We are now seeing review comments about millwork or casework subs not having FSC certification.
The reference manual, the addenda and the definition provided on this website all suggest that it is the Vendor who is subject to certification. Since 2010 the definition has been: "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."
Up until recently our casework/millwork subs were installers not vendors. When did this change? If our millwork sub comes on-site with his FSC trim and cuts it to fit, does he need to be certified? What constitutes modification beyond installation? Do furniture installers and general contractors now need to be certified also?
Does this all have more to do with including the whole assembly as a dollar value as opposed to just the wood component part of the assembly since the assembly value as a whole is going to come from the sub and not the suppliers? What if we are only claiming the supplier dollars and not the "value added" assembly dollars?
Sadly as LEED consultants in the Pacific Northwest where sustainable wood is a big deal, this credit is so difficult to document to GBCI reviewers' satisfaction that we can't currently recommend it to our clients as being worth their cost and effort. Whether they do the right thing or not. Clarity on this issue would help a lot.
Doug Pierce, AIA
Architect / Sustainability StrategistPerkins+Will
235 thumbs up
October 30, 2012 - 11:59 am
Personally, I am not aware of any signficant changes to the LEED Certified Wood Documentation requirements OR FSC COC requirements as they apply to the majority of projects. To avoid confusion or interpretation errors, I am going to post quotes (+ links) on this topic without comment that are directly from both FSC (Date: Mid 2010) and the Green Building Certification Institute (Date: Late 2011):
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POST ON THE FSC United States WEBSITE:
FREQUENTLY ASKED QUESTIONS ABOUT THE LEED "CERTIFIED WOOD CREDIT" posted around July 19th, 2010 and located here: http://us.fsc.org/frequently-asked-questions.296.htm
"As of July 19th, 2010, the United States Green Building Council (USGBC) published several addenda relating to the MRc7 credit for FSC certified wood which can be found here. The addenda clarify two important issues relating to who needs to be FSC certified and partial claims:
Organizations that install an FSC-certified product or products on the project building/site (typically project contractors or subcontractors such as flooring installers or framing contractors, but also furniture installers and the like) do not require FSC CoC certification as long as they do not modify the product’s packaging or form except as is required for installation. All other organizations will need to be FSC CoC certified in order for the certified wood products they fabricate and install to count toward MRc7. This includes organizations like cabinetmakers and architectural millworkers that manufacture products off-site and then install them on-site (even if considered a subcontractor)
No partial claims can be made for products that contain FSC certified wood but are not sold with an FSC claim. This means that a company cannot mix FSC-certified components with non-certified components that are not eligible inputs into FSC Mixed products in an assembly and get credit for the certified portion. The product can only count towards the MRc7 point if the product complies with FSC Chain-of-Custody rules for Mixed products and the invoice carries a valid FSC claim and chain of custody number
Both clarifications further align the USGBC LEED documentation requirements with the FSC CoC standard"
For more informatin link to: http://us.fsc.org/frequently-asked-questions.296.htm
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Green Building Certification Institute (GBCI) PDF Download:
LEED PROJECT SUBMITTAL TIPS: NEW CONSTRUCTION 2009 Published on 12/23/ 2011 and located here: http://www.gbci.org/Libraries/Certification_Resources/LEED_Project_Submi...
QUOTE:
"Remember that valid FSC chain of custody numbers for each FSC certified wood product must be provided.
Be sure that the products on the vendor invoices for all new wood products are separated on a line item basis. Invoices need to include the dollar value of each product as well as vendor's COC certificate numbers for all FSC certified wood.
Be sure that the table includes the product name, vendor, product cost, wood component percentage, and FSC certified wood percentage of product shown on vendor invoice.
If furniture is included in the materials calculations be sure that it is included consistently across MR Credits 3-7.
Remember to upload cut sheets for 100% of the materials"
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Hope this helps to provide a little clarity,
Doug
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
October 30, 2012 - 1:01 pm
Yes it does, thanks Doug.
Since flooring and framing subs are not considered to need certification, does a millwork/casework sub only need certification if they are fabricating something off-site? If they are only on-site installers, does that make them analagous to a framing sub or furniture installer?
Doug Pierce, AIA
Architect / Sustainability StrategistPerkins+Will
235 thumbs up
October 30, 2012 - 1:23 pm
Hi Michelle - It has been my long time practice to interpret the situation you describe above, for LEED Certifications, in the following way: A millwork/ casework subcontractor that is installing FSC Certified assemblies, provided by a different FSC Certified Vendor and / or Fabricator, would Not need to be FSC Certified if they are Not making modifications to the product beyond that needed for installation. I.E. They are playing a roll in the FSC Chain of Custody (CoC) that is very similar to a "furniture installer and the like" as noted in FSC's LEED FAQ quoted further above and located at: http://us.fsc.org/frequently-asked-questions.296.htm
Best,
Doug
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
November 2, 2012 - 5:14 pm
So Doug, now that I've talked to a few local casework subs and contractors, I'm hearing that this certification requirement will be very onerous for small businesses who will have to segregate their production facilities. And having looked at half a dozen CI projects in-house, they won't be able to comply with MR7 without being able to use the value of casework. NCand CS projects may be able to use the other typical wood components and still make the threshold without including their casework.
Being a small business owner myself, I'm particularly sensitive to this kind of barrier. I'm feeling an unfortunate sense of confluence with the MR4 LEED Interpretation discussion where some are concerned large scale manufacturers are favored over smaller suppliers. Other than simply not pursuing MR7 on CI projects, any suggestions for how to approach this?
Doug Pierce, AIA
Architect / Sustainability StrategistPerkins+Will
235 thumbs up
November 2, 2012 - 11:22 pm
Michelle - My wife has had her own small business for over 10 years and I know that it can be very challenging.
I must say that the certification requirements above are not really new. The LEED Certified Wood credit has functioned roughly this way for many years, so it shouldn't really be an a new burden from that perspective.
I must ask, have your fabricators looked closely at the requirements for FSC Certification of their operations? I would not assume anything about what the requirements are as FSC has now made provisions for small business through Group Certifications. Here's a link:
http://us.fsc.org/coc-group-certification.286.htm
Of course Coc certification will not be complelely hassle free - but without some accountability (which is what causes the hassles), the certification would not be of any value. There is a signficant difference between FSC forestry / Coc requirements and other forest certifications or status quo forestry...I.E. being FSC Coc certified means more than a piece of paper - it has real environmental and social value.
If you are wondering what the differences really are and why FSC is important, I published an article in Trim Tab (the Cascadia Green Building Council's quarterly publication) last summer titled "FSC+Better? What is the status of the Wood Certification Gap?" The article compares 5 key features of all the forest certifications operating in the U.S. and can be found here:
http://www.pageturnpro.com/Cascadia-Green-Building-Council/41769-Trim-Ta...
Best Regards,
Doug
Furniture Assembly Team
February 5, 2019 - 12:05 am
What does it require at commercial furniture installation service?