FOREST MANAGEMENT SURVEILLANCE REPORT

Doc. Number: AD 37-01

Version date: 1 February 2005

SGS QUALIFOR

(Associated Documents) Page: 1 of 25

SGS QUALIFOR, Unit 5 Mifa Park, 399 George Rd, Randjespark, Midrand, South Africa CONTACT PERSON: Michal Brink, Tel: +27 (0)11 652 1441, Fax: +27 (0)11 652 1403

WWW.QUALIFOR.SGS.COM

FOREST MANAGEMENT SURVEILLANCE REPORT

SSEECCTTIIOONN AA:: PPUUBBLLIICC SSUUMMMMAARRYY

Project Nr.: 8400-NA

Client: Savannah Charcoal SLIMF

WebPage: NA

Address: P.O. Box 93, Outjo

Country: Namibia

Certificate Nr. SGS-FM/CoC-1841 Certificate Type: Group Forest Management SLIMF

Date of Issue 20 September 2004 Date of expiry: 19 September 2009

Scope: Forest Management of the Savannah Charcoal SLIMF group of farms in the Kunene region of Namibia for the production and sale of charcoal and other fuel wood products from selected indigenous tree species.

Company Contact Person:

Magda Prinsloo (Admin Manager)

Address: PO Box 93; Outjo; Namibia.

Tel: 00264 67313980

Fax 00264 67313973

Email: [email protected]

Evaluation dates:

Surveillance 1 7-8 June 2005

Surveillance 2 20-21 February 2007

Surveillance 3 2-4 April 2008

AD 37-01 Page 2 of 25

TTAABBLLEE OOFF CCOONNTTEENNTTSS

1. SAMPLING AND EVALUATION APPROACH......................................................................... 3

2. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING........... 3

3. STANDARD USED IN THE EVALUATIONS ........................................................................... 3

4. RECORD OF CORRECTIVE ACTION REQUESTS (CARS) .................................................. 4

5. RECORD OF Observations................................................................................................... 17

6. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS ........................................ 21

7. RECORD OF COMPLAINTS................................................................................................. 23

8. MAINTENANCE OF CERTIFICATION.................................................................................. 24

AD 37-01 Page 3 of 25

1. SAMPLING AND EVALUATION APPROACH

A detailed record of the following is available in section B of the Evaluation report. This section does not form part of the public summary, but includes information on:

� Sampling methodology and rationale;

� FMUs included in the sample;

� Sites visited during the field Evaluation; and

� Man-day allocation.

At the main assessment of 2004, there were four group members, of which two were visited (Tzobaas and Harris). At the first surveillance visit, the other two members (Annenhof and Saalburg) were visited as well as a new member (Breedskroon) who joined after the main assessment. All assessments will involve a visit to the Factory in Outjo, since this is the main office of the group, and the factory needs to be assessed in terms of the group chain of custody. At the 2nd surveillance only two members were still part of the group, Tzobaas and Breedtskroon. Both were visited. The factory has closed down since the 1

st surveillance. At the 3

rd surveillance the

Group has increase to 10 members. One of the old members and 3 of the new members were visited.

2. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING

The following table shows significant changes that took place in the management, monitoring, harvesting and regeneration practices of the certificate holder over the certificate period.

Description of Change Notes

SURVEILLANCE 1 (2005)

One new member joined the group in November 2004, namely Mr Willem Enslin of Breedskroon farm. This member is only harvesting Acacia mellifera.

Breedskroon farm is 5 325 ha. In order to qualify for SLIMF, the annual charcoal production must be less than 1 000 m

3 per annum (or 5 000 m

3

raw material), and the harvesting must be less than 20% of the MAI per annum. Breedskroon qualifies on both accounts, using a 1:4 conversion factor of raw material to charcoal and using a conservative MAI of 1m

3/ha/year.


The group experienced a major collapse in their export market in the UK and practically ceased operations between September 2005 and December 2006. The factory in Outjo also closed down. Membership shrunk to two members only. Due to non-payment of fees, certification was also suspended, but this was re-

instated on 29 January 2007. Markets have recently been found again and the group is positive about future growth. Negotiations have also commenced about the possible re-opening of the factory.


The Group has increased to 10 members who all produce their charcoal on their farms and dispatch the product directly to the Group’s client in South Africa. Group management has been put under considerable strain to produce management plans and provide training to the new members, but has made significant progress in this regard.

3. STANDARD USED IN THE EVALUATIONS

AD 37-01 Page 4 of 25

A checklist was prepared that consisted of the document listed below. This checklist was prepared by adapting the QUALIFOR generic forest management checklist.

This adaptation included canvassing comments from stakeholders. A copy of this checklist is available on the SGS Qualifor website, www.sgs.com/forestry.

Standard Used in Evaluation Effective Date Version Nr Changes to Standard

SGS Qualifor: Generic Forest Management Standard (AD33) adapted for Namibia

1 July 2005 AD33-NA-01

New Standard used for the Surveillance 01 assessment.

SGS Qualifor: Group Management Checklist (AD34)

1 February 2005

Surveillance 01: No changes

SGS Qualifor: Generic Forest Management Standard (AD33) adapted for Namibia

1 July 2005 AD33-NA-01

Surveillance 02: No change to the standard.

SGS Qualifor: Group Management Checklist (AD34)

1 February 2005

Surveillance 03: No change to the standard.

4. RECORD OF CORRECTIVE ACTION REQUESTS (CARS)

CAR # Indicator CAR DETAIL

Date Recorded>

2004 / 07 / 23 Due Date> 1

st

Surveillance Date Closed> 8 June 2005

Non-Conformance:

The system to be aware of and implement requirements of new and existing legislation, Codes of Practice or guidelines is incomplete.

Objective Evidence:

Important pieces of legislation and regulations are not available. These include: Social Security Act of 2001; Workman’s Compensation Act of 1995; Health & Safety Regulations 1998; GN 77/2003 (Collective agreement on minimum wages in the agricultural sector). Environmental Impact Assessment Policy.

Close-out evidence:

01 1.1.1

All of the pertinent Acts are kept filed in M. Prinsloo’s Office, and members have been informed of the Acts and where they are. Forms such as Social Security are provided to the members. In addition, Savannah Charcoal has applied to the Namibian Government Offices as a subscriber to all relevant amendments to Forestry, Labour and other Acts. The Management Plan lists the Acts that are available at the Office. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

The owner / manager and workers do not fully understand and comply with the policy and the spirit of the FSC P&C.

Objective Evidence:

While the owner / manager fully understand the FSC P&C, none of the workers in either the factory of the FMU’s does.

02 1.6.3

Close-out evidence:

AD 37-01 Page 5 of 25


All members have been provided with a chart of the FSC Objectives, on a one page information sheet to be used for training. This was available at Annenhof, where all 65 workers have been through this training. Workers have had training in Aids, FSC and Environmental Protection. Various workers on the member’s farms and at the factory were interviewed, and they all demonstrated good awareness of FSC and what it was about. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Workers are engaged in debt bondage or other forms of forced labour.

Objective Evidence:

In the factory workers occasionally obtain advance payments / credit which is subtracted from their monthly wages. At Tzobaas and Harris farms, charcoal burners obtain goods from the farm-store owned by the employer on credit. The debt incurred through these purchases is deducted from payments for charcoal produced and delivered.

Close-out evidence:

03 4.1.7

Tuck shops have been provided on most of the member’s farms with essential commodities. Credit has been set at 30% of salary payment. An interview with some of the workers on Annenhof farm, revealed that goods purchased were on a voluntary basis, and cash or credit was allowed and that this system suited them. Payment slips with money owing and money subtracted confirmed under 30%. On Saalburg farm, a tuck shop was available for workers with basic provisions, but incentive to pay cash for goods was that the cash price was cheaper. On Annenhof, Saalburg and Breedskroon farms, there was no evidence of debt bondage or other forms of forced labour. At the factory, the advance payments and credit system were a service rather than a vice. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Employees and contractors and their families do not have access to adequate local medical facilities, shelter and accommodation while working on the FMU.

Workers have not had relevant training in safe working practice and First Aid, and do not hold appropriate skills certificates.

Objective Evidence:

No First Aid kits are available either in the factory or on the FMU. Wood cutters / burners on the FMU are working far away from medical facilities.

No training of workers in the factory and on FMU’s safe working practice & First Aid has taken place and no one holds appropriate skills certificates.

Close-out evidence:

04 4.2.2; 4.2.5

First aid kits are available at the harvesting site on Annenhof, and the farm owner, K. Boldt, is a trained first aider. On Breedskroon farm, there are two certificated trained first aiders on site, and a first aid kit is kept at the farmhouse. At the Factory, medical evaluations are carried out prior to employment (seen on a contract signed by the Clinic Sister), and the workers have a medical check-up every six months. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Not all necessary tools, machines, substances and equipment, including appropriate personal protective equipment (PPE) are available on the worksite and are in safe and serviceable condition.

05 4.2.6

Objective Evidence:

AD 37-01 Page 6 of 25


Not all workers are in possession and / or using of appropriate PPE. More specifically not all workers had been issued with safety boots, gloves, overalls and protective head gear.

Close-out evidence:

On Saalburg Farm, the cutters are issued with overalls, boots and leather gloves. On Breedskroon farm, the contractor’s gloves and overalls are subsidized to over one third of the cost, and there are issuing records that are signed by the workers. The sieve (screening) workers are provided with helmets and dust masks and goggles. Savannah Charcoal Group Certification Scheme Manual also states the “Personal Protective Equipment Standards” that are required for the different jobs. It is noted that the issue of PVC gloves should perhaps more appropriately be leather gloves for the cutters. This CAR is closed, but an observation 01 was raised for Annenhof Farm, due to lack of gloves for the workers.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

No Health and Safety records (including risk evaluations, accident records) are maintained and kept up to date.

Objective Evidence:

Medical examinations are neither carried out before employing workers / contractors nor are regular check-ups done. No accident record system is in place.

Close-out evidence:

06 4.2.7

H&S records are kept on the farm Breedskroon, and common injuries are gashes from falling wood at the cutting site and from burns at the kiln sites. This has been dealt with through better training and provision of PPE (gloves and boots). The Savannah manual has accident forms which are to be completed, and medical evaluations are carried out prior to employment (seen on a contract signed by the Clinic Sister. At the Factory, the workers have a medical check up every six months. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Not all Group Scheme members have been registered and contributing the legally required payments in terms of the prescribed fees, royalties and taxes.

Objective Evidence:

At Harris farm, the owner (and member of the Group Scheme) has not been registered for any of the legally prescribed fees and taxes (Income Tax; Social Security, etc.).

At Savannah Charcoal factory not all of the workers were registered for Social Security.

Close-out evidence:

07 1.1.3; 1.2.1

This issue was specifically checked on Annenhof farm, where it was found that Social Security and Tax were paid (Tax # 264321-01-5). Proof of payment for permits (harvesting and transport) was also available on file. Breedskroon farm was also registered for Social Security and had contracts with all workers. On Saalburg farm, contracts were available for both temporary and permanent workers, and all workers and contractors were registered with Social Security. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st

Surveillance Date Closed> 2007/02/21

Non-Conformance:

Guidelines / Plans for harvesting are not being implemented, overall objectives are not achieved and the ecological integrity of the (forest) woodland is not maintained with current harvesting practices.

08 7.1.13

Objective Evidence:

AD 37-01 Page 7 of 25


The Group Scheme guidelines of harvesting states that 10% of large trees (>15 cm dbh) will be harvested and 90% of the smaller invasive shrubs (bush encroachment). At Harris farm, the opposite was noted with 90 – 100% of large Mopane trees harvested with 0% of invasive shrubs. At the same farm (Harris) Kanniedood trees (Commiphora) trees were felled / damaged, this is not allowed according to the permit for Harris. The Tzobaas farm charcoal harvesting also exceeded the 10% statement. Supervision / monitoring were inadequate at both sites.

2005 progress: New harvesting guidelines have been drawn up for Saalburg farm by Stephan Albat, the District Forestry Officer. These guidelines are based on actual surveys of the vegetation composition in terms of species, stems per hectare, and the diameter classes for the species. Harvesting intensity is then determined by the stems per ha in the different diameter classes per species. Instead of specifying the percentage of trees that may be harvested, these guidelines specify the number of stems per ha that should remain per diameter class AFTER harvesting. This targets the smaller diameter species, and enables better long term planning. Similar plans are necessary for the other member’s farms. This CAR is to remain open for further monitoring.

Close-out evidence:

A document titled Regulations and Procedures for Otjiwarongo District by the Forestry Department has been compiled and now formally accepted for the application throughout Namibia. This document spells out all aspects of forest management particularly with reference to charcoal production. Furthermore have general harvesting guidelines for the group dated July 2005 been compiled covering aspects such as pre-harvest plans, harvest operations, post harvest audit and burning documentation. An example of a pre-harvest plan was seen as well as the post harvest form. The latter has not yet been completed due to the cessation in activities during 2005/06. In-field on both Breedtskroon and Tzobaas it was clear that emphasis is now placed on the removal of smaller trees and the correct spp only. This has largely been achieved through training provided by the farm owners personally to the cutters. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st

Surveillance Date Closed> 8 Jun 2005

Non-Conformance:

Sustainable harvest and thinning intensities have not been calculated for the FMU’s.

Objective Evidence:

There is no pre-determined harvesting or thinning intensity or frequency calculated or based on the most up to date available information on any of the FMU’s.

Close-out evidence:

09 5.6.3

Closed and replaced with Major CAR 15.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

All activities that require monitoring have not been identified or documented in a monitoring programme nor has the frequency or intensity been defined.

Objective Evidence:

Monitoring of contractors, Health & Safety, RTE species, Second Party Assessments, harvesting / post-harvesting, yields of harvested areas, potability of water, etc. has not all been identified nor has the frequency or intensity of monitoring been allocated.

Close-out evidence:

10 8.1.1; 8.1.2


Date Recorded>

2004 / 07 / 23 Due Date> 1

st

Surveillance Date Closed> 8 Jun 2005 11 7.1.13

Non-Conformance:

AD 37-01 Page 8 of 25


Long, medium and short term planning for harvesting operations are inadequate or non-existent.

Objective Evidence:

Planning at the Group farms does not include Short term (Annual); Medium term (Tactical 3-5 year) or Long term (Strategic / Rotational) harvesting plans.

Close-out evidence:


Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Workers and operators/drivers are not aware of hydrocarbon spill procedures; plastics are burnt at all refuse sites.

Objective Evidence:

At Savannah’s charcoal factory, Tzobaas and Harris farms, drivers and relevant workers are not familiar with emergency or management procedures for oil contamination of soil or groundwater. At Tzobaas and Harris plastic refuse is burnt at refuse sites.

Close-out evidence:

12 6.5.4; 6.7.2

The Savannah Group scheme has developed “Agro-chemical and Hydrocarbon Guidelines” which specifies storage, spill prevention measures (e.g. bunding, oil traps) and spillage clean up measures. There was no evidence of any oil spills on Annenhof or Saalburg, and there was no burning of plastics on either of the farms where this was specifically checked. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

Representative area of all existing ecosystems have not been identified with Conservation Organisations and acknowledged experts, nor have these areas been demarcated on maps or the ground.

Objective Evidence:

At none of the four farms comprising the Group Scheme has representative samples of existing ecosystems been identified within the landscape to be protected in their natural state.

Close-out evidence:

13 6.4.1

On Annenhof, the key vegetation types have been identified and the Omarambu Woodland (Riverine) has been identified as a no harvest area. On Breedskroon, a Camelthorn Conservation area of 1400 ha has been set aside as a specific conservation zone, and the farm has been zoned into different vegetation types (e.g. Mixed Acacia Terminalia Combretum woodlands). Maps are available for the farms and the local Forestry department (Stephan Albat) also provided assistance to the members. This CAR is closed.

Date Recorded>

2004 / 07 / 23 Due Date> 1

st


Non-Conformance:

At none of the FMU’s have forests been assessed in terms of high conservation values nor has biological, socio-economic or cultural attributes been identified.

Objective Evidence:

HCVF’s (High Conservation Value Forests) has not been assessed at any of the four Group Scheme farms; this should be done in consultation wit Conservation Organisations, Regulatory Authorities and other local or national stakeholders.

14 9.1.1

Close-out evidence:

AD 37-01 Page 9 of 25


A letter is available (dated 12 August 2004) from the District Forest Officer, Stephan Albat, stating that the farms Tzobaas #218, Saalburg #157, Breedskroon #242, Annenhof #158 and Harris #340 do not contain any protected forest areas within their boundaries. Stephan Albat was also interviewed during the assessment and confirmed that there were no HCVF on any of the Members farms in terms of the FSC definitions of HCVF as documented in Principle 9. This CAR is closed.

Date Recorded>

8 June 2005 Due Date> 20 July 2005 Date Closed> 18 July 2005

Non-Conformance:

Long-term sustainable thinning intensities have not been calculated. (Upgraded from Minor CARs 9 and 11).

Objective Evidence:

No such long-term data or planning is available.

No determination of densities of harvestable species prior to harvest for Annenhof and Breedskroon.

Close-out evidence:

M15 5.6.2

Piet Krone, has been employed by Savannah Charcoal to provide technical assistance to group members. He has undertaken to do a "Harvesting Guidelines" survey for the balance of Savannah members with Stephan Albat. The existing Saalburg plan is an excellent model for the rest of the farms. This plan determines current densities of all species in specified diameter classes (0-5cm, 6-10; 11-15; 16-20 and 20<), then provides thinning intensities per compartment, based on the surveys. This still needs to be extrapolated to the long term. Stephan Albat has committed to complete the remaining farms (Tzobaas, Harris, Annenhof and Breedskroon) farms by December 2005.

This CAR is closed on the basis of this Action plan that was provided on 18 July 2005, and is replaced with Minor CAR 20 in order to monitor the implementation of this action plan at the next surveillance visit.

Date Recorded>


Non-Conformance:

Not all activities that require monitoring have been identified and certain crucial monitoring activities are not taking place. (Upgraded from Minor CAR 10).

Objective Evidence:

1. No establishment of trial plots to monitor regeneration (post harvest)

2. Control plots need to be established in representative production areas.

3. Conversion ratios of raw material to charcoal need to be established and monitored for different species. Variables such as stem diameter and method of carbonisation also need to be factored in.

M16 8.1.1; 8.1.2

Close-out evidence:

AD 37-01 Page 10 of 25


An action plan received on 18 July 2005, detailed the following corrective actions:

1. One representative trial plot per camp harvested will be established. This trial plot will be clearly demarcated and harvest date recorded. The trees remaining will be identified counted and diameters recorded. Once a year the re-growth will be monitored (species, number height etc.). Once the trees are large enough the diameters will be measured too. Piet Krone is to assist each member in establishing such plots by December 2005.

2. One representative control plot of one hectare will be identified and clearly marked out per vegetation type for each farm. The tree species stem count and average diameters will be recorded and dated per control block. These plots will be monitored on an annual basis and the data recorded. The vegetation types have already been identified by Piet Krone for each member farm. The management plan will be amended accordingly. The deadline is December 2005.

3. Stephan Albat, the District Forest Officer stated that he works on a conversion ratio of 1:4. It is planned to set up trials per species per month in order to give seasonal conversion fluctuations. Savannah Charcoal has provided a “Charcoal Conversion Summary”, which is a data sheet to capture the date, kiln number, input mass, charcoal mass, and species. Ratios will be calculated and monthly summaries generated. This will continue until reliable average norms have been set per species. This project is to be initiated immediately. It was recommended by the auditor that stem diameter of species input also be recorded in set diameter classes, and factored into the survey.

This CAR is closed on the basis of this Action plan that was provided, and is replaced with Minor CAR 21 in order to monitor the implementation of this action plan at the next surveillance visit.

Date Recorded>

8 June 2005 Due Date> June 2006 Date Closed> 2007/02/21

Non-Conformance:

Not all sites of cultural, historical or religious significance have been identified, described and mapped in co-operation with affected or interested stakeholders.

Objective Evidence:

Graves on Saalburg have not been mapped, and there are no management prescriptions for these graves.

Close-out evidence:

17 3.3.1

Saalburg is not a member of the group any more. Government offices in Windhoek were also visited to determine whether there were records of sites of significance on the farms – no evidence of any such sites could be found. A letter was also sent to all members pointing out the need to identify and protect any such sites. This CAR is closed.

Date Recorded>


Non-Conformance:

Not all members meet SLIMF criteria.

Objective Evidence:

The farm Annenhof does not meet the SLIMF criteria as follows:

1. At present the harvesting level of less than 20% of the MAI is difficult to assess, since there is a lack of data on MAI for the commercial tree species Namibia. The MAI for Mopane has been reported Botswana as 1 ton/ha/year, and for Zimbabwe as 1.2 and 1.5 tons/ha/year by different researchers. At conservative estimate of 1 ton/ha/year or 1m3/ha/year, Annenhof is harvesting

in excess of 20% of the MAI.

2. The criteria of harvesting less than 5000m3 per year (raw material) cannot be accurately

determined due to inaccurate conversion ratios. At a conversion of 1:4 (raw material to charcoal), Annenhof is harvesting 5760 tons per year. At a more realistic conversion of 1:5, Annenhof is harvesting 7200 tons per annum. Either way, this is in excess of the 5000 m

3 cut-off for SLIMF.

M18 AD 34 (Group)

Close-out evidence:

AD 37-01 Page 11 of 25


1. Augmented by studies from the Cheetah Conservation Fund harvesting, who have also reported and MAI of 1 ton/ha/year or 1m3/ha/year, this figure was used to calculate that given the 5 000 ha Annenhof farm, the MAI of the farm is 5 000 m

3/ha/year, of which 20% would constitute

1000 m3/ha/year, that could be harvested. Currently Annenhof is producing an average of 50.56

tons per month, which will be about 606.7 tons per year. If one adds 28% “fines” on to this (which are not supplied to Savannah), this constitutes 776.6 tons per year. By converting this back to raw material (x4 for a 1:4 conversion ratio), gives 3106 tons harvested per year, which clearly exceeds the 20%. This information was forwarded to the Qualifor Programme Manager, who took the decision to disregard the 20% criteria based on the fact that the bush clearing programme was beneficial (please see Main Assessment report) in terms of the bush encroachment in Namibia.

2. The charcoal supply from Annenhof is described above as about 3106 tons per year. This is below the SLIMF cut off criteria of harvesting less than 5000m

3 per year (raw material).

Conversion figures are currently being determined by Savannah Charcoal (see major CAR 16 and Minor CAR 21), but in the interim, a conversion factor of 1:4 will be used, based on the recommended conversion that was quoted by the District Forest Officer, Stephan Albat.

Given the leeway on the 20% MAI cut-off, then Annenhof qualify for SLIMF due to the fact that they harvest less than 5 000 m

3 per year (raw material). This CAR is closed, but is replaced by Minor CAR

22, in order to continue monitoring of members, especially Annenhof, when a full 12 month period of harvesting data is available.

Date Recorded>

8 June 2005 Due Date> June 2006 Date Closed> 2007/02/21

Non-Conformance:

Not all COC requirements are being met.

Objective Evidence:

1. Certificate numbers are not being included on the invoices and delivery notes of the members.

2. Harvesting permits are not retained for a period of 5 years after expiry (e.g. Annenhof)

3. There is no copy of the logo approval on the Direct Charcoal bags (certificate number SGS-CoC-1679)

Close-out evidence:

19 8.3.3

1. Certificate numbers are shown on sales invoices and delivery notes e.g. a tax invoice dated 2007/01/19 from Enslin Charcoal (Breedtskroon) to Direct Charcoal for 30 tonnes of screened bulk charcoal contained the correct certificate number SGS-FM/COC-1841.

2. Letters were send to all farmers reminding them that all permits must be retained for a period of 5 years. All permits issued since production started in September 2004 were available and seen e.g. harvesting permit WHKottH10790/05 dated 2005/01/17.

3. All charcoal is now being dispatched in 50 kg polyprop unmarked bags.

This CAR is closed.

Date Recorded>

30 July 2005 Due Date> June 2006 Date Closed> 2008/04/04

Non-Conformance:

Bush surveys have not been done and long-term sustainable thinning intensities have not been calculated. (See Major CAR 15).

20 5.6.2

8.2.2.1

Objective Evidence:

AD 37-01 Page 12 of 25


SA2005: No such long-term data or planning is available. No determination of densities of harvestable species prior to harvest for Tzobaas, Harris, Annenhof and Breedskroon.

SA2007: The District Forest officer, Stephan Albat, undertook to do such planning for each farm. Unfortunately he resigned from the Forestry Department and this work could therefore not yet be done. The total collapse of the markets of the group in 2005/06 also made it impossible to finance any significant expenditures such as e.g. forestry consultants. The group effectively only commenced with activities during January 2007. Due to these unforeseen circumstances this CAR will remain open for monitoring. Should this subject not have received sufficient attention at the time of the 2008 surveillance, a Major CAR must be opened. As it will then be the 2

nd time that a Major CAR is

raised on this subject, the certificate may then be suspended and a Re-Assessment may become necessary.

Close-out evidence:

A consultant has been appointed who prepared management plans for each of the 10 members. These plans addresses subjects such as management objectives, conservation areas, general vegetation description, general harvesting plan, detailed vegetation description and harvesting guidelines, monitoring and a list of tree spp identified on each farm. Specific guidelines are prescribed for each of the target spp in terms of how many may be removed in various stem diameter classes – e.g. harvesting according to these guidelines on Goroab-ost would reduce stem densities of these target species from 4 823 stems/ha to 3 863 stems/ha. The prescriptions for each farm are well motivated. CAR 20 is closed.

Date Recorded>


Non-Conformance:

Not all activities that require monitoring have been identified and certain crucial monitoring activities are not taking place. (See Major CAR 16).

Objective Evidence:

SA2005:

1. No establishment of trial plots to monitor regeneration (post harvest)

2. Control plots need to be established in representative production areas.

3. Conversion ratios of raw material to charcoal need to be established and monitored for different species. Variables such as stem diameter and method of carbonisation also need to be factored in.

SA2007: Each farmer received instructions to establish control and trial plots. Examples of data sheets for each type of plot were seen. However, the establishment has not yet taken place due to the total collapse of their market in 2005/06.

Charcoal conversion records are being kept and summaries of the results were seen for both Breedtskroon and Tzobaas. Conversion from wood to charcoal on Tzobaas ranged from 2,6:1 for dry mixed wood to 3,9:1 for large wet mopane. On Breedtskroon it ranged from 3.0:1 to 5,2:1 for mainly Acacia material.

This CAR remains open to monitor the establishment of trial and control plots.

Close-out evidence:

21 8.1.1; 8.1.2

The management plans provide for the establishment of monitoring plots on all farms and the location of such intended sites has been determined. However, no actual monitoring of any plots has yet been undertaken. This non conformance was first raised in 2005 and kept open for monitoring in 2007. As little, if any, real progress has been made over three years to institute a full monitoring programme this Minor CAR 21 is closed and Major CAR M29 is raised.

Date Recorded>


Non-Conformance:

22 AD 34 (Group)

Not all members meet SLIMF criteria.

AD 37-01 Page 13 of 25


Objective Evidence:

The farm Annenhof does not meet the SLIMF criteria. Please see Major CAR 18

Close-out evidence:

Annenhof is not a member of the group any more. Breedtskroon produced 61 tonnes during the period 2005/01/01 to 2005/12/31 and Tzobaas produced 0 tonnes during this period – both clearly complying with the SLIMF requirement of producing less than 5 000 m3 / year. This CAR is closed.

Date Recorded>

2007/02/21 Due Date> 2009/04/03 Date Closed> yy/mm/dd

Non-Conformance:

A coherent outline is not provided on how management objectives will be achieved.

Objective Evidence:

SA2007: The restoration of natural savannah grasslands implies control over bush regrowth after the initial harvesting operation, and where charcoal production is seen as the primary objective, some form of coppice management is required after the initial harvest. Both strategies must be based on the sustainable utilization of the woodland resource. Trees are currently allowed to coppice with no policy/actions on e.g. chemical control or a fire regime in combination with a browser programme or steps to prevent/limit/manage copping after harvesting using e.g. chemical or manual methods. Management objectives will not be achieved based on the current policy and procedures.

SA2008: Although management objectives are now addressed for some farms in the new management plans, they are still not clearly articulated for some other farms, particularly in terms of what strategy will be followed to achieve such objectives. The achievement of sustainability in this process also needs to be clearly explained as well as the scheduling of operational activities indicated. The CAR 23 remains open for monitoring.

Close-out evidence:

23 7.1.2

7.1.13

6.3.3

Date Recorded>

2007/02/21 Due Date> 2008/02/20 Date Closed> 2008/04/04

Non-Conformance:

The storage procedures of chemical pesticides do not comply with the minimum requirements of the ILO.

Objective Evidence:

Two containers of 10 litres Molopo (Tebuthiuron) were stored in a room where foodstuffs were kept as well, such as cooking oil.

Close-out evidence:

24 6.6.5

Molopo was used in the past on Nora to control coppice regrowth, but is not currently in use or in storage. No chemicals are currently in use on any FMU in the Group within the scope of the certificate. Most members are also cattle farmers and use chemicals in that part of their business, but not in forest operations. The CAR is closed.

Date Recorded>


Non-Conformance:

Worker accommodation and nutrition does not in all aspects comply with minimum standards.

25 4.2.9

8.1.2.2

8.2.10

Objective Evidence:

AD 37-01 Page 14 of 25


SA2007:

1. Despite being raised as Observation 2 no steps have been taken to either re-test the suitability of drinking water for human consumption on both Tzobaas and Breedtskroon, and/or to take remedial steps to improve the quality of the water. Insufficient attention is given to the availability of potable water and the quality of drinking water is inadequately monitored.

2. A waste pit in the worker village on Breedtskroon was unfenced and presented a safety risk to children and anyone walking in the dark.

SA2008:

1. Water tests were conducted for all farms and, with one exception, were found to be suitable for human use. The exception related to the farm Nuitsas-Sud where the nitrate level was too high, which can cause methaemoglobinaemia in babies under one year old. Handling of the exception must be monitored during future surveillances.

2. The waste pit at Breedtskroon has been filled in and replaced with a system of collection bins/bags which are periodically removed for emptying at the municipal waste site at Otjiwarongo.

3. However, instances were found where no toilet facilities are provided for workers at their accommodation such as on Nuitsas-Sud, and in the case where workers are unwilling to use the facilities provided such as on Gorooab-Ost and Nora, no procedures are available to ensure that human waste is disposed of in a hygienic manner. The CAR remains open for monitoring of this aspect.

Close-out evidence:

Date Recorded>


Non-Conformance:

All appropriate PPE are not available at the worksite.

Objective Evidence:

In terms of the ILO standards, it is specified that workers should be protected from excessive UV radiation. Workers on Breedtskroon have not been provided with hats to protect them from radiation in an environment where solar radiation can be very harsh.

Close-out evidence:

26 4.2.5

Workers are provided with an overall, gumboots and a face mask and/or hand gloves. Interviews with workers confirmed that it is not part of their culture to wear hats and that they do not want hats. The Government Department of Labour also indicated its acceptance of the current PPE issue. The CAR is closed out.

Date Recorded>


Non-Conformance:

Wood waste during harvesting is not minimised.

Objective Evidence:

Group Management indicated that the policy is to utilise all material down to 2 cm diameter for charcoal production. However, it was found on a number of felling sites on Breedtskroon that branches considerably larger than 2 cm diameter are being left in-field after harvesting.

Close-out evidence:

27 5.3.1

All farms were visited by both Group management and a consultant where, amongst others, farmers and workers were again instructed to ensure that minimum utilizable levels are adhered to. Inspection of the 4 farms visited during this assessment also indicated that full utilization of felled material is taking place.

AD 37-01 Page 15 of 25


Date Recorded>


Non-Conformance:

The chain of custody process failed to prevent uncertified material from being sold as certified.

Objective Evidence:

Certificate numbers are shown on sales invoices and delivery notes e.g. a tax invoice dated 2007/01/19 from Enslin Charcoal (Breedtskroon) to Direct Charcoal for 30 tonnes of screened bulk charcoal contained the certificate number SGS-FM/COC-1841. The certificate was suspended at this time. This constitutes a major non-conformance. The group has to inform Direct Charcoal that the product sold as certified was in fact not certified. SGS must be presented with evidence of this to close out the Major.

Close-out evidence:

M28 8.3

An e-mail dated 14 June 2007 was sent by the group to Direct Charcoal pointing out that the load in question was uncertified; that they had to adjust their records accordingly; and that they must supply proof that this was done. A replacement invoice was issued, Tax Invoice No 17 dated 17 January 2007, clearly indicating that the 29,5 tonnes screened lumpwood (bulk charcoal) was uncertified.

A letter dated 28 June 2007 from Direct Charcoal SA to their client Direct Charoal Ltd was seen in which it was stated that an error was made relating to containers marked as FSC product that were in fact non-FSC. It was pointed out that container no’s GLDU0695444 and MSCU7900696 shipped on the MSC Colombia V01R are in fact Non–Certified Product.

Major CAR M28 is closed. A new Minor CAR is not raised for monitoring as this aspect receives attention during each assessment.

Date Recorded>


Non-Conformance:

Monitoring procedures that are consistent and replicable over time to allow comparison of results and assessmnent of change have not been implemented

Objective Evidence:

See Minor CAR 21.

M29 8.1

7.1.5

Close-out evidence:

AD 37-01 Page 16 of 25


The following action plan was compiled to close-out the major CAR: Two monitoring plots of one ha each have been set out with GPS on each farm and indicated on the respective management plans. These plots will be clearly demarcated with fencing poles on the perimeter corners of each plot. The two plots on each farm were established prior to the starting of thinning operations on that particular part of the farm. The following data will be collected in each plot:

Plot 1 (no harvesting will occur):

1. Species composition.

2. Stems per hectare.

3. Diameter classes.

4. Annual growth.

Plot 2 (will be harvested to pre-determined densities):

1. Species composition.

2. Stems per hectare.

3. Diameter classes.

4. Weight of biomass removed.

5. Weight of charcoal produced.

6. Annual re-growth for charcoal sustainability.

This data will be gathered on an annual basis and recorded on the Control Plot Data Sheet. Phasing of the data capture will be as follows:

1. W. Enslin and H. Otto – July 2008.

2. S. Kühn and H. Haraseb – December 2008.

3. M. Diederiks and J. Hijaranguru – May 2009.

4. A. Maritz and N. Badenhorst – October 2009.

5. J. Jansen and F. Holtzkampf – March 2010.

This action plan is considered sufficient to adequately address the non-conformance and Group management has until 2008/07/03 to provide evidence that the action plan was implemented before the Major CAR can be closed.

Date Recorded>


Non-Conformance:

Rare, Threatened and Endangered spp have not been identified or their habitats mapped and protected.

Objective Evidence:

The current information base on RTE spp is limited and little attempt has been made to investigate the occurrence of such spp and to formulate practical conservation measures as appropriate. Group members and their employees should receive proper communication/ education about such spp and their conservation.

Close-out evidence:

30 6.2.1

7.1.7

Date Recorded>

2008/04/04 Due Date> 2009/04/03 Date Closed> yy/mm/dd 31 7.3.1

Non-Conformance:

AD 37-01 Page 17 of 25


Forest workers at all levels of skills and responsibility are not always appropriately trained in the tasks they are asigned to.

Objective Evidence:

Interviews with two workers on two different farms indicated that cutters were not properly trained to e.g. identify trees that may not be felled (with e.g. Commiphora spp incorrectly felled) or to leave a few large trees of the target spp unfelled. A more coherent approach to identify training needs and to formulate and implement a training programme is required.

Close-out evidence:

Date Recorded>


Non-Conformance:

A formal EIA proces has not been followed for all activities listed in terms of Section 23 (1) of the Forest Act No12 of 2001.

Objective Evidence:

Some group members convert parts of their farms to open grasslands e.g. on the farm Gorooab-Ost an open grassland of some 30 ha was established and on the farm Deutsch-Erde it is planned to create two grassland areas of 80 and 70 ha respectively. These must be seen in the context of the massive bush encroachment problem in northern Namibia and the large size of individual farms with the smallest farm in the Group being 2 000 ha. Such clearings can not be seen as forest/bush conversion but is actually enhancing biodiversity and creating a more diverse landscape. There is no question that it is a positive management action that will benefit the conservation of the local plant, animal and other biotic communities. This practice is strongly supported by a local forestry consultant. However, in terms of Section 23 (1) of the Forest Act No 12 of 2001 a formal EIA is required for clearings of more than 15 ha in extend, and this was not available.

Close-out evidence:

32 6.1.2.1

1.1.1

5. RECORD OF OBSERVATIONS

OBS # Indicator Observation Detail

Date Recorded> 08 June 2005 Date Closed> 2007/02/21

Observation:

On Annenhof farm the cutters did not have gloves (issued or subsidised), and their hands (visual inspection) were damaged by the thorny vegetation.

Follow-up evidence:

01 4.2.2; 4.2.5

Annenhof is not a member of the group any more. On both Tzobaas and Breedtskroon the cutters have been issued with gloves, overalls and gumboots. The availability of these were confirmed during field visits to both farms. Some of the cutters refuse to wear the gloves though as they claim it is too hot for these conditions.


Observation:

02 8.1.2.2

Drinking water is monitored, but in some cases, the results have indicated that this water is not fit for drinking (e.g. on Tzobaas and Annenhof, March 2005 tests by Allerton Provincial Veterinary Lab, RSA, and on Harris and Breedskroon in 2004), yet there has been no further action in terms of investigating the cause or improving the water quality.

AD 37-01 Page 18 of 25


Follow-up evidence:

No further tests have been done or steps taken to implement remedial action. Minor CAR 25 was raised.


Observation:

The cutters on Annenhof do not know the buffer zone specifications in terms of harvesting (e.g. no harvesting within 100m of a river).

Follow-up evidence:

03 6.5.3.1

Annenhof is not a member of the group any more. A meeting was held on 2005/06/03 where all CARs and Observations, such as this one, were discussed. Cutters on Tzobaas and Breedtskroon were aware that they may not cut large trees and near riverine areas.


Observation:

In terms of the ILO standards, it is specified that workers should be protected from excessive UV radiation. None of the members provide any such protection (e.g. hats).

Follow-up evidence:

04 4.2.5

Although hats have been provided to workers on Tzobaas, workers on Breedtskroon have not been provided with hats to protect them from radiation in an environment where solar radiation can be very harsh. Minor CAR 26 was raised.


Observation:

The labour accommodation and facilities on Annenhof was not very good in that the pit latrines were not under cover, and there were no washing facilities.

Follow-up evidence:

05 4.2.9

The labour accommodation on Breedtskroon were built in the traditional style and presented a neat and clean appearance. New toilets have been provided and a bio-enzyme is used to break down the sewerage – this is very effective and the toilets give a clean impression with virtually no smells. The worker facilities on Tzobaas are more basic, but built with brick. A new toilet and shower is in the process of construction.


Observation:

On Annenhof and Breedskroon, there were no waste management plans for the ash and sand that is generated at the screening site, and these piles are just enlarging, so this will become an issue.

Follow-up evidence:

06 6.7.2

All fines at Breedtskroon go to E & C in Natal, with therefore very little waste generated. Tzobaas sells all its production in bulk and again therefore very little waste is involved. There was also practically no production between September 2005 and December 2006 and consequently no possibility of any waste generation.


Observation:

Not all utilizable branches are used on Annenhof, for example, branches of 6-8cm in diameter are left in field at K3, and these could be utilised for charcoal.

07 5.3.3

Follow-up evidence:

AD 37-01 Page 19 of 25


Group Management indicated that the policy is to utilise all material down to 2 cm diameter for charcoal production. However, it was found on a number of felling sites on Breedtskroon that branches considerably larger than 2 cm diameter are being left in-field after harvesting. Minor CAR 27 was raised.


Observation:

On Annenhof there was an Apple leaf tree that was cut and utilized for charcoal. This represents illegal harvesting since this species is not on the permit. Furthermore, there was no disciplinary action against the cutter. On Annenhof, there was also evidence of the cutting of dead trees.

Follow-up evidence:

08 1.5.1

The group harvesting guidelines now stipulate that 2-3 dead trees /ha must be left after harvesting and that cutters must be trained to identify all spp on their cutting list. No evidence was seen in-field of any trees being utilized that does not appear on the harvesting permit. Annenhof is also not a member of the group any more.


Observation:

There is no covering of the charcoal on the farm Grootfontein (Annenhof) at the depot site, therefore this charcoal could deteriorate.

Follow-up evidence:

09 5.3.4

All farmers have canvas to cover charcoal at depot sites on each farm.


Observation:

Annenhof provided 9 months of volume data at the time of the assessment. Through extrapolation to 12 months, Annenhof is producing an average of 50.56 tons per month, which will be about 606.7 tons per year. If one adds 28% “fines” on to this (which are not supplied to Savannah), this constitutes 776.6 tons per year. Permit specifications available for Annenhof state 150 tons of charcoal, but a mistake has been made with the date of validity (permit # GRH061/2005; GRM062/2005) being from 06/02/2005 until 12/02/2005. The charcoal permits normally specify 150 tons per species per 6 months? Actual volume of charcoal produced on Annenhof (including fines) needs to be checked against permit requirements over a period of 12 months.

Follow-up evidence:

10 1.1.1

Annenhof is not a member of the group any more. The allowed volumes on the harvesting permits at this stage significantly exceed the actual volumes being produced e.g. the current harvesting permit for Breedtskroon allows 100 tonnes for the 6 month period until 2007/05/14 whereas they only produced 61 tonnes during the 2006 calender year. This aspect will be checked again as a routine part of any future surveillance assessment.

Date Recorded> 08 June 2005 Date Closed> 2008/04/04 11 7.1.6; 6.3.2

Observation:

AD 37-01 Page 20 of 25


SA2005: The management plan needs to include Management prescriptions for leaving “clumps” of bush (dense patches for different habitat and cover). The management plan and consequently the operational harvesting plan does not provide for this. The need for such “clumps” was pointed out by local ecological expert, Peter Cunningham.

The management plan also needs to include prescriptions for the eradication of invasive exotic species such as Opuntia spp; Prosopis spp; Lucenia spp and Dodonaea spp, which are problematic in that area of Namibia, although were not specifically encountered during the surveillance visit (hence Observation and not CAR).

SA2007: This subject has not yet received adequate attention either in planning or execution. The Observation remains open for monitoring.

Follow-up evidence:

The consultant used to compile the 10 management plans indicate that both the above subjects were considered. However, since the target spp comprise only a part of the total spp composition of any particular vegetation type, any felling of such spp will naturally result in a mosaic of denser and more open areas. This was observed during field inspections to occur. No alien plant spp occur in the blocks that are harvested or are intended to be harvested and none were observed in-field during the assessment.


Observation:

There is inadequate provision for coppice management relating to harvesting techniques. That is, the management plan needs to clarify if coppice regeneration is wanted or not, and the harvesting techniques should be designed to either promote coppice regeneration or prevent coppice regeneration. Post-harvest care also needs to deal with coppice management (e.g. thinning of coppice or killing of coppice?). This was not actively checked thoroughly enough on all of the farms and is therefore raised as an observation and not a CAR.

Follow-up evidence:

12 7.1.11

This subject is crucial for the attainment of management objectives, but has not yet received adequate attention. The observation was closed and Minor CAR 23 was raised.


Observation:

The signed agreements with the members do not commit the members to the full 5 year period of certification.

Follow-up evidence:

13 2.2.1.2

(AD64 Group checklist)

This requirement is seen as impractical. A farmer can not make this commitment, not knowing whether he may sell his farm within this period. The current practice of one year contracts with mutual 3 month notice periods in the event of cancellation is viewed as a realistic approach.

Date Recorded> 08 June 2005 Date Closed> 2007/02/21 14 Group SLIMF requireme Observation:

AD 37-01 Page 21 of 25


In terms of WI 15-01 dated 1 February 2005, the size of the individual SLIMF forests should not exceed 3 000 ha. If SLIMF members exceed this 3 000 ha, then this needs to be approved on a case by case basis by SGS and such exceptions need to be kept by SGS and documented on the project file. In the case of the Savannah Charcoal SLIMF group, ALL of the member’s farms exceed 5 000 ha, but there is no documented approval from SGS for these exceptions.

Note from Programme Director: WI15 was developed before SLIMF and the SLIMF factor was not considered when the document was reissued in 2005. Document will be reviewed to address this, as an area restriction will be counter productive in terms of the SLIMF initiative.

Follow-up evidence:

nts

Observation closed – see note by Programme Director.

Date Recorded> 21/02/2007 Date Closed> 04/04/2008

Observation:

It was not clear whether the harvesting permits allowed the harvesting of the stated volumes per month or for the full 6 months of the validity period of the permit. This creates the potential for over-felling.

Follow-up evidence:

15 1.1.1.1

Permits have been clarified to indicate that the validity of the granted volumes covers the 6 months duration of the permit. Permits also now specify the percentage of each spp that a particular farm may harvest.

Date Recorded> 04/04/2008 Date Closed>

Observation:

All necessary equipment is not always available at all work sites. Although available at most work sites, at least one instance was found where no first aid kit was available to workers.

Follow-up evidence:

16 4.2.5

Date Recorded> 04/04/2008 Date Closed>

Observation:

The current management plans do not make provision that at least 3 dead trees per hectare must remain unfelled.

Follow-up evidence:

17 6.5.2

6. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS

Nr Comment Response

SURVEILLANCE 1

AD 37-01 Page 22 of 25

Nr Comment Response

1 The absence of a Qualifor standard for Namibia against which the Main Assessment could audit Savannah Charcoal was questioned.

An adapted checklist for Namibia was collated by SGS and used for the first surveillance.

Note from Programme Director: The standard for South Africa was applied as a regional standard with supplementary requirements provided by the 2004 De Klerk report. This was the modus operandi with all other countries in Southern Africa until beginning of 2005. This main assessment was done at the time SGS was waiting for endorsement from FSC for the new generic SGS standard, which was subsequently used to develop a standard for Namibia.

2 It was questioned whether the Outjo factory was Chain of Custody (CoC) certified.

This was not done simultaneously with the main assessment. Both the Outjo factory and the on-site charcoal processing need to be CoC certified against the FSC chain of custody standards since the timber that is harvested is physically modified prior to leaving the forest. This was an initial oversight of the main assessment. An assessor was subsequently sent to carry out a group CoC assessment and this was included under the scope of the FM certificate.

3. It was questioned why the main assessment report failed to report on all of the SLIMF criteria for acceptance. Specifically, one of the absent criteria was that the harvest levels should be less than 20% of the MAI.

The Programme Manager stated that the Main assessment report would be revised to incorporate this.

4 From the main Assessment report, there was a comment that the member Annenhof did not meet the SLIMF criteria.

This is correct in terms of the requirement to harvest less than 20% of the MAI. Major CAR 18 was raised in this respect. Please see Record of CARs.

5 It was questioned whether all of the members were meeting the harvesting permit requirements, since this was not apparent from the main assessment report.

The permits checked at the first surveillance for Annenhof and Breedskroon were both incorrect. The District Forest Officer was personally questioned about this and he stated that the issuing of permits from his office was a big problem, and mistakes were often made. This issue was raised as Observation 10. The Programme Manager also stated that this was unclear in the Main assessment report, which would be revised to better explain the permit system.

6 It was questioned why the Harris Farm (L.Katjivena) could be certified, given the harvesting of large Mopane trees, which is a form of deforestation, and large Mopane trees could not be considered as typical “bush encroachment”. The stakeholder also drew attention to an article in the Windhoek Observer, dated 22 July 2000, where the destruction of Mopane forests was exposed in the Outjo, Otavi and Otjiwarango areas of Namibia.

Given the time constraints, and the distance of the Harris farm from the new members that needed to be visited, the Harris farm was not visited. The Savannah management, however, said that this was no longer happening, but this could not be verified. It is recommended that

this specifically be checked on Harris farm as well as on the other member’s farm. The Namibian Standard was not available for the main assessment, but these diameter cut-offs are now incorporated in the adapted Namibian Standard. The specific targeting of large trees was not encountered on the three farms visited at this first surveillance.

AD 37-01 Page 23 of 25

Nr Comment Response

7 No provision appears to have been made for coppice management.

Correct. There is no active coppice management and the harvesting guidelines and post-harvesting guidelines do not make provision for coppice management. Observation 12 was raised.

SURVEILLANCE 2

1 The subject of the harvesting of large mopane trees was raised as an issue during the 1

st

surveillance.

No evidence could be found that large trees of any spp, including mopane, were being harvested. It was evident that effort is being made to limit harvesting to smaller trees only on Breedtskroon where the most active harvesting was taking place. The farm Harris is not part of the group any more.

SURVEILLANCE 3

1 In general the charcoal industry has developed in the past years, with some improvements for the labourers which have always been (and still are) a major concern. The industry seems to be better organized, but still people need to be laid off every 6 months due to the lack of stockpiling facilities. The incentive to cut down big trees in the charcoal industry exists, which is another concern. Regarding the question of overexploitation: we are very far from that, the industry is so minute (with charcoal actually by far the biggest player) at present and has such large barriers of entry that we will hardly see overexploitation. Yet, in some very localised sites it might happen, but in theory harvesting permits are there to ensure that desirable species are not harvested and I know of cases where operations were shut down when not complying with the rules. In short: the rate of encroachment actually exceeds the harvesting/clearing efforts at present: the rule of thumb for optimal tree density is 2 times the mean annual rainfall; even in only moderately encroached areas we have 12-22 tons per ha and some 8-10000 bushes, in Tsumeb there are 20 000 bushes per ha apparently.

The Department of Labour, the Farm Workers Union and the Charcoal Producers Association are engaged in discussions to formulate a mutually acceptable approach to labour matters in the charcoal industry in Namibia. Significant progress has been made and an agreement should be forthcoming in the not too distant future.

Only target encroacher spp are utilized by Group members and even within target spp instructions have been formulated to leave a number of the larger specimens of such spp unfelled.

This comment endorses the view of most players in the charcoal industry that sustainability is not a practical problem at this stage. The extend of encroachment is so large that the efforts of charcoal producers are not having a significant impact on the resource. Nevertheless consideration is taken of this subject and management plans reflect the need to execute the operations in a sustainable manner.

2 Have very limited knowledge about the charcoal industry and have never heard of the company Savanna Charcoal. My knowledge of the industry covers around the bush encroachment problem. My understanding is that many farmers are faced with a devastating manifestation of the invasive bush that reduces their cattle grazing acreage hence they utilise the bush by making charcoal.

No response required.

7. RECORD OF COMPLAINTS

Detail Nr

Complaint: Date Recorded >

AD 37-01 Page 24 of 25

Detail

Objective evidence obtained:

Close-out information: Date Closed >

8. MAINTENANCE OF CERTIFICATION

During the surveillance evaluation, it is assessed if there is continuing compliance with the requirements of the Qualifor Programme. Any areas of non-conformance with the QUALIFOR Programme are raised as one of two types of Corrective Action Request (CAR):

i. Major CARs - which must be addressed and closed out urgently with an agreed short time frame since the organisation is already a QUALIFOR certified organisation. Failure to close out within the agreed time frame can lead to suspension of the certificate.

ii. Minor CARs - which must be addressed within an agreed time frame, and will normally be checked at the next surveillance visit

The full record of CARs raised over the certification period is provided above.

The table below provides a progressive summary of findings for each surveillance. A complete record of observations demonstrating compliance or non-compliance with each criterion of the Forest Stewardship Standard is contained in a separate document that does not form part of the public summary.

SURVEILLANCE 1

Issues that were hard to assess

In general, farmers are not very fond of paperwork, therefore the need for long-term documented cutting plans, and operational harvesting plans had to be well justified, and most operators wanted examples of such plans. This was difficult because auditors should not play advisory roles. This issue was transferred to the District Forest Officer.

It was also difficult to ascertain the volumes actually cut, because there are no reliable conversion ratios available for Namibian hardwood. Experimental conversions on Breedskroon Farm ranged from 2.8:1 to 5.16:1. Actual volumes cut need to be determined in order to check that the permit specifications are not exceeded, and that SLIMF criteria are met.

Number of CARs closed 13 of the 14 CARs raised were closed.

Nr of CARs remaining open One Outstanding CAR from previous evaluations was not closed.

New CARs raised 3 New Major CARs and 2 Minor CARs were raised.

Certification Decision The forest management of the forests of Savannah Charcoal remains certified as:

� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and

� The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.

SURVEILLANCE 2


Due to a total collapse of their market between September 2005 and December 2006 there has been very little activity in the group in the intervening period since the 1

st surveillance. Other than the lack of activities

AD 37-01 Page 25 of 25

though, there were no particularly difficult issues experienced during the audit.

Number of CARs closed 4 Outstanding CARs were closed.

Nr of CARs remaining open 2 Outstanding CARs from previous evaluations were not closed.

New CARs raised No New Major CARs and 5 Minor CARs were raised.




SURVEILLANCE 3


The certificate holder complained that other certificate holders in Namibia who are assessed by another certification body, are assessed at a much “easier” level than by SGS. They question whether there should not be one FSC standard. Of course they are right, but there is nothing that the audit team can do about this situation, and it often created tension during the audit. This subject has been raised with SGS and directly with members of FSC staff in the past, but it does not appear as if any action is taken.

Number of CARs closed 5 Outstanding CARs were closed.

Nr of CARs remaining open 2 Outstanding CARs from previous evaluations were not closed.

New CARs raised One New Major CAR and 3 Minor CARs were raised. An action plan was compiled to address the Major CAR and its implementation before 2008/07/03 will be monitored.




END OF PUBLIC SUMMARY