Supply Base Report:
BSL Woodfiber SA
Main (Initial) Audit
www.sbp-cert.org
Completed in accordance with the Supply Base Report Template Version 1.3
For further information on the SBP Framework and to view the full set of documentation see www.sbp-cert.org
Document history
Version 1.0: published 26 March 2015
Version 1.1 published 22 February 2016
Version 1.2 published 23 June 2016
Version 1.3 published 14 January 2019; re-published 3 April 2020
© Copyright Sustainable Biomass Program Limited 2020
Supply Base Report: Page ii Contents
1 Overview ...... 1 2 Description of the Supply Base ...... 3 2.1 General description ...... 3 2.2 Actions taken to promote certification amongst feedstock supplier ...... 9 2.3 Final harvest sampling programme ...... 9 2.4 Flow diagram of feedstock inputs showing feedstock type [optional] ...... 9 2.5 Quantification of the Supply Base ...... 11 3 Requirement for a Supply Base Evaluation ...... 13 4 Supply Base Evaluation ...... 14 4.1 Scope ...... 14 4.2 Justification ...... 14 4.3 Results of Risk Assessment ...... 14 4.4 Results of Supplier Verification Programme ...... 15 4.5 Conclusion ...... 15 5 Supply Base Evaluation Process...... 17 6 Stakeholder Consultation ...... 18 6.1 Response to stakeholder comments ...... 18 7 Overview of Initial Assessment of Risk ...... 19 8 Supplier Verification Programme ...... 20 8.1 Description of the Supplier Verification Programme ...... 20 8.2 Site visits ...... 20 8.3 Conclusions from the Supplier Verification Programme ...... 20 9 Mitigation Measures ...... 21 9.1 Mitigation measures ...... 21 9.2 Monitoring and outcomes ...... 21 10 Detailed Findings for Indicators ...... 23 11 Review of Report ...... 25 11.1 Peer review ...... 25 11.2 Public or additional reviews ...... 25 12 Approval of Report ...... 25 13 Updates ...... 27 13.1 Significant changes in the Supply Base ...... 27 13.2 Effectiveness of previous mitigation measures ...... 27 13.3 New risk ratings and mitigation measures ...... 27
Supply Base Report: Page iii 13.4 Actual figures for feedstock over the previous 12 months ...... 27 13.5 Projected figures for feedstock over the next 12 months ...... 27
Supply Base Report: Page iv 1 Overview
Producer name: BSL WOODFIBER, S.A.
Producer location:
- Headoffice: Travesia de La Marina, 51, 3º, 27850, Viveiro (Lugo), SPAIN - Chipping operations: Porto Exterior de Ferrol - Pioriño, 15593, Ferrol (A Coruña) SPAIN - Storage of logs: o Port of Burela: Muelle - Avenida da Mariña, 27880, Burela (Lugo) SPAIN o Port of Cariño: Zona Portuaria de Cariño, 15360, Cariño (A Coruña) SPAIN o Port of Ribadeo: Peirao de Mirasol, 27700, Ribadeo (Lugo), SPAIN o Port of Huelva: Plaza Aurtoridad Puertto de Huelva, (Huelva) Spain Geographic position:
- Headoffice: 43°39'36" N - 7°35'48” W - Chipping operations: 43°27'59” N - 8°19'17" W - Port of Burela: 43°39'26’’ N - 7°20'53’’ W - Port of Cariño: 43°44'17’’ N - 7°51'57’’ W - Port of Ribadeo: 43°32'00’’ N - 7°02'16’’ W - Port of Huelva: 37°11'26.4"N+6°55'53.4"W
Primary contact: Cecília Nolasco / Pedro Rodrigues – [email protected]
Company website: http://www.bsl.pt
Date report finalised: 24th July 2020
Close of last CB audit: N/A
Name of CB: In Process
Translations from English: Yes, to Spanish
SBP Standard(s) used: Standard 1, v. 1.0;
Standard 2, v. 1.0;
Standard 4, v. 1.0;
Standard 5, v. 1.0.
Weblink to Standard(s) used: https://sbp-cert.org/documents/standards-documents/standards
SBP Endorsed Regional Risk Assessment: N/A
Weblink to SBE on Company website: http://www.bsl.pt/madeira/
Supply Base Report: Page 1
Indicate how the current evaluation fits within the cycle of Supply Base Evaluations
Main (Initial) First Second Third Fourth Evaluation Surveillance Surveillance Surveillance Surveillance ☐ ☐ ☐ ☐
Supply Base Report: Page 2 2 Description of the Supply Base
2.1 General description
BSL Woodfiber is a wood producer that could operates as:
- Woodchips producer in the Port of Ferrol. In this case, the wood is purchased to forest owners, of eucalyptus plantations FSC, and also occasionally PEFC, certified. All of them are small plots from smallhorlders certified under Groups certificates. Port of Ferrol can also receibe eucalyptus wood from external suppliers, but amost all wood is FSC or FSC and PEFC certified. Despite its history of handling wood logs and wood chips in Spain, BSL Woodfiber is in an initial phase of SBP implementation, with the aim of reaching an annual average of 25,000 tonnes per year. Considering the total amount of woodchips that BSL woodfiber processes, BSL Woodfiber is one of the largest woodchips producers Galicia for exportation. - As a loging company, selling logs in Ports of Burela, Cariño and Ribadeo. Wood is purchased also to forest owners of FSC or FSC and PEFC eucalyptus plantations. BSL Woodfiber can also purchase logs of pine to external suppliers. This pine wood is also FSC or PEFC certified in most of the cases. As a Logging company is also a very relevant player in the north of Galicia, especially on the eucalyptus market. - Woodchips producer in the Ports of Huelva. BSL receibes all logs of pine and eucaliptus from one supplier, that is also works as a subcontractor of chipping operations. This wood is not FSC or PEFC certified.
The supply base of BSL Woodfiber can be defined by all the provinces and Autonomous Communities where the company operates:
- Galicia - Principado de Asturias - Andalucía - Castilla y León
The supply Base is considered homogenous with regard to SBP risks despite the different ecoregions, because of the similar legislation and level of compliance.
BSL only accepts wood from a short list species. None of them are listed by CITES or IUCN: Especies principals: Maritime pine (Pinus pinaster) Scots pine (Pinus sylvestris) Monterey pine (Pinus radiata) Austrian pine (Pinus nigra) Stone pine (Pinus pinea) Pino carrasco (Pinus halepensis) Eucalypt (Eucalyptus spp.) Poplar (Populus spp.). Acacia (Acacia spp.) Volúmenes residuales de: Oak (Quercus rubra), as secondary species, not from natural forest European oak (Quercus robur), as secondary species, not from natural forest
Supply Base Report: Page 3 Sessile oak (Quercus petraea), as secondary species, not from natural forest Rebollo oak (Quercus pyrenaica), as secondary species, not from natural forest Willow (Salix babylonica), as secondary species, not from riparian vegetation Planes (Platanus spp.), as secondary species, not from natural forest Chestnuts (Castanea spp.), as secondary species, not from natural forest Ash (Fraxinus spp.), as secondary species, not from riparian vegetation Alder (Alnus spp.), as secondary species, not from riparian vegetation
Forest Land
Spanish mainland forest occupies around 55% (27.165.392 hectares)1 of the territory. A global description of mainland Spain by Autonomous Community (CC.AA.):
CC.AA. Total area (ha) Forest area (ha)
Andalucía 8.759.100 4.467.070 51% Aragón 4.769.800 2.615.332 55% Cantabria 525.300 364.317 69% Castilla - La Mancha 7.940.900 3.597.537 45% Castilla y León 9.381.400 4.815.357 51% Cataluña 3.209.100 2.008.329 63% Comunidad de Madrid 802.200 438.262 55% Comunidad Foral de Navarra 980.100 594.366 61% Comunidad Valenciana 2.325.400 1.267.036 54% Extremadura 4.163.400 2.872.451 69% Galicia 2.957.400 2.040.754 69% La Rioja 502.800 310.952 62% País Vasco 708.900 491.786 69% Principado de Asturias 1.060.400 770.479 73% Región de Murcia 1.131.300 511.364 45% Total 49.217.500 27.165.392 55%
According to data from the INE (Spanish National Institute of Statistics), Spain has the third longest forest cover in the European Union after Sweden and Finland.
Species The total volume of cuts in 2017 was 17.680.025 m3. And the most relevant species of both softwoods and hardwoods2:
Softwood (54% of total):
1 Anuario de Estadística Forestal 2017; Instituto Geográfico Nacional 2 Anuario de Estadística Forestal 2017; Instituto Geográfico Nacional
Supply Base Report: Page 4 Specie Volume (m3) Pinus radiata 3.618.924 Pinus pinaster 3.402.714 Pinus sylvestris 1.362.173 Pinus nigra 552.315 Pinus halepensis 259.821 Pinus pinea 136.388 Other Pinus spp. 123.391 Other softwoods 133.295 TOTAL 9.589.021
And hardwoods (46%):
Specie Volume (m3) Eucalyptus spp. 6.939.402 Populus spp. 531.587 Quercus robur 134.861 Quercus ilex 119.181 Castanea sativa 101.531 Quercus pyrenaica 94.816 Other hardwoods 169.626 TOTAL 8.091.004
Property According to data from MAPA (Ministry of Agriculture, Fisheries and Food), 27% (7,317,900 hectares) of forest cover corresponds to public domain forests that belong to the State, to the Autonomous Communities (AC), to local organisations and to other organisations under public law. And 73% (19,847,488 hectares) is private forests owned by individuals or legal entities under private law and are either individually or co-owned, which can be further categorised into:
Collectively owned which represent 3% of the total, and Private forests, with a significant superficial variability according to the different zones, from the Galician micro-property to the large estates in other Autonomous Communities, which represent 70%.
Property Forest area (ha) (%) Communities 823.289 3,03% Private 19.024.198 70,03% State and Aut. Com. 1.458.703 5,37% Local entities 5.859.198 21,57% Total 27.165.388 100,00%
Forestry management practices or land management practices
Article 33 of the Forest Law establishes the necessity for public forests and protected forest areas to have a Forest Management Plan and an Operational Scheme or another equivalent Management Instrument. These
Supply Base Report: Page 5 documents are elaborated by forest management units and must always be approved by the regional forestry organization. Regional forestry organizations regulate in which cases it is mandatory to have a management instrument for regular private and public forests (not catalogued as protected). Multiple laws in each Autonomous Community regulate the specific technical forestry operating constraints of forest management.
In accordance with Spanish legislation, there are three possible legal documents that prove legality of forest operations: Notification for harvesting (in private forests with Forest Management Plan or equivalent). The owner must notify the competent body of the Autonomous Community before harvesting. Authorization for harvesting (in private forests without a Forest Management Plan). It is required to obtain the Authorization before harvesting. Adjudication for harvesting (in public forests).
The three documents are evaluated by forestry technicians of the administration and enhance the legality, sustainability and respect for the environment of the requested harvesting operations. The technicians, in all three cases, make an on-site inspection of the forest to be sure of the best sustainable management of the forest. If the area of harvesting is related to any special protection function, they consult with the competent organization to make sure that environmental aspects are respected. For example, if the harvesting is within a natural park, the technician of the natural park, can mark restrictions in the cutting permit, for example, as not to interfere with nesting of certain bird species in a certain season. The technician can also prohibit operating in certain areas.
In the case of natural catastrophes, such as forest fires, wind and snowfall damage, or pests, additional cutting authorizations can be issued to mitigate the impact. These operations aim at preventing forest pests and guaranteeing regeneration of the forest area.
According to the 2010 report of the SECF "Spanish Society of Forestry Sciences", the following characteristics of Spanish forests serve as the basis for understanding the situation in forestry today: The annual growth (net increment) of wood is three times higher than the amount that is cut and harvested. The increment is 45 million m3 annually and wood extraction is around 17 million m3 a year. The total annual consumption of wood is around 32 to 33 million m3; Spain imports around 15 million m3 a year. Certain aspects related to the costs of exploitation, the structure of the market for forest products, and the use of current legal, financial and administrative instruments that have become obsolete in today's society, are some of the causes of this disbalance. Spanish forest area is expanding, and this trend manifests itself to a greater extent than in other European countries. Spanish forests cover over half the national surface. Regarding total forest area Spain is the third country in the European Union, behind Sweden and Finland, but ahead of France, Germany, and Poland. The forested area per inhabitant is higher in Spain than the average in the European Union. Spain has in average 0.4 ha of forest per inhabitant, compared to 0.3 ha per inhabitant in the EU. Most of the Spanish forests consists of native species. Contrary to what is often mentioned in various media, the area covered by hardwood species exceeds the area covered by coniferous species. Spanish forests are multifunctional. Important is the protective role of forests and their ability to conserve the hydrological cycle, and biodiversity. Its production function of forest products (wood, firewood, biomass for energy, cork, resins, edible mushrooms, pinion, livestock) is not negligible either. Hunting is also practised in Spain. The role of forests related to carbon fixation and the maintenance of the landscape and its biological wealth is transcendent. Spanish forests play an important role in improving air quality and mitigating of climate change. A study carried out in the CIFOR-INIA shows that at present, Spanish forests accumulate around 87 million tons of CO2 every year due to their growth. This means that the forests fix more than 24% of the total CO2 emissions of Spain each year. The current average consumption of wood in Spain is 0.8 m3 per inhabitant, in Central Europe it is 1.5 m3 and in Northern Europe 3.0 m3. Everything indicates that Spanish consumption of wood will continue to grow and that there will be a need to extract more wood from the Spanish forests or import more from other countries. The Forestry Sector has a great potential in the creation of rural employment (unemployment is a major problem in Spain, it decreased to 14.55% of the active population in 2018). If harvesting would increase from 15 to 30 million m3 a year, forestry employment could double, from the current 155 000 to around 300 000 jobs. The Forestry Sector has an increasing influence on rural development through forestry, hunting, recreational use and rural tourism.
Supply Base Report: Page 6 More than 2/3 of the Spanish forest area is privately owned, what must be taken into account when encouraging certain forest policies. Spanish forests are to a large extent abandoned. The forests are accumulating fuel biomass in excess, which increases the risk of large forest fires, and yet the use of its biomass for energy purposes is not considered an attractive business by energy companies.
Ecoregions
Supply Base Report: Page 7 There are two main different ecoregions3 in Mainland Spain, each of them can be subdivided:
- Temperate broadleaf and mixed forests 1. Cantabrian mixed forests 2. Pyrenees conifer and mixed forests - Mediterranean forests 3. Iberian conifer forests 4. Iberian sclerophyllous and semi-deciduous forests 5. Northeastern Spain and Southern France Mediterranean forests 6. Northwest Iberian montane forests 7. Southeastern Iberian shrubs and woodlands 8. Southwest Iberian Mediterranean sclerophyllous and mixed forests
1 2
6 5
3
4
8 7
According to IUCN,4 “Spain is one of the most diverse countries in terms of biodiversity in the European Union. Situated between the Atlantic and the Mediterranean, Spain contains four of the nine biogeographic regions of the European Union (Atlantic, Alpine, Mediterranean and Macronesian), which provide the coexistence of a large number of species of fauna and flora. The country is located in one of the 25 biodiversity hotspots in the world, thanks to its high rate of endemisms, which requires specific steps to address conservation issues… Protected areas in Spain cover more than 15 million hectares, representing over 27% of its land are”
Because of this, the conservation of HCVF is critical. Biomass production is not a controversial sector, since most part of the feedstsock is coming from co-products, cleanings and pruning. Forest operations in protected areas are limited and controlled, with low impacts in the remain ecosystem.
3 According to WWF 4 https://www.iucn.org/regions/europe/resources/country-focus/spain?page=1
Supply Base Report: Page 8 Despite this diversity, there are no CITES species in Spain.
Biomass sector
More specifically, the biomass sector in Spain is still young, especially if we take into account all its potential5. The overall dynamics of the Spanish forest sector is promoted or supported by other sectors like: Pulp and paper Board panels Saw timber Silvopastoral (forest grazing for pork, cows,etc.)
There are also other specific Mediterranean non-timber forest products (NTFPs) such as cork, resin and pine cones, with great social and economic relevance in rural areas.
2.2 Actions taken to promote certification amongst feedstock supplier
BSL encourages FSC and PEFC certification among its suppliers, underlining the advantages and importance of forest certification to the wood sector
2.3 Final harvest sampling programme
BSL feedstock comes 0-20% from forest residues from final fellings or from forest maintenance operations, and aproximately 80-100% comes from logs of final fellings. Most of final fellings are small, around 2 ha or less. In the north clear cuts are restricted to maximally 10 ha. Reforestation is performed by the land owners.
From the species used by BSL, several Pines (Pinus pinaster, Pinus sylvestris, Pinus nigra, Pinus pinea) can have a planned forest management period of more than 40 years, but BSL only uses low grade roundwood. Eucalyptus, poplar and Pinus radiata are fast-growing species, with a rotation of less than 40 years.
BSL examines the forest plots and their age before harvest. The age of the forest is indicated on the comunications / authorizations of harvesting.
2.4 Flow diagram of feedstock inputs showing feedstock type [optional]
Woodchipping in the Port of Ferrol:
5 http://www.unionporlabiomasa.org/pdf/Balance_Biomasas.pdf
Supply Base Report: Page 9 Forest operations Chipping by: by: •BSL Woodfiber Storage (Port of •Suppliers Ferrol) •BSL Woodfiber
Loadding of vessel Client
Logging operations (Ports of Burela, Cariño and Ribadeo):
Forest operations by: Storage (Ports of Burela, Cariño, • Suppliers Ribadeo) • BSL Woodfiber
Loadding of Client vessel
Woodchipping in the Port of Huelva:
Supply Base Report: Page 10 Forest Chipping by: operations by: Storage (Port • Supplier (as a of Huelva) • Suppliers subcontractor)
Loadding of Client vessel
2.5 Quantification of the Supply Base Supply Base a. Total Supply Base area (ha): Asturias: 770.000 ha Galicia: 2.030.680 ha Andalucía: 4.467.070 ha Castilla y León: 4.815.357 ha TOTAL: 12.093.660 ha b. Tenure by type (ha): 73% Privately owned and 27% Public owned c. Forest by type (ha): 100% Temperate Forest d. Forest by management type (ha): 12% Plantation, 88% Managed Natural e. Certified forest by scheme (ha): FSC: 313 thousand ha (2020) PEFC 2.311 thousand ha (2020)
Feedstock f. Total volume of Feedstock: 0 - 200.000 tonnes (127.546 tonnes of round wood for pulp and paper industries) g. Volume of primary feedstock: 0 - 200.000 tonnes (127.546 tonnes of round wood for pulp and paper industries) h. List percentage of primary feedstock (g), by the following categories: - 80%-100% Certified to an SBP-approved Forest Management Scheme (FSC and PEFC) - 0%-20% Not certified to an SBP-approved Forest Management Scheme i. List all species in primary feedstock, including scientific name Maritime pine (Pinus pinaster) Champion oak (Quercus rubra) Scots pine (Pinus sylvestris) Weeping willow (Salix babylonica) Monterey pine (Pinus radiata) Acacia (Acacia spp.) Austrian pine (Pinus nigra) Planes (Platanus spp.) Stone pine (Pinus pinea) Chestnuts (Castanea spp.)
Supply Base Report: Page 11 Eucalypt (Eucalyptus spp.); Ash (Fraxinus spp.) Poplar (Populus spp.). Alder (Alnus spp.) Portuguese oak (Quercus fagines) j. Volume of primary feedstock from primary forest None k. List percentage of primary feedstock from primary forest (j), Not applicable l. Volume of secondary feedstock: None m. Volume of tertiary feedstock: None
Supply Base Report: Page 12 3 Requirement for a Supply Base Evaluation
SBE not SBE completed completed
☐
BSL Woodfiber has chosen to implement the SBP Supply Base Evaluation method (SBP Standard 1), to cover the small percentage of inputs (less than 20%) that are no SBP-approved Forest Management Scheme compliant.
BSL Woodfiber is compromised to obtain international recognition considering the quality and sustainability of forest operations and is motivated to cooperate with forest harvesting companies to implement risk mitigation measures.
Supply Base Report: Page 13 4 Supply Base Evaluation
4.1 Scope
The scope of this SBE covers:
- Galicia: operations of logging and chipping - Principado de Asturias: operations of logging - Castilla y León: operations of logging - Andalucía: operations of logging and chipping
4.2 Justification
The approach used in this SBE is risk assessment, according to legality and sustainability principles. The following sources of information were studied to assess the risks: - Applicable legislation; - Reports of official organizations; - National statistics; - FSC National Risk Assessment 2018; - Scientific studies; - Mass media sources; - Company specific information of BSL Woodfiber and its suppliers.
Besides that, the SBR and SBE were published online for stakeholder consultation. Stakeholders were proactively approached and invited to provide their input and comments.
4.3 Results of Risk Assessment
Several indicators showed specified risks, but BSL Woodfiber had standard operational procedures in place mitigating these risks, already before start of preparing for SBP certification, and also some additional measures were implemented.
The result of the risk assessment was the identification of 4 specified risks within the supply base related to indicators 2.2.2, 2.3.2, 2.4.2 and 2.8.1.
Table 4.3: Risk Assessment Results of BSL SBP Indicators of specified risk Indicator
2.2.2 The Biomass Producer has implemented appropriate control systems and procedures for verifying that feedstock is sourced from forests where management maintains or improves soil quality. The European Court of Auditors (ECA) research indicates that up to 44% of Spain runs a great risk of soil erosion. According to JRC Science for Policy report “Condition of agricultural soil: Factsheet on soil erosion”, 2017, Soil degradation by water erosion is particularly significant in Spain (3,7 t/ha/year) in years 2000-1012. This indicator is classified as Specified risk for “Mediterranean forests” (Andalucía), because of the erosion, desertification and loss of nutrients.
Supply Base Report: Page 14 2.3.2 Adequate training is provided for all personnel, including employees and contractors (CPET S6d). Training in the forest sector is quite weak. Legislation is mainly focused on health and safety, and there are not specific topics for forestry sector despite the danger of the forest operations. The use of subcontractors and self-employees are quite common on forest sector. Conditions of these forest workers could be one of the weakest points of forestry sector. 2.4.2 The Biomass Producer has implemented appropriate control systems and procedures for verifying that natural processes, such as fires, pests and diseases are managed appropriately. Forest fires: Forest treatments like thinning and clearing has a positive impact on the prevention of forest fires, as it reduces the density and biomass in the forest cover. And forest operations are not considered a relevant cause of forest fires. Despite this, BSL has in place systems to prevent forest fires.
Pest and diseases: The infractions detected with pine wood nematode and its potential impact is so high, the risk related to Pest and diseases is considered Specified Risk. 2.8.1 The Biomass Producer has implemented appropriate control systems and procedures for verifying that appropriate safeguards are put in place to protect the health and safety of forest workers (CPET S12). The forestry sector is, after the construction sector, the one with the highest rate of occupational accidents and occupational diseases.
A more detailed analysis of the main sources of accidents in forestry work reveals that the forestry exploitation phase and, more specifically, the felling, felling and cutting with chainsaws are the forestry activities with the highest accident rate. The use of the chainsaw, which is a widespread tool in rural areas, causes 18% of accidents.
According to International Labour Organization, there have been an increase in fatal and non- fatal injuries related to agriculture, forestry and fishing sector in Spain.
Regardless of its legal requirements, Spain still performs poorly on work safety. Outsourcing and self-employed services are quite common in forest sector
4.4 Results of Supplier Verification Programme
BSL Woodfiber has studied all the indicators of SBP Standard 1 in relation to the scope of the SBE and categorised all indicators as either low risk or specified risk. Therefore, a Supplier Verification Program was not needed.
4.5 Conclusion
Discussion points and opinions on possible sustainability risks in feedstock procurement in Spain have been studied in detail over the last years by a broad group of stakeholders and institutes. In general, there is a good understanding of the necessity of performing additional mitigating measures.
Forest ownership in Spain is fragmented; there are many small holders, it is therefore clear that several forest management tasks, starting with an evaluation of ecological, economic and social impacts of operational plans should be considered before and during the forest operations commence.
Supply Base Report: Page 15 Within the framework of the FSC Controlled Wood and Due Diligence evaluations, several mitigation measures were already in place.
Four SBP indicators were assessed ‘specified risk’, of which 1 partly.
These specified risks are, however, well mitigatable. Moreover, corruption in Spain is relatively low, what is confirmed by the CPI score of 58 points (2018). Forestry in Spain has a long history and a sound framework of relevant institutes.
Supply Base Report: Page 16 5 Supply Base Evaluation Process
The Supply Base Evaluation (SBE) was performed by Rogelio Gonzalez, Ineva, with the internal support of Cecilia Nolasco from the BSL Chain of Custody Team and her manager, Pedro Rodrigues, also responsible for the operations of the BSL Group, being directly involved in prospecting and supporting the decision to buy wood (raw material) ), as well as inspections / visits to the field.
Rogelio Gonzalez (forestry Engineer) has around 20 years of experience in forest FSC and PEFC certification. He passed the SBP auditor exams in 2019.
The Supply Base Evaluation Process started with public reports into consideration, as also national legislation, national policies, and publications of relevant institutions and authorities. During the preparation of the SBE, a detailed baseline study was made for each of the SBP indicators. A summarised description on each indicator is presented in Annex 1 and covers all relevant indicators of SBP Standard 1.
The certification team took the following steps in developing the Supply Base Evaluation: • Study the draft SBP National Risk Assessments and compare it with BSL Woodfiber’s own experience and procedures • Study publicly available reports on the legality and sustainability risks in Spain; • Develop the Risk Assessment and Risk Mitigation Measures in cooperation with BSL Woodfiber’s suppliers; • Develop procedures and check-lists related to the assessment of forestry operations and feedstock procurement; • Train the harvesting teams of the feedstock suppliers; • Evaluate the effectiveness of the Risk Mitigation Measures in practice (during harvesting operations).
The Forestry Manager is a specialist, who has been involved in wood procurement and field inspections for many years.
The documents stated below are of importance to the management system: Procedure on the origin of raw material; Best practices regarding harvesting operations; Sampling and monitoring procedure; Training program Assessment reports and checklists on: o Planned forest operations (field inspections); o Primary feedstock suppliers (companies); Complaint procedures.
The Risk Assessment (RA) did not result in inconclusive indicators (see paragraph 4.3).
Supply Base Report: Page 17 6 Stakeholder Consultation
The risk assessment has been sent to a group of over 100 stakeholders and leading experts in nature conservation and forestry. The stakeholder consultation was open from 24th June, till 24th august 2020
6.1 Response to stakeholder comments
Provide a summary of all stakeholder comments received and how the comments were taken into consideration in the SBE process.
Comment 1:
Response 1:
Comment 2:
Response 2:
Supply Base Report: Page 18 7 Overview of Initial Assessment of Risk
Table 1. Overview of results from the risk assessment of all Indicators (prior to SVP)
Initial Risk Rating Initial Risk Rating Indicator Indicator Specified Low Unspecified Specified Low Unspecified X X 1.1.1 2.3.1 X X 1.1.2 2.3.2 X X 1.1.3 2.3.3 X X 1.2.1 2.4.1 X X 1.3.1 2.4.2 X X 1.4.1 2.4.3 X X 1.5.1 2.5.1 X X 1.6.1 2.5.2 X X 2.1.1 2.6.1 X X 2.1.2 2.7.1 X X 2.1.3 2.7.2 X X 2.2.1 2.7.3 X X 2.2.2 2.7.4 X X 2.2.3 2.7.5 X X 2.2.4 2.8.1 X X 2.2.5 2.9.1 X X 2.2.6 2.9.2 X X 2.2.7 2.10.1 X 2.2.8 X 2.2.9
Supply Base Report: Page 19 8 Supplier Verification Programme
8.1 Description of the Supplier Verification Programme
The Risk Assessment had no inconclusive indicators (no ‘unspecified risks’). The results have been discussed with feedstock suppliers and other stakeholders. The indicators, risks, and mitigation measures were clear.
8.2 Site visits
Not applicable.
8.3 Conclusions from the Supplier Verification Programme
Not applicable.
Supply Base Report: Page 20 9 Mitigation Measures
9.1 Mitigation measures
The mitigation measures per indicator are given in the table below.
Table 9.1 Risk Mitgation Measeures Summary
Supply Base Report: Page 21 The Biomass Producer has implemented appropriate control systems and procedures 2.2.2 for verifying that feedstock is sourced from forests where management maintains or improves soil quality (CPET S5b). BSL Woodfiber evaluates the impacts of its operations about the erosion, desertification and loss of nutrients in Andalucía, through the implementation of the Manual of good practices: • Were needed, considering the soil and groundwater level, only selective cuttings and small clear cuts of maximally 5 ha are planned; Mitigation • Leave nutrients in the forests, mainly the green fraction of forest residues less or equal to 3 cm (on the other hand other forest residues need to be cleared to prevent forest measures fires. • Do not operate in near-water areas.
On dry locations selective cuttings are often preferable, because the ground gets less direct impact of the sun and the forest can maintain soil quality and regenerate naturally. Adequate training is provided for all personnel, including employees and contractors 2.3.2 (CPET S6d). BSL Woodfiber trains its personnel on all relevant aspects and demands the same from its feedstock suppliers. • Training records obligatory according to legislation and records of qualification are collected during supplier qualification process and checked during supplier inspections; Mitigation • Training conducted by BSL in several fields, including identification of key ecosystems, measures habitats and species biodiversity (annually and based on the results of field visits); • Training on best forest management practices.
BSL performs supplier inspections: the training records, (new) workforce, and the hiring of specialists. The level of knowledge of personnel is inspected during site visits. The Biomass Producer has implemented appropriate control systems and procedures 2.4.2 for verifying that natural processes, such as fires, pests and diseases are managed Forest fires appropriately (CPET S7b). Forest fires: • Visual inspection of the plot before harvesting; • Implementation of forest fire fighting measures according to law; Mitigation • Best forest practices. measures Pest and diseases • BSL Woodfiber do no accept wood cooming from nematode affected area. The Biomass Producer has implemented appropriate control systems and procedures 2.8.1 for verifying that appropriate safeguards are put in place to protect the health and safety of forest workers (CPET S12). BSL has a control system and adequate procedures on the health and safety of forest workers.
BSL demands the same from its feedstock suppliers and checks the health safety of harvesting personnel during its monitoring (administrative and field) inspections. • Supplier qualification process and inspections of the supplier’s administration: o Insurances and aptitude forms; o Social Security; o Present workforce and training (new) personnel; Mitigation o Health and safety procedures; o Training records and hiring of specialists; measures o Records of Personal Protection Equipment (PPE) distribution; o Records of machinery safety tools and equipment on documental register; o Medical record for employment. • Field inspection supplier: o Protective equipment use; o Medical kit; o Fire extinguisher; o Respect of safety distances; o Level of knowledge of personnel.
Supply Base Report: Page 22
9.2 Monitoring and outcomes
With the implementation of the SBP, BSL Woodfiber reinforces its commitment with its principles, while adopting a performance model based on structured procedures for systematic implementation.
Under this framework, the current procedures provide practices that make it possible to evaluate, at regular intervals, the results of the SBP. That means, whether it maintains an adequate level of performance and in accordance with the current Standards and requirements.
BSL uses the information collected from monitoring (through field actions, including audits) to verify that it is achieving the expected results, including the improving of its internal and external performance, the degree of compliance with legal, normative and others obligations needed for reaching the objectives defined by SBP.
The monitoring and measurement actions related with the scope of the SBP include:
• Document and other available information analysis, • Analysis of the records and other information associated with the control of origin, legality and other SBP compliance requirements / criteria applicable to the control of the raw material supply base; • Visits / contacts, with relevant stakeholders; • Training and Information: • Audits, • Treatment of Non-Conformities, Complaints or other Concerns of Stakeholders, including internal follow-up actions and with their subcontractors and suppliers. • Analysis and review of results and decision making, based on the information resulting from the monitoring and measurement carried out, as well as regarding any changes, with an impact on the SBP, ensuring that they are identified, their consequence is determined in the achievement of the desired results and, • Changes are planned in order to mitigate negative effects on the intended results.
The anticipation to situations with the potential to generate non-compliance, will result from proactive monitoring by the entire BSL structure and the creation and development of cooperative relationships with its suppliers and business partners.
Supply Base Report: Page 23 10 Detailed Findings for Indicators
Detailed findings for each Indicator are given in Annex 1.
Supply Base Report: Page 24 11 Review of Report
11.1 Peer review
The report was sent to a large number of stakeholder, who are experts in different related fields. Therefore, a peer review was not necessary.
11.2 Public or additional reviews
The SBR and SBE were sent to a large group of stakeholders for review (more information in Chapter 6). The SBR and SBE are always available at the SBP web site and BSL web site. Any interested party can contact Cecília Nolasco by mail [email protected] to provide its comment, which will be obligatory taken into consideration
Supply Base Report: Page 25 12 Approval of Report
Approval of Supply Base Report by senior management
Cecília Nolasco Report Chain of Custody Team 24-07-2020 Prepared Pedro Rodrigues by: Name Title Date The undersigned persons confirm that I/we are members of the organisation’s senior management and do hereby affirm that the contents of this evaluation report were duly acknowledged by senior management as being accurate prior to approval and finalisation of the report.
Report Jaime Reis Administration 24-07-2020 approved by: Name Title Date
Supply Base Report: Page 26 13 Updates
Initial audit. Not applicable.
13.1 Significant changes in the Supply Base
Initial audit. Not applicable.
13.2 Effectiveness of previous mitigation measures
In the development process of the SBE, additions have been made to BSL’s procedures and evaluation tools. The measures were tested in practise. They proved to be effective.
13.3 New risk ratings and mitigation measures
Initial audit. Not applicable.
13.4 Actual figures for feedstock over the previous 12 months
Based on the historical data, it’s in the range 0 - 200,000 tons (127.546 tonnes of primary raw material roun wood - 2019).
13.5 Projected figures for feedstock over the next 12 months
Regarding the projection of the raw material for the current year, and based on the expected evolution and the historical data of wood sales, it will be in the range of 0 to 200,000 tons (from 10,000 to 25,000 tons of wood for the pulp and paper industries)
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