Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global

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Evaluation and assessment of Uruguayan Forest Certification scheme against the requirements of the PEFC Council 3rd Para The conformity of the Standard … 29 5.2 Compatibility of the ME with PEOLG … with PEOLG Criteria are coded as C and associated relevant indicators coded as I 29 Table heading - UFCS p.30, 1.2 c compliance PEOLGs! Comment: There are no requirements per se in UNIT 1152 – it is comprised of Criteria and Indicators … with PEOLG Criteria are coded as C eg C 1 and associated relevant indicators coded as I eg I 6.1.1. – this provides guidance to a reader. Query: Are these the consultants words or are they PEFC Uruguay’s words? “... expansion of plantations where benefit to general society’s well being ...”. ENGOs are clearly a part of the general society! Who decides whether society benefits or not, and what kind of benefits...? (not very satisfactory!) 29-35 General Comments I cannot understand how a Criterion or a number of Criteria can specifically provide conformity with a PEOLG – it must be the Indicator under the Criterion which provides the conformance. The PEOLG is at the operational level but the Criteria in UNIT 1152 are based on the Montreal Process at the highest level of SFM. There is a lack of normative language in the Indicators which is the means to provide assurance of the outcome for the Criterion. Must is mostly used but it is no substitute for shall. I cannot understand how reference to Section 4.1 of UNIT 1152 provides explicit conformance as in many cases, it is implicit and there is an onus on explicit evidence for conformity assessment. PEOLGs 1.2c, 2.2b, 2.2d indicate that there is not the required evidence but there is a ‘conforms’ assessment! I cannot agree that a proper evaluation of UNIT 1152 Comments valid. Clarification text has been added to the document. Consultant’s comments. Table heading changed to ‘Evidence’. In Uruguay plantation projects are required to be approved by Ministry of Agriculture and Ministry of Environment. Ministry of Environment has specific responsibilities to evaluate benefits to society for specific plantation projects. 1. Comments noted. To strengthen the assessment the specific indicators for each criteria have been added in cases where indicators were not previously specified. 2. In relation to comment of normative language in Indicators, it is relevant to note that each indicator is supported by an indicator and specific framework of justification, objective, parameters, procedures, documents and registers. 3. In relation to interpretation the use of “must” in Standard has been considered equivalent to “shall” under PEFC requirement. 4. Reference to Section 4 of UNIT 1152 has been labelled as ‘General’ while reference to criteria and indicators has been labelled ‘Specific’ to strengthen evaluation www.itsglobal.net Page 82
Evaluation and assessment of Uruguayan Forest Certification scheme against the requirements of the PEFC Council 35 5.7 Overall Assessment, 2 nd sentence provides adequate conformity assessment against the PEOLGs – there is a greater need to indicate specific Indicators to provide the conformity. If this is the assessment wouldn’t it be a ‘partial conformity’? The policies – are they the Uruguayan Government policies? If so, it needs to be explicitly stated as it may demonstrate compliance with legislation. framework. Comments noted. Justification text added to support consultants’ assessment. 6. Assessment of UFCS chain of custody standard against PEFCC requirements 36 6. Assessment of UFCS Chain of Custody Standard against PEFCC Requirements Comment: I would expect that GD2 and DG08 are also applicable UFCS documentation – all relevant sources should be cited. Comments valid. Additional references added. 8. Assessment of UFCS certification and accreditation arrangements against PEFCC requirements 38 8.1.1 Competence of Certification Bodies … (refer to Section 5, SD03) … 1) … (refer to SD03) … 38 4) and 5) Comment: I would adjudge these as Partial Conformity based on matching the documented evidence against the 39 6) … (refer to SD03, Section 3) … 39 7) … (refer to SD04, Section 4) … 39 9) … (refer to SD04, Section 5) … … work experience and requirement. Incorrect reference … (refer to SD03, Section 5, b) … Applicable references … (refer to SD04, Section 4, 5 & 8) … Applicable reference … (refer to SD04, Section 5 & 8) … … work experience, competence and training. Comments were noted. Report has been amended accordingly. Comments noted. Additional text and references added to justify consultants assessment. Comment noted. Reference amended. Comments noted. Additional references added. Comments noted. Additional references noted. www.itsglobal.net Page 83
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Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global

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