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

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