PEFC CHAIN OF CUSTODY CERTIFICATION REPORT...SGS South Africa (Qualifor Programme) 58 Melville Road,...

SGS QUALIFOR

(Associated Documents)

Doc. Number: AD-56-09

Doc. Version date: 5 April 2013

Page: 1 of 30

Approved by: Gerrit Marais

This document is issued by the Company under its General Conditions of Service accessible at http://www.sgs.com/en/Terms-and-

Conditions.aspx. Attention is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein.

Any holder of this document is advised that information contained hereon reflects the Company’s findings at the time of its intervention only and within

the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a

transaction from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the

content or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.

SGS South Africa (Qualifor Programm e) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 South Africa

System s and Services Cert ificat ion Division fores [email protected] South Africa (Qualifor Programm e) 58 Melville Road, Booysens - PO Box 82582, Southdale 2185 - South Africa

System s and Services Cert ificat ion Division C ontact Program me Director at t . +27 11 681-2500 www .sgs.com/en/Agriculture-Food/F orestry /

PEFC CHAIN OF CUSTODY CERTIFICATION REPORT

PROJECT NO. 2010180-CL

CLIENT: CMPC USA Inc.

Type of certificate Simple No of Sites 1

ADDRESS:

Physical Address: 1040 Crown Pointe Parkway Suite 800 Atlanta, USA GA 30338

Postal Address: 1040 Crown Pointe Parkway Suite 800 Atlanta, USA Atlanta. GA 30338

TEL: 562 441 2820

E-MAIL: [email protected]

Company website:

www.cmpc-usa.com

AUDIT SCOPE:

The purchase, outsourced storage in the USA, sale and transport of PEFC certified Cardboard under Section 4, physical separation method and implemented based on Appendix 1 (certified material) and Appendix 4 (social health and safety requirements in chain of custody).

CERTIFICATE NO: SGS-PEFC/COC-1368 PEFC LOGO USAGE LICENCE NO:

DATE OF ISSUE: 22 Aug 2011 DATE OF EXPIRY: 21 Aug 2016

NO. EMPLOYEES: 10

STANDARD:

PEFC ST 2002:2010 PEFC INTERNATIONAL STANDARD: Requirements for PEFC scheme users dated 2010-11-26

PEFC ST 2001:2008 PEFC INTERNATIONAL STANDARD “PEFC Logo usage rules - requirements”, version 2 dated 2010-11-26.

DATE OF LAST REPORT UPDATE: 01-12-2013

AD56-09 Page 2 of 30

TABLE OF CONTENTS

1. INTRODUCTION .................................................................................................................... 4

2. AUDIT SCOPE ....................................................................................................................... 8

3. CHANGES TO SCOPE OF CERTIFICATE, PRODUCTS, COMPANY DETAIL OR CONTACT DETAIL 8

4. AUDITED SYSTEM ................................................................................................................ 8

5. TIME ALLOCATION ............................................................................................................... 9

6. SITE SAMPLING METHODOLOGY (FOR GROUPS, MULTI-SITES AND OUTSOURCING) . 9

7. CORRECTIVE ACTION REQUESTS AND OBSERVATIONS ................................................ 9

8. TECHNICAL REQUIREMENT ................................................................................................ 9

8.1 REQUIREMENTS FOR CHAIN OF CUSTODY PROCESS ..................................................................... 9

8.2 MINIMUM MANAGEMENT SYSTEM REQUIREMENTS (PEFC STANDARD 6) .......................................... 9

8.3 PURCHASING .......................................................................................................................... 16

8.4 USE OF RECYCLED MATERIAL FOREST BASED MATERIAL ............................................................. 18

8.5 PHYSICAL SEPARATION METHOD (PEFC – 4) ............................................................................. 18

8.6 PERCENTAGE METHOD ............................................................................................................ 19

8.7 SALE AND COMMUNICATION ON CERTIFIED PRODUCTS (PEFC – 4.4/5.5) ...................................... 19

8.8 USAGE OF PEFC LOGOS AND LABELS (PEFC – 4.4.2/5.5.2) ....................................................... 21

8.9 PEFC DUE DILIGENCE SYSTEM (DDS) FOR AVOIDANCE OF RAW MATERIAL FROM CONTROVERSIAL

SOURCES ............................................................................................................................... 23

8.10 SOCIAL, HEALTH AND SAFETY REQUIREMENTS IN COC (APPENDIX 4) ............................................ 23

8.11 COMPLAINTS (PEFC - 6.7) ...................................................................................................... 24

8.12 SUBCONTRACTING (PEFC – 6.8) ............................................................................................. 25

9. AUDIT SUMMARY AND RECOMMENDATION: ................................................................... 26

APPENDIX A: CORRECTIVE ACTION REQUESTS ............................................................................. 27

APPENDIX B: OBSERVATIONS ........................................................................................................... 29

APPENDIX C: OUTSOURCING CONTRACTORS................................................................................. 30


BASIC EVALUATION INFORMATION

Audit History:

Audit: Date: Team Leader/Team:

Main Assessment / Re-Assessment

01/06/2011 (Chile) and 10/06/2011 (USA)

Jorge Morales Gamboni (SGS Chile)/Don Stigliano (SGS USA) - auditor

Surveillance 1 07/27/2012 (Chile) 08/10/2012 (USA)

Auditor Líder: Gustavo Daniluk/ / Don Stigliano (SGS USA)

Surveillance 2 04/10/2013 (Chile) 05Sep2013 (USA –outsource contractor)

Mario O’Ryan Lead auditor /Don Stigliano – Auditor SGSNA

Surveillance 3

Surveillance 4

Review:

Affiliate Project Manager: Mario O’Ryan Date: 01-12-2014

Report approved by: Date:

NACE codes checked and found within the scope of accreditation by:

To be completed by the reviewer approving certification.

Date:

Certification approved by: Date:

Database logged by: Date:


1. INTRODUCTION

This report presents the results of the certification evaluation CMPC USA at 05/09/2013 and 04/10/2013 by SGS Qualifor. The purpose was to assess the operations of CMPC USA against the requirements of the PEFC Council for Chain-of-Custody (COC) certifications.

Main office is located in Santiago Chile. Directive staff works on this place and trading business are generated there.

The company has an outsourced warehouse on USA, on Pensilvannia, Philadelfia Port. The warehouse does warehousing services to several clients and has merchandize management protocols, ensuring that client’s products don´t mix. They have an outsourcing contract with CMPC USA.

Both sites: head office and warehouse were audited.

1. COMPANY COMMITMENT

CMPC USA Inc. Is an American company, dedicate to wood products and by-products

commercialization, from Chilean affiliate companies: Cartulinas CMPC S.A., CMPC Maderas

S.A. and FORSAC S.A.

With the purpose of guarantee their clients traceability on certificated products

commercialization, CMPC USA Inc. subscribed to the principles, criteria and indicators of

PEFC Chain of Custody (COC).

Due this, the company is committed to supply human, materials, intellectuals and financial

resources needed to get fully implementation of the COC.

2. OBJETIVE

The present document describes the COC implemented by CMPC USA Inc. to guarantee

traceability on PEFC certificated products that commercialize. All the parties, activities,

responsibilities and documents related to the COC are identified and also it´s relation with it.

In this sense, the document main objective is to explain how the company´s internal

management is articulate to manage the PEFC COC.


Process covered by Chain of Custody.

CMPC USA process flowchart:

Critical Control Points:

1. OC is the quotation, it specifies if the purchase must be done with PEFC claim (it´s interpret by purchase responsible or invoicing supervisor.) The sales order is generated in parallel with product purchase order number (sales person). Risk of mixing is low.

2. Purchase order gets out with material certificate indications and with the same previous OC number.

3. Purchase order is received in the USA throughout exportation invoice and entries on inventory. The invoice mentioned PEFC.

4. The product entries to an in transit importation account. With product description as certificate. There is PEFC stock.

5. The product entries to the warehouse in USA, a sub-contractor site.

6. The product is dispatched from the USA warehouse to the costumer.

Certified Raw Material Availability:

tn Purchasing Sales

2011 1.438,97 856,40

2012 2.201,76 1918,80

2012 – 2013 (Sept) 3.537 4190

Stock 862

Cardborads purchase and sale process – CMPC USA

CMPC USA (Main Office Santiago, Chile)

Warehouse, Penn, Philadelphia

Cartulinas CMPC Final

costumer

Purchase Process. Sales Process Inventory Control


1.1 Certified product information:

Product name Product category code*

Product description * Species code (can include more than one)

folding boxboard 07032 Graphic papers 1; 3

* Refer RD19 for codes of product categories and species. If the product includes species of more than one category (e.g. 1 - coniferous and 3 - non-coniferous), please type all the appropriate codes into the column.

1.2 Tariffs of PEFC Notification Fee

Annual PEFC Notification fee is based the annual wood based products turnover of the company. This fee is determined by the different PEFC offices and is collected by SGS on behalf of the PEFC office.

Turnover of the PEFC certified organisation (CHF) PEFC notification fee Tick

under 150,000 50 CHF

150,000 to 750,000 150 CHF

750,000 to 1.5 million 300 CHF

1.5 million to 15 million 600 CHF

15 million to 45 million 1000 CHF



450 million to 1.5 billion 4000 CHF

Over 1,5 Billion 5000 CHF

In case of multi-site certification the multi-site organisation’s turnover is calculated as a sum of turnovers of sites covered by the multi-site organisation.

Note: notification fee to be changed were applicable. The fee is determined by the applicable PEFC National Governing Body.

1.3 SYSTEM UNDER REVIEW

Critical Control Points:

1. OC is the quotation, it specifies if the purchase must be done with PEFC claim (it´s interpret by purchase responsible or invoicing supervisor.) The sales order is generated in parallel with product purchase order number (sales person). Risk of mixing is low.

2. Purchase order gets out with material certificate indications and with the same previous OC number.

3. Purchase order is received in the USA throughout exportation invoice and entries on inventory. The invoice mentioned PEFC.


4. The product entries to an in transit importation account. With product description as certificate. There is PEFC stock.

5. The product entries to the warehouse in USA, a sub-contractor site.

6. The product is dispatched from the USA warehouse to the costumer.

Process covered by Chain of Custody.

CMPC USA process flowchart:

Outsourcing of US distribution is handled by Penn Warehousing in Philadelphia, PA US. CMPC warehouses

paper for its US customers at Penn Warehousing based on pending orders. PW is sent a delivery order indicating a shipment to be received. Shipping containers are received with a “serial number manifest” which identifies each roll included in the shipment. Shipments are further identified by lot numbers which include groups of rolls for specific customers with specific requirements which may include PEFC certified status. Packing lists (containers per shipment) and serial number manifests per container are verified against the shipment upon receipt. Rolls are barcode scanned into inventory by serial number with weight and linear feet per roll received. Rolls are stored in designated warehouse areas (addresses) and physically separated by lot number. Penn Warehousing receives “release instruction” from CMPC for specific quantities to be distributed to customers. A shipment number / pick ticket is created accordingly. Deliveries are identified per roll ID numbers on serial number manifests. Bills of Lading are included with deliveries referencing shipment numbers. BOL’s include PEFC claims per instruction from CMPC based on an identifier in the product description of the rolls included in the lot.

1.4 IDENTIFICATION OF CRITICAL CONTROL POINTS & CONTROLS

CCPs Risk of Mixing Controls

Purchase Order

Low High

OC is the quotation, it specifies if the purchase must be done with PEFC claim (it´s interpret by purchase responsible or invoicing supervisor.) The sales order is generated in parallel with product purchase order number (sales person).

Cardborads purchase and sale process – CMPC USA

CMPC USA (Main Office Santiago, Chile)

Warehouse, Penn, Philadelphia

Cartulinas CMPC Final

costumer

Purchase Process. Sales Process Inventory Control


Purchase reception in USA

Low High

Purchase order is received in the USA throughout exportation invoice and entries on inventory. The invoice mentions PEFC. Personnel are fully trained to recognize a PEFC order.

Shipping Low High

The product entries to an in transit importation account. With product description as certificate. There is PEFC stock

Shipping containers are received with a “serial number manifest” which identifies each roll included in the shipment. Shipments are further identified by lot numbers which include groups of rolls for specific customers with specific requirements which may include PEFC certified status. Packing lists (containers per shipment) and serial number manifests per container are verified against the shipment upon receipt

Outsourcing Low Paper is received, warehoused, and distributed on behalf of CMPC based on detailed work instructions. Individual roll identification, physical separation methods, and a comprehensive document trail are used to ensure low risk of mixing certified with uncertified paper. Only the specific paper identified per release instruction is shipped per order.

Invoice low High

PO is linked to the invoice and contains the corresponding PEFC claim according to the original claim.

2. AUDIT SCOPE

The scope of this assessment is the following operations of CMPC USA in Chile and USA:

The purchase, outsourced storage in the USA, sale and transport of PEFC certified Cardboard under Section 4, physical separation method and implemented based on Appendix 1 (certified material) and Appendix 4 (social health and safety requirements in chain of custody).

3. Changes to Scope of Certificate, products, company detail or contact detail

Changes

No Changes

4. AUDITED SYSTEM

The objective of the PEFC chain of custody requirements is to ensure that all products marked with the PEFC logo or sold as PEFC certified products are produced from raw material that comes from certified forests. This is based on the stipulations of PEFC ST 2002:2010 PEFC International Standard: Requirements for PEFC scheme users dated 2010-11-26.

ELEMENTS ASSESSMENT-RESULT

Which other quality or environmental management FSC No


systems has the company been certified against? ISO 14001 NO

ISO 9001 ff NO

EMAS NO

Other NO

5. TIME ALLOCATION

Man-days Methodology and Rationale

1,5 Physical separation method. Offices in Santiago and Outsourced warehouse are audit: 1 day in main office and 0,5 day in warehouse.

6. Site Sampling methodology (for groups, multi-sites and outsourcing)

Sampling Methodology and Rationale

headquarters was audited in USA where material is received, stored and shipped to end customers. No changes in the system of work, contract or site addresses.

Single Outsource Contractor audited as all US distribution is handled as outsourced activity.

Penn Warehousing 2147 S Columbus Boulevard Philadelphia PA, 19148, US

7. CORRECTIVE ACTION REQUESTS AND OBSERVATIONS

Please see Appendix A for a summary of Corrective Action Requests and Appendix B for the summary of the Observations

8. TECHNICAL REQUIREMENT

8.1 Requirements for Chain of Custody process

The organisation can supply verifiable information on the origin of the raw material within a certain time period based on stock control and registration of material flow. The origin of the wood raw material during transportation and processing of purchased products can be traced on the product documentation.

CMPC USA has decided to use the Physical Separation Minimum management system requirements (PEFC Standard 6) Physical Separation is implemented at Penn Warehousing (Contractor)

8.2 Minimum management system requirements (PEFC Standard 6)

8.2.1 Responsibilities and authorities (PEFC 6.2) - General responsibilities (PEFC 6.2.1)

CMPC USA shall operate a management system in accordance with the following elements of this standard, which ensure correct implementation, and maintenance of the chain of custody process(es).

The management system shall be appropriate to the type, range and volume of work performed.

Note: An organisation’s quality (ISO 9001:2008) or environmental (ISO 14001:2004) management system can be used to meet the minimum requirements for the management system defined in this standard.

AD56-09 Page 10 of 30

8.2.1.1 Does the organisation’s management define and document its commitment to implement and maintain the chain of custody requirements in accordance with the PEFC standard?

Is the organisation’s commitment available to the organisation’s personnel, suppliers, customers, and other interested parties? (PEFC - 6.2.1.1)

Is the organisation’s PEFC Due Diligence System for the use of uncertified material in the PEFC products supported by the organisation’s management system? (PEFC App 2 - 1.5).

Verifiers and guidance:

Absence of this declaration at the main assessment shall result in a MAJOR CAR and will preclude certification

Findings In compliance: Yes: x No:

Objective evidence:

The company maintains the declaration to comply, maintain and implement the chain of custody on the website of the company: www.cmpc-usa.com in the chapter on environmental mission. It was verified during the audit on the company website.

For Outsource Contractor – A statement of commitment is included in the Warehouse Procedure document to which Penn Warehousing is required to comply

8.2.1.2 Has the organisation’s management appointed a member of the management who, irrespective of other responsibilities, has overall responsibility and authority for the organisation’s chain of custody? (PEFC - 6.2.1.2)


Insert the person’s name, position, date of appointment and who authorized his appointment. Also indicate the training the person received and if the person have the capability to implement and maintain the system.


Objective evidence:

In the Manual PEFC Chain of Custody General Requirements (Rev 6 30/09/2013 M-CDC-01.) specified in Chapter 4 of responsibilities that the process sub manager Carolina Estay is responsible for the chain of custody. Training record of PEFC dated 23-25.8.2013 by CERTFOR Chile.

8.2.1.3 Does the organisation’s management shall carry out a regular periodic review of the organisation’s chain of custody and its compliance with the requirements of this standard? (PEFC - 6.2.1.3)


This MUST have been conducted before the Main Assessment (ISO65 requirement) and the records must be available. Failure to do this will result in a MAJOR CAR and preclude certification.

This annual internal audit and review MUST be conducted regardless of whether certified product had been used in the year preceding the surveillance, failing which a major CAR must be raised. The internal audit and review must have substantive evidence and not merely a checklist or confirmation that this had taken place.


Objective evidence:

The report of the external consultant Pamela Reyes SSC Americas SA Audit on 06.14.2013 has been verified. The audit included the administrative office and outsourced storage.

The report was submitted on 15.06.2013 with the nonconformities sent to the responsible for the chain of custody.

AD56-09 Page 11 of 30

8.2.2 Responsibilities and authorities for chain of custody (PEFC - 6.2.2)

8.2.2.1 Has the organisation:

• Identify the personnel performing activities for the implementation and maintenance of chain of custody?

• Establish personnel responsibilities and authorities relating to chain of custody for at least the following elements:

(a) raw material procurement and identification of the origin,

(b) product processing covering physical separation or percentage calculation and transfer into output products,

(c) product sale and labelling,

(d) record keeping,

(e) internal audits and non-conformity control,

(f) due diligence system relating to controversial sources?


This is referring the company’s procedures and the responsibilities requirements for the controls of the COC system.

Note: The responsibilities and authorities for the chain of custody given above can be cumulative.


Objective evidence:

The responsibilities inside the COC are clearly defined on the COC manual.

Activities Position Responsible

Chain of Custody General

Responsible.

Process and management

control Engineer.

Carolina Estay

Products purchase. Invoicing supervisor. Miriam Ramirez

Purchased products

reception.

Inventory Supervisor

Ernesto Arroyo

Invoice Emission Invoicing supervisor. Daniela Roman

Monthly management

reports (purchases, stock

and sales)

Accountant department

chief.

Manuel Millán

Inventory Control Planning and logistics chief. Mauricio Suazo

Training. Process and Management

control engineer.

Carolina Estay

Internal Control Process and Management

control engineer.

Carolina Estay

Records Invoicing supervisor. Miriam Ramirez

AD56-09 Page 12 of 30

Storage and delivery to

costumers.

CMPC USA Operations

Manager.

Felipe Irigoyen

Storage responsible on

outsource Warehouse

Customer Service Manager Laurie Mac Donald

/ USA – Felipe Irigoyen (CMPC US Operations Manager), and Tom Mutz (Penn Warehousing Director) were interviewed and remain responsible for receiving, storage, and delivery of PEFC certified product for CMPC US.

8.2.3 Documented procedures (PEFC - 6.3)

8.2.3.1 Did the organisation establish written documented procedures for its chain of custody?

8.2.3.2 Do the documented procedures include at least the following elements (PEFC - 6.3.1):

(a) organisational structure, responsibilities and authorities relating to chain of custody,

(b) description of the raw material flow within the production/trading process(es), including definition of product groups,

(c) procedures for chain of custody process covering all requirements of this standard, including:

- identification of the raw material origin,

- physical separation of certified material (for the organisations applying the physical separation),

- definition of product groups, calculation of the certified percentage, calculation of volume credits, management of credit accounts (for the organisations applying percentage based methods),

- sale/transfer of products, on-products claims and on-product labelling,

(d) procedures for the due diligence system relating to controversial sources, as applicable,

(e) procedures for internal audits, and

(f) procedures for complaints resolution?


Note: Failure to have proper procedures as described above shall result in a MAJOR CAR and will preclude certification at the main assessment.


Objective evidence:

There is a COC manual (Rev 6 30/09/2013 M-CDC-01.), that includes amongst others:

• Chart describing the product flow.

• Responsibility definition table, for every aspect and critical point of the COC.

• Procedures according to ISO 9001 format. The procedures are articulated in relation to corresponding manual.

• procedures for internal audits, and

• procedures for complaints resolution

Contractor Audit – Warehouse Procedure P-CDC-01 4/9/2013 is in place and was reviewed. All activity of Penn Warehousing (receiving, material control, shipping) is covered.

AD56-09 Page 13 of 30

8.2.4 Record keeping (PEFC - 6.4)

8.2.4.1 Did the organisation establish and maintain records on its COC to provide evidence of conformity with the requirements of the standard and its effectiveness and efficiency?

8.2.4.2 Does the organisation keep at least the following records relating to the product groups covered by the COC (PEFC - 6.4.1):

(a) records of all suppliers of certified material, including copies of the suppliers’ forest management or COC certificates or other documents confirming the supplier’s compliance with the criteria for suppliers of certified material,

(b) records of all input material, including claims on the material origin and documents associated to the delivery of the input material,

(c) records of calculation of the certified percentage, transfer of the percentage to output products and management of the credit account, as applicable,

(d) records of all products sold/transferred, including claims on the material origin and documents associated to the delivery of the output products,

(e) records of the due diligence system relating to controversial sources, including records of self-declarations, risk assessment and high risk supplies management, as applicable,

(f) records of internal audits, periodic chain of custody review, non-conformities which occurred and corrective actions taken, and

(g) records on complaints and their resolution?


Auditor to check these records as a matter of course and provide samples in the report.


Objective evidence:

There are procedures for records maintenance.

It is confirmed that the Company Tecnologías de la Información y Comunicaciones, perform daily backups, weekly and monthly leaving a copy at the company CMPC. Contract sighned by Alberto Compagnon ICT Manager.

Evidence of the following Purchase orders:

PO N°160973 Date: 05/03/2013. All the orders detailed 100% PEFC materials.

Evidence of the following Invoices:

Invoice N° IN00279783 Date: 29/08/2013. All the orders detailed 100% PEFC materials.

Evidence of the following Supply Invoices:

Invoice N° 95599 Date: 27/05/2013. All the orders detailed 100% PEFC materials.

Contractor audit – Penn Warehousing maintains all transport and inventory control documents supporting all transactions. Documents sampled – Delivery Order 56856, Container ID MRKV2837915, Packing List 89756, Release Instruction GP1/14/13, Pick Ticket S291113, and BOL S291113.

8.2.4.3 Does the organisation maintain the records for a minimum period of five years? (PEFC - 6.4.2)


Note: The records cover the media and information, including electronic media.

During surveillance and re-assessment audits the maintenance and accessibility of records shall be verified.

The auditor must check that the archived documents are available.


AD56-09 Page 14 of 30

Objective evidence:

The company started working since 2007.

The following historical invoices were noticed, all evidence of the documents are stored in time:

6646 of 30.07.2007, 7142 of 08.01.2007, 7141 of 02.08.2007

Invoice N°IN00189116 Date 12/28/2011 , Packing List SI N° S00188682, Invoice instruction, and BOL 2011

USA – Penn Warehousing record retention policy is in accordance with CMPC US work instructions. All requested records supporting COC were available upon request.

8.2.5 Resource management (PEFC - 6.5)

8.2.5.1 Human resources/personnel (PEFC - 6.5.1) – Can the organisation ensure and demonstrate that all personnel performing activities affecting the implementation and maintenance of the COC are competent on the basis of appropriate training, education, skills and experience? (PEFC - 6.5.1.1)


List the people interviewed, their position and understanding of the system.

Confirm they have received the required training to maintain the COC system.


Objective evidence:

The following people Participated in the audit:

Estay Carolina. Responsible for COC. Management Assistant

Patricio Maldonado. Logistics Supervisor

Miriam Ramirez: Responsible for billing.

Nestor Paz. Administrative Inventory

Luis Gutierrez. accounting

Miriam Ramirez. Credit and Collections Officer.

Natalia Figueroa Invoice supervisor

Mario Figueroa. Ing Process Management

Key staff received training About CoC

Contractor audit – Interview with Jim Pratt (Receiving, Shipping, Material Control), and Tom Mutz (Director of Operations) demonstrated training, experience, and a good understanding of work instructions for handling CMPC USA material.

Verification of Training courses

22-08-2013 relator Pamela Reyes 5 assistants with signatures and PEFC Requirements updated.

09/07/2013 relator Pamela 20 sales assistants and certification PEFC responsible, mainly environment , health and security.

8.2.5.2 Technical facilities (PEFC - 6.5.2) – Has the organisation identified, provided and maintained the infrastructure and technical facilities needed for effective implementation and maintenance of the organisation’s COC with the requirements of the PEFC standard?


Check if the company has the capability to produce the volumes of certified product they have indicated.


Objective evidence:

It has centralized computer systems in all critical control points.

The staff is properly trained

Contractor Audit – Sufficient warehouse capacity and material handling equipment was

AD56-09 Page 15 of 30

demonstrated. A capable inventory control software system is in place (bar coding).

It is confirmed that the internal audit report was done on 06.14.2013, by the external consultant Pamela Reyes SSC Americas SA. The report was submitted on 06/15/2013 to the responsible of the chain of custody.

/ USA – Felipe Irigoyen indicated at interview that “paper trail” internal audits of outsourced operations are conducted by CMPC US management in Cartulinas. On site internal audit of outsourced operations is done by Felipe Irigoyen as incorporated into the annual SGSNA audit (10Aug12).

8.2.6 Inspection and control (PEFC - 6.6)

8.2.6.1 Has the organisation conducted internal audits at least annually covering all requirements of the PEFC standard and establish corrective and preventive measures if required? (PEFC - 6.6.1)


This MUST have been conducted before the main or re-evaluations (ISO65 requirement) and the records must be available. Failure to do this will preclude certification. A MAJOR CAR must be raised.

Audits to be conducted annually regardless of whether certified material has been used, failing which a major CAR must be raised. The internal audit must have substantive evidence and not merely a checklist or confirmation that this had taken place.


Objective evidence:

The internal 2013 audit report is verified, it was completed by the external consultancy. The report was submitted to CMPC USA to the responsible for the chain of custody.

/ USA – Felipe Irigoyen indicated at interview that “paper trail” internal audits of outsourced operations are conducted by CMPC US management in Cartulinas. On site internal audit of outsourced operations is done by Felipe Irigoyen as incorporated into the annual SGSNA audit (Sep2013).

8.2.6.2 Was the report on the internal audit reviewed by top management and is it done annually? (PEFC - 6.6.2.)


Note: Guidance for performing internal audits is given in ISO 19011:2002

This MUST have been conducted before the main or re-evaluation (ISO65 requirement) and the records must be available. Failure to do this will preclude certification. A MAJOR Finding must be raised.

Audits to be conducted annually regardless of whether certified material has been used, failing which a major CAR must be raised. The internal audit must have substantive evidence and not merely a checklist or confirmation that this had taken place.


Objective evidence:

The audit report was approved by the responsible chain of custody on 06.15.2013. According to an area meeting sustained.

AD56-09 Page 16 of 30

8.3 Purchasing

8.3.1 Identification of the origin of certified material/products (PEFC - 4.2/5.2)

Identification at delivery (incoming) level (PEFC - 4.2.1/5.2.1)

8.3.1.1 Does the organisation obtain from the suppliers for each delivery of certified material/products information necessary to verify the suppliers’ certified status? (PEFC - 4.2.1.1/5.2.1.1)

8.3.1.2 Does a document associated with each delivery of certified material/products include at least the following information (PEFC - 4.2.1.2/5.2.1.2/5.2.1.3):

(a) the organisation’s name as the customer of the delivery,

(b) supplier identification,

(c) product(s) identification,

(d) quantity of delivery for each product covered by the documentation,

(e) date of delivery / delivery period / accounting period,

(f) the formal claim on the material origin (including percentage of certified material) specifically for each certified product covered by the documentation, and

(g) the identifier of the supplier’s COC or forest management certificate or other document confirming the supplier’s certified status?


Accreditation requirements stipulate that certified material must have been processed at the time of the main or re-evaluation.

If no certified material had been processed at the time of the main or re-evaluation, a MAJOR CAR must be raised and be closed out before certification can be recommended.

Supplier documentation must clearly indicate the PEFC certificate number and the PEFC category of the material being purchased.

Has the certification status of the suppliers been verified on www.pefc.org?

Note 1: The formal claim, which means the claim in its exact wording, as well as documents confirming the certified status are specified in an Appendix to the PEFC standard or by other document(s) defined by the relevant forest certification or labelling scheme.

Note 2: The certificate identifier can be a numerical or alpha-numerical combination and is usually referred to as the “certification number”.

Note 3: An example of the delivery documentation is an invoice or delivery note provided that it meets all the requirements of 8.3.1.2 (PEFC - 4.2.1.2./ 5.2.1.2/5.2.1.3)


Objective evidence:

It was confirmed with Miriam Ramirez who knows how to verify the validity of PEFC certificates. There was evidence that she verified the 03-10-2013.

The following sales invoices were evidenced with the corresponding purchase order:

1. Invoice N° 95599 Date: 27-05-2013 100% PEFC PO: N° 160973




Every Document had the requirements stated from a) to g)

All purchase orders requested indicated 100% PEFC materials and all invoices evidenced to meet the standard.

AD56-09 Page 17 of 30

8.3.1.3 For each delivery, does the organisation classify the procured material as certified, neutral or other material following the claim specification for which the chain of custody was implemented? (PEFC - 4.2.1.3/5.2.1.4.)


Note: Criteria for certified, neutral and other material for a specific claim are specified in an Appendix on specification of the claim or by other document(s) defined by the relevant forest certification or labelling scheme.

Findings In compliance: Yes: No:

Objective evidence:

The company has only one supplier. Cartulinas CMPC SA CL09/2009565.which one sells 100% Certified PEFC material

Contractor audit – Material is controlled by use of lot numbers and roll ID’s. Material is classified as PEFC certified or other based on item descriptions for roll paper.

8.3.2 Identification at supplier level (PEFC - 4.2.2/5.2.2)

8.3.2.1 Does the organisation require, from all suppliers of certified material, a copy of or access to the forest management or COC certificate or another document confirming the supplier’s certified status which proves that the criteria set for the supplier of the certified material have been met? (PEFC - 4.2.2.1/5.2.2.1.)


Note: The criteria for the supplier of certified material are specified for each claim in an Appendix 1 to the PEFC standard or by other document(s) defined by the relevant forest certification or labelling scheme.


Objective evidence:

It was confirmed that the company has the one valid supplier certificate. Cartulinas CMPC SA CL09/2009565. According to this, CMPC USA can buy and sell PEFC 100% cardboard.

8.3.2.2 Does the organisation evaluate the supplier’s certified status with the criteria for the suppliers of certified material based on validity and scope of documents received under 8.3.1.4 (PEFC - 4.2.2.1/5.2.2.1.)? (PEFC - 4.2.2.2/5.2.2.2)


Note: In addition to the receipt of a document identified under 8.3.1.4 from the supplier, the organisation should make use of publicly available registers of suppliers of certified material kept by the PEFC Council or other recognised organisations.


Objective evidence:

The responsible (Daniela Roman) knows how to access the web verification of PEFC she keeps a copy of the validity print screen.

AD56-09 Page 18 of 30

8.4 Use of Recycled material Forest based material

8.4.1 Is the company using Recycled material Forest based material that is (PEFC - 3.19)

(a) diverted from the waste stream during a manufacturing process,.

• Excluded is reutilisation of materials such as rework, regrind or scrap generated in a process and capable of being reclaimed within the same process that generated it,

• Excluded are by-products such as sawmilling by-products (sawdust, chips, bark, etc.) or forestry residues (bark, chips from branches, roots, etc.) as they do not represent “waste stream”, and

(b) generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product which can no longer be used for its intended purpose. This includes returns of material from the distribution chain?


Note 1: The term “capable of being reclaimed within the same process that generated it” means that the material generated in one process is continuously returned to the same process at the same site. An example is residue generated by a press line in a panel board production which continuously re-enters the same press line. This is not considered as recycled material.

Note 2: Material classified under the grades of recovered paper according to EN 643 is recognised as meeting the definition of the recycled material.

Note 3: The definition is based on definitions of ISO 14021:1999.

Verify that the material is in line with the definition for recycled material.

Do the suppliers’ sales documents provide the relevant information on the status of the material?

Findings In compliance: Yes: x No: NA

Objective evidence:

Contractor audit – All PEFC paper handled by Penn Warehousing on behalf of CMPC USA is 100% PEFC certified per written instruction.

8.5 Physical separation method (PEFC – 4)

CMPC USA has decided for the chain of custody process of the physical separation method because they can guarantee that the certified raw material is kept separated and/or clearly identifiable at all stages of the production or trading process.

8.5.1 Does the organisation applying the physical separation method ensure that the certified material is separated or clearly identifiable at all stages of the production or trading process? (PEFC - 4.1.2).

The physical separation method may also apply to the certified products with various content of certified material (PEFC - 4.1.3).


Note: The organisation may physically separate a product(s) with the same percentage based claim from other products with or without different percentage claims.

Confirm which method the company is using and is the material clearly identifiable?

If certified and uncertified products are handled is the risk of mixing managed?


Objective evidence:

Contractor Audit – Penn Warehousing applies the physical separation method using lot numbers, roll ID’s, and warehouse address locations for storage. Bar codes are used to identify each roll received, stored, and shipped.

AD56-09 Page 19 of 30

8.5.2 Separation of certified material/products (PEFC - 4.3)

8.5.2.1 Do certified material and certified products with different content of certified material remain clearly identifiable throughout the whole production/trading process, including storage?

This shall be achieved by (PEFC - 4.3.1):

(a) physical separation in terms of production and storage space, or

(b) physical separation in terms of time, or

(c) clear identification of the certified material/products during the process.


Note: The organisation may physically separate a product(s) with the same percentage based claim from other products with or without different percentage claims.

Confirm which method the company is using and is the material clearly identifiable?

If certified and uncertified products are handled is the risk of mixing managed?


Objective evidence:

Contractor Audit – Site tour demonstrated clear identification of certified material and storage space is in use at Penn Warehousing. At this time all PEFC certified paper handled on behalf of CMPC USA is 100% PEFC certified and effectively physically separated from other material.

8.6 Percentage method -- Not Applicable

8.7 Sale and communication on certified products (PEFC – 4.4/5.5)

8.7.1 Documentation associated with sold/transferred products (PEFC - 4.4.1/5.5.1)

8.7.1.1 At the point of sale or transfer of certified products to the customer, does the organisation (PEFC - 4.4.1.1/5.5.1.1):

(a) Provide the customer with a copy or access to a copy of its COC certificate or other document confirming the organisation’s compliance with the criteria for the supplier of certified material,

(b) Inform the customers about any change in the scope of its certification and

(c) Not misuse its COC certification.

(d) In the case of multi-site certification where individual sites receive a separate document (referring to the main certificate) confirming their certified status, the organisation (the site) provides its customers copies of this document together with the main certificate?


Are the requirements included in the procedures and are the sales personnel aware of the requirements?


Objective evidence:

The certificate is available for any client when requested, however clients acknowledge the PEFC website for verification.

It is Specified in the procedures to notify customers of any changes to the scope.

AD56-09 Page 20 of 30

8.7.1.2 For the purposes of communication of the chain of custody claim, does the organisation identify a single type of document associated with the delivery of all sold/transferred products?

8.7.1.3 Does the document including:

(a) the formal claim, and

(b) is issued to a single customer.

8.7.1.4 Does the organisation maintain copies of the documents and ensure that information contained within those copies cannot be altered after the originals are delivered to the customers? (PEFC - 4.4.1.2/5.5.1.2).


Note: The document associated to each delivery covers the media and information, including electronic media. An example of the delivery documentation is an invoice or delivery note provided that it meets all the requirements of 8.6.1.2 and 8.6.1.3 (PEFC - 4.4.1.2, and 4.4.1.3).

Note: The document associated to each delivery covers the media and information, including electronic media.


Objective evidence:

Contractor Audit – Penn Warehousing is given work instruction to include the PEFC claim on delivery documents when shipping PEFC certified paper on behalf of CMPC USA. The pro-forma invoice for each international shipment received includes the 100% PEFC certified claim. An email work instruction is in place and was provided as audit evidence that Penn Warehousing is to include the 100% PEFC certified claim on all shipments of PEFC certified paper until further notice.

8.7.1.5 The document associated with each delivery of all certified products includes at least the following information? (PEFC - 4.4.1.3/5.5.1.3)

(a) customer identification,

(b) supplier identification,

(c) product(s) identification,

(d) quantity of delivery for each product covered by the documentation,

(e) date of delivery / delivery period / accounting period,

(f) the formal claim on the material origin (including percentage of certified material) specifically for each certified product covered by the document, and

(g) the identifier of the supplier’s COC certificate or other document confirming the supplier’s certified status.


Note 1: The formal claim, which means the claim in its exact wording, as well as documents confirming the certified status are specified in an Appendix to the PEFC standard or by other document(s) defined by the relevant forest certification or labelling scheme.

Note 2: The certificate identifier can be a numerical or alpha-numerical combination and is usually referred to as the “certification number”.


Objective evidence:

Contractor Audit – BOL S291113 was sampled and reviewed. All required information is included.

Examples of Invoices

Commercial Invoice N° IN00270113 Date 07/02/2013 100%PEFC SGS-PEFC/COC-1368





AD56-09 Page 21 of 30

8.8 Usage of PEFC logos and labels (PEFC – 4.4.2/5.5.2)

The PEFC Logo and trademark creates an information link between the raw material included in a forest based product and the origin of that raw material as defined in the international processes for sustainable forest management and certified by an independent third party in accordance with the requirements of the PEFC system.

8.8.1 Procedures for the control of the PEFC logo according to PEFC ST 2001-2008 v2 PEFC Logo usage use is available and a person has been nominated for the management of the logo use?


Objective evidence:

Contractor Audit – Site tour evidenced that rolls of paper received and shipped on behalf of CMPC USA include the PEFC logo on the roll tag. Penn Warehousing only receives and ships product per CMPC work instructions and does not apply, change, or remove any PEFC labels.

8.8.2 Does the organisation which uses a logo or label, for on-product and/or off-product purposes, relating to the COC certification, have an authorisation (Logo Licence) from the logo/label’s trademark owner (PEFC) or from the owner’s authorised representative (PEFC NGB)?

8.8.3 Is usage carried out according to the terms and conditions of the authorisation? (PEFC - 4.4.2.1/5.5.2.1)


PEFC Logo usage rights - The PEFC Logo shall be used under the authority of a PEFC Logo usage licence which is issued by the PEFC Council or other body authorised by the PEFC Council relevant to the country in which the PEFC Logo user is registered. The PEFC Logo licence applies to an individual legal entity (PEFC ST 2001-2008 v2 PEFC Logo usage - 5.2).

Note 1: Where the organisation decides to use the logo/label, the logo/label usage rules specified by the logo/label owner become an integral part of the chain of custody requirements.

Note 2: In case of PEFC Logo usage, “authorisation” means a valid licence issued by the PEFC Council or another body authorised by the PEFC Council and the “terms and conditions” of the licence requires compliance with PEFC ST 2001:2008.

Once the company is certified, the company must be registered with the applicable PEFC NGB. If not, the PEFC NGB will not issue a logo licence number.

During surveillance audit check if a signed (by both parties) writing issuance of a logo usage license to the company is available.

This should be obtained by application to:

PEFC Council ASBL World Trade Center 1 10, route de l'Aéroport CH-1215 Geneva Switzerland

Tel: +41 22 799 45 40 Fax: +41 22 799 45 50

Email: [email protected]

POSTAL ADDRESS: PEFC Council Case Postale 636 CH-1215 Genève 15 Switzerland


Objective evidence:

The company is a Trader and does not apply or change Logo labels on product. They remain identified as from origin.

AD56-09 Page 22 of 30

8.8.4 The label is only on-product for those certified products that meet the eligibility criteria for product labelling as specified by the owner of the logo/label trademark? (PEFC - 4.4.2.2/5.5.2.2).

(a) “PEFC certified” label - The product includes minimum of 70 % of “PEFC certified” material from forest which has been certified against a PEFC endorsed forest certification scheme as sustainably managed or from recycled material. The content of recycled material is lower than 85 %. (PEFC ST 2001-2008 v2 PEFC Logo usage - 7.2.3.1)

(b) “PEFC recycled” label - The product includes a minimum of 70 % of “PEFC certified” material from recycled sources (PEFC ST 2001-2008 v2 PEFC Logo usage - 7.2.3.2).


The content of “PEFC certified” material is verified through the PEFC recognised chain of custody standard.

Both forest management and chain of custody have been certified by third party certification body accredited by an IAF (International Accreditation Forum) member accreditation body.

Where the product does not include recycled material, the label claim shall be used without the word “recycled”.


Objective evidence:

PEFC labelled product is identified as PEFC certified in the product description on documents which drives Penn Warehousing to include the 100% PEFC certified claim on delivery documents per CMPC USA work instruction.

8.8.5 Does the organisation which makes on-product claims on the product itself or its packaging (without a logo or label) relating to COC certification always uses the formal claim and the organisation making the claim is identifiable? (PEFC - 4.4.2.3).


Note: The term “formal claim” means the claim in its exact wording as specified in an Appendix on specification of the claim or by other document(s) defined by the relevant forest certification or labelling scheme.


Objective evidence:

Contractor Audit – No on product claims besides the PEFC logo were observed during the site tour

8.8.6 Is the logo used in accordance with the following terms?

(a) The PEFC logo is used in the appropriate size, colour, and other qualities and following the instructions for the reproduction of the PEFC logo,

(b) with the PEFC Copyright PEFC™,

(c) with the licence number for the logo usage.

(d) The Mobius symbol shall be used together with the PEFC Logo if the content of PEFC recycled raw material is used for meeting the minimum percentage threshold.


Check a) to d) above and record individually or state N/A


Objective evidence:

Contractor Audit – All PEFC logos on roll tags observed during the site tour appeared correctly used

8.8.7 Use of the SGS Product logo

(a) When the SGS product logo is used, is it used with the PEFC logo (reflecting the company’s logo licence number). (Note: The SGS logo must always be used with the PEFC logo)

(b) If the SGS logo is used does the company have copies of:

• “Regulations governing the use of SGS product certification mark”

• “SGS Certification Mark Licence Terms and Conditions July 2005”


AD56-09 Page 23 of 30

Check the paperwork they should have received from SGS.


Objective evidence:

The SGS Logo is not used in any document or digital document of CMPC USA

8.9 PEFC Due Diligence System (DDS) for avoidance of raw material from controversial

sources N/A

8.10 Social, health and safety requirements in COC (Appendix 4)

8.10.1 Does the organisation have a documented policy that includes the organisation’s commitment to implement and comply with the social, health and safety requirements defined in this standard? (PEFC App 4 – 2.1)


The document should be publically available. Indicate is it is available and where.


Objective evidence:

The company has a policy of working conditions have respect and job security. This policy is declared and available on the company's offices in Santiago, Chile

Warehouse Procedure P-CDC-01 was reviewed and includes detailed instruction regarding adherence to the CMPC commitment to workers health and safety (Paragraph 14). No issues relating to workers health and safety were observed at the Contractor audit.

8.10.2 The organisation demonstrate that it (PEFC APP 4 -2.2):

(a) Ensures workers’ freedom of associations and rights for collective bargaining?


These include working contracts which do not prevent workers from joining/participating in workers organisations and collective bargaining; workers’ access to representatives; transparent procedures for dismissal and bargaining with workers’ representatives of legally recognised labour organisations where this is required or permitted by law.


Objective evidence:

Penn Warehousing employees are represented by a collective bargaining unit.

(b) Prohibits the use of forced labour covering the organisation?


Objective evidence:

Penn Warehousing - Local, State, and National law prohibit forced labor in the US. No indication of forced labor observed.

(c) Ensures minimum age for the employment of employees?


Objective evidence:

Penn Warehousing - Local, State, and National law establish minimum employment age requirments in the US. No indication of under age labor observed at contractor facility.

(d) Ensures equal employment that covers recruitment, promotion, division of work and dismissal?


Objective evidence:

Penn Warehousing – Local, State, and Federal law require equal opportunity in employment. Penn Warehousing collective bargaining agreement is in place.

(e) Ensures occupational health and safety, including its documentation and reporting?

AD56-09 Page 24 of 30


Objective evidence:

The visit to the headquarters in Santiago and warehouse products in USA demonstrated good working conditions. Offices well implemented, using the latest computer systems, high-tech warehouses.

Procedure 12 includes all details of security and health issues

Penn Warehousing (Contractor) – Interview with Terry Brown (VP – Penn Warehousing) explained methods by which PW ensures workers health and safety. Shanna Gatusso is identified as Safety Manager. A Safety Manual is in place which meets OSHA requirements. PW is state certified for safety. Monthly safety meetings are held. Insurance company audits and seminars are conducted. Collective bargaining agreement provides for employees to “stop work” based on safety concerns.

8.11 Complaints (PEFC - 6.7)

8.11.1 The organisation established procedures for dealing with complaints from suppliers, customers and other parties relating to the organisation’s chain of custody? (PEFC - 6.7.1).


Objective evidence:

The Company has a complaint admission and administration procedure. This procedure is part of CoC manual. On the outsourced Company case, possess on its clause 11 the indications for complaint management.

Warehouse Procedure 13 – Claims and Complaints is included in the work instructions for Penn Warehousing (Contractor). Penn Warehousing is instructed to immediately notify CMPC of any complaints. No complaints noted to date at Penn Warehousing facility.

8.11.2 Upon receipt of the complaint, does the organisation (PEFC - 6.7.2):

(a) acknowledge the complaint to the complainant,

(b) gather and verify all necessary information to evaluate and validate the complaint and make decision on the complaint,

(c) formally communicate the decision on the complaint and of the complaint handling process to the complainant, and

(d) ensure that any appropriate corrective and preventive actions are taken?


The certified company must have records that the complaint has been recorded, what the findings was of the investigation and the actions taken to rectify the problem.


Objective evidence:

These aspects are considered on COC Manual. The complaint procedure considers:

• To accept the complaint;

• To verify the complaint information taking a decision about it.

• To communicate the denunciator the decision; and

• To ensure the correspondent SAC.

No complaints were received.

AD56-09 Page 25 of 30

8.12 Subcontracting (PEFC – 6.8)

Note 1: An example of subcontracting is outsourcing of cutting and stapling process by a printing house with chain of custody where the printed material is transferred to the subcontractor and returned back to the printing house after the subcontracted activities have been performed.

Note 2: An entity which is either involved in procuring the raw material or sale of the output products is required to implement its own chain of custody. The terms “receives the material from the organisation” and “returns the material back to the organisation” also cover situation where the material is received by the subcontractor directly from the supplier on the organisation’s behalf or is sent by the subcontractor to the customer on the organisation’s behalf. The organisation still remains responsible for all parts of the chain of custody, including requirements relating to the material procurement and sale and communication.

Note 3: Subcontracting is not considered as being in conflict with 5.1.2.3 of the PEFC COC standard that requires the product group to be manufactured at one site.

8.12.1 The organisation’s chain of custody also covers activities of sub-contractors involved in the manufacturing of products covered by the organisation’s COC process(es), within or outside the organisation’s site? (PEFC - 6.8.1)


Objective evidence:

Outsourcing to Penn Warehousing of material receiving, warehousing, and shipment to customers is included in the control of chain of custody.

8.12.2 The organisation only considers those activities as subcontracting where the subcontractor receives the material from the organisation which is physically separated from other material and returns the material back to the organisation after the subcontracted work is completed or where the organisation remains responsible for the sale or transfer of the product to the customer? (PEFC - 6.8.2).


Objective evidence:

Outsourcing is specifically for distribution of product. CMPC works closely with Penn Warehousing and is responsible for delivery release instructions, and final sale of product.

Release instruction GP1/14/13 was sampled for review.

8.12.3 The organisation takes full responsibility for the all the subcontracted activities in relation with the organisation’s chain of custody? (PEFC - 6.8.3).


Objective evidence:

Interview with Terry Ashman (CMPC USA) demonstrated CMPC direct involvement and responsibility for communicating specific instructions regarding receiving, storage, and shipments. Warehouse procedure document P-CDC-01 (4/9/2013) was provided for review which includes detailed material control requirements.

8.12.4 The organisation has a written agreement with all subcontractors ensuring that the organisation’s material/products are physically separated from other material or products? (PEFC - 6.8.4).


Objective evidence:

Interview with Terry Brown (VP – Penn Warehousing), and Tom Mutz (Director of Operations – Penn Warehousing) indicated that a written agreement is in place between CMPC USA and Penn Warehousing covering outsourced activities. Adherence to CMPC Warehouse Procedure P-CDC-01 which includes instruction for physical separation was demonstrated but a signed agreement was not provided at the outsource location and should be confirmed at the main site audit.

8.12.5 The organisation’s internal audit programme covers the subcontractor’s activities? (PEFC - 6.8.5).


Objective evidence:

Supporting document control per order indicates CMPC direct involvement in the distribution process. Terry Ashman (CMPC) attended and participated in the SGS audit. Regular visits by CMPC to Penn Warehousing are done. A specific internal audit document or report was not provided as evidence of internal audits and should be confirmed at the main site audit.

AD56-09 Page 26 of 30

9. Audit Summary and Recommendation:

A short summary of the evaluation and any issues that was hard to assess.

xxx

Audit of Penn Warehousing for Material Handling of Paper purchased and sold by CMPC USA evidenced conformance to contract obligations and adherence to work instructions provided by CMPC USA providing a system for conformance to PEFC ST 2002:2010 at the Material Receiving, Handling, and Shipping Level with no Corrective Actions Raised. An opening meeting was held, interviews conducted, and a site tour was given. Work instructions and outsource contracts were reviewed. Sample documents were provided. No issues were difficult to assess.

CARs raised 0 CARs were raised at the audit

Number of CARs closed N/A.

(Re-) Certification Recommendation There being no Major or Minor Corrective Action Requests, the

auditor recommends certification of Outsource Contractor Operations at Penn Warehousing 2147 S Columbus Boulevard Philadelphia PA, 19148, US

for CMPC USA chain of custody for the scope mentioned above.

Surveillance NO: 2 Surveillance 2

A short summary of the evaluation and any issues that was hard to assess.

There were no issues hard to assess.

Number of CARs closed 0 Cars Closed

Nr of CARs remaining open 0 Cars remain Open

New CARs raised 0 Cars Raised

Recommendation: The Chain of Custody of CMPC USA to remain certified as:

� The management system is capable of ensuring that all of the requirements of the applicable standard(s) are met over all areas 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 scope of the certificate.

AD56-09 Page 27 of 30

APPENDIX A: CORRECTIVE ACTION REQUESTS

Guidance note

The non-conformance raised for the full certification period must be maintained in each report.

Read GN 2009-02 when raising and closing cars and the correct methods required.

The non conformance is always the negative of the specific clause, as it relates to the specific non conformance identified during the audit. Words that can appropriately reflect the negative of the clause are (by way of example): “does not” or “does not always”.

Where a CAR cannot be closed out, reasons for this must be given and the due date adjusted. Please refer specifically the requirements of Procedure 04.

The objective evidence is the actual evidence that was observed during the audit, relating to documentation, field evidence or interviews.

Major CAR number is given as M00 and minor as 00 in the CAR number column

Include the relevant checklist number and clause reference under the indicator column

CAR # Indicator CAR Detail

M01 8.2.1.1 Record date.

June 01st 2011.

Expiration date.

June 08th 2011.

Rising date. June 08th

2011.

Non-Conformity.

The company does not have a documented commitment to implement and maintain a chain of custody according to PEFC standard.

Objective evidence.

No documented declaration were available.,

Rising evidence.

The company issued a declaration on its web page with an explicit adhesion to the requirements of PEFC COC.

M02 8.2.6.1 Record date.

June 01st 2011.

Expiration date.

June 08th 2011.

Rising date. June 08th

2011.

Non-Conformity.

The company has not performed an internal audit of it´s COC in the main office.

Objective evidence.

Only evidence of internal audit performed in the warehouse were evidenced.

Rising evidence.

The company performed an internal audit according to their internal audit procedure.

03 8.2.5.1 Record date.

June 01st 2011.

Expiration date.

Before certification

Rising date. 20.06.2011

Non-Conformity.

Not all the team member knows their responsibility in the COC.

Objective evidence.

An invoicing responsible did not know how to check validity of PEFC certificate on the web page

Rising evidence.

AD56-09 Page 28 of 30

Refreshment training was done for personnel involved in the COC on July 15, 2011. CAR is closed.

AD56-09 Page 29 of 30

APPENDIX B: OBSERVATIONS

Guidance note

The observations raised for the full certification period must be maintained in each report.

Include the relevant checklist number and clause reference under the indicator column

Close-out date only to be completed once the observation has been closed.

OBS # Indicator Observation Detail

01 8.8.1 Record date. 01/06/11 Rising date. 27/07/2012.

Observación:

The procedures don’t describes with detail the logo usage rules. It only state that they will follow PEFC rules.

Follow up Evidence:

Se amplió la información en referencia a las exigencias de uso del logo transcribiendo además los requerimientos técnicos en el capítulo 10 del Manual de Cadena de Custodia

information is more detailed and accurate in reference to the requirements for use of the logo also transcribing technical requirements in Chapter 10 of the Manual Chain of Custody

Date Recorded> dd MMM yy Date Closed> dd MMM yy

Observation:

Follow-up evidence:


Observation:

Follow-up evidence:


Observation:

Follow-up evidence:

AD56-09 Page 30 of 30

APPENDIX C: OUTSOURCING CONTRACTORS

1. Detail of outsourcing contractors

Please complete detail for each organisation involved in outsourcing or reclaim suppliers.

Organisation name: Penn Warehousing & Distributing Inc.

Address: 2147 S Columbus Boulevard Philadelphia PA, 19148, US

Contact person: Thomas Mutz

Contact detail: Director – Global Business Development 908-507-8933

Service provided: Receiving, Storage, Shipping

Material send for outsourcing: Paper

Product produced: Paper unchanged

2. Risk Assessment

Yes No

The organisation is outsourcing a wide range of production related activities; X

The organisation is outsourcing to a contractor or a number of contractors on a regular basis

X

Contractors grade or sort the material during outsourced processing X

Contractors label the product during outsourced processing

Contractors do not physically return the certified product following outsourced processing X X

The organisation is outsourcing processing across national borders X

Please indicate risk and motivate. Low

All receiving, handling, and shipping of material is done by the outsource contractor indicating “regular basis”. However, Paper is unchanged and not unwrapped in the receiving and delivery process. Each roll is bar code identified with a detailed roll tag information. Well documented procedural requirements and highly effective inventory control system is in place.

3. Outsourcing Organisations Visits

The following outsourcing sites were included in the sample used for the evaluation.

Name of subcontractor or reclaimed material supplier Company SGS

Penn Warehousing +

End of Report

Date post:	30-May-2020
Category:	Documents
Upload:	others
View:	1 times
Download:	0 times