Forest Stewardship Council...PSU_GF_01022012”) of the Polish standard that indicates in track changes the feedback made by PSU. On structure: this requires that all FSC standards

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Forest Stewardship Council

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The Policy and Standard Unit National Standards Report for the Republic of Poland

Document reference code: FSC-STD-POL-01-2013-Poland Natural and

Plantations EN

Scope: Natural and Plantations- National

Last updated: April.2013

Contact Unit in FSC FSC Policy and Standards Unit

E-mail for comments: [email protected]

mailto:[email protected]

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PART 1: Summary Analysis

1.1 Introduction:

In 1999 a group of Polish forest stakeholders that included NGOs, State Forest representatives and certifiers from

Poland initiated the process of development of National FSC Forest Stewardship Standard (FSS).

After the first meeting the group expanded to include other environmental NGOs, representatives of social stake-

holders, scientists and representatives of religious movement.

In May 1999 a Steering Committee was created to lead the process. The committee initiated in April 2000 the first

public request and consultation on the then existing draft 01 of the standard. This draft was discussed at a meeting

of an informal Working Group in September 2000. The group was formalized as the official group to develop

Polish FSC FSS in May 2003. This was the group that prepared and publicly consulted on 2nd, 3rd and 4th draft

of the National FSC Standards.

It is also worth noting that efforts were made to produce a document that harmonise with other existing FSC FSS

in neighboring countries like in the Czech Republic. The standard was approved by national stakeholders after it

was field tested and updated with outcomes and recommendations from the field test.

The present version being submitted by the Policy and Standards Unit (PSU) for the Policy and Standards Com-

mittee approval (PSC) has been subjected to a number of issues and discussions that took the process longer than

was planned. These issues will be looked at in this report.

The PSU staff responsible for the process is now confident after reviewing the standard for a second time that it is

ready to operate as an FSC FSS in Poland and as such seeks with this report for PSC’s approval of the standard.

As the FSC is now moving towards a new revised P&C it is advised that the standard should be approved

for two year; time when the Polish standard will be transferred to the revised P&C.

1.2 PSU Evaluation and Analysis:

1.2.1. Process assessment: The PSU assessment started with looking at the process of developing the Polish

standard. A document uploaded on the intranet titled “Process Chronology Poland” completes this section on

process assessment reporting.

The process assessment of standards development within the PSU is governed by FSC-STD-60-006 (V1-2) EN

otherwise known as “Process requirements for the development and maintenance of National Forest Stewardship

Standards”. This standard requires that the following steps are respected while developing any FSC FSS. A de-

tailed process check list is included in section 2 below.

a. A Proposal to develop an FSC Forest Stewardship Standard prepared and submitted to FSC PSU:

This requires that the person who is facilitating the process in Poland completes annex “A” of the FSC-STD-60-

006 (V1-2) EN. This Annex is a Template for proposals and work plan for development or revision of an FSC

Forest Stewardship Standard. Amongst other things, the template provides sections for PSU to assess if the stand-

ard submitted is a new or a revised standard, to also know if the process involved a three chamber decision mak-

ing system, a consultative forum, resource needed to run the process is secured and a timetable provided. This was

correctly presented and assessed as satisfactory by PSU staff. The work plan was then submitted to PSU and the

group for developing the Polish standard was approved.

b. An official announcement of a new standard under development: This is also one of the requirements of

the FSC-STD-60-006 (V1-2) EN that was fulfilled satisfactorily by the standard development group. An an-

nouncement was made on the Polish Website http://pl.fsc.org/ . FSC-STD-60-006 (V1-2) EN requires that such an

announcement should be done through FSC website and the website of the organisation developing the standard.

c. Facilitation and Chairing: Facilitation and chairing of discussions is to be done by one person appointed by

the group for this purpose. In Poland this has been assured by different people who came in and left over time as

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the standard was being developed. There was satisfactory communication between these persons and the FSC staff

that was enough to conclude that facilitation and Chairing provisions met expectations of an FSC process for de-

veloping forest stewardship standards.

d. The role of the Standards Development Group: A three chamber standard development group was estab-

lished to run the process as required in the FSC-STD-60-006 (V1-2) EN. The group was constituted in respect of

provisions outlined in section 4.3 of the above standard. Every decision of the group was later submitted to an

assembly of Polish stakeholders that voted for or against the decisions made by the group. The vote mechanism

was in line with FSC General Assembly consensus type decision making mechanism, with a balanced decision

making in all chambers. The general assembly also acted as the consultative forum in addition to the one that was

officially constituted at the beginning of the process.

e. Summary of main issues and comments: during the process that took longer than was originally planned,

the main issues that came up were around

The use of pesticides in nurseries: when the standard was first assessed it was identified that indicators

under C6.6 made an exception to use pesticides in nurseries without obtaining FSC derogation as per FSC-

POL-30-001 (2005) EN “FSC Pesticide policy”. The SDG was asked to correct this. The Polish stakeholders

did not accept this as the use of pesticides in nurseries is long standing practice that is crucial for the economic

viability of companies. Following several meetings with PSU staff it was concluded that nurseries in which

pesticides have been used shall be excluded from the scope of certification. The indicators were taken out and

replaced with the current indicators mostly from 60-004.

The threshold division between reserves set aside of representative sample areas and Conservation

zones: the initial assessment of Polish standard did not contain conservation and reserve set aside thresholds.

This was included in the assessment report as a pre-condition for submitting the standard to the Policy and

Standards Committee. The pre-condition was accepted but stakeholders differed over what percentages should

be allowed for on the one hand conservation areas (6.2) and on the other reserve set aside areas (6.4). This

took long discussions and meetings with PSU staff that resulted in the conclusion to have 10% threshold for

the total Conservation and reserve set aside of representative areas

f. Forest testing: Field testing of the standard was done by SGS an accredited FSC certification body as re-

quired in FSC-STD-60-006.

With the above main steps outlined in FSC-STD-60-006 (V1-2) EN followed, PSU staff concludes that the

process for developing the Polish standard has been followed satisfactorily. It is also important to note that

there was satisfactory collaboration with PSU staff during the process.

1.2.2. Structure and Content assessment: Content wise the Polish standard meets satisfactorily the requirements

of good forest stewardship as viewed by FSC. The assessment of the content was done using FSC-STD-60-002

(V1-0) EN “Structure and Content of National Forest Stewardship Standards”; besides using this document to

assess the structure and content; FSC-GUI-60-004 (V1-0) EN FSC “Forest Stewardship Standards: structure,

content and suggested indicators”, was used to determine if the standard contained good indicators that are

SMART to be applicable in forest management. A detailed assessment report that was submitted to the Polish

SDG is uploaded on the intranet for reference. The document is titled “National_FSS_Assessment Re-

port_PSU_Poland_09082012”. Accompanying this is the Annotated version (“Annotated_FSC_Poland_NatSTD_

PSU_GF_01022012”) of the Polish standard that indicates in track changes the feedback made by PSU.

On structure: this requires that all FSC standards be structured in a manner that specifies the Scope of

the standard. This is usually geographical, forest type and Size. Also, the standard needs to show a hierarchy

of Principles Criteria Indicators and Verifiers. The Polish standard has been structured satisfactorily in this

manner

On Content: The following was the outcome of assessing indicators:

SMART indicators (Specific, Measurable, Achievable, Relevant and Tangible): The wordings in some indi-

cators were found to be ambiguous. This was the case particularly with the following indicators 1.1.1, 1.5.3,

2.3.3, 4.1.2, 4.2.1, 4.2.2, 4.2.3, 6.3.2, 6.7.3, 7.1.3, 7.3.1.

PSU advised the SDG to rewrite the Indicators using a clear and consistent vocabulary, free from subjective

elements. The use of such phrases as “ordinarily”, “substantial”, “proactive”, “appropriate to”, “minimize

„wherever possible”, “thorough” or “best available” should were to be avoided

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Under Criterion 1.1: Indicators were not developed to cover administrative requirements of the criterion.

The SDG was asked to include the following suggestions from FSC-GUI-60-004 (V1-0) EN

“1.1.4 If any non-compliance with legal or administrative requirements has been identified by the enterprise

or by third parties in the previous five years, they shall have been documented by the enterprise, were

promptly corrected, and effective action has been taken to prevent their recurrence”.

Under Criterion 2.2: PSU assessment indicated that the criterion also looks at a situation in which local

communities “...delegate control with free and informed consent...” As this was not covered in the Polish

standard, the group was asked to include the following indicator from FSC-GUI-60-004 (V1-0) EN, in the

standard to cover this aspect of the criterion

“2.2.4 Where communities have delegated control of their legal or customary tenure or use rights, or part

thereof, this shall be con-firmed by documented agreements and/or interviews with the representatives of lo-

cal communities.”

Under criterion 2.3: It was also noted during PSU assessment that the indicators in C2.3 of the Polish stand-

ard did not require the forest manager to have a mechanism in place for resolving disputes. As this is an im-

portant part of the criterion 2.3 the SDG was asked to address this with the following indicator form FSC-

GUI-60-004 (V1-0) EN

2.3.4: In the case of a dispute related to the tenure claims and use rights of local communities, there shall be

a process to resolve the dispute which has been mutually agreed.

Under Principle3: the group considered the principle not to be applicable in Poland. An explanation was not

given whereas standard practice requires that an explanation be given if an FSC principle is considered not

applicable to a particular country or region. The SDG was asked after assessment to provide an explanation in

the standard why P3 does not concern Poland. The explanation given is as follows

“According to the FSC and UN definition of Indigenous people, there are not such groups in Poland. Poland

is located in the center of Europe, which has been crossed by numerous communication and merchant trails

since historical times. Thus, the territory of Poland has been subjected to continuous processes of coloniza-

tion, migration and settlement of different tribes and social groups. Some of these groups have significantly

influenced the evolution of Polish nation, but none of them can be considered as indigenous, as they have al-

ways been mixing with other groups of peoples, who had settled down beforehand. Moreover, all inhabitants

of the territory of Poland nowadays have equal status and rights and are part of modern social life.”

Under Criterion 4.4 the second part was not clear because the idea that those affected by management ac-

tivities needed to be consulted upon did not come out clearly the group was therefore asked to modify the in-

dicator by adding the right highlight below.

Under criterion 4.4, there was an omission of the words “men and women” from the FSC criterion. The group

was asked to include the wordings of FSC P&C as they ought to be.

4.4.2 Large and medium FMU-s: FMU shall consult and keep records of stakeholders’ (men and women)

concerns and requests followed by relevant FMU’s responses.

Under Criterion 4.5: not all the requirements of 4.5 were covered when the standard was assessed. 4.5 re-

quire compensation in case of loss or damage affecting the legal or customary rights of local people. For this

reason, the Polish SDG was required to include indicator below or provide similar ones to cover the criterion

in full.

4.5. X: “Fair compensation shall be offered in the case of any loss or damage caused by the forest enterprise

and affecting the legal or customary rights, property, resources or livelihoods of local peoples”.

FSC Criterion 4.2 was omitted from the standard with no reason given. The SDG was asked to include it

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Under Criterion 6.1: Indicators 6.1.7 and 6.1.8 were added in order to complete the parts of criterion 6.1 that

requires consideration of impact at landscape level and impact of processing facilities on the environment.

This was not addressed by the indicators in the previous version of the Polish standard.

Under criterion 6.2: Threshold requirement was not included. The group was asked to include a 10%

threshold for both reserve set aside of Representative Sample Area and Conservation areas.

Taking account of Scale and intensity: The standard is adapted to scale and intensity of management oper-

ations be first defining the small, medium size and large operations as follows:

“For the purpose of this standard the thresholds for SLIMF, medium and large FMO-s is following:

Small and Low Impact Management Forests (SLIMF FMO-s): A) FMO-s managing forest area below 500 ha (one or homogenous forest ownership),

B) FMO-s where the rate of harvest is less than 20% of mean annual increment and total annual harvest is

less than 5000 CbM,

Medium size FMO-s: FMO-s managing forest area of 500 to 10 000 hectares (one or homogenous forest

ownership)

Large size FMO-s: FMO-s managing forest area over 10 000 hectares (one or homogenous forest owner-

ship)”

After reviewing the Polish standard to make sure that the above assessments have been correctly addressed,

the staff in charge of the process is confident that the standard now meets the content and structure require-

ments for a positive approval by the Policy and Standards Committee.

Part 2: Summary Checklists of the Standards Development Process and its Structure and Content:

Table1. The process:

Full Assessment of FSC Forest Stewardship Standards (FSS) setting Process for Poland

Requirements of FSC-STD-60-006 (V1-2) EN (V1-2) EN Process requirements for the development and maintenance of Na-

tional Forest Stewardship Standards

Requirement PSU assessment of the process

1.Proposal

1.1. Proposals to develop or revise Forest Stewardship Standards (FSS)

may originate from discussion by the FSC Board of Directors, the FSC

General Assembly, or from proposals by FSC members, FSC accredited

National Initiatives, members of FSC staff or staff of Accreditation Ser-

vices International (ASI).

Completed satisfactorily. The proposal originated

from FSC Polish National office

1.2. The formal decision to register development or revision of FSS shall

be taken by the Head of the FSC PSU, taking account of the approved

strategic planning documentation, work plans and other instructions of the

Executive Director.

Completed satisfactorily. This decision was taken by

the head of the Policy and Standards unit as required.

1.3. All elements of the proposal and standard developed shall be submit-

ted to FSC in either English or Spanish.

Completed satisfactorily. The proposal was submitted

to FSC in English

1.4. Development or revision of a proposed FSC FSS shall not proceed

prior to formal notification of registration from the FSC PSU.

Completed satisfactorily.

2. Official announcement of a new standard under development or

current standard under revision:

2.1. An announcement shall be sent to all key stakeholder groups within

the territory once the process has been officially registered by FSC PSU

Completed satisfactorily. This was done via the FSC

polish website and also via e-mail contacts with the

stakeholders.

3. Facilitation and Chairing

3.1. The body which proposed the standards development shall identify


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the person (or positions) responsible for implementing each element iden-

tified in FSC-STD-60-006 (V1-2) EN (V1-2) EN

3.2 Facilitation and chairing provision shall ensure that the SDG operates

responsibly and in accordance with its ToR and the applicable procedures.


3.3. Facilitation and chairing provision shall ensure that all members of

the SDG have the opportunity to express their opinions and concerns, and

shall aim to find consensus in all recommendations of the SDG.


3.4. Facilitation and chairing provision shall ensure that there is effective

communication with the appointed member of Staff within the FSC Policy

and Standards Unit at all stages of development of the standard.

Completed satisfactorily

4. The role of SDG during the process

4.1 A SDG shall be established for the development of the Forest Stew-

ardship Standards.


4.2 The SDG shall have three separate chambers representing social, envi-

ronmental and economic interests, with at least two representatives in each

chamber, and equal number of people (or equal weighting) in each cham-

ber.


4.3 Members of the SDG shall be selected on the basis of their, (a) expert

knowledge and/or experience of the issue under consideration;(b) up-to-

date knowledge and experience of FSC’s systems and procedures; (c) rep-

resentation of points of view from the corresponding FSC chamber, and

the points of view of small, medium and large enterprises affected by the

standard; (d) understanding of the potential impact of the standard on af-

fected stakeholders; (e) understanding of and support for FSC’s mission

and vision; (f) ability to review and comment on documents submitted in

the working language(s) established for the SDG

Completed satisfactorily. All members of the SDG

had some experience with FSC in being members and

haven attended FSC workshops. They were also ex-

perts in their field of discussions during group meet-

ings.

4.4. All members of the SDG shall receive and commit to the ToR and

work plan prior to commencement of the standards development.


4.5. Technical experts may be appointed to participate in SDG discus-

sions. These technical experts shall have voice in the SDG discussions but

no formal role in its decision making processes.


4.6 When drafting the standard the SDG shall: (a) take into account all

relevant FSC documents pertaining to the process (b) provide detailed

input to the development of the FSS in accordance with its terms of refer-

ence; (c) sign off all drafts of the standard before they are submitted for

consultation; (d) formally recommend that the final draft standard be sub-

mitted to FSC for approval as an FSC FSS

When drafting the standard, the group took into ac-

count the following as stated in 4.6

a) All relevant FSC document required for the

process. This was also mentioned in their

proposal to revise the standard

b) Input was provided to the revision as re-

quired and members of the group adhered to

their ToR

c) And D) were confirmed by the facilitator of

the group

4.7 The SDG shall be chaired by a person or persons appointed by consen-

sus of the group.


4.8. The Chair(s) should be independent from any one chamber and broker

consensus rather than represent one chamber.


5. Terms of Reference and Work plan Completed satisfactorily

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5.1. The SDG shall agree terms of reference, the work plan and budget for

the development of the proposed standard.

5.2. The terms of reference for the SDG shall include at least the follow-

ing: (a) the approved version of the proposal; (b) the procedures to be fol-

lowed, including those required by this standard; (c) the agreed working

language(s) for the Standards Development Group; (d) all documents re-

lated to the process of the development of FSC Forest Stewardship Stand-

ards; (e) any additional specific requirements to complete the work; (f)

timetable for the standard development process.


5.3 The work plan shall include at least the following:(a) the setting up

and support of the SDG; (b) the setting up and support of a Consultative

Forum (c) drafting, consulting on, and redrafting standard(s) ;(d) the SDG

shall test the standard in the forest prior to submission of a final draft to

FSC for approval, (e) specification of a communications plan for the

standard development process which shall establish the working lan-

guage(s) for the standards development and most appropriate form of

communication to stakeholder groups;(f) detailed timetable for the stand-

ard development process, including an estimated date on which the com-

pleted standard(s) will be submitted to FSC for the approval process.

The work plan included the following elements stated

in 5.3

a) A Standard Development Group (SDG)

b) Consultative forum

c) The SDG was responsible for drafting, con-

sulting and redrafting of the standard

d) Ok

e) The work plan also specified the communica-

tion plan as required

f) It included a detailed timetable as required

5.4 The terms of reference, work plan and budget shall be singed off by

the SDG and submitted to the FSC PSU allowing two (2) weeks for com-

ment prior to commencement of the standards development.

Completed satisfactorily as confirmed by the facilita-

tor

6. Consultative Forum

6.1 The SDG shall be responsible for setting up a Consultative Forum for

the standards development process.


6.2. Membership of a Consultative Forum shall be open to any stakeholder

on request. The number of members shall not be limited.

Membership of the consultative forum was opened as

confirmed by the facilitator of the group

6.3 The Consultative Forum shall at a minimum include individuals and/or

organizations reflecting the full range of stakeholders affected by the

standard(s) under development at the national level.


6.4 The Consultative forum shall be consulted and kept informed at each

stage of the standards development; their comments being addressed and

recorded.


7. Preparatory drafting and consultation

7.1 A person (or position) shall be identified as responsible for compiling

the standard on behalf of the SDG. This shall include record keeping, mi-

nute taking and circulation of papers to the Standards Development Group

and Consultative Forum.


7.2 The role of the SDG members shall be to scrutinize and recommend

drafts; review and advice on comments submitted by stakeholders; and

suggest wording on specific aspects that might achieve consensus support

of all members of the Standards Development Group.

This role was fulfilled as required in 7.2

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7.3 At a minimum, the following drafts shall be prepared: (a) a first draft,

which shall be widely distributed to stakeholders for comment; (b) a sec-

ond draft, which takes account of the initial stakeholders comments and

shall be tested in the forest; (c) a ‘forest-tested’ draft, which takes account

of the results of the testing in the forest , and which shall be widely dis-

tributed to stakeholders for comment; (d) a ‘pre-approval’ draft, which

takes account of stakeholder comments on the forest-tested draft

Completed satisfactorily. In total five drafts were pre-

pared due to the need to have more discussions on

issues that stakeholders did not agree on like conser-

vation and representative sample area thresholds. Pes-

ticide usage.

7.4 Drafts for public consultation shall be officially announced as identi-

fied in the communications plan together with a summary of the key

points and a formal comments form, and shall be circulated to:(a) all

members of the Standards Development Group; (b) all members of the

Consultative Forum; (c) all FSC National Initiatives and National and Re-

gional Offices within the region; (d) all FSC-accredited certification bod-

ies operating in the region; (e) all key stakeholder groups identified under

Annex A; and, (f) the FSC Policy and Standards Unit.


7.5. The period to submit comments on the first draft for public consulta-

tion shall be a minimum of sixty (60) days from the date of publication.

The period for consultation on intermediate drafts shall be a minimum of

thirty (30) days from the date of publication. The period for consultation

on the final draft prior to decision making shall be sixty (60) days from the

date of publication.


7.6 All formal comments shall be kept on file. Completed satisfactorily

7.7 A report on the formal comments shall be prepared which includes: (a)

a summary of the issues raised; (b) an analysis of the range of stakeholder

groups who have submitted comments; (c) a general response to the com-

ments;(d) an indication of how the comments have been taken into ac-

count in the subsequent public draft standard; and (e) a copy of all the

formal comments as an annex.


7.6. SDG shall analyze the sources of the comments to ensure that formal

comments have been received from representatives of all the key stake-

holder groups identified as being impacted by the implementation of the

proposed standard.


7.7 The SDG shall be proactive in seeking input from representatives of

stakeholder groups. Special provision to ensure that formal comments are

received from representatives of any marginalized groups that may be

affected by the standard shall be made and potential impacts of the stand-

ard on such groups shall be explicitly identified and taken into account in

the development of the standard.


8 Content Assessed as satisfactory.

9. Forest testing

9.1 New standards shall be tested in the forest before it is submitted to

FSC for approval.


9.2 Ideally, the standard should be tested in the range of conditions in

which it is applicable, including both large and small forests, and in a rep-

resentative range of forest types within the specified scope.


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9.3 The standard shall be tested by an FSC-accredited certification body

and one representative of the SDG with technical expertise in forest man-

agement in the area of scope should also attend.


9.4 Testing shall include the full range of indicators included in the stand-

ard, and shall consider the auditability of the standard as a whole as well

as the socioeconomic impacts of compliance.


9.5 A report on the results of the testing shall be made publicly available

on request.


9.6 The findings from the forest testing shall be considered and agreed by

the SDG. The resulting draft shall form the ‘forest-tested’ draft of the

standard.


10. Draft standard(s) submitted for decision making

10.1 Prior to submission of the standard to FSC for approval, a formal

motion shall be put before the SDG members that the draft standard: (a)

has undergone sufficient consultation and testing; (b) meets the aims and

objectives specified in the terms of reference of the SDG; (c) merits the

approval by FSC.


10.2. When a draft standard has the formal recommendation of the SDG it

shall be published as identified in the communications plan.

Completed satisfactorily. The draft standard is made

public on FSC Poland website.

10.3. A report shall be prepared on behalf of the SDG. The report shall: (a)

summarize the standards development process, taking into account any

deviations from the original work plan; (b) explain the main issues and

concerns raised during the process, and explain how these have been ad-

dressed; (c) include a clear description of any departures from these pro-

cedures, demonstrating compliance with the requirements of section 16 of

this document;(d) include as Annexes a list of the names and affiliations of

the members of the SDG, and the names and affiliations (including speci-

fication whether the stakeholder is an FSC member, and, if so, of which

chamber and sub-chamber) of all stakeholders that have submitted com-

ments during the standards development process; (e) include the motion of

recommendation of the Standards Development Group, and the results of

this motion; (f) a translation into English of the ‘pre-approval’ draft rec-

ommended for the approval of FSC; (g) a copy of all formal comments

received during the final period of public consultation.


10.4 The finalized report shall be sent to the FSC Policy and Standards

Unit for formal approval.

Done

2.2 Table 2; Summary Checklist of Structure and Content

Threshold Requirements References FSC Evaluation

1. Specification of scope

1.1. The Forest Stewardship Standard shall speci-

fy the geographical scope to which it applies. This

may be a political designation (e.g. a country or a

region a province/state (i.e. a sub-national area)),

or a combination of political and ecological des-

ignations (e.g. a specified forest type or an eco-

logically-delimited area (eco-region) within a

political designation).


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2. FSC Hierarchical framework

2.1. The standard shall be structured as a hierar-

chy of Principles, Criteria and associated Indica-

tors.


3. Content

3.1 The standard shall include the wording of

each FSC Principle and each FSC Criterion, in the

same order as they occur in the current version of

FSC-STD-01-001 FSC Principles and Criteria of

Forest Stewardship.



3.2. The standard may include additional criteria

which are not part of FSC-STD-01-001 FSC Prin-

ciples and Criteria of Forest Stewardship and

may be added to the standard.

The standard does not include any additional criteria

3.3. An explanation shall be provided in the

standard if any FSC Criterion is considered to be

inapplicable1 in a given situation. Explanations

shall not conflict with FSC policy, standards, ad-

vice notes or other such documents related to the

criterion.

An explanation was given as required why criteria un-

der P3 are not included in the standard. See section

1.2.2 above under assessment of P3.

3.4. The standard shall comply with the latest

versions of all approved FSC policies, standards,

directives, guidelines and advice notes that apply

to the interpretation of the FSC Principles and

Criteria, as published on the official FSC Interna-

tional website.


4. The standard shall include as annexes:

4.1 a) A list of the national and local forest laws

and administrative requirements which apply in

the country or region in which the standard is to

be used,


4.1 b) A list of the multilateral environmental

agreements and conventions that the country has

ratified and the ILO Conventions listed in FSC-

POL-30-401 FSC and the ILO Conventions which

must be complied with in all FSC certified forests.


4.1 c) A list of, or reference to official lists of,

endangered species in the country or region in

which the standard is to be used


4.2. The requirements of any FSC Criterion that

can be evaluated in the forest without the need for

further interpretation shall be restated as an indi-

cator or indicators.


4.3. The standard shall include definitions to iden-

tify any categories of users to whom special

provisions are applicable, e.g. 'small-scale', 'low

intensity', 'community' or plantation forest

management units.


1 A Criterion may be considered inapplicable if there are no circumstances in which the Criterion can be evaluated in the geographical scope of the standard, or for a particular category of forest land within the scope of the standard. A Criterion may not be designated as 'inapplicable' on the basis that the standards development group would prefer not to apply it.

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4.4. The standard may include guidance notes to

help auditors, forest managers or others in using

the standard. Such guidance notes or applicability

notes may be included as annexes to the standard,

or be published as separate documents.


4.5. Each indicator shall specify outcomes or lev-

els (i.e. thresholds) of performance that are meas-

urable during an evaluation.



4.6. The standard may include references to sup-

plementary standards or documents (e.g. best

practice guidelines) developed by third parties

that provide additional guidance on implementa-

tion. Such references shall specify clearly whether

compliance with any additional requirements is

normative.


4.7. Indicators shall not be defined in terms of

design or descriptive characteristics, and shall not

favour a particular technology or patented item.


5. Indicators

5.1 The standard shall specify indicators for each

element of every criterion in accordance to the

requirements of this standard.


5.2 Each indicator shall specify one aspect of

compliance rather than multiple aspects of com-

pliance.


5.3 When an FSC Criterion includes several re-

quirements (e.g. FSC Criterion 6.5; FSC Criterion

7.1 a), b), c), etc.), associated indicators shall be

developed for each requirement.


5.4 Every indicator should include examples of

means of verification.


5.5. Indicators shall apply to all forests covered

by the scope of the standard, including smaller or

lower intensity managed forests, unless otherwise

specified.


6. The standard shall be written using a clear and consistent vocabulary which uses or permits unambiguous translation

of the following English/Spanish words in accordance with the specific meanings given below:

6.1 The words ‘shall’ to indicate a requirement of

the standard, and the words ‘shall not’ to indicate

a prohibition.


6.2 The words ‘should’ or ‘should not” to indicate

a recommendation, rather than a requirement or

prohibition, of the standard.


6.3 The words ‘may’ to indicate a permitted

course of action, within the limits of the standard.


6.4 The words ‘need not’ to indicate that a speci-

fied course of action is not a requirement.


7. Numbering

7.1 The numbering of Principles and Criteria

within the standard shall be the same as in FSC-

STD-01-001 FSC Principles and Criteria of Forest


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Stewardship.

7.2 Indicators shall be numbered with the initial

numbers of the relevant FSC Criterion, followed

by numbering for each indicator within the crite-

rion. Indicators may be sub-divided when this is

considered useful, with the sub-divisions listed,

etc.



8. Taking account of scale and intensity of forest management2

8.1 The standard shall be cost effective and prac-

tical for use in small-scale and low intensity forest

management units.


8.2. Small and/or low intensity managed forests

may be made exempt from some indicators which

are applicable to other forests, and/or alternative

indicators may be developed for application to

small and/or low intensity managed forests. In

such cases this shall be clearly indicated in the

standard. Development of indicators specific to

large and high intensity managed forests may also

be developed.


8.3. Alternative indicators and associated means

of verification may be developed for any criterion,

but shall be developed for at least the following

FSC Criteria which require special provision

when applied to scale, intensity and uniqueness of

the effected resource: FSC Criteria 6.1, 6.2, 6.4,

7.1, 7.2, 7.3, 7.4, 8.1, 8.2, 8.3, 8.4, 8.5, 9.1, 10.5

and 10.8.


8.4 The standard shall include clear guidance as to

the category of forest management units to which

any exemptions or alternative indicators apply.


2.3 Table3. Summary Checklist of Technical Review of Content:

2 Additional guidance is being prepared by the FSC International Centre to facilitate the development of standards applicable to small and low intensity man-aged forests.

Reference Condition for approval Comments (PSU)

Pre-approval condition 1-15-08-2012 Under indicators 1.1.1, 1.5.3, 2.3.3,

4.1.2, 4.2.1, 4.2.2, 4.2.3, 6.3.2,

6.7.3, 7.1.3, 7.3.1 and any other

indicators that are open to subjec-

tive interpretation; the SDG shall

avoid using words as indicated in

the annotated version.

Indicators shall be written using

a clear and consistent vocabu-

lary, free from subjective ele-

ments. The use of such phrases

as “ordinarily”, “substantial”,

“proactive”, “appropriate to”,

“minimize“wherever possible”,

“thorough” or “best available”

should be avoided.

SDG comments:

Pre-approval condition 2-15-08-2012 Criterion 1.1. Indicators not devel-

oped to cover administrative re-

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quirements of the criterion. The

SDG shall include the following

suggestions in the annotated version

“ 1.1.4 If any non-compliances with

legal or administrative require-

ments have been identified by the

enterprise or by third parties in the

previous five years, they shall have

been documented by the enterprise,

were promptly corrected, and effec-

tive action has been taken to pre-

vent their recurrence”.


Pre-approval condition 3-15-08-2012 Criterion 2.2. This criterion also

predicts a situation that local com-

munities “...delegate control with

free and informed consent...”

The following indicator shall be

included in the standard to cover

this aspect of the criterion

“2.2.4 Where communities have

delegated control of their legal or

customary tenure or use rights, or

part thereof, this shall be confirmed

by documented agreements and/or

interviews with the representatives

of local communities.”

See explanation column

The standard shall specify indi-

cators for each element of every

criterion in accordance to the

requirements of this standard.

SDG comments:

Pre-approval condition 4-15-08-2012 2.3.4.

In the case of a dispute related to

the tenure claims and use rights of

local communities, there shall be a

process to resolve the dispute which

has been mutually agreed.

The indicators in C2.3 do not

require the forest manager to

have a mechanism in place for

resolving disputes. This is a

crucial part of the criterion 2.3

and shall be addressed by indi-

cators in the Polish standard

with indicator 2.3.4 suggested

or similar ones

SDG comments:

Pre-approval condition 5-15-08-2012 4.4.2

Large and medium FMU-s: FMU

shall consult and keep records of

stakeholders’ (men and woman)

concerns and requests followed by

relevant FMU’s responses.

It is important that the idea of

consultation with those affected

by forest management activities

come out clearly in one of the

indicators in 4.4. This is the

second part of criterion 4.4. The

addition in indicator 4.4.2 in red

is acceptable.

SDG comments:

Pre-approval condition 6-15-08-2012 Indicators 4.5.1, 4.5.2 shall be sep-

arated in the annotated version in

order to address the specific re-

quirement of the criterion as shown

4.5.x Fair compensation shall be

offered in the case of any loss or

Note that these indicators are

not new to the Polish Standard.

What was done is to separate

the original indicator 4.5.1 into

parts in order to permit audita-

bility of the standard. This is

crucial to approving the Polish

standard. In addition not all the

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damage caused by the forest

enterprise and affecting the legal or

customary rights, property,

resources or livelihoods of local

peoples.

requirements of 4.5 have been

covered. For example 4.5 re-

quire compensation in case of

loss or damage affecting the

legal or customary rights of

local people. For this reason,

the Polish SDG shall include

indicator 4.5.x or provide simi-

lar ones to cover the criterion in

full.

SDG comments:


Pre-approval condition 7-15-08-2012 6.1.1- 6.1.4 and 6.1.6 shall be sepa-

rated in the annotated version in

order to address the specific re-

quirement of the criterion as shown

6.1.7

The enterprise shall complete and

document an assessment of the en-

vironmental impacts of its manage-

ment activities at the level of the

landscape in which it is situated.

6.1.8

The enterprise shall complete and

document an assessment of the en-

vironmental impacts of any pro-

cessing facilities within the FMU

under assessment.

Note that 6.1.1-6.1.4 and 6.1.6 are

not new FSC indicators. These are

originally Polish Indicators that

were grouped together and later

separated by PSU staff during

assessment in order to make the

standard auditable or clearer to the

user. Grouping or requirements

from a criterion into one indicator

dilutes the standard. This is not a

recommended practice in writing

standards

Furthermore, the newly introduced

indicators 6.1.7 and 6.1.8 are in

order to complete the parts of cri-

terion 6.1 that requires considera-

tion of impact at landscape level

and impact of processing facilities

on the environment. These were

not addressed by the indicators in

the Polish standard

SDG comments:

Pre-approval condition 8-15-08-2012 6.4.1.

Large FMU-s: FMU shall select

record on maps and keep repre-

sentative samples of existing eco-

systems in their natural state. If

necessary, the protected areas, ac-

cording to their plans, shall be set

aside. For the forest areas, the for-

est type is regarded as an ecosys-

tem. At least 1 % of the area of ref-

erential type of ecosystems is kept

for certified FMU. Total area of

naturally kept ecosystems of the

certificated unit shall cover at least

5%.

This is an original indicator from

the Polish standard. it is not clear

to me why the GA did not accept

this indicator that would seem was

previously voted by them.

SDG comments:

Pre-approval condition 9-15-08-2012 6.6.4 and 6.6.5 and 6.8.1, 6.8.2 Same comment as in Pre-approval

condition 8-15-08-2012

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Part 3: Statement on Recommendation by the PSU to the PSC for Approval of the Standard

3.1: Based on the assessment undertaken by the National Standard Manager, the Head of the Policy and Standards

Unit recommends to the Policy and Standards Committee of the FSC International Board of Directors for approv-

al; the FSC Forest Stewardship Standard for the Republic of Poland. With this final assessment of the standard

and its development process, all non-conformities formerly identified by the National Standard Manager have

been satisfactorily addressed.

Part 4: List of Evaluation Documents on the Intranet

Table 4: List of Document attached on the intranet

Process Chronology Poland

National_FSS_Assessment Report_PSU_Poland_09082012

Annotated_FSC_Poland_NatSTD_ PSU_GF_01022012

Nurseries_Consultation_report_31.05.2012_Poland

Process Assessment_Poland

SDG comments:

Pre-approval condition 10-15-08-2012 The SDG shall provide an explana-

tion in the standard why P3 does not

concern Poland.

This is in conformity with FSC-

STD-60-0.02

SDG comments:

Pre-approval condition 11-15-08-2012 The SDG shall include FSC Criteri-

on 4.2 as indicated in the standard.

No reason was provided for not

including this FSC criterion

SDG comments:

Pre-approval condition 12-15-08-2012 Under criterion 4.4, there is an

omission of the words “men and

women” from the FSC criterion.

The SDG shall include these words

as they are in FSC-STD-01-001_V4

No reason was given for omitting

words in FSC criterion

SDG comments:

Pre-approval condition 13-15-08-2012 The SDG shall include at the annex

of the standard a List of or reference

to official lists of, endangered spe-

cies in Poland