We are working on a project that has this requirement in the contract:
"Credit MR 7: Provide a minimum of 50 percent (by cost) of wood-based materials that are produced from wood obtained from forests certified by an FSC-accredited certification body to comply with FSC STD-01-001, "FSC Principles and Criteria for Forest Stewardship."
We are an FSC certified shop. However, each product we ship will not be FSC certified as we will only meet the 50% by cost requirement. (ie: we will mix FSC and NONFSC material to create a finished cabinet) Therefore the product will not shop FSC certified. But for the submittals, we can complete the MCDS sheets by MATERIAL (not product) and show that we met the 50% by cost FSC requirement and submit our supplier invoices showing THEIR COC # and fsc CLAIM and dollar value for material. If we, as the manufacturer who is changing the product prior to install, do not ship the items as FSC certified but follow above procedure be able to meet this requirement ? It also appears important for reasons I do not understand that we INSTALL the product to be able to meet the alternative documentation process for Architectural Millwork but we do not own install on this job. When we do, we sub it out.
Jon Clifford
LEED-AP BD+CGREENSQUARE
LEEDuser Expert
327 thumbs up
January 6, 2016 - 1:31 am
Sara—The requirement that you cite is the standard language often found in Specification Section 01.81.13 Sustainable Design Requirements. This is one of the “Front-End” Sections that spell out the project’s General Contractor’s goals and responsibilities for LEED. The requirement is that 50% of the ENTIRE PROJECT’S wood costs go toward FSC wood. It is often left to the General Contractor’s discretion how to meet this goal.
I will guess that your company works as a subcontractor to the project’s GC and that, as the woodwork supplier & fabricator, your firm provides a large share—but not all—of the wood purchased for the project. Several other subs probably provide rough carpentry, sheathing, and other miscellaneous wood items, any of which may or may not be FSC-certified. In fact, since your’s is an FSC shop, the GC may elect to purchase the bulk of the project’s FSC wood from your company. The GC may call on your firm to provide the highest FSC percentages possible in order to offset non-FSC purchases made elsewhere.
Work with your GC to determine the appropriate strategy and the FSC percentages to target for your Scope. Above all, handle, fabricate, and install FSC materials and report FSC content according to FSC rules to maintain the integrity of the chain of custody. (I am sure that Lori can address that topic with much greater authority than I.)
Lori Knosalla
Policy and Standards Manager - Chain of CustodyForest Stewardship Council US
LEEDuser Expert
17 thumbs up
January 6, 2016 - 9:28 am
The LEED MR7 credit requires project teams to purchase credit contributing materials from FSC certified vendors, so glad to hear you all are FSC certified already. The only exception to a supplier being FSC certified is for those who ONLY install on the project site, otherwise all suppliers to the project must be certified. The reason for this is because the project teams need to receive FSC claims on invoices or the alternative documentation (via the LEED Interpretation you mention) to document and contribute to the credit achievement of 50% by cost. So to contribute to the credit, FSC materials must be sold to the project team with an FSC claim on the invoice as per normal FSC Chain of Custody procedures, or architectural woodworkers can submit alternative documentation as discussed in the LEED Interpretation #10296: http://www.usgbc.org/node/1731359?view=interpretations
LEED does not allow or require invoices from further up the supply chain to be used for credit contribution and documentation. The FSC claim must be provided by the last vendor in that supply chain (unless they are ONLY installing). Therefore, as an FSC certified shop who is not installing on the project, you must follow your FSC Chain of Custody procedures that have been approved by your Certification Body. To contribute to the credit the LEED Project Team will need from you an invoice that conforms with FSC Chain of Custody requirements: your FSC COC certificate code and FSC claims identifying the materials sold to them as FSC certified.
As Jon mentions above, it is up to the GC and the LEED Project Teams to decide how they will meet the credit requirement of 50% by cost.
Sara Axon
General Woodworking, Inc.January 6, 2016 - 10:17 am
Thank you both so much. What I am taking from this is that to meet this requirement from the G/C, we will have to ship HALF our products as CERTIFIED FSC PRODUCTS (by cost) - all FSC: Every item in the construction of the cabinet: laminate/board/edgeband will have to be FSC. Our p/s will carry the FSC certification (COC# and claim) and our invoices WOULD as well but we bill these out with g/c provided online AIA forms that do not allow FSC information to be included on it. (So our invoices are not accepted form of billing) Do you have any advice for including FSC claim information on AIA forms that do not allow for it ?
Sara Axon
General Woodworking, Inc.January 6, 2016 - 10:43 am
If I understand the "alternative documentation process" correctly - it would appear that it is also acceptable to NOT ship 100% certified product but to break down the project costs into materials, separate from install, and count those MATERIALS (by cost) separately. Not including our fsc claim ANYWHERE.
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An alternative documentation process is available for architectural woodworkers (manufacturers of millwork, casework, and furniture) who supply custom wood products to the project. The purpose of this alternative process is to allow FSC-certified materials used in a custom millwork, casework, or furniture package to contribute toward the credit even if the entire package is not eligible to be invoiced with a FSC claim. Documentation for this alternative process must meet all of the following requirements:
- The woodworker (whether an individual or a company) must be FSC CoC certified, and the CoC certificate number must appear on the project invoice.
- The woodworker must install the custom millwork, casework, or furniture.
- The woodworker’s invoice must isolate product costs from installation costs.
- The woodworker must provide a document, separate from the project invoice, detailing FSC-certified wood materials used and total cost of wood materials used. (The woodworker does not need to provide itemized material cost calculations but must maintain calculation records for auditing purposes by the FSC certifying body.)
- The contract cost may include assembly labor but must exclude on-site labor (see MR Overview, Determining Product Cost).
The project team should complete a spreadsheet itemizing wood components by cost and identifying FSC-certified and noncertified components to determine overall contributions to the credit, to be entered into the MR calculator. Calculate the FSC-certified contribution value toward the credit by multiplying the percentage of FSC-certified wood by the overall value of the contract. Calculate the percentage of FSC-certified wood by dividing the cost of FSC-certified wood by the total cost of the wood. Submit the FSC-certified contribution value as well as the total contract amount. Include the woodworker’s CoC certificate number, invoice, and itemized costs.
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To me, above means I can make whatever i want here, mixing FSC and NONFSC wood products in my finished product and ship with the documentation by material as described above. I would need my FSC COC # on the invoice BUT NOT THE CLAIM, thereby NOT CERTIFYING the job and submit. I am still hung up on "The woodworker must install the custom millwork, casework, or furniture". We do not install, we SUB THIS OUT, but we (the millwork provider/manufacturer/subcontractor) BILL FOR INSTALL - we are in control of the install, we are responsible for the install. We just don't physically do it. Separate company. Thoughts ?
Lori Knosalla
Policy and Standards Manager - Chain of CustodyForest Stewardship Council US
LEEDuser Expert
17 thumbs up
January 6, 2016 - 11:17 am
First, I think you should clarify with with the GC about what materials they are expecting to purchase from you as FSC certified. You should not assume that they only want 50% FSC and the other 50% non-FSC. They may want as much FSC material from you as is possible. The Project Team will achieve this credit by reaching the 50% on the overall project, but you may be just one of a few suppliers of wood products, and they may be expecting your company to contribute all FSC. I would check with them before you assume they only want 50%.
The Alternative Pathway is only for companies who install, and the reason for this is to ensure that there is an intact chain of custody throughout the supply chain until the installer/end user of the product. If this requirement for installation was not part of the alternative pathway it would be impossible to ensure an intact chain of custody from forest to the project.
I am not entirely certain on the LEED rules around subcontractors installing the material for your company, but I would guess since you all are managing the installation process of the subcontractor and billing the GC, then you should be eligible to use the alternative pathway and therefore be able to use FSC and non FSC wood as it allows.
However, again, make sure you verify with the GC as soon as possible what materials they are expecting to receive from you as FSC certified. The credit language states 50%, but that does not mean you should only provide them with 50%.