22-1012 Revisions to FSC Last Link and Market Limitations Exceptions

As of 10/12/22, the Last Link and Market Limitations exceptions for FSC wood were revised and made available to LBC 4.0 and Core project teams. LBC 4.0 and Core teams may only use the exceptions, where applicable, as specified here and in the online handbooks. 

MT-012 FSC Last Link in COC

In the case that FSC wood can be tracked by Chain of Custody (COC) to a “last link” before the project receives the wood, the team may use the products from the “last link” provided all of the following conditions are met:
  • FSC or compliant alternatives were specified in bid and applicable contract documents,
  • The team has tried, but is unable to convince the one “missing link” to get FSC certification, 
  • There is no viable "outsourcing" option (through an FSC certified entity or a project contractor), and,
  • In the event that certified wood with a complete Chain of Custody is available, all timelines for delivery would cause untenable delays for dependent work scope. 
To use this exception, project teams must submit the following documentation for audit: 
  • Narrative describing the team's efforts to locate FSC wood with a complete COC, including attempts to coordinate outsourcing. In addition, where FSC with COC or other compliant wood could be sourced, but in a timeframe that the project schedule couldn’t accommodate, the delays to dependent work that would have resulted if that source(s) were used, must be explained.
  • Technical documentation substantiating: 
    • That FSC or other compliant wood was specified in bid and applicable contracting documents,
    • The asserted disruption to the project schedule, such as approved schedules in effect at the time of sourcing efforts, and 
    • That the final link is accurately attributing the FSC wood to the LBC project, and not double counting it for other projects (e.g. a signed statement from the foreman, owner, or other responsible party)
  • Advocacy to at least three local suppliers to become COC certified, including providing information about "individual":http://https://us.fsc.org/en-us/certification/chain-of-custody-certification and "group":https://us.fsc.org/en-us/certification/chain-of-custody-certification/coc-group-certification certification.
  • Documentation demonstrating due diligence to procure compliant material for the product type to which this exception is being applied, including relevant communications with suppliers and the regional FSC sourcing representative.
MT-013 FSC Market Limitations
Project teams may use non-FSC "low risk" wood if all of the following criteria are met:
  • FSC or compliant alternatives were specified in bid and applicable contract documents,
  • Use of FSC or compliant alternatives is maximized, as available, for all other project applications,
  • The team demonstrates due diligence, including contacting the regional FSC sourcing representative, in attempting to locate wood that is either FSC, salvaged, or meets an existing exception:
    • MT-001 Pending FSC Certification
    • MT-002 Invasive Species (of tree or organism)
    • MT-003 Surplus Wood 
    • MT-004 Urban Harvested Wood
    • MT-005 Storm-felled Wood 
    • MT-012 FSC Last Link in Chain of Custody
  • The team advocates to at least three local suppliers to become FSC certified, through individual or group certification, and
  • Where FSC wood or alternate compliant wood is available, all timelines for delivery would cause untenable delays for dependent work scope.
To use this exception, project teams must submit the following documentation for audit:
  • Narrative describing the team's efforts to locate wood for the relevant application, that is FSC, salvaged, or that meets another exception. In addition, where fully certified FSC or other compliant wood could be sourced, but in a timeframe that the project schedule couldn’t accommodate, the delays to dependent work that would have resulted if that source(s) were used, must be explained.
  • Technical documentation substantiating: 
    • That FSC or other compliant wood was specified in bid and applicable contracting documents, and
    • The asserted disruption to the project schedule, such as approved schedules in effect at the time of sourcing efforts.
  • Letters to at least three local suppliers advocating for either "individual":https://us.fsc.org/en-us/certification/become-certified or "group":https://us.fsc.org/en-us/certification/group-certification certification.
  • Documentation demonstrating due diligence to procure compliant material for the product type to which this exception is being applied, including relevant communications with suppliers and the regional FSC sourcing representative.

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