Chain of Custody Control System – FSC

ENPOINTE

Chain-of-Custody Control System: FSC-Certified Printed Materials

Brooklyn Park (Corporate Headquarters)
6845 Winnetka Circle
Brooklyn Park, MN 55428-1537
763-535-7277

Certification Contact:
Jeff Storeby
Purchasing/Quality Agent
763-971-3280

I. PURCHASING AND RECEIVING

1.1 Procedures for purchasing FSC-certified material.
All purchase orders for FSC paper will require the paper to be FSC certified and request the paper merchant to supply its FSC Certification number on the invoice and on product packages. ENPOINTE purchase orders will specify FSC ordered paper as FSC-100%, FSC-mix, FSC-recycled. This is triggered through the client desire to have Chain of Custody (CoC) certification on a specific job. Upon being awarded a job the estimate contains the trigger to request, purchase, receive, manufacture, and ship a FSC certified job.
1.2 Verifying Validity of Supplier’s FSC Certificate
Prior to placing an order requiring FSC-certified materials Purchasing will confirm the merchant providing materials is certified by going to “info.fsc.org” that the material is FSC certified. If the merchant/paper desired is not certified, another merchant/paper will need to be selected.
1.3 Procedures for verifying the FSC-certified status of material purchased.
ENPOINTE Paper Handlers will verify the FSC status of the paper both on accompanying documentation as well as on-product labels. Receiving staff will be certain the paper merchant provides its FSC Certification number and when not present will alert the purchasing department. The purchasing department will contact the vendor to resolve discrepancies, or the shipment will be rejected. Paper merchant invoices will be verified for the FSC certification number, percent FSC content, and an FSC product description.
1.4 Procedures for maintaining the separate identity of certified materials upon receiving.
ENPOINTE Paper Handlers will place a load tag on the material before they move the material to the staging area on the shop floor. This load tag will have the material description and ENPOINTE job number as identifiers. The material description will identify it as FSC. All materials are tied to a specific job number, which is the primary designator of certified jobs.
1.5 Procedures for recording quantities of certified materials received.
Quantities received will be recorded in Printstream under the receiving P.O., which is tied to job number. Certified paper will be identified as such in Printstream and job numbers will be available in summary format. The materials are received against the purchase order tied to the job. This information can be extracted from our system by a custom software program that can show volume of FSC materials that have been purchased.
1.6 Producing FSC work.
The organization may act as an FSC-certified contractor providing services to other contracting organizations. In this case, the organization shall include the outsourcing services under the scope of its FSC certificate ensuring that all applicable certification requirements are met.
1.7 Producing non-FSC work.
When the organization provides FSC-certified outsourcing services to non-FSC-certified contracting organizations, it is acceptable that the contracting organization buys the raw material for the outsourced processes. To ensure that the CoC is not broken, the material shall be transported directly from an FSC-certified supplier to the organization (i.e. the non-certified contracting organization shall not take physical possession of the materials before outsourcing).
1.8 Transactional: Compliance with timber legality legislation.
ENPOINTE shall ensure that its FSC-certified products conform to all applicable timber legality legislation. At a minimum, ENPOINTE shall:
a. have procedures in place to ensure the import and/or export of FSC-certified products by the organization conform to all applicable trade and customs laws1 (if the organization exports and/or imports FSC products);
b. upon request, collect and provide information on species (common and scientific name) and country of harvest (or more specific location details if required by legislation) to direct customers and/or any FSC-certified organizations further down the supply chain that need this information to comply with timber legality legislation. The form and frequency of providing this information may be agreed upon between the organization and the requester;
c. ensure that FSC-certified products containing pre-consumer reclaimed wood (except reclaimed paper) being sold to companies located in countries where timber legality legislation applies either:
i. only include pre-consumer reclaimed wood materials that conform to FSC Controlled Wood requirements in accordance with FSC-STD-40-005; or
ii. inform their customers about the presence of pre-consumer reclaimed wood in the product and support their due diligence system as required by applicable timber legality legislation.
1.9 Responsible personnel for purchasing and receiving.

  • ENPOINTE Purchasing Agent
  • ENPOINTE Warehouse/Receiving manager
  • ENPOINTE Material Handlers
1.10 Forms/records used for purchasing and receiving.
Purchase orders will identify certified orders placed.
Our inventory system will identify certified materials in stock and the job number.

II. PRODUCTION

2.1 A Ticket Packet (work ticket) will be generated for each certified print order.
The packet will be identified as certified by “FSC Required” printed on the job ticket, and includes press, finishing, distribution, mailing operations and shipping, instructions for the order. All printing of certified products will be done in individual batch runs per specific customer order.
2.2 Procedures for tracking certified materials within production.
As above, a work ticket will follow the specific certified print order and will include an identifier of the certified status.
2.3 Responsible personnel for production.

  • ENPOINTE Vice President of Manufacturing
  • ENPOINTE Pressroom Manager
  • ENPOINTE Finishing Manager
  • ENPOINTE Premedia Manager
  • ENPOINTE Mailing Operations Manger
  • ENPOINTE Distribution Manager
2.4 Forms/records used for production.
Ticket package includes Work Ticket (shows order number and FSC required), and press ticket for each component. Further, the Work ticket will include in its Job Title that the job is FSC-certified and what the FSC Product Category of the paper.

III. PERCENTAGE-BASED CLAIMS

3.1 Procedures for tracking FSC-certified and non-certified materials.
All materials for jobs are purchased and tracked using purchase order numbers. Each purchase order references a specific job number for the material to be used. All materials will be identified per part 1.4 of this document “Procedures for maintaining the separate identity of certified materials upon receiving”
3.2 Records of FSC-certified vs. non-certified material volumes.
A copy of the purchase orders for both FSC-certified and non-certified materials will be retained for a period of 5 years and will indicate pounds purchased of each type of material. This will be used as the inputs for the products to show the FSC percent content. At least 17.5% by weight of the total paper in the print job is FSC-Certified AND at least 50% by weight of the virgin paper in the print job is FSC certified per FSC-POL-40-001. A printed publication shall be considered as one product when calculating the minimum percentage. When ENPOINTE receives FSC material certified according to the FSC Credit System of FSC-STD-40-004V3-1 all of the material can be used in calculations for percentage based claims.
3.3 Procedures for FSC-labeling percentage-based products.
Label of percentage-based product will follow the guidelines in part VI “Labeling/Logo Use” of this document along with the calculation of FSC-certified material to meet or exceed the appropriate percentage.
3.4 Procedures for avoiding controversial sources for non-certified content.
ENPOINTE in its efforts to avoid purchasing the following categories has embraced the following “Policy for Wood Procurement for Uncertified Contents and Controversial Sources”: Wood that has been illegally harvested; Wood from genetically modified trees; Wood from areas where there is a clear demonstration of violation of traditional; customary or civil rights; or of serious extant disputes with indigenous peoples or other social stakeholders, involving confrontation or violence; Wood from uncertified high conservation value forests (HCVFs).

IV. OUTSOURCING

4.1 Procedures for using an outsourcing agreement with subcontractors.
ENPOINTE vendors performing work on a FSC project will be asked to sign a Chain of Custody Outsourcing Agreement. The organization shall establish an outsourcing agreement with each non-FSC-certified contractor, specifying at minimum that the contractor shall:
a. conform to all applicable certification requirements and the FSC Certificate Holder’s procedures related to the outsourced activity.
b. track and control all materials that are outsourced for use in FSC-certified products to ensure they are not at risk of mixing or being contaminated with any other materials during the outsourcing arrangement.
c. use only the material provided by the FSC Certificate Holder for products covered by this outsourcing arrangement.
d. maintain records of inputs, outputs, and delivery documentation associated with all material processed during the outsourcing arrangement.
e. The FSC Certificate Holder shall issue the final invoice for the FSC-certified products following the outsourcing arrangement.
f. not use the FSC or ENPOINTE trademarks for promotional use or on any products not included in this outsourcing arrangement.
g. not further outsource the processing of the material to any other entity.
h. allow ENPOINTE to conduct audits of its operation, including on-site evaluation, as part of its auditing of the FSC Certificate Holder.
i. agree to conform with the FSC Core Labor Requirements as described in the FSC Certificate Holder’s procedures as follows (main points):

  • 7.2. The organization shall not use child labor.
  • 7.3. The organization shall eliminate all forms of forced and compulsory labor.
  • 7.4. The organization shall ensure that there is no discrimination in employment and occupation.
  • 7.5. The organization shall respect freedom of association and the effective right to collective bargaining.

j. notify the organization within the period of 10 business days if the contractor is included in the list of organizations that are disassociated from FSC, in accordance with the FSC-POL-01-004, and therefore subsequently ineligible to provide outsourcing services to FSC-certified organizations.

4.2 Description of the outsourcing arrangements(s).
ENPOINTE will subcontract for services it does not provide or for capacity offload reasons. ENPOINTE may subcontract materials from all FSC product groups as necessary.
4.3 Procedures for subcontractors handling FSC-certified material.
The subcontractor shall track and control all materials that are outsourced for use in FSC- certified products to ensure they are not at risk of mixing or being contaminated with any other material during the outsourcing arrangement. The subcontractor shall not use the FSC/BV/RA trademarks for promotional use or on any products not included in this outsourcing agreement.
4.4 Subcontractor recordkeeping.
The subcontractor shall maintain records of inputs, outputs, and shipping documents associated with all material processed during the outsourcing arrangement. All incoming material from the vendor will have a ENPOINTE job number to identify the material.
4.5 Record of subcontractors.
ENPOINTE will keep names and contacts of all used for the production of certified materials along with details. Prior to outsourcing, ENPOINTE will provide its certification body with names and contact details on any new contractor used for the processing or production of certified materials outsourced.

V. FINISHED PRODUCT HANDLING AND SALES

5.1 Procedures for maintaining the separate identity of finished certified products.
Certified orders are kept by Job Number. The specific job work ticket will include requirements for FSC logo use within the printed product. Shipping documents kept with the finished printed material will include an indicator (Job Number) of the certified status of the job.
5.2 Procedures for recording quantities of finished certified products in inventory and sales.
Job Number is used as key for designating certified product sales. Sales may be summarized by customer. Summaries can be generated by a ‘certified’ designation for easy annual auditing quantity data. Quantity on packing slip drives quantity on invoice.
5.3 Procedures for invoicing and shipping of FSC-certified products.
Invoices will have a description of the product, including the certified status, FSC Product Category, and the ENPOINTE FSC Certification Number. Packing lists will include the Job number, Customer PO, a reference to the certified status, and the ENPOINTE FSC Certification Number.
5.4 Responsible personnel for finished product handling and sales.

  • ENPOINTE Shipping Manager
  • ENPOINTE Distribution Manager
5.5 Forms/records used for finished product handling and sales.
Work Ticket with certified description and job number.
Invoice: Based on FSC flag on the job, and the category type (100%, Mix, Recycled)“FSC #BV-COC-940655 FSC ”
Packing List: Based on FSC flag on the job, and the category type (100%, Mix, Recycled) each packing list will include the following:“FSC#BV-COC-940655 FSC ”
Product and Package Labels contain ENPOINTE job number
Sales Summaries: Based on FSC flag on the job, reports can be generated listing the following information, for the desired job closing date range:
Job #
Paper Qty
Paper Description
Vendor Name
Vendor Certification #

VI. LABELING/LOGO USE

6.1 Types of labels or other marks that will be used on finished certified products.
Certified print orders will include a request from the customer for use of the FSC logo. The final printed product will include the FSC logo and other required elements.
6.2 Review and Approval Correspondence.
ENPOINTE will retain FSC logo approval correspondence from the auditing firm for a minimum of 5 years and will be made available during annual audits for auditor review. ENPOINTE will submit all jobs for on product label approval including: reruns without changes, reruns with changes, new artwork. Included in these types of jobs would be the request to use a third party certificate number.
6.3 FSC Label Category.
ENPOINTE is a commercial printer. All products are custom made to customer specifications. Only the applicable FSC label will be used per our FSC Product Group Schedule (FSC-100%, FSC-mix, FSC-recycled), and only products in our FSC Product Group Schedule and only products meeting eligibility requirements per CoC standards for FSC-labeling will be FSC-labeled.
6.4 Other Forest Certification Labeling.
FSC-labeled product will not include or endorse other forest certifications.
6.5 Responsible personnel for labels and logo use.

  • ENPOINTE PreMedia Manager
  • ENPOINTE PreMedia Facilitator
  • ENPOINTE PreMedia Preflight

VII. RECORD KEEPING

7.1 Procedures for maintaining records pertaining to certification.
All records covering certified product are public information, certified paper purchased, certified production, and certified product shipping/sales will be kept for a period of five years. This information is compiled and stored in individual job jackets as hardcopy files for 3 years and as digital data for a period of 5 years. Additionally, Purchasing and Accounting records are maintained as digital data.
7.2 Procedures for compiling annual audit data for surveillance auditors.
Prior to the annual surveillance audit, a summary will be prepared showing certified paper purchases, use, inventory, and sales as well as a listing of public information and advertising. Based on FSC flag on the job, reports will be generated listing the following information, for the desired job closing date range:
Job #
Paper Qty
Paper Description
Vendor Name
Vendor Certification #
7.3 Procedures for annual training.
Prior to the annual surveillance audit, training of new employees and an annual training recap shall be completed and records to be maintained for a period of 5 years including training dates and attendees. These records will be maintained in the departments by the department managers.
7.4 FSC Product Group Schedule
ENPOINTE will maintain and update as need a FSC Product Group Schedule. All FSC certified products listed on this schedule must be covered under ENPOINTE certificate scope. The ENPOINTE FSC Product Group Schedule is available to the public up request.

VIII. TRAINING

8.1 Training Procedures.
This document “ENPOINTE Chain-of-Custody Control System: FSC-certified printed materials will serve as the initial policy and procedure and will be used for annual training and reference when producing FSC jobs. Any employee working with or on a FSC job will require training by their department manager prior to performing the required task.
8.2 Training Records.
Training records will be kept and maintain by department managers and will be retained up to 5 years and available to surveillance auditors to demonstrate date and attendees of training events that have taken place.

IX. PROCESS REVIEW

9.1 Internal Audit.
ENPOINTE will conduct an annual audit of the FSC procedures included in this document and all records relating to the purchase of FSC materials on an annual basis. This internal audit will be conducted at both campuses and findings will be presented to the Senior Management Group.
9.2 Management Review.
All audit findings will be reviewed by Senior Management Group on an annual basis. Upon review of any findings the Senior Management Group will provide support to ensure any procedural changes will successfully be implanted prior to the next review.

X. NON-CONFORMING PRODUCT

10.1 Non-Conforming Product.
The organization shall have procedures in place to ensure that any non-conforming products are identified and controlled to prevent their unintended sale and delivery with FSC claims.Where non-conforming products are detected after they have been delivered, the organization shall undertake the following activities:
a. notify its certification body and all affected direct customers in writing within five business days of the non-conforming product identification, and maintain records of that notice;
b. analyze causes for occurrence of non-conforming products, and implement measures to prevent their re-occurrence;
c. cooperate with its certification body in order to allow the certification body to confirm that appropriate actions were taken to correct the non-conformity.
10.2 Complaints.
The organization shall ensure that complaints received regarding the organization’s conformity to the requirements applicable to the scope of the organization’s CoC certificate are adequately considered, including the following:
a. acknowledge receipt of the complaint to the complainant within two (2) weeks of receiving the complaint;
b. investigate the complaint and specify its proposed actions in response to the complaint within three (3) months. If more time is needed to complete the investigation, the complainant and the organization’s certification body shall be notified;
c. take appropriate actions with respect to complaints and any deficiencies found in processes that affect conformity to the certification requirements;
d. notify the complainant and the organization’s certification body when the complaint is considered to be successfully addressed and closed.