Requirements for Certification Bodies operating Certification against the PEFC International Chain of Custody Standard

Transcription

1 Requirements for Certification Bodies operating Certification against the PEFC International Chain of Custody Standard PEFC ST 2003:2012 Questions and Answers PEFC Council World Trade Center 1, 10 Route de l Aéroport CH-1215 Geneva, Switzerland Tel: +41 (0) , Fax: +41 (0) info@pefc.org, Web:

2 Copyright notice PEFC Council 2014 This PEFC Council document is copyright-protected by the PEFC Council. This document is freely available from the PEFC Council website or upon request. No part of this document covered by the copyright may be changed or amended, reproduced or copied, in any form or by any means for commercial purposes without the permission of the PEFC Council. The only official version of this document is English. Translations of this document can be provided by the PEFC Council or PEFC National Governing Bodies. In case of any doubt the English version is binding. PEFC ST 2003:2012, Questions and Answers 2

3 General General Do we need to apply the new requirements to all auditors or do they apply only to auditors assessed after the issue date of the standard? Can the existing auditor base be used under the new standard? The requirements are mandatory for all auditors carrying out PEFC chain of custody audits. A few specific clarifications apply for the existing auditor bas (auditors operating before 16th July 2012 in PEFC chain of custody audits). The requirements are mandatory for all auditors carrying out PEFC chain of custody audits. General Does PEFC ST 2003:2012 refer to PEFC GD 2001:2011 Section 2: Guidance for the implementation of PEFC Chain of Custody for specified projects? In other words - are we expected to follow 2003:2012 for Project Certification? If not then what is the appropriate accreditation standard? General Is there any intention from PEFC to develop a certificate transfer procedure in the accreditation standard? Certificate migration is becoming a quite frequent case and currently the old certificate must be terminated and new one issue by succeeding Certification Body Education within forest based industries can be replaced by work experience within these sectors. Does auditing such industries equate to work experience? A few specific clarifications apply for the existing auditor base (auditors operating before 16th July 2012 in PEFC chain of custody audits). For chain of custody auditors carrying out project chain of custody certification PEFC ST 2003:2012 is a mandatory document as well. Currently PEFC refers to IAF MD 2:2007 ( Presumably PEFC will develop someday a PEFC specific version. Strict handling for "new auditors" (as of 16th July 2012). The following clarification for the existing auditor base (before 16th July 2012): If the CB is using a procedure to identify the aspects as defined in 5.2 of the standard for individual auditors and can deliver proof of evidence regarding the competence of the auditor, the accreditation body can accept these auditors on a case by case decision. Such a procedure can be used only, if one part of the requirements are not met by the auditor (education or working experience). PEFC ST 2003:2012, Questions and Answers 3

4 5.2.1 Is it acceptable to consider the high number of PEFC audits they already have carried out as well as training received by our CB on PEFC and FSC auditing as sufficient evidence to demonstrate its equivalence to the required education? Generally yes. It depends on the extent of the auditing, the number of the audits. The accreditation body has to decide on a case by case basis whether the auditor or rather his activities can be regarded as equivalent. A full proof of the activities / track record shall be available Could you please explain how PEFC could recognise our internal PEFC COC education programme? Also is it required to do this training every two years regardless if PEFC COC standard has changed or not? Will PEFC Asia Promotions provide the training programs regularly? Is there any way to save those who could not attend the program? (Such as internal training by those who attended PEFCAP program) Attending to training is not always possible for some people. They may have funeral or things like that. Therefore there must be a way for these people to be trained. Things like webinar may be a good tool. Could you consider about it? FSC chain of custody experience can be considered, but the auditors shall be trained for PEFC specific aspects. Currently PEFC does not recognize any training program from PEFC external organisations. PEFC offers a "Training Recognition Program" as of June This program enables the participating CBs to implement an internal training concept, always limited to two years, recognized by PEFC Council. Yes, training is required independent from a revision. PEFC International will offer trainings on a continuous basis and support regional or national initiatives for offering trainings as well. No. Since trainings will be offered worldwide on a continuous basis the requirement is mandatory for everybody. PEFC International will also provide online training from October 2014 at the latest. PEFC International will also provide online training from October 2014 at the latest. PEFC ST 2003:2012, Questions and Answers 4

5 5.2.4 Requires full time experience the forest based industries. What is meant by full time? Full time employment or would for instance being a consultant or an auditor also be acceptable. If auditing experience is acceptable, will this also apply to auditors that do by example 5 audits in a year What does a first qualification mean? Our CB has auditors that are ISO and 9001 auditors currently but just starting out to be PEFC ST CoC auditors. If they are already auditors of various other standards would that not mean that they are qualified? Our CB has an instance where I currently have an auditor in training in New Zealand and need to know if, in your opinion, the requirement for 3 years of full time experience in forest based and related industries has been met. The auditor has been involved as an observer on 3 Surveillance audits and has participated as an auditor on 3 other surveillances for the AFS 4707 standard which is the Australian standard endorsed by PEFC. All these audits have been through XYZ. His training to date was completed in February of this year prior to the new Strict handling for "new auditors" (as of 16th July 2012). The following interpretation for the existing auditor base (before 16th July 2012): If the CB is using a procedure to identify the aspects as defined in 5.2 of the standard for individual auditors and can deliver proof of evidence regarding the competence of the auditor, the accreditation body can accept these auditors on a case by case decision. Such a procedure can be used only, if one part of the requirements are not met by the auditor (education or working experience). Strict handling for "new auditors" (as of 16th July 2012). The following interpretation for the existing auditor base (before 16th July 2014): If the CB is using a procedure to identify the aspects as defined in 5.2 of the standard for individual auditors and can deliver proof of evidence regarding the competence of the auditor, the accreditation body can accept these auditors on a case by case decision. Such a procedure can be used only, if one part of the requirements are not met by the auditor (education or working experience). Requirement refers to a period of time and not to a number of audits. Number of audits is relevant in Audit experience. These two aspects work experience and audit experience have to be covered separately. How audit experience in ISO 9001 or ISO can partly replace audit experience in chain of custody is also described in ISO and 9001 experience cannot fully replace the required chain of custody audit experience. PEFC ST 2003:2012, Questions and Answers 5

6 standard being released Finally I need to know how stringent is PEFC going to be on the requirement for an auditor to have a minimum of 3 years of full time forest based and related industries. I currently have a Chemical Engineer/P.Eng and an Economist both certified as ISO auditors. My P.Eng is also a Lead ISO 9001 auditor while my Economist conducts GHG verification audits as well. I find it difficult to rationalize why a forestry related background is needed for a CoC in a pulp mill (better suited for a chemical engineer) or a printer or a recycler. These 2 auditors have already started to do observation audits with me while I have been conducting PEFC ST audits. Again training started prior to the new standard release The wording of the original requirement does not seem to exclude auditors experiences in FSC or MSC audits. In fact, our CB is afraid that we do not have enough number of PEFC clients for our auditors to satisfy this requirement and that other CBs may interpret that this requirement does not exclude auditors experiences in audits of other certification schemes than PEFC, such as FSC, MSC, etc. PEFC is very stringent. Nevertheless, the standard is using the wording "forest based and related industries". That means that pulp mills as well as printers are covered by the definition. From specific experience results a restriction of the industries which can be covered by the auditor. Being qualified for a pulp mill does not mean being qualified for sawmills. Basic purpose of the education and experience requirements in PEFC ST 2003 is to exclude "PEFC COC auditors by occasion". Nevertheless, PEFC recognizes that experience in other chain of custody standards is helpful to understand and audit the PEFC Chain of Custody Standard. Hence, experience in other chain of custody standards can be accepted if the auditor additionally can deliver proof of evidence for participation in a PEFC recognized training explicitly covering - PEFC's DDS (chapter 5) PEFC ST 2003:2012, Questions and Answers 6

7 - PEFC's social, health and safety requirements (chapter 9) - Specification of the PEFC claims (Appendix 1) Is it possible to count FSC COC audits into the required minimum two audits? For regaining qualification to conduct PEFC-COC-Audits, for example after a long illness or maternity leave, does a PEFC-auditor has to perform two audits under the leadership of a qualified auditor, according to the standard 2003:2012, indicator 5.2.5? In our opinion it would be sufficient he has to participate in an education program to be up date, as required in Since PEFC-auditor has got working experience (in our case over years) and it would be not in proportion to compare him with a beginner b) Auditor must show ability in cultural and social customs of the client. Would language proficiency suffice? See above. Yes, a PEFC auditor has to perform two audits under the leadership of a qualified auditor. Language proficiency is a basic precondition for the auditor, but it is not sufficient. For the understanding of an organisation s operational context some broader experience of the business environment of an organisation is necessary. It's sufficient if the experience is available by working with an audit team. PEFC ST 2003:2012, Questions and Answers 7

8 c) Knowledge and skills in the applicable legal requirements. This will have to be tailor made for each country and a CB will have to find a way to ensure compliance with this. Not clear why auditors need to know legal requirements related to forest governance. This is a huge field that bears no relationship to CoC c) What is the purpose of the requirement to have knowledge and skills relating to forest governance and laws in countries where uncertified materials originate from? Is the auditor expected to make a judgement on the legality of uncertified material? And, if so, is the auditor expected to communicate their knowledge to the Certificate Holder? b) Knowledge and skills for products and practices in the specific forest based sector. Would audit experience be acceptable or do they need to have work experience. If so, would this have to be in the specific sector? c) What management systems" are referred to here? Not clear what is required. The last statement is not correct. Bullet point c explains why it is necessary to have this knowledge! No legal compliance audit required. The requirement refers to chain of custody related issues (and the specific context). E.g. relevant for risk assessment. The auditor is expected to carry out the DDS according to the PEFC Chain of Custody Standard. Some basic knowledge about forest governance and laws are necessary, otherwise a correct DDS is hardly possible. This requirement shall be read in context especially with 5.2.1, 5.2.3, 5.2.4, The sector specific context is clearly stated in the requirement. No reference to a specific management system. It is required that the auditors understand how management systems in general work and how they are used in forest based and related industries (e.g. 9001, 14001, lean, OHSAS). PEFC ST 2003:2012, Questions and Answers 8

9 8.1 Why the requirement 8.1 b) has appeared in the accreditation standard? Most of companies from timber and paper sector apply for PEFC COC certification in the matter of urgency without any extensive knowledge of PEFC ST 2002:2010 nor prepared documented PEFC COC procedures/manual. By the time they are being audited they gather all necessary knowledge, prepare documents and train the key personnel. Please explain why the organisation is not able even to apply without the documented system? Is it not allowed to issue/reissue certificate when any nonconformity, even minor nonconformity, was found in the course of initial certification or re-certification? b) In case of percentage based method is it necessary to further specify "average percentage" or "volume Annex Annex credit"? Is it possible that the client organisation performs internal audit and add new sites between the surveillances? Is it correct that new sites only can be added as a result of an audit and does this also apply to groups? In case of groups we have often a system were the group management is adding new sites without audit from the CB and the new sites are sampled in a separate stratum at next surveillance. PEFC expects that the CoC standard is fully implemented before the audit takes place. The following differentiation can be applied: the "request for a proposal" is different from the formal application for certification. The application for certification may be include all steps before the formal certification process starts. The points mentioned under 8.1 and 8.2 must be clarified/available when the organization assigns the CB with the certification audit. The main objective for PEFC is to prevent that the CB does not start with the certification process before the company is properly prepared. If this would be the case, there is a certain risk that the CB starts with consulting and therewith a potential conflict of interest occurs. Yes. Same for Annex 3, No, just specify whether certified to physical separation or percentage based. No. Wording in the standard is clear. Yes. Wording in the standard is clear. PEFC ST 2003:2012, Questions and Answers 9