FSC certified subcontractor?

Hi EH,
Yes, it is my understanding that if the sub is actually cutting and finishing the wood, whether that is onsite or not, they are not just an installer and must be FSC certified. We are losing this credit now on our CI projects because 99% of our local millwork/casework subs even in the Pacific Northwest are not certified and can't afford the costs of separating their manufacturing lines. You should have a shot with an NC project which likely has other wood components that may comply.

Woodworkers who fabricate custom millwork/casework/etc. off-site need FSC CoC. Subcontractors such as flooring installers who do not modify materials off-site do not need FSC CoC.

There is nothing in FSC CoC that would require a millworker to "separate their manufacturing lines." There are costs and administrative burdens, for sure, however, and as Michelle states, many woodworkers have opted to not obtain FSC CoC and thus are not able to contribute to MRc7 -- although as many as 15% nationwide have, according to the Architectural Woodwork Institute. If you want the wood in interior woodwork to count toward MRc7, then project teams should verify in advance that woodworkers bidding the job have FSC CoC.

Michelle is correct.

We only had one, now two, FSC millwork shops in the area. It was a pain because it severely limited the bidders on jobs. But we had to use them if we had any hope of getting that credit on a lot of projects since the millwork packages were large. We've reached over 50% on some projects when it was large enough with other wood components to make up for it, or on CI projects with a lot of wood furniture that was FSC.

We have a few projects which were registered, and some bid, before July 2011, when the interpretation of this credit changed. Is there any protocol for "grandfathering" this credit? IE, if the project was bid prior to July 2011, and as there was no precedent for requiring a cabinet shop to be FSC certified up to that point, that requirement wasn't not included in the specifications, is it possible to get the credit? Assuming, of course, that it was properly documented by prior standards?
What about if the budget and scope was established by the public agency client prior to July 2011, but the CDs were not yet completed?

I don't know the answer to this question -- maybe Doug or Tristan can help

Hi Susan - in regards to grandfathered Issues: Everything is relative to the date the project was LEED 'Registered'. I.E. Whatever LEED criteria were in place at that date of registration prevail (including addenda, etc.). You will need to determine specifically when the project was registered down to the date.

Public agency scope and budget are not really relevant to this credit (not to be confused with the actual project costs). In this case the date of CD's has no impact because the certification criteria are tied to the date of registration.

As far as no requirement for cabinet shops to be FSC certified in the past...I have always required cabinets shops to be FSC certified on the LEED projects I administer - otherwise the cabinets (which are assemblies) cannot really be considered FSC certified because the cabinet shop opens the packaging and significantly modifies the FSC materials to fabricate the cabinets (I.E. plywood’s, MDF, hardwoods, etc., etc.). Without FSC certification, the cabinet shop breaks the FSC chain of custody and cannot claim the cabinets to be FSC certified. You can search for past LEEDUser posts on this topic that go into more detail.

In regards to FSC certification for installers, the February 2, 2011 Addenda to (LEED 2009 First Edition BD+C) makes the following clarification (below).
February 2, 2011 Addenda to (LEED 2009 First Edition BD+C) http://www.usgbc.org/Docs/Archive/General/Docs6392.pdf:

"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. Contractors and sub-contractors that temporarily possess FSC-certified material prior to installation should be careful not mix or contaminate the FSC-certified material with non- FSC-certified material."

Best Regards,
Doug