A look at common scenarios and whether or not COC applies.

Nearly every call for assistance on a LEED project includes one of the following questions or comments: “That Chain of Custody thing doesn’t apply to me, does it?” or, “My lumber dealer says no one after him ever needs to be on the FSC Chain of Custody” or, “We figured out how we can get around being on the FSC Chain of Custody.”

These dialogues aren’t new. Ever since LEED began and FSC was a part of it, it has been unclear to both woodworkers and LEED Accredited Professionals alike what anyone is actually supposed to do to earn the “certified wood” credit.

The criteria says, “Use a minimum of 50% wood-based materials and products, which are certified in accordance with the Forest Stewardship Council’s (FSC) Principles and Criteria for wood building components. These components include, but are not limited to, structural framing and general dimensional framing, flooring, sub-flooring wood doors and finishes.” Only new wood, not salvaged or recycled wood, counts for this particular credit.

In the distant past, this was widely interpreted as simply, “Make sure that FSC wood gets used,” without consideration of the FSC Principles and Criteria, which require a full chain of custody. In the more recent past, however, this has been interpreted to show that it matters whose hands the FSC wood passes through in order to be considered a complete chain of custody that makes the FSC wood count valid.

It is easy to understand why it is confusing. The U.S. Green Building Council (USGBC) does not have anyone from the wood industry or even from forestry sitting on its MR TAG (technical advisory committee). So the complicated nature of our industry and its materials and supply process didn’t come into focus until questions started to pile up on USGBC’s doorstep. Typically, these have been answered by either: 1) no response, or 2) “Take your question to FSC.”

As a result, FSC made an attempt to sort out how it wants its Chain of Custody to be complete by declaring, “Companies that take legal ownership of FSC products and produce, sell, promote or trade them should be certified for Chain of Custody.”

But even following that clarification, credit documentation is still being submitted to USGBC with an incomplete Chain of Custody. Also, in many cases, the LEED AP involved doesn’t understand fully what is needed to show that material truly is “certified in accordance with FSC’s Principles and Criteria.” (And how can he or she, if they don’t first download the FSC’s documents showing what needs to happen and then pass that information along to the GC and then the millworker, who also need to understand? Unfortunately, this does not always happen.)

While it is true that only about 12% of completed LEED projects earn the certified wood credit, it is well known that many FSC credits have been awarded to projects which didn’t have a complete COC or a correct content calculation. USGBC took notice, and finally made an attempt at clarity in spring of 2008. Realizing that this credit is still open to interpretation and argument, both FSC and USGBC wrote similar documents which were released on April 7, 2008. (They can be found online via the following links: USGBC — www.usgbc.org/ShowFile.aspx?DocumentID=4027; FSC — www.fscus.org/green_building/leed_faq.php.)

Yet, even after the issuance of those documents, confusion remains, and custom woodwork manufacturers for the most part are still involved in heated discussions. Part of the disagreement comes from FSC’s and USGBC’s choice of words. The words “vendor,” “contractor” and “subcontractor” are not defined, and in our industry they can be used interchangeably or take on different meanings in various areas across the country.

For instance, in some places a custom woodwork manufacturer is called a vendor, but in others he is termed a subcontractor. In a few cases, the custom woodwork is a prime contract and the woodwork firm is the contractor. In some cases, the GC owns the woodworking firm — and so on. Then there is outsourcing to consider, too. In fact, there are at least 25 different scenarios involving woodworker, contractor and supplier relationships in a project. Most of them stand open to interpretation.

So, to figure out where your business stands by using the language in the FSC and USGBC April documents is not enough to clarify what you need to do. Therefore, I have tried to dig deeper and get some real answers.


What FSC Says

In an effort to obtain some “real world” clarity, I described a number of scenarios to Frank Judd, an inspector for FSC COC at Scientific Certification Systems (SCS), one of FSC’s certifying bodies. I asked him to judge them individually and determine whether or not the firm in each situation needs FSC COC in order to offer materials for LEED projects.

Judd graciously took each into consideration and identified which are subject to being on the FSC COC and which are not. (Incidentally, Judd also acknowledges that it is not always immediately known that FSC COC requirements for the possession and sale of FSC material vary slightly from what USGBC wants.) If you can find your business type in the following descriptions, you will better understand your company’s obligations.

First, the “yes” types of companies that do need to have an FSC Chain of Custody to have their products count toward the earning of LEED credits, according to Judd:

• An architectural woodworking company that is independently owned. It buys FSC materials and cuts them up to make custom wood items, such as cabinets and architectural woodwork that gets attached to a building.

• An architectural woodworking company that is independently owned and buys already constructed cabinets, mouldings or countertops from someone else, but includes them with the architectural woodwork it builds and sells to a general contractor. It delivers to the job site and needs FSC COC, whether it installs the products or not.

• A custom architectural woodwork company that does not create any of the doors, mouldings, panels or cabinets for the project itself, but makes its entire business from buying FSC products made by several other independent custom architectural woodworking firms. It pursues the work, estimates and bids it, then acts as a project manager, parsing out the work to several other woodworking firms and selling all of it to a general contractor for one building project. Generally, this type of company is referred to as a “broker.”

• A lumber company that sells raw hardwood or dimensional lumber and is owned by a GC.

• The GC who owns the lumber company that sells FSC hardwood or dimensional lumber.

• An architectural woodwork company that is owned by a lumber company.

• Component manufacturers, such as a company that produces drawer boxes for a cabinet company.

• An architectural woodwork or cabinet company that has FSC parts like drawer sides or mouldings made by a component company. The exception to this is when an operation is described and approved by a certifying body as “outsourcing.” (See separate outsourcing discussion below.)

• A component manufacturer that just makes mouldings, whether it sells them to custom architectural woodwork companies, to general contractors or to independent carpenters.

• A general contractor who buys a moulder, sets it up in his machine shop so he can make mouldings for his own projects, but also makes mouldings for other general contractors.

• A general contractor who buys a moulder, sets it up in his machine shop so he can make mouldings for his own projects, but he exchanges the FSC lumber from a lumberyard for mouldings that he makes out of that exchanged material.

(Note: USGBC’s April document, Sub Paragraph D, reminds us that, “The vendor’s COC Certificate number must be shown on any invoice that includes FSC products.”)

The ‘No’ Companies

According to Judd, the following types of businesses do not need to have an FSC Chain of Custody Certificate to have products count toward the earning of LEED credits.

• An architectural woodworking company that is independently owned. It buys FSC materials and cuts them up to make custom wood items, such as cabinets and architectural woodwork that get attached to a building, and it installs the products itself. (Note: When such a company acts as the installer, it is considered a subcontractor and therefore doesn’t need to be certified, according to USGBC LEED NC2.2, page 283. In this case, it would use its vendor’s FSC materials invoice and COC number for the project. An upcoming article will describe in detail how these calculations work.)

• A general contractor who buys the custom woodwork and has his own team of carpenters who take the provided FSC mouldings, door trim, paneling or countertops that were built by an architectural woodwork company, then scribe, trim and fit to building all those parts. (But the architectural woodwork company still has to have it.)

• A general contractor who hires a separate team of carpenters to install custom FSC wood products purchased from an architectural woodwork company. (But the architectural woodwork company has to have it.)

• A general contractor who owns a custom architectural woodwork company that buys FSC materials for its use. (But the architectural woodwork company must have it.)

• A general contractor who owns a custom architectural woodwork company and installs the woodwork it builds with his own carpenters or the woodwork shop’s employees, where the woodwork company buys FSC materials it needs to build whatever the general contractor asks for. (But the architectural woodwork company must have it.)

• An independent carpentry contractor (hired by the general contractor) who does not buy FSC materials but will cut and fit FSC cabinets, mouldings, paneling, doors and frames on the project.

• A general contractor who buys a moulder and sets it up in his machine shop so he can make all the mouldings for his projects.


Recently, there has been renewed angst over the policy of “outsourcing.” A lumber company or millwork company cannot just assume that it keeps its COC unbroken if the material changes hands or manufacturing facilities without changing money. There are limits to outsourcing agreements. Here are some basic guidelines:

• No outsourcing may be done without an “Outsourcing Agreement” as written and approved by the certifying body. This document will cover the details of separate storage, shipping, handling, etc., by the outsource company, which may not advertise, promote or claim to hold an FSC COC.

The Chain of Custody Certificate holder must have procedures in place showing how the process will be carried out and the controls it has to prove: that the outsourced company accounts for all materials, that they are all shipped back to the FSC COC holder and that they are following instructions.

Outsourcing must be direct, without going to a third party. An example would be an FSC COC moulding manufacturer that sends them to a finisher, who primes them and returns them directly back to their origin.

Outsourcing will become a part of an FSC COC Certificate holder’s annual audit if it is participating in one of these approved arrangements. In some cases, there will be an extra charge if you use one, but simple ones may go without an additional fee.

If outsourcing is desired in your operation, please go over your situation with your certifying body before engaging in an outsourcing practice of any kind. Then you can determine your COC obligations.

One final word: Ultimately when it comes to LEED, the LEED AP most likely will be making the final call, based on the language of LEED NC2.2, page 283. I recommend that you become familiar with this information to aid in your understanding of this complicated process.

Margaret Fisher is Market Development Manager of Saunders Wood Specialties in Park Falls, WI., and serves as the AWI (Architectural Woodwork Institute) liaison to the USGBC (U.S. Green Building Council). Her previous articles about LEED and wood as a sustainable material are archived on CWB’s Web site, www.iswonline.com.

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