by Tammy Coe, Quality Assurance Manager, Rainforest Alliance
Monday morning’s spirited discussion on Motion 61, whether certification bodies can deliver independent audits, brought many important points to the surface. As a certification body, the Rainforest Alliance stands by the perspective that certification bodies can operate independently. The current checks and balances within the FSC system go a long way towards ensuring this independence. The rule to rotate auditors reduces risk of what one panelist termed “unconscious focus,” and the use of staff and independent contract auditors keeps the mix diverse. And careful monitoring of staff goals ensures that quality are the important metrics, rather than client retention.
Additionally, the generalization that certification bodies compete mostly on price, resulting in a race to the bottom, simplifies a company’s decision-making process. As one certificate holder from Europe pointed out, FSC is very often a value-add choice, and the quality of an audit is more important than the price tag of the service. Our twenty-five years of experience as a certification body corroborates this statement: we have seen that competition based on quality is absolutely possible.
One member’s point that long-standing business relationships between certificate holders and certification bodies can in fact lead to a more effective audit experience for the company is a good one. When auditors are familiar with a certificate holder’s structure and processes, the audit can proceed in a more efficient manner. Removing a certificate holder’s choice in certification bodies is contrary to the spirit of a voluntary system. If we move to a model where an external body matches the CB to the client, this could negatively impact smaller CBs that require predictable business. Smaller certification bodies will not thrive in an environment where they cannot compete against larger CBs that are better positioned to deal with that level of uncertainty.
But there is certainly value in exploring the extent of the issue and potential solutions, and the Rainforest Alliance agrees that an evaluation of the current model could lead to benefits for all parties. Through an open stakeholder process, we may determine a different approach. For example, a policy-level change could achieve the desired effect of increased independence without such a dramatic alteration of the current FSC system. Setting guidelines for level of effort (i.e., auditor days) on an audit could be one such policy change. Standardizing report templates from which ASI could collect data and then spot larger trends could also be a move towards ensuring transparency.
The perceived conflict of interest between certification bodies and clients is not only an FSC challenge. Therefore, we suggest engaging ISEAL, who could ensure the perspective of other certification schemes be brought into consideration; identify a solution that might already exist; or could be extended to these other schemes.
A detailed evaluation of the problem suggested by Motion 61 would need to include all stakeholder groups, and take into account potentially unintended consequences, such as the viability of smaller CBs that we mentioned above.
In its current state, the Rainforest Alliance cannot support Motion 61 due its prescriptive phrasing. However, we agree that an exploration of the idea behind Motion 61 could be valuable—that is, let us continue the constructive discussions to explore the extent of conflict of interest within the current CB model. With modification, this motion has potential to make the FSC system stronger.