BC Timber Sales 2016/17 SFI Re-certification Audit

Transcription

1 BC Timber Sales 2016/17 SFI Re-certification Audit Between May 2016 and April 2017 an audit team from KPMG Performance Registrar Inc. (KPMG PRI) carried out a multi-site re-certification audit of BC Timber Sales operations within selected Business Areas against the requirements of the Sustainable Forestry Initiative (SFI) Forest Management Standard. To provide for a more efficient audit, an ISO surveillance audit was conducted at the same time. This Certification Summary Report provides an overview of the process and KPMG s findings. Description of the BC Timber Sales Organization BC Timber Sales is an autonomous organization within the Ministry of Forests, Lands, Natural Resource Operations and Rural Development (MFLNRORD), with financial and operational independence from Regional and District operations. The organization is comprised of 12 Business Areas with an operational presence in 33 locations across the province, and supports the Ministry's goal of providing British Columbians with sustainable benefits from the commercial use of public forests. BC Timber Sales provides these benefits by planning, developing and selling through auction a substantial and representative portion of the province's annual available timber volume. The bid prices received from auctioned timber drive the Market Pricing System for setting stumpage in coastal and interior operating areas of the province. The organization manages approximately 20% of the provincial allowable annual cut (AAC). BC Timber Sales does not operate any forest products manufacturing facilities, nor does it does it have a fibre sourcing program. BC Timber Sales Certifications All 12 BC Timber Sales Business Areas are covered under a multi-site ISO 14001:2004 certificate, which is valid until September 15, The organization also holds a number of single-site CSA Z809 certificates covering portions of 3 Business Areas. In addition, BC Timber Sales holds a multi-site SFI forest management certificate covering all or portions of its 12 Business Area (BA)s that is valid until September 9, Scope of the BC Timber Sales SFI Certification The BC Timber Sales multi-site SFI certificate applies to sustainable forest management planning and practices (roads, harvesting and silviculture) conducted by BC Timber Sales Corporate staff, Business Area staff, licensees/permittees and contractors (LPCs) in all or portions of the following Business Areas: Babine Business Area (TBA) Cariboo-Chilcotin Business Area (TCC) Chinook Business Area (TCH) Kamloops Business Area (TKA) Kootenay Business Area (TKO) Okanagan-Columbia Business Area (TOC) Peace-Liard Business Area (TPL) Prince George Business Area (TPG) Seaward-tlasta Business Area (TST) Skeena Business Area (TSK) Strait of Georgia Business Area (TSG) Stuart-Nechako Business Area (TSN) A detailed listing of applicable forest management units is included as Appendix B of the BC Timber Sales Provincial Sustainable Forest Management plan at: # Plan.pdf

2 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 2 At the time of the 2016/17 audit BC Timber Sales had a combined AAC apportionment of 12,090,608 m 3 per year within the forest management units covered under its multi-site SFI forest management certificate. This equates to a prorated area under management of 9,918,333 hectares. The 2016/17 audit confirmed that BC Timber Sales had not exceeded its combined AAC apportionment for the most recent reporting year (note that a number of Business Areas currently have unused volume relative to their AAC apportionments). The portions of the BC Timber Sales Business Areas that are included within the scope of the organization s SFI certification are covered by a multi-site sustainable forest management (SFM) plan that addresses the Objectives of the SFI forest management standard and includes a variety of targets in relation to them. In addition, governmentapproved Forest Stewardship Plans (FSPs) that address both timber and non-timber values are also in place. Various higher level plans developed by government (e.g., Land and Resource Management Plans (LRMPs), etc.) also provide direction to forest management within the areas managed by the organization. The areas covered by BC Timber Sales SFI certification fall within the following World Wildlife Fund (WWF) ecoregions: (1) Alberta-British Columbia Foothills Forests, (2) North Alberta Mountain Forests, (3) British Columbia Mainland Coastal Forests, (4) Cascade Mountains Leeward Forests, (5) Central British Columbia Mountain Forests, (6) Central Pacific Coastal Forests, (7) Fraser Plateau and Basin Complex, (8) Muskwa-Slave Lake Forests, (9) North Central Rockies Forests, (10) Northern Cordillera Forests, (11) Northern Pacific Coastal Forests, (12) Northern Transitional Alpine Forests, (13) Okanagan Dry Forests, (14) Pacific Coastal Mountains Icefields and Tundra, (15) Puget Lowlands Forests, and (16) Queen Charlotte Islands. The forests managed by the BC Timber Sales are predominantly coniferous with the main commercial tree species being Douglas-fir, hemlock (western and mountain), western red cedar, yellow cedar, lodgepole pine, spruce (Sitka, white, black, Engleman and hybrids), grand fir, subalpine fir, balsam fir, western larch and trembling aspen. The forest management approach employed by BC Timber Sales is based primarily on even-aged management, ground and overhead cable-based harvesting systems, clearcut harvesting with the retention of reserves of standing trees (either within or adjacent to harvest areas), replanting of harvest areas within a few years with a mix of ecologically suited tree species and control of competing vegetation through the use of governmentapproved chemical herbicides (only some Business Areas) and/or mechanical means. Controls are in place to help reduce reliance on chemical brush control where feasible to do so. Audit Scope The ISO portion of the audit included a limited scope assessment of the BC Timber Sales environmental management system (EMS) against the requirements of the ISO 14001:2004 standard. The SFI portion of the audit was conducted against the requirements of the SFI forest management standard, and incorporated an assessment against the SFI program objectives for: 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 recreation benefits; 6. Protection of special sites; BC Timber Sales 2016/17 SFI Re-certification Audit Findings Open non-conformities from previous audits New major non-conformities 0 New minor non-conformities 6 New systemic 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 non-critical 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 2

3 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 3 7. Efficient use of fibre resources; 8. Recognize and respect Indigenous Peoples rights; 9. Legal and regulatory compliance; 10. Forestry research, science and technology; 11. Training and education; 12. Community involvement and landowner outreach; 13. Public lands management responsibilities; 14. Communication and public reporting, and; 15. Management review and continual improvement. The Audit Audit Team The audit was conducted by Dave Bebb, RPF, EP(EMSLA), Mike Alexander, RPF, EP(EMSLA), Del Ferguson, P.Geo, FGAC, Branden Beatty, RPBio, EMS(LA), Sylvi Holmsen, RPF, CA, EP(EMSLA), Dennis Lozinsky, RPF, EP(EMSLA), Neil MacEachern, RPF, Yurgen Menninga, RPF, EP(EMSLA) and Craig Roessler, RPF, EP(EMSLA). All of the members of the audit team have conducted numerous forest management audits under a variety of standards including SFI, ISO 14001, CSA Z809 and FSC. Combined 2016/17 SFI/ISO Audit The audit included an assessment of the BC Timber Sales EMS and SFI program. Site visits were made to 6 out of the 12 Business Areas (Chinook, Strait of Georgia, Okanagan-Columbia, Cariboo- Chilcotin, Babine and Seaward-tlasta). In addition, the audit included an assessment of the BC Timber Sales Corporate Office s implementation of the SFI program requirements that are applicable at the corporate level. This level of sampling meets the IAF (International Accreditation Forum) requirements regarding audit sampling for multi-site certifications with 12 sites. The audit involved a review of selected EMS and SFI records, interviews with a sample of staff, licensees and local stakeholders, and visits to several field sites (64 roads, 49 cutblocks, 40 silviculture sites and 4 marine log dumps) to assess conformance with the requirements of the SFI Forest Management Standard. The SFI portion of the audit took approximately 37 days to complete, 30 of which were spent on-site. The balance of audit time was spent preparing the audit plan, completing off-site document reviews of and completing various audit checklists and preparing the main and public summary audit reports. BC Timber Sales SFI Program Representative Kerri Brownie, RPF, BC Timber Sales Acting Certification Officer served as the organization s corporate level SFI program representative during the audit. In addition, the various Certification Standards Officers located at each of the BC Timber Sales Business Area offices included in the audit sample acted as the SFI program representatives at the Business Area level. Audit Objectives The objective(s) of the audit were to evaluate the environmental and sustainable forest management system at BC Timber Sales to: Determine its conformance with the requirements of ISO 14001:2004 and the SFI Forest Management Standard; Evaluate the ability of the system to ensure that BC Timber Sales operations meet applicable regulatory requirements, and; Evaluate the effectiveness of the system in ensuring that BC Timber Sales meets its specified SFM objectives. BC Timber Sales is an autonomous organization within the Ministry of Forests, Lands, Natural Resource Operations and Rural Development (MFLNRORD), with financial and operational independence from Regional and District operations. The organization is comprised of 12 Business Areas with an operational presence in 33 locations across the province, and supports the Ministry's goal of providing British Columbians with sustainable benefits from the commercial use of public forests. BC Timber Sales provides these benefits by planning, developing and selling through auction a substantial and representative portion of the province's annual available timber volume. The bid prices received from auctioned timber drive the Market Pricing System for setting stumpage in coastal and interior operating areas of the province. The organization manages approximately 20% (16 million m 3 /year) of the provincial allowable annual cut (AAC).

4 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 4 Use of Substitute SFI Indicators The SFI portion of the audit involved an assessment of conformance against the applicable objectives, performance measures and indicators included in the SFI Forest Management Standard. None of the indicators included in the SFI standard were modified or substituted for the purpose of this audit. Audit Conclusions The audit found that the BC Timber Sales sustainable forest management system: Was in full conformance with the requirements of the SFI and ISO standards included within the scope of the audit, except where noted otherwise in this report; Has been effectively implemented, and; Is sufficient to systematically meet the commitments included within the organization s environmental and SFM policies, provided that the system continues to be implemented and maintained as required. As a result, a decision has been reached by the lead auditor to recommend that BC Timber Sales: (1) continue to be certified to the ISO 14001:2004 standard, and (2) be recertified to the SFI forest management standard. Evidence of Conformity with the SFI Forest Management Standard The audit involved a review of selected EMS and SFI records, interviews with a sample of staff, licensees and local stakeholders, and visits to several field sites (64 roads, 49 cutblocks, 40 silviculture sites and 4 marine log dumps) to assess conformance with the requirements of the SFI Forest Management Standard. SFI Objective # Key Evidence of Conformity 1. Forest Management Planning SFM plan, FSPs, Timber Supply Review (TSR) AAC Rationales, Geographic Information System (GIS), review of site plans, interviews with a sample of staff and LPCs, field inspections. 2. Forest Health and Productivity SFM plan, FSPs, EMS operational controls, review of site plans, interviews with a sample of staff and LPCs, review of silviculture records for selected operations, field inspections. 3. Protection and Maintenance of Water Resources 4. Conservation of Biological Diversity 5. Management of Visual Quality and Recreational Benefits SFM plan, FSPs, EMS operational controls, conformance with the results of watershed assessments, review of site plans & harvest plans, field inspections. SFM plan, FSPs, interviews with planning staff, EMS operational controls, review of wildlife and biodiversity information and strategies contained in BA GIS, site plans, inspection of a sample of field sites. SFM plan, FSPs, review of site plans and associated Visual Impact Assessment (VIA) results, interviews with a sample of staff and LPCs, field inspections.

5 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 5 SFI Objective # Key Evidence of Conformity 6. Protection of Special Sites SFM plan, FSPs, review of site plans and associated Archaeological Impact Assessment (AIA) results, review of selected stakeholder and First Nations consultation records, field inspections. 7. Efficient Use of Fibre Resources SFM plan, waste survey results, final block inspections, inspection of a sample of recently completed harvesting areas. 8. Recognize and Respect Indigenous Peoples Rights 9. Legal and Regulatory Compliance 10. Forestry Research, Science & Technology BCTS policy on Indigenous Peoples rights, records of consultation with local Indigenous Peoples, interviews with BCTS staff and representatives of local Indigenous Peoples. SFM plan, BC Timber Sales environmental, social and health & safety policies, BA and Provincial level EMS and SFI management review records, BC MFLNRO C&E reports, BA non-compliance records, field inspections. SFM plan, BA and Provincial level SFI management review records, BA research records, interviews with BA staff. Although most BCTS LPCs employ either ground-based or overhead cable logging systems, a small proportion of the overall BCTS AAC apportionment is harvested using helicopters. This harvest method is sometimes employed in steep coastal terrain to access forest stands that would otherwise be inaccessible. 11. Training and Education SFM plan, EMS and SFI awareness training materials and records, interviews with a sample of staff and LPC employees. 12. Community Involvement and Landowner Outreach 13. Public Land Management Responsibilities 14. Communication and Public Reporting 15. Management Review and Continual Improvement SFM plan and related monitoring results, WCSIC meeting minutes, correspondence related to community and school outreach programs, staff interviews. SFM plan, FSPs and related agency and stakeholder referral correspondence, review of site plans, review of selected stakeholder consultation records, field inspections. Certification summary report. SFM plan, BA and Provincial level EMS and SFI management review records, internal audit reports and associated action plans, BA and Provincial level Environmental Management Programs (EMPs), interviews with a sample of corporate and BA staff. Follow-up on Findings from Previous Audits At the beginning of the May 1, 2016 April 30, 2017 audit period there were a total of 7 open minor non-conformities from previous audits that were applicable at the corporate level. The audit team reviewed the implementation of the action plans developed by BC Timber Sales to address these findings and found that they had been effectively implemented in 4 out of 7 instances. As a result, 4 out of the 7 previously identified non-

6 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 6 conformities have been closed. However, although the audit found that BCTS had implemented all of its proposed corrective actions in relation to the remaining 3 nonconformities (which related to weaknesses in: (1) riparian management practices, (2) the implementation of BCTS inspections of LPC operations, and (3) the tracking of corrective actions associated with non-conformities identified through BCTS inspections), additional improvements in performance are still required, most notably at the Cariboo- Chilcotin Business Area. As a result, these non-conformities have been kept open pending completion of a special purpose site visit to the Cariboo-Chilcotin Business Area in fall Good Practices A number of good practices were identified during the course of the 2016/17 BC Timber Sales ISO 14001/SFI audit. Examples included: SFI Forest Management Objective 1 (forest management planning): The Babine Business Area has developed an Auto-planner resource check tool which uses the GIS to report on which forest management constraints apply to a specific planned harvest area (e.g., visuals, First Nations consultation, landscape corridors, other tenures, habitat areas). Seral targets are also considered and added manually to the Auto-planner. This puts all the constraints in one place so that those that apply are identified and trigger management strategies. In addition, the tool also serves as a means to document the due diligence check. (Babine Business Area) SFI Forest Management Objective 2 (forest health and productivity): On one block visited during the audit that had minimal amounts of Douglas-fir the LPC decided to retain over-story Douglas-fir where possible, even though the prescription did not require its retention. (Cariboo-Chilcotin Business Area) SFI Forest Management Objective 2 (forest health and productivity): The audit found that the Cariboo-Chilcotin Timber Sales Manager had appointed a timber inventory analyst to address critical forest health issues in the Williams Lake TSA including: (1) MPB stands identified for potential harvest or rehabilitation under Forests for Tomorrow or the Forest Enhancement Program, (2) the spruce bark beetle, and (2) Douglas-fir beetle. (Cariboo-Chilcotin Business Area) SFI Forest Management Objective 4 (conservation of biological diversity): An audit field visit of a timber sale found that a site plan amendment had been completed in order to leave a 70 metre buffer around an identified sharp-shinned hawk nest as recommend by an RPBio, despite there being no legal requirement for the buffer. (Strait of Georgia Business Area). SFI Forest Management Objective 5 (management of visual quality and recreational benefits): The audit found that the Strait of Georgia Business Area has established and implemented an effective process for managing visual quality objectives (VQOs), including the running of a 3D moving model at the preliminary design stage to view proposed blocks and address VQOs from various visual viewpoints. In addition, the Business Area periodically (every 2 years) verifies the effectiveness of the VIA models in predicting the visual impact of proposed harvest blocks by conducting post-harvest visual evaluations. (Strait of Georgia Business Area) SFI Forest Management Objective 6 (protection of special sites): The audit found that the Seaward-tlasta Business Area has developed a program for mapping potential high value/monumental cedars for use in Aboriginal cultural practices, both inside and outside the area known as the Great Bear Rainforest. (Seawardtlasta Business Area) SFI Forest Management Objective 8 (recognize and respect Indigenous Peoples rights): The audit noted a number of examples of efforts to build capacity within local First Nations at the Babine Business Area including: (1) the existence of a First Nation Forestry Training program, which is a provincial program that the In the area of the central BC coast that is commonly referred to as the Great Bear Rainforest, BCTS and other forest enterprises continue to apply the principles of Ecosystem-based Management (EBM) as a means to help ensure the long term viability of local ecosystems while also providing for economic and social values.

7 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 7 Business Area is involved in, (2) designing smaller road maintenance contracts to be suitable for local First Nations companies (which are still open competitive bids), (3) direct awards to an archaeological consultant that employs Wet'suwet'en employees, and (4) working with the Lake Babine First Nation on a capacity and benefits agreement for 50,000 m 3 of harvest volume. (Babine Business Area) SFI Forest Management Objective 13 (public land management responsibilities): The audit found that the Powell River Field Team (PRFT) had implemented a number of enhanced public consultation processes in recent years, including: (1) proposed roads and cutblocks are now shown for the next 5 years, and a link on the PRFT website now allows stakeholders to view maps on proposed operations using Google earth, and (2) the PRFT has increased liaison with the Powell River Regional District, (PRRD) to address public concerns regarding slope stability and flooding. Through referral of operational plans the PRFT and PRRD now engage in the consultation and review of hydrology and geotechnical reports in both jurisdictions to ensure potential risks are identified and mitigation measures address concerns from both parties. (Chinook Business Area Powell River Field Team) NB: The above list of good practices is not intended to be a comprehensive list of all of the noteworthy or innovative forest practices that are taking place at the operations included in the 2016/17 audit sample. Rather, they are simply observations made by the audit team that were deemed worthy of inclusion in this public summary report as a means to highlight some of the positive aspects of the organization s forest management practices. The audit included the inspection of several recently installed temporary bridges to assess their conformance with both regulatory and BCTS EMS requirements. New Areas of Nonconformity The 2016/17 BC Timber Sales ISO 14001/SFI audit identified a total of 6 new minor non-conformities in relation to the requirements of the SFI Forest Management Standard, as follows: SFI Forest Management Performance Measure 2.3 requires Program Participants to implement forest practices to protect and maintain soils and forest productivity. These requirements were found to have been met of the majority of sites included in the audit sample. However, the audit identified a number of weaknesses in the BCTS EMS procedures that address these requirements (i.e., excessive cutting and side-casting of material during road construction on an active TSL during wet conditions (note that BCTS had identified the same issue on 2 other blocks in this TSL but there were no inspection reports to document this issue and it had not been entered into the BCTS incident tracking system) and several instances on a recently completed TSL where logging slash had been piled too close to standing timber and dispersed retained trees (this issue had also not been identified as an issue in the BCTS final inspection of this block)). (Cariboo-Chilcotin Business Area) SFI Forest Management Performance Measure 3.2 requires Program Participants to develop and implement plans to manage or protect rivers, streams, lakes and other water bodies. In addition, EFP 01 requires LPCs and/or their workers to follow the project plan, while EFP 04 requires them to minimize the impact of their activities on water quality and site productivity. However, field inspection of a sample of active and recently completed field sites identified a number of weaknesses in the implementation of riparian management practices (i.e., lack of adequate drainage control on a deactivated road on one TSL, failure by a licensee to clean out culverts on four S6 streams following completion of logging, installation of a 600mm culvert on an S6 stream that was too short to prevent excavated material from entering the stream channel and a failure by BCTS to provide information with the pre-work for a road construction project defining culvert locations, stream classifications or machine-free zones). (Cariboo- Chilcotin, Strait of Georgia and Babine Business Areas)

8 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 8 SFI Forest Management Performance Measure 9.1 requires that Program Participants develop and implement a system to comply with applicable laws and regulations, including those that relate to fuel storage and the management of industrial waste. These requirements were found to have been met of the majority of sites included in the audit sample. However, the audit identified a number of weaknesses in the implementation of the BCTS EMS procedures that address these requirements (i.e., large fuel tanks at a licensee camp that lacked the required collision protection barriers and a log dump where the licensee was not storing and disposing of industrial waste in accordance with the applicable BCTS EMS requirements). (Cariboo-Chilcotin and Seward-tlasta Business Areas) SFI Forest Management Performance Measure 11.1 requires that Program Participants assign roles and responsibilities for achieving the SFI forest management objectives and that these be understood by those to whom they are assigned. The audit found that these requirements had been met at most of the Business Areas included in the 2016/17 audit sample. However, the Cariboo Chilcotin Business Area has undergone a number of staffing changes in recent years and has been without a fulltime Certification Standards Officer (CSO) since Prior to that time, there had also been frequent turnovers in the CSO position, as well as numerous other staff changes. As a result, there has been a lack of consistent focus on the implementation of the EMS at the Business Area, resulting in several weaknesses in the implementation of EMS procedures (i.e., gaps in staff training records, lack of consistency in the implementation of various EMS requirements by BCTS staff, lack of completeness of the annual Business Area management review and the lack of a clear linkage between the Business Area EMP targets and the responsibilities of BCTS staff and licensees to implement actions to achieve those targets). (Cariboo-Chilcotin Business Area) SFI Forest Management Performance Measure 11.1 requires that Program Participants provide staff and contractor training sufficient to their roles and responsibilities. The audit found that these requirements had been met in the majority of instances. However, the audit identified a number of gaps at the Cariboo-Chilcotin Business Area in staff training, awareness and implementation of the EMS requirements related to inspections, legal requirements and contract requirements (i.e., some new staff who had yet to receive BCTS EMS/SFI training as well as approximately 40% of Business Area staff who had yet to receive SAR training, inconsistencies in site plan riparian prescriptions resulting from weaknesses in staff understanding of the applicable requirements, and several weaknesses in the implementation of EMS procedures for inspections, incident investigation and the tracking of required corrective actions in the BCTS incident tracking system). (Cariboo-Chilcotin Business Area) SFI Forest Management Performance Measure 2.3 requires Program Participants to implement forest practices to protect and maintain soils and forest productivity, These requirements are addressed through various BCTS EMS procedures including those related to emergency preparedness and response. However, the audit identified a number weaknesses in the implementation of these procedures (i.e., several instances where required fire extinguishers were found to be discharged or had not been inspected in the past year, missing or incomplete spill kits on equipment and vehicles carrying auxiliary fuel tanks and a number of licensee emergency response plans that were incomplete). (Seaward-tlasta, Strait of Georgia, Okanagan-Columbia and Cariboo-Chilcotin Business Areas) New Opportunities for Improvement Several opportunities for improvement, many of which were restricted to a single Business Area, were identified during the 2016/17 BC Timber Sales ISO 14001/SFI audit. These have already been reported to BCTS through the Business Area level audit reports that were provided to the organization either on-site or soon after the applicable Business Area site visits took place. Inspection of a recently harvested timber sale in the Mamquam River area found that BCTS had worked with local recreational groups to help minimize the impact of forest harvesting on a mountain bike trail. This corporate level Certification Summary Report only includes systemic (i.e., corporate level and/or multi-business Area) opportunities for improvement.

9 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 9 The 2016/17 BC Timber Sales ISO 14001/SFI audit identified a total of 2 new systemic opportunities for improvement that related to the requirements of the SFI Forest Management Standard, as follows: SFI Performance Measure 2.3 requires Program Participants to implement forest practices to protect and maintain soils and forest productivity. BCTS has developed various procedures and operational controls in support of these requirements (e.g., EFP 01, EFP 05, BCTS Staff Emergency Response Plan, LPC ERP template). However: (1) there are no specific timing or burning condition constraints in the EMS operational controls, and BCTS cannot stop a licensee from burning logging slash even if BCTS feels it is high risk, (2) post-burn infrared scanning, which is an industry standard, typically does not occur, and (3) BCTS leaves it up to contractors/licensees to determine what is needed for fire response equipment, but has no oversight as to whether it is adequate to address the risk, nor guidance as to what is suitable. (Corporate Issue) The BCTS Provincial Audit Program and Plan outlines a risk-based approach to audit scheduling under which each Business Area (BA) will receive a combined ISO 14001/SFI at least once every 3 years. In addition, if a BA exceeds the current risk score benchmark of 19 points (which is based on the number and severity of audit findings in the previous year) the BA will be recommended for a follow-up internal audit in the following year. However, although this risk-based approach to internal audit scheduling has been in place for a number of years and various BAs have had risk scores above the benchmark, it has yet to result in a BA receiving an internal ISO 14001/SFI audit more frequently than the minimum of once every 3 years. (Corporate Issue) Corrective Action Plans Corrective action plans designed to address the root cause(s) of the findings identified during the 2016/17 audit have been developed by BC Timber Sales 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: Implementation of the action plans developed by BC Timber Sales to address all open non-conformities identified during previous external audits. Follow-up on the Business Area-specific EMS issues/potential concerns noted in the applicable Business Area audit reports. Conclusion of the Pacific TSA TSR process by government and the resulting AAC determination and BCTS apportionment. (Strait of Georgia Business Area) Implementation of the BCTS procedures to address the requirements of the Migratory Birds Convention Act. Waste levels on cruise-based sales in the Skaha Lake area. (Okanagan-Columbia Business Area) Progress towards more consistent implementation of the EMS at the Cariboo- Chilcotin Business Area. Note: A special purpose assessment was conducted at TCC in October 2017 to assess the Business Area s progress towards the implementation of the action plans that were developed to address the applicable findings of the 2016/17 audit. However, although the assessment found that progress had been made, a significant amount of work remained to be done. As a result, all of the action plans developed by the Business Area to address the findings of the 2016/17 remain open. An additional audit site visit to TCC is Although larger riparian features can often be identified using aerial photos of a planned harvest area, small features (such as the stream above) are typically identified and mapped by field layout crews. Riparian management prescriptions are then developed to help protect both the waterbody and the riparian management area immediately adjacent to it.

10 Findings BC Timber Sales 2016/17 SFI Re-certification Audit Page 10 scheduled for August 2018 to assess the Business Area s continued progress towards addressing the issues identified during the 2016/17 audit. Steep slope harvesting of traditional cable ground and plans to harvest some of these areas. (Babine Business Area) Follow-up on fire hazard assessments resulting in recommended abatement score, but not receiving abatement treatment. (Seaward-tlasta Business Area) Inspection of a sample of silviculture sites found a high level of compliance with the reforestation requirement specified in the applicable Forest Stewardship Plan. Contacts: Chris Ridley-Thomas, RPBio, EP(EMSLA) (604) David Bebb, RPF, EP(EMSLA) (604) This report is the property of KPMG and may only be reproduced by the intended client, BC Timber Sales, 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.