical standards in Uruguay.

ii) The processes UNIT follows (methodology) in developing standards focusing on the role of

specialized technical committees.

iii) The evolution of development and approval of forest management standards commencing

with UNIT approval of Project “Access to markets and the integration through technical

normalization” and approval of UNIT 1151: 2009 and UNIT 1152: 2009 by UNIT’s General

Committee of Norms on 14 December 2009.

iv) Explanation of the UNIT statutes and associated documentation for impartial handling of

disputes and complaints associated with standard setting processes.

v) Review of a sample of minutes (relating to meeting of STC-SFM between 2006 and 2009).

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vi)

Explanation of process followed for public consultation of forest management standards

UNIT 1152: 2006 and UNIT 1151: 2006 in 2009, including use of UNIT’s website, media

advertisements and 24 individually targeted letters requesting comment.

It was explained that while intended for consultation to run for 60 days there was an

error in the media advertisement identifying public consultation period from 1 April to 23

May 2009, a period of 53 days.

UNIT representative explained and showed evidence from electronic logs that the forest

management standards were on UNIT’s website for the period 1 st April 2009 to 28 th June

2009.

UNIT would have accepted any submission received after the advertised closure of public

consultation period (23 May 2009) as a valid submission. However none were received.

3) Meeting with representatives of Specialized Technical Committee – Sustainable Forest

Management (STC-SFM):

Attendees:

Mr Juan Cabris, Forestry Department, University of Uruguay – Former Chairperson of STC-

SFM

Ms Carolina Sans Dobe, Associate Professor, Dept of Forestry, University of Uruguay

Ms Ana Quintillan, Benho de Seguros Del Estado (BSE)

Mr Miguel Farina, Manager, Weyerhaeuser Products, SA

Ms Mary Rosas, Consultant, Terrasys

Mr Peter Baptista, Manager, Forestry Directorate, Dept of Agriculture

Discussions:

i) Outline of the long development (over 40 meetings) and testing process for UNIT 1151

and UNIT 1152, including three versions between 2006 and 2009.

ii) Discussions establishing that the STC-SFM operated by consensus.

iii) Explanation that the STC-SFM’s activities were co-ordinated and undertaken consistent

with UNIT procedures.

iv) Explanation that the STC-SFM took into account the intent of ILO Protocol for Health and

Safety for Forestry in their deliberations and the requirements of Uruguayan legislation

on worker health and safety.

4) Meeting with Forestry Directorate, Dept of Agriculture (Uruguay):

Attendees:

Mr Daniel San Roman, Director, Forestry Division

Mr Peter Baptista, Manager, Forestry Division

Discussions:

i) History of proactive Uruguayan Government policy to expand forestry plantations within

the framework of protecting high quality agricultural lands for cropping and dairying.

ii) Explanation and examples of process the Forestry Division must follow by regulation to

approve plantation development proposals above 100 ha.

iii) The UFCS is consistent with the Uruguayan Government’s policies and legal requirements

for establishment and management of forestry plantations.

5) Meeting with Dept of Environment (Uruguay):

Attendees:

Mr Jorge Rucks, National Director, Dept of Environment (Uruguay)

Mr Luis Sayagues, Adviser

Discussions:

i) Plantation forestry in Uruguay is conducted within a framework established for

agriculture.

ii) The focus of regulatory process is to organise forests within landscape on soils specified

by Government regulations.

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iii) Plantation forestry is a major component of sustainable development policy of

Government.

iv) Forest management standards (UNIT 1152: 2009 and UNIT 1151: 2009) considered to be of

“high quality and practical”.

v) Department of Environment had very satisfactory input in the development and approval

of forest management standards.

vi) Department of Environment’s major interest in forest plantations relate to flow-on

impacts associated with herbicide and pesticide use, water use, biodiversity, protected

areas, scenic amenity and protection of small farms principally dairy farms.

vii) Commented that ENGOs (umbrella ENGO in Uruguay is Group Guayubira –

www.guayubira.org.au) while invited did not participate in development of forest

management standards as they do not support expansion of plantations in Uruguay,

primarily citing:

Adverse changes in landscape;

Use of introduced species and monocultures;

Implied support for international companies;

Impacts on protected areas; and

Adverse cultural and social impacts on local communities.

6) Meeting with Organismo Uruguayo De Acreditacion (OUA):

Attendee: Mr Feodero Kunin, President

Discussion:

i) Explanation, based around power point presentation, of the role and authorities of OUA

in accrediting certification bodies.

ii) OUA’s utilization of independent Accreditation Committee to accredit certification

bodies.

iii) OUA’s procedures for finalizing accreditation of certification bodies based on UFCS

procedures.

7) Meeting with College of Agriculture, University of Uruguay:

Attendees:

(a) Soils Department

Dr Duran, Former Dean

Dr Mano Perez

Mr Jorge Hernandez

(b) Forestry Department

Associate Professor Carolina Sans Dobe (Forest technical expert)

Dr Juan Cabris (Forest technical expert)

Mr Luis Gallo (Forest technical expert)

Ms Graciela Rumero (Forest pests expert)

Dr Carlos Pelegrino (Landscape expert)

Discussions:

i) Explanation of the involvement of University of Uruguay staff in the development of

forest management standards including provision of technical advice and pilot testing.

ii)

iii)

Consensus that forest management standard in the UFCS was appropriate for Uruguay.

Highlighted necessity to ensure field staff and managers receive appropriate training to

successfully implement the UFSC.

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Annex 3. PEFC Council Minimum Requirements Checklist

Detailed below is an assessment of the UFCS against PEFCC minimum requirements checklist

(GL2/2010) covering:

‣ Part I - Checklist for Standard Setting Process (Annex 2)

‣ Part II Checklist for Certification Schemes and their Implementation (Annex 3)

‣ Part III - Checklist for UFCS Compliance with PEOLG (Annex 3, Chapter 4.2)

‣ Part VI - Checklist for the UFCS CoC Standard (Annex 4)

‣ Part VII - Checklist for Certification and Accreditation Procedures (Annex 6)

The column titled “Consultant assessment & reference to assessment report (where relevant)”

is an assessment of the UFCS’ level of conformity with PEFCC requirements for the specific

question, cross referenced to a section in the assessment report. Where a suitable cross

reference in the assessment report is not available, a response is provided in the column

headed “Reference to application documents”.

For tracking purposes the Checklist retains the responses submitted by PEFC Uruguay as part of

UFCS documentation (highlighted in red). The original response submitted by PEFC Uruguay

used an earlier version of the Checklist (GL 2/2008). In the following tables, PEFC Uruguay’s

answers have been integrated into the current Checklist format (GL 2/2010). It is also

important to note that column titled “Reference to application documents” refers to the

reference used by PEFC Uruguay in submitting documentation. When matching PEFC Uruguay’s

reference to Consultant’s assessment reference (last column of Checklist) the following table

may assist the reader:

Reference Document in

PEFC Uruguay Documentation

PEFC Application Letter

Uruguayan Forest Certification Scheme

PEFC Uruguay Acta 18-12-2009

PEFC Uruguay Statutes

Annex 1 UFCS

Annex 2 UFCS

PEFC Checklist - December

Report UNIT 1151 - 2009

Report UNIT 1152 - 2009

UNIT 1151 – 2009 – Amended Version

UNIT 1152 – 2009 Amended Version

Documents Numbered – DG01 to DG09

Equivalent Document used in

Consultant’s Assessment

GD03

GD02

GD03

GD04

GD03

GD06

GD07

GD08

GD09

GD10

GD11

SD01 to SD09

PART I: MINIMUM REQUIREMENTS CHECKLIST FOR STANDARD SETTING PROCESS (ANNEX 2)

SCOPE:

Part I covers the requirements for the standard setting process defined in Annex 2 of the PEFC

Council Technical Document (Rules for Standard Setting).

No.

Question

Reference

to PEFC

Council

doc.

1 Has the development of the

Annex 2, 3.2

certification standards been

independent from the certification

and accreditation process? [*1]

Assess.

Basis*

Yes/

No*

Standard setting for forest certification

Doc.

Yes

Reference to

application

documents

Section 7 of the

Uruguayan

Forest

Certification

Scheme (UFCS).

Consultant assessment &

reference to assessment

report (where relevant)

Conforms

(Section 3.1.1)

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No.

Question

Reference

to PEFC

Council

doc.

Assess.

Basis*

Yes/

No*

2 Has the standard setting process

been carried out at national and/or

sub-national levels? Annex 2, 3.3 Doc. Yes

Reference to

application

documents

Process Yes Annex 1 of UFCS

Section 5 of the

UFCS. GD 07.01.

Requirements

for group

certification

Consultant assessment &

reference to assessment

report (where relevant)

Conforms

(Section 3.1.1)

Conforms

National level

(Section 3.1.1)

Process

Yes

Section 7 of the

UFCS. Annex 1

Conforms

(Section 3.1.1)

3 Has the standard setting process

been co-ordinated by the PEFC

National Governing Body? [*1]

4 Has the certification standard been

drafted to be applied at individual

and/or group and/or regional level?

Annex 2, 3.3 Doc. Yes

Annex 2, 3.3

Process Yes Annex 1

Yes

Section 1 of

UFCS.

Section 5 of

UFCS, 5.1, 5.2

and DG 07.01.

Conforms (Section 3.1.1)

Conforms

(Section 3.1.1)

Conforms

(Section 3.1.1)

5 Has the development of

certification criteria been initiated

by national forest owners'

Annex 2,

3.4.1

organisations or national forestry

sector organisations having support

of the major forest owners'

organisations in that country? [*1]

Yes

Section 1 and 7

of UFCS

Conforms

(Section 3.1.1)

6 Have all relevant interested parties

representing the different aspects of

sustainable forest management

Annex 2,

been invited to participate in the

3.4.1

standard setting process and a

created Forum? [*1]

7 Do consensus-building procedures of

the Forum provide for balanced

Annex 2,

representation of interest

3.4.1

categories? [*2]

8 Have the views of all relevant

interested parties been documented

and considered in an open and

transparent way? [*3] Annex 2,

3.4.1

Doc.

Yes

Section 7 of

UFCS.

Does not Conform

(Section 3.1.2)

Process Yes Annex 1 Does not Conform

(Section 3.1.2)

Doc.

Yes

Process Yes Annex 1

Doc.

Yes

Section 7 of

UFCS.

Section 7 of

UFCS.

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

9 Has the formal approval of standards

been based on evidence of

consensus? [*3] Annex 2,

3.4.1

Process Yes Annex 1

Doc.

Yes

Process Yes Annex 1

Section 7 of

UFCS

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

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No.

Question

10 Does the implementation of the

consensus based approach comply

with Guideline GL 5/2006

Reference

to PEFC

Council

doc.

11 Has the Forum defined its own

written procedures which have been

made available to interest parties

upon request? [*2] Annex 2,

3.4.1

12 Do the written procedures for

standard setting contain an appeal

mechanism for impartial handling of

any substantive and procedural

complaints? [*2]

13 Has the start of the standard setting

process been communicated to the

public? [*3]

Assess.

Basis*

Yes/

No*

GL 5/2006 Doc. Yes

Process Yes Annex 1

Doc.

Yes

Process Yes Annex 1

Annex2,

3.4.1 Doc. No

Annex2,

3.4.2

Process

Doc.

No

Yes

Reference to

application

documents

Section 7 of

UFCS.

Section 7 of

UFCS.

VER CON UNIT

Process Yes Annex 1

14 Has the information on the Annex 2,

development process been 3.4.2 Doc. Yes

distributed and discussed? [*3]

15 Has the final draft standard been

available to all interested parties, e.g.

by posting it on the Internet?

[*3]

16 Has the final draft standard been

sent out for formal national

Annex 2,

consultation process? [*3] 3.4.3

17 Have views of interested parties

been discussed? [*3] Annex 2,

3.4.3

18 Has the Forum given general

information on the changes made as

a result of a consultation process? [*3] Annex 2,

3.4.3

19 Had the consultation been at least

[*3]

60 days? Annex 2,

3.4.3

20-

34

Process

Yes

Annex 2,

3.4.2 Doc. Yes

Process

Doc.

Process

Doc.

Process

Doc.

Yes

Section 7 of

UFCS.

Section 7 of

UFCS.

Annex 1

Section 7 of

UFCS.

Annex 1

En proceso

Process Yes Annex 1

Doc.

Yes

Process Yes Annex 1

Standards for chain of custody certification

Questions relating to scheme specific

Chain of Custody standard

Section 7 of

UFCS.

Section 7 of

UFCS.

Consultant assessment &

reference to assessment

report (where relevant)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Conforms

(Section 3.1.2)

Does not conform

(Section 3.1.2)

Not Applicable

Pilot Testing

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No.

Question

Reference

to PEFC

Council

doc.

35 Have the first results on the testing

of the final drafts for national/subnational

forest certification

standards and their implementation

arrangements been available prior to Annex 2, 5

PEFC Council endorsement and

mutual recognition? [*7]

submission of the scheme for the

Assess.

Basis*

Doc.

Process

Yes/

No*

Yes

Reference to

application

documents

Section 7 of

UFCS.

Annex 2 and 3

Consultant assessment &

reference to assessment

report (where relevant)

Conforms

(Section 3.3)

Conforms

(Section 3.3)

36 Has appropriate action been taken

to incorporate improvements and

recommendations prior to

submission of the scheme for the

PEFC Council endorsement and

mutual recognition process? [*7]

Annex

2, 5

Doc.

Process

Yes

Section 7 of

UFCS.

Annex 1

Conforms

(Section 3.3)

Conforms

(Section 3.3)

37 Have the standards on forest and

chain of custody certifications been

reviewed at least every 5 years or is

it foreseen to review these standards

at least every 5 years?

38 Does the scheme documentation

indicate which organisation is

responsible to initiate the revision

work?

Review of Standards

Annex

2, 6.1 Doc. Yes

Annex 2, 6.1

Section 7 of

UFCS.

Conforms

(Section 3.4.1)

Process No Not applicable Not applicable

(Section 3.4.1)

Yes

Section 7 of

UFCS.

Conforms

(Section 3.4.1)

39 Has the revision procedures been

participatory, fair and transparent?

[*8]

Annex 2, 6.1

No

Not applicable

(Section 3.4.1)

40 Has the PEFC National Governing

Body appropriately considered the

revisions of the general PEFC Annex 2, 6.2

requirements for standard setting

and implementation in the national

standards? [*8]

Yes

Section 7 of

UFCS.

Not applicable

(Section 3.4.1)

41 Has the PEFC National Governing Annex 2, 6.2 No Not applicable Not applicable

Body indicated to the PEFC Council

(Section 3.4.1)

the appropriate considerations of the

revisions induced by the PEFC

Council in national standards? [*8]

Application documentation

The application for the endorsement and mutual recognition as defined in Chapter 5 of Annex 7 (Endorsement

and Mutual Recognition of National Schemes and their Revision) shall include information which enables the

assessment of the applicant scheme’s compliance with the PEFC Council requirements.

The application documentation should identify and make reference to other detailed documentation such as

minutes, internal procedures and rules, reports, etc. which do not need to create a part of the application

documentation.

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Asses. basis*

YES/NO*

The standard setting is assessed against the PEFC Council requirements in two stages (i)

compliance of written standard setting procedures (Doc.) and (ii) compliance of the standard

setting process itself (Process).

If the answer to any question is no, the application documentation shall indicate for each

element why and what alternative measures have been taken to address the element in

question.

[*1] Includes a description of an organisation responsible for co-ordination and decision making in the forest

management standard setting process; details on organisations and/or individuals who participated and/or who

were invited to participate in the standard setting process including their status (forest owners, industry, E-NGO,

etc.); creation of a Forum and representation of different stakeholders.

Questions: 1, 3, 5, 6

[*2] Includes information on written procedures for forest management standard setting process adopted by the

Forum

Questions: 7, 11, 12

[*3] Includes a description of the forest management standard setting process including measures for ensuring

transparency and credibility of the standard setting process; details on meetings and other events; public

availability of draft documents; consultation process and time periods.

Questions: 8, 9, 13, 14, 15, 16, 17, 18, 19

[*4] Includes a description of a organisation responsible for co-ordination and decision making of the chain of

custody standard setting process, details on organisations and/or individuals who participated and/or who were

invited to participate in the standard setting process including their status (forest owners, industry, E-NGO, etc.);

creation of a Forum and representation of different stakeholders.

Questions: 20, 21, 22

[*5] Includes a description of the chain of custody standard setting process including measures for ensuring

transparency and credibility of the standard setting process; details on meetings and other events; public

availability of draft documents; consultation process and time periods.

Questions: 24, 25, 29, 30, 31, 32, 33, 34

[*6] Includes information on written procedures for chain of custody standard setting process adopted by the

Forum.

Questions: 23, 27, 28

[*7] Includes information on pilot project(s) for the testing of forest management and/or chain of custody

standards; scope of the pilot projects; details on organisations/ individuals participated in the pilot projects;

results of the pilot projects and follow up actions.

Questions: 35, 36

[*8] Includes a description of the process of review and revision of the national standard(s)

Questions: 39, 40, 41

www.itsglobal.net Page 55

PART II: MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION SCHEMES AND THEIR

IMPLEMENTATION (ANNEX 3)

SCOPE:

Part II covers requirements for certification schemes and their implementation given in Annex 3

of the PEFC Council Technical Document (Basis for certification schemes and their

implementation).

No.

Question

Reference to

PEFC

Council doc.

YES / NO*

General requirements for certification criteria

1 Are the criteria relevant to all types Annex 3, 3.6

of forests and management

systems, which exist in the

nation/region they have been

elaborated for?

2 Do the criteria clearly express the Annex 3, 3.6

objectives for forest management

that can be unambiguously verified

by different auditors?

Reference to scheme

documentation

Consultant

comment &

reference to

assessment

report

Conforms

(Section 4.1.1

Conforms

(Section 4.1.1)

3 Are management and performance

requirements applicable at the level

of a forest management unit?

Annex 3, 3.6

Conforms

(Section 4.1.1)

Annex 3, 3.6 Conforms

4 Are management and performance

also at group and regional levels? [*5]

requirements applicable optionally

(Section 4.1.1)

Other requirements for Forest management criteria

5 Does the scheme require that

property rights and land tenure

arrangements shall be clearly

defined, documented and

established for the relevant forest

area?

6 Does the scheme require the

clarification, recognition and respect

of legal, customary and traditional

rights related to the forest land in

compliance with chapter 3.5 of

Annex?

7 Does the scheme require that a

summary of the forest management

plan or its equivalent, which

contains information about the

forest management measures to be

applied, is publicly available, except

for confidential business and

personal information?

8 Are the national certification criteria

in compliance with national laws

programmes and policies?

9 Are the references to national laws,

programs and policies indicated in

Annex 3, 3.5

Laws and regulations

Annex 3, 3.2,

3.6

Annex 3, 3.6

Conforms

(Section 4.1.2)

Conforms

(Section 4.1.2)

Does not

Conform

(Section 4.1.2)

Conforms

(Section 4.1.3)

Conforms

(Section 4.1.3)

www.itsglobal.net Page 56

No.

Question

Reference to

PEFC

Council doc.

YES / NO*

Reference to scheme

documentation

Consultant

comment &

reference to

assessment

report

the scheme documentation when

relevant, e.g., if the requirement of

the PEOLG is not addressed in the

certification criteria but is included

in normative regulations?

10 Does the scheme include the

requirement that any apparent

violation of the legislation shall be

taken into consideration in internal

and external audits?

Annex 3, 3.2

Conforms

(Section 4.1.3)

ILO Conventions

11 Are the Core ILO Conventions

ratified by the country and

implemented through the legislative

framework?

Annex 3, 3.3

Conforms

(Section 4.1.4)

12 Do the national certification criteria

address the core elements of those

Core ILO Conventions, which have

been not ratified by the country?

Annex 3, 3.3

Conforms

(Section 4.1.4)

13 Has the ILO Code of Practise on

Safety and Health in Forestry Work

been considered in development of

national and regional certification

criteria?

Annex 3, 3.3

Conforms

(Section 4.1.4)

Other international conventions

14 Are the international conventions

relevant to forest management and

ratified by the country and

respected through the legislative

framework?

Annex 3, 3.4

Conforms

(Section 4.154)

15 Are the requirements agreed upon

in the conventions, even if they are

not ratified by the country,

respected in the certification criteria

to the degree that they are covered

in PEOLG or other reference

documents basis approved by the

PEFC Council?

Annex 3, 3.4

Conforms

(Section 4.1.5)

Level of application – general

16 Are the applicants, the certified

areas and participating forest

owners/managers/others actors

clearly identified in the scheme

documentation?

Annex 3, 4.1

Conforms

(Section 4.2.1)

17 Does the scheme documentation

require that all actors involved in or

operating on the certified area

comply with the certification

requirements?

Annex 3, 4.1

Conforms

(Section 4.2.1)

18 Does the scheme documentation

require that all actors individually

certified or participating in

regional/group certification are

Annex 3, 4.1

Conforms

(Section 4.2.1)

www.itsglobal.net Page 57

No.

Question

responsible for ensuring that

contractors’ activities and

operations meet the respective

forest management criteria?

Reference to

PEFC

Council doc.

YES / NO*

Reference to scheme

documentation

Level of application – regional certification (only for schemes which include regional certification)

19 Does the national definition of

regional certification comply with

the PEFC Council definition?

20 Does the forest certification

standard include criteria for the

regional and also for forest

management unit level?

21 Does the scheme documentation

require that the assessment of the

certification criteria defined for the

regional level covers the whole

region to be certified?

22 Does the scheme documentation

require that sampling for the

assessment of the certification

criteria defined for the forest

management unit level cover forest

owners/managers/other actors

participating in the regional

certification?

23 Does the scheme documentation

require that the applicant

organisation shall be a legal entity?

24 Does the scheme documentation

require that the applicant

organisation should represent more

than 50 % of forest area of the

region? (This does not need to be

fulfilled by the time of the start of

certification – see reference)

25 Does the scheme documentation

describe the applicant’s

responsibility to assure the

compliance of all participants with

the certification requirements?

26 Does the scheme documentation

describe the applicant’s

responsibility to ensure that credible

registers of participants to

certification and certified forest area

are kept?

27 Does the scheme documentation

describe the applicant’s

responsibility to implement rules for

regional certification?

28 Does the scheme documentation

define the responsibilities and

authorities of the applicant and

Annex 3, 4.1, a

NA

Consultant

comment &

reference to

assessment

report

www.itsglobal.net Page 58

No.

Question

participating

forest

owners/managers for the inclusion

of new participants and to inform

the certification body thereof?

29 Does the scheme documentation

define the responsibilities and

authorities of the applicant and

participating

forest

owners/managers for the internal

control of conformity and follow up

corrective and preventive

measures?

30 Does the scheme documentation

describe that forest management

certificate is issued to the applicant

(certificate holder)?

31 Does the scheme documentation

describe that participants in regional

certification shall receive either a

copy of the regional certificate

including the appendix (when

applicable) listing all participating

forest owners or an individual

attestation issued by the

certification body or the applicant

which refers to the main certificate?

32 Does the scheme documentation

require that forest

owners/managers/other actors can

participate in the regional

certification either by (i) entering

into an individually signed

commitment, or (ii) based on the

majority decision of a forest owner’s

organisation on behalf of forest

owners they represent in the

region?

33 Does the scheme documentation

require that only participating forest

owners / managers shall be

considered as certified; their area

counted as certified area and the

forest raw material coming from

thereof will be considered as

certified raw material?

34 Does the scheme documentation

describe that forest owners should

submit all the forest area under his

management in the region for

certification? (not obligatory to be

met but should be aimed at)

Reference to

PEFC

Council doc.

Annex 3, 4.1, a

YES / NO*

Reference to scheme

documentation

Level of application – group certification (only for schemes which include group certification)

35 Does the national definition for

group certification comply with the

Annex 3, 4.1 b Yes Uruguay Forest Certification

Scheme DG 07.

NA

Consultant

comment &

reference to

assessment

report

Conforms

(Section 4.2.3)

www.itsglobal.net Page 59

No.

Question

PEFC Council definition?

36 Does the scheme documentation

clearly define who the applicant is

for group certification?

37 Does the scheme documentation

describe the applicant’s

responsibility to assure the

compliance of all participants with

the certification requirements?

38 Does the scheme documentation

describe the applicant’s

responsibility to ensure that credible

registers are kept of participants to

certification and certified forest

area?

39 Does the scheme documentation

describe the applicant’s

responsibility to implement the

rules for group certification?

40 Does the scheme documentation

require that total forest area

participating in group certification is

recorded?

41 Does the scheme documentation

describe that forest owners should

submit all the forest area under his

management in the catchment area

for the group certification? (not

obligatory to be met but should be

aimed at)

42 Does the scheme documentation

define the responsibilities and

authorities of the applicant and

participating

forest

owners/managers for the inclusion

of new participants and to inform

the certification body thereof?

43 Does the scheme documentation

define the responsibilities and

authorities of the applicant and

participating

forest

owners/managers for the internal

control of conformity and follow up

corrective and/or preventive

measures?

44 Does the scheme documentation

describe that the forest

management certificate is issued to

the applicant (certificate holder)?

45 Does the scheme documentation

describe that participants in group

certification shall receive either a

copy of the regional certificate

Reference to

PEFC

Council doc.

YES / NO*

Reference to scheme

documentation

Consultant

comment &

reference to

assessment

report

Annex 3, 4.1 b Yes DG 07: Section 3 and 4 Refer to Section

4.2.3

Annex 3, 4.1 b Yes DG 07: Section 4.2 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07: Section 4.6 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07: Section 4.1 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07: Section 4.6 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07: Section 7.1 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07:Section 4.8 and 4.11 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes DG 07: Section 4.3 and 7.3 Conforms

(Section 4.2.3)

Annex 3, 4.1 b Yes Uruguayan Forest Certification

Scheme

DG 07:Section 4.10

Conforms

(Section 4.4.3)

Annex 3, 4.1 b Yes DG 07: Section 4.10,6.2 and 6.3 Conforms

(Section 4.4.3)

www.itsglobal.net Page 60

No.

Question

including the appendix (when

applicable) listing all participating

forest owners or an individual

attestation issued by the

certification body or the applicant

which refers to the main certificate?

Reference to

PEFC

Council doc.

YES / NO*

Reference to scheme

documentation

Level of application – individual certification (only for schemes which include individual certification)

Annex 3, 4.1 c

46 Does the scheme documentation

describe that forest owner should

submit all the forest area under his

management in the catchment area

of the certification scheme in the

certification? (not obligatory to be

met but should be aimed at)

Implementation of changes to the scheme

47 Does the scheme documentation Annex 3, 5

define transition period(s) for

implementation of changes to the

endorsed scheme in compliance

with chapter 5 of Annex 3?

(This is not applicable to the initial

endorsement of a scheme)

Appeals, complaints and dispute procedures

48 Has the PEFC National Governing

Body set up or appointed an

impartial and independent dispute

settlement body on a permanent

basis or does it have written

procedures for the establishment of

a dispute settlement body on an ad

hoc basis?

49 Has the PEFC National Governing

Body established and have

documented procedures for an

independent dispute settlement

body, either permanent or ad hoc,

that takes care of those complaints

arising from forest management or

chain of custody scheme

implementation that cannot be

addressed in the dispute settlement

procedures of the relevant

certification or accreditation body?

50 Can the dispute settlement body

also resolve possible grievances in

chain of custody certification that do

not exclusively concern an applicant

and a certification body?

51 Does the scheme documentation

require that the accredited

certification body has procedures

for dispute settlement for all

grievances between the applicant

and the certification body?

Consultant

comment &

reference to

assessment

report

Conforms

(Section 4.2.4)

NA

(Section 4.2.5)

Annex 3, 6.1 Yes GD 06: Section 3 Conforms

(Section 4.3)

Annex 3, 6.1 Yes DG 06 Conforms

(Section 4.3)

Annex 3, 6.1 Yes DG 06 – DG 03: Section 13 Conforms

(Section 4.3)

Annex 3, 6.2 Yes DG 03: Section 13 Conforms

(Section 4.3)

www.itsglobal.net Page 61

No.

Question

52 Does the scheme documentation

require that the relevant

accreditation body, whose

accreditation covers the

certification, deals with disputes and

complaints concerning observance

of the accreditation requirements?

Reference to

PEFC

Council doc.

YES / NO*

Reference to scheme

documentation

Consultant

comment &

reference to

assessment

report

Annex 3, 6.2 Yes DG 03: Section 13 Conforms

(Section 4.3)

www.itsglobal.net Page 62

PART III:

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH PEOLG

(ANNEX 3, CHAPTER 4.2)

SCOPE

Part III covers requirements for certification criteria (forest management standards) for all

schemes except those which are covered by ATO/ITTO PCI and by ITTO process.

No.

1

2

Question

Reference

to PEFC

Council doc.

YES /

NO*

Reference to scheme documentation

Basis for criteria development (only for schemes based on MCPFE)

Are certification criteria

used in the national or

sub-national scheme

Annex 3,

based on Pan European

3.1.1

Criteria and Indicators

for SFM as a common

framework?

Have the Pan European

Operational Level

Guidelines (PEOLG)

formed the reference

base when the national

and regional criteria

Annex 3,

3.1.2

Consultant

comment &

reference

to

assessment

report

Refer to

Section 5 of

Report

Refer to

Section 5 of

Report

were elaborated,

amended or revised?

Basis for criteria development (only for schemes based on inter-governmental processes other than MCPFE, ATO/ITTO

and ITTO)

The UFCS

Are the certification

certification

criteria based on the

criteria are

inter-governmental

based on

3

process other than

Montreal

Annex 3,

MCPFE, ATO /ITTO and

Process

3.1.5

ITTO process (only for

Criteria.

process)? [*2] Section 5 of

countries which

participated in this

Refer to

Report

Compatibility with the PEOLG (only for schemes to be assessed against the PEOLG) [*1]

4

PEOLG 1.1.a

Conforms

5 Criterion 1: Maintenance PEOLG 1.1.b Conforms

6 and appropriate PEOLG 1.1.c Conforms

7 enhancement of forest PEOLG 1.1.d Conforms

8 and their contribution to PEOLG 1.2.a Conforms

9 global carbon cycle PEOLG 1.2.b Conforms

10 PEOLG 1.2.c Conforms

11

PEOLG 2.1.a

Conforms

12 PEOLG 2.1.b Conforms

13 Criterion 2: Maintenance PEOLG 2.1.c Conforms

14 of forest ecosystem PEOLG 2.2.a Conforms

15 health and vitality PEOLG 2.2.b Conforms

16 PEOLG 2.2.c Conforms

17 PEOLG 2.2.d Conforms

18

PEOLG 3.1.a

Conforms

19 Criterion 3: Maintenance PEOLG 3.1.b Conforms

20 and encouragement of PEOLG 3.1.c Conforms

21 productive functions of PEOLG 3.2.a Conforms

22 forests (wood and nonwood)

PEOLG 3.3.c Conforms

PEOLG 3.2.b Conforms

23

24 PEOLG 3.3.d Conforms

25 Criterion 4: Maintenance, PEOLG 4.1.a

Conforms

26 conservation and PEOLG 4.1.b Conforms

27 appropriate

PEOLG 4.2.a Conforms

28 enhancement of PEOLG 4.2.b Conforms

29 biological diversity in PEOLG 4.2.c Conforms

www.itsglobal.net Page 63

No.

Question

Reference

to PEFC

Council doc.

YES /

NO*

Reference to scheme documentation

Consultant

comment &

reference

to

assessment

report

30 forest ecosystems PEOLG 4.2.d Conforms

31 PEOLG 4.2.e Conforms

32 PEOLG 4.2.f Conforms

33 PEOLG 4.2.g Conforms

34 PEOLG 4.2.h Conforms

35 PEOLG 4.2.i Conforms

36 Criterion 5: Maintenance PEOLG 5.1.a

Conforms

37 and appropriate PEOLG 5.1.b Conforms

38 enhancement of PEOLG 5.2.a Conforms

39 protective functions in PEOLG 5.2.b Conforms

forest management

40

(notably soil and water)

PEOLG 5.2.c

Conforms

41

PEOLG 6.1.a

Conforms

42 PEOLG 6.1.b Conforms

43 PEOLG 6.1.c Conforms

Criterion 6: Maintenance

44 PEOLG 6.1.d Conforms

of other socio-economic

45 PEOLG 6.1.e Conforms

functions and conditions

46 PEOLG 6.2.a Conforms

47 PEOLG 6.2.b Conforms

48 PEOLG 6.2.c Conforms

[*1]

For the purposes of PEFC assessment and endorsement of national or sub national forest

certification schemes the terms “should” used in the PEOLG shall be interpreted as “shall”.

www.itsglobal.net Page 64

PART IV:

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH ATO / ITTO

PCI (ANNEX 3, CHAPTER 4.3)

SCOPE

Part IV includes requirements for certification criteria (forest management standards for

schemes which are covered by ATO/ITTO PCI.

Not applicable

PART V:

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH ITTO

GUIDELINES (ANNEX 3, CHAPTER 4.4)

SCOPE

Part V included requirements for certification criteria (forest management standards) for forest

management of natural tropical forests and planted tropical forests for scheme developed in

ITTO member producing countries except those which are covered by ATO/ITTO PCI (as per Part

IV).

Not applicable

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PART VI:

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME SPECIFIC CHAIN OF CUSTODY

STANDARDS (ANNEX 4)

The UFCS does not have a Scheme specific CoC. The UFCS utilizes PEFCC Annex 4 for CoC

certification under the UFCS. As a consequence Part VI of Checklist is Not Applicable.

SCOPE

Not applicable.

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PART VII:

MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION AND ACCREDITATION

PROCEDURES (ANNEX 6)

SCOPE

This document covers requirements for certification and accreditation procedures given in

Annex 6 to the PEFC Council Technical Document (Certification and accreditation procedures).

No. Question Reference to

PEFC Council

doc.

Certification Bodies

YES /

NO*

Reference to

scheme

documentation

Consultant comment

& reference to

assessment report

1. Does the scheme documentation require that

certification shall be carried out by impartial,

independent third parties that cannot be

involved in the standard setting process as

governing or decision making body, or in the

forest management and are independent of

the certified entity?

2. Does the scheme documentation require that

certification body for forest management

certification or chain of custody certification

against a scheme specific chain of custody

standard shall fulfil requirements defined in

ISO Guide 62, or ISO Guide 66, or ISO Guide

65?

3. Does the scheme documentation require that

certification body chain of custody

certification against Annex 4 shall fulfil

requirements defined in ISO Guide 65?

4. Does the scheme documentation require that

certification bodies carrying out forest

certification shall have the technical

competence in forest management on its

economic, social and environmental impacts,

and on the forest certification criteria?

5. Does the scheme documentation require that

certification bodies carrying out C-o-C

certifications shall have technical

competence in forest based products

procurement and processing and material

flows in different stages of processing and

trading?

6. Does the scheme documentation require that

certification bodies shall have a good

understanding of the national PEFC system

against which they carry out forest

management or C-o-C certifications?

7. Does the scheme documentation require that

certification bodies have the responsibility to

use competent auditors and who have

adequate technical know-how on the

certification process and issues related to

forest management or chain of custody

certification?

Annex 6, 3.1 Yes DG 03: Section

5c and 5d

Annex 6, 3.1 Yes DG 03: Section

5n and 5o

Annex 6, 3.1 Yes DG 03: Section

5o

Annex 6, 3.1 Yes DG 03: Section

5m

DG 04

Annex 6, 3.1 Yes DG 03: Section

5m

DG 04

Annex 6, 3.1 Yes DG 03: Section

4

DG 04

Conforms

(Section 8.1.1)

Conforms

(Section 8.1.1)

Conforms

(Section 8.1.1)

Conforms

(Section 8.1.1)

Conforms

(Section 8.1.1)

Conforms

(Section 8.1.1)

Annex 6, 3.2 Yes DG 04 Conforms

(Section 8.1.2)

www.itsglobal.net Page 67

No. Question Reference to

PEFC Council

doc.

8. Does the scheme documentation require that

the auditors must fulfil the general criteria of

ISO 19011 for Quality Management Systems

auditors or for Environmental Management

Systems auditors?

9. Does the scheme documentation include

additional qualification requirements for

auditors carrying out forest management or

YES /

NO*

Reference to

scheme

documentation

Annex 6, 3.2 Yes DG 04: Section

4 and 9

Annex 6, 3.2 Yes DG 04: Section

5.1, 5.2, 5.3, 8.1

and 8.3.

Certification procedures

Consultant comment

& reference to

assessment report

Conforms

(Section 8.1.2)

Conforms

(Section 8.1.2)

10. Does the scheme documentation require that

certification bodies shall have established

internal procedures for forest management

and/or chain of custody certification?

11. Does the scheme documentation require that

applied certification procedures for forest

management certification or chain of custody

certification against a scheme specific chain

of custody standard shall fulfil or be

compatible with the requirements defined in

ISO Guide 62, or ISO Guide 66, or ISO Guide

65?

12. Does the scheme documentation require that

applied certification procedures for chain of

custody certification against Annex 4 shall

fulfil or be compatible with the requirements

defined in ISO Guide 65?

13. Does the scheme documentation require that

applied auditing procedures shall fulfil or be

compatible with the requirements of ISO

19011?

14. Does the scheme documentation require that

certification body shall inform the relevant

PEFC National Governing Body about all

issued forest management and chain of

custody certificates and changes concerning

the validity and scope of these certificates?

15. Does the scheme documentation require that

certification body shall carry out controls of

PEFC logo usage if the certified entity is a

PEFC logo user?

Annex 6, 4 Yes DG 03: Section

5q

Annex 6, 4 Yes DG 03: Section

3c and d

Annex 6, 4 Yes DG 03: Section

3d

Annex 6, 4 Yes DG 03: Section

5q

Annex 6, 4 Yes DG 03: Section

5w

Annex 6, 4 Yes DG 03: Section

5x

Conforms

(Section 8.2)

Conforms

Section 8.2)

Conforms

Section 8.2)

Conforms

Section 8.2)

Conforms

Section 8.2)

Conforms

Section 8.2)

16. Does a maximum period for surveillance

audits defined by the scheme documentation

not exceed more than one year?

17 Does a maximum period for assessment audit

not exceed five years for both forest

management and chain of custody

certifications?

18 Does the scheme documentation include

requirements for public availability of

certification report summaries?

19 Does the scheme documentation include

requirements for usage of information from

external parties as the audit evidence?

Annex 6, 4 Yes DG 03: Section 5p Conforms

Section 8.2)

Annex 6, 4 Yes DG 03: Section

5p2

Annex 6, 4 Yes DG 03: Section

9g

Annex 6, 4 Yes DG 03: Section

10

Conforms

Section 8.2)

Conforms

Section 8.2)

Conforms

Section 8.2)

www.itsglobal.net Page 68

No. Question Reference to

PEFC Council

doc.

YES /

NO*

Reference to

scheme

documentation

20. Does the scheme documentation include Annex 6, 4 Yes DG 03: Section

additional requirements for certification

11

procedures? [*1]

Accreditation procedures

Consultant comment

& reference to

assessment report

Conforms

(Section 8.2)

21. Does the scheme documentation require that

certification bodies carrying out forest

management and/or chain of custody

certification shall be accredited by a national

accreditation body?

22. Does the scheme documentation require that

an accredited certificate shall bear an

accreditation symbol of the relevant

accreditation body?

23. Does the scheme documentation require that

the accreditation shall be issued by an

accreditation body which is a part of the

International Accreditation Forum (IAF)

umbrella and which implement procedures

described in ISO 17011 and other documents

recognised by the above mentioned

organisations?

24. Does the scheme documentation require that

certification body undertake forest

management or/and chain of custody

certification against a scheme specific chain

of custody standard as “accredited

certification” using one of two options

recognised by the PEFC Council?

25. Does the scheme documentation require that

certification body undertake chain of custody

certification against Annex 4 as “accredited

certification” based on ISO Guide 65?

26. Does the scheme documentation include a

mechanism for PEFC notification of

certification bodies?

27. Are the procedures for PEFC notification of

certification bodies non-discriminatory?

Annex 6, 5 Yes DG 03: Section

3a

Annex 6, 5 Yes GD 03: Section

3d

Annex 6, 5 Yes DG 03: Section

3a

Annex 6, 5 Yes DG 03: Section

3c and d

Annex 6, 5 Yes DG 03: Section

3d

Annex 6, 6 Yes DG 03: Section

3 e

Annex 6, 6 Yes DG 03: Section

4

Conforms

(Section 8.3)

Does not conforms

(Section 8.3)

Conforms

(Section 8.3)

Conforms

(Section 8.3)

Conforms

(Section 8.3)

Partly Conforms

(Section 8.4)

Does not Conform

(Section 8.4)

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Annex 4. Assessment of the Uruguayan Forest Certification Scheme - Panel of Experts review

Issues raised by the Panel of Experts and Consultants’ responses are detailed in the following table.

Report

chapter/

page

Consultant’s report

statement

PoE member comment

SUMMARY OF PoE review

As a summary of my review of the evaluation report, I

cannot consider that the information provided by the

consultant has provided the objective evidence to provide

the consultant’s positive assessment of the UFCS.

Consultant’s response

General

There is no doubt that a positive evaluation is achievable,

on the basis of the UFCS documentation, provided the

consultant addresses to issues I have identified in my

consideration.

There are definitely more than 3 issues as identified by the

consultant, in my opinion, and any recommendation for

endorsement of the UFCS would definitely be a conditional

one with agreed work required within timelines.

Comments noted. Additional text has been

added to justify Consultants’ assessment with

conclusions modified accordingly.

General

Having read relevant sections of the UFCS documentation to

back up the assessment by the consultant and

acknowledging that English is a second language for PEFC

Uruguay, the review of the UFCS by an English as a first

language would be beneficial for the UFCS if it is to be

maintained on the PEFC website.

The assessment is based on the normal documentation (desk

work) and a 4-5 days field visit with various meetings. Since

ITS Global is from Australia there are no linguistic

deficiencies. It is clearly structured and its

recommendations can be fully supported.

A few major and minor items, however, need further

clarification (following the pages of the report):

Comments noted.

www.itsglobal.net Page 70

General

A lot of evidence of the assessment is based on findings

during the field visit (from documents or/and oral sources?),

the total absence of cooperation of ENGOs is certainly a

major weakness of the scheme (the Department of the

Environment being part of government!) Would there not

have been a possibility during the field visit to meat at least

one of them (f.e. WWF, IUCN, Friends of the Earth,

Greenpeace or the Uruguyan Umbrella organisation)?

Comments valid.

During Field Visit attempts to contact Group

Guayubira (Uruguayan umbrella organisation)

were unsuccessful.

1 Executive Summary, 2 Introduction, 3 History and structure of the UFCS

3 Preface, 2 nd Para

UFCS was …

As the UFCS is basically an object, it need to be identified

properly i.e.

The UFCS was …

6 Acronyms A check of the UNIT website indicates its spelling as

Instituto Uruguayo de Normas Técnicas

IEC is missing from the list

Why is ‘management systems’ in lower case for QMS?

7 Recommendation to PEFC

Council Board of Directors,

1 st Para

… of the Program for the …

Why is ‘forest management’ in lower case for SD?

Incorrect term for PEFC – it is Programme

Comments valid. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

7 Summary of Findings, 1 b. Spelling of UNIT – see above for correct spelling Comments valid. Report has been amended

accordingly.

p.8 ... comments received from PEFCC members and “other

stakeholders”. Who were they, please identify.

8 1. Introduction

… to PEFCC (Program for

Endorsement of Forest

Certification Council) for …

Incorrect term for PEFC – it is Programme for the

Endorsement of Forest Certification schemes Council

One submission was received (after the public

consultation phase had closed) from Cassie

Phillips, Vice President, Sustainable Forests

and Products, Weyerhauser (Refer to Annex

1).

Comments valid. Report has been amended

accordingly.

8 Assessment Process and Expression: Comments valid. Report has been amended

Methodology for Report, 1 st accordingly.

www.itsglobal.net Page 71

Para

… reviewed during Field

Visit.

8 Assessment Process and

Methodology for Report, 3 rd

Para

… PEFC consultants

assessing forest

certification schemes.

9 2. History and Structure of

the Uruguayan Forest

Certification Scheme

(UFCS), 2 nd Para

… of the organisational

structures and process …

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Para

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Para

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Phase, 1 st Para

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Phase, 3 rd

Para

The STC-SFM …

… reviewed during the Field Visit.

Clarification

… PEFC consultants assessing national forest certification

schemes.

Do these words relate to PEFC Uruguay?

Clarification:

… of the organisational structures and implementation

processes …

Use of Evolution in heading and in 1 st Para – surely the

correct word in the context of standardisation is

‘Development’?

Having read the full report and some of the UFCS

documentation, I would make it explicit in this paragraph

that the standard only covers plantations and not any native

forests in Uruguay.

Incorrect spelling of UNIT – see Page 6 comment above

There is no information on Uruguayan Society of Forestry

Producers – a short footnote to describe them would be

helpful

Is this body the standard setting body? I believe this is a

better expression

Does the Code of Good Forest Practice (2004) have a URL?

An annex indicating the Uruguayan Government forestry

policies would be useful for UFCS to have as part of its

documentation

… as reference documents to develop the sustainable …

Comments noted. Report has been amended

accordingly.

Comments noted. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

Comments noted. Explanatory phrase added

to text.

Comment noted. Report has been amended

accordingly.

Comments noted. Explanatory phrase stating

that STC-SFM is the standard setting body

referred to in PEFCC document has been

added to text.

www.itsglobal.net Page 72

… as reference document to

develop sustainable …

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Phase, 4 th

Para

… (Spanish forest

management standard).

9 2.1 Evolution of Sustainable

Forest Management

Standard, 1 st Phase, 5 th

Para, 1 st and 2 nd dot points

The document …

Clarification

… (Spanish forest management standard which is endorsed

under the Spanish scheme).

This document …

It is STC-SFM not SFC-SFM!

UNIT 1152 is before UNIT 1151 – it is normal to have

documents listed in numerical order even though 1152 is the

actual SFM standard

p.10 are all the necessary documents for evaluation in English?

Yes or no. )last but one sentence; see also page 17, 15 Doc.)

p.10 the non-conformity with public consultation (53 instead of

60 days minimum) may be tolerated under the existing

circumstances, but the total absence of responses is not

encouraging. Less important is the issue of the accreditation

symbol (p.42, 8.5, 22) because it is not a mandatory

requirement.

10 2.1 Evolution of Sustainable There is more than 1 requirement in Annex 4!

Forest Management

Standard, 1 st Phase, 5 th … the use of the requirements specified …

Para, 3 rd dot point

… the use of requirement

Comments noted. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

1. All necessary documents are not in English.

2. As noted in the body of the report, five

organisations commented during public

consultation phase (April-May 2009).

Comments noted. Additional text added for

further clarification.

Comments valid. Report has been amended

accordingly.

Clarification Comments valid. Report has been amended

specified …

10 2.1 Evolution of Sustainable

Standard, 2 nd Phase, 1 st

Forest Management

accordingly.

www.itsglobal.net Page 73

Para

… gaining PEFC membership

in 2009 … as PEFC

Governing Body …

10 2.1 Evolution of Sustainable

Forest Management

Standard, 2 nd Phase, 2 nd

Para

… PEFC Uruguayan

Associations Assembly on 15

December 2009 …

8 th Para

… PEFC Uruguayan

Associates Assembly on 15

December 2009 …

… gaining PEFC Council membership in 2009 … as PEFC

National Governing Body …

Please indicate the timing of the pilot testing to place it in

perspective with dates in paragraph

… PEFC Uruguayan Associations Assembly on 18 December

2009 …

- need to clarify the organisation’s name as

‘Associates’ is used on pages 10 & 11 and

‘Associated’ is used on page 21

- the 18 th is used in 2.2 on page 11

Comments noted.

1. Additional text added to clarify the

sequence of pilot testing.

2. Text standardized to PEFCC Uruguayan

General Assembly.

10 2.1 Evolution of Sustainable

Forest Management

Standard, 2 nd Phase, 8 th

Para

As documented, the UFCS

uses these standards

together with …

11 2.2 Organisational Structure

of UFCS

1 st Para

… to align to requirements

of PEFCC for mutual

recognition. …

… Assembly approved UFCS

…

11 2.2 Organisational Structure

of UFCS

2 nd Para

As documented above, the UFCS uses these forest

management standards together with …

… to the align with the requirements of PEFCC for mutual

recognition of the UFCS. …

… Assembly approved the UFCS …

Use of ‘Revised’ – usually means the re-endorsement

documentation i.e. after 5 years. Why use revised here?

Comments valid. Report has been amended

accordingly.

Comments valid. Text amended accordingly.

In this context ‘revised’ refers to the process

of developing the UFCS (rather than its

application for endorsement under PEFC)

www.itsglobal.net Page 74

11 2.3 Documentation, 1 st Para This isn’t a review – it is a conformity assessment!

It should be noted that the …

Please note that the …

11 2.3 Documentation, 2 nd Accordingly, PEFC Uruguay’s forest certification …

Para

Accordingly the PEFC

Uruguay certification …

11 General Documents (GD) Why is there a full stop after the document identifier? See

the SD listing which doesn’t have the full stop!

11 System Documents (SD) – These are labelled DG in the relevant folder of the UFCS.

PEFC Uruguay

Need to ensure the correct identifier is used!

What is ‘Organism’ in SD03 – it usually is the Spanish

translation of ‘Organisation’

11 2.3 Documentation, 4 th Para

The UFCS also refers to

documentation which is

referenced to support

Scheme documentation

including:

12 2.3 Documentation, 4 th Para

3 rd dot point

5 th dot point

The UFCS also refers to documentation from other sources

which are referenced to support the UFCS documentation

including:

It should be noted that ISO G 62 and 66 are no longer

applicable as replaced by ISO 17021!

The full name of the document should used especially for a

Montreal Process country.

Comments valid. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

Comments valid. Full stops removed.

The consultants intentionally used this

labelling system (SD) to reduce confusion (ie

between DG and GD).

“Organism”, not “organisation” is used in the

PEFC Uruguay document list submitted for

assessment.

Comments are valid. Report amended

accordingly.

Comments were noted and text amended

accordingly. Reference to ISO Guides 62 and

66 removed.

3 Assessment of the Standard Setting Procedures for UFSC against PEFCC requirements

13 3.1.1 Independence, 3) This set up is similar to Spain if I recollect – need to show

the coordination role if UNIT undertook it. See 1) iii of

Annex 2

I am unsure as to the Conforms rating for this question in

light of my comment.

The work of the Specialized Technical

Committee of Sustainable Forest Management

was co-ordinated and performed consistent

with UNIT’s procedures and processes. UNIT is

internationally recognised standard setting

body for Uruguay. Conform rating is

considered appropriate.

www.itsglobal.net Page 75

p.14

(bottom

line)

How many of the 36 organisations and individuals invite

actually participated in the process? A list would clarify

(physically present or by writing)

14 3.1.1 Independence, 5) Some documentation would be preferable e.g. a URL to

back up the pers comm.

14 3.1.2 Participatory Process

6)

Documentation

… of letter of invitation and

minutes …

Practice

15 3.1.2 Participatory Process

7)

15 3.1.2 Participatory Process

8)

Practice

15 3.1.2 Participatory Process

9)

Clarification

… of letter of invitation to participate on the STC-SFM and

minutes …

Do the 36 organisations cover the environmental, social and

economic interests in Uruguay?

This question is about representation – 9) is the question for

consensus. It should relate back to 6) for representation.

I am unsure as to the Conforms rating for this question in

light of my comment.

Are the ‘Project Meetings’ the committee meetings of the

STC-SFM? Whether it is or is not, it needs to be explained.

Are the ‘UNIT’s operating procedure’ in fact the ISO/IEC

Directive Part 1?

A review of Minutes of STC-SFM meetings

maintained by UNIT indicates that majority of

organisations were represented, although not

consistently, over the 40 meetings held by

STC-SFM to develop the Standards.

Text modified to clarify the report.

Unfortunately PEFC Uruguay could not locate

original documentation.

The list of organisations and persons invited

to participate in STC-SFM (held by UNIT) was

sighted during Field Visit and covers

environmental, social and economic interests

in Uruguay. Clarification text has been added.

Text clarified to confirm that STC-SFM used

consensus building procedures to provide

balanced representation by diverse

participants.

Project meetings refer to STC-SFM. Wording

of text has been clarified.

UNIT’s operating requirements are consistent

with ISO/IEC Directive, Part 1.

15 3.1.2 Participatory Process

10)

Documentation

16 3.1.2 Participatory Process

12)

Documentation

… in relation to standard

setting procedures.

16 3.1.2 Participatory Process

13)

Is there a specific document(s) which is/are the ‘UNIT’s

standard setting processes’?

Are the ‘UNIT statutes’ part of the other documents at 2.3,

4 th Para? If so, they need to be mentioned

Clarification

… in relation to STC-SFM’s standard setting procedures.

This is a very specific means of communication. The

general public is a much wider reach and there is no

Refer to www.iso.org for standard

development processes used by UNIT. Text

clarified.

Comments noted. Reference to UNIT’s

statutes incorporated in text.

Consultants agree that this is restricted

communication. Nonetheless it still

www.itsglobal.net Page 76

Documentation reference to any other type of communications. demonstrated communication to public.

Are the ‘UNIT regulations’ in fact the operating procedures Comments noted. Text has been clarified to

– see Q 6)?

clearly state that UNIT processes require

It is ISO/IEC not ISO/ICC.

conformity with ISO/IEC Directive, Part 1.

The name of the document should be included – it is

‘Procedures for the technical work 2008’

16 3.1.2 Participatory Process

14)

Documentation

17 3.1.2 Participatory Process

15)

Documentation

17 3.1.2 Participatory Process

17)

Practice

… were arrived at after …

p.18, 18

18 3.1.2 Participatory Process

18)

Practice

18 3.1.2 Participatory Process

19)

Documentation

However documentation

does state …

18 3.1.2 Participatory Process

19)

Practice

19 3.3 Pilot Testing 35)

Documentation

19 3.3 Pilot Testing 35)

Practice

From documentation

presented … third pilot

audit by consultant in

UNIT 1152 was approved in march 2007 but UNIT 1151 was

approved in May 2006 – need to have correct approval

dates.

As 2 documents ‘was’ should be ‘were made’

How does (April/May 2009) fit in with the Practice of 1 April

2009 to 28 June 2009?

… were finalised after …

It would be preferable to stick with standard as the correct

terminology in this context rather than use ‘norms’.

Does public availability on request (!) satisfy PEFCC? (see

also p. 23, 4.1.2, 7)

The (see below) is really 3.3, so why not indicate it

specifically?

However, documentation does state …

- the documentation is GD 2 and SD08, so why not indicate

it to assist others who want verification.

The question posed here is did the STC-SFM start its work

after May or after June – if it is June, the 60+ days would

possibly be OK in intent.

The 4 th sentence could reference back to Q 18).

Based on documentation presented … third pilot audit by a

consultant in March 2009 …

Is the consultant known – it would lend weight to the pilot

testing phase even if only the firm’s name was used.

Dates are correct. Text modified to more

clearly identify the final draft made available

to interested parties.

Comments were noted. Report has been

amended accordingly.

Comments noted. Wording of text has been

clarified.

Comments were noted. Report has been

amended accordingly.

Comments were valid. Report has been

amended accordingly.

Comments were noted. Additional text

included.

Comments were noted. Report has been

amended accordingly.

Comments were noted. Additional text has

been added.

www.itsglobal.net Page 77

March 2009 …

19 3.3 Pilot Testing 36)

Documentation

… of pilot testing in final

approved …

19 3.4.1 Periodic Review 37)

Documentation

… of pilot testing within the final approved …

Comments were valid. Report has been

amended accordingly.

It is SD08 not SG08.

Comments valid. Text modified as suggested.

Also, GD2 is applicable for documentation

… PEFCC Annex 4 requirements and it will be PEFCC’s

… PEFCC Annex 4

responsibility to review this standard.

requirements.

20 3.3 Pilot Testing 38) Why not indicate the UFCS documentation – GD2 and GD8? The consultants did not asses GD8 as relevant

in this context.

20 3.5 Overall Assessment Comment: I have a real concern on the assessment for 3), 7)

and 19) – I would seek further evidence to justify the

current assessment.

20 3.5 Overall Assessment, 1 st

dot point

Firstly the announced …

20 3.5 Overall Assessment, 2 nd

Para

As noted in response to

Question 19 the final draft

of forest management

standards was available …

Further letters informing …

21 3.5 Overall Assessment, 3 rd

Para

21 3.5 Overall Assessment, 4 th

Para

20 3.5 Overall Assessment, 2 nd

dot point

The first issue relates to the announced … - to be consistent

with the 2 nd dot point

As noted in the response to Question 19, the final drafts of

forest management standards were available …

Furthermore, letters informing …

It is assumed that ‘technical standards’ are the same as

‘national standards’?

This is only focussed on forest management – there is a need

for a sentence to cover off on CoC standard as part of the

UFCS package.

It would be preferable to indicate that the invitation was

sent to it (and to others) – dated letters sighted in Field

Visit.

Assessment modified to address nonconformities

associated with:

1. Lack of evidence to demonstrate

environmental NGOs were invited to

participate in deliberation of STC-SFM.

2. Public consultation being less than 60 days.

Comments were valid. Report has been

amended accordingly.

Comments were valid. Report has been

amended accordingly.

Comments noted. Additional text added to

provide further clarification.

Comments noted. Text has been amended

accordingly.

Comments valid. Additional text added.

www.itsglobal.net Page 78

4 Assessment of the implementation of UFCS against PEFCC requirements

p.21 (SD

13,

Section

4)

21 4. Assessment of the

Implementation of UFCS

against PEFCC

Requirements, 1 st Para

Performance requirements

for UFCS are detailed in

PEFC Uruguay system

documents (SD01 to SD09,

and GD2).

Does the “general society’s well being” include the

ecological components?

Performance requirements for the UFCS are detailed in

PEFC Uruguay system documents (SD01 to SD09) and GD2.

“general society’s well being” is interpreted

to incorporate economic, social and

environmental components. Text expanded to

reinforce SFM requirements.

Comment valid. Text has been amended

accordingly.

21 4. 3 rd Para Change case for Document ie document Comments noted. Report has been amended

accordingly.

21 4 th Para

Incorrect reference – it is GD2, 5.3 (it hasn’t been labelled Correct reference SD03 added.

(refer to GD3, Section 5.4) as 5.4 in the document)

21 5 th Para

The Forest Management

System …

It refers to planification – not normally used in English

(French for planning). An FMS is much more than planning!

There is no such document in 2.3. Is it in fact GD13?

Comments noted. Clarification text added to

state that General Plan of Management is a

component of Forest Management System.

(refer to SD13, Section 4)

21 6 th Para

(refer to GD13) and (refer

to GD12)

… by PEFC Uruguay

Associated Assembly …

… based on Montreal

Process …

21 7 th Para

… based on Montreal

(referred to as GD13) and (referred to as GD12)

See comment for Page 11, 2.2

… based on the Montreal Process …

Comments were noted. Report has been

amended accordingly.

Comments were noted. Report has been

amended accordingly.

www.itsglobal.net Page 79

Process …

p.22,

4.1.1., 1

22 4.1.1 General Requirements

1)

(refer to GD 13)

“...relevant to all forests and management systems ...”

(vice versa plantations)?

The FM standard is applicable for forest plantations only!

The consultant should identify the relevant section/chapter

which indicates compliance – this is s general comment for

much of the rest of the assessment ie refer to 1 of GD13

22 2) Clarification

… by different auditors based on the justifications as the

normative requirements.

22 3)

(refer to 1, 4 of GD 13)

(refer to GD 13)

23 7) I cannot confirm the consultant’s conclusion – GD13

provides for the FMP – there is no indication of availability

23 8) Clarification

5 of GD2 applies!

23 10) I cannot confirm the consultant’s conclusion – it isn’t

explicit. There is basically an inference rather than

evidence!

23 11) Comment – ratification implies application through national

legislation

24 13) Query – was it sighted in the Field Visit i.e. confirmed in the

minutes of meetings

24 14)

The signing of this Protocol can’t be verified on

bch.cbd.int/protocol/parties

The Biosafety Protocol The Cartagena Protocol on Biosafety

25 17) Comment – can delete text after SD07 and GD2 as have

already established text in 4.2.1!

Agree for SD07 but it isn’t explicit in GD2 to indicate

conformance

Comments were noted. Text clarifying that

criteria apply to plantations has been added.

Refer to above comment.

Comments are valid. Suggestion to identify

relevant section/chapter has been

implemented.

Comments are valid. Additional text has been

added.

Additional text added.

Comments are valid. Text has been modified

to recognise that while the practice of forest

companies is to make copies of FMP publicly

available, this is not explicitly required by

documentation.

Comments valid. Additional reference added.

Comments noted. Additional reference to

GD02, Section 2 added.

Comments noted.

Confirmed in discussions with members of

STC-SFM. Refer to Annex 1.

Uruguay’s country profile indicates that the

Protocol was signed on 1/2/2001 (cited in the

conformity assessment). Profile accessible at:

http://bch.cbd.int/about/countryprofile.sht

ml?country=uy

Comments valid. Additional reference to

GD02, Section 5.1 added.

www.itsglobal.net Page 80

25 4.2.3 Group Certification This introduction relates in fact to the SFM system which

relates to 5.3 of GD2

25 35)

The criteria and requirements for group certification as set

The criteria and

out in SD07 comply with PEFCC requirements.

requirements for group There is no need to repeat the PEFCC reference!

certification within UFCS

(SD07) comply with PEFCC

requirements detailed in

Annex 3, 4.1b.

26 43) Comment – Under 7, it is explicit for the member but it is

implicit for the Group Administrator!

... forest area under his/her management should be added

by PEFCC

Comments noted. Text amended accordingly.

Comments valid. Text amended accordingly

Comments noted.

p. 27,

4.2.4, 46

The consultants agree with the comment. The

consultants used the exact wording of the

PEFC Council Minimum Requirements

Checklist (GL 2/2010), but would recommend

that PEFCC considers amending the

documentation so that it does not contain

gender specific references.

27 45) The shading is missing for the Conforms Comments valid. Report has been amended

27 48)

… on ad hoc basis … … on an ad hoc basis …

28 49)

… on ad hoc basis … … on an ad hoc basis …

28 4.4 Overall Assessment Comment: I have a real concern on the assessment for 7),

10), 14), 17) and 43) – I would seek further evidence to

justify the current assessment.

5. Assessment of UFCS Forest Management Standards against PEOLG

accordingly.

Comments valid. Report has been amended

accordingly.

Comments valid. Report has been amended

accordingly.

Comments noted. Assessment modified to

recognise non-conformity associated with a

lack of documentation requirements for

making summary of FMP publicly available.

29 5.1 Assessment Framework,

1st Para

UFCS utilizes Norm

(Standard) 1152: 2009 …

The UFCS utilizes Norm (Standard) UNIT 1152: 2009 …

The conformity of the Criteria and Indicators of Standard …

It is the C&I which provide the equivalence with the

Comments were noted. Report has been

amended accordingly.

Text amended.

www.itsglobal.net Page 81

3rd Para

The conformity of the

Standard …

29 5.2 Compatibility of the ME

with PEOLG

… with PEOLG Criteria are

coded as C and associated

relevant indicators coded

as I

29 Table heading - UFCS

p.30, 1.2

c

compliance

PEOLGs!

Comment: There are no requirements per se in UNIT 1152 –

it is comprised of Criteria and Indicators

… with PEOLG Criteria are coded as C eg C 1 and associated

relevant indicators coded as I eg I 6.1.1. – this provides

guidance to a reader.

Query: Are these the consultants words or are they PEFC

Uruguay’s words?

“... expansion of plantations where benefit to general

society’s well being ...”. ENGOs are clearly a part of the

general society! Who decides whether society benefits or

not, and what kind of benefits...? (not very satisfactory!)

29-35 General Comments

I cannot understand how a Criterion or a number of Criteria

can specifically provide conformity with a PEOLG – it must

be the Indicator under the Criterion which provides the

conformance. The PEOLG is at the operational level but the

Criteria in UNIT 1152 are based on the Montreal Process at

the highest level of SFM.

There is a lack of normative language in the Indicators

which is the means to provide assurance of the outcome for

the Criterion. Must is mostly used but it is no substitute for

shall.

I cannot understand how reference to Section 4.1 of UNIT

1152 provides explicit conformance as in many cases, it is

implicit and there is an onus on explicit evidence for

conformity assessment.

PEOLGs 1.2c, 2.2b, 2.2d indicate that there is not the

required evidence but there is a ‘conforms’ assessment!

I cannot agree that a proper evaluation of UNIT 1152

Comments valid. Clarification text has been

added to the document.

Consultant’s comments. Table heading

changed to ‘Evidence’.

In Uruguay plantation projects are required to

be approved by Ministry of Agriculture and

Ministry of Environment.

Ministry of Environment has specific

responsibilities to evaluate benefits to society

for specific plantation projects.

1. Comments noted. To strengthen the

assessment the specific indicators for each

criteria have been added in cases where

indicators were not previously specified.

2. In relation to comment of normative

language in Indicators, it is relevant to

note that each indicator is supported by an

indicator and specific framework of

justification, objective, parameters,

procedures, documents and registers.

3. In relation to interpretation the use of

“must” in Standard has been considered

equivalent to “shall” under PEFC

requirement.

4. Reference to Section 4 of UNIT 1152 has

been labelled as ‘General’ while reference

to criteria and indicators has been labelled

‘Specific’ to strengthen evaluation

www.itsglobal.net Page 82

35 5.7 Overall Assessment, 2 nd

sentence

provides adequate conformity assessment against the

PEOLGs – there is a greater need to indicate specific

Indicators to provide the conformity.

If this is the assessment wouldn’t it be a ‘partial

conformity’?

The policies – are they the Uruguayan Government policies?

If so, it needs to be explicitly stated as it may demonstrate

compliance with legislation.

framework.

Comments noted. Justification text added to

support consultants’ assessment.

6. Assessment of UFCS chain of custody standard against PEFCC requirements

36 6. Assessment of UFCS

Chain of Custody Standard

against PEFCC

Requirements

Comment: I would expect that GD2 and DG08 are also

applicable UFCS documentation – all relevant sources should

be cited.

Comments valid. Additional references added.

8. Assessment of UFCS certification and accreditation arrangements against PEFCC requirements

38 8.1.1 Competence of

Certification Bodies … (refer to Section 5, SD03) …

1)

… (refer to SD03) …

38 4) and 5) Comment: I would adjudge these as Partial Conformity

based on matching the documented evidence against the

39 6)

… (refer to SD03, Section 3)

…

39 7)

… (refer to SD04, Section 4)

…

39 9)

… (refer to SD04, Section 5)

…

… work experience and

requirement.

Incorrect reference

… (refer to SD03, Section 5, b) …

Applicable references

… (refer to SD04, Section 4, 5 & 8) …

Applicable reference

… (refer to SD04, Section 5 & 8) …

… work experience, competence and training.

Comments were noted. Report has been

amended accordingly.

Comments noted. Additional text and

references added to justify consultants

assessment.

Comment noted. Reference amended.

Comments noted. Additional references

added.

Comments noted. Additional references

noted.

www.itsglobal.net Page 83

training.

39 10)

… (refer to SD04) …

Incorrect reference

… (refer to SD03, 5 p) …

39 11) Comment: As the UFCS uses Annex 4, it is not a scheme

specific CoC Standard and the response only needs to

address the FM Standard

8.2 /

p.40

8.2 /

p.40

Question 12:

“…with requirements of ISO

Guide 65 adjusted to the

type, range and volume of

work”

Question 18:

“…make available, at

request, “summaries of the

certification””.

40 12)

… (refer to SD03, Section

5(n)) …

40 15)

… (refer to SD03, Section

5(x)) …

40 18)

… (refer to SD03, Section 9)

…

What in detail is meant with “adjusted to the type, range

and volume of work”? And is this enough for conformity?

Is “at request” enough to satisfy the requirements?

Applicable reference

… (refer to SD03, Section 3 & 5(n)) …

Correct reference: check on 9e!

… (refer to SD03, Section 9(g)) …

41 19) Comment: I would adjudge these as Partial Conformity

based on matching the documented evidence against the

requirement.

Comment noted. Reference amended.

Comment noted. Additional explanatory text

added.

Comment noted. The wording is assessed by

the Consultants as being consistent with

requirement of ISO Guide 65.

Comments noted and text clarified. Response

is assessed by Consultant as satisfying PEFCC’s

requirements.

Comments were noted. Report has been

amended accordingly.

Comments were noted. Report has been

amended accordingly.

Comments were noted. Report has been

amended accordingly.

Comment noted. Clarifying text added to

support assessment.

41 21) Not referenced so lacks consistency – should be SD03, 3a! Comments were noted. Report has been

amended accordingly.

41 23)

… (refer to SD03, Section 3)

…

… (refer to SD03, Section 3(a))

Comments were noted. Report has been

amended accordingly.

42 26) This is a non-conformity as there is no PEFC Notification

document in the SD series. GZD2 doesn’t have ‘notified’ or

‘notification’ in the whole document. Maybe the reference

is SD03, 3e?

Comments were noted. Text clarified to

support conformity assessment.

www.itsglobal.net Page 84

42 27) Impartial and non-discriminatory are not mentioned at all in

the statutes – I would asses this as a non-conformity!

42 8.5 Overall Assessment I do not agree with the consultant’s assessment as it is a

3 rd para

requirement of the PEFC for accredited certification of an

organisation. The certificate must (shall) have the

accreditation symbol, so it not in the UFCS, it is a nonconformity

which requires corrective action by PEFC

Uruguay

Comments valid. Text has been amended

accordingly.

Comments noted. Text and recommendations

have been modified.

Annex 1, 2 and 3

44 Annex 2, 2)

Correct spelling for UNIT – see Page 6 comment

… individually targeted letters …

vi) … individually target

letters …

45 3 rd Para

However none were However, none were received.

received.

45 4)

… Directory …

… Director …!

46 6) iii) The statement needs to end with ‘based on … …’ to indicate

the basis of the procedures.

46 7) iii)

… successfully implement … successfully implement the UFCS.

Scheme.

47-50 PART I

I cannot locate any document labelled Annex 1 in 2.3.

Nos. 1 -19 and 35 – 41 There is no Annex 1 to GD2 which is the implication of the

response to the Process in No. 1 and wherever referenced in

the PEFCC requirements.

It is only by looking through the UFCS documentation that

an Annex 1 can be found!

Also, there seems to be no Annex 3!

The only visible document with an Annex label is Annex 2

which is GD6.

Having the name used as reference and having it visible in

the report need matching if in fact Annexes 1 and 3 are

Comments were noted. Report has been

amended accordingly.

Text changed.

Comments were noted. Report has been

amended accordingly.

Comments noted. Text amended accordingly.

Comments were noted. Report has been

amended accordingly.

Comments noted. Additional text and table

added to clarify the equivalence of

documents cited by PEFC Uruguay as

reference document, and document numbers

used in Consultants’ assessment.

www.itsglobal.net Page 85

Annex 3,

Part I /

48

Question 12:

No, No, VER CON UNIT

contained in 2.3

The answers do not fit to main assessment report.

48 No. 12 Whilst the Consultant has indicated No, the response in the

text at Pg 16 is Conforms which to my understanding is a

Yes!

Annex 3,

Part I /

49

Annex 3,

Part I /

49

Annex 3,

Part II /

52

Question 16, 17:

No answers / “En proceso”

in columns 5, 6

Question 37:

Missing answer in column 5

Questions 1 –18, 46:

Columns 4 and 5 are not

completed

52-53 PART II

Nos. 1 - 34

Answers missing

The answer should be “yes”?

Anwers are missing. If the answers are not necessary this

should be mentioned somewhere.

The whole point of the Checklist is to indicate in a concise

manner the relevant documentation of the scheme which

the consultant has assessed as satisfying the PEFCC

requirement (or in the case of partial or non-conformity,

indicating that assessment). All the blank sections need to

be completed as the main document is also light on specific

references to documents especially to the relevant sections

of the documents.

57 No. 46 Surely GD2, 5.1 is the specific reference even noting the

PEFCC comment.

59 PART III

There are more than one Criterion for the Montreal Process

No. 3

Criteria!

59-60 PART III

No. 4 – 48

This is definitely not good enough fore an evaluation – see

my comment above for pages 52-53.

The FM standard is the essence of any forest certification

scheme and it must be well articulated in the checklist to

As noted in the report, boxes shaded in red

are answers provided by PEFC Uruguay. The

Consultant’s assessment is located in the final

column. The Consultants’ assessment

corresponds to discussion found in the body of

the report.

The appeal mechanisms for handling

complaints against STC-SFM are specified by

UNIT. Text has been revised to provide

further explanation.

PEFC Uruguay did not file answers for these

questions

Comments were noted. Report has been

amended accordingly.

PEFC Uruguay did not provide answers to

these questions in their application for

endorsement

As noted above, PEFC Uruguay did not provide

responses to these questions. Consequently

the column is blank.

Comment valid. PEFC Uruguay did not

document specific references.

Comment valid. Report has been amended

accordingly.

Comments noted. Consultants’ conformity

assessment has been added.

www.itsglobal.net Page 86

Annex 3,

Part III /

62

Column 4 is not completed

indicate compliance or equivalence.

As I have raised substantial queries in the body of the

report, it must be completed in unison with consideration of

the body of the report.

Answers are missing. If the answers are not necessary this

should be mentioned somewhere.

62-64 PART VI The consultant hasn’t read the heading for this part – it is

ONLY applicable to a scheme specific CoC standard. This is

not the case for the UFCS as it uses PEFC’s Annex 4. The

correct response would be Not applicable!

As noted above, PEFC Uruguay did not provide

responses to these questions.

Comments noted. Report has been amended

accordingly.

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