This article provides some background on the standard development process, explains the changes that have been made to the draft standard, and outlines the next steps.
The UK Woodland Assurance Standard (UKWAS) is the national forest stewardship standard used in FSC forest management certification in the UK. It’s unusual in the global FSC system for being an independent standard, owned by a not-for-profit company, which takes into account the requirements of more than one certification scheme. In FSC terms, the UKWAS Steering Group fulfils the role of a national standard development group.
The UKWAS standard has its own structure and language which are quite different from other FSC national standards, which follow the order and language of FSC’s international Principles and Criteria. For its formal approval as an FSC standard, FSC UK staff reorganise the text of the UKWAS standard to fit the Principles and Criteria order, without changing the actual requirements of the standard; in other words, while the two versions of the standard look very different, they are functionally the same.
The current approved version of the standard is UKWAS 3.1; the version in development is UKWAS 4.
National standards are revised regularly, usually every five years, to take account of changing circumstances and new technical knowledge. For FSC, a crucial element of the current revision is the need to move from version 4 to version 5-2 of the Principles and Criteria.
The draft of UKWAS 4 was developed by the UKWAS Steering Group, with FSC UK providing technical advice on how they might meet the changed requirements of the Principles and Criteria. The drafting process included an evidence gathering phase and two public consultations, so that stakeholder views could be taken into account.
The Steering Group agreed a final draft in April 2016. FSC UK reformatted the draft standard, prepared supporting documentation, and formally submitted the standard for approval to FSC International in June. The standard was considered first by FSC International staff in the Policy and Standards Unit (PSU), then passed to the independent Policy and Standards Committee (PSC), made up of FSC members, for a decision.
In our November article we talked about the challenge of balancing the local adaptation of national forest stewardship standards like UKWAS with the need to fulfil the international FSC Principles and Criteria and achieve some level of global consistency. PSU noted that the current version of the Principles and Criteria is more specific in its requirements than the previous version, and that they felt that there were a number of areas where the draft UK standard did not fully address those requirements.
Changes made in the revised draft standard include:
- Additional requirements clarifying the legal status, tenure and rights of the forest owner/manager (FSC Criteria 1.1, 1.2 and 1.3, UKWAS section 1);
- New explicit references to legislation and associated guidance in relation to transportation and trade of forest products (FSC Criterion 1.5, UKWAS section 1.1.7), corruption (FSC Criterion 1.7, UKWAS section 1.1.6), workers’ rights (FSC Criterion 2.1, UKWAS section 5.6.1), and payment of living wages (FSC Criterion 2.4, UKWAS section 5.6.1);
- New explicit reference to mechanisms for resolving workers’ grievances which meet the requirements of statutory codes of practice (FSC Criterion 2.6, UKWAS section 5.6.1);
- Restored and revised requirement addressing investment to secure long-term economic viability (FSC Criterion 5.5, UKWAS section 2.1.3);
- Separation of requirements for the protection of priority species and habitats (FSC Criterion 6.4, UKWAS section 4.1.2) and the maintenance and enhancement of high conservation values, specifically designated sites (FSC Principle 9, UKWAS section 4.1.1);
- Clarification of minimum areas of semi-natural habitat (FSC Criterion 6.5, UKWAS section 4.4.3); and,
- New reference to co-operation with statutory bodies in the control of invasive plants and wild animals (FSC Criterion 10.3, UKWAS section 2.3.2).
Scale, intensity and risk
One thing that hasn’t changed in the revised draft is UKWAS’s approach to the FSC concept of scale, intensity and risk (SIR).
FSC recommends that different standard requirements be set where there are different potential impacts of operations, for example one variation for where operations are small scale, low intensity or present a small risk to environmental or social values, and another for where operations are extensive, high intensity or present major risks to environmental or social values. The UKWAS Steering Group has instead opted to make the standard ‘size-neutral’, allowing flexibility in the means of conforming to the standard, and of demonstrating that conformance, for each individual owner’s or manager’s circumstances.
In their feedback, PSU asked the standard development group to give greater consideration to SIR guidelines, or provide further justification for the approach adopted. The Steering Group opted to provide further justification, and a written explanation of their reasoning was submitted along with the revised draft standard.
One thing that hasn’t changed in the revised draft is UKWAS’s approach to the FSC concept of scale, intensity and risk (SIR).
FSC recommends that different standard requirements be set where there are different potential impacts of operations, for example one variation for where operations are small scale, low intensity or present a small risk to environmental or social values, and another for where operations are extensive, high intensity or present major risks to environmental or social values. The UKWAS Steering Group has instead opted to make the standard ‘size-neutral’, allowing flexibility in the means of conforming to the standard, and of demonstrating that conformance, for each individual owner’s or manager’s circumstances.
In their feedback, PSU asked the standard development group to give greater consideration to SIR guidelines, or provide further justification for the approach adopted. The Steering Group opted to provide further justification, and a written explanation of their reasoning was submitted along with the revised draft standard.
All parties – UKWAS, FSC UK and FSC International – have worked actively and constructively to find a way forward. FSC UK staff and the UKWAS Board spoke directly with senior staff at FSC International, and the decision on the UK standard was discussed by the FSC International Board of Directors. In close collaboration, PSU provided UKWAS with further feedback on outstanding issues, and FSC UK provided concrete proposals for how these issues might be addressed in the draft standard. At an UKWAS Steering Group meeting in Edinburgh in December, the Group agreed to a number of changes to address FSC’s concerns.
As with the initial submission, the standard will first be considered by PSU staff who will check for procedural and technical correctness; during this period there will be informal contact between FSC UK and PSU and there may be minor editorial changes to the draft standard or refinement of supporting documentation. UKWAS 4 will be reconsidered by the Policy and Standards Committee at their meeting in April, and a decision should be announced shortly thereafter.
Naturally we hope for a positive outcome, particularly in light of the intensive scrutiny the draft standard has faced over the past few months, but there is still the possibility of conditions being applied to any approval. In the meantime, UKWAS 3.1 remains valid.
Further information
If you have any questions about the UK national forest stewardship standard or the standard development and approval process, please contact FSC UK Forest Standards Manager, Dr Owen Davies,
at: owen@fsc-uk.org.