Forum discussion

NC-2009 MRc7:Certified Wood

Chain of Custody Certification

For a project, we have specified FSC wood for the casework. The casework subcontractor/installer is planning on buying FSC wood, building the casework offsite, and then installing the finished casework on the project. We are confused as to whether the casework subcontractor/installer needs to be CoC certified, since technically he is "modifying the product beyond what is required for installing," but he is also not selling us a final FSC-certified product, only installing it. Can we get some guidance here?

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Wed, 07/30/2014 - 17:23

Installing contractors do not require a COC, but the subcontractor who fabricates the casework offsite DOES. If a non-FSC-Certified sub builds the cabinets offsite, the chain of custody is broken and the FSC Certificate is invalid. See the July 2010 Reference Guide Correction ID#100000383 on the USGBC Addenda Database: “Entities that install an FSC-certified product on the project building/site (typically project contractors or subcontractors, but also furniture installers and the like), do not require CoC certification as long as they do not modify the product’s packaging or form except as is required for installation.” See: https://us.fsc.org/download.coc-basics.129.pdf.

Wed, 07/30/2014 - 17:26

Thank you for your quick response! We were thinking the same thing, and you have confirmed it for us.

Wed, 07/30/2014 - 17:45

When specifying casework for LEED MRc7, it is wise to include FSC-CoC among the “Fabricator Qualifications” listed in the Spec Section’s “Quality Assurance” Article. Requiring the fabricator to submit their FSC qualifications up front ensures that you get what you are asking for BEFORE the subcontract is awarded. Boilerplate woodwork Specs frequently require that the wood be FSC-Certified for LEED, but they often omit the fabricator qualification.

Wed, 07/30/2014 - 22:06

That's exactly the issue we came up against, thanks for the advice!

Wed, 07/30/2014 - 22:23

Jordan - This link might also help explain FSC in LEED - https://us.fsc.org/frequently-asked-questions.296.htm. It doesn't address some of the new issues though. Like this LEED Interpretation - http://www.usgbc.org/leed-interpretations?keys=10296 - that explains an alternative documentation process for architectural woodworkers who also install product. It helps to avoid having to have them produce every single invoice for a large job.

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