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Forest Management SmartWood Headquarters 65 Millet St. Suite 201 2009 Annual audit Richmond, VT 05477 USA Tel: 802-434-5491 Fax: 802-434-3116 Report for: www.smartwood.org State of Wisconsin Department of Natural Resources Audit Managed by: Managed Forest Law Tree United States Regional Office 801 Highway 3 North, Suite 200 Farm Group Northfield, MN 55057 Tel: 507-663-1115 Fax: 507-663-7111 In Contact person: Kara Wires, Forestry Technical Coordinator Email: kwires@ra.org Madison, WI USA Report Finalized: October 26, 2009 Audit Dates: July 20-23, 2009 Audit Team: Robert R. Bryan SW-FM/COC-003626 Certificate code(s): Certificate issued: 12/4/08 ACCREDITED FSC-ACC-004 Organization Contact: Paul Pingrey © 1996 Forest Stewardship Council A.C. Address: State of Wisconsin Department of Natural Resources FM-06 January 2009 PO Box 7921 Madison, WI 53707 TABLE OF CONTENTS 1. INTRODUCTION .................................................................................................................................... 3 2. AUDIT FINDINGS AND RESULTS ........ 3 2.1. AUDIT CONCLUSION ...... 3 2.2. CHANGES IN THE FOREST MANAGEMENT OF THE FME AND THE ASSOCIATED EFFECTS ON CONFORMANCE WITH THE STANDARD. ...................................................................................................................... 3 2.3. STAKEHOLDER ISSUES ................................. 3 2.4. ...
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SmartWood Headquarters 65 Millet St. Suite 201 Richmond, VT 05477 USA Tel: 802-434-5491 Fax: 802-434-3116 www.smartwood.org Audit Managed by: United States Regional Office 801 Highway 3 North, Suite 200 Northfield, MN 55057 Tel: 507-663-1115 Fax: 507-663-7111 Contact person: Kara Wires, Forestry Technical Coordinator Email: kwires@ra.org
ACCREDITED FSC-ACC-004 © 1996 Forest Stewardship Council A.C. FM-06 January 2009
Forest Management 2009 Annual audit Report for: State of Wisconsin Department of Natural Resources Managed Forest Law Tree Farm Group In Madison, WI USA
Report Finalized: October 26, 2009 Audit Dates: July 20-23, 2009 Audit Team: Robert R. Br an Certificate code(s): SW-FM/COC-003626 Certificate issued: 12/4/08 Organization Contact: Paul Pingrey Address: State of Wisconsin Department of Natural Resources PO Box 7921 Madison, WI 53707
TABLE OF CONTENTS 1.................................................................................................................................ICTDURONT....N IO3 2.AUDIT FINDINGS AND RESULTS ........................................................................................................32.1.AUDIT CONCLUSION.............................................................................. ........................3 ................................2.2.CHANGES IN THE FOREST MANAGEMENT OF THEFMEAND THE ASSOCIATED EFFECTS ON CONFORMANCE WITH THE STANDARD....................................................................................................................... 32.3.STAKEHOLDER ISSUES................................................................................................................................. 32.4.CONFORMANCE WITH APPLICABLE CORRECTIVE ACTION REQUESTS....................................7 ...................... 2.5.NEW CORRECTIVE ACTIONS ISSUED AS A RESULT OF THIS AUDIT............................................................. 192.6.AUDIT OBSERVATIONS..................................................... 19......... ..................................................................3.SECORP TIDUA..............S ..................................................................................................12................3.1.AUDITORS AND QUALIFICATIONS:................................................................1....2 ................................... ........3.2.AUDIT SCHEDULE22 ........ ................................................................................................................................3.3.SAMPLING METHODOLOGY:........................................................................................................................ 223.4.STAKEHOLDER CONSULTATION PROCESS........................................22 ......................... .................................3.5.CHANGES TOCERTIFICATIONSTANDARDS ............................................................................................... .32APPENDIX I: List of visited sites (confidential) ............................................................................................24APPENDIX II: List of stakeholders consulted (confidential) .........................................................................28APPENDIX III: Forest management standard conformance (confidential) ..................................................29APPENDIX IV: Chain-of-Custody Conformance (confidential) ....................................................................37APPENDIX V: FSC Annual Audit Reporting Form: (confidential) ................................................................41APPENDIX VI: SmartWood Database Update Form ...................................................................................43APPENDIX VII: Group management conformance checklist (confidential) .................................................44
Standard Conversions 3 1 mbf = 5.1 m 1 cord = 2.55 m3 1 gallon (US) = 3.78541 liters 1 inch = 2.54 cm 1 foot = 0.3048 m 1 yard = 0.9144 m 1 mile = 1.60934 km 1 acre = 0.404687 hectares 1 pound = 0.4536 kg 1 US ton = 907.185 kg 1 UK ton = 1016.047 kg
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1. INTRODUCTION The purpose of this report is to document annual audit conformance of State of Wisconsin Department of Natural Resources Managed Forest Law Tree Farm Group (WI DNR MFL), hereafter referred to as Forest Management Enterprise (FME). The report presents the findings of SmartWood auditors who have evaluated company systems and performance against FSC forest management standards and policies. Section 2 of this report provides the audit conclusions and any necessary follow-up actions by the company through corrective action requests. SmartWood audit reports include information which will become public information. Sections 1-3 will beposted on SmartWood’s websiteaccording to FSC requirements. All appendices will remain confidential. Dispute resolution: If SmartWood clients encounter organizations or individuals having concerns or comments about Rainforest Alliance / SmartWood and our services, these parties are strongly encouraged to contact SmartWood regional or Headquarters offices directly (see contact information on report cover). Formal complaints or concerns should be sent in writing.
2. AUDIT FINDINGS AND RESULTS 2.1. Audit conclusion Based on Company’s conformance with FSC and SmartWood requirements, the audit team makes the following recommendation: Certification requirements met, certificate maintenance recommended No CAR(s) issued Certification requirements not met: Additional comments: Issues identified asNone controversial or hard to evaluate. 2.2. Changes in the forest management of the FME and the associated effects on conformance with the standard. WIDNR has instituted minor changes in its management systems to address Corrective Action Requests issued during the initial assessment. These changes, which have brought WIDNR into full conformance with the standard, are described in detail in Section 2.4. The overall size of the group grew from 40,702 members and 2,166,271 acres to 41,865 members and 2,239,206 acres since the 2008 assessment. 2.3. Stakeholder issues
Stakeholder issues are summarized in the following table. Stakeholder Issue SmartWood Response The inability of MFL to require many The certification process verifies conformance fundamental forestry practices [other than with the FSC Lake States Standard, which silviculturally-based timber production] is a includes over 62 criteria and over 150 basic structural flaw in MFL, which prevents it supporting indicators that address social, from ever being a sustainable forestry program economic, and environmental sustainability. until some very broad changes are made. While it is true that the MFL program cannot require that landowners implement certain practices (e.g., pre-commercial thinning or implementing specific wildlife conservation practices) to remain in the MFL tax program, there are provisions for removal of a property from the MFL FSC certification group (a subset of the MFL lands) for non-conformance with the FSC standard. These procedures are described in Chapter 60 of the Forest Tax Law Handbook. Monitoring by DNR foresters and annual audits by SmartWood are used to verify conformance with the FSC Lake States Standard and take the necessary steps to bring landowners into conformance or remove them from the group. Most MFL plans pay little or no attention to The initial assessment found that not all MFL wildlife or ecology. So long as DNR habitually management plans met the FSC standards for accepts plans which give little attention to non- management plans, and CAR 08/08 was timber aspects, it cannot be considered a issued to address this non-conformance. DNR sustainable forestry program. has developed a new management plan format that includes all the required ecological elements of the FSC standard, including information on rare, threatened and endangered species, links to ecological information for the forest type, and information on regional landscape ecology. Site specific wildlife information and information on harvested non-timber forest products would be included if they were landowner objectives, but the plans do not necessarily have site specific wildlife habitat information (unless rare species are known to be present). See OBS 04/09. Many MFL plans are over simplified in terms of Many of these comments may be applicable to stand delineations, resources are described older MFL plans. As noted above, CAR 08/08 primarily in terms of commercial forest was issued to address consistency of MFL produces, ecologic or plant communities are plans with the FSC Lake States Standard and barely described at all, cut-and-paste bring old plans up to standard. To address the prescriptions are over used and unreasonable variety in quality of plans and extensive review or unlikely to work, but DNR usually time required by DNR foresters (the audit approves such plans without question, so longconfirmed that plans are not “reviewed without as the paperwork is filled out correctly. Until it isquestion”), DNR has developed a standardized, required by MFL that plans address more form-based plan with menu selections that comprehensive forestry, and plan-writers are addresses weaknesses in many of the older given adequate training in certain non-timber plans identified by this comment. Stand aspects, the motivations to do brief descriptions and prescriptions are updated as simplified plans will remain. It is very common necessary at the time that Cutting Notices are to get MFL plans changed substantially, to filed, including information on rare species,
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reflect the actual composition and management habitats, and cultural resources. Other needs of the forest as well as to provide for documents, such asWisconsin’s Forest issues beyond basic timber production. Management Guidelines, and Silviculture Manual, and website links embedded in the plans, supplement these plans and provide more specific guidance when management activities are being implemented. Annual SmartWood field audits of practices prescribed by the plans are used confirm conformance with the social, economic, and environmental requirements of the Standard (i.e., Principles 2, 3, 4, 5, and 6). All existing MFL entries are being certified and The initial assessment included a requirement all past plans are being accepted in one to bring existing plans into conformance with sweeping decision. There isn't even any the FSC standard. WIDNR has initiated a provision for reviewing and improving the process to bring all MFL plans into existing plans as a condition of the certification. conformance with the FSC standard. See findings for CAR 08/08 in Section 2.4. MFL provides for up to 20% of the acreage in Areas identified as non-productive are included any MFL contract to be considered "non- within the scope of the certificate. Depending productive", essentially areas in which the on the nature of the resource, passive landowner doesn't have to do anything. It often management (e.g. no harvesting) may be an happens that such areas have the highest appropriate management strategy to conserve biologic diversity and the most uncommon important values (e.g., wetlands and other species on the property. Plans usually do not native plant communities).The FSC Lakes include requirements or even States standard does not require that all areas recommendations for these areas. These areas of an ownership be actively managed. DNR are not mentioned as being excluded from the staff report these are often sensitive sites, scope of the certificate. If the certification does areas that landowners wish to preserve for cover these areas, SmartWood should non-timber values (e.g., very old forest consider that a) Nothing can be made patches) or areas managed actively for non-mandatory in non-productive areas, potentially timber values (e.g., oak savannah restoration). up to 20% of MFL, and b) Little is even However, if passive management is recommended for these areas in most plans, recommended, DNR requires that these areas even for those with high biologic diversity. be monitored to ensure that the non-timber objectives are not being threatened (e.g., invasion of a natural community by exotic plants). DNR has recently had a series of trainings around the state for service foresters and certified plan writers to review the requirements for non-productive lands that are included in MFL plans. No non-conformances related to the FSC standard were identified regarding identified non-productive lands. DNR should have more training so that DNR has a wide range of training opportunities foresters can identify rare or uncommon plant for landowners and land managers. This is a communities. constructive comment that DNR could consider; however, no non-conformances related to the FSC standard were identified regarding identification and protection of rare or uncommon plant communities. The stated primary management objective for The FSC standard does not require that land MFL lands is legislated to be “timber managers practice “ecological forestry” or production”.This statement limits the MFL“mimic natural processes.”However, the certified plan writer’s options to manage forStandard (notably Criterion 6.3) does require ecologically-based forest management. that species composition, structures, and
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Ecological forestry seeks to emulate natural processes of native forest ecosystems be disturbance regimes and incorporate natural maintained. The initial assessment found that models into silviculture that mimic ecological the MFL lands were in conformance with processes that have shaped our forests for Criterion 6.3 and that the mandate of timber thousands of years. This legislated provision is production has not compromised maintaining a fundamental constraint to practicing FSC ecological values. The 2008 field audit in the certifiable forestry on MFL lands and should be South Central and South East Regions found changed (though legislation) as a precondition that landowners were trying to maintain before FSC/RA certification is enacted. declining types (e.g., fire-dependent oak), maintaining old-forest structures, restoring The application of the silvicultural native forest ecosystems through mixed-recommendations contained in the WI DNR species planting, and working with Wisconsin Forest Management Guidelines: successional processes. PUB-FR-226 2003 (to which conformity is required in preparing MFL forest management DNR reports that it is continuing to work with plans) has become too prescriptive. Rigid cooperating foresters and certified plan writers interpretation of these concepts can easily fall to address differences of opinion in into the same trap of constraining a forest management plan content and latitude in manager’s options and development of creative writing silvicultural prescriptions. DNR has held solutions. The prerogative and decision of what many meetings to address these concerns in silvicultural system to be applied should remain developing its new MFL Management Plan in the hands of the resource manager closest to Template. the problem. The MFL certified plan writers have the skills to prescribe the silviculture to be Nonetheless, there could be instances where applied and should be allowed the freedom and the Silviculture Manual limits management encouraged to experiment and develop creative options including both timber production and approaches to the silviculture applied on MFL restoration goals (aspen has been identified by lands. some stakeholders as a problematic type) and the creativity of qualified land managers. DNR reports that one landowner group has However, no instances of non-conformance raised concerns that the MFL Silviculture with the FSC standard (notably Criterion 6.3) Manual limits what the landowner considers to have been identified to date. This general topic be acceptable ecological forestry practices (i.e., the Silviculture Handbook and related elements of the management planning system on ecologically based management options as related to Criterion 6.3 and associated Criteria and Indicators) will be a focus element of the 2010 annual audit. Currently MFL only allows a 20% non- The 2008 assessment did not include Vilas productive category for wetlands and other County, but it did not find evidence the 20% protected areas on a given entry. This is applied non-productive limit was resulting in statewide with no consideration of the inappropriate management on fragile lands. percentage of wetlands found in any given Areas visited in 2009 had very low levels county. Vilas County lands contain (probably less than 5%) of non-productive approximately 30% or more in designated lands. wetlands on average, but can be considerably higher on any given ownership. This means No instances of non-conformance with the FSC foresters writing MFL plans on Northern standard have been identified to date regarding Wisconsin counties are commonly running up this issue. This issue will be reviewed during against the 20% limit forcing them to prescribe the 2010 audit (Criterion 6.3 and 6.5) including treatment on fragile lands which in other site visits to counties with a high percentage of counties, not facing this constraint, can be left non-productive land. as designated non-productive areas. This is a significant flaw in the MFL law. The 20% non-productive clause should be changed before certification is enacted to allow consideration
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according to the percent of wetlands, other fragile lands, and critical habitat found in any given county. DNR has been under some pressure from the MFL procedures require that the timing of timber industry to get the harvests done despite mandatory practices is based on stand the current market, and is pushing MFL sales at conditions and silviculture. Markets, landowner the current market prices. The industry seems need for cash flow, or desire not to cut do not to be having some trouble procuring timber enter into the decision. A consulting forester because landowners are resisting low prices, with a large number of clients in the MFL and they seem to want ready supplies of program reported no pressure from DNR and cheaper timber to match their lower lumber noted that DNR allows some landowners and prices. discretion (typically months, not years) forester in the timing of harvests due to market conditions. No instances of non-conformance with the FSC standard have been identified to date regarding this issue. Future audits will continue to consider this issue as it relates to the requirements of the FSC standard. 2.4. Conformance with applicable corrective action requests The section below describes the activities of the certificate holder to address each applicable corrective action issued during previous evaluations. For each CAR a finding is presented along with a description of its current status using the following categories. Failure to meet CARs will result in nonconformances being upgraded from minor to major status with conformance required within 3 months with risk of suspension or termination of the SmartWood certificate if Major CARs are not met. The following classification is used to indicate the status of the CAR: Status Categories Explanation Closed Operation has successfully met the CAR. Operation has either not met or has partially met the CAR. Open Check if N/A (there are no open CARs to review) CAR 01/08 Reference Standard & Criteria: 1.1.a; 4.2.a Nonconformance Field audits found non-compliance with OSHA safety laws and Major Minorhitses gnsetiorctons ct ae iv snayoeetnar doc WI someemplDNR noitalug gnoma sre arv . Corrective Action Request:WI DNR’s MFL program shall implement measures to promote implementation of staff safety policies; provide guidance to MFL landowners on OSHA requirements during timber harvesting; and develop reporting policies for observed OSHA violations. Timeline for conformance:By the next annual audit Evidence to close CAR:Wisconsin statutes do not authorize DNR foresters to enforce or administer specific Occupational Safety & Health Administration (OSHA) regulations on private lands. The CAR as written (to require DNR to develop a reporting system for observed OSHA violations) is in conflict with state law and would expose DNR to liability if it were implemented.
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Therefore, analysis of conformance of this CAR will focus strictly on the language of Indicators 1.1a and 4.2.a, which do not require reporting on OSHA violations but do require that applicable safety laws (1.1a) and related safety programs and procedures (4.2.a) be followed. DNR has provided additional guidance to MFL landowners on OSHA requirements for timber harvesting on private lands by adding Article 47 of the Sample Timber Sale Contract, which specifies that operations should be in compliance with OSHA safety regulations. The Division of Forestry has had a policy that requires employees and contractors to wear safety glasses when working in the woods since December 13, 2005. DNR has had a policy since September 9, 1998 to provide employees with eye protection when duties expose them to hazards that cause injury to the eyes. This policy is found in Manual Code 9185.5. DNR has had a policy since April 4, 2008 that requires DNR employees and contractors to wear hard hats when working on active logging sites. Other safety topics can be found on the DNR intranet pages underManual Code and Handbooks. Safety policies are promoted within DNR in the ForesTREEporter, the Division of Forestry’s newsletter.The newsletter includeslinks under “Staff Tools” and “Field Safety.”on where DNR Foresters may find thisReminders information are scheduled to be published in the ForesTREEporter. Cooperating Foresters receive correspondence from DNR through theFor Cooperating Foresterspage in the DNR Forestry public website. A link to Forestry Industry Safety & Training Alliance (FISTA)website informs cooperating foresters of scheduled safety training, SFI certification and Master Logger Certification classes. DNR staff members followed safety practices in the field (e.g., hardhats, safety glasses, seat belts). There were no active logging jobs, but logging contractors interviewed indicated that property safety equipment was used on all jobs. Each year DNR is required to report on the injuries experienced by its employees and their causes. The Division of Forestry does this for its employees as well. Page 21-11 of the Forest Tax Law Handbook, DNR foresters “are encouraged” to consider ifreasonable safety precautions are followed. However, DNR does not have a monitoring checklist that is used for site visits and no evidence that they
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were actively monitoring safety practices of loggers was noted. As the related Handbook footnote observes, DNR Service Foresters may offer general safety information or observations about safety concerns, but they are not authorized to enforce or administer OSHA regulations. Additionally, since loggers purchase stumpage and are not contracted by the landowner or WI DNR, they are not considered contractors as per the language of Indicator 4.2.a. Page 21-15 of the Forest Tax Law specifies that an ownership may be removed from the FSC group for non-conformance with the FSC standard. Chapter 60 describes the administrative procedures for notifying landowners of non-conformance with the FSC Standard and, if necessary, removing an ownership from the FSC group. No evidence of removal for non-conformance was reported to the auditor. DNR prefers to educate landowners to change behavior before removing them from the group and to date has found that to be effective. Thus, DNR has the procedures in place to ensure that safety practices are being followed on MFL lands in the FSC group. However, DNR staff and landowners have not been made specifically aware of the FSC safety requirements. The preceding procedures address the requirements of Indicators 1.1.a and 4.2.a, but OBS 01/09 has been issued to address the apparent weakness in conveying the importance of these requirements to DNR staff, cooperators, and landowners. CAR Status:CLOSED Follow-up Actions (if app.):See OBS 01/09 CAR 02/08 Reference Standard & Criteria:1.6.a Nonconformance WI DNR MFL Program has not officially documented its commitment to Major MinorFSC Principles and Criteria. Corrective Action Request:WI DNR shall develop a documented statement of commitment to the FSC Principles and Criteria. Timeline for conformance:By the next annual audit Evidence to close CAR:to the Forest Tax Law HandbookDNR has added wording documenting its commitment to the FSC Principles and Criteria (Chapter 21-1). The handbook was updated on Oct. 30, 2008 CAR Status:CLOSED Follow-up Actions (if app.):None CAR 03/08 Reference Standard & Criteria: 3.2.b, 3.3.a, 8.2.d.3 Nonconformance WI DNRDNR’s policy on tribal consultation onhas not implemented WI Major Minorlands in the MFL group. Corrective Action Request:WI DNR’s MFL program shall implement existing policies and
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procedures on consultation with tribes. Timeline for conformance:By the next annual audit Evidence to close CAR:personnel to act as liaisons for eachDNR has identified Native American tribe. DNR also identified a tribal contact for each tribe. A meeting has been held to bring the Tribal Liaisons together to review expectations of the liaison role. This meeting was held on January 15, 2009. Letters were sent to tribal leaders announcing the tribal liaison process and requesting face-to-face meetings. At the request of the tribes, DNR Tribal Liaisons make MFL information on scheduled harvests available to tribes so that they may comment regarding protection of Native American resources. Since this policy was implemented no tribes have requested further information about any MFL cutting notices or indicated that any tribal resources might be harmed by MFL members. As part of process to clarify treaty rights, DNR will be meeting with tribes to discuss tribal rights regarding herbaceous plants. This process has not yet begun. CAR Status:CLOSED Follow-up Actions (if app.):None CAR 04/08 Reference Standard & Criteria: 3.3.a, 4.4.b Nonconformance Private lands foresters and Cooperating Foresters have not been trained Ma or Minorand archeological sites to jf idcrioepdatenpue hmin niotyt fsiteted epor unrlarutluc fo noiteecnoitdprd ann ioat s Corrective Action Request:WI DNR shall implement measures to train foresters working on properties in the MFL group in cultural resource identification and protection. Timeline for conformance:By the next annual audit Evidence to close CAR:The DNR Archeologist has provided seven training sessions on identifying archeological sites. Consulting foresters were invited to three of these sessions and in the future there will be at least one such session annually. Rosters of 5 of the training sessions are attached. Another training session is planned in the near future. The training sessions are well attended and the material learned will be used on private lands. Instructions for obtaining cultural and archeological resource data is provided to DNR and Cooperating Foresters. Reminders on obtaining this information are provided at the annual MFL update sessions. A review of management plans and cutting notices indicated that foresters are checking for cultural resource information. No cultural sites are known on the sites reviewed during the audit. DNR Archeologist has developed guidance on managing
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archeological resources on state lands. This guidance is being reviewed for applicability on MFL lands. If sensitive resources are identified on MFL lands, the DNR forester works with the state archaeologist and cooperating forester to develop appropriate management strategies. CAR Status:CLOSED Follow-up Actions (if app.):None CAR 05/08 Reference Standard & Criteria: 6.6.a Nonconformance WI DNR includes at least two FSC Highly Hazardous Pesticides (FSC Major Minoricalchem of list dofneedocmm serngdilunc ie,usr T .sdnal LFM no po )d a nihoretib he document indicates these chemicals cannot be used on certified land. WI DNR has no measures to enforce the requirement that these FSC prohibited chemicals are not used on FSC certified lands Corrective Action Request:WI DNR shall develop and implement measures to enforce the prohibited use of FSC highly hazardous chemicals (until/unless a derogation is in place) on properties to be included in the WI DNR MFL group certification. Timeline for conformance:By the next annual audit Evidence to close CAR:Enforcement of the Managed Forest Law (MFL), Tree Farm and FSC certification requirements is identified through Chapter 60 of the Forest Tax Law Handbook. Chapter 60 includes procedures for removing lands from the MFL FSC certification program for nonconformance with the standards. Wording was added to page 60-15 to provide examples and the basis for removing landowners from group certification if an FSC prohibited pesticide is applied on certified lands. Enforcement of the MFL program is done in accordance with procedures outlined underSteps to Successful Compliance or Enforcementon page 60-1 and 60-2. Two instances of highly hazardous pesticide use were reviewed during the audit, as described below in CAR 06/08. In each instance DNR followed up with the landowners in a letter that described the FSC prohibition on certain chemicals and that gave them the option of ceasing use of the prohibited chemical or voluntarily leaving the group. In both cases the landowners agreed to stop using the chemical. Because the landowners agreed to stop using the chemical WIDNR has not needed to remove them from the through its formal enforcement procedures. DNR has also develop new measures for monitoring pesticide use (see CAR 06/08 below) and for monitoring conformance with the overall FSC Standard (see CAR 12/08 below), and related Observations OBS 02/09 and OBS 08/09. CAR Status:CLOSED Follow-up Actions (if app.):See OBS 02/09 and OBS 08/09 CAR 06/08 Reference Standard & Criteria: 6.6.a, 6.6.d, 6.6.f, 6.6.g Nonconformance MFL property owners and cooperating foresters have not been provided
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