Program QWEB PTPB-V3
December 2009
CHAIN-OF-CUSTODY CERTIFICATION PROGRAM FOR WOOD PRODUCTS
1.0 GENERAL DESCRIPTION OF PROGRAM (1)
This program is designed to encourage the wood products industry to not only establish and maintain a tracking system for their wood, but also to increase the use of certified wood. The program aims to provide support to wood product companies in the following cases:
- A company would like to undertake the process to establish a chain of custody for its products, which meets the requirements of one or several forest certifications, and wants to prepare for one or more certification audits.
- A company already has a chain of custody for its products, under a forest certification, but wants this chain to meet the requirements of one or more other certifications and would like to prepare to pass a certification audit for these certifications.
- A company already has a chain of custody that meets the requirements of one or more forest certifications and would like to receive financial assistance to conduct its next annual external audit(s).
- A company is already registered with the Canadian Food Inspection Agency (CFIA) and would like to receive financial assistance to conduct an additional audit, including a complete update of the procedures manual for meeting the phytosanitary standards of the Canadian Heat Treatment Wood Products Certification Program (CHTWPCP) or the Canadian Wood Packaging Certification Program (CWPCP).(2)
- A company wishes to have a chain of custody that allows it to confirm the legal source of the wood used for its products, so it respects current and future market requirements (e.g. the Lacey Act).
For chains of custody being established, companies participating in the program shall agree to have their chain of custody certified and pay all costs associated with the registration with a registrar and those for the certification audit. In the case of the phytosanitary program, companies must also pay the costs associated with registering in this program.
It is also important to point out that a company that wants to have a chain of custody, for any one of the forest certifications identified, shall have to demonstrate that it has access, or has taken adequate measures to attempt to have access, to a volume of certified wood that is sufficient to enable this chain to work properly.
For a chain of custody for products having to meet conditions governing the export of wood products, under the CHTWPCP or CWPCP, the time anticipated for providing implementation support and monitoring the chain during the first year was established at four days.
The amount of work required to support the implementation of other types of chains of custody will be evaluated with a diagnosis (variance analysis) of the company, conducted beforehand by QWEB. This step will help determine the maximum financial assistance granted for implementation purposes, considering the program’s financial parameters.
Towards the end of the implementation phase, QWEB will conduct a pre-audit. This audit aims to verify if the management system is certifiable (auditable) and will be based on material and documentary evidence that can demonstrate compliance.
It will also serve to verify if the company has clearly understood the requirements of the certification standard and has done due diligence to ensure it meets the requirement whereby it must have access to a volume of certified wood.
For the support to implement their chain, companies must choose a consultant from the list of consultants accredited by QWEB for its Chain-of-Custody Certification Program for Wood Products. The list of accredited consultants is available on QWEB’s website.
Whatever the mechanisms used by QWEB and the resources called upon to conduct diagnoses and pre-audits, these two activities cannot be, under any circumstances, performed by the accredited consultants providing the implementation support.
2.0 ORGANIZATIONAL STRUCTURE
This program, which benefits from financial assistance from the Canadian and Quebec governments, is administered as an ad hoc project by QWEB, for a specific period of time that ends in March 2012.
A Management Committee, made up of industry, government and NGO representatives, has the mandate to see if objectives are met and to monitor the budget.
The following government departments, groups and organizations are represented on the Management
Committee:
- Canada Economic Development (CED)
- Ministère des Ressources naturelles et de la Faune du Québec (MRNF)
- Ministère du Développement économique, de l’Innovation et de l’Exportation (MDEIE)
- Quebec Wood Export Bureau (QWEB)
- Hardwood lumber industry Softwood lumber industry
- Secondary wood products processing industry
- Prefabricated housing industry
- The environmental community (ENGO)
Furthermore, a Technical Committee will ensure that the terms and conditions established for the Chain-of-Custody Certification Program for Wood Products are effective and relevant, without however having a say in the use of program funds.
3.0 ELIGIBLE COMPANIES
Eligible companies are those whose business is related to the forest industry. More specifically, they are companies from the wood products manufacturing sector (3), including 1st, 2nd and 3rd processing companies, along with those that market wood products.
The Chain-of-Custody Certification Program for Wood Products aims to serve the broadest possible range of companies. However, it should be pointed out that, for practical reasons, and to ensure support primarily to companies the most likely to benefit from this program, QWEB reserves the right to refuse a company or put it on hold, based on the following criteria: size of company, nature of business activities, volume of product(s) involved, main markets for these products and the company’s operational period during the year.
4.0 REGISTRATION
Companies can apply to participate in the program by completing the registration form for this purpose (4) (Appendix 1) and sending it to the following e-mail address: jgauvin@quebecwoodexport.com.
The first registration period ended on November 18, 2009. A second registration period will start on Monday, January 11, 2010. Other registration periods may be subsequently added, depending on demand.
5.0 REQUIREMENTS
Once a company has been accepted in the program, it must sign a contractual agreement with QWEB. For chains of custody related to forest certifications and the verification of the wood’s legal origin, the agreement (Appendix 2) will specify, among other things, the product(s) included in the chain of custody.
As for the financial aspect, the agreement shall confirm that the costs associated with the diagnosis, implementation support and pre-audit, are assumed by the program, according to the program’s terms and conditions. In return, the company shall agree to have its chain of custody certified and pay all costs associated with its registration with a registrar and associated with the certification audit. Lastly, the agreement also states that, unless exceptional circumstances arise, this audit must be conducted within three months after the implementation support activities, led by the accredited consultant, have ended.
When it comes to phytosanitary standards, the agreement (Appendix 3) states that the company shall assume the cost of registering in the CFIA’s phytosanitary program.
An agreement will also need to be signed in the case where financial assistance is requested for an annual external audit of a chain of custody or for an audit for the updating of the procedures manual for phytosanitary standards (Appendix 4).
These agreements all contain a confidentiality clause for QWEB, with regard to all company information and data it may have obtained, directly or indirectly, during the work carried out under the program.
Such a confidentiality requirement is also included in a document called: Declaration regarding ethics, confidentiality and the absence of conflicts of interest (Appendix 5), which will be an integral part of the agreement that QWEB will sign with the accredited consultants (Appendix 6).
The requirement regarding certified wood does not apply to companies seeking to implement a chain of custody for meeting CFIA phytosanitary standards, under the CHTWPCP or CWPCP or, also, when it is solely question of verifying the legal origin of the wood.
The senior manager of the company, or this person’s representative, shall identify a person who will be responsible for answering on behalf of the company to QWEB any questions regarding the company’s participation in the program.
The company shall also provide all information and documents, allowing QWEB to make a diagnosis, and allowing the accredited consultant, or organization recognized by the CFIA, to provide the appropriate implementation support.
The company shall agree to provide certain information regarding its business activities, for the sole purpose of evaluating the benefits of the program, and also to provide QWEB with the audit report received from the registrar.
Lastly, the agreement shall set out in which circumstances any amendment, cancellation or suspension of agreement may occur.
6.0 ACCREDITATION OF CONSULTANTS
For the implementation of a chain of custody aimed specifically at meeting the phytosanitary requirements of CFIA programs, QWEB has engaged the services of the Quebec Forest Industry Council (QFIC), an organization recognized by the CFIA.
For the implementation of chains of custody for other purposes, QWEB shall accredit consultants interested in providing this service. To qualify, these consultants must meet the requirements established by QWEB (Appendix 7). These requirements will ensure that persons who provide support to companies have the necessary expertise and experience to do so.
The list of accredited consultants is available on QWEB’s website. Each of the consultants has been assigned a specific accreditation number by QWEB, which they will keep for as long as they remain certified.
In addition, QWEB will keep a register of activities carried out as part of the program. It will contain the name of companies having used the program and that of the consultant or organization having assisted them. This register is available for consultation on QWEB’s website.
1. The program is effective on June 22, 2009, with the necessary adjustments, for activities already undertaken between this date and the date the program is launched.
2. It should be noted that a company may request a reimbursement for both the costs of the audit associated with the phytosanitary program and those for an annual audit for another chain of custody.
3. Establishments primarily engaged in manufacturing products from wood, i.e. those engaged in sawing logs into lumber and similar products, or preserving these products; making products that improve the natural characteristics of wood, by making veneers, plywood, reconstituted wood panel products or engineered wood assemblies; and making a diverse range of wood products, such as millwork (Subsector 321 of the North American Industry Classification System (NAICS)). Establishments that manufacture pulp, paper or paperboard, either alone or in combination with paper converting, are included (Group 3221 of subsector 322, Paper Manufacturing, NAICS).
4. This document is available on QWEB’s website and companies can register online.
Link to company registration form (Appendix 1)
Implementation of phytosanitary standards - company ( Appendix 3)
Requirements for the accreditation of consultants (Appendix 7)