UKFCG 10th Anniversary – Quinquennial Re-assessment of FSC and PEFC Certificates.

The final report from the 2022 re-assessment audit conducted by Soil Association has been received and we can confirm the findings from the audit which require follow-up action.  In addition to site based audits, the audit focused on management of the Group and our record keeping.  Thank you to all forest managers in the Group for sending back the annual summary spreadsheet which included details of timber sales, pesticide and fertiliser use, serious accidents, complaints and deer cull figures – all for 2021/22.  These records are an important part of Group management and are submitted to Soil Association every year.

The very small number of follow-up actions is a reflection of the high standards of forest management and record keeping which were clearly evident at the ten forests visited during the audit.  Closure of the Corrective Actions is being undertaken by forest managers at the selected sites, however, it is important that all UKFCG Group members are aware of the issues and take steps to ensure that management of every forest avoids the risk of recurrence at other locations.

The audit findings are as follows, site details have been removed:

Corrective Actions

UKWAS section 3.1.1

Requirement: Woodland operations shall conform to forestry best practice guidance.

Auditor Findings: Log stacks exceeded product length, there was no risk assessment in place to account for this.  At another site the Harvesting Risk Assessment stated that stacks should be kept to 2m, or failing that product length, and that if this is exceeded the forwarder operator must ‘run a red and white tape along the stack’.  The additional measures stated in the risk assessment had not been acted on, however, this was done before the site visit ended.

UKFCG Group Manager Comment: Since this site visit, the Forest Manager has written a memo for stacking compliant with FISA 503, the Harvesting Contractor has revised their Work Site Risk Assessment to include this memo, and this has been communicated to the forwarder driver on site.  FISA 503 states: Generally stacks heights should not exceed product length and should not exceed the height for a haulier to be able to see across the top of the stack. Where site specific conditions dictate that stack heights need to be more than product length then extra precautions must be put in place around the stack. The agreed stack height should be included in the site risk assessment. If circumstances change the risks must be reassessed. 

Further guidance can be found in UKFCG Briefing Note 002 – Timber Stack Heights.

Action required – All Group Members:  Operational monitoring visits should include checks on timber stacks and a written record or checklist retained for future reference.  Review the rate of despatch of timber from site in relation to the rate of growth of timber stacks and volume of timber awaiting forwarding to the loading bay.  Anticipate the likelihood of timber stack heights exceeding product length and, if necessary, ensure that a site specific supplementary timber stacks risk assessment is carried out and documented.  Ensure that additional safety measures defined in the risk assessment are put in place.  Keep a record of all actions taken.

The NC has been closed.

UKWAS section 4.7.1.a.

Auditor Findings: A designated ASNW was restocked with native trees, but the recent plant supply invoice with details of provenance of the planting stock could not be retrieved owing to IT difficulties.

UKFCG Group Manager Comment: In woodlands identified in sections 4.1-4.4, [Forests with ASNW/PAWS/LEPO designations] where appropriate and possible, owners/managers shall use natural regeneration or planting stock from parental material growing in the local native seed zone (native species).

Action required – All Group Members: Any restocking with native species in Forests with ASNW/PAWS/LEPO designations, forest managers should ensure that plant supply invoices include details of provenance.  A copy of the documentation should be retained and be available at the time of UKFCG surveillance or Soil Association audits.  This is particularly important if the supply of plants is undertaken by the contractor, please ensure the provenance information is obtained from the contractor.  If you would like a copy of the UK Provenance Zone map, please contact UKFCG and this will be sent to you as a pdf.

Provenance documents were subsequently located and The NC has been closed.

UKWAS section 3.4.2

Auditor Findings: An Integrated Pest Management Strategy could not be produced for inspection by the auditor.

UKFCG Group Manager Comment: Even if there has been no pesticide use and there is no intention to use pesticides, UKFCG urges all Group Members to prepare an Integrated Pest Management Strategy [IPMS].  Other aspects of IPMS include deer control, species mixtures for restocking to minimise risk from pests and other strategies which reduce the likelihood of having to resort to pesticide use.  An IPMS can be incorporated in the forest management plan, or appended to the plan.  UKFCG’s IPMS has been prepared to cover all applicable aspects of UKWAS and is available on request, our most up to date version [v3 Sep2022] includes reference to The Official Controls (Plant Protection Products) Regulations 2020 (OCR).

Action required – All Group Members:  Prepare an IPMS if you do not already have one.  For existing IPMS, please review your document and ensure there are no references to specific pesticides which may have been banned since IPMS preparation or may be banned in future – best not to mention any by name.  Ensure your IPMS is not time limited. e.g. if the document states an annual review will be carried out – make sure you do it and keep a record.  Update the IPMS if necessary, make sure UKFCG has a copy of your updated IPMS – this will save time during audits.

Updated IPMS has subsequently been provided by the forest manager and the NC has been closed.

FSC Trademark – Sales claims

Auditor Findings: Although not one of the sample sites for the audit, a stakeholder responded to the consultation that a timber sale invoice had been issued without the correct ‘FSC 100%’ claim. The Forest Manager had sent an invoice template to the accounts department for the estate with the correct claim, but this did not appear on the actual paper invoice sent to this customer. 

The accounts department have been made aware of the sales claim requirements and an amended invoice has been sent to the buyer, the NC has been closed.

UKFCG Group Manager Comment: Similar occurrences have been found during several internal surveillance audits in recent years.  The majority of timber sales invoices show the correct FSC 100% claim and forest certification code/sub-code, this includes SBIs and invoices raised by the forest manager.  Incorrect claims arise in situations where invoicing is undertaken by other personnel, usually estate office or forest owners.

Action required – All Group Members:  Forest managers please check all sales claims on invoices show the correct FSC 100% claim and FSC code/sub-code (and/or PEFC if used).  Particular attention should be directed to invoicing carried out by others involved with administration of timber sales documents.  Forest managers should obtain a copy of a despatched invoice for each new harvesting operation to ensure the claims are correctly shown.  Please contact UKFCG for further guidance if required, or refer to UKFCG’s Doc10b Selling Timber with FSC/PEFC claims which is sent to all new members at the time of joining UKFCG.


UKWAS section 2.7.1

Auditor Findings: restructuring in one of the audited forests is under way, with areas of broadleaf planted in compliance with UKFS. However, there is extensive natural regeneration of SS in the MB area. If left untreated, the SS will overwhelm the MB and this restructured area will effectively be lost. Hence there is a risk of non-compliance if the SS is not controlled or removed.

UKFCG Group Manager Comment: In addition to the UKWAS requirements stated by the auditor, there are other factors to be considered which were not referenced in the audit report.  3.1.2 regarding relevant permissions includes felling licences.  Restocking mixtures defined in the licence, if not complied with in the long term, may result in failure to comply with applicable sections of the Forestry Act.  This in turn could lead to audit findings under section 1.1.1 – Compliance with the law.

Action required – All Group Members:  Ensure that all restocking accurately reflects the restocking conditions enshrined in felling licences and forest management plans.  UKWAS 2.8.1.b) requires stand composition to be restored in a timely manner. UKWAS 2.15.1.c) requires monitoring of changes in environmental conditions which includes woodland composition and structure. 

Please contact UKFCG if you have any questions or would like copies of additional documents that are referenced in the newsletter.