Jason has long been focused on how wood is treated in LEED, working both for companies that market and sell into the LEED market as well as for NGOs that want LEED to support responsible forestry and forest conservation. He is very familiar with the wood flooring industry specifically and is responsible for Lacey compliance for one of his clients, the well-known flooring distributor Galleher. Jason is one of the key authors and designers of the newly released Timber Traceability Pilot Credit. The credit is intended to support the development of a reliable system for avoiding the use of illegal wood in building construction.
Jason, tell us about this new program.
Jason: Thank you for giving me this space to reach out to the flooring industry. I am very excited about the potential of this new program and hope that it will drive the development of techniques and approaches that will eventually be more effective than the risk mitigation methods most commonly employed today. This new approach can be summarized as declare, map and test:
- Declare: The credit requires disclosure of species and country of harvest for all wood products used in a LEED project. No big deal, as gathering this information is now standard practice for wood imported into the US as it is a requirement of the Lacey Act. But it gets a more challenging from here.
- Map: The credit requires that at least 50%, by cost, of the wood used in the project must be accompanied by maps that show the approximate location of the forests of origin.
- Test: Samples of wood products that will contribute toward achieving the credit must be submitted for testing with the goal of driving the evolution of an infrastructure that will, over the course of time, be able to scientifically verify declarations of species and origin, including information provided in maps. In addition, samples of all wood products that originate in countries where there is a high risk of illegal logging must be tested. Also, high-risk products must meet additional requirements: they must be FSC or PEFC-certified, verified legal or carry a FLEGT license.
I’d like to emphasize upfront that this is a pilot credit, and as such is part of the process by which USGBC tests, refines and evolves new approaches based on learnings gained from project experience. The overarching goal is to contribute to the continuous improvement of LEED by bringing road-tested innovation into the mainframe of the rating system. If people have ideas for improvement, they should post them on the LEEDuser forum that’s been set up for the credit.
How would wood samples be tested?
Jason: Today there are laboratories around the world that can identify species through wood anatomy, and new technologies, like the XyloTron and DART mass spectrometry, that can ID species quickly and inexpensively are on the horizon. There are also methods such as stable isotope analysis and DNA analysis that can be used to verify origin. However, in order to do so, both methods require a substantial repository of reference data against which the test results of any given wood product can be compared. While only a small body of reference data exists currently, there are international efforts underway to expand it and also to build a trustworthy, independent institutional infrastructure to house it. A recent article in Nature magazine provides an excellent overview of these topics, as did your recent post on reference data.
The declare, map and test approach is needed because the due diligence systems most commonly used by US importers, as well as those in countries in the European Union and elsewhere that have Lacey-style legislation in place, are vulnerable to gaming. Documents can all too easily be copied or forged; auditors can all too easily be fooled, whether they work directly for companies or for third-party forest certification or legality verification schemes.
Will “declare, map and test” eliminate illegal wood?
Jason: On its own, declare, map and test obviously won’t be able to distinguish wood that is legal from illegal wood that is mixed with it somewhere in the value chain. However, for importers and their customers, it offers a mechanism to keep upstream suppliers of high-risk products honest – and since cheap, illegal wood undercuts managed forestry and the legal wood trade, a system that creates accountability is ultimately to the benefit of law-abiding companies everywhere.
If a declare, map and test infrastructure were to work in concert with traceability systems (such as FSC/PEFC chain of custody or those employed by governments in producer countries like Brazil and Indonesia), traceability technologies, and advances in forest monitoring efforts (e.g., Global Forest Watch), then over time there is real hope of rooting out the crime that threatens many of the world’s most valuable forests.
Thank you! Next week we’ll talk about the process of designing such a program.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.