It’s wonderful to see more and more companies jumping on the sustainable forestry bandwagon. But, as this relatively new certification comes to bear on industry practices, there are bound to be kinks in the chain-of-custody that need working out.
Cary Sherburne, senior editor for Lexington, Kentucky-based WhatTheyThink, reported on a dilemma faced by Alpharetta, Georgia-based Neenah Paper. Her article, Environmental Sustainability: Not Always Easy; Lessons Learned from Neenah Paper FSC Certification Issues, appeared May 13 on the website www.whattheythink.com. Excerpts of the most salient points have been edited for space and are reprinted here with permission.
On April 25, Neenah Paper notified customers its FSC Chain-of-Custody (CoC) certification had lapsed. This lapse resulted in product being manufactured and packaged with the FSC logo during March and April when [technically,] the company was not certified and, therefore, unauthorized to use the logo. Neenah was quick to point out that none of its CoC practices had changed since its original certification in 2003, and at the time of the lapse, it had been nearing the conclusion of the recertification process with the New York-based Rainforest Alliance’s SmartWood program.
“When we initially certified in 2003 as one of the first premium mills globally, and one of the first North American mills in any category, the process took one month,” said John O’Donnell, president of Neenah Fine Papers. “Recertification, on the other hand, took seven months, much longer than anyone anticipated.”
Dave Bubser, U.S. regional manager for certification agent SmartWood, stressed that FSC certification is a voluntary program, [yet it] holds a lot of appeal throughout the supply chain. He also explained that CoC certification is all about inventory control and making accurate representations about the actual fiber content of, in this case, paper. (There is also FSC certification at the forest level that is more comprehensive and includes environmental, social and economic criteria covering everything from protection of endangered species to water protection and workers’ rights.)
Bubser acknowledged the most common barriers to FSC CoC certification are largely administrative. “We are in the midst of a real tsunami of demand for certification,” he said. “We used to tell folks that the certification process would take four to six weeks. Now, we are telling people it will be several months before the process is completed, although we believe this to be a temporary situation as we increase staffing and clear the backlog of certification requests.” (SmartWood grew almost 100 percent last year based on the spike in demand.)
The Neenah Situation
Neenah Paper successfully completed its recertification process on April 29, so the paper manufactured by the company as FSC certified between March 1 and April 28, technically violated FSC standards. The FSC communication states in part, “FSC follows a strict position with regard to the sale of inventory product after the termination of an FSC certificate; suppliers shall immediately cease to make ... use of any FSC trademarks, or to sell any products that the supplier has previously labeled or marked using the FSC trademarks or to make ... claims that imply that they comply with the requirements for certification.”
However, in the case of Neenah Paper, while the certification had lapsed, the FSC did point out its inspections indicated the integrity of Neenah’s FSC inventory had demonstrably been maintained at all times. In light of this fact, the FSC excluded product that was shipped prior to certification expiration from the rules violation for Neenah, yet maintains product manufactured during the period of lapsed certification cannot be labeled as FSC certified.
Said O’Donnell, “Our biggest mistake was assuming we would be bridging certification due to delays by the certifiers, since we had not changed our operating philosophy. This is often the case with regulatory bodies. But in this case, there was a hard stop. That notification was received in one of our manufacturing facilities on March 3rd and did not arrive in corporate until mid-April. At the same time, our certifier was indicating that we had almost completed the process.”
In a letter reminding the marketplace of the importance of standards compliance, the FSC stressed, “It is important to remind all participants in the FSC network—and in particular all certificate holders—of the need for clear and accurate internal communication between all departments of a company to ensure that opportunities to incorrectly reflect the status of participation in FSC programs are minimized. Additionally, it is vital that sales and marketing staff are kept up-to-date and aware of the status of certification and of any issues potentially impacting it to prevent opportunities for misrepresentation in the marketplace.”
Moving Forward
One factor, according to O’Donnell, that extended the recertification process was the company’s decision to include four facilities in the recertification process, even though two—which had been acquired—had certification in place that was not expiring. “We believed it would be easier for our customers to have coterminous expiration dates for our certification, but in hindsight, that was not a good decision,” he reflected. “My biggest regret,” continued O’Donnell, “is the issues that we caused for our customers. We’re being transparent about our situation in the hope that other mills, merchants and printers will be able to learn from our situation.”
What lessons learned did O’Donnell share?
• Actively lead your recertification process. The certifiers are interested in the process, as they should be, and less interested in the business implications.
• Expect delays and plan for them. Had Neenah clearly understood the ‘hard stop,’ the company would have planned for that differently in the manufacturing process.
• Make sure internal communications are robust. Even as an early adopter, Neenah did not have a full appreciation for the business and financial implications a hard cut-off date would have for the company, and should have explored more deeply what the implications of that March 3rd communication were, despite assurances from the certifier that it had nearly completed the process.
Neenah is in the midst of assessing how much inaccurately labeled paper actually entered the supply chain. “We believe most of it is still in our facilities, and we will relabel that stock to comply with the standard,” reported O’Donnell. “During most of the period, we were shipping inventory that had been manufactured prior to the certification lapsing.”
Nonetheless, Neenah remains committed to its Neenah Green initiatives. “This is an important certification for us and for the marketplace. This unfortunate situation could give the marketplace the wrong impression—that we don’t care about timetables and expiration dates. And that is contrary to who we are and how we have acted in the past,” emphasized O’Donnell. “Our intent is to continue to take the risks that early adopters take as we explore growing our Neenah Green initiatives. This situation has not soured us on the importance of leadership in this area, which we believe is critical. Our hope is that others will learn from our experiences and that they will make sure there is clarity around any issues that arise during their own certification processes.”
- Companies:
- Neenah Paper