SGS QUALIFOR Doc. Number: AD 36-A-05
(Associated Document) Doc. Version date: 24 May 2007 Page: 1 of 74
FOREST MANAGEMENT CERTIFICATION REPORT
SECTION A: PUBLIC SUMMARY
Project Nr: 6092 ZA
Client: Komatiland Forests
Web Page: www.safcol.co.za
Private Bag X11201 Address: Nelspruit, 1200.
Country: South Africa
SGS-FM/CoC- Certificate Type: Certificate Nr. Forest Management 000068
Date of Issue Date of expiry:
SGS Forest Management Standard (AD33) adapted for South Africa version 04 of 29 March Evaluation Standard 2010
Forest Zone: Softwood and Hardwood Plantations
Total Certified Area 187 320.31 ha
Scope: The management of exotic plantations in the Mpumalanga, KwaZulu-Natal and Limpopo provinces of South Africa, for the production of softwood and hardwood timber products.
Location of the FMUs The FMU’s are located in the provinces of Limpopo, Mpumalanga and northern Kwa-Zulu included in the scope Natal.
Company Contact Jan Huyser Person:
Address: Private Bag X11201, Nelspruit 1200, South Africa.
Tel: +27 (0) 83 627 8607
Fax +27 (0) 13 752 6204
Email: [email protected]
Evaluation dates:
Main Evaluation 6 – 13 June 2007
Re-Assessment COF 26 July 2007 Surveillance 1 6 – 10 October 2008
SGS services are rendered in accordance with the applicable SGS General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm
SGS South Africa (Qualifor Programme) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 -South South Africa Systems and Services Certification Division Contact Programme Director at t. +27 11 681-2500 [email protected] www.sgs.co m/forestry AD 36-A-05 Page 2 of 74
Surveillance 2 26 – 30 Oct 2009
Surveillance 3 11 – 15 October 2010
Surveillance 4
Copyright: © 2010 SGS South Africa (Pty) Ltd All rights reserved
AD 36-A-05 Page 3 of 74
TABLE OF CONTENTS
1. SCOPE OF CERTIFICATE ...... 5 2. COMPANY BACKGROUND ...... 12 2.1 Ownership ...... 12 2.2 Company Key Objectives ...... 12 2.3 Company History ...... 13 2.4 Organisational Structure ...... 13 2.5 Ownership and Use Rights ...... 13 2.6 Other Land Uses ...... 13 2.7 Non-certified Forests ...... 14 3. FOREST MANAGEMENT SYSTEM ...... 14 3.1 Bio-physical setting ...... 14 3.2 History of use ...... 15 3.3 Planning process ...... 15 3.4 Harvest and regeneration ...... 16 3.5 Monitoring processes ...... 17 4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT ...... 17 4.1 Social aspects ...... 17 4.2 Environmental aspects ...... 18 4.3 Administration, Legislation and Guidelines ...... 18 5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING ...... 21 6. PREPARATION FOR THE EVALUATION ...... 22 6.1 Schedule ...... 22 6.2 Team ...... 22 6.3 Checklist Preparation ...... 22 6.4 Stakeholder notification ...... 22 7. THE EVALUATION ...... 22 7.1 Opening meeting ...... 22 7.2 Document review ...... 23 7.3 Sampling and Evaluation Approach...... 23 7.4 Field assessments ...... 23 7.5 Stakeholder interviews ...... 23 7.6 Summing up and closing meeting ...... 24 8. EVALUATION RESULTS ...... 24 8.1 Findings related to the general QUALIFOR Programme ...... 25 PRINCIPLE 1: Compliance with law and FSC Principles ...... 25 PRINCIPLE 2: Tenure and use rights and responsibilities ...... 26 PRINCIPLE 3: Indigenous peoples’ rights ...... 26 PRINCIPLE 4: Community relations and workers rights ...... 27 AD 36-A-05 Page 4 of 74
PRINCIPLE 5: Benefits from the forest ...... 29 PRINCIPLE 6: Environmental impact ...... 30 PRINCIPLE 7: Management plan ...... 33 PRINCIPLE 8: Monitoring and evaluation ...... 35 PRINCIPLE 9: High Conservation Value Forests ...... 36 PRINCIPLE 10: Plantations ...... 37 9. CERTIFICATION DECISION...... 39 10. MAINTENANCE OF CERTIFICATION ...... 39 11. RECORD OF CORRECTIVE ACTION REQUESTS (CARs) ...... 42 12. RECORD OF OBSERVATIONS ...... 50 Observations raised during the last Surveillance of the previous (2nd) Certificate: ...... 59 13. RECORD OF COMPLAINTS ...... 74
ASSOCIATED DOCUMENTS (not part of the Public Summary)
AD 20: Evaluation Itinerary AD 21: Attendance Record AD 26: Corrective Action Requests AD 36-B: Evaluation - Observations and Information on Logistics AD 36-C: Evaluation – Information on Group Members AD 38: Peer Review Report AD 40: Stakeholder Reports Evaluation team CV’s List of stakeholders contacted
Complaints and Disputes
Procedures for submitting complaints, appeals and disputes, and the SGS processing of such are published on www.sgs.com/forestry. This information is also available on request – refer contact details on the first page.
AD 36-A-05 Page 5 of 74
INTRODUCTION
The purpose of the evaluation was to evaluate the operations of Komatiland Forests against the requirements of the QUALIFOR Programme, the SGS Group’s forest certification programme accredited by Forest Stewardship Council.
1. SCOPE OF CERTIFICATE The scope of the certificate falls within the Temperate Forest Zone and includes 18 Forest Management Units (FMUs) as described below.
Description of FMUs: Description Ownership Area (ha) Longitude E/W Latitude N/S Belfast - Highveld/ Belfast Komatiland Forests 6 245.45 30 02 11 -25 35 38 Berlin - Highveld/Kaapshehoop Komatiland Forests 13 583.35 30 44 46 -25 34 01 Jessievale - Highveld/Ermelo Komatiland Forests 18 721.61 30 32 35 -26 17 04 Ngome - Highveld/Vryheid Komatiland Forests 3 700.51 31 27 38 -27 49 20 Uitsoek - Central/Nelspruit-Sudwala Komatiland Forests 9 911.62 30 34 12 -25 16 51 Nelshoogte - Highveld/Barberton Komatiland Forests 11 704.34 30 48 59 -25 49 26 Roburnia - Highveld/Amsterdam Komatiland Forests 15 207.71 30 44 47 -26 40 33 Witklip - Central/Witrivier Komatiland Forests 9 883.68 30 55 04 -25 13 20 Bergvliet - Central/Sabie Komatiland Forests 13 248.9 30 51 60 -25 04 58 Brooklands - Central/Sabie Komatiland Forests 12 779.93 30 47 16 -25 16 14 Spitskop - Central/Sabie Komatiland Forests 4 659.43 30 49 57 -25 08 10 Tweefontein - Central/Sabie Komatiland Forests 18 967.77 30 44 42 -25 03 13 Blyde - Northern/Graskop Komatiland Forests 6 780.69 30 51 09 -24 50 38 Morgenzon - Northern/Pilgrims Rest Komatiland Forests 6 142.85 30 43 05 -24 49 07 Wilgeboom - Northern/Hazyview Komatiland Forests 9 339.16 30 56 29 -24 55 57 Woodbush - Northern/Tzaneen Komatiland Forests 5 550.28 30 00 12 -23 47 36 Entabeni - Northern/Louis Trichardt Komatiland Forests 16 997.8 30 14 50 -23 00 33 New Agatha - Northern/Tzaneen Komatiland Forests 3 895.19 30 09 42 -24 00 41 TOTAL 187 320.31
Size of FMUs: Nr of FMUs Area (ha) Less than 100ha 0 0 100 to 1000 ha in area 0 0 1001 to 10000 ha in area 10 66 108.9 More than 10000 ha in area 8 121 211.41 Total 18 187 320.31
AD 36-A-05 Page 6 of 74
Total Area in the Scope of the Certificate that is: Area (ha) Privately managed 187 320.31 State Managed 0 Community Managed 0
Composition of the Certified Forest(s) Area (ha) Area of forest protected from commercial harvesting of timber and managed primarily for 59 645,96 conservation objectives Area of forest protected from commercial harvesting of timber and managed primarily for 596,46 production of NTFPs or services Area of forest classified as “high conservation value forest” 39029.05 Total area of production forest (i.e. forest from which timber may be harvested) 127 676,31 Area of production forest classified as “plantation” 127 676,31 Area of production forest regenerated primarily by replanting 127 676,31 Area of production forest regenerate primarily by natural regeneration 0
List of High Conservation Values Description Notes Riparian zones Minor CARs 02 and 04 raised Wetlands Minor CAR 02 raised Natural Forests Well managed and monitored Ecotones Forest ecotones well managed Grasslands Monitoring taking place Cliffs, Rocky outcrops and waterfalls. Waterfalls recorded as ASI’s Sites of special interest Well managed and identified RT & E species. Minor CAR 08 raised
List of Timber Product Categories Product Class Product Type Trade Name Category Species Wood in the Logs of coniferous Pine Conifer Pinus patula rough wood Pinus taeda
Pinus elliottii For the other pinus species see the list below Wood in the Logs of non- Eucs Hardwood Eucalyptus grandis rough coniferous wood Gums Eucalyptus camaldulensis See other eucs below
AD 36-A-05 Page 7 of 74
Annual Timber Production Maximum Annual Sustainable Species (common Species (botanical name) Area (ha) Yield (m3) name) Projected Actual Mexican White Pinus ayacahuite Pine 5.67 62 94 Pinus caribaea Caribbean Pine 134.22 1,634 4,611 Pinus chiapensis 16.38 261 127 Pinus durangensis 7.58 116 290 Pinus elliottii Slash Pine 33928.7 400,412 417,926 Pinus elliottii x P.caribaea 11305.48 136,751 13,064 Pinus greggii/P.leiophylla 1.05 8 24 Pinus greggii Gregg’s Pine 1271.49 12,652 4,301 Pinus kesiya/P.caribaea 3.85 91 250 Pinus kesiya/P.taeda 2.28 24 113 Pinus kesiya Khasi Pine 470.91 6,917 11,103 Smooth-leaved Pinus leiophylla Pine 11.94 130 174 Pinus maximinoi/P.chiapensis 16.12 159 0 Pinus massoniana/P.taiwanensis 0.78 7 25 Pinus massoniana Masson’s Pine 0.67 6 17 Pinus maximinoi 54.26 1,063 1,204 Pinus michoacana 6.67 44 80 Pinus mixed 57.73 708 517 Pinus oocarpa/P.taeda 13.68 199 361 Pinus oocarpa/P.tecunumannii 4.4 52 90 Pinus oocarpa Ocote Pine 310.22 4,986 7,718 Pinus patula/P.elliottii 37.23 424 207 Pinus patula Patula Pine 61135.53 881,859 783,043 Pinus pringlei Pringle’s Pine 86.21 1,196 1,437 P.pseudostrobus/P.montezuma Pseudostrobus e Pine 102.27 1,368 2,923 Pinus patula x P.tecunumannii 21.36 332 0 Pinus radiate Monterey Pine 17.05 205 206 Pinus roxburghii Chir Pine 12.33 243 797 Pinus rudis 0.33 5 4 Pinus taeda Loblolly Pine 4343.07 48,298 112,223 Pinus taiwanensis 0.9 5 35 Pinus tecunumannii 457.61 7,879 7,603 AD 36-A-05 Page 8 of 74
Acacia mearnsii Black Wattle 1324.08 4,124 12,202 Eucalyptus camaldulensis 0.93 42 18 Eucalyptus cloeziana 679.11 7,718 15,800 Eucalyptus grandis 4771.18 256,095 70,136 E.grandis x E.camaldulensis 705.81 8,886 8,763 Eucalyptus mixed 4.82 41 15 Totals 121,323.9 1,785,002 1,477,501
2009 SA02 update Due to the wind damage in 2007 and then the damage due to wild fires, the Annual Allowable Cut has been reduced to 1,390,000 m3 per annum.
List of Timber Product Categories Product Notes Pruned and unpruned round wood from Pine and Eucalyptus Sawn wood working circles Pruned round wood from Pine working circles, specific Veneer dimensions. Pulp wood Small wood from Pine, Eucalyptus and Acacia working circles Poles Eucalyptus poles mainly from Eucalyptus Poles working circle Fire wood/ Waste Short and small wood remaining after harvesting operations. Mining timber Eucalyptus with specific dimensions Bark Bark from black wattle compartments
Approximate Annual Commercial Production of Non-Timber-Forest-Products Product Species Unit of measure Total units Botanical Name Common Name) Mushrooms Boletus edulus Button mushroom - - 2007: Information not available – see Minor CAR 08 raised in this regard. It is done by private company on concession and does not go through KLFs books.
Approximate Annual Commercial Production of Non-Timber-Forest-Products Product Species Unit of Total units measure Botanical Name Common Name) Sugarcane 324095.1 Mushrooms 58334 Biesiegras 79.09 Fishing 2651.84 Grazing 9123.08 AD 36-A-05 Page 9 of 74
Approximate Annual Commercial Production of Non-Timber-Forest-Products Product Species Unit of Total units measure Botanical Name Common Name) Picnic 22097.92 Lakenvlei 526808.9 Ecotourism 2238911 TOTAL 3182100.93
Lists of Pesticides Product Name Quantity Used Area of application MA SA1 SA2 SA3 SA4 MA SA1 SA2 SA3 SA4 Access 85.4 219.1 74.2 75.8 307. 868. 138. 1294 32 79 49 .27 Actipron 1967.5 685.6 897.2 1659. 5403 5445 6617 8140 44 .2 .7 .2 .655 Add 2 20 0 0 0 15 0 0 0 Aqua matrix Clear 71.4 0 0 0 50 0 0 0 Basta 0 0 0 1954. 0 0 0 1106 2 .26 Beefup oil 1740.7 1789. 1795 1688. 1799 2535 2213 1101 0 5 .1 .7 .3 9.52 Benlate / Benomyl 18.3 12.2 13.4 6.272 Nurs Nurs Nurs Nurs ery ery ery ery Bitam 0 20 22 5 0 95.8 14.9 7.18 Blue dye 55.5 86.5 49 0 1199 736. 562. 0 2 3 Blupro 850 0 0 0 60 0 0 0 Browser 370 0 0 0 238. 0 0 0 3 Brushoff 18387 4696. 2.75 0 1545 383 27.1 0 3 .9 Chemical Dye 6.9 10 12 44.5 108 232. 5.1 998. 4 63 Chlorine pills 614 1761 1620 245 Nurs Nurs Nurs Nurs ery ery ery ery Chopper 1963.9 3486 2610 3399. 332. 1031 1170 1312 4.3 1.6 4 2 5.6 5.7 5.20 2 Clearout 21450.4 1783 1106 3727 6275 5717 3958 1524 4.8 6 .6 .3 .72 Confront 2910.8 59.2 0 0 290. 66.4 0 0 3 Crop oil 24.9 0 0 0 161. 0 0 0 6 Decis 1 0 0 0 1 0 0 0 AD 36-A-05 Page 10 of 74
Lists of Pesticides Product Name Quantity Used Area of application Ecored dye 29 36.5 22 0 27 502. 598. 0 1 3 Eco Imazypyr 0 0 125 235 0 0 226. 880. 7 57 Eco rat 0 0 1 0 0 0 0 0 Erase 6935 3365 0 0 2311 764. 0 0 .5 5 Erase granules 100 0 0 0 62.7 0 0 0 Everdip 2175 2725 2350 1625 Nurs Nurs Nurs Nurs ery ery ery ery Fertilizer 97 578 119 0 53.9 394. 47.4 0 2 Fine Sorb 80 50 0 50 1420 0 0 0 Flame Bloc 25 0 0 0 0 0 0 0 Folicur 30 10 20 11 Nurs Nurs Nurs Nurs ery ery ery ery Garlon 15482.2 943.1 3492 3787. 1475 1134 6907 1888 412 0 2.7 .9 9.03 Glyphogan 930 0 0 0 492. 0 0 0 1 Glyphosate 6536.2 2932 1460 1285 3569 2374 8490 5307 5.5 9 9.44 .8 .2 .14 Gramoxone 1794.6 1087 694 0 2447 763 207. 0 8 Hatchet 135 357 0 25 390 1552 0 11 .2 Herbiplus 597.6 298.1 2440 113 275. 977. 2164 73.6 55 1 6 .6 5 Icon 20 0 0 0 Villa 0 0 0 ge Jeyes Fluid 1750 2125 1055 2395 Nurs Nurs Nurs Nurs ery ery ery ery Kemprin 0 10 2 0 0 151. 34 0 7 Kilo 1429 3843. 30 0 686. 1479 1330 0 3 1 5.5 .6 Lumberjack 16957.3 812.4 0 70 7811 1812 0 2087 .1 .8 .24 Mamba 25481.2 2285 1137 2301 1032 9622 7674 1702 4.4 88.6 3.33 6.8 .9 .7 9.47 MAP 2550 4653 3580 1543 2 561. 29.4 6.29 5 MCW EOS 0 38.5 0 0 0 48.9 0 0 MSMA 160 205 20 0 104. 97.1 28.1 0 1 Muscle-up 0 0 0 500 0 0 0 84.7 6 AD 36-A-05 Page 11 of 74
Lists of Pesticides Product Name Quantity Used Area of application N-Film-P 0 0 10 0 0 0 53.1 0 Nomix 0 0 555 0 0 0 113. 0 8 Nicanor 0 24.1 15.3 0 0 224. 353. 0 4 1 Nutrigro 7350 6300 5175 2375 Nurs Nurs Nurs Nurs ery ery ery ery Nutriplex 6825 6550 4275 1950 Nurs Nurs Nurs Nurs ery ery ery ery Octave 6 3 4 6.816 Nurs Nurs Nurs Nurs ery ery ery ery Paraquat 0 20 690 0 0 0 3362 0 .3 Penetrex 1075.9 0 200 0 592 0 32 0 Plenum 0 1068. 6370. 4358. 0 1368 5268 7135 6 8 2 .9 .41 Polythrin 10.2 237.2 0 0 90.2 19 0 0 Power up 190 1.9 0 0 2 1.2 0 0 Preeglone 0 48.5 24.5 0 0 100 18 0 Privicur N 15.3 6 10 9 Nurs Nurs Nurs Nurs ery ery ery ery Roundup 47614.4 3931 2143 3857 1784 1629 8683 7521 6.4 1.7 1.915 6.9 5.3 .3 .20 Roundup Max 8660.1 7535. 1831 5888. 1173 3205 1086 5560 4 7 6.7 .1 .8 .06 Round up Turbo 0 2013 36.3 0 0 2490 0 Roundup Weather Max 0 983.9 5089. 1359 0 338. 3741 7744 7 6.66 8 .4 .62 Round up Ultra 250 185.7 0 0 57.2 196. 0 0 7 Spill sorb 25 25 1050 0 Sporekill 0 50 50 5 Nurs Nurs Nurs Nurs ery ery ery ery Springbok 41.5 540.5 95.5 16 114. 144 138. 234. 2 6 7 Starane 816.3 552.2 9036 224.8 4975 3362 5181 5425 8.4 3 .7 .03 Stockosorb 35 50 0 0 33.6 110. 0 0 6 Sugar soap 7 1 0 0 0 0 0 0 Sultan 0 50 0 0 0 24.8 0 0 Timbrel 244.4 906.5 484.2 652.6 2090 6790 1707 1151 24 .5 .9 .5 9.45 Tomahawk 8822.9 1011 199.7 487.4 4840 3065 1323 1528 6 6 .2 .3 .2 .02 Tribel 0 50 0 0 0 57.8 0 0 AD 36-A-05 Page 12 of 74
Lists of Pesticides Product Name Quantity Used Area of application Triclon 205.1 964.2 33 0 2732 3961 136. 0 .3 .7 2 Tumbleweed 620 660 0 0 266. 256. 0 0 4 1 Ultra hume 32500 5000 0 0 Nurs Nurs 0 0 ery ery Viro-axe 21748.2 5682 922.7 1418. 2490 1734 1782 2552 6.8 25 .1 .2 .9 .2 Water absorbant 500 475 525 0 263 156. 325. 0 3 6 Wetcit 140 420 0 0 93.8 300. 0 0 4
2. COMPANY BACKGROUND
2.1 Ownership Komatiland Forests Pty (Ltd) is a subsidiary of the South African Forestry Company Ltd. (SAFCOL). SAFCOL is the commercial arm of the South African state owned forestry operated as an autonomous commercial entity.
2.2 Company Key Objectives
Objective Notes Commercial Sustainable development and optimisation of its assets and land value according to accepted commercial management practices and conservation principles. Procuring services and goods in accordance with own environmental standards and Broad Based Black Economic Empowerment legislation requirements. Social Promoting the long term well-being of employees, neighbouring communities, customers and other stakeholders by supporting social and economic development in accordance with statutory and specifically Employment Equity requirements Optimising multiple use of resources on a sustainable basis by allowing controlled public access to land and the sale of forestry and other products. Environmental Following a proactive approach to identify, minimize and manage potential impacts on the natural environment. Conserving biodiversity in natural ecosystems, protecting rare and endangered species, communities, habitats and archaeological and cultural artefacts.
AD 36-A-05 Page 13 of 74
2.3 Company History KLF Company was formed during 2001 as a special purpose vehicle to sell the plantations as part of ongoing privatization of the commercial sector of state forestry. The competition tribunal deemed it to be a monopolizing transaction in the sawlog industry. The preferred bidder withdrew their offer and subsequently the government reaffirmed the intention to privatize KLF – the process is ongoing at present. KLF comprises the former SAFCOL areas in KwaZulu-Natal’s Ngome region as well as Mpumalanga South and North. In addition four ex-South African state Department of Water Affairs and Forestry (DWAF) plantations are included namely Mamathola, Tathe Vondo, Redhill and Blairmore. KLF’s key objectives are the sustainable development and optimisation of its assets and land value according to accepted commercial management practices and conservation principles.
2.4 Organisational Structure GM Forest is at the head of the structure, a 6 tier responsibility can be attributed to this position: (1) District Manager North (Entabeni, New Agatha, Woodbush, Wilgeboom, Morgenzon and Blyde); (2) District Manager Central (Bergvliet, Brooklands, Witklip, Spitskop, Tweefontein, Uitsoek); (3) Forest Engineer (Engineer Civil, Roads techinicians, Maintenance Coordinator); (4) Logistic Manager (Operations Manager); (5) District Manager South (Belfast, Berlin, Jessievale, Ngome, Nelshoogte and Roburnia), and (6) IFLOMA. The organogram below was added during SA 2009.32, provided by KLF Management
2.5 Ownership and Use Rights KLF is a public tenure ownership. The land formally belongs to government and is currently leased to KLF in a long term lease agreement. This is also viewed against the backdrop of South Africa’s land reform under the new constitutional dispensation with various plantations subjected to land claims.
2.6 Other Land Uses Commercial and own ecotourism ventures including seven overnight hiking trails, a commercial lodge (Lakenvlei), mountain bike trails, day visitor facilities, horse trails, a forestry industry museum and joint ventures with associated tourism projects all form part of other land uses than timber production. NTFP’s (non-timber forest products) are utilized at various plantations – examples are mushroom AD 36-A-05 Page 14 of 74
collecting in the highveld FMU’s, bee-keeping, firewood collection, thatch collection and grazing of cattle.
2.7 Non-certified Forests
In addition to the forest areas covered in this assessment - certificate (SGS-FM/CoC-0068) in the Republic of South Africa, KLF is also responsible for the management of forestry land in Mozambique: The IFLOMA project. IFLOMA – (Industrias Florestais de Manica), SARL, is a public liability company, registered in Mozambique and was established in 1980 as a government initiative. KLF obtained 80% shareholding through a tender process on 1 April 2004, the government of Mozambique retains the remaining 20% shares through IGEPE (Institute for the Management of Government Shares). IFLOMA consists of 3 plantations (Bandula, Penhalonga and Rotanda) in the Manica Province of Mozambique. The surface area consists of approximately 25 000 ha in total of which around 7000 ha is planted with Pine and Eucalyptus (mainly Pine). The land is leased from the Mozambique Government on a 50 year lease, renewable for another 50 years. Only Eucalyptus and Pine trees are harvested, indigenous forest patches on the project land are being conserved. The KLF policy states clearly that a long term commitment exists to manage all landholdings in the spirit of the FSC P&C. IFLOMA is not in a position to apply for certification yet due to years of neglect from previous management as well as infrastructure collapse. The project is, however, managed with the future view of compliance with FSC P&C. Sound and mutually beneficial relationships with neighbouring communities in Mozambique are an essential aspect in the sustainability of the company’s operations in this project. Challenges are numerous including the cultural traditions/differences of communities living on the project land (impacts such as subsistence gardening, clearing of indigenous vegetation for farming plots etc.). The same management system that currently exists in the certified KLF plantations in RSA will be implemented at IFLOMA.
3. FOREST MANAGEMENT SYSTEM
3.1 Bio-physical setting KLF consists of 18 Forestry Management Units (FMU’S), spread over a wide area stretching from the Soutpansberg in the Limpopo Province, through Mpumalanga Province and into Northern Kwa-Zulu Natal in the south. The majority of the plantations are in Mpumalanga (14), followed by Limpopo (3) and with one in Kwa-Zulu Natal. In total, 187 320.3 hectares are managed, of which 127 674.3 hectares are planted to commercial exotic plantation timber and the remaining 59 645.96 hectares are classified as non-commercial open areas consisting of firebreaks, maintenance areas, infrastructure and conservation zones. Geography: KLF plantations’ ranges from upper mountain slopes of above 1200 masl on geological formations of intercalated assemblages of compact sedimentary and extrusive rocks in the north to acid and intermediate intrusives to the south west going over to dolomite and limestone and porous unconsolidated sedimentary strata to Tzaneen. Towards the south from Blyde to Sabie and Ngome geology changes from intercalated arenaceous and argillaceous strata from the west to basic mafic lavas and eventually to undifferentiated assemblages of compact sedimentary extrusive and intrusive rocks with dolomites and limestones to the south. Upon weathering the geology leads to steep shallow sandy soils in the north, to undulating moderate deep to deep sandy loams. From Tzaneen steep moderate to deep clayey loam to sandy loams to the south. Some of the Ecca sediments and exposed Molteno beds on the escarpment weathers to form yellow and red apedal dystrophic soils. The plantations are situated in the summer rainfall zone and in general receive a relatively high rainfall when compared with that of the rest of South Africa. The average annual rainfall on the plantations varies from around 800mm at sites like Blairmore to around 2000mm at God’s Window/Sabie and parts of Woodbush. Snow sometimes falls on the escarpment and highveld areas, and hail is experienced on most plantations. The mean temperatures for summer and winter are around 18 to 24, AD 36-A-05 Page 15 of 74
and 10 to 16, respectively. During middle to late winter it is not uncommon to experience hot, dry ‘Berg’ winds prior to a cold front, which present problems in terms of increasing the danger of wildfires. From around 1200 masl the natural vegetation varies from the Montane-Forest belt of the upper mountain slopes previously classified as North-eastern Mountain Sourveld by Acocks in 1953. The upper Mistbelt levels of the Escarpment is a very restricted grassland type and contains 78 endemic or near endemic species on the Black Reef Quartzites. A further 31 endemic species occur on the drier dolomites of the Chuniespoort Group. Predominantly a grassland area, the North-eastern Mountain Sourveld was initially classified as an inland Tropical Forest type due to the patches of indigenous forest that occurs in the sheltered ravines and valleys of the Escarpment. Along the foothills, the steeply sloping and incised Sub-Montane Scrub-Forest Belt and lower mountain slopes extends from the Montane Forest Belt down to 900masl. This zone is devoid of climax forest and possible reasons are fire, grazing and human settlement, it forms part of the Savanna Biome of the country and is often referred to as "Bushveld".
3.2 History of use Commercial forestry in South Africa commenced during the last quarter of the nineteenth century with government afforestation projects. Originally, planting was aimed at supplying the mining sector with pit props. Timber plantations were established during the 1930’s. Around the turn of the century eucalyptus and wattle were brought in from Australia, and pine trees from America and Europe. From 1920 onwards, afforestation increased rapidly, bringing with it some relief for the impact on indigenous timber such as Yellowwood and Stinkwood exploited at the time as the sole source of timber. Today, the area of commercial plantations had grown to approximately 1.6 million hectares. It consists of roughly 54% pine, 38% eucalyptus, 7% wattle and 1% other hardwoods. The Mpumalanga Province has the largest plantation areas closely followed by Kwa-Zulu-Natal with other plantation areas including Limpopo, and the Eastern and Western Cape Provinces. The potential productivity of these plantation forests averages about 20m3 per ha per annum, which is relatively high by world standards. Timber plantations currently yield approximately 19 to 20 million m3 per year. The history of some of the KLF plantations dates back to nearly the same time as the initial establishment of exotic timber plantations, especially the KLF properties in the Sabie area. The surrounding land use to KLF is largely other private forestry companies, livestock farming as well as tropical fruit and nut farming.
3.3 Planning process Planning is according to the 3-tiered approach, encompassing the following levels: o Strategic Planning is carried out by the senior forest management and planning team - it includes business planning and yield regulation (30 year plan) to ensure sustainability. o Tactical Planning is completed by individual management teams and includes the Annual Plan of Operations (APO), harvesting and fire break schedules, silviculture and conservation plans. o Operational Planning undertaken by foresters, supervisors and contractors responsible for particular operations. These plans include compartment level planning for harvesting, silviculture, roads maintenance, fire protection and ecological burning and the maintenance of conservation areas according to FMU specific Environmental Management Plans. The Planning Manager is responsible for the maintenance of the GIS and plantation stock database and makes use of ArcView and Microforest. Microforest is a computer programme that incorporates a database (linked to GIS), a compartment inventory system and stand growth models that are used to prepare the Working Plans. Data from PSP’s (Permanent Sample Plots) are used in growth models to predict volumes, actual versus predicted volumes are used to adjust the growth model to improve accuracy of averages. Planning is done on strategic level using Microforest computer software and FORSAT (Forestry Scenario Analysis Tool) with growth formulas and predictions are made on actual data collected and monitoring information. Inventories are carried out at age 25 and then 1 year prior to clearfelling.
AD 36-A-05 Page 16 of 74
Operational training for all staff is planned on an annual basis by means of a needs analysis, and takes place in-field or at the Platorand KLF training centre. KLF has an in-house research unit based in Sabie as well as their own nursery also based in Sabie. The research unit’s primary focus is on tree improvement projects for the Pine species grown on the FMUs and the nursery produces high quality seedlings for the plantations, it is able to produce up to 10 million seedlings per annum. At Strategic level several policies are formulated and updated, examples of these are: The Timber Growing Policy which is broken down into several other policies – (1) Forest Management Policy (2) Silviculture Policy (3) Weed Control Policy (4) Fire Protection Policy (5) Environmental Policy (6) Thinning and Pruning Policy, and (7) Forest Engineering Policy. At a Tactical level the tactical plans are documents where guidelines and plans for periods from three to five years are set out. These plans are compiled at the plantation level and are separated into Tactical Harvesting Plans and Tactical Silvicultural Plans. Operational planning is done at the district/plantation level and covers the Annual Plan of Operations (APO) and different operational plans. The APO’s generally consists of a compartment register detailing all compartments to be felled, thinned, pruned, planted, weeded, etc. for the specific year. From the APO’s flow the operational plans that provide the requirements or procedures per compartment for specific activities. For instance: an operational harvesting plan would provide detail on the harvesting system used, extraction routes, log landings, identify special management zones and problem areas, work sequence and production targets.
3.4 Harvest and regeneration KLF has a “Policy on the Method of Harvest Scheduling” which outlines the strategic, tactical and operational planning. The strategic plan focuses on the long term, with a time horizon of 1 – 3 rotations and the tactical plan focuses on 3 – 5 years.
The operational plan uses the results of the tactical plan to determine how and in which sequence the compartments scheduled for the current year will be harvested. A tactical plan for at least 2 rotations is available for each FMU and the company as a whole. Tactical plans are used to determine harvesting machinery requirements and are set up at regular intervals. The goal of the tactical plan is also to produce a spatially feasible and sustainable plan that can be implemented on the ground. Several harvesting operations were assessed during the Re-Assessment and found to be compliant in terms of Operational Harvesting Plans and their implementation.
The Programme Manager for Growth and Yield Research is responsible for the growth models and the updating of the simulator from data from the PSP’s. The Site Index estimation is then adjusted, and yield tables as well as projections are calibrated. Actual versus Predicted volumes for the research plots are used to adjust the growth model which provides averages. FORSAT (Forestry Scenario Analysis Tool) is then used as a test bench to test the models. This is then run in MicroForest and Forsat and this is then compared to see that the correct results are obtained.
Inventories are carried out approximately 6 times. This takes place at age 4, before the 1st thinning, before the nd 2 thinning, at age 20 to calibrate the SI20, at age 25 and then 1 year prior to clearfelling. Once the compartment has been thinned or clearfelled, a “volume reconciliation” form is completed by the forester with the volumes obtained from “Logprog” which captures the volumes during harvesting. Any deviation of more than 5% needs to be explained by the forester as to why this has occurred.
The Harvest Scheduling Method has been revised since the devastating fires of 2003. Plantations are now grouped into geographical regions for harvest scheduling whereas in the past each FMU was treated separately.
The Annual Allowable Cut (AAC) is established by using the MicroForest computer program. A list of compartments to be thinned and clearfelled for the next 3 years is sent out to the foresters who then consolidate compartments for improved planning and return the schedules to the Planning Department. They in turn, produce the “Proposed Budget Volumes for 2007/2008” - the actual compartment allocations for the financial year.
Specific management prescriptions are recorded in the “Silviculture Policy”. This was last updated in AD 36-A-05 Page 17 of 74
April 2007 and deals with topics such as Nursery, Slash management, Site Preparation, Site Species Matching, Planting, Planting espacement, Blanking, Fertilizing, Weed Control, Marking for thinnings, Thinnings and Audits.
3.5 Monitoring processes Monitoring and auditing of operations forms an integral part of the daily activities of the forest managers, foresters and contractors. Operational progress is monitored through the preparation and presentation of monthly reports through the hierarchy of the management structure; and through management meetings held at weekly and monthly intervals. Operational monitoring is carried out daily from production sheets and post harvest monitoring checklists. Conservation monitoring is carried out annually by means of CMP records which ensures that the proposed activities on the plan are executed. Monitoring of weed control activities and the rehabilitation of degraded sites are regularly followed up by District Environmental Practioners. Further individual monitoring exists for specific species found on plantations such as Cycads, Oribi and Blue Swallows, specific RTE species, HCV Forests, grasslands, water quality (SASS5) and environmental impact assessments. Working Plan and Thinning Control enumerations are carried out approximately six times during the lifetime of a tree, as stated earlier. Silviculture monitoring includes weed assessments, blanking assessments, seedling condition and monitoring of soil and erosion after burning operations of slash for site preparation. In addition to this, the occurrence of pests or diseases is monitored on an ongoing basis by all field staff. Social investment and progress of sponsored projects are monitored. Water quality at all villages and office complexes are monitored annually as well as effluent from sewage plants.
4. SOCIO-ECONOMIC AND ENVIRONMENTAL CONTEXT
4.1 Social aspects
Number of own workers Male Female 1640 425 Number of contract workers 3495 Minimum daily wage for agricultural/forestry workers 2008 -R42.25 2009 – R52.56 2010 – R56.34 Infant mortality rates (under 5 years) Unknown Proportion of workers employed from the local population (%) 95%
KLF headcount of permanent positions are 1729 as of May 2007, KLF Fixed term positions are 310 and 48 contractors employ a total of 3495 workers. All labour is employed from local communities, (a KLF requirement).
Nationalities KLF give preference and only employ RSA citizens for its operations. This excludes IFLOMA where preference is given to employment of Mozambicans. Currently KLF only employ the following number of foreigners: a) KLF – 1 b) IFLOMA - 3 Contractors are encouraged to also follow the same guidelines.
Cultures / Social Groups KwaZulu Natal (Ngome) - Zulu Mpumalanga (Highveld - East) - Swazi AD 36-A-05 Page 18 of 74
Mpumalanga (Highveld - Belfast) - Ndebele Mpumalanga (Platorand – Sabie) - Sotho Limpopo (Tzaneen) - Sotho Limpopo (North) - Venda
Social Problems Poverty - Job creation HIV/Aids - Awareness, wellness Women and Child Abuse - Awareness Literacy - Abet Education - Facilities
Sources of Employment Adjacent communities with focussed areas for each of the centres. (e.g. Nelshoogte, Tarkastad, Badplaas and Barberton). Same approaches apply to recruitment of bursary students and trainees – preference given to adjacent communities.
4.2 Environmental aspects The principle environmental impact in the SA forestry sector is alien invasive plant species in the non- commercial and commercial compartments. Historical budget cuts in conservation programmes, turnover of staff, changing weed control plans, lack of dedicated teams for alien plant control and lack of follow-up (or too long intervals between follow-up) of initial control activities are some of the biggest problems in the South African forestry industry in terms of weed control, and KLF is no exception. At the dawn of its third certificate period KLF is one of the longest standing certificate holders in South Africa and sets a fine example in many fields, but weed control requires urgent and dedicated attention to minimize the company’s footprint in the natural environment. Several projects to minimize erosion and sedimentation are ongoing or completed at a number of Forest Management Units (FMU’S). Numerous sites of Rare, Threatened or Endangered species, and especially plant species have been identified by different consultants – there are detailed reports available and such sites are monitored according to schedules to ensure optimum conservation and protection of the sites and relevant species. An RTE booklet identifying the most common Red Data species at the different FMU’s was completed a number of years ago and has subsequently been updated. This booklet is used by patrol and forest guards to record sightings of specific species. All site disturbing activities are assessed prior to any disturbance taking place by the completion of an internal EIA document identifying potential impacts and highlighting possible mitigation measures. Such assessments are completed by the District Environmental Practioners and signed off by the plantation managers prior to the specific activity commencing. Environmental monitoring of grasslands, water quality and riparian zones, wetland delineation and High Conservation Value Forests takes place annually. Other specific conservation sites such as the cycad reserve at Uitsoek and Berlin, Protea at Nelshoogte, Aloes at Entabeni and Witklip and several other sites are monitored by KLF and external interested parties and tertiary institutions.
4.3 Administration, Legislation and Guidelines The following table lists the key national legislation, regulations, guidelines and codes of best practice that are relevant to forestry in the commercial, environmental and social sectors. This list does not purport to be comprehensive, but indicates information that is key to the forestry sector.
A. NATIONAL LEGISLATION NOTES
National legislation governs many of the activities in forestry in South Africa. Some of the applicable Acts are as follows
Forestry, Agriculture and Environment:
1. Advertising On Roads And Ribbon Development Act (No. 21 of 1940) 2. Agricultural Pests Act (No. 39 of 1983) AD 36-A-05 Page 19 of 74
3. Animal Disease Act (No. 35 of 1984) 4. Conservation of Agricultural Resources Act (No. 43 of 1983), as amended 2001. 5. Constitution of South Africa (1996) 6. Environment Conservation Act (No. 73 of 1989) 7. Fencing Act (No. 31 of 1963) 8. Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act (No. 36 of 1947). 9. Hazardous Substances Act (No. 15 of 1973) 10. Minerals and Petroleum Resources Development Act (No. 28 of 2002) 11. National Building Regulations and Building Standards (No. 103 of 1977) 12. National Environmental Management Act (No. 107 of 1998) 13. National Environmental Management: Air Quality Act (2004) 14. National Environmental Management: Biodiversity Act (No. 10 of 2004) 15. National Environmental Management: Protected Areas Act (No. 57 of 2003) 16. National Forests Act (No. 84 of 1998) 17. National Road Traffic Amendment Act [No. 21 of 1999] 18. National Veld and Forest Fire Act (No. 101 of 1998) 19. National Water Act (No. 36 of 1998) 20. Plant Breeders Rights Act (No. 15 of 1976) 21. Plant Improvement Act (No. 53 of 1976)
Cultural and social:
22. Animal Protection Act (No. 71 of 1962) 23. Basic Conditions of Employment Act (No. 75 of 1997) 24. Communal Land Rights Act (No. 11 of 2004) 25. Compensation for Occupational Injuries and Diseases Act (No. 130 of 1993) 26. Employment Equity Act (No. 55 of 1998) 27. Extension of Security of Tenure Act (No. 67 of 1997) 28. Labour Relations Act (No. 66 of 1995) and Labour Relations Amendment Act of 1997. 29. Land Reform Act (No. 3 of 1996) 30. National Heritage Resources Act (No. 25 of 1999) 31. Occupational Health and Safety Act (No. 85 of 1993) 32. Prevention of Illegal Eviction from and Unlawful occupation of Land Act (No. 19 of 1998) 33. Protection of Informal land Rights Act (No. 31 of 1996) 34. Restitution of Land Rights Act (No. 22 of 1994) 35. SA Schools Act (No. 84 of 1996) 36. Security Officer’s Amendment Act (1997) 37. Skills Development Act (No. 97 of 1998) 38. Skills Development Levies Act (No. 9 of 1999) 39. Unemployment Insurance Act (No. 30 of 1966) AD 36-A-05 Page 20 of 74
B. REGULATIONS PERTINENT TO FORESTRY RELATED TO AND EMERGING FROM NATIONAL LEGISLATION AND OTHER NATIONAL ATLASES:
40. Barnes, K. N. (ed.) 2000. The Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland. BirdLife South Africa, Johannesburg - ISBN number 0-620-25499-8 41. Bromilow, C. 2001. Problem Plants of South Africa. A guide to the identification and control of more than 300 invasive plants and other weeds. Briza Publications. 42. Draft Lists of Threatened and Protected Species issued in terms of Section 56 (1) of the National Environmental Management: Biodiversity Act, 2004. 43. Friedmann Y. and Daly B, (editors) 2004. Red Data Book of the Mammals of South Africa: A Conservation Assessment: CBSG Southern Africa, Conservation Breeding Specialist Group (SSC/IUCN), Endangered Wildlife Trust. South Africa - ISBN number 0-620-32017-6 44. Golding, J. (ed) 2002. Southern African Plant Red Data Lists. South African Botanical Diversity Network report No 14. 45. Henderson, L. 2001. Alien Weeds and Invasive Plants: A complete guide to declared weeds and invaders in South Africa. Plant Protection Research Institute handbook No12, Agricultural Research Council. 46. Hilton-Taylor, C. 1996. Red Data list of Southern African Plants. NBI. Strelitzia 4. 47. Minter, L.R., M. Burger, J.A. Harrison, H.H. Braak, P.J. Bishop and D. Kloepfer, eds, 2004. Atlas and Red Data Book of the Frogs of South Africa, Lesotho and Swaziland. SI/MAB Series #9. 48. National List of Declared Weeds and Invader Plants: Table 3 of Regulation 15 of Conservation of Agricultural resources Act (43 of 1983). 49. National Principles, Criteria, Indicators and Standards (PCI&S) of Sustainable Forest Management (SFM). Section 3 of the National Forest Act (84 of 1998). Version 30 March 2005. 50. Scott-Shaw, C. R. 1999. Rare and Threatened Plants of KwaZulu-Natal and Neighbouring Regions. KwaZulu-Natal Nature Conservation Service. 51. The South African Red Data Book Series (National Scientific Programmes Report Series published by the CSIR: No 7 and 11 in 1976, 14 and 18 in 1977, 23 in 1978, 45 in 1980, 97 in 1984 and 117 in 1986. These cover birds, small mammals, fishes, large mammals, reptiles and amphibians and vascular plants.
C. INTERNATIONAL AGREEMENTS PERTINENT TO FORESTRY
South Africa is a signatory to the following, however, current South African legislation encapsulates the obligations of these international agreements: 52. Convention on Biological Diversity 53. Convention on the International Trade in Endangered Species (CITES) 54. International Labour Organisation (ILO)
D. LOCAL STANDARDS AND BEST OPERATING PRACTICES
Local standards have also been introduced by the forestry industry. Nationally or Industry endorsed local standards (Best Operating Practices) are listed below: 55. A practical field procedure for identification and delineation of wetlands and riparian areas. Final draft: February 2003. Department of Water Affairs and Forestry. 56. Best Management Practices for Preventing and Controlling Invasive Alien AD 36-A-05 Page 21 of 74
Species. Symposium Proceedings, The Working for Water Programme, 22- 24 February 2000. 57. Engelbrecht, G. v. R. and Warkotsch, P.W. 1994. Chute Operating Manual – FESA Chute Project Group 58. Environmental Guidelines for Commercial Forestry Plantations in South Africa (Forestry South Africa, Second Edition, August 2002). 59. Guidelines for Forest Engineering Practices in South Africa. Forest Engineering Working Group of South Africa (FESA), May 1999. 60. Protective Device for users of sharp bladed tools: Requirements for leg protectors. FESA standard FESA 001:1998. 61. Relevant ICFR Bulletins and handbook series. 62. Responsible Use Guide. AVCASA Crop protection and Animal Health Association, October 2001. 63. South African Forestry Handbook, Volumes 1 & 2. The South African Institute of Forestry, 2000. 64. The Private Security Industry Regulatory Authority (SIRA) Regulations. 65. The South African Cable-yarding Safety and Operating handbook (FESA). 66. The South African Chainsaw Safety and Operating handbook January 2000. (FESA). 67. The South African Forestry Road Handbook. FESA Working Group, August 2004. (Available on CD, and currently in publication – available from Francois Oberholzer 082 850 4330).
5. CHANGES IN MANAGEMENT, HARVESTING, SILVICULTURE AND MONITORING The following table shows significant changes that took place in the management, monitoring, harvesting and regeneration practices of the certificate holder over the certificate period.
Description of Change Notes SURVEILLANCE 1 No significant changes. It Appear that the privatisation process is halted for the time being. And the status quo remain. A dedicated roads team was established and successes were noticeable. Strategic and long term planning is done as it will stay a parastatal. SURVEILLANCE 2 No significant changes have been made in senior The privatisation process has been placed on management. hold indefinitely.
SURVEILLANCE 3 No significant changes have been made in senior The structure has remained the same as the management previous audit.
SURVEILLANCE 4
AD 36-A-05 Page 22 of 74
6. PREPARATION FOR THE EVALUATION
6.1 Schedule The Evaluation was not preceded by a pre-evaluation due to this being the 3rd Certificate Re- Assessment, it was preceded by the 4th Surveillance Assessment of the previous certificate period.
6.2 Team The table below shows the team that conducted the Re-evaluation and the independent specialist(s) that were selected to review the re-evaluation report.
Evaluation Team Notes Team Leader Has a Diploma in Forestry, a BSc and Masters Degree in Conservation and Environmental Management and 24 years experience in forestry and environmental management internationally and nationally. 95 days FSC auditing, speaks Afrikaans and English with a good understanding of Zulu. Local Specialist Has a B:Tech Forestry degree, 12 years experience in forestry both internationally and nationally. Speaks English, Afrikaans and Zulu fluently and speaks Portuguese well. Local Specialist Has a BLC. LLB. LLM (Human Rights and Democratisation in Africa) degrees and holds a Diploma in Alternative Dispute Resolution. He is currently completing a LLD in Environmental Law and has undertaken numerous short courses including environmental, social and FSC auditing. He has approximately 8 years relevant experience to environmental law and human rights issues internationally, regionally (Africa) and nationally.
6.3 Checklist Preparation A checklist was prepared that consisted of the documents listed below. This checklist was prepared using the FSC-endorsed national or regional standard. A copy of this checklist is available on the SGS Qualifor website, www.sgs.com/forestry.
Standard Used in Evaluation Effective Date Version Nr Changes to Standard Adapted SGS checklist for South 1 September 02 Checklist adapted to suit South African Africa AD 33-ZA-02 2005 conditions. Adapted SGS checklist for South 29 March 04 Checklist adapted to suit South African Africa AD 33-ZA-04 2010 conditions.
6.4 Stakeholder notification A wide range of stakeholders were contacted 4 weeks before the planned evaluation to inform them of the evaluation and ask for their views on relevant forest management issues. All stakeholders with access to electronic mail were contacted by email. A random selection of stakeholders without access to electronic mail was contacted by telephone (per FMU - Forest Management Unit) and others were interviewed in person. In addition to this the company sent out stakeholder response sheets with a covering letter. Stakeholders included environmental interest groups, local government agencies and forestry authorities, forest user groups, and workers’ unions. The full list of stakeholders that were contacted is available from SGS. Responses received and comments from interviews are recorded under paragraph 0 of this Public Summary.
7. THE EVALUATION The Re-evaluation was conducted in the steps outlined below.
7.1 Opening meeting AD 36-A-05 Page 23 of 74
An opening meeting was held at KLF Head Office in Nelspruit, Mpumalanga. The scope of the evaluation was explained and schedules were determined. Record was kept of all persons that attended this meeting.
7.2 Document review A review of the main forest management documentation was conducted to evaluate the adequacy of coverage of the QUALIFOR Programme requirements. This involved examination of policies, management plans, systems, procedures, instructions and controls.
7.3 Sampling and Evaluation Approach A detailed record of the following is available in section B of the evaluation report. This section does not form part of the public summary, but includes information on:
Sampling methodology and rationale; FMUs included in the sample; Sites visited during the field evaluation; and Man-day allocation. The evaluation covered 5 FMUs in two provinces with both the opening and closing meeting at the Head Office in Nelspruit. Several people were interviewed (telephonically or in person), mill sites, contractor offices and samples of all current operations were visited and assessed over the 6 day period by two auditors. A third Assessor was present during the first day to assess the sustainable management of KLFs resource utilisation and harvesting regime.
7.4 Field assessments Field assessments aimed to determine how closely activities in the field complied with documented management systems and QUALIFOR Programme requirements. Interviews with staff, operators and contractors were conducted to determine their familiarity with and their application of policies, procedures and practices that are relevant to their activities. A carefully selected sample of sites was visited to evaluate whether practices met the required performance levels.
7.5 Stakeholder interviews Meetings or telephone interviews were held with stakeholders as determined by the responses to notification letters and SGS discretion as to key stakeholders that should be interviewed. These aimed to:
clarify any issues raised and the company’s responses to them;
obtain additional information where necessary; and
obtain the views of key stakeholders that did not respond to the written invitation sent out before the evaluation.
Nr of Stakeholders Nr of Interviews with contacted NGOs Government Other MAIN EVALUATION
56 via electronic mail and 6 – Telephonic 1 - Live interview 6 - Live interviews, Union 720 via postal mail. and electronic representatives, stakeholders and 4 - Telephonic and workers. electronic (e-mail) 25 - Clients and neighbours via telephone SURVEILLANCE 1
6 1 1 4 SURVEILLANCE 2 AD 36-A-05 Page 24 of 74
Nr of Stakeholders Nr of Interviews with contacted NGOs Government Other
10 0 0 3 – Ward committee councilors – Ngome – Social Compact.
3 – FAWU shop steward committee – Branch Secretary and 2 shop stewards – Jessievale
1 – FAWU fulltime Union Branch Secretary – Nelspruit
3- Land Claimants – Local Chief, wife and local headman – Badplaas. SURVEILLANCE 3
Contacted 7 and 3 other 4 1 2 emails not responded to. Crane Department of Food and Allied Workers Union – Conservation Agriculture , National Coordinator Project. Fisheries and Forests Roburnia Cluster Committee. Mpumalanga Tourism and Parks Grassland Monitoring Group Griffon Poison Information Centre SURVEILLANCE 4
Responses received and comments from interviews are recorded under paragraph 0 of this Public Summary.
7.6 Summing up and closing meeting At the conclusion of the field evaluation, findings were presented to company management at a closing meeting. Any areas of non-conformance with the QUALIFOR Programme were raised as one of two types of Corrective Action Request (CAR):
Major CARs - which must be addressed and re-assessed before certification can proceed
Minor CARs - which do not preclude certification, but must be addressed within an agreed time frame, and will be checked at the first surveillance visit A record was kept of persons that attended this meeting.
8. EVALUATION RESULTS Detailed evaluation findings are included in Section B of the evaluation report. This does not form part of the public summary. For each QUALIFOR requirement, these show the related findings, and any observations or corrective actions raised. The main issues are discussed below. AD 36-A-05 Page 25 of 74
8.1 Findings related to the general QUALIFOR Programme
PPPRRRIIINNNCCCIIIPPPLLLEEE 111::: CCCooommmpppllliiiaaannnccceee wwwiiittthhh lllaaawww aaannnddd FFFSSSCCC PPPrrriiinnnccciiipppllleeesss
Criterion 1.1 Respect for national and local laws and administrative requirements
Strengths Weaknesses Observation 5 was raised at New Agatha Plantation with reference to Mogoboya mill, which is presently under the KLF lease agreement. The lease-agreement is currently being revised by the Department (DWAF) which will effectively excise the mill area. An audit visit on the mill premises revealed concerns relating to adverse environmental impacts as well as safety concerns. As a result of these findings, KLF runs the risk of incurring liability in respect of i.e. pollution. Finalization of the excision / lease agreement is required. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Observation prior to the 2008 Surveillance. Compliance General awareness of national and local laws was found to be satisfactory during interviews with managers and staff.
Criterion 1.2 Payment of legally prescribed fees, royalties, taxes and other charges
Strengths Weaknesses Compliance Payment of legally prescribed fees, royalties, taxes and other charges were found to be compliant.
Criterion 1.3 Respect for provisions of international agreements
Strengths Within the Human Resources Department there exists a strong awareness of the Requirements of the ILO Conventions. Weaknesses Compliance The Environmental Division and its staff has a sound basic knowledge of CITES. Operations reflect compliance and there exist unionised operations. There is no restriction or infringements of labour rights as provided for by the ILO Conventions.
Criterion 1.4 Conflicts between laws and regulations, and the FSC P&C
Strengths Weaknesses Compliance There are no conflicts between laws and regulations and the FSC P&Cs.
Criterion 1.5 Protection of forests from illegal activities
Strengths Weaknesses During the reassessment it was found that appropriate and effective measures to monitor, identify and control illegal harvesting, settlement and other unauthorised activities were not in place. Minor CAR 11 was raised as result of this and on matters of access control. Re- Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance KLF regulates the monitoring of illegal activities mainly through private security contractors and/or their own forest guards.
Criterion 1.6 Demonstration of a long-term commitment to the FSC P&C
Strengths KLF’s strong commitment to FSC P&C is exemplified by the manner through which, it manages its forests, efforts made to protect the environment and a range of social projects geared at assisting and developing communities surrounding operations. The Major CAR recorded, and relative high number of Minor CARs recorded should not be used as a measure of the company’s commitment. Weaknesses Despite this strong commitment Major CAR 12 was raised through PROC 04-02: ‘Failure to AD 36-A-05 Page 26 of 74
ensure continued compliance with the FSC standard’. Where more than 10 Minor Corrective Action Requests are raised within a Re-Assessment or Surveillance Assessment, a Major CAR is raised as result. Re-Assessment COF findings: Closure of 4 Minor CARs and 2 Observations as well as Action Plans for all other non-compliance resulted in the closure of this Major CAR 12. Compliance A publicly available policy endorsed by the KLF Executive Officer is displayed at all offices and available to the public. Contractors have a sound awareness of policy and procedures and are also audited against an internal company checklist. KLF is also responsible for the management of approximately 25 000 hectares of land in Mozambique, the IFLOMA project. IFLOMA is not in a position to apply for certification yet due to years of neglect from previous management as well as infrastructure collapse. The project is, however, managed with the future view of compliance with FSC P&C. The same management system that currently exists in the certified KLF plantations in RSA will be implemented at IFLOMA.
PPPRRRIIINNNCCCIIIPPPLLLEEE 222::: TTTeeennnuuurrreee aaannnddd uuussseee rrriiiggghhhtttsss aaannnddd rrreeessspppooonnnsssiiibbbiiillliiitttiiieeesss
Criterion 2.1 Demonstration of land tenure and forest use rights
Strengths Weaknesses Compliance KLF leases the property from the Department of Public Works under a long term lease agreement (Initial period of 35 years + renewal/termination of 35 years = 70 years). The existing agreement is currently being revised/amended. Public KLF Commitment to FSC Principles and Criteria is available and reiterates a long-term commitment to sustainable forest management.
Criterion 2.2 Local communities’ legal or customary tenure or use rights
Strengths Weaknesses Cattle grazing in the Highveld region (Roburnia) is of concern. Related Minor CAR 11 was raised under 1.5 and 4.1 Compliance Local communities have not proclaimed any legal or customary tenure rights. Use rights are in the form of permits i.e. grazing. In addition land claims are part of the current land reform process within the country and records are kept relating to land claims.
Criterion 2.3 Disputes over tenure claims and use rights
Strengths Weaknesses Compliance A range of land claims exist in respect of land managed by KLF. Areas include Woodbush, New Agatha, Nelshoogte, etc. Land claims are part of the country’s land reform process and are resolved at formal/official level. The Company regularly meets with communities/rights holders and meetings are documented. Dispute records are kept, maintained and are appropriately distinguished from other documents at plantation level.
PPPRRRIIINNNCCCIIIPPPLLLEEE 333::: IIInnndddiiigggeeennnooouuusss pppeeeooopppllleeesss’’’ rrriiiggghhhtttsss
Criterion 3.1 Indigenous peoples’ control of forest management
Strengths Weaknesses Compliance Land is owned by the Government and leased to KLF and there are no legal and customary rights of indigenous peoples to own, use and manage their lands, territories, and resources applicable on the FMU. AD 36-A-05 Page 27 of 74
Criterion 3.2 Maintenance of indigenous peoples’ resources or tenure rights
Strengths Weaknesses Compliance Not applicable.
Criterion 3.3 Protection of sites of special cultural, ecological, economic or religious significance to indigenous peoples
Strengths Weaknesses Observation 01 was raised due to only part of an ASI being demarcated at a commercial thinning operation at Roburnia B19. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Observation and findings of the COF verified the implementation – this Observation is closed. Compliance Sites of special cultural, historical, ecological, economic or religious significance are identified, described and mapped. Related CAR 64 from the previous certificate period was closed. The updated EMS (Environmental Management System) sets clear standards for the identification and management of ASI’s, it is an ongoing process. The EMS also sets clear standards for the identification of ASI’s allowing for input form a range of stakeholders. Access to sites is provided for at plantation level and the company grants access per request.
Criterion 3.4 Compensation of indigenous peoples for the application of their traditional knowledge
Strengths Weaknesses Compliance Not applicable – (Commercial plantation. Local communities do not access forest produce that are subject traditional knowledge).
PPPRRRIIINNNCCCIIIPPPLLLEEE 444::: CCCooommmmmmuuunnniiitttyyy rrreeelllaaatttiiiooonnnsss aaannnddd wwwooorrrkkkeeerrrsss rrriiiggghhhtttsss
Criterion 4.1 Employment, training, and other services for local communities
Strengths The company has sound social corporate responsibility and can be commended on its awareness and diverse range of projects in this regard. KLF can be commended for the work done to bring contractors on par with regulatory requirements. Weaknesses Uncontrolled and illegal activities include: i.e. illegal cattle grazing (which poses a frequent problem at Roburnia), unauthorised collection of waste wood, unauthorised collection of plant materials and other activities. During the reassessment it was found that appropriate and effective measures to control access were not in place. Minor CAR 11 was raised in this regard (see also Criterion 1.5). Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance Workers on the FMUs are employed from nearby communities. Contracts are awarded through a tender/quote process. Appropriate training programmes exists for all staff members. Social corporate responsibility support ranges from donations and active assistance and involvement relating to care, health, education, environmental awareness, conservation and other. Local communities can access forest and non-forest products. This is done through request to the local forest manager. A range of Human Resource Policies (i.e Equity Policy) make qualifications, skills and experience the basis for recruitment, placement, training and advancement of staff at all levels. Records and contracts complied with the Basic Conditions of Employment Act and the Sectoral Determination for the Forestry Sector.
Criterion 4.2 Compliance with health and safety regulations
Strengths Villages were visited at all plantations assessed (Woodbush, New Agatha, Roburnia, Belfast AD 36-A-05 Page 28 of 74
and Blyde Mill). KLF accommodation is of the best assessed to date and most villages have adequate ventilation, are structurally sound, clean and with adequate sanitation. In addition, meeting venues are available, and at some villages, sport grounds and other non-essential facilities. Weaknesses Concerns were raised in respect of the awareness of safety representatives designated i.t.o. OHS Act. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Observation prior to the 2008 Surveillance. The lookout tower at Belfast plantation was visited. A safety risk exists when the operator climbs into the cabin on top of the steel tower. Observation 04 was raised. Re-Assessment COF findings: This Observation was closed due to Risk Assessment completed and action plan implemented. Contractor staff / Contract operations were problematic and workers interviewed have not consistently been trained for safe working practices nor are all aware of such procedures. Minor CAR 09 was opened. Re-Assessment COF findings: An Action Plan was compiled by KLF and the assessment conducted in July 2007 resulted in the closure of this Minor CAR. Operations visited did not consistently have the required First Aid kits at operations. Minor CAR 01 was raised as result. Re-Assessment COF findings: An Action Plan was compiled by KLF and the assessment conducted in July resulted in the closure of this Minor CAR. A number of concerns were noted and relate to potable water and sanitation. Minor CAR 07 was opened due to the non-compliance. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance The Company complies with regulatory health and safety requirements. It further prescribes to NOSA (Safety certification) with high results. KLF also requires a 3 star rating from its contractors. KLF has systematically assessed the risk associated with all tasks and prescribed appropriate safe procedures and personal protective equipment (PPE). Training and training records were verified at all plantations sampled. Health and Safety Records were checked at all plantations sampled as well as at regional office (Nelspruit) as well and found to be compliant in all cases. KLF salaried staff, has access to a medical aid, and waged staff have access to adequate medical facilities in surrounding communities. Adequate mechanisms exist to identify and deal with endemic and other diseases. KLF has moved towards mainstreaming HIV in the work place.
Criterion 4.3 Workers’ rights to organise and negotiate with employers
Strengths Weaknesses Compliance During interviews with union representatives it was established that rights are respected, and such rights are also incorporated into employment contracts. FAWUs representative was satisfied that KLF complied with the applicable labour laws and positive as to the contributions made by KLF iro HIV/AIDS. The representative was also positive about the accessibility of KLF in respect of dialogue. With respect to contractors, there existed no restrictions relating to these rights. Effective mechanisms are present to enable workers to participate in decision making. Various forums are present for dissemination and interactions and Policies and procedures also encourage interaction.
Criterion 4.4 Social impact evaluations and consultation
Strengths Weaknesses During Re-Assessment stakeholder consultation it was found that several of the telephone numbers, company names or names of individual neighbours had changed or did not exist AD 36-A-05 Page 29 of 74
anymore. Minor CAR 03 was raised. Re-Assessment COF findings: An Action Plan was compiled and implemented by KLF and this Minor CAR was closed during the COF Assessment. Compliance KLF engages with various different stakeholder groups through meetings and representatives from HR department. Social internal audits are also conducted at company level. Issues raised, especially through local communities are dealt with constructively and satisfactorily. At plantation level there exists ongoing interaction with local and surrounding communities. This is normally through the HR representative and is done when (1) issues are raised and (2) when social /community projects are undertaken. Communications with stakeholders on issues that require action and follow-up are documented. At wider level, the Timber allocation process serves as example. The revised allocation procedures were followed in and evidence of consultation was presented. The 2007 allocation had a stakeholder consultation meeting that included opportunity for all stakeholders to hold open dialogue.
Criterion 4.5 Resolution of grievances and settlement of compensation claims
Strengths Weaknesses Compliance The company has a grievance procedure and a procedure for the handling of complaints. An up do date complaints register is kept and all correspondence regarding complaints are on file, dispute resolution and grievance procedures are incorporated into the company policies and procedures.
PPPRRRIIINNNCCCIIIPPPLLLEEE 555::: BBBeeennneeefffiiitttsss fffrrrooommm ttthhheee fffooorrreeesssttt
Criterion 5.1 Economic viability taking full environmental, social, and operational costs into account
Strengths KLF has improved on the economic viability through better profits over the past few years. Optimal use is made of the harvest debris with a project to recover timber of 30cm lengths for the Particle Board market. KLF management is part of a vast list of forums and working groups and the managers’ awareness of all these issues are exceptionally good. Weaknesses Compliance Forest managers are well aware of the ranges and values of timber that is available and that utilized. Pinus, Eucalyptus and Acacia are planted for optimal utilization. Trends have been analyzed within SAFCOL since 1993, and are also kept up to date through the Crickmay index, Independent Economists and International Publications.
The current (2007-2008) KLF budget consists of 6 categories for which provision was made: (1) Environmental (2) Operational (3) Social (4) Research (5) Tourism, and (6) Processing. KLF employs their own forest guards in some cases or in others they make use of security companies to patrol the land, as well as private consultants and specialists to complete monitoring of natural resources.
Criterion 5.2 Optimal use and local processing of forest products
Strengths Weaknesses Compliance NTFP’s are firewood collection, ecotourism such as picnic, camping, hiking, fishing, bicycling, horse riding and film shooting, beekeeping and mushroom collecting in the highveld areas. Evidence of management’s promotion of NTFP’s was seen in the promotion of ecotourism and sourcing of people to collect waste timber from harvesting compartments. All timber sales are provided to local timber markets, at present no timber is being exported.
Criterion 5.3 Waste minimisation and avoidance of damage to forest resources
Strengths Several harvesting operations were visited during the Re-Assessment and all found to be compliant with a very good awareness and implementation of planned protection of special AD 36-A-05 Page 30 of 74
management zones such as indigenous forest and stream courses. Weaknesses Compliance The company has a “Policy on the Method of Harvest Scheduling” which outlines the strategic, tactical and operational planning. The strategic plan focuses on the long term, with a time horizon of 1 – 3 rotations and the tactical plan focuses on 3 – 5 years. The operational plan uses the results of the tactical plan to determine how and in which sequence the compartments scheduled for the current year will be harvested. Harvesting techniques are according to Industry guidelines and KLF company policy. The waste utilization from timber harvesting operations were found to be good and timber takes anything from 1 day to 1 week before it is removed from the site of felling.
Criterion 5.4 Forest management and the local economy
Strengths Weaknesses Compliance More than one species of timber is utilized by the company and there is a strong support of ecotourism ventures on the plantations. The utilization of NTFP’s includes firewood collection, ecotourism such as picnic, camping, hiking, fishing, bicycling, horse riding and film shooting, beekeeping and mushrooms in the highveld areas.
Criterion 5.5 Maintenance of the value of forest services and resources
Strengths Weaknesses Compliance Forest managers are aware of the range of services provided by KLF’s landholdings, and the company’s operational activities are planned in order to minimize impacts on the environment.
Criterion 5.6 Harvest levels
Strengths Weaknesses NTFP’s that are utilized are not recorded and sustainable utilization cannot be ensured. Minor CAR 05 was raised. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance Timber harvest levels are maintained while optimal use is made of the forest products. The harvest levels are well planned and maintained through the MicroForest computer program which KLF has invested in. The Harvest Scheduling Method has been revised since the devastating fires of 2003. Plantations are now managed to reach a fully regulated state as soon as possible, preferably before the end of the first rotation.
PPPRRRIIINNNCCCIIIPPPLLLEEE 666::: EEEnnnvvviiirrrooonnnmmmeeennntttaaalll iiimmmpppaaacccttt
Criterion 6.1 Environmental impacts evaluation
Strengths Weaknesses Compliance KLF has systematically identified all the activities that could potentially impact on the natural environment; management recommendations of all of these include mitigation actions or preventative measures. Internal EIA’s are conducted for all site disturbing activities where a potential exists of environmental impact. The Environmental section raises internal CARs where potential environmental impact is expected and mitigation is required or where monitoring consultants raises issues at specific sites that requires remedial action or follow-up (for example grassland monitoring or SASS5 water quality monitoring). AD 36-A-05 Page 31 of 74
Criterion 6.2 Protection of rare, threatened and endangered species
Strengths Weaknesses Floristic and mammalian RTE species have been identified and are monitored to some degree, with limited bird records and virtually no reptile/amphibian baseline studies or records available. Minor CAR 08 was opened. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Plans are not available for all wetlands in terms of the restoration of wetlands and riparian zones which have historically been degraded through poor land-use of previous rotations of timber planting. Minor CAR 02 was raised. (See also 6.3 and 6.5 below). Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. NTFP’s are not adequately known or managed. See Minor CAR 05 raised under Criteria 8.2 and 5.6. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance Acknowledged experts and provincial specialists have been contacted in terms of most floristic conservation efforts of rare and Endangered plant species. Known habitats or RTE species of plants have been identified and are adequately protected during operations such as burning or harvesting. (e.g. Woodbush). Conservation management is mapped, planned and the plans implemented, examples were recorded at Woodbush and Uitsoek.
Criterion 6.3 Maintenance of ecological functions and values
Strengths Weaknesses Weed control plans exist for both commercial and non-commercial areas, however shortcomings have been noted in work completed over the past two years as well as lack of follow up of previous initial work and as result of this Minor CAR 04 was raised. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. The farm Pan, (Belfast) is currently dormant and in a transition period with a phase-out strategy. The current silviculture procedure is not to plant and management is limited, making this farm unsustainable in terms of FSC P&C. A decision has to be finalised with clear exit dates and procedures and lease termination. Observation 03 was opened to ensure follow-up of this issue. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Observation prior to the 2008 Surveillance. At New Agatha, Woodbush and Roburnia – no plans were available to ensure that excisions will be managed in an environmentally acceptable manner or will be included in the adjacent non-commercial LMU management. At Belfast, evidence was obtained of peat damaged by fire in the wetland system. There is no documentation regarding protective measures nor are all the peatland zones identified / known to effectively protect these rare habitats against ground fires or desiccation. Minor CAR 02 was raised as result.
Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance.
Compliance Eroded sites and degraded areas are recorded on an ongoing basis with completion of management plans and budget allocation where required. Lists of weed control invaders on all FMU’s are completed as recorded on an ongoing basis. Good silvicultural practices were noted at several operations visited during the 2007 Re- Assessment. Burning is scheduled on a rotational basis where possible (Woodbush & Roburnia) for wetlands and riparian breaks. In commercial plantation compartments regeneration is artificial in terms of planting after harvesting. All areas where significant site disturbance is planned prior to planting such as AD 36-A-05 Page 32 of 74
ripping of Dresden soils (hard plinthite) the activity will be subjected to an internal EIA process.
Criterion 6.4 Protection of representative samples of existing ecosystems
Strengths Weaknesses Compliance All habitat types have been accurately mapped in terms of commercial plantation forest compartments, non-commercial natural habitats divided into wetland, forest and grassland ecosystems as well as dams, open areas (rocky), roads, depots, rivers and streams, etc. Management prescriptions exist for different habitats (e.g. wetlands at Lakenvlei, grasslands at Roburnia, indigenous forest areas, etc.)
Criterion 6.5 Protection against damage to soils, residual forest and water resources during operations
Strengths Weaknesses Inadequate implementation of guidelines developed to protect the environment during sensitive forest operations. Roburnia thinning operation – OHP stated grave and kraal would be demarcated (no demarcation of kraal). Observation 1 was raised. Re-Assessment COF findings: This Observation was closed based on implementation of the action plan and activities assessed infield. Buffer zones, Wetlands and Water courses are not adequately protected and maintained. Minor CAR 02 was raised (see also Indicators 6.2 and 6.3) Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Waste is not disposed of in an environmentally sound manner. (Significant Oil leak from T25 forwarder, Sewage effluent above legal limit and general littering at worksites) Minor CAR 10 was raised (See also Criterion 6.7). Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance Forest managers have access to the relevant legislation, subscribe to Forestry Journals and have copies of Forest Engineering- and Environmental industry guidelines that give guidance on site preparation, planting harvesting and extraction road maintenance etc. KLF also has a detailed EMP explaining the procedures for all sensitive forest operations and ways to minimize and prevent potential impacts. Examples of compliance to the 5m buffer adjacent to indigenous forest patches was recorded at Woodbush at several post harvested and newly planted compartments. At several workshops and a harvesting operation, tractor/skidder operators were interviewed and had the required knowledge of oils spills and remediation.
Criterion 6.6 Chemical pest management
Strengths All chemical stores assessed were found to be exceptionally neat and well managed with good awareness of spill procedures, container control and legal requirements by storekeepers. (Woodbush, New Agatha, Roburnia and Uitsoek). Weaknesses Compliance An up to date list is available of all chemicals in use on KLF properties – the list includes information on active ingredient, trade name and its use. Detailed records are kept of all chemicals used in terms of volumes and site of usage. All contractors and staff applying chemicals are registered pest applicators with permits. Transport, storage and handling takes place according to the KLF procedures which are compliant to ILO requirements. Operators are aware of PPE requirements of different chemicals and ensure that these are worn by workers. Chemicals used at KLF are in compliance with the FSC policy.
Criterion 6.7 Use and disposal of chemicals, containers, liquid and solid non-organic wastes
Strengths AD 36-A-05 Page 33 of 74
Weaknesses Minor CAR 10 was opened due to waste not always being disposed of in an environmentally sound manner. (See also Criterion 6.5 above) Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance. Compliance At all workshops visited recycling is implemented, oil is either stored in suitable containers owned by OilKol oil recycling company or stored until it can be taken to a FMU with such a container. Oil traps are in place and working at all workshop sites. Batteries and tyres are returned to sales companies and other waste is transported to the nearest Municipal Waste site or landfill. Examples of agreements between KLF and local municipalities are recorded. At all villages, picnic sites, look-out towers, offices and other sites where people could potentially distribute waste, such as operational activities, dustbins or bags were noted. All chemical containers are returned to sales representatives and they sign acceptance of containers (Woodbush, New Agatha) , in other cases all containers are rendered useless by triple rinsing and punching full of holes prior to removal to a suitable municipality landfill site (Roburnia)
Criterion 6.8 Use of biological control agents and genetically modified organisms
Strengths JDM Keet FMU on New Agatha is one of five mass rearing sites in South Africa where Working for Water rears biological control agents to try and curb the spread and seeding of several exotic invasive plants. Weaknesses Compliance Biological control agents are only used in assistance with other control mechanisms such as chemical and manual control of exotic invasive vegetation or pests and diseases. No GMOs are used on any of KLF properties in management, production or research programmes.
Criterion 6.9 The use of exotic species
Strengths Weaknesses Implementation of non-commercial zone weed control was found lacking - see Criterion 6.3. Compliance Exotic species are restricted to the commercial species grown on the FMU’s pine, eucalyptus and wattle. Other exotics are invaders spreading into commercial and non-commercial zones by natural means. Weed control programmes exists for both commercial and non-commercial zones.
Criterion 6.10 Forest conversion to plantations or non-forest land uses
Strengths Weaknesses Compliance No forest conversion takes place at KLF. Wetland delineation excision areas are converted back to wetland in some cases (Minor CAR 04 raised where it did not take place) and other sites of excision was identified in old plantation compartments that have now been allocated to conservation – examples are the Chlorophytum radula in Woodbush and cycad reserve at Uitsoek. Excisions demarcated for specific reasons of RTE species protection or the reclamation of previous wetland or riparian zones are substantial and long term.
PPPRRRIIINNNCCCIIIPPPLLLEEE 777::: MMMaaannnaaagggeeemmmeeennnttt ppplllaaannn
Criterion 7.1 Management plan requirements
Strengths Weaknesses Compliance The management plan is available and consists of several documents that are updated at various intervals. In total the Management Plan comprises of 11 documents: (1) Annual Plan of Operations; (2) Growth Stock Management Plan; (3) Tactical Harvesting Plan; (4) Road Maintenance Plan; (5) Fire Protection Plan; (6) Conservation Management Plan; (7) Budget; AD 36-A-05 Page 34 of 74
(8)Social Plans; (9) HR Plan; (10) Plantation maps, and (11) Environmental Management System. Management objectives are clearly described on the policy displayed at all offices “Komatiland Forests Objectives”. Species selection is documented in the “Growing Stock Management Plan” which contains data for each FMU. The CSIR developed a Site Classification and Evaluation Package per FMU in March 1998. Within each compartment it shows the various site types and has a predicted MAI for a specific species on that site. The rate of harvest is documented in the “Policy on the Method of Harvest Schedule”. Viewed “Policy on the Method of Harvest Schedule” February 2007. Growth stock management plan is available describing the plantation dynamics. Forest growth is closely monitored and used in the calculations and predictions in the decision making process regarding harvest of resources on a sustainable basis. The only control of wild animals that takes place on KLF properties is the control of baboons that cause damage to the plantation crop. Since 2006 KLF decided to follow the path of a self- imposed ban on the trapping and shooting of baboons. An Expert was contracted to review the issue and look for alternative methods of control or minimizing the damage to crops. An updated version of the Management plan was completed during June 2007. Harvesting techniques are described in the FMU harvesting EMS describing the optimal use of machinery and justifying the routes, system of harvesting and the identification of potential impacts with mitigation measures. A tactical plan is produced for scheduling harvesting machinery and is completed on the FMU. The goal of the tactical plan is also to produce a spatially feasible and sustainable plan that can be implemented on the ground. Viewed “Policy on the Method of Harvest Scheduling February 2007” Tactical plans are available at FMU level.
Criterion 7.2 Management plan revision
Strengths Weaknesses Compliance Several staff members are involved in the management plan updates and each component of the plan is functionalized per person. The update of the plan is a combined effort of several people. Most of the documents that make up the management plan are updated annually, others are every 3 to 5 years depending on the amount of strategic changes required. New scientific and technical developments are available at all FMU’s in the form of company newsletters, journals and magazines. New developments and results of monitoring are incorporated into management plans from SASS5 water quality biomonitoring, Working for Wetlands and wetland rehabilitation and management, Grassveld monitoring and burning plans, operational harvesting and sensitive sites.
Criterion 7.3 Training and supervision of forest workers
Strengths Weaknesses Forest workers are not adequately trained in the tasks assigned in all cases – see Criterion 4.2. It was also found that not all activities are supervised and monitored sufficiently to ensure that plans and procedures are adequately implemented. Minor CAR 06 was raised. Re-Assessment COF findings: An Action Plan was compiled by KLF and implemented – this was verified and the Minor CAR closed during the COF. Compliance From the sample of operations assessed during the Re-Assessment it was ascertained that management and supervisors have all received adequate training to complete the tasks they have been designated with the organisation’s plan, policies and procedures. Two exceptions were found at new contractor operations and are referred to above under “weaknesses”. Long-term training schedules exist for all employees, indicating who will be trained when and in what aspect – this was verified at New Agatha where the local FMU training schedule for 2007 was assessed and found to be compliant and implemented to date (for own staff). A weakness was identified with outsourced contracted workers (as indicated above) - inadequate training of some contracted employees visited. AD 36-A-05 Page 35 of 74
Criterion 7.4 Public availability of the management plan elements
Strengths Weaknesses Compliance The publicly available document entitled Environmental Report is dated 2006 and covers the period from 1 July 2004 to 31 March 2006. An updated version will soon be completed during 2007 for the time period from April 2006 to March 2007. The report covers the core values of KLF, an overview of operations, the environmental management programme (including all data on monitoring completed), environmental auditing and the results as well as stakeholder and community development and other issues listed under Principle 7.1.
PPPRRRIIINNNCCCIIIPPPLLLEEE 888::: MMMooonnniiitttooorrriiinnnggg aaannnddd eeevvvaaallluuuaaatttiiiooonnn
Criterion 8.1 Frequency, intensity and consistency of monitoring
Strengths Weaknesses Floristic and mammalian RTE species have been identified and are monitored, but with limited bird records and virtually no reptile/amphibian baseline studies or records available. Minor CAR 08 was opened under Principle 6. Re-Assessment COF findings: An Action Plan was compiled by KLF to close this Minor CAR prior to the 2008 Surveillance Compliance Monitoring information is available in the Environmental report that clearly describes 2 years worth of data on several operational, social and environmental issues. The frequency of monitoring and the expense allocated to it is defined per focus area such as: natural environment – SASS5; grassland; RTE species; HCVF’s; ASI’s; Delineation of wetland areas; waste management, harvesting impacts. Other aspects monitored are contractor compliance, chemical use and silviculture operations, harvesting and production operations, timber growth and resource utilization. Internal CARs (Corrective Action Requests) raised as result of monitoring are carried over to the respective CMP for the forest management unit with a date of closure and this is followed up by the environmental officers in the case of environmental issues or the operational managers in the case of harvesting or silviculture, with the same where social or safety issues are recorded as CARs – HR or the relevant safety manager will follow up for closure. A total of 325 PSP’s are distributed across the different plantations and includes Pine (258 plots), Eucalyptus (55 plots) and Wattle (12 plots) PSP’s. The PSP’s are monitored biannually
Criterion 8.2 Research and data collection for monitoring
Strengths Weaknesses Compliance During the lifetime of a tree, an inventory is carried out approximately 6 times. This takes place st nd at age 4, before the 1 thinning, before the 2 thinning, at age 20 to calibrate the SI20, at age 25 and then 1 year before clearfelling. All volumes from timber yields are recorded by the tally clerks in field on “data loggers and tally sheets” This data is the transferred to a computer program called “Logprog ver 5.3.0” which calculates the volumes. A volume reconciliation sheet is then sent to the planning department after the compartment has been completed. All incidents of injuries in field operations are recorded, and health and safety records are kept. NOSA audits are conducted and the risk / safety manager also conducts annual audits as well as the internal audit process that includes social, environmental, operational and safety aspects. All non-compliance is recorded and CARs raised for closure and follow-up by the relevant person(s). Several sites of post harvesting monitoring were assessed and followed-up and found to be compliant with closure of potential impacts identified, rehabilitation completed and very little waste overall as result of small contractors with pallet or tomato box producing plants, as well as communities taking fire wood. Contractor’s performance is monitored annually, including compliance with contract specifications and legal requirements such as minimum wage, PPE compliance, training and implementation of work according to FSC P&C and KLF procedures. AD 36-A-05 Page 36 of 74
Criterion 8.3 Chain of custody
Strengths Weaknesses Compliance There are no depots or landings that are used with other timber companies where contamination of FSC and non-FSC timber could take place. All logs are tagged with a waterproof paper tag (stapled onto the thin end of the log). This tag identifies the log in terms of its origin (compartment, species, FMU) as well as the client to whom it will go. Each tag is logged onto a PSION onto the “logprog” programme. Delivery notes and invoices are generated from this data. Sales invoices were assessed and found to be compliant in terms of the correct certificate number in the correct format displayed on all. Records are kept of all quantities per product sold as well as quantities sold to CoC clients.
Criterion 8.4 Incorporation of monitoring results into the management plan
Strengths Weaknesses Compliance New developments and results of monitoring are incorporated into management plans from SASS5 water quality biomonitoring, Working for Wetlands and wetland rehabilitation and management, Grassveld monitoring and burning plans, operational harvesting and sensitive sites.
Criterion 8.5 Publicly available summary of monitoring
Strengths Weaknesses Compliance The annual Environmental Report includes all relevant summaries of monitoring results and is available to the public.
PPPRRRIIINNNCCCIIIPPPLLLEEE 999::: HHHiiiggghhh CCCooonnnssseeerrrvvvaaatttiiiooonnn VVVaaallluuueee FFFooorrreeessstttsss
Criterion 9.1 Evaluation to determine high conservation value attributes
Strengths Weaknesses Compliance All FMU’s on KLF land with indigenous forest areas under KLF management is regarded as HCVF (High Conservation Value Forest). Baseline studies are conducted by a local forest specialist from MTPA – follow-up monitoring is scheduled for future periods once all KLF managed forest patches have been assessed. Initial assessments included Bergvliet and Berlin FMUs during 2004, followed by Maritzbos and Mauchsberg Bonnet during 2005. Morgenzon, Ngome, and Wilgeboom (north) HCVF were assessed during 2006, while this year (2007) Woodbush, Wilgeboom (south) and Maritzbos will be assessed. Nelshoogte and Tweefontein (Bonnet) is scheduled for 2008’s assessment and thereafter the remaining Uitsoek and Entabeni indigenous forest areas will be undergo a baseline assessment.
Criterion 9.2 Consultation process
Strengths Weaknesses Compliance KLF is a member of the local HCVF Working Group in Mpumalanga where consultation takes place regarding the type of assessments required for HCVF’s and the priorities of forest patches to be assessed as well and priority generic management requirements. Specific management measures are only finalized once a forest patch was assessed by an acknowledged expert. AD 36-A-05 Page 37 of 74
Criterion 9.3 Measures to maintain and enhance high conservation value attributes
Strengths Weaknesses Compliance Management prescriptions focuses mainly on patrolling to manage and minimize uncontrolled access and utilization in terms of medicinal plant (bark) removal and snaring of animals. The biggest impact is the invasive weeds colonizing open areas in the forests or along the forest ecotone – alien plant control along the forest edges and disturbed openings in the forest, is thus of major importance. Patrolling and bark utilization is under control but weeding requires attention – see related Minor CAR 04.
Criterion 9.4 Monitoring to assess effectiveness
Strengths Weaknesses Compliance Reports are completed for each assessment and monitoring is conducted by the district environmental personnel recording management recommendations in the specific FMU’s Environmental Management Programme (EMP). Environmental District Managers are made aware of research developments as discussed at the HCVF working group and implemented by the local specialist.
PPPRRRIIINNNCCCIIIPPPLLLEEE 111000::: PPPlllaaannntttaaatttiiiooonnnsss
Criterion 10.1 Statement of objectives in the management plan
Strengths Weaknesses Compliance KLF’s Management Objectives are stated in the plan and displayed on office walls. Objectives include sustainable production of sawtimber, contribution to socio-economic development and the minimization of environmental impact. Achievements of objectives are easily demonstrated from progress reports which provide detail of progress made on any activity as stated in the objectives. Monthly feedback sessions with presentations ensure progress made in economic, environmental, social or production objectives are constantly monitored.
Criterion 10.2 Plantation design and layout
Strengths Weaknesses Compliance The plantation design and layout is several rotations old and would be impractical and extremely costly to amend now to modern visually acceptable standards. However, where possible and practical the boundaries of commercial compartments are altered during the wetland delineation process to ensure that a more natural line is followed along wetlands and riparian zones with minimal impact to water resources and hydric habitats. All of the individual FMU’s are mapped in terms of natural vegetation and commercial plantations, including topography, soils information, roads and streams as well as cadastral boundaries and specialist information such as ASI’s, RTE habitats, etc.
Criterion 10.3 Diversity in composition
Strengths Weaknesses Compliance A total of 38 different species of exotic commercial timber trees are grown on KLF properties. The six dominant species are: Pinus patula, Pinus taeda, Pinus elliottii, P. ell. X P. caribeae, Eucalyptus grandis and Acacia mearnsii. Indigenous species are not grown for timber production since they cannot compete with the growth of the listed exotics. KLF policy states that the maximum clear-cut size is not more than one third of a catchment area per any 2 year period. AD 36-A-05 Page 38 of 74
Criterion 10.4 Species selection
Strengths Weaknesses Compliance Site-Species Matching is completed per compartment, based on climate, topography, slope and soil type. Most of the sites are suited to the primary product, sawtimber from Pinus patula trees but in total 38 different tree species are grown on KLF land. No evidence was recorded of trees being planted where they can not be harvested during the 2007 Re-Assessment period. Several PSP’s have been established at numerous FMU’s across the spread of KLF landholdings.
Criterion 10.5 Restoration of natural forest
Strengths Weaknesses Compliance Natural forests under management of KLF are never harvested and all are managed under full protection as HCVF’s. Plantations are permitted through the forestry permit system and KLF has legal permits to afforest the plantations certified. Some areas, like wetlands and riparian zones historically planted, are now reclaimed during the delineation process and managed for their conservation value.
Criterion 10.6 Impacts on soil and water
Strengths Weaknesses Compliance Minor CAR 58 identified during the last surveillance of the previous certificate was closed due to the work done on degraded sites. KLF identified several degraded sites at each of the FMUs since the beginning of 2007. Rehabilitated borrow-pits were visited at Belfast . The grassland at rock window (Blyde) was rehabilitated and the Jessievale site management plan completed. Projects at several FMU’s for restoration and rehabilitation are ongoing. In addition to this Working for Wetlands rehabilitated several zones of degraded wetland sites in the Lakenvlei system. Land preparation is based on site conditions and conforms to guidelines. Extraction methods varied from mules (thinning at Uitsoek C15) to forwarder, tractor, skidder or skyline operations, all were according to terrain conditions and no non-compliance were recorded at any of the harvesting sites visited. KLF has employed the full-time services of two roads engineers to plan and control all new roads and to manage the maintenance of all existing roads. A road maintenance strategy completed during 2005 and a Road maintenance policy dated February 2007 was perused and found to be very detailed and all-encompassing. Slash management was assessed at Woodbush and Roburnia where burning took place at compartments. Both instances the required documentation was completed and authorisation signed off by the relevant manager. No hoeing of tracers was noted on any of the firebreaks assessed.
Criterion 10.7 Pests and diseases
Strengths Weaknesses Compliance Forest pests and diseases are identified and recorded as and when noticed, or samples sent to the relevant experts to identify possible pests or diseases. KLF subscribe to FABI and is regularly updated with information of potential risks or new pests or diseases identified. Fire breaks are as wide and long as required by the specific site, slope or danger rating of the particular boundary. Since hoeing is not implemented anymore, the risk of erosion is minimal. Sites where hoeing is still the only alternative, specific preventative measures had been put in place to curb erosion and the sites are monitored regularly. Firebreaks are burnt after the tracer belts (treated with Gramoxone) were prepared (burnt) and these areas are then free of flammable material. AD 36-A-05 Page 39 of 74
The most important pest currently is the damage done to pine stands in the Escarpment area by baboons. This has been a continuous problem common to most forestry companies on the escarpment and these companies have formed a SA Baboon Damage Working Group where strategy is discussed and joint action is taken.
Criterion 10.8 Monitoring of impacts, species testing and tenure rights
Strengths Weaknesses Observation 05 under Criterion 1.1.1 was raised as result of the potential on-site impacts of the Mogoboya mill on KLF leased land in terms of waste (oil and mill waste such as bark etc.) Compliance A total of 27 EIA’s were completed for site disturbing activities on KLF FMUs since the beginning of 2007– these varied from water pipelines, access routes, power lines, water hydrant, stream crossings, landings, permanent depots, stacking points and the construction of a concrete apron.
Criterion 10.9 Plantations established in areas converted from natural forests after November 1994
Strengths Weaknesses Compliance None of the planted area on KLF properties consist of land converted since November 1994, all of the land has been in production for many years and most of it prior to 1972.
9. CERTIFICATION DECISION SGS considers that Komatiland Forests’ forest management of its (KLF) plantations in Limpopo, Mpumalanga and Kwa-Zulu Natal remain certified if: i. The single outstanding Major Corrective Action Request is to be closed during the COF (Closure of Findings) to take place on 26th of July 2007. The Major CAR may be closed if sufficient progress can be indicated by the company regarding the 11 Minor CARs raised. COF Findings: The Major CAR was closed based on progress with identified non- compliance and action plans for the remainder. ii. The outstanding Minor Corrective Action Requests (that can not be closed during the COF), will not preclude certification, but KLF is required to provide action plans for each Minor CAR, and the company must implement the agreed actions as proposed, before the next Surveillance in 2008. These will be verified by SGS QUALIFOR at the first surveillance to be carried out during 2008. If satisfactory actions have been taken, the CARs will be ‘closed out’; otherwise, Minor CARs will be raised to Major CARs. iii. The management system, if implemented as described, is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; iv. The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
10. MAINTENANCE OF CERTIFICATION During the surveillance evaluation, it is assessed if there is continuing compliance with the requirements of the Qualifor Programme. Any areas of non-conformance with the QUALIFOR Programme are raised as one of two types of Corrective Action Request (CAR): .01 Major CARs - which must be addressed and closed out urgently with an agreed short time frame since the organisation is already a QUALIFOR certified organisation. Failure to close out within the agreed time frame can lead to suspension of the certificate. .02 Minor CARs - which must be addressed within an agreed time frame, and will normally be checked at the next surveillance visit AD 36-A-05 Page 40 of 74
The full record of CARs raised over the certification period is listed under section 11 below. The table below provides a progressive summary of findings for each surveillance. A complete record of observations demonstrating compliance or non-compliance with each criterion of the Forest Stewardship Standard is contained in a separate document that does not form part of the public summary.
INTERIM RE-ASSESSMENT - COF Issues that were hard to None. assess Number of CARs closed 4 Outstanding Minor CARs and 1 Major CAR was closed. Nr of CARs remaining open 7 Outstanding CARs from the main assessment were not closed. New CARs raised 1 Major CAR and 11 minor cars were opened, of which 1 major CAR and 4 minor CARS were closed with the COF visit.. Recommendation The forest management of the forests of Komatiland Forests remains certified as: The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate. SURVEILLANCE 1 Issues that were hard to None in particular assess Number of CARs closed _5_ Outstanding CARs were closed. Nr of CARs remaining open _2_ Outstanding CARs from previous evaluations were not closed. New CARs raised _0_ New Major CARs and _6_ Minor CARs were raised. Recommendation The forest management of the forests of ____KLF_____ remains certified as: The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate. SURVEILLANCE 2 Issues that were hard to None assess Number of CARs closed 8 Outstanding CARs were closed. Nr of CARs remaining open 0 Outstanding CARs from previous evaluations were not closed. Nr of New CARs raised 0 New Major CARs and 6 Minor CARs were raised. Recommendation The forest management of the forests of KLF remains certified as: The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate. SURVEILLANCE 3 AD 36-A-05 Page 41 of 74
Issues that were hard to None assess Number of CARs closed 6 Outstanding CARs were closed. Nr of CARs remaining open 0 Outstanding CARs from previous evaluations were not closed. Nr of New CARs raised 0 New Major CARs and 9 Minor CARs were raised. Recommendation The forest management of the forests of Komatiland Forests remains certified as: The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate. SURVEILLANCE 4 Issues that were hard to assess Number of CARs closed __ Outstanding CARs were closed. Nr of CARs remaining open __ Outstanding CARs from previous evaluations were not closed. Nr of New CARs raised __ New Major CARs and __ Minor CARs were raised. Recommendation The forest management of the forests of ______remains certified as: The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over the whole forest area covered by the scope of the evaluation; and The certificate holder has demonstrated, subject to the specified corrective actions, that the described system of management is being implemented consistently over the whole forest area covered by the scope of the certificate.
AD 36-A-05 Page 42 of 74
11. RECORD OF CORRECTIVE ACTION REQUESTS (CARS) CARs raised during the last Surveillance of the previous (2nd) Certificate:
CAR # Indicator CAR Detail
Date 58 10.6.2 11/8/2005 Due Date> Next Surv. Date Closed> 13/06/2007 Recorded>
Non-Conformance:
Degraded sites are not identified and managed.
Objective Evidence: Road through the grassland to the rock window at Blyde and the surrounding quarries not identified and action plans in place to rehabilitate. Surveillance 4 (2006). At Jessievale a degraded site (old compound) was mapped and rehabilitated, but there was no management plan to verify the status of the rehabilitation. The work in progress was done and there is no need to raise the CAR to a major. The CAR remains open for monitoring.
Close-out evidence: KLF identified several degraded sites at each of the FMUs since the beginning of 2007. Rehabilitated borrow-pits were visited at Belfast , the grassland at rock window (Blyde) was rehabilitated and the Jessievale site management plan completed. In addition to this Working for Wetlands rehabilitated several zones of wetland in the Lakenvlei system. This CAR is closed.
Date 62 6.1.3 01/12/2006 Due Date> RA 2007 Date Closed> 13/06/2007 Recorded>
Non-Conformance:
Not all environmental impacts that are identified during assessments are considered during operations and planning to ensure they are avoided or mitigated.
Objective Evidence: The assessment that was done for the alterations to the airstrip buildings at Roburnia contained certain aspects that are allocated to the plantation manager. The assessment was not signed by the manager and the development differs from the prescriptions of the assessment. At Nelshoogte an assessment was done for a water pipe, but the conditions described in the assessment were not carried out.
Close-out evidence: Since the beginning of 2007 a total of 26 new internal Environmental Impact Assessments were completed, at New Agatha EIA (869/01-2007) for a concrete apron at the diesel filling site and Woodbush EIA (862/01-2007) stream crossing were assessed. The Woodbush stream crossing was a temporary crossing constructed for timber extraction, it should either be rehabilitated or upgraded to a permanent structure. [Surveillance 2008 Audit Lead]. Other EMP’s visited included the Blairmore permanent depot site at J14 and Belfast stream crossing at D8w. Both of these were compliant as well. This Minor CAR is closed.
63 7.3.3 Date See Minor 01/12/2006 Due Date> RA 2007 Date Closed> Recorded> 06
Non-Conformance:
Not all activities are supervised and monitored sufficiently to ensure that plans and procedures are adequately implemented.
Objective Evidence: AD 36-A-05 Page 43 of 74
CAR # Indicator CAR Detail
At Nelshoogte a truck that is used for labour transport, was found with a worn front tyre. There is a pre-use inspection system in use in the company, but despite the completed forms, the vehicle was operating for some time while not complying with standards. 2007 Findings: (1) Since the CAR was raised management followed up with internal audits and updated Assessment formats. An internal assessment for Woodbush revealed that the reporting of faults is not managed. (2) A First-aider’s certificate at Woodbush expired the following day. He’s training was not done prior to the audit inspection. He was also unaware of the fact. (3) A contractor audit conducted at New Agatha over five consecutive weeks revealed that the contractor was non-compliant on a number of issues but continued working during the period (non-compliance included inadequate PPE, no safety representative, no OHP etc.) On the same FMU a contracted thinning operation visited at Mogoboya G10 had no OHP. Due to progress in monitoring but implementation of results still lacking this CAR is not closed or upgraded but carried over to the new certificate period as Minor CAR 06.
Close-out evidence: Not closed – see Minor CAR 06
Date 64 3.3.1 15/12/2006 Due Date> RA 2007 Date Closed> 13/06/2007 Recorded>
Non-Conformance:
Sites of special cultural, historical, ecological, economical and religious significance are not adequately identified, described and mapped in co-operation with affected and interested stakeholders.
Objective Evidence: At Nelshoogte an old historic building was found that was not identified and described. It also lacks a management plan including maintenance of the building itself. Jessievale has a lane of oak trees that does not form part of production forestry, but it is conserved for its splendid vista and atmosphere. However it is not identified and managed as an area of special interest. However, throughout the company, KLF has made significant progress in identifying and managing ASIs and detailed registers and management plans are generally available, e.g. RTE sites at Roburnia and cultural sites at Morgenzon. A Close-Out Plan for Major CAR M61 has been accepted (15.12.06) resulting in the raising of this Minor CAR. The Close-Out Plan clearly sets out a program for re- evaluating each FMU and applying follow up action and verification during internal audits. The detailed registers and management plans for ASI’s in general can be seen as the company’s commitment to comply.
Close-out evidence: The updated EMS (Environmental Management System) sets clear standards for the identification and management of ASI’s, it is an ongoing process and KLF raised a CAR per FMU to close this non-compliance. The old historic building mentioned plus 10 additional ASI’s were registered at Nelshoogte, Belfast (5), Berlin (20), Jessievale (16), Ngome (4), Roburnia (11), Uitsoek (6), Brooklands (1), Morgenzon (5), Wilgeboom (3), Woodbush (4) and New Agatha (1). During the 2007 Re-Assessment it was found that identified ASI’s are managed as per proposed instructions – (examples are New Agatha graves and monument and Woodbush (F1) grave, Belfast and Roburnia graves). This Minor CAR is closed.
CARs raised during this Re-Assessment 2007 - (3rd) Certificate:
CAR # Indicator CAR Detail
Date 01 4.2.5 13/06/2007 Due Date> SA2008.31 Date Closed> 26/07/2007 Recorded> AD 36-A-05 Page 44 of 74
CAR # Indicator CAR Detail
Non-Conformance:
Medical Kits are not always available at all operations.
Objective Evidence: During December 2006, Observation (#10) was raised on the distance that chainsaw- operators were working from First aid kits. Close-out procedures for this Observation included the compulsory use of FAD 6 (First Aid Dressing) by all chainsaw operators and for First Aid Kits to be placed at the workplace with a 2nd back-up kit in the truck / bakkie. At New Agatha (Mogoboya) compartment G10 a contracted thinning operation was assessed where no First Aid kit was available and the compulsory FAD 6 was not available either. A KLF felling operation at JDM Keet, J23 the FAD 6 was also not available.
Close-out evidence: At all sites there were at least one (sometimes two) First Aid Kits with one or two trained First Aiders as well as certified copies of all training completed.
Date 02 6.2.4.2; 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 Recorded> 6.3.3.1; Non-Conformance: 6.5.3 Buffer zones, Wetlands and Water courses are not adequately protected and maintained.
Objective Evidence: (1) Lack of or inappropriate delineation of buffer zones.
(2) Lack of or inappropriate restoration plans for excised areas.
(3) Fire damage to sensitive (e.g. peat bog) wetlands.
COF – July 2007 Findings: KLF Action Plan: 1. Engaged with DWAF regarding the verification of KLF afforested areas, exchange areas and KLF Draft Policy on Delineation and Excision. This process to continue. 2. Pilot Project underway in cooperation with AfriGis to establish full extent of excisions on KLF land before any policy change is effected. 3. Until “bigger picture” with DWAF is resolved, KLF to focus on clear and obvious delineation/excisions during specifically clearfelling operations (replant to delineation line only). Delineation/Excisions during thinnings to be done only where there is a clear need to do so. 4. Internal Audits to focus specifically on this aspect. Non-compliant FMUs to revisit plantings of last 3 years and remove any trees planted in areas where delineation was not done properly. To be followed up during 2008.
Close-out evidence: - KLF sought legal opinion on the issue of wetland delineation and its legal and best practices impact on the operations. It concludes that KLF has the legal obligation to delineate wetlands and riparian areas in their forests. - They developed guidelines and methodologies for wetland delineation in conjunction with specialists. - A large number of staff was trained in the identification and delineation of wetland and riparian habitat by specialists. - Various sites visited on Entabeni, Woodbush and Wilgeboom indicate that delineation was done and all were compliant. CAR closed. AD 36-A-05 Page 45 of 74
CAR # Indicator CAR Detail
Date 03 4.4.3 13/06/2007 Due Date> SA2008.31 Date Closed> 26/07/2007 Recorded>
Non-Conformance:
Stakeholder lists are not maintained.
Objective Evidence: During Re-Assessment stakeholder consultation it was found that several of the telephone numbers, company names or names of individuals had changed or did not exist anymore.
Close-out evidence: A basic guideline was compiled to standardise lists and sent to Plantations regarding structure and information required. These lists were all updated and all known non- compliant data had been corrected and was verified during the COF assessment on 26/07/2007. This Minor CAR 03 is closed.
Date 04 6.2.4.1; 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 6.3.3.4 Recorded> Non-Conformance:
There is inadequate measurable progress in weed control / eradication programmes over time.
Objective Evidence: Initial control and follow up of weeds sometimes overlooks specific species or weed patches or annual follow up does not take place. COF – July 2007 Findings: KLF Action Plan: 1. Contract services of specialist to compile MUCP for Nelshoogte Plantation as Pilot Project. 2. Workshop Nelshooghte MUCP with Silviculture Foresters and decide on final format. 3. Compile MUCP’s for all Plantations 4. Implement MUCP’s – integrate into open area module-Micro Forest. To be followed up during 2008.
Close-out evidence: The MUCP’s was developed for all the FMUs and give measurable timeframes to get the weed into maintenance phase. It is linked to budgets and can be audited. It indicates the current scenario with current budgets and a role out plan that extends to 17 years in some instances. It also gives guidance with regards to required budgets to shorten this time frame to a maximum of seven years. Figures for the whole of KLF were not available yet. Future auditing of this issue needs to verify to what extend these additional budgets is made available and to what extend it is implemented. A system for reporting any changes to the plan and reporting progress with GIS supported maps are still being developed. The system take care of the philosophy of prioritising clean areas to keep them clean and then systematically grow the clean areas until the whole FMU is done. At Entabeni and Wilgeboom estates where the role-out was verified it was clear that the system work and significant amount of work was done to provide evidence for the CAR to be closed.
Date 05 8.2.3; 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 5.6.3 Recorded> Non-Conformance:
Insufficient evidence is available of NTFP’s in terms of resource use or availability to ensure sustainable utilization.
Objective Evidence: AD 36-A-05 Page 46 of 74
CAR # Indicator CAR Detail
NTFP’s (Non-Timber Forest Products) are utilized to different degrees on the various FMUs, but utilization is not recorded nor is a resource inventory conducted per FMU. COF – July 2007 Findings: KLF Action Plan: 1. Compile broad policy/strategy plan for KLF 2. Identification, resource inventory and recording of the use of NFTP’s per FMU. To be followed up during 2008.
Close-out evidence: The action plan was implemented and the NTFP uses are recorded per FMU. CAR closed.
Date 06 7.3.3 13/06/2007 Due Date> SA2008.31 Date Closed> 26/07/2007 Recorded>
Non-Conformance:
Not all activities are supervised and monitored sufficiently to ensure that plans and procedures are adequately implemented.
Objective Evidence: Minor CAR 63 raised in 2006 stated: At Nelshoogte a truck that is used for labour transport, was found with a worn front tyre. There is a pre-use inspection system in use in the company, but despite the completed forms, the vehicle was operating for some time while not complying with standards. 2007 Findings: (1) Since the CAR was raised management followed up with internal audits and updated Assessment formats. An internal assessment for Woodbush revealed that the reporting of faults is not managed. (2) A contractor audit conducted at New Agatha over five consecutive weeks revealed that the contractor was non-compliant on a number of issues but continued working during the period. Due to progress in monitoring but implementation of results still lacking this CAR is not closed or upgraded but carried over to the new certificate period as Minor CAR 06.
Close-out evidence: COF July 2007 Findings: 1. A Directive from GM Forests was sent out to all FMU’s. 2. District & Plantation Managers to ensure that suitable action is taken in cases where any non conformance is identified on any monitoring system or checklist. Non conformances can not be allowed to continue week after week. 3. See also the “Show Stoppers” identified and implemented as described under Minor CAR 09. An example of implementation was found at Witklip where oil leaking from a contracted vehicle was noted on the 19th of July 2007. A letter was handed to the contractor on the 20th requiring the vehicle to be removed and not to return until the leak was fixed. This Minor CAR 06 is closed.
Date 07 4.2.9 13/06/2007 Due Date> SA2008.31 Date Closed> 30 Oct 2009 Recorded>
Non-Conformance:
Sanitation and potable water does not conform to ILO Code of Practice or company standards in all cases.
Objective Evidence: AD 36-A-05 Page 47 of 74
CAR # Indicator CAR Detail
(1) The 2007 potable water analysis was declared unfit for human consumption at several sites. (2) At other sites, toilets were unsafe to use or inadequate in number. COF – July 2007 Findings: KLF Action Plan: 1. Technical Services to investigate and come up with an engineering solution to all non compliant villages and centrums. 2. Budget for water purification equipment and installation thereof. 3. Contract a Service Provider for monitoring of water quality and reporting per plantation. Progress 2008: The company employed an external company to do the sampling of all the estates. They also trained a number of staff in sampling techniques. The installation of the treatment plants has begun and forms part of the CAPEX budget for the next year. They obtained the quotes for the installation of the rest of the treatment plants. The CAR is not escalated to Major for the amount of effort and resources that did go into complying. However it is not closed either due to some shortcomings not addressed yet. There is a lack of a standard for Village maintenance and there is no guideline for dealing with asbestos during maintenance. (Woodbush village has asbestos roofs and the De Hoek village were lacking maintenance.
Close-out evidence: Significant progress has been made and management have committed to a programme to address the potable water situation. Villages visited were in an acceptable condition with sound roofs, electricity, hot and cold water. Below is a table of the management programme to deal with the water situation. In this format the progress can be easily monitored on an annual basis. Progress since 2008 to 2009 Plantation 2008 2009 Belfast All sites within specs All sites within specs Lakenvlei I site within spec 1 site within spec Berlin All sites 3 of 3 out of spec All sites within spec (dosing plant installed) Bergvliet All sites 5 of 5 out of spec All sites 5 of 5 within spec (Phase 1 planned for 2009) Brooklands All sites 4 of 4 out of spec All sites 4 of 4 out of spec (Phase 1. planned for 2009 ) Blyde 3 of 4 sites out of spec 3 of 4 sites within spec (Phase 1 planned for 2009) Entabeni 9 of 9 sites out of spec 9 of 9 sites out of spec JDM Keet 2 of 2 out of spec 1 of 2 out of spec Jessievale 3 of 3 out of spec All sites within spec (dosing pump installed) Morgenzon 3 of 4 out of spec 3 of 4 out of spec Nelshoogte 3 of 3 out of spec All sites within spec (Phase 1 planned for 2009) New Agatha 1 of 2 out of spec 1 of 2 out of spec Ngome 2 of 2 out of spec All sites within spec (dosing pump installed) Spitskop 3 of 3 out of spec 3 of 3 out of spec (New plant commissioned) Roburnia 2 of 3 out of spec All sites within spec (dosing pump installed) Witklip 2 of 2 out of spec All sites within spec (dosing pump installed) Swartfontein 1 of 1 within spec 1 of 1 within spec Uitsoek 1 site within spec 1 site within spec (Phase 1 planned for 2009) Wilgeboom 3 of 3 out of spec 3 of 3 out of spec (Phase 1 planned for 2009) Woodbush 3 of 4 out of spec 2 of 4 out of spec Tweefontein All sites within spec All sites within spec (dosing pump installed)
AD 36-A-05 Page 48 of 74
CAR # Indicator CAR Detail
Date 08 6.2.1 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 Recorded>
Non-Conformance:
Floristic and mammalian RTE species have been identified and are monitored to some degree, with limited bird records and virtually no reptile/amphibian baseline studies or records available.
Objective Evidence: (i) Dwarf chameleon presumed to exist at Morgenzon had not been identified, nor has the presence of the Woodbush gecko been confirmed at Woodbush. (ii) RTE birds are known at some of the FMUs but structured and consistent monitoring does not take place. (iii) Recording of RTE species by Forest guards / security companies is not always accurate COF – July 2007 Findings: KLF Action Plan: 1. Compile monitoring schedule for reptiles and amphibians on KLF Plantations. 2. Contract specialist/s to perform baseline assessments with Management Recommendations on FMU’s identified by specialist. 3. Implement management recommendations where feasible. 4. Follow up monitoring for reptiles. 5. Involve local Bird clubs on monitoring of RTE bird species. To be followed up during 2008.
Close-out evidence: The company involved the local conservation authorities in establishing C-Plan overlays of potential importance of certain areas and species. Various specialists, (VT Egon, Les minter, M Lotter, & G Theron) were consulted to provide specialist input into their various fields of reptiles, plants, frogs etc, adding to baseline knowledge and provide management recommendations where necessary. KLF has species list of their actual and presumed RT&E species on their estates. Structured monitoring takes place but are sometimes linked to bigger schemes. E.g. Cape parrot and blue swallow monitoring is done in conjunction with the respective working groups or bird clubs where the monitoring stretch beyond the boundaries of KLF estates. Ad hoc sightings and recordings of species is seen in the context of expanding baseline data basis and not as the only monitoring done.
Date 09 4.2.3 13/06/2007 Due Date> SA2008.31 Date Closed> 26/07/2007 Recorded>
Non-Conformance:
Workers interviewed have not consistently been trained for safe working practices nor are all aware of such procedures.
Objective Evidence: (1) Not all operators of chainsaws had evidence of training and poor safe working procedures were noted.
Close-out evidence: AD 36-A-05 Page 49 of 74
CAR # Indicator CAR Detail
COF Findings July 2007: Contracted operations (silviculture and harvesting) were visited at Witklip FMU – B46 and J5 as well as at Bergvliet FMU – A48b and M14. At all four sites there were at least one (sometimes two) First Aid Kits with one or two trained First Aiders as well as certified copies of all other training for machine operators, drivers, chainsaw operators. All chainsaw operators and drivers as well as supervisors interviewed displayed a very good knowledge of health and safety as well as environmental issues. In addition to these findings KLF has compiled a list of safety and environmental “Show Stoppers” that necessitates immediate stopping of operations. The “Show Stoppers” will be integrated into the Management Checklist and will be applicable to any new contractor that comes onto a plantation. To be verified before commencement of operations. This Minor CAR 09 is closed
Date 10 6.5.4; 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 Recorded> 6.7.2 Non-Conformance:
Waste is not disposed in an environmental sound manner.
Objective Evidence: Uncontrolled oil leakage, unplanned disposal of bark and the release of effluent with high coliform concentrations into natural systems resulted in this CAR being raised. COF – July 2007 Findings: KLF Action Plan: 1. Vehicles and Machines (both own and contractors) that leak oil will not be tolerated. Such vehicles/machines to stop operating immediately. 2. Directive from GM Forests regarding littering and cleaning of sites after operations. 3. Management Plan for depot at C30 on Uitsoek to be revised so that bark/soil waste is dealt with in a compliant manner. 4. Environmental Officer visited Roburnia and a plan has been compiled. To be implemented with immediate effect. New Scotland Sawmill management to sign for acceptance of management plan. 5. Technical Services to provide operational management plans and procedures for sewage treatment plants. Implementation of Operational Management Plans for sewage treatment plants. Contract Service Provider for monitoring and reporting on legal compliance of effluent from sewage plants.
Close-out evidence: Action plan as above has been implemented. Operations in field were clean and waste collection was provided. Operators of the sewage plants were trained in the operation and monitoring of the plants and upgrades to some of the plants are planned. Villages were inspected specifically to concentrate on litter and rubbish removal, the following villages were visited; Spitskop; Blyde; Tweefontein; and Jessievale. No litter was seen and the rubbish removal programme is operative. At Nelshoogte a specific area signposted as “Scrapyard” accommodates a range of old cars and general steel scrap, awaiting delivery to a scrap dealer. Toolbox talks have been conducted highlighting litter. The company internal audit programme has focused on litter and the subject has been tabled at Safety, Health and Environment meetings/forums. CAR is closed SA2009.32 follow up The village at Spitskop was visited and was found to be very neat and tidy with no litter, to the point where a compliment was passed on the by the auditor to management
Date 11 4.1.5; 13/06/2007 Due Date> SA2008.31 Date Closed> 10/10/2008 Recorded> AD 36-A-05 Page 50 of 74
CAR # Indicator CAR Detail
1.5.1 Non-Conformance:
Where possible and practical, communities are not given controlled access to forest and non-forest products on the FMU / Forest managers have not taken reasonable measures to monitor, identify and control illegal harvesting, settlement or unauthorised activities.
Objective Evidence: At several FMU’s no mechanism was in place to regulate controlled access to the plantation. COF – July 2007 Findings: KLF Action Plan: 1. Controlled access to FMU’s to be defined per activity, per FMU. 2. A standardised licence or other control systems to be implemented for the regulation of access where required. 3. Licence/other control systems to be used as basis for monitoring of controlled access. 4. Adapt access control measures where negative impacts are occurring. 5. Register of illegal harvesting, settlement or unauthorised activities to be kept by each FMU.
Due date : November 2007 – Plantation managers and Corporate Services. To be followed up in 2008.
Close-out evidence: All the FMUs are state land and access is permissible. Control measures are merely to prevent illegal activities. Action plan as indicated above is implemented. CAR closed.
Date M12 PROC 13/06/2007 Due Date> 14/09/2007 Date Closed> 26/07/2007 04-02 Recorded> Non-Conformance:
Failure to ensure adequate continued compliance with the FSC standard.
Objective Evidence: Reference to the 11 Minor CARs rose during the 2007 Re-Assessment.
Close-out evidence: COF Findings – July 2007: Based on the closure of 4 Minor CARs (1, 3, 6 and 9) and 2 Observations (1 & 4), as well as the provision of adequate Action plans for all other outstanding CARs with dates and responsible persons allocated to each action – this Major CAR 12 is closed.
Date 13 10.8.2 10/10/2008 Due Date> Next SA Date Closed> 30 Oct 2009 Recorded>
Non-Conformance:
Off site impacts are not adequately monitored and treated and there is no evidence of consultation with affected parties.
Objective Evidence: Plantation species are spreading onto neighbouring farms on the northern boundary of Woodbush.
Close-out evidence: AD 36-A-05 Page 51 of 74
CAR # Indicator CAR Detail
The control of spread of exotic plantation species are described in the IMS under the Natural Resource Manual para 4.7. The action is to: • Record all commercial species on neighbouring property • Provision for the eradication of the spread of the commercial tree • Proactive control of the commercial species spread • Identification of the locations of the spread of escapees and plans to eradicate • Timeous follow ups to minimise the spread of escapee weeds. A letter was drafted and sent to all neighbours on 27 July 2009 regarding the “escape of commercially grown tree species from KLF to adjacent private property. The owners were asked to respond. They were given a choice of whether they would like the trees to remain or whether they would like KLF to schedule the eradication of the trees. There were numerous respondents and their comments have been recorded and scheduled. At Nelshoogte “escapees” have been controlled at two areas. A total of R 95,743 was used to clear these 2 areas.
Date 14 4.2.2 10/10/2008 Due Date> Next SA Date Closed> 30/10/2009 Recorded>
Non-Conformance:
Not all risks associated with the company’s key responsibilities have been adequately assessed.
Objective Evidence: Several estates have dams on the estate that is managed by the company. The risks of dam safety for those dams with walls higher than 5 m was not adequately assessed as required by chapter 12 of the Water Act.
Close-out evidence: There are three existing dams that were registered on 07/04/2009. These registrations have been confirmed by Department of Water Affairs – Dam Safety Office. Two of these dams are in the Louis Trichardt district and the third in the Vryheid district. The registration is for dams where the maximum wall height exceeds 5 meters and the gross capacity is more than 50,000 cubic meters.
Date 15 8.1.4 10/10/2008 Due Date> Next SA Date Closed> 30 Oct 09 Recorded>
Non-Conformance:
Monitoring information is not readily available in a format that facilitates effective auditing.
Objective Evidence: At Timbadola sawmill that is situated on the Entabeni FMU the results of monitoring of dust and fly ash from the stacks as required by the permit was not available for auditing. Although a letter from the service provider was provided that the underground fuel storage tank had an integrity test done, the results of the test could not be provided.
Close-out evidence: A report from Exco Environmental and Occupational Health Services was provided on 28 May 2009 with the results from the Stack Emission Monitoring A vacusonic test data sheet was received from Ummbele Installations on 15 May 2009 on the results of the underground fuel storage tank at Timbadola Sawmill
Date 16 6.3.3 10/10/2008 Due Date> Next SA Date Closed> 30 Oct 2009 Recorded>
Non-Conformance:
There is no program for the restoration of degraded sites. AD 36-A-05 Page 52 of 74
CAR # Indicator CAR Detail
Objective Evidence: Old and abandoned buildings at Entabeni (Timbadola Sawmill) and Woodbush (De Hoek workshop) have no management plans for maintenance or proper decommissioning.
Close-out evidence: KLF management developed a programme which has included the following;
• Safety officers have completed a basic safety risk assessment (electricity and structural) on all old and abandoned buildings with recommendations. In April 2009 Technical Services (TS) had been formed to address the results of the above.
• TS allocated an official who compiled a data register of all structures that includes the current state of the buildings covering, eg. roofing, structural soundness, type of structure etc., and to compile long term maintenance plans.
• Old and abandoned buildings were included in this process which was completed in October 2009 and included in excess of 600 buildings. In addition a policy was approved to facilitate the process to address the maintenance or decommissioning of structures.
• In summary, derelict, unsafe or uneconomical buildings will be removed by operations or by way of SED initiatives, and will be financed as part of the Forests budget.
This process due to the complexities of the lease with DWAF, geographical locations and resources will be completed in June 2013.
Date 17 6.5.1 10/10/2008 Due Date> Next SA Date Closed> 30 Oct 2009 Recorded> 6.5.2 Non-Conformance:
Written guidelines for environmentally sensitive operations are not well defined to meet or exceed best practices and neither are they implemented during operations.
Objective Evidence: There was damage to standing indigenous trees along the extraction route in the excise operation of compartment H5. Woodbush, which could have been prevented or mitigated.
Close-out evidence: Written guidelines have been prepared for each activity by the personnel of the environmental department. No damage of indigenous trees were observed during operations, in particular A8b at Ngome plantation 18 1.1.1 Date Recorded 10/10/2008 Due Date> Next SA Date Closed> 30/10/2009 >
Non-Conformance:
Evidence of non-compliance with national legislation and administrative processes
Objective Evidence: The APPA Certificate for Timbadola Sawmill has expired. There is a requirement to apply for a license within 24 months of the proclamation of the new National Air Quality Management Act. Employment contract between Brooksaf Forestry and M. Vhukeya does not provide an accurate description of the work for which she is employed, her place of work or of her hours and days of work. The contract does not clearly spell out the specific leave arrangements of her job.
Close-out evidence: AD 36-A-05 Page 53 of 74
CAR # Indicator CAR Detail
In a letter 23/09/2009 the Deputy Director: Air Quality Management Chief Directorate; is quoted as “The Registration Certificate no. 2050/1 is still valid”. The company will be required to convert the certificate into a Atmospheric Emission License under the new Environmental Management : Air Quality Management Act 39 of 2004. The company will have three years to do this conversion from the date of the repeal of the District Municipality. A new fixed term contract of employment for the employee at the hiking hut has been agreed to and formally signed. All employment requirements are included in this contract. 19 6.7.2 Date Recorded 10/10/2008 Due Date> Next SA Date Closed> 30 Oct 2009 >
Non-Conformance:
Waste is not disposed in an environmental sound manner.
Objective Evidence: At De Hoek and to lesser extent Spitskop villages, the perimeter outside the village fence was littered with bottles and general waste despite the fact that adequate waste removal services were provided.
Close-out evidence: Action plan as above has been implemented. Operations in field were clean and waste collection was provided. Operators of the sewage plants were trained in the operation and monitoring of the plants and upgrades to some of the plants are planned Villages were inspected specifically to concentrate on litter and rubbish removal, the following villages were visited; Spitskop; Blyde; Tweefontein; and Jessievale. No litter was seen and the rubbish removal programme is operative. At Nelshoogte a specific area signposted as “Scrapyard” accommodates a range of old cars and general steel scrap, awaiting delivery to a scrap dealer. Toolbox talks have been conducted highlighting litter. The company internal audit programme has focused on litter and the subject has been tabled at Safety, Health and Environment meetings/forums. Waste from Nelshoogte is collected every Thursday and taken to a waste disposal site located on the FMU. A letter 16/2/7/X301/B36 from DWAF confirms the authorization for the general waste disposal facilities in terms of sections 20(5) (b) of the ECA 75 of 1989. They are in accordance with the minimum requirements for waste Disposal by Landfill (2nd Edition 1998). 20 7.1.1 Date Recorded 30 Oct 09 Due Date> Next surv Date Closed> 15 Oct 2010 >
Non-Conformance:
There is no document or overview linking different planning documents in the management plan.
Objective Evidence: There are several documents that make up the overall management plan. The various plans (are listed on a document held by the Environmental Manager. Other elements appear in the Integrated Management System (IMS) as well as the Corporate Plan. There is no overview that links the various documents.
Close-out evidence: The company has created a “IMS policy Manual” dated 01/05/2010 which describes the Integrated Management System that is being used in KLF. The IMS policy manual contains the components a – h. CAR 20 is closed. 21 8.3.3 Date Recorded 30 Oct 09 Due Date> Next Surv Date Closed> 15 Oct 2010 > AD 36-A-05 Page 54 of 74
CAR # Indicator CAR Detail
Non-Conformance:
Sales invoices and other documentation related to sales of certified material do not always include the chain of custody certificate number, and not in the correct format (SGS-FM/CoC-XXXXXX)
Objective Evidence: Sales invoices contain the relevant information, however this is not in the correct format and the FSC claim (ie FSC pure) does not appear on the delivery notes. Invoice FT 9200665 of 31/08/09 has the format at SGS-FM-COC-0068, whereas the format should be SGS-FM/CoC-000068. Delivery Note 8210005306 has the CoC certificate number in the SGS-FM-COC-0068 format and the FSC Pure claim does not appear on the delivery note.
Close-out evidence: The invoicing system has been corrected. The invoices, delivery notes and credit notes are displaying the chain of custody certificate number in the correct format as SGS- FM/CoC-000068 – FSC Pure. Delivery note 86200004590 of 12 Oct 2009 for poles from Woodbush Plantation is correct as well as invoice 8040000037 from Brooklands Plantation. 22 6.1.5 Date Recorded 30 Oct 09 Due Date> Next SA Date Closed> 15 Oct 2010 >
Non-Conformance:
Corrective action requests (CARs) are recorded and not closed out appropriately
Objective Evidence: CAR’s are closed out in some instances (CAR 715-014 closed on 31/08/09 at Ngome. CAR’s 718-010 and 718-015 closed out at Nelshoogte); however there are many instances where these CAR’s are left open longer than the scheduled date. Many CARs are reported as “ongoing” .
Close-out evidence: The Internal CAR system has been completely revised by having the system decentralised to the four districts. The Environmental Practitioners now report directly to the District Manger which now involves line management in the CAR’s, whereas before they were not always directly involved. Each Environmental Practitioner controls the CAR register, and this is then reported into Head Office at the end of each month. Each CAR is given a specific close out date, and the term ‘ongoing” is no longer being used to monitor CAR’s. As per the District Meeting of 6 July 2010 held at Jessievale Plantation, the minutes noted that no CAR with a target date may be postponed more than 3 times. The CAR register for the Highveld District showed that there were no overdue CARs. All CARs were closed out on time in the Central District. (See CAR register for Highveld and Central Districts).
Date 23 10.3.2 30 Oct 09 Due Date> Next Surv Date Closed> 15 Oct 2010 Recorded
Non-Conformance:
Maximum clear-cut size is not defined. No documented justification could be provided where there are potential adverse environmental or socio-economic impacts
Objective Evidence: The clear-cut size has not been defined and documented.
Close-out evidence: AD 36-A-05 Page 55 of 74
CAR # Indicator CAR Detail
The Harvesting Manual (updated 01/10/2010 Ref FH 001-03) defines the size of clearfelling as “no more than one third of the catchment should be clearfelled within a two-year period” This is in accordance with the Environmental Guidelines for Commercial Forestry Plantations in South Africa (Aug 2002) page 13.
Date 24 1.1.1 30/10/2009 Due Date> Next Surv Date Closed> 15 Oct 2010 Recorded
Non-Conformance:
There is evidence of non-compliance with national and local laws and administrative requirements
Objective Evidence: The contracts of employment for the KLF permanent staff and sub-contractors do not comply with the minimum requirements of the Basic Conditions Of Employment for the Sectoral Determination 12 for the Forestry Sector South Africa.
Close-out evidence: The latest version of the contract of employment for KLF permanent staff , SC 12 Production 12/10/10, meets or exceeds the requirements of the Basic Conditions Of Employment for the Sectoral Determination 12 for the Forestry Sector South Africa. The silviculture contractors at the following plantations were checked and found to comply at Wood bush; Morgenzon; and Uitsoek.
Date 25 4.1.7 30/10/2009 Due Date> Next SA Date Closed> 15 Oct 2010 Recorded
Non-Conformance:
Not all contractors and sub-contractors are paid a fair wage and other benefits, which meet or exceed all legal requirements and those provided in comparable occupations in the same region
Objective Evidence: Contractors and sub-contractors’ employees are not paid a fair minimum wage, which meets or exceeds all legal requirements as per the Sectoral Determination 12: Forestry Sector
Close-out evidence: The entire wage register for all KLF employees was checked and found to comply with the required minimum wage. The contractor wage registers at three of the plantations were checked in detail and found to comply with the wage rate applicable form 01/04/2010, as per the table below, for both existing and new employees.
1st April 2010 - Period 31st March 2011 Per Month R 1 221.83 Per Week R 281.98 Per Hour R 6.26
Date 26 10.7.1 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
The principle forest pests and diseases are not identified.
Objective Evidence: While the principle pests and diseases are known at plantation level, there is no documented evidence of these identifications
Close-out evidence: AD 36-A-05 Page 56 of 74
CAR # Indicator CAR Detail
Date 27 10.6.1 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Site information is not being used in all forestry operations
Objective Evidence: The soils info is not being used when planning harvesting operations at Woodbush, compartments G4 and C26
Close-out evidence:
Date 28 1.1.2 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Forest managers do not demonstrate awareness with recommendations of the Record of Decision from the EIA process
Objective Evidence: The conditions from the ROD from the erection of the WAN towers at Belfast and Roburnia have not been fully complied to.
Close-out evidence:
Date 29 7.2.5 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
There is no timetable for the periodic review of the management plan
Objective Evidence: While the relevant sections of the management plan are being updated on a regular basis, there is no documented timetable that outlines periodic revision.
Close-out evidence:
Date 30 4.2.4 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Forestry operations do not comply as a minimum with the ILO code of Practice on Safety and Health in Forestry
Objective Evidence: At compartment A11 at Belfast Plantation, five trees were hung up and not dropped or demarcated as per the requirements of the ILO code of Practice on Safety and Health in Forestry
Close-out evidence:
Date 31 1.2.1 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
There is no evidence that required payments have been made. AD 36-A-05 Page 57 of 74
CAR # Indicator CAR Detail
Objective Evidence: The silviculture contractors at the three plantations visited calculate the UIF payment only on the basic wage and not the total earnings. This was established from scrutinising the wage registers in each case.
Close-out evidence:
Date 32 4.2.7 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Health and safety records (including risk evaluations, accident records) are maintained and up-to-date but exclude contractors.
Objective Evidence: The contractors reporting systems were checked and it was found that only five out of 18 of the plantations include the contractor statistics, therefore accident reporting has been understated.
Close-out evidence:
Date 33 4.2.9 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Where located and provided on the FMU, worker accommodation does not comply as a minimum with the ILO code of Practice on Safety and health in forestry.
Objective Evidence: The fire fighting equipment at the Uitsoek Village, with a capacity of 120 inhabitants, is limited to two fire extinguishers and two hydrants for which there are no hoses. This situation was assessed to be an unsafe situation, especially with cooking taking place in the houses.
Close-out evidence:
Date 34 4.5.2 15/10/10 Due Date> Next SA Date Closed> Recorded
Non-Conformance:
Dispute resolution is not clearly defined. The system for resolving disputes includes legal requirements and is not documented for large scale organizations.
Objective Evidence: Apart from the Grievance Procedure for staff, there is at present no “documented system for resolving disputes including legal requirements” for resolving disputes or for providing fair compensation in the case of loss or damage affecting the legal or customary rights, property, resources or livelihoods of local stakeholders.
Close-out evidence:
AD 36-A-05 Page 58 of 74
AD 36-A-05 Page 59 of 74
12. RECORD OF OBSERVATIONS Observations raised during the last Surveillance of the previous (2nd) Certificate:
OBS # Indicator Observation Detail
7 6.5.4 Date Recorded> 01/12/2006 Date Closed> Upgraded
Observation:
Legal compliance. The sewage plants installed at Jessievale and Nelshoogte do not comply with regulatory requirements regarding the specification regarding effluents.
Follow-up evidence:
This Observation could not be closed and was upgraded to Minor CAR 10. 8 6.5.2 Date Recorded> 01/12/2006 Date Closed> 13/06/2007
Observation:
The form that is used for control burning has only a small area for comment on post burn observations. It does not give enough guidance for the manager as to the criteria for evaluation and is therefore very seldom completed.
Follow-up evidence:
The form was adapted and now includes a much bigger section for comment on post burn observations. It was made available for management on the 27th of May 2007 and has not yet been used. Comment section now includes post operation questions such as: (1) Condition of the soil, (2) Condition of the humus layer (3) Possibility of erosion (4) Measures in place to control erosion. This Observation is closed. 9 4.4.5 Date Recorded> 01/12/2006 Date Closed> 13/06/2007
Observation:
The stakeholder consultation in KLF is generally of an exceptionally high standard. However concerns are present regarding the consultation with a local community in Nelshoogte area.
Follow-up evidence: The Nelshoogte stakeholder consultation issues had been resolved with the local community, documentation of meetings and solutions to the problems were available, assessed and this Observation is closed. 10 4.2.4 Date Recorded> 01/12/2006 Date Closed> Upgraded
Observation:
The medical kits are not always easily accessible during operations. Specific reference is made to the distance of the medical aid kits from chain saw operators at Nelshoogte.
Follow-up evidence: Close-out procedures for this Observation included the compulsory use of FAD 6 (First Aid Dressing) by all chainsaw operators and for First Aid Kits to be placed at the workplace with a 2nd back-up kit in the truck / bakkie. At New Agatha (Mogoboya) compartment G10 a contracted thinning operation was assessed where no First Aid kit was available and the compulsory FAD 6 was not available. A KLF felling operation at JDM Keet J23 the FAD 6 was also not available. This Observation is raised as Minor 01.
Observations raised during this Re-Assessment 2007 - (3rd) Certificate:
OBS # Indicator Observation Detail
01 6.5.2 Date Recorded> 13/07/2006 Date Closed> 26/07/2007
Observation: AD 36-A-05 Page 60 of 74
OBS # Indicator Observation Detail
Inadequate implementation of guidelines developed to protect the environment during sensitive forest operations. Roburnia B19 thinning operation – OHP stated grave and kraal would be demarcated (no demarcation of kraal).
Follow-up evidence: The above non-compliance was an isolated incident, no additional sites were found with ASI’s or sensitive sites in operational compartments. All operations visited during the COF assessment of 26/7/2007 included interviews with workers and supervisors regarding identification and management of ASI’s or other sensitive sites. All displayed an excellent awareness of company requirements and BOP’s and as result this Observation is closed. 02 4.2.1 Date Recorded> 13/07/2006 Date Closed> 10/10/2008
Observation:
The Company does not meet or exceed all applicable laws and/or regulations covering health and safety of employees and their family. COF – July 2007 Findings: KLF Action Plan: All safety reps have been trained. Evaluation and in service training to be given in: 1. Practical implementation of roles and responsibilities of safety reps. in the workplace. Due date : September 2007 by A. Odendaal. To be followed up during 2008.
Follow-up evidence: Safety reps were appointed and trained in their work. 03 6.3.2 Date Recorded> 13/07/2006 Date Closed> 10/10/2008
Observation:
Implementation of an appropriate silvicultural system is not consistent. The farm Pan, falling under the Belfast plantation is currently dormant and in a transition period with a phase-out strategy. The current silviculture procedure is not to plant and management is limited, making this farm unsustainable in terms of FSC P&C. COF – July 2007 Findings: KLF Action Plan: At the time of COF, there was no final decision on Pan. The following options are being investigated 1. Re commence commercial planting regime. 2. Excise Pan from KLF lease agreement. 3. Withdraw Pan from FSC Certified area on KLF Due date : February 2008 - MANCO and KLF Board of Directors (Arrie Bijl). To be followed up during 2008.
Follow-up evidence: After all the options were assessed the decision was made to re-commence with the planting of Pan plantation and it will remain a certified FMU. 04 4.2.2 Date Recorded> 13/07/2006 Date Closed> 26/07/2007
Observation:
Appropriate risk-assessment was not done for all activities relating to safety and equipment (PPE).
Follow-up evidence: A full Risk Assessment was conducted by PPE Technologies from Nelspruit (JJ McAllister) report dated 25 July 2007 – Doc. No. GQ706095. Look-out Tower Access report – the report was completed for 9 towers on the highveld area with recommendations on providing safe access to the towers and comments on other safety deviations. This Observation is closed. AD 36-A-05 Page 61 of 74
OBS # Indicator Observation Detail
05 1.1.1 Date Recorded> 13/07/2006 Date Closed> 10/10/2008 Observation:
Mogoboya mill is presently under the KLF lease agreement. As a result of various environmental non-compliances, KLF runs the risk of incurring liability in respect of i.e. pollution. Finalization of the excision / lease agreement is required. COF – July 2007 Findings: KLF Action Plan: At the time of COF, there was no final decision on Mogaboya. The following options are being investigated - 1. Excise Mogoboya mill from KLF lease agreement. 2. Cancel Mogaboya lease contract. 3. Institute external control measures such as ISO 14000 certification. 4. Find amicable cooperative way of resolving safety and environmental issues on a sustainable basis. Due date : February 2008 - MANCO and KLF Board of Directors (Willem Hollenstein) To be followed up during 2008.
Follow-up evidence: Lease cancelled. In process of rehabilitating site. 06 No further action Date Recorded> 10/10/2008 Date Closed required
Observation:
During the audit, several good and positive observations were made that require no further action but are noted. - Management presence during the audit. Also management board presence at the closing meeting. - Good audit preparation with files and required information readily available at Berlin, Wilgeboom. - Roads were noticeably well attended to and although not selected as audit site visit, it was noted that a sincere effort was made on all the estates and that all the roads seen were in good shape. - On weeds one is always reluctant to make positive comments, because it is such an easy topic to go wrong if sustainable funding and effort is not maintained. Regardless of that, KLF has perform well on the short term and the high risk estates like Entabeni and Wilgeboom was remarkably clean. - The excising of isolated plantation patches in the indigenous forest at Woodbush is a good conservation initiative. - Fire awareness, prevention and Management system.
Follow-up evidence: No further action required. 07 1.1.1 Date Recorded> 10/10/2008 Date Closed 30 Oct 2009
Observation:
Lack of details filled in prescribed forms: - EMP forms are being updated, but not all the defined fields are filled in. The form also contains a section on auditing that is not descriptive and not helping the manager to achieve their goals. - Complaint register was filled in but a few forms lack information in certain fields. .
Follow-up evidence: EMP forms at Ngome 715/01-2009 and 715/02-2009 were evaluated and found to be complete, with all fields filled in. 08 Date Recorded> 10.10.2008 Date Closed 30 Oct 2009 AD 36-A-05 Page 62 of 74
OBS # Indicator Observation Detail
Observation:
At Wilgeboom village a scrapyard is starting to develop.
Scrap is removed on a regular basis, as soon as there is enough scrap to justify a full load. Nelshoogte scrap is gathered and removed 09 6.5.4 Date Recorded> 30 Oct 2009 Date Closed 15 Oct 2010
Observation:
Although operators are aware of and able to implement adequate emergency procedures for clean up following accidental oil and chemical spillages, there are insufficient control measures at site where fuel is potentially held. There is no bunding wall at the generator house of the water pump at Nelshoogte.
Photographic evidence was received that the bunding wall had been built to contain the fuel in the event of a tank burst. 10 10.6.2 Date Recorded> 15 Oct 2010 Date Closed
Observation:
Where soils are degraded from previous activities, there are plan to restore them, however at Belfast there are only 18 plans compared to the 20 sites that require restoration.
13. RECORD OF STAKEHOLDER COMMENTS AND INTERVIEWS
Nr Comment Response
Main Evaluation
1. 25(+) Stakeholders: All the positive responses were filed with those mentioned below and KLF is congratulated with the Between 20 and 30 of the responses received large number of positive feedback forms. with regard to the 2007 Re-Assessment were positive feedback supporting KLF’s commitment to FSC P&C and providing several motions of good relations between the company and its stakeholders. AD 36-A-05 Page 63 of 74
Nr Comment Response
2. Stakeholder 1: (a) The industry guideline requires that wetland and riparian delineation be completed along all NGO feedback required: (a) “..remove all hydromorphic or riverine zones taking into account trees from the buffer riparian zone which topography, vegetation and signs of wetness in the soils should be at least 30m each side of the centre (hydromorphy). This is generally being completed after line of a river, stream or drainage line.” clearfell harvesting of a compartment. KLF did not (b) KLF is urged to carefully examine their consistently comply with all of the procedures at sites coverage on a per catchment basis, with a visited and a Minor CAR was raised # 02. view to reducing stream flow reduction to a (b) KLF’s plantation afforestation is legal with evidence level that does not create water shortages of the required permits and water use licences. They downstream, especially in the White River are not the only forestry company in the mentioned catchment. catchment and the weed control and wetland (c) The stakeholder urges that greater delineation is part of the plan to minimize the impact of attention is given to destroying alien and plantations on water resources. invasive vegetation that is seen growing in (c) Weed control activities was assessed at all FMU’s and along side plantations. visited during the assessment. KLF has extensive plans of all Land Management Units (no-commercial and commercial). It was found that follow-up activities do not take place as planned or required and not all weeds are controlled in non-commercial zones. Due to this and the overall lack of impact that past weed control operations had a Minor CAR was raised, # 04. 3. Stakeholder 2: (a) See 2 (a) above regarding Minor 02; NGO Conservation Forum raised the (b) Harvesting and post-harvesting operations were following: (a) plantations planted to near to visited where these are situated adjacent to indigenous rivers or straight through drainage lines; forests, wetlands and riparian zones at all 5 FMU’s visited and compliance was noted in all cases. Plans (b) when plantation next to forest was felled, carefully highlighted SMZ’s (Special Management indigenous trees were damaged in the Zones) and at no compartment visited could any process; negligence or damage to natural habitats be identified. (c) Specific wetland and grassland areas were (c) See 2 (c) above regarding Minor CAR 04. mentioned with regards to weeds and lack of alien plant control. (d) All certified plantation owners in South Africa is aware of the impact of plantations on the natural (d) The biodiversity value of specific environment. KLF has identified specific areas per grasslands and in particular plant, reptile and FMU that will never be planted and manage these as bird endemics are impacted on because of conservation zones. Other areas have been excised plantations. from commercial forest for specific protection of particular species (Rare and Endangered). KLF also monitors RTE mammals and plants on an ongoing basis. Baseline information on amphibians, reptiles and in some cases of birds was found to be lacking and as result of this Minor CAR 08 was opened. 4. Stakeholder 3: KLF responded that the company has decided to ban all off road motor-biking and Quad-biking after a fatal A neighbouring forest manager suggested accident and as result of damage to sensitive land on that KLF “tend to exclude a certain sector of steep zones where ill-informed riders cause erosion and the local community by not allowing Quad or damage to native vegetation. Several hiking trails, off-road biking (motorbike) on their property” picnic sites, camping and overnight huts, horse riding and proposed that should these activities be and mountain biking routes are available to the public regulated by a registered service provider it and actively advertised. would keep illegal resource use to a minimum. AD 36-A-05 Page 64 of 74
Nr Comment Response
5. Stakeholder 4: (a)The particular hiking trail was closed prior to KLF’s lease of the property when it was still managed by the A Government Department requested that: Department of Water Affairs and Forestry. It was (a) A specific hiking trail be renovated and closed based on security issues with hikers and will not managed. be re-opened due to the current security situation in the area. A consultant is at present contracted by KLF to (b) A particular road was mentioned as in investigate potential opportunities of involvement of need of repair and maintenance. local communities in the area in other ventures than hiking trails. (b) The specific road was upgraded last year and is up for maintenance on this year’s budget again, evidence was provided of budget availability and allocation. 6. Stakeholder 5: (a) KLF responded that he road was ripped due to the fact that a pot-holed tar road is worse than a poorly A Lodge Owner raised the following concerns: maintained dirt road. Since then it had been graded (a) A tar road was ripped in 1998 and since and rolled. With the mill being ‘moth-balled’ traffic then has become a dust hazard. activity will be reduced to a contractor transport vehicle, which will reduce dust problems. (b) Baboons are continuously harassed. (b) Since May 2006 KLF implemented a self-imposed (c) The closure of a local sawmill resulted in moratorium on the controlling of baboons. The Baboon the occupation of certain individuals that was Working Group continues to meet and KLF employed described as a lawless element and since the services of an acknowledged expert in problem closure of the site several cases of theft had animal control. A draft document was completed during taken place. 2007 to assess possible non-lethal methods of managing baboon damage. At present no harassment or capture etc. is taking place. (c) There is no evidence that theft can be associated to the particular village site. KLF employs the services of a security company stationed at the village and mill complex, theft was noted at the mill and the company was replaced by a different private security agency and since then no problems were identified. It is planned that KLF forests will in future take control of the village site and control the occupants. 7. Stakeholder 6: (a) KLF was not aware of any Dwarf chameleon communities at this FMU and as result of this and other A farm owner and neighbour to one of the KLF associated non-compliance Minor CAR 08 was raised. Forest Management Units (FMU’s) responded See also 3 (d) above. as follows: (b) The company responded that adequate time is given (a) A large number of Dwarf Chameleon is for neighbours to plan their assistance or presence at killed annually due to the early burning of fire- external break burns. Due to climatic conditions and breaks in the area (pre-mid June). the amount of burning required on highveld plantations, (b)The land owner felt that there is insufficient forestry companies cannot always wait till land-owners planning of fire break burning with adjacent are able to assist. KLF also stated that the responsible land holders and farmers are just told when it Area Manager visit the particular land owner to explain will take place. The land owner stated that he the problems around burning and come to a mutual would prefer to discuss this matter with the agreement. relevant Area Manager. (c) Fire breaks at this particular site was assessed and (c) The land owner also felt that fire breaks found to be of standard width with exception of block are too wide. burns / ecological burns, it may be that the neighbour confused ecological block burns with those of external firebreaks. AD 36-A-05 Page 65 of 74
Nr Comment Response
8. Stakeholder 7: Although the specific FMU referred to by the Department was not visited during this Re-Assessment A Provincial Conservation Authority period, most of the concerns can be answered. responded as follows: (a) The road issue is a concern that was identified at (a) some forestry roads runs through seepage other sites as well – where concerns were followed up slope wetland areas. KLF had made provision in the budget for upgrading of (b) A specific site should be fenced/secured to the stream crossings to minimize impact on the wetland protect it from vandalism. areas. (c) Compartments in seepage slope wetland (b) The site has no signs of vandalism and KLF prefers areas. to keep it in a natural state. Fences tend to get stolen in such situations or the nature of humans is to get in demarcated areas such as is proposed here, evidence of this was seen elsewhere where fences were erected. (c) See the response as given under 2 (a) above regarding the same issue. 9. Stakeholder 8: (a) The entire resource allocation issue was followed up with SGS during 2005/2006 and KLF found to be A Mill manager raised three issues as listed compliant in terms of legal obligations. The open below: market sales document was reviewed and found to be (a) Loss of continued timber source from KLF implemented in this case as in other similar situations. resulted in the closure of the stakeholder’s (b) The roads at the particular FMU was assessed and mill. found to be fair to good particularly where harvesting is (b) “Often we complained about the conditions taking place. of the access roads for our trucks as at times (c) KLF denies that they have ever requested transport these were in shocking conditions causing contractors to be absent during FSC audits. All spring blades to snap on trucks as well as contractors and transport contractors were present trailers. Tyres of all the vehicles at times were during the 6 day Re-Assessment visits to 6 FMU’s destroyed due to sharp rock’s on the roads as well as to poor maintenance.” (c) “When-ever SGS inspections took place in the XX Plantation only our trucks and log loader were allowed into the forest. All other contractor’s were forewarned not to collect logs on these days.” 10. Stakeholder 9: (a) See response to 2 (b) above. Another land owner (sole member) of land (b) The boundary between the two properties and the adjacent to a KLF FMU responded as follows: amount of pine escapees (two) that could be noticed from the vantage point did not constitute non- (a) Concern is raised regarding the impact of compliance to relevant FSC indicators. KLF is however, forestry in the catchment in terms of water use urged to assist neighbours where it is obvious that and availability to downstream users. escapee commercial aliens have their origins on KLF (b) “The spread of pines onto my land is properties. irritating, but given the effort involved in (c) RTE species that are unknown or poorly managed cutting them down, not critical” resulted in Minor CAR # 08 being raised. KLF (c) “The issue of cycads on the adjoining management was not aware of cycads on the firebreak, firebreak has not (to my knowledge) been they also excised a portion of land to establish a cycad addressed…..” reserve on the FMU and thus the cycad issue should be addressed between the landowner and KLF. (d) “… on occasions I only receive 1 or 2 days notice of a plan to burn a firebreak on my (d) KLF responded that the particular neighbour does boundary, which is less than legally required.” not assist in terms of workers or equipment during fire break preparation and they end up doing the break themselves. The nature of burning requires quick decisions when the weather and wind conditions are favourable and it is not always possible to please everyone in terms of timing if all breaks has to be completed prior to a certain cut-off date.
Surveillance 1 AD 36-A-05 Page 66 of 74
Nr Comment Response
11 Stakeholder: School Principals Positive comment and SGS takes note. Appreciation for support provided to schools for construction of classrooms and halls, employing additional teachers for remedial classes, cultural events 12 Stakeholder: Police Positive comment and SGS takes note. Appreciation for support provided to the Victim Empowerment program, expressed confidence in KLF’s commitment to community building 13 Stakeholder: Representatives of the Tathe Positive comment and SGS takes note. Vonde Firewood collection committee Are confident that the firewood collection project is well managed and operating effectively since the setting up of the committee 14 Stakeholder: Chiefs Positive comment and SGS takes note. Outlined various community development initiatives that KLF has supported and expressed their appreciation for these. 15 Stakeholder: NEHAWU organisers Positive comment and SGS takes note. KLF has a good record of labour relations. There is effective communication with unions and labour representatives, and a good working relationship between the parties.
Surveillance 2 AD 36-A-05 Page 67 of 74
Nr Comment Response
16 NGOME – SOCIAL COMPACT Ward committee representing three separate areas comprising 33 villages in total and
approximately 8500 community members.
This is indeed the case, since the new plantation - The committee felt that the relationship had manager was appointed there was good progress that improved considerably over the last year, needs to be followed up on. although there was still room for greater cooperation between the parties. - Recent planting and cleaning of graves had taken place without any consultation with the local stakeholders. They did not expect that KLF understands this concern and will in future liaise the company should ask for permission, but with the specific communities regarding the employment they would have appreciated being informed, of people to manage the grave sites. and possibly they could have undertaken the cleaning of the graves. The company should have employed those people responsible for the graves as they know them well and it was
this issue that had been responsible for the recent strike. - The committee was most grateful for the KLF accepts the gratitude of the community. primary school with 400 learners and the crèche that been built and the sponsorship of the crèche teacher. - There were various allegations against the KLF will take up the matter with the contractor and get contractor Thuthugane iro of sick leave, to the bottom of the allegations. annual leave, maternity leave and the importing of labour rather than using local labour. - The committee questioned what the Due to the non-capital intensive nature of Silviculture, motivation was to employ contractors and not KLF awards various Silviculture contracts. As long as more of their own / local labour instead of the contractor meets the minimum wage criteria set by using “these slavery contractors” whose pay Govt/KLF, we have little leverage ito the wages paid. scale was below the company wages.
- It was confirmed that adequate personal protective equipment (PPE) was provided. This is good to hear and confirmed by our internal audit processes. - The collection of their wages at month-end proved difficult as the return taxi fare was This is a valid concern and we will endeavour to R50, while the company provided free influence the contractor to supply free transport at transport for their own workers month end. - The committee was grateful for the road to The Provincial Roads Department will complete the last Mooiplaas and questioned when it would be section of the road. completed.
- They were very pleased with managements’ This is positive and will continue. commitment to the working group concept in that meetings were held monthly with formal minutes and follow up actions.
- They requested that should the company need a contractor local communities should This will definitely be an important consideration with be used. new contracts.
AD 36-A-05 Page 68 of 74
Nr Comment Response
17 JESSIEVALE – FAWU - SHOP STEWARD COMMITTEE. Senior shop steward, FAWU branch secretary and a shop steward. The following issues were raised by the committee; - PPE was issued regularly and was sufficient KLF will follow up. and appreciated, but follow-up on contractor PPE is needed. - the soccer sponsorship was appreciated but there have been occasions when due to a lack KLF will assist where possible. It is good to see that this of transport they have not been able to get to sponsorship is valued by the community. fixtures. They did agree that the 100km radius was acceptable. - the relationship with management was good This is positive and will continue. and the Union had made a lot of effort to further improve the situation. This is positive and will continue. - Training for employees and contractors was adequate and involves all labour. - The transporters vehicles are not roadworthy KLF is not aware of any un-roadworthy vehicles. We will and KLF only has two fire trucks in good investigate the allegation. condition.
- There are inadequate trucks to fight fires and Will be investigated. management’s response time does not show any urgency. All this results in unnecessary losses.
- Contractors do not comply with the requirements iro payslips, sick and annual Will be investigated leave and not permitted to participate in the This programme will be extended to contractors during Base Line Medical programme. November 2009 - Contractor staff have to pay for their own Coming from own labour, this is hearsay. This will be PPE which is deducted from their payslips checked during internal HR audits of contractors. without their permission.
- In August 2008 a contractor terminated 30 employees were for joining the union and Suggested that the contractor’s labour takes it up with since then contractor staff have been afraid to the relevant labour union. join the union.
- The management of contractor work needs Will be investigated during internal HR audits. to be monitored as often contractor work has to be redone, and at other times work is completed correctly but the labour are not paid. - The contractors should not be given the responsibility of fire fighting and over the last This is a serious allegation and will be investigated. 5-6 years KLF employees have had to come in as the contractors don’t seem to care and are often the instigators. The shop stewards advised management against awarding the fire fighting contract to a particular contractor as they were known to be the instigators of
the fires so that they could be paid as they do not get paid a standby allowance. This was confirmed by the full time Branch Secretary of the Union in a separate interview. - In a fire in block F, management gave the Management are human and will make mistakes. The incorrect instructions and the fire trucks were matter will be forwarded to the relevant managers to directed to the wrong area, managements’ attempt to prevent a re-occurrence. It might be that the reaction on this occasion lacked urgency, and rationale for management decisions are not well many trees could have been saved. understood and needs to be better communicated.
AD 36-A-05 Page 69 of 74
Nr Comment Response
- Certain chemicals are bought from a Will be investigated. contractor who then uses them. This did not seem like a good practice as the more he was able to use the more he could sell.
18 BADPLAAS – LOCAL CHIEF AND WIFE, LOCAL HEADMAN - LAND CLAIMANTS.
The claim was finalised in 2007 after 14 years
and the authorities were now busy with the transfer of ownership. The chief’s approach at present is that KLF are managing the plantations on the communities behalf at present. He indicated that once the transfer had been finalized they would want KLF to continue as the preferred tenant. He believes th the handover will happen on 16 December 2009.
- There are approximately 500 members of the community that the chief represents. - The relationship with the company is very This is positive and will continue. professional and cordial and there is an
undertaking of cooperation, as both parties have a similar vision of the future. - There is an interdependence between the parties and the signed accord, the declaration of intent, accommodates the objectives of the company and the dreams of the community. KLF agrees. - The chief feels strongly that he is not a neighbour but rather a stakeholder and is very encouraged by the company initiative to teach his people about forestry. This will commence This relationship is starting to blossom and needs to be with an educational visit to the plantation for enhanced further. This is positive to KLF. clan leadership.
- The chief is keen to become more involved in the fire awareness programme, especially in respect of educating the youth.
- They were “shocked” to learn that their special areas of importance eg.; grave sites and the magic pools; were actually on the KLF agrees and will pass this desire of the chief on to plantation working maps and that staff concerned with fire awareness programmes. management made special plans to ensure the care of these sacred places – it indicated to the community at large that the company respected and understood their culture. These aspects went a long way down the road to This is very positive reward for the dedicated effort improve the relationship between the parties. regarding the identification, safeguarding and They also appreciated the access to these management of ASI’s. areas.
- The chief stressed his request to utilize local labour to assist with the alleviation of poverty.
AD 36-A-05 Page 70 of 74
Nr Comment Response
19 FOOD AND ALLIED WORKERS UNION (FAWU) – FULL-TIME BRANCH SECRETARY – NELSPRUIT. At present there are 658 union members, and the current recruitment drive should bring the KLF takes note. membership to 1000 people. The existing recognition agreements are at plantation level and he is driving to unite these scattered groups and have a centralized bargaining unit the union only has members from A1 – B4 and FAWU now aim to include others eg. clerks etc. from whom they have received an anonymous letter requesting membership.
- The FAWU official finds “working with KLF is This is positive and will continue. amazingly good”. There has never been a
case that has been referred to the CCMA and he applauds the HR professionals. - The main problem the Union has is that the shop stewards are not adequately trained in union matters, which starts with stewards who KLF agrees. Training needs to be given by the Union. are incorrectly elected in terms of their abilities, especially the level of literacy.
- FAWU were included in the Wellness Programme proposal and have supported it throughout the implementation. - The communication process between This is positive and will continue. management, the union and the employees on certain plantations requires attention. There was an incident where there had been an agreement with the union regarding standby allowances which had been reneged KLF will investigate. on. There are minutes of the agreement which management failed to honour. - The FAWU official is not aware of any This is positive and will continue. This seems to nullify situation where contractor staff have been the comment in this regard made by the KLF shop prevented from joining the union. steward at Jessievale.
Surveillance 3 AD 36-A-05 Page 71 of 74
Nr Comment Response
20 FOOD AND ALLIED WORKERS UNION (FAWU) – National Coordinator Forestry.;
The Union is still seeking a single combined agreement for all estates in stead of KLF takes note. agreements by region.
It appears to the union that there is a level of
mistrust at management level as Head Office seems to not trust local management as they KLF takes note. contradict decisions made by the local mangers. The access to KLF permanent employee KLF Management will always be approachable to members is good and no problems have been Unions, however they do not always have full control encounted and management are generally over the situation regarding contractors and their cooperative. It does seem that the contractors employees. Should this escalate to a serious issue, the are not as helpful, as often the workers are company informed SGS that they must be infomed not available as had been previously about this. arranged. Whilst the union is aware of the social compacts and joint community forums, they are suspicious of them as they have no input KLF has now included two labour representatives onto or have any involvement and there is a sense the social compact structures. It is normally two shop that management are working behind the stewards that represent the Labour Unions. unions’ back. They also question the ability to spend money on projects, yet are unable to meet the union demands, this appears to be a contradiction from management, again the This is a subjective matter and KLF is doing its utmost situation of Head office and local management to take a balanced approach when it comes to the making conflicting decisions. interest of own workforce and that of adjoining The granting of large sums of money to communities. communities where no employees or their
families were involved seemed incorrect, especially where the transport of employees children to school had been stopped on two of the plantations. KLF takes note. New directions that the union is looking to be involved with are; Medical aid for workers; change to the Provident rules; health and safety committees; and a more transparent job advertising process. KLF takes note. The union acknowledged that all the KLF workers were permitted to join a union and to bargain collectively. They felt strongly about derogatory remarks from a member of the EXCO in respect of the use of contractors.
21 Crane Conservation Project : KLF hopes to build on this relationship as well. This person was only recently appointed and KLF have Contact with KLF been limited to access of indicated that they will forge better cooperation with one plantation. However, they hope to further them. the relationship with other KLF Plantations where cranes are found. AD 36-A-05 Page 72 of 74
Nr Comment Response
Customer / Neighbour;: Positive feedback noted... A healthy, co-operative and mutually beneficial relationship exists with KLF, especially with regards to fire fighting, protection and prevention. There are no negative aspects to mention. Formal and informal communications are good – ideas are shared, and issues discussed. KLF are well represented and contribute well to projects/working groups. At times KLF is perceived to be slower to adapt to new ideas and staff are not given the authority to make decisions. KLF have met expectations – including to be actively involved to initiate innovation. The uncertainty of what the future holds for KLF, ie. To be sold or privatized, is creating instability within KLF and the entire forestry industry. 22 EIA Scientist : Mpumalanga Tourism and Positive feedback noted. Parks; Interaction with KLF is largely in public participation meetings regarding environmental issues. Communication channels are good ; KLF is seen as a partner in the conservation of biodiversity KLF is supportive, and joins in the battle against irresponsible mining and the negative effects thereof – specifically water pollution. 23 Grassland Monitoring; Positive feedback noted. KLF really showed interest in working groups/projects ; took recommendations seriously ; always good communications with senior and junior managemnt; offered a positive attitude in all aspects. Plantation managers were of great help and showed interest and commitment to the programme. 24 Griffon Poison Information Centre; Positive feedback noted. Interaction with KLF has been through the Timber Industry Pesticide Working Group (TIPWG). KLF, who chair TIPWG, are progressive in their thinking ; they take the lead and have been very involved and pro- active in searching for new pest management tools. Easy and productive communications with KLF are enjoyed and they are always responsive. Even though KLF is comparatively small, they have exceeded expectations in new initiatives, progressive thinking and performance. KLF have, motivated a number of initiatives to find alternatives to highly hazardous pesticides and encouraged other members of the TIPWG to do the same. AD 36-A-05 Page 73 of 74
Nr Comment Response
25 DAFF : DAFF has always had a very good relationship with all the KLF estate managers. Currently they enter into a tender/contract KLF stated that they have over the years forged strong annually for management services provided links with the DAFF management members and are by KLF for conservation areas that fall under involved in various cooperative management measures. DAFF. Any shortcoming in the relationship comes from the slowness of the State’s procurement system in preparing the annual contracts. The whole Environmental section “are good friends”, who work well together and are mutually supportive in issues like mining operations and Land Claims on State Forest land. Since DAFF are the implementers of the National forest Act, they all work together to facilitate a smooth process. KLF graciously hosts the meetings of the Kaapschehoop Environmental Committee involving all surrounding landowners. KLF are co-operative and always open to discussion of any issues. 26 Roburnia Cluster – Amsterdam; The Chairman, who is not an employee, and the committee of 7 people, advised how grateful and proud they were to be members Positive feedback noted. of the cluster and was most appreciative of the progress made. It was particularly encouraging that the company always consulted them about their needs and did not force their own plans and projects down on them. It was for this reason that every project to date had been a success as it was driven
by the needs of the people. Positive feedback noted. Local businesses and NGO were all involved and had in some way benefitted. Particular mention was made of the fact the local plantation manager always attended all meetings. He was always at the various Positive feedback noted. handover ceremonies and without his continued support the projects would fail
Mention was also made of the support and direction and commitment from the Nelspruit Positive feedback noted. office who seemed always to deliver on their promises.
There are two wards in this cluster and collectively represented approximately 15,000 KLF recognises that this is significant. people who were affected by the progress of the projects in either a direct or indirect way. Surveillance 4
AD 36-A-05 Page 74 of 74
14. RECORD OF COMPLAINTS
Nr Detail
Complaint: # 914/06/01E Date Recorded > 21/11/ 2006
01 Dumping of general household waste in a donga busy rehabilitating on KLF plantation property.
Objective evidence obtained: Household waste was noted where it was dumped by an unknown trespasser in the abovementioned donga.
Close-out information: Date Closed > 29/05/ 2007 The waste was removed to a suitable landfill site by KLF staff and no further action was required. Patrolling takes place to ensure it does not reoccur.
02 Complaint: # 890/06/11E Date Recorded > 20/11/2006
A lodge owner complained about weeds from the plantation becoming established on his property.
Objective evidence obtained: The complaint was logged and the District environmental officer followed up with the relevant forester.
Close-out information: Date Closed > 21/11/2006 The weeds were removed and since then followed-up again. The lodge owner was contacted by SGS auditor on 06.05.2007 to confirm successful closure of the complaint.
03 Complaint Date Recorded > 29/05/2006
New Agatha: Neighbours to KLF reported a hole in a road used by both the company and neighbour.
Objective evidence obtained: The forester followed up by filling the hole in the road, grading the specific road and fitting a chevron “danger board” at the culvert.
Close-out information: Date Closed > 31/07/2006 The road was visited to confirm that the above was completed as stated, assessed on 08/05/2007.
04 Complaint # 890/07/03 Date Recorded > 28/02/2007
A protected indigenous tree (Breonadia) was felled illegally along an ESKOM powerline at Elandshoek and purchased from the transgressor by a KLF manager. A DWAF forest guard noted and recorded the incident and the person that illegally cut the tree, are to be prosecuted.
Objective evidence obtained: On the 19th of March 2007 the Mpumalanga DWAF offices sent an affidavit signed by the KLF manager regarding the incident. DWAF cited the National Forest Act 1998 (Act no. 84 of 1998). This complaint is not yet closed and disciplinary action is still to be decided on by KLF management.
Close-out information: Date Closed > 11/04/2007 Due process have been followed, where the manager in question has been taken through the internal disciplinary process. Awareness about this issue was also distributed to other managers and to the rest of the company employees. The Integrated Management System has this issue built into it to create awareness.
End of Public Summary