FSC, assemblies and recent addenda

Hi Steve - Based on what you have quoted from the LEED 2009 BD&C addenda and what you've said about the product, it sounds like the flooring product is 1). all wood that is 2). more like a door than a cabinet or piece of furniture which might contain non-wood components; this points to the entire product being certified. Your product may or may not qualify as FSC Mixed Credit; it will depend on the overall operation. FSC Mixed Credit is similar to a carbon offset or renewable energy credit - the FSC fiber might not all be in the specific product you installed, but an equal amount of fiber that is not in the product you've installed, is another product. Based on comments from FSC US website, FSC Mixed Credit will result in 100% of the wood product value contributing to the LEED Certified Wood Credit. If you haven't been there, go to FSC US webpage addressing LEED FAQ/'s and refer to the quesiton: "WHY ARE PRODUCTS THAT ARE IDENTIFIED ON VENDOR INVOICES AS “FSC Mixed [NN]%” VALUED LESS THAN PRODUCTS THAT ARE IDENTIFIED AS “FSC Pure” OR “FSC Mixed Credit,” WHICH ARE VALUED AT 100%?" Here's the link: http://www.fscus.org/green_building/leed_faq.php | dp

In response to Steve's questions I agree with his comment that the product is an assembly. The two components used to manufacture the flooring would be classified as "inputs" which can be with different FSC claims and without FSC claims. The requirement for the veneer would be that is is a "controlled" wood input. The FSC percentage would be the volume or weight of FSC input divided by the total volume or weight ot the final product. The product would then qulaify as a FSC Mixed xx% claim. The FSC content of the final flooring assembly would then need to noted on the packing list information and invoices. Please reference FSC-STD-40-004 (version 2-0) EN Percentage System and Annex I: comparison of the transfer, percentage and credit system.

Steve, This might get a little long, so hold on – here we go. It sounds like you are purchasing a wood flooring product that is made up of FSC backing with a Non FSC Veneer applied. Correct? I understand it to be that you are not the manufacturer. The short answer is that if this product is sold to you without an FSC Claim, than you must put the entire value of this product in your ‘non FSC’ column for this calculation (even if you’ve been told that it has some FSC material in the assembly). If this product is sold to you with an FSC claim, than depending on the type of claim on the product, depends on how much of the dollar value gets allocated to FSC and what amount goes to non FSC. Here’s the reasoning and some clarification. This product should come from the manufacturer either with or without an FSC Claim –simple as that. If it has no claim (even if you know it has FSC Core) than you must put the entire value of this product in the ‘non FSC’ column for your project calculation. The FSC Claim would appear on the invoice and shippers from the supplier. If the supplier of this product is not FSC COC Certified, than they cannot ever make any claim regarding the FSC content of this product. Thus their invoice could never include the documentation needed to satisfy the requirements for this credit. (FSC COC# & FSC Claim type). If you are the manufacturer, than first you must be FSC COC Certified for you to make any type of claim on this product. If you were an FSC COC Certified manufacturer, you would know that you cannot put a NON FSC veneer on a FSC Core and ever make any type of claim on this product. FSC Does not allow you to do this. I could go on about minor component derogations etc. But it will always lead back to the fact that you cannot mix FSC with NON FSC and have an FSC Product. The guidance for assemblies would apply to something like a cabinet, (an item with wood and non wood components) If I sell you a cabinet that is made up of wood (sides, top, bottom, door etc.) and metal (hardware, hinges, drawer glides) AND all the wood in that assembly is FSC material, than I can sell you an FSC Certified product. However when reporting that product to GBCI for the MR7 Credit, you would need to figure out what amount of that assembly is wood, and what amount is metal, and only report the value of the wood in that product. Your manufacturer of that product should be able to help you out with that calculation. As an FSC COC Certified manufacturer, I could not make an FSC claim on that cabinet if I used a mix of FSC and NON-FSC wood Materials. If I did this than the entire product would be considered a NON FSC assembly, and the chain of FSC product would end with me. Thus giving you the consumer a non FSC product. Mike’s comments are a little misleading. They are accurate if you are a FSC COC Manufacturer, not if you are a consumer. You cannot purchase a product and on your own decide what the FSC Claim is for a product. The process that Mike lays out is the calculation procedure for a FSC COC Manufacturer of a product ONLY.

Hi Kevin, I am not sure why you say "If you were an FSC COC Certified manufacturer, you would know that you cannot put a NON FSC veneer on a FSC Core and ever make any type of claim on this product. FSC Does not allow you to do this" The LEED reference guide gives a clear example under "Examples" of how to calculate an assembly that has a veneer that is one of the wood-based components but is not FSC certified. I agree that the Manufacturer must be an FSC COC, but I thought the whole point of the FSC Mixed xx% was for products that have some FSC Wood and some non-FSC wood. Here is a definition I came across: "FSC Mixed xx%: This material category details a specific content of FSC-certified material in the product. For labeling purposes, the % must be greater than 70% and there must be documentation to prove this percentage. Most cabinetry, furniture or custom woodworking will carry this label due to the product being built from various inputs. FSC Mixed xx% most often trades under the Percentage systems."

Heather, there are 2 perspectives to this issue. First is what USGBC has written regarding what is and is not acceptable with FSC materials. The second is the responsibility that a COC Certified manufacturer has to FSC and the standards which they are certified against. There had in the past always been a 'grey' area between these two before the release of an addendum on July 19th 2010. Regardless of what LEED has published in the past, what is important is what is found in the addenda's and CIR's. Staying current with these can be time consuming, but is the responsibility of each individual LEED AP/ GA. Unfortunately simply reading the reference guide without taking these other documents into consideration will not give you an accurate picture of what is required. Please reference the attached link. http://www.usgbc.org/ShowFile.aspx?DocumentID=6392 On page 28 & 29 there is line item 397 that lays out how you do the calculations for FSC products. Notice the last part of that paragraph "For example, a product that includes multiple wood components, like a door, the entire product must be FSC certified. The door cannot be labeled, or claim, that only the door core is FSC certified." This is an example of a non FSC veneer being applied to an FSC core, USGBC no longer accepts this methodology for FSC claims - even though the example you sight is written in the reference guide, it is superseded by this addenda. This addendum brought USGBC into alignment with FSC standards. This directly ties into the second part of this FSC puzzle. As an FSC COC certified manufacturer, I cannot apply a non FSC face veneer to an FSC core and EVER make a claim that the product is FSC certified. FSC strictly forbids this exact application. The second misunderstanding from your post is that FSC would allow the use of non FSC materials into an assembly / calculation and that's how you arrive at the FSC mixed xx %. FSC does not allow the use of non FSC materials in any assembly that will carry an FSC claim or label. (The caveat to that being that under some circumstances, a minor component derogation may be allowed if there are extreme circumstances, and even if this derogation is exercised, that material must make up less than 5% of the entire assembly. - Still under this derogation the material cannot be a face veneer.) A company that is making a FSC mixed percentage claim is arriving at this figure one of 2 ways. Either they themselves are mixing materials with an FSC Pure or an FSC Mixed percentage claim into one product, thus relegating the FSC claim down to a percentage based claim. Or they are mixing FSC labeled wood with 'controlled wood'. Controlled wood is wood that has been harvested by non FSC parties, and then later shown to have met FSC's principals and criteria for sustainably harvested materials. Even though this material has been proven to have been harvested sustainably, the fact that a non FSC company did this now makes this wood a lesser product. Using FSC Controlled wood in an assembly will default your claim to a percentage based system. (IE 95% of the wood in my cabinet is FSC Pure, 5% is Controlled wood - my claim on that cabinet is FSC Mixed 95%) You can find this information here - http://www.scscertified.com/docs/FSC-STD-40-004_V2-0_EN_Standard_for_CoC_Certification.pdf Look at the last 2 pages of this document. This is the visual representation of how claims are made. Hope this helps.

FSC does allow assemblies such as wood doors to carry FSC Mixed % claims as noted above, as long as the wood in the assembly that is not FSC has been assessed as Controlled Wood and validated as such either through a company risk assessment that has been approved by the manufacturers certfication body, or by purchasing components from vendors that are FSC CW certfified. Wood in the assembly including the vertical and horizonatal edges of doors, door crossbands, face veneer, light molding, etc. must comply. FSC nor the USGBC requires "all" wood to be FSC. The 70% threshold is only required if the product has a FSC on-product label. On-product labels are not required by the FSC. It is optional. If the product does not have a FSC on-product label applied to it, then any amount of FSC % can be claimed. While there is no minimum FSC % requirement, the goal is to supply the greatest amount of FSC contribution possible.

Judy, I agree with most of your statement. However your statement "FSC nor the USGBC requires "all" wood to be FSC" is misleading. Wood inputs can be either FSC Pure FSC Mixed Credit FSC mixed xx% or FSC Controlled wood. If you use a wood that does not fit into one of these 4 categories on your door, than your door no longer holds any FSC value. As you stated the 70% threshold is only for labeling purposes. However all wood must be from one of the above categories to carry any FSC claim on the invoice- which is used for submittal to GBCI.

Kevin, We can continue to agree to disagree. Judy's comment is correct in that you can provide "controlled wood" as FSC controlled wood or controlled wood through an organization's controlled wood risk assessment. The controlled wood does not have to be FSC controlled wood, but the organization better have the approved risk assessment if they are not providing FSC controlled wood.

Agreed mike, I think it's a matter of semantics.

One of the better documents explaining in depth the history and details of controlled wood can be downloaded from the Dovetail Partners website at http://www.dovetailinc.org/reportsview/2007/sustainable-forestry/pmatthew-wenban-smithp/fsc-controlled-wood-standard-what-it-an

Thanks Judy - this is great. As mentioned above much of the confusion comes from semantics. I consider FSC Controlled Wood to be "non-FSC certified" since the wood itself is not actually "certified" - at least not as I understand the semantics. I believe it is more correct to say the wood complies with standards - is that correct? However, it would have been much clearer in my post had I referenced the FSC Controlled Wood standard. I also agree it is very important to keep up with the addendae and I do. I try to cut and paste into my Reference Guide all the addendae, but it is making for a very bulky Guide and is time consuming. There have been so many addendae since 2009, I think anyone who purchased a Guide in the past should have access to a one-time printing of an updateing Guide with all addendae incorporated. But that is just an aside....

The following is taken directly from a document that our FSC certfication body (SCS) published. "FSC Controlled Wood products do not originate from forests certified to an FSC Forest Management standard." This same document also list the following "If your company is seeking to undertake a Controlled Wood verification program to determine whether the non-FSC certified virgin wood/fiber you are sourcing comes from forests that meet the five criteria of the FSC Controlled Wood standard, you must meet all the requirements of the FSC-STD-40-005 V2-1 standard." Hope this helps.