Michael E. Conroy
FSC individual member,
Social Chamber North
“Accreditation” of the FSC forest certification system is, in the language of lay-people like me, the process by which certification bodies (or CBs) are found to be impartial, technically competent, and, in practice, appropriately applying the FSC’s principles, criteria, and indicators in certifying forest product companies. More simply, accreditation is the answer to the questions: Who audits the auditors? Or who certifies the certifiers?
In this brief note I want to share some of the history of accreditation within FSC, some of the associated challenges, and how ASI has evolved as FSC’s sole accreditation provider. I cover five important themes:
- A brief discussion of the importance of independence and impartiality in contemporary accreditation systems.
- A brief history of the evolution of accreditation within the early years of FSC.
- A summary of the steps that FSC has taken to improve the real and perceived independence and impartiality of ASI accreditation.
- Current dimensions of innovation by ASI, especially in its work for FSC.
- And what does ASI mean to FSC?
ORIGINS AND ISSUES
According to the current definitions of the International Standards Organization (ISO), accreditation is “the formal recognition by an independent body, generally known as an accreditation body, that a certification body operates according to international standards.” The two most important concepts embodied in contemporary accreditation are “independence” and “impartiality.” Independence, in this context, means that the evaluation of certification bodies (CBs) is undertaken by specialists who are not part of the certification scheme itself. Impartiality means that CBs are evaluated without bias with respect to the outcomes of their assessments. FSC has struggled with those concepts since the very beginning.
The concept of accreditation has been a part of the FSC system from the start. The first mention of accreditation came in the minutes of Board Meeting 4 (BM4), held in Indonesia in September 1994. The minutes of that meeting note that “Tim [Synnott] is currently preparing evaluation and accreditation protocols along IFOAM/ISO guidelines.” Accreditation issues came up at virtually every Board meeting over the next five or six years. And, realistically, the nature of accreditation has evolved almost as much as FSC itself.
By BM5 (Oaxaca, December 1994) it was clear that FSC staff would undertake the accreditation process. The board also decided that FSC accreditation visits to certified forests would depend upon the “type, diversity, fragility, number and size of the forests being certified, as well as the certifier’s reputation and the size of their portfolio.” This was a major step forward in the certification world at that time, essentially making FSC inspections somewhat “risk-based.” But was FSC accreditation of its own CBs “independent”? And could that accreditation by FSC staff be fully “impartial”? Those issues, while overlooked at that time, have become very important in recent years.
At BM7 (London, August 1995), according to participants in that meeting, a great deal of time was spent by the Board itself reviewing staff evaluations of each candidate CB and debating and drafting extensive preconditions that each had to meet. In that same 1995 meeting, the Board defined a very active role for itself in vetting and accrediting all CBs. The Board asked to receive monthly reports on each CB, and any non-conformance and CB corrective action request (CAR) would automatically become an agenda item for the next Board meeting.
This Board’s role in accreditation and monitoring of the CBs was controversial from the beginning. The minutes note that one early FSC member, Bernd Neugebaur, urged in writing that the Board NOT be involved in accreditation decisions; but the Board chose to ignore that plea.
The “radical” notion of charging CBs for FSC’s costs of accreditation didn’t come up until BM8 and was debated further in BM9 (Oaxaca, June 1996) when it was decided that fees would be introduced as of January 1997. It was hoped that fees charged for accreditation might generate significant surplus revenues for FSC operations not related to accreditation. But by BM11 (Port Moresby, PNG, September 1997) charging fees for the full direct and indirect costs of accreditation was approved. However, it became clear that accreditation fees were not going to generate much revenue over and above the costs incurred.
Eventually, an Accreditation Committee comprised of three Board members and two outside specialists was formed to lead this work in 2001. And FSC developed an in-house program, called the Accreditation Business Unit (ABU), to support the accreditation process. The ABU was given the task of assessing candidate CBs and reporting to this committee. That role, and the resulting accreditation protocol, earned the respect of other social and environmental certification systems to the extent that the ABU began providing accreditation for the CBs of the Marine Stewardship Council. This extension of the work helped to distribute the overhead costs of the ABU. But it also gave rise to new concerns about “impartiality.” That is, could FSC’s ABU provide impartial evaluation of a CB for the MSC if it were not happy with the FSC-related behavior of that CB?
EVOLUTION TOWARD GREATER INDEPENDENCE AND IMPARTIALITY
Over the last 10 years, a number of steps have been taken to give FSC’s accreditation system greater independence and impartiality as it spread its wings to encompass most of the major global voluntary certification systems focused on social and environmental practices. The ABU became Accreditation Services International (ASI) in 2006 and moved into separate offices in Bonn in 2011. Although physically separate from FSC, it remained tightly integrated with FSC operations and enjoyed, until 2012, a significant FSC subsidy built into its otherwise rather rickety finances.
In addition to MSC, the present-day ASI also provides accreditation to the Roundtable on Sustainable Palm Oil (RSPO), the Aquaculture Stewardship Council (ASC), the Roundtable on Sustainable Biomaterials (RSB – formerly Roundtable on Sustainable Biofuels), and, on a pilot basis, for the Global Sustainable Tourism Council (GSTC) and the Sustainable Biomass Partnership (SBP). It also provides development services to the IUCN on certifying protected areas, and services to a variety of new certification schemes seeking appropriate assurance structures.
Facing growing criticism about its independence, the FSC Board reviewed and approved terms of reference for a separate Board of Directors for ASI at BM59 (San Lorenzo and Santiago, Chile, February 2012). But the approval included strong dimensions of continued FSC control, such as a guaranteed permanent presence for an FSC representative on the ASI Board and a positive veto by FSC over major changes at ASI, such as extension of ASI services to other certification schemes. And the members of ASI’s Board had to be approved by the FSC Board of Directors. Given continued financial challenges faced by ASI, questions were raised at that Board meeting about “selling shares” in ASI to other schemes or even to outside investors. But it was quickly seen that ASI’s finances at that time would not make it very attractive to other potential investors.
The new ASI Board, working closely with Managing Director Guntars Lagūns, has gradually made ASI a stand-alone organization with small positive profitability in each of the four years from 2013 to 2016. Yet criticisms of continued FSC control, undercutting independence and impartiality, have been raised repeatedly, both in external reviews by the ISEAL Alliance (of which FSC is a founding member) and by the official government procurement agencies of the UK and the Netherlands. This creates for FSC a risk that the procurement agencies will not endorse FSC-certified products for sustainability purchases by those governments. It has also led to public charges by the competitors of FSC (and competitors of the other certification systems supported by ASI) that they are not fully accredited by an independent and impartial accreditation body.
In May of this year, at BM75 (Sao Paulo), the FSC Board took further steps to counter these external concerns. The ASI Board will now become a fully-empowered, self-replicating Supervisory Board by the beginning of 2018. FSC will no longer maintain a guaranteed position on the ASI Board, and FSC will no longer have an effective veto over most ASI decisions, though it remains the sole shareholder of ASI.
ASI ACCREDITATION FOR FSC TODAY
ASI is now stronger and more capable than ever to support the credibility of FSC certification. Here are a few highlights of recent advances and innovations at ASI, focused primarily on its work for FSC:
- Carrying out two “Certification Integrity Projects,” along with FSC’s Quality Assurance Unit and FSC National Offices, to review how the FSC auditing processes can be strengthened in Russia and China. These projects led to new approaches, such as “calibration workshops” where all CBs working in those regions were trained to employ similar interpretations of critical issues.
- Introduction of a much higher number of “Compliance Assessments” where, rather than simply “witnessing” a CB team at work, ASI personnel do a targeted audit of their own to assess the accuracy of CB audits, for example, in the case of complaints.
- Creation and implementation of an “Incident Register” in which interested parties can report any issues related to FSC accreditation or certification linked to certificate holders, CBs, or to ASI. This includes non-formal complaints, media mentions, and information from ASI assessors or whistle-blowers. All such incidents are registered and investigated to determine whether there should be further ASI engagement around the problems noted.
- Development of an “ASI Risk Score” and an annual “ASI CB Performance Review” for every CB accredited to FSC in order to evaluate and determine the quality of CB internal organization and CB performance in the field beyond mere standard conformance.
- Introduction of more comprehensive risk-based audit planning under which CBs with more NCs (non-conformities), more complaints, and weaker internal structures are subjected to more frequent surveillance by ASI, while those CBs that have fewer NCs and better overall ratings are audited less frequently, giving the CBs new financial incentives to perform better. In 2017, one third of the CBs accredited for FSC have had their ASI assessment sampling rates modified by this risk-based system, half of them with increased surveillance, about half with less.
- Development of a comprehensive standard online-reporting platform for FSC FM certification, together with FSC International, so that all CBs can begin to use a common reporting format, as demanded in the 2014 General Assembly, facilitating improved analyses of certification issues as well as the performance of the CBs themselves; now being pilot tested.
- Management of the FSC Auditor and Training Registry, monitoring qualifications of all FSC auditors and CB training processes to ensure quality performance.
- Covered all of its costs for the last four years without FSC subsidies, generating small profits after taxes.
- Conducted a full business evaluation through an independent external auditing firm which produced an estimate of the value of ASI as a company, wholly owned by FSC, of more than €2,000,000. (That is the present value of ASI’s accumulated technology, personnel, flows of revenue, etc., but not an indication of liquidity or profits.)
WHAT DOES ASI MEAN TO FSC?
- ASI is an organization that has grown through FSC investments over 20-plus years and is now worth more than €2,000,000.
- ASI is an important technical asset that belongs fully to FSC and that is innovative and responsive to FSC’s needs.
- ASI, as FSC’s sole and distinctive accreditation body, has shown that it is capable of providing increasingly independent and impartial assessment of the performance of all 39 CBs presently accredited for FSC.
- ASI is the global leader on accreditation for voluntary sustainability certification systems focused on social and environmental standards.
- ASI is seen within the ISEAL Alliance community as a leader in innovative solutions to improve CB assessment and performance.
- ASI operates with transparency towards all stakeholders, CBs, and FSC, by publishing reports, announcing assessments, and reporting regularly to FSC about nonconformity trends and assessment data.
- ASI adds value to the system by requiring CBs to conduct “Root Cause Analysis” for every non-conformity in order to understand and eliminate the cause of a problem.
- ASI offers worldwide oversight to FSC, with the advantage of overseeing the full supply chain and all certificate holders, allowing enhanced supply chain integrity and comprehensive understanding of the global implementation of the standards.
- ASI is a critical element in FSC credibility worldwide.
 In full transparency, I have been a member of the board of directors of ASI for most of the past five years, since the creation of an ASI Board of Directors. I am also writing an analytical history of FSC that includes a chapter on certification and accreditation. I served on the FSC International Board as a technical advisor from 2003 to 2008 and as an elected representative of the Social Chamber North from 2011 to 2016, including 3 years as Board Chair (2012 to 2015).
 Technically, they’re “conformity assessment bodies” (CABs), but within FSC we’ve always called them certification bodies, or “CBs.”
 Emphasis added.
 Research for the book has included review of the minutes of every FSC International Board of Directors meeting since the very first.
 Three of the board members at that meeting are among the 97 persons I have interviewed, so far, for the history of FSC that I am writing.
 ASI’s Annual Report for 2016 is available at: http://www.accreditation-services.com/archives/asi-annual-report-2016.
The views expressed in the opinion pieces released both prior to and at the FSC General Assembly are the personal opinion of the author, and do not represent the views of FSC. Different members were approached to provide two sides of each argument, but some members exercised their right to decline.