Skeena Sawmills Ltd SFI Surveillance Audit

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1 Skeena Sawmills Ltd SFI Surveillance Audit From August an audit team from KPMG Performance Registrar Inc. (KPMG PRI) carried out an SFI surveillance audit of Skeena Sawmills Ltd. woodlands operations and fibre procurement activities against the requirements of the Sustainable Forestry Initiative (SFI) forest management and fibre sourcing standards. To provide for a more efficient audit, a PEFC Chain of Custody surveillance audit was conducted at the same time. This Certification Summary Report provides an overview of the process and KPMG s findings. Description of Skeena Sawmills Ltd. Woodlands Operations Skeena Sawmills Ltd. woodlands operations are located in the vicinity of Terrace, BC and encompass a total area of 560,923 hectares. Skeena Sawmills has three licenses on crown land (FL A16885, FL A16882, TFL 41) and a total AAC (allowable annual cut) of 316,596 m3/year. The 2018 audit found that the Company s forest harvesting conforms to the AAC applicable to these operations. The woodlands operations that are included within the scope of the Company s SFI certification are covered by government-approved harvest plans that address both timber and non-timber values. These are developed to be consistent with their Forest Stewardship Plan for operations administered by Skeena Sawmills Ltd. in the Kalum and Nass Timber Supply Areas located within the Coast Mountains Resource District. The areas covered by Skeena Sawmills Ltd. SFI certification fall within the following WWF ecoregions: (11) Northern Pacific Coastal Forests, (12) Northern Transitional Alpine Forests, and (14) Pacific Coastal Mountains Icefields and Tundra. The forests managed by Skeena Sawmills s are predominantly coniferous with the main commercial tree species being Western hemlock, Amabilis fir, Western redcedar, Sitka spruce, and Yellow-cedar. The forest management approach employed by the the company is based on even-aged management, ground-based harvesting systems, clearcut harvesting with the retention of reserves of standing trees either within or adjacent to harvest areas and replanting of harvest areas within a few years with a mix of ecologically suited tree species. Description of Skeena Sawmill s Manufacturing Facilities and Fibre Sourcing Program The company operates its sawmill in the community of Terrace, BC and sources fibre from the Coast Mountain Resource District. Most of the logs for the mills are sourced from the company s two Forest licenses and one Tree farm License with a small amount being purchased from privately held land. The Company participates in the Western Canada SFI Implementation Committee (WCSIC) Purchase Wood Monitoring Program by completing risk assessments for all wood purchases and purchase wood inspections as necessary. The results are then collated by WCSIC (of which the Company is a member) in order to identify trends in performance and opportunities for improvement. #0746 Audit Scope The audit was conducted against the requirements of the edition of the SFI forest management and fibre sourcing standards, and incorporated an assessment against the SFI program objectives shown in Tables 1 & 2 in the report. The scope of the 2018 SFI surveillance audit of forestry and logging (including planning, roads, harvesting, and silviculture) on Skeena Sawmills Ltd. s forest licenses and fibre sourcing for the company s sawmill located in Terrace, BC.

2 Findings: Skeena Sawmills Ltd SFI Surveillance Audit The Audit Audit Team The audit was conducted by Branden Beatty, R.P.Bio, EP(EMSLA) Lead Auditor, and Bodo von Schilling RPF, EP(EMSLA) as team member. Branden is an employee of KPMG PRI, and has conducted numerous forest management audits under a variety of standards including SFI, ISO 14001, CSA Z809 and FSC. Bodo is an independent consultant with experience in conducting forest against the ISO and SFI standards SFI Surveillance Audit The audit involved an on-site assessment of all elements of the SFI program, and included visits to several field sites (6 roads, 5 harvesting, 1 silviculture sites, and 2 wood procurement sites) to evaluate conformance with the requirements of the current SFI forest management and fibre sourcing standards. The 2018 Skeena Sawmills audit took a total of 5 auditor days to complete, 4 days of which were spent on-site at the operations included in the audit sample. The balance of audit time was spent preparing the audit plan, completing an off-site review of selected company documents and records and completing various audit checklists and preparing the main and public summary audit reports. Skeena Sawmills Ltd. SFI Program Representative Rony Mazumder served as Skeena Sawmills Ltd s SFI program representatives during the audit. Use of Substitute Indicators The audit involved an assessment of conformance against the applicable objectives, performance measures and indicators included in the version of the SFI forest management and fiber sourcing standards. None of the indicators included in the SFI standards were modified or substituted for the purpose of this audit. Audit Objectives The objectives of the audit were to evaluate the sustainable forest management system at Skeena Sawmills Ltd. to: Determine its conformance with the requirements of the SFI forest management and fibre sourcing standards; Evaluate the ability of the system to ensure that Skeena Sawmills Ltd. woodlands operations meet applicable regulatory requirements; Evaluate the effectiveness of the system in ensuring that Skeena Sawmills Ltd. meets its specified SFM objectives, and; Where applicable, identify opportunities for improvement. Skeen Sawmills Ltd. SFI Surveillance Audit Findings Open non-conformities from previous audits New major nonconformities New minor nonconformities New opportunities for improvement Types of audit findings Major non-conformities: Are pervasive or critical to the achievement of the SFM Objectives. Minor non-conformities: Are isolated incidents that are noncritical to the achievement of SFM Objectives. All non-conformities require the development of a corrective action plan within 30 days of the audit. Corrective action plans to address major nonconformities must be fully implemented by the operation within 3 months or certification cannot be achieved / maintained. Corrective action plans to address minor non-conformities must be fully implemented within 12 months Opportunities for Improvement: Are not non-conformities but are comments on specific areas of the SFM System where improvements can be made.

3 Findings: Skeena Sawmills Ltd SFI Surveillance Audit Evidence of Conformity with the SFI Forest Management and Fibre Sourcing Standards Primary sources of evidence assessed to determine conformity with the SFI forest management and fibre sourcing standards are presented in the following tables. SFI Forest Management Objective Key Evidence of Conformity 1. Forest Management Planning 2. Forest Health and Productivity 3. Protection and Maintenance of Water Resources 4. Conservation of Biological Diversity 5. Management of Visual Quality and Recreational Benefits 6. Protection of Special Sites Field inspections of riparian areas, review of site plans & harvest plans, implementation of EMS in relation to water protection. Forest management plan, FSP, harvest plans, field inspections. 7. Efficient Use of Fibre Resources Forest management plan, waste reports, field inspections. 8. Recognize and Respect Indigenous Peoples Rights 9. Legal and Regulatory Compliance 10. Forestry Research, Science and Technology Forest management plan, environmental management plan (EMP), health & safety policy, field inspections. 11. Training and Education 12. Community Involvement and Landowner Outreach 13. Public Land Management Responsibilities 14. Communications and Public Reporting 15. Management Review and Continual Improvement Forest management plan, EMP, SIC minutes & resources, community and landowner outreach records, staff interviews. Forest management plan, management review records, internal audit and related action plans. Effectiveness of SOP coverage of SFI objectives. Example of visual quality objective achievement on a cut block with view points along a highway.

4 Findings: Skeena Sawmills Ltd SFI Surveillance Audit Page 4 Evidence of Conformity with the SFI Fibre Sourcing Standard SFI Fibre Sourcing Objective # Key Evidence of Conformity 1. Biodiversity in Fibre Sourcing Program to promote biodiversity in fibre sourcing, records of involvement in local or regional conservation efforts, interviews with procurement staff. 2. Adherence to Best Management Practices Fibre sourcing policy and records of its distribution to wood producers, written fibre sourcing agreements, records of implementation of the BMP monitoring system, inspection of a sample of procurement sites. 3. Use of Qualified Resource and Qualified Logging Professionals 4. Legal and Regulatory Compliance Company policies regarding regulatory compliance, procedures to ensure compliance with applicable regulatory requirements, inspection of a sample of procurement sites, interviews with regulatory agency personnel. 5. Forestry Research, Science and Technology 6. Training and Education 7. Community Involvement and Landowner Outreach 8. Public Land Management Responsibilities 9. Communications and Public Reporting 10. Management Review and Continual Improvement SIC minutes & resources, community and landowner outreach records, staff interviews. Management review records, internal audit and related action plans. Example of a recent bridge reinstallation to replace aging infrastructure. 11. Promote Conservation of Biological Diversity, Biodiversity Hotspots and High-Biodiversity Wilderness Areas 12. Avoidance of Controversial Sources Including Illegal Logging 13. Avoidance of Controversial Sources Including Fibre Sourced from Areas without Effective Social Laws This objective only applies outside Canada and the US. This objective only applies outside Canada and the US. This objective only applies outside Canada and the US.

5 Findings: Skeena Sawmills Ltd SFI Surveillance Audit Page 5 Follow-up on Findings from Previous Audits At the time of this assessment there were a total of 3 open non-conformities from previous Skeena Sawmills Ltd. external SFI audits. The audit team reviewed the status of the action plans that were developed by the Company to address these previous audit findings and concluded that: (1) Action plans had been implemented as required for two of the non-conformities, and (2) those action plans were effective in addressing the root causes of the non-conformities. For the remaining nonconformity, the action plans were implemented but there remains a need for additional training. As a result, one non-conformity remains open and will be reassessed in Areas of Nonconformance A total of 3 minor non-conformities were identified during the SFI certification audit of Skeena Sawmills Ltd. woodlands and fibre sourcing operations. These were: SFI Forest Management Objective 15 (Management Review) requires program participants to have a system for collecting, reviewing, and reporting information to management regarding progress in achieving SFI Forest Management Standard objectives and performance measures. Skeena Sawmill s FSP provides, for each resource value that has an assigned objective, a stand-alone set of results and strategies for Skeena s primary forest activities that will be undertaken within the Kalum TSA, TFL 41, and the Nass TSA. The audit found that the management review did not provide enough detail in order to determine whether Skeena Sawmills is evaluating performance pertaining to the various commitments under the FSP. SFI Forest management Objective 15 and SFI Fibre Sourcing Objective 10 (Incident Tracking) require the organization to have system for collecting, reviewing, and reporting information to management regarding progress in achieving SFI Standard objectives and performance measures. The audit noted that Skeena Sawmills had failed to document evidence of nonconformity closure from the 2017 external audit. SFI Fibre Sourcing Objective 2 (Water Quality BMPs) requires the organization to have a program to require that harvests of purchased stumpage comply with best management practices. The audit field sample included two blocks, both of which had over 1000 m3 of logs sourced from, and therefore would require a follow up inspection. The audit noted no inspections were on file for the blocks visited, and both blocks had the following deficiencies noted during the audit site visit. -Block TM K1X011 (terrace community forests CP 11), the audit noted a tidy tank of one of the operators was not strapped down to the frame of the truck. -Block Kitsilas CP 105 TM FL3105, the audit noted the banks on either side of a removed bridge on an S4 crossing at the entrance to block had not been effectively stabilized upon removal. Opportunities for Improvement One opportunity for improvement was also identified during the audit: SFI Forest Management Objective 11 (Training) requires the organization to require appropriate training of contractors so that they are competent to fulfill their responsibilities. The audit noted that while drills were being completed Commercial thinning on a cut block where fibre was procured

6 Findings: Skeena Sawmills Ltd SFI Surveillance Audit Page 6 with an emphasis on fire drills for numerous contractors, one road construction contractor had not undergone any drills for some time. Audit Conclusions The audit found that the Skeena Sawmill s sustainable forest management system and fibre sourcing program: Were in full conformance with the requirements of the SFI forest management and fibre sourcing standards included within the scope of the audit, except where noted otherwise in this report; Have been effectively implemented, and; Are sufficient to systematically meet the commitments included within the organization s environmental and SFM policies, provided that the systems continues to be implemented and maintained as required. As a result, a decision has been reached by the lead auditor to recommend that Skeena Sawmill s continue to be certified to the SFI forest management and fibre sourcing standards. Corrective Action Plans Corrective action plans designed to address the root causes of the non-conformities identified during the audit have been developed by Skeena Sawmills Ltd. and reviewed and approved by KPMG PRI. The next surveillance audit will include a follow-up assessment of these issues to confirm that the corrective action plans developed to address them have been implemented as required. Focus Areas for the Next Audit Visit The following issues/potential concerns have been identified as focus areas for the next audit visit: Roles and responsibilities, and associated competencies, related to the EMS and fibre sourcing program. Contacts: Chris Ridley-Thomas, RPBio, EP(EMSLA) (604) David Bebb, RPF, EP(EMSLA) (604) This report may only be reproduced by the intended client, Skeena Sawmills Ltd., with the express consent of KPMG. Information in this issue is of a general nature with respect to audit findings and is not intended to be acted upon without appropriate professional advice KPMG. All rights reserved. Through KPMG PRI, KPMG s Vancouver based forestry group is accredited to register forest companies to ISO 14001, CSA-SFM, SFI and PEFC certification standards.