Q: Does a BP sourcing only material with an FSC 100% claim with a declaration in the supplier contract to the effect that the supplied material must only come from a specified country still have to source additional records to prove the origin and place of harvesting? The situation is quite clear for uncertified or controlled material where the origin has to be proved anyway due to the FSC/PEFC requirements. However, for FSC/PEFC-certified material the traceability is assured, therefore is a declaration in the supplier contract sufficient?
A: The CB would need to determine if the FSC/PEFC certification was enough or if additional due diligence was required.
Q. SBP Standard 2 section 6.2 “The BP shall record the place of harvesting and the identity of the primary wood processor responsible for the supply of inputs classified as SBP-compliant secondary feedstock”. Would it be sufficient if the biomass producer would know the region/country to prove that the material comes from designated SB?
A. The Standard requires that the BP is able to record the place of harvesting such that it can be confirmed if the place of harvesting is within the Supply Base. The place of harvesting may never be larger than a country but may be any smaller geographic area, including a county, region, or state.
Q: Is material procured under the SFI Fiber Sourcing standard recognised under the SBP rules? If not, is this something that is being revisited given the release of the new SFI Standards, and the FS standard as a stand-alone piece?
A: SFI Fiber Sourcing is not considered to be SBP compliant as regulators in key biomass importing countries do not currently recognise it as demonstrating compliance with their sustainability criteria. Therefore, SBP would only be in a position to review its position if the relevant regulatory authorities revise their interpretations.
Q. Can salvage, sanitation, and fire-prevention cuts be automatically accepted as being "sustainable."?
A. Salvage, sanitation, and fire-prevention cuts are not exempt from the evaluation of sustainability and must comply the SBP requirements for primary feedstock.
Q. How is woody feedstock sourced from plantations established for production of non woody products (e.g. rubber) considered in SBP?
A. Woody feedstock sourced from plantations established for production of non woody products (e.g. rubber) must comply the SBP requirements for primary feedstock.
Q. A BP wishes to producer SBP certified pellets made from lignin. The lignin is a residue from bioethanol production and the trees were harvested 25-30 years ago. How could compliance with SBP sustainability requirements be demonstrated?
A. SBP considers that lignin residue is not woody biomass and therefore not within the scope of SBP certification.
Q. Can Pre-Commercial thinning automatically be considered as being "sustainable"?
A. Pre-commercial and commercial thinnings are not exempt from the evaluation of sustainability and must
comply the SBP requirements for primary feedstock.
Section 9: Clarification of management system, SVP and mitigation measures in risk reduction
Clarification: In evaluating risk against the indicators in Standard 1 the BP is required to evaluate the risks that result from a combination of factors that are related to the woody biomass found in the Supply Base and the management system of the BP. This requires both evaluation of the risks associated with the feedstock and the impact of the BP management system.
In some instances the risk may be low as a result of factors outside the influence of the BP, such as the nature of the forest type or a strong regulatory framework combined with effective enforcement.
Risk may also be altered by action taken by the BP such as sourcing policies, mapping of high risk areas or undertaking supplier audits. It may not always be clear if these interventions are part of the BP management system, Supplier Verification Program or mitigation measures. An example of this would be a BP’s decision not to purchase from particular suppliers that are associated with particular risks. Activities that may be part of the SVP for one BP may be considered part of the management system of another BP, for example, because the BP has been implementing field audits for a long time.
Where the action of the BP reduces the risk (as a result of the management system, SVP or mitigation measure) then the effectiveness of this action needs to be monitored by the BP either as part of operating an effective management system, as part of monitoring the SVP, or as part of monitoring mitigation measures. The justification for low risk, either as a result of external factors or as a result of actions taken by the BP, must be documented.
In evaluating compliance of the BP the CB is required to evaluate the actions of the BP in reducing risk whether as part of the management system, SVP or mitigation measure.
Where a BP’s SBE concludes low risk, a neighbouring BP with an identical Supply Base may not necessarily conclude low risk because of differences between the BPs, for example in their management system.
Erratum: "Where a Supply Base covers more than one country (or regions where different legislative jurisdictions apply) then each must be considered a separate subscope.” should be replaced with "Where a
Supply Base covers more than one country (or regions where different legislative jurisdictions apply) then each may be considered a separate sub-scope."
Section 13: Relationship between the BP and CB consultation processes
Clarification: BPs are required to complete a stakeholder consultation as part of the SBE with the intention that stakeholders have an opportunity to help identify risks in the Supply Base. The consultation may be combined with the LAV consultation process. The requirement that “Stakeholders shall be provided with adequate information as a basis for informed comment” includes the requirement to provide a copy of or access to (for example, via a web-link) SBP Standard 1. Findings from the stakeholder consultation are used to inform the SBE.
The CB stakeholder consultation process should take place once the BP stakeholder consultation is complete and it should be completed by the time of the CB onsite audit. In that way the process informs the CB audit, including evaluation of whether stakeholders’ comments were adequately addressed by the BP. Additional stakeholder engagement during or after the audit may be appropriate to follow up on issues identified.
Instruction Note 2A, Section 1.5
Q: Section 1.5 states: “Suppliers selected by the BP for monitoring purposes should be different to those who have been selected for evaluation by the CB, except in situations where actions to address complaints or evaluate risk factors require verification.” How does the CB select the sample of suppliers to be evaluated, since this is not covered in Standard 3? What qualifications are needed for auditors conducting on-site monitoring of suppliers who are forest owners?
A: CBs need to justify the sampling techniques and the competence requirements of personnel. It is expected that both these would be based on processes included in the CBs’ sampling procedures for accredited SBP-approved Forest Management Schemes and that auditors can demonstrate relevant forest auditing competencies.
CBs are required to audit the BP management system and mitigation measures. Where the BP management system or mitigation measures extend to activities such as monitoring forest operations then CBs are required to audit these aspects of the BPs operation to evaluate compliance.
Instruction Note 2A, Section 8.4
Q: Can feedstock sourced from within a SB where a SBE is completed and found to be compliant with SBP requirements (including low-risk against all indicators in SBP Standard 1. Feedstock Compliance Standard) be classified as SBP-compliant feedstock if the feedstock is harvested on property owned or managed by the BP?
Instruction Note 2C
Q: Regarding the Supply Base Report Template for Biomass Producers and Supply Base Report Template for Biomass Producers Annex 1, does the Annex 1 document need to be made publicly available as well the report? If, so why are they separate documents?
A: Annex 1 needs to be made publicly available where a Supply Base Evaluation is completed. A Supply Base Report needs to be completed by all Biomass Producers.