Breaking down the barriers to small and medium-scale certification...

by Steve Germishuizen

Small-scale growers load harvested timber in Samungu, KwaZulu-Natal. Timber is a useful income supplement for local families.

Small grower landscape deep in KwaZulu-Natal. Photo: Steve Germishuizen

After a protracted process that started in 2007, the Forest Stewardship Council recently approved the new South African National FSC standards. There are two standards, the Plantation Standard designed for plantations that are over 1000 ha and the SLIMF (Small Low Intensity Managed Forests) Standard, for those under 1000ha. From July, the certification bodies will be auditing against these new standards.

What are National FSC standards? The way it works is as follows; the FSC standard has 10 principles and a host of criteria, set by the FSC as measures of responsible forestry. These commandments cannot be changed, but countries can develop their own indicators of performance which can be tailor-made to suite the local circumstances. If countries do not develop their own national FSC standards then they have to be audited against checklists with indicators that are developed by the Certification Bodies (CB), as has been the situation in South Africa since the first certificate was awarded to SAFCOL in 1996.

It remains to be seen what impact the new Standards have on plantation management, but it is anticipated that the SLIMF standard will make it easier for smaller plantations to get certified. The SLIMF standard is aimed at plantations that range in size from tiny woodlots of less than a tenth of a hectare in Tribal Authority areas to farmers that have plantations of up to 1000 ha. The SLIMF standard relies less on documentation and complicated systems to indicate compliance and more on field checks and interviews with the foresters. In order to bring down the costs of the auditing process there is also a decrease in the frequency of external audits required. Small scale timber growers generally get certified as part of a group certification scheme which allows many of the certification requirements to be met by the group as a whole.

Despite the introduction of the SLIMF system and a few other initiatives, there are still other factors that make it more difficult for the smaller plantations to get certified. This is more pronounced in the Global South or the developing countries of the world. Put simply, certification is much easier to achieve if you are big and/or rich; but I suppose this is merely an echo of the principle of economy of scale which applies to all businesses. To overcome economies of scale (and as with many things life) the small have to have some other advantage to compensate for their lack of size.

The situation is no different in South Africa where practically all the large plantations and only a fraction of the small and medium scale growers are certified. At the same time, the demand for FSC certified products is increasing, as can be seen by the rapid rise in the number of processors and retailers that are getting Chain of Custody certification. If the situation continues, then certification is in danger of becoming a significant trade barrier to smaller enterprises, in ironic contradiction to many of the values in the FSC Principles and Criteria themselves. The FSC has understood this for a long time but seems to be taking it more seriously of late and are promoting and supporting projects that have innovative - even radical - approaches to the certification of small holders. There is actually a group within the FSC that is advocating for a separate set of Principles and Criteria for forestry managed by communities.

The exclusion of the small holder sector from certification is a concern for the South African timber industry as a whole, as most large and small growers supply common markets. There is also expected to be a growth in the small grower sector as the land reform programme rolls out.

Just what makes it so difficult for the smaller plantations to get certified?

Even with more scale appropriate indicators such as those in the SLIMF standard, most auditors still have a tendency to look at community and small farmer plantations from a large commercial forestry perspective. This is understandable because most of the policies and best operating practices were developed from a large-scale commercial forestry perspective and most auditors in South Africa come from that sort of background. To change this, perhaps a paradigm shift is required that cannot be easily captured in a forest management standard, but more about this in the next section. However, what the SA SLIMF standard will certainly do, is raise the profile of the smaller plantations and highlight the fact that auditors need to be thinking differently when assessing them.

Concentrate the effort on where it really matters.

FSC certification is proving to be increasingly important as a marketing tool. However, if its role as a management tool and a system to control risk could be improved it could become more relevant for all scales of forestry and more attractive for the smaller operators in particular. Up to now it has been a regular complaint from certificate holders and stakeholders that FSC audits focus on issues which seem really insignificant to the overall sustainability of the plantations, or to the greater objectives of the FSC, while ignoring the most important things. For example, an irregularity in planning documentation could take up hours of an audit and attract Corrective Action Requests while grossly inadequate fire protection measures might go unnoticed. Notwithstanding this, the FSC system has proved that it can be a very effective tool to help improve some areas; health and safety being the most obvious example.

To address these criticisms there needs to be an audit system which picks up the critically important things and pays less attention to the picky details. In order to identify the critical elements for sustainability one could use a risk assessment based approach, which after consultation and analysis identifies and ranks the risks. The analysis could identify certain key indicators, upon which others depend and FSC assessments focus on these most vigorously.

The same concept could apply at a higher level - for example, across different scales of forestry. A small farm or a community forestry operation, harvesting a few hectares a year using local labour and low impact equipment, has got a much smaller impact on the environment and therefore poses a low risk. On the other hand, large industrial timber enterprises can conduct operations and make policy decisions that can have profound environmental and social consequences in a very short time frame. These sorts of operations need more frequent and intense auditing than the small ones. To some extent the FSC applies this concept to Controlled Wood assessments but perhaps they can do more to adapt their overall compliance monitoring systems to cater for risk.

What is happening in South Africa to help break down the barriers?

Forestry South Africa is acutely aware of these issues and has formed a sub-committee of the Environmental Management Committee in order to oversee a project aimed at making certification fair for all scales of forestry. The project aims to develop risk based and other innovative approaches, such as the use of remote sensing that can be adopted by the South African plantation industry and have relevance in other African countries

NCT, Mondi, Sappi and TWK contributed R50 000 and released a tender for a consultant to run the project, and an appointment was made in October 2013. The next task was to raise further funds and NCT volunteered as a potential recipient of donor funding. The committee agreed that NCT, as a cooperative, would be attractive to funders. And indeed the, the FSC provided 30 000 Euro and the Critical Ecosystem Partnership Fund (CEPF) $50 000, both aimed at certification of small-scale timber growers in a landscape of various other land uses, a so called "multifunctional landscape". The approach taken in this project is to attempt to demonstrate that the entire landscape meets the certification criteria as apposed to trying to certify individual woodlots. In addition The CEPF wants to establish a 750 ha protected area in the Ozwathini area in partnership with the KZN Biodiversity Stewardship Programme run by Ezemvelo. The planned PA contains valuable scarp forests and the most significant remaining patch of Endangered KZN Sandstone Sourveld. The project will involve developing a management plan and training the community in the fundamentals of grassland management. This follows on the SANBI Grasslands Programme's involvement in the area where they have been funding a mentorship and training programme run by Gilbert Plant.

In addition to this NCT has applied to the Global Environmental Facility (GEF) for R8 million to train and develop small and medium scale timber growers in the Umgungundlovu District Municipality. This will involve employing mentors and trainers to develop the capacity of communities, land reform beneficiaries and small-scale farmers to improve their timber production and their capacity to manage the ecosystems. The project will also attempt to certify these timber growers by testing various new approaches.

FSC certified commercial farm in the KwaZulu-Natal midlands. Photo: Steve Germishuizen