Annual audit of UKFCG by the Soil Association
The 2024 audit of UKFCG is at the halfway point with a brief one-day break in Inverness before week three which concludes with the closing meeting on 4th May. We have been notified of a small number of corrective actions which are summarised here, a more detailed report will be circulated in May as soon as we receive the final audit report. In the meantime, please react to the interim findings to ensure there are no repeat occurrences in the forests you manage. Our May newsletter will include further insights into the auditor’s emphasis on subjects which were satisfactorily assessed and did not lead to corrective actions.
CAR – Monitoring of PAWS [2.15.1 and 4.3.1]
Please ensure that if your forest includes PAWS areas, the monitoring of these areas is included in your monitoring plan. The purpose of monitoring is to ensure that operational activity is at least maintaining the status of the PAWS area and preferably enhancing the remnant ASNW features.
For other monitoring: Monitoring plans should be reviewed and revised at least in line with management plan review/renewal periods. Check the frequency of monitoring stated in your plans and if it’s in the plan, make sure you do it and keep a written record of the monitoring, its findings, and an action plan if necessary. Avoid using the word ‘periodic’ for frequency of monitoring as this can not be audited and could lead to corrective actions.
CAR – Redundant Materials and Waste [UKWAS 3.6.1 and 3.6.2]
A recurring theme which has cropped up on a couple of sites, and frequently encountered during our internal surveillance audits. The SA audit has found discarded band tracks, lorry tyre and other detritus, redundant deer feeder and a redundant high seat (raised under 5.2.1 for public safety)
– SO FAR! We are aware that many such occurrences may be out with the forest manager’s control. Please be vigilant; if you see it shift it.
CAR – Warning signs in operational areas [UKWAS 5.2.1 and 5.4.1]
A harvesting site, where the forest road beyond the operational area was a cul de sac, only had warning signs on one approach. A harvesting site is a high-risk work site and the full suite of threshold, warning and prohibition signs must be in place on all approaches.
Additionally, the warning signs on the approach to overhead powerlines did not have the maximum safe height on the warning signs.
A reminder of the requirements can be found in the two publications attached with this newsletter.
Forestry Commission Practice Note FCPN019 Managing Public Safety on Harvesting Sites.
FISA Safety Guide 804 Electricity at Work: Forestry.
CAR – Tree Safety Surveys [UKWAS 5.2.1]
A tree safety survey undertaken in 2019 included a recommendation for follow-up survey after two years. There was no evidence of a follow-up survey. There are many aspects associated with this failing, additional to non-compliance with certification requirements. Apart from the risk to the public, the forest owner/manager should be aware of the litigation risks following injury if a tree safety policy, consistent timely approach and reaction to findings cannot be evidenced.
All forest managers should determine whether a tree safety policy and inspections are required. The National Tree Safety Group have published valuable guidance on this subject which is now often quoted and used in court cases where there have been tree safety related issues. A link to their key publications is.
https://ntsgroup.org.uk/guidance-publications/
Tree Safety (continued)
While UKWAS requirement 5.2.1 makes reference to natural hazards including trees there are no specific requirements in terms of the how tree safety inspections are timed or undertaken so UKFCG is not indicating that this particular approach is any more valid than others or necessary for compliance. We hope these are of interest and things such as the language and definitions used – high and low risk zones, informal and formal inspections etc may help when articulating or discussing an approach to tree safety.
Correct Action Requests (CARs)
Mindful of recent events which led to suspension of another company’s group FSC/PEFC certificate, please be assured that we will work on your behalf to reduce the risk of this occurring to UKFCG, but, we need your cooperation at all times.
⦁ If we inform you of CAR trends – take action, make sure it does not happen to you.
⦁ If we issue a CAR during a surveillance audit on your forest – take action, react with evidence to close the CAR in a timely manner.
⦁ If you are unsure of what is required for any certification matters or CAR – contact UKFCG at the earliest opportunity.
We will not hesitate to suspend the FSC/PEFC certification of any member who fails to deal with CARs before the notified deadline. Our action in this respect is aimed at protecting the integrity of the group, our reputation and the certification of all our members.
OTHER NEWS
EU Deforestation Regulations – EUDR
Here is some information on EUDR. FSC have put together a little package of information including a presentation on the FSC UK web-site and the link is below.
https://uk.fsc.org/legislation/eudr-and-fsc
We hope this will give you some more of the background and also a preview as to how FSC is looking to deal with this – although the majority of the approaches/tookit such as the Regulatory Module, the Risk Assessment and Bloc-chain based tracing system have just been subject to a consultation process and so could change.
What we do hope this shows is that there will be impacts for any Forest Manager who is supplying timber into a supply chain that ends up with a product entering the EU. At the very least there will be impacts on the level of information that they will have to supply to the buyer of their timber – geo-location data, information on whether it is derived as a result of conversion, and a detailed product breakdown. At the other end there may be market pressure for Forest Managers to adopt the FSC Regulatory Module (although this is a voluntary element.
UKFCG has also been informed about a Confor webinar open to everyone (Confor member or not) intended to give an insight into the forth coming EU Deforestation Regulations.
The regulations track timber from source to final product and will affect the whole of the forestry sector.
Follow this link to the Confor webpage for more information and registration.
Webinar date: Monday 20th May, 1-2pm
[With thanks to Andy Sharkey from FSC UK and Richard Hunter from Confor for providing information and links in respect of EUDR]
Cypermethrin
The latest edition of Confor’s Forestry and Timber News April/May 2024 has, once again, made reference to Cypermethrin being only permitted for use from 1st August. THIS IS INCORRECT.
UKFCG has checked with FSC UK who have confirmed: There is no requirement under the existing FSC pesticide policy for a formal approval of use of Forester by FSC. In essence the position remains that FSC Pesticide Policy allows that:
⦁ Forester (Cypermethrin) has a higher FSC hazard rating than Gazelle (Acetamiprid). As such until Gazelle loses its approval for use and where managers of FSC Certificated forests have access to stocks Gazelle should be used in preference to Forester.
⦁ If managers of FSC Certificated forests have concluded, as part of the Integrated Pest Strategy process that for the control of Pine Weevil they need to use a pesticide and are unable to secure any Gazelle then they can use Forester.
⦁ However, they must, as they will have done for Gazelle, produce an Environmental and Social Risk Assessment (ESRA) that is specific for Forester and specific for the site on which the control is to take place that clearly states the control and mitigation measures needed to protect any identified Environmental or Social (including workers) Risks. If managers of FSC Certified forests haven’t completed an ESRA before or are unsure about the process then they should contact UKFCG for guidance of completion of the Cypermethrin ESRA.
⦁ To help the creation of suitable ESRA’s, FSC UK will be working with members of the Hylobius Industry Research Programme (HIRP) to create a generic ESRA for Forester (Cypermethrin) to support Certificate Holders, but in the meantime Certificate Holders are able to create their own ESRA in support of Forester use should they need to use it.
HSE has made recent updates to its first aid at work publication
The updates include emphasising the employer’s responsibility to take account of employee mental health in their first aid needs assessment. For more information, please visit: First aid needs assessment – First aid at work – HSE.
HSE cannot tell you what provision you should make for first aid. You, as an employer, are best placed to understand the exact nature of your workplace and decide what you need to provide. First aid provision must be adequate and appropriate. This means that you must provide sufficient first aid equipment (first aid kit), facilities and personnel at all times. In order to decide what provision you need to make you should undertake a first-aid needs assessment. The assessment should consider the circumstances of your workplace, workforce and the hazards and risks that may be present. The findings will help you decide what first-aid arrangements you need to put in place.
Deer controllers – First Aid requirements
An up to date first aid qualification is required for all workers involved with deer control activities. Risk assessment for all operational activity should include provision of first aid training and equipment.
On a personal note, during my involvement with low intensity recreational stalking, I have witnessed colleagues with a broken ankle due to a fall from a high seat, and cuts to hands while gralloching. Fortunately, no incidents arising from discharge of firearms.
Clearly a high-risk activity for which first aid training and equipment is required to ensure compliance with UKWAS 5.4.1 and 5.5.1, and to potentially save life.
Some additional reminders
Management plans must display the 20yr period to avoid CARs.
High Seat safety inspections – ensure your lease conditions are complied, annual safety inspections are documented and available for inspection during audits, no access warning signs are placed on high seats.
