Module 5 - VicForests

Module 5 - Harvesting and Closure
Appendix I
Auditee responses to matters of fact
I
VicForests Comments on the Draft Forest Audit Program Report 25/02/11
Comment Page Coupe General Comments Auditors consideration
Ref
1 13 n/a The level of compliance graph illustrates that our lowest level of
compliance is biodiversity conservation. This is largely due to
document control and not value protection as the term
biodiversity conservation implies. Can the graph be altered to
A new EIA category of "No impact" has been added to the EIA tool for those issues
where there it is assessed that there is no actual environmental impact as a result of a
non-compliance, to distinguish them from non-compliances that result in a negligible
actual or potential environmental impact.
reflect what the findings were, such as weed survey
documentation, machine wash down documentation etc
2 13 n/a This section focuses on crossing the tape line even though the
buffers were marked wider than the minimum prescribed width
and the minimum with is in no way compromised The operation
has therefore not impacted on the buffer. The audit has focused
on the input rather than the outcome of this issue. The objective
of the Environmental Assessment tool is to assess
environmental impact and in this case there has been none. This
'depth' of audit goes beyond the scope of the audit against the
Code and Management Procedures for this element.
Coupe reconnaissance and marking cause 19% of VicForests
OH&S incidents and 30% of our lost time injuries. The focus on
the marked or taped boundary line as being sacrosanct
exacerbates this potential for injury when we need to look for
other, safer ways of establishing the correct boundary.
In accordance with the FAP methodology, non-compliances are not limited to those
areas where environmental impact is noted, but where a Code, MP or salvage
prescription requirement is assessed as not having been met. The Auditor considers
that there must be no ambiguity about the way that coupe boundaries are managed in
terms of which tape lines can be crossed and which can not. Assessment of breached
taped boundaries as non-compliances is consistent with the way that assessments have
been made in past EPA audits that have been limited to Code compliance. However,
the Auditor accepts that crossing of taped boundaries is technically not a noncompliance
with Code or Management Procedure requirements if the required buffer
remains intact. Therefore, this non-compliance has been removed and text added that
the Auditor considers the culture and practice of accepting that taped boundaries may
be crossed carries a risk of leading to a non-compliance.
3 15 n/a Table 4.1 of total non-compliances shows no comparison to the
total number of audit elements or total compliance. It also does
not identify that the results are for 25 VicForests coupes and
only 2 DSE coupes. Please add further context and information
to this table.
4 17&1
8
n/a
At the bottom of page 17 it states that there may be a weakness
in planning or mapping processes, although the top of page 18 it
states that all 27 coupes were assessed as complying with the
requirements pertaining to planning. How is it that there is a
weakness if planning requirements comply Can this comment
be removed or amended to resolve the inconsistencies
especially as there is again no environmental impact.
The number of compliances and total number of coupes for each of VicForests and DSE
have been added.
Sentence about weakness in planning remains. Further clarification that the 'Exclusion
Zones' requirements address protection of exclusion zones has been added.
5 21 n/a If there has been no environmental impact why has incorrect
tape colour resulted in a non-compliance We do not believe this
is a non-compliance as the buffers meet the requirement of the
Code and Management Procedures.
6 21 n/a Harvest debris was pushed over the taped boundaries but they
were marked wider than the prescribed width. Therefore there
was no impact on the buffer or the value being protected. We do
not believe this is a non-compliance and goes beyond the scope
of the audit against the Code and Management Procedures.
7 21 n/a One buffer was taped at an insufficient width, but there was no
harvesting activities in the area between the taped boundary and
where the boundary should have been marked. Therefore there
has been no environmental impact to the buffer and this goes
beyond the scope of the audit against the Code and
Management Procedures
8 28 n/a The report states that there was no documentary evidence of soil
having been removed from machinery before floating to or from
a fire salvage coupe. In the Coupe Monitoring Records there is
evidence of machine wash down. If more evidence is preferred,
should this be a recommendation for improvement instead of a
non-compliance
9 43 n/a Can the dot point "trees pulled out of buffer without
documentation" be worded better as it sounds like harvesting
occurred in the buffer Trees were felled within the coupe but
slid down a hill into a buffer. The contractor removed the trees
but there was not sufficient documentation on the incident
10 25 n/a If there is evidence of weeds prior to harvesting in our records
we do not believe we should be issued a non-compliance for
weeds located within the coupe post harvest
11 26 n/a The default field for marking habitat trees states that the
variation for marking should be viewed. Foresters can update
this field with comments. The coupes listed below have
comments in this field detailing what the marking methods were
and where the habitat trees are located. If this has been
identified in the coupe plan and the correct number of trees have
been retained and protected the we do not believe this is noncompliant
The Code requires that "the location of buffer and filter strips must be easily
distinguishable in the field" and be identified in the Forest Coupe Plan. The FCP states
that the buffers are marked with red tape, however they were marked in orange tape.
The Auditor considers that there must be no ambiguity in relation to harvest boundaries.
In accordance with the FAP methodology, non-compliances are not limited to those
areas where environmental impact is noted, but where a Code, MP or salvage
prescription requirement is assessed as not having been met. In this instance, the
introduction of a new EIA category of "No impact" will enable the actual environmental
impact (none) to be reflected.
See response to comment #2.
Text has been changed accordingly.
See response to comment #2.
Text has been changed accordingly.
Where further information has been provided to the Auditor (CMRs) the audit finding has
been reassessed and in all but one instance the non-compliance has been reversed,
noting however that this is based on limited information. Text also added at end of
paparagraph 'The Auditor notes that this presents an opportunity for improvement in the
documentation of machinery wash-down activities'. See the coupe specific comments
for results.
Text has been changed to: "Inadequate evidence that authorisation was given to
remove trees felled into buffers"
All non-compliances related to weed management during harvest operations and preand
post-harvest weed surveys were reassessed based on further information and
comments on MOF provided by audittees:
1. Where information on occurrence of weeds before harvest has been provided in the
FCP or MIR, no non-compliance for pre-harvest weed surveys has been recorded,
noting that at times this was based on limited information;
2. Where a weed species is identified in the pre-harvest surveys and was observed by
the Auditor on the coupe, a non-compliance has been recorded for the lack of evidence
of management during harvest operations and the lack of post-harvest weed
inspections; and
3. Where a weed species is not identified in the pre-harvest surveys and was observed
by the Auditor on the coupe, a non-compliance has not been recorded for the lack of
evidence of management during harvest operations but a non-compliance has been
recorded for the lack of post-harvest weed inspections.
The report text has been updated
Where further information has been provided to the Auditor (Contractor directions) the
audit finding has been reassessed and in all but one instance the non-compliance has
been reversed. See the coupe specific comments for results. Identified as an area for
improvement.
42807504/01/01