Sat, Aug

Putting you in the loop

Putting you in the loop

What structures do you need to have in place to ensure you are part of the chain of custody? Environment consultant Clare Taylor explains.

The term 'chain of custody' keeps being bandied about and in all likelihood you're going to get more clients talking to you about the need to be part of it. From a printer's perspective chain of custody is usually branded an environmental accreditation - but strictly speaking it isn't: it's the forest certification of the substrates printed upon that is. Chain of custody is purely a system for managing and tracing certified paper through your production and administrative processes. This allows your customers to have a logo on printed products, giving their customers the reassurance that the fibre from which their paper is made truly is responsibly sourced. Chain of custody grew out of a recognition by timber users, traders, and people working for environmental and human rights organisations that simply certifying forest management couldn't work on its own: a way of identifying end products sourced from those forests was needed. Concerned buyers could then be sure that they were only buying responsibly sourced products. If you're just buying felled timber, it can be reasonably straightforward - but when it gets to buying manufactured products with long supply chains, tracing the source can be next to impossible. So the concept of chain of custody was created. The purpose was quite simple - to provide an audit trail for the timber from the forest (and now from the reclamation site for recycled materials) to the client/consumer - and it sat alongside the certification for forest  management (FSC). It follows the ownership of the fibre - if your customer supplies the paper, they are the one that needs the certification. PEFC followed a while later and, although their specific requirements for chain of custody differ slightly, the principle is the same.
What do you need to do?
The requirements for chain of custody are designed to apply equally to any user of wood: a timber merchant, maker of paper, wooden spoons or furniture, or a printer. Some of it can therefore seem a bit odd at first glance, but the basic requirements are pretty straightforward for a printer - ensuring that a job is printed on the right paper. The main difficulty for most people is the evidence that's needed - if you don't have the records to prove what you have done, it doesn't count. Records of everything have to be kept for five years: no chucking out the delivery notes as soon as you run out of room in the file. The FSC and PEFC standards for chain of custody have a common thread, and though each has requirements that the other doesn't, they can be put together to create a system that works for both. The basics are summarised here - there is not enough room to go into all the detail, but the documents for both are free to download from the web addresses given in the panel. Most paper merchants with chain of custody certification will offer support to their customers wanting to gain it themselves - some even have guides on their websites. Currently, FSC is the more prescriptive of the two Standards and clearly states exactly what's expected of you in every area. You can use it almost as a checklist. The PEFC standard is less so, but does have more detailed requirements in the new draft out for consultation. Both systems ask that you have a management representative with overall responsibility and authority for your chain of custody. The day-to-day running of the system can be delegated to the people who are involved at each stage of the process. Your MIS may be able to look after much of the tracking and record keeping, so speak to your provider. You need to have a set of procedures to cover the requirements of the standards, a procedure being simply a specified way of doing something. Management systems tend to have their own language, but both standards provide definitions to avoid confusion. Bear in mind that the aim is to be able to provide clear evidence that the job you have printed with a chain of custody logo is actually printed on the certified paper specified. All the risk points have to be covered: Paper purchasing: check (and keep evidence, such as copies of their certificates) that the company from whom you are buying the paper has chain of custody themselves: just buying an FSC or PEFC paper is not enough. Make sure you can link the paper to the job - one way is quoting your job number on your purchase order, or a stock requisition if using paper from stock. Taking delivery: check that the paper is correctly labelled and is what you were expecting and check the paperwork (see the last point). Think about how you can ensure that no-one picks up the wrong paper to print on. Keeping certified paper separately from other paper is ideal, but generally not practical, so clear labelling is important. Before the paper is unwrapped, it will be labelled - but if you only use a part pallet or packet, you will need to make sure the label is not lost. Repro: you need a checking system to make sure you have the right logo (there are several variants for each), used according to the guidelines. For FSC you will need to get a PDF approved by your certifier. While you are working: build in checks to verify that the correct paper has been loaded. Think about what will you do if you have a problem on the job, and find yourself short on paper. Outwork: if you put work out, even for finishing (when it's clearly identifiable and has the logo printed on it), you must have an agreement with your finishers that they will stick to the chain of custody requirements. These are clearly laid out in the FSC Chain of Custody Standard. Delivery and invoicing: to complete the paper trail, certain information has to go on the invoice and on delivery notes - again, the FSC standard, which is the more specific in this area, clearly details what is needed. Your production/accounting records for each job, or claim period if that better suits the type of work you do, should show how the volume of labelled work you have produced matches the volume of paper purchased, taking into account make-ready allowances, and include product, claim, sales and purchase information to tie it all together. FSC also ask for annual volume summaries, broken down by the material categories you have purchased and the product types you've produced. You will need to train your staff - and,once again, keep records to show that you have done so. Everyone must understand the importance of keeping to the ways of working you have set out and of not breaking the chain. For PEFC you will need to carry out internal audits and regular reviews to check that everything is working, whereas FSC is structured more towards records as evidence - but even if you are just going for FSC, regular checks are a good idea.
Finding a certifier

Only a few companies are accredited to certify to either of the chain of custody standards. To find who you can use, go to the UK web sites for FSC (www. fscuk.org) and PEFC (www.pefc.co.uk), where they are listed along with their contact information. Some will certify to both at the same time.
Keeping up to date

Standards are commonly reviewed every few years. The FSC Chain of Custody standard was revised in 2007, coming into effect from early last year. A revised draft of the PEFC standard is out for consultation with the new standard scheduled to take effect in 2010.


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