PEFC Council comments on the Alliance QACC

PEFC Council's first review of the Alliance's internally developed QACC (Questionnaire for Assessing the Comprehensiveness of Certification Schemes / Systems) identifies over 60 areas of concern. Given the shortcomings of the Questionnaire PEFC Council considers field testing the QACC as premature and offers the World Bank/WWF Alliance joint consultations in an open dialogue process.

Although the Alliance recognizes that the QACC in its current form needs to undergo a set of revisions, it intends to use the questionnaire to assess two forest certification schemes, the Programme for the Endorsement of Forest Certification Schemes (PEFC) and the Forest Stewardship Council (FSC) starting this summer.

PEFC Council's review of the QACC, highlighting over 60 areas of concern, shows that the questionnaire and its supporting documents are not of required quality and are in need of further development before they can be used to assess schemes in an objective manner. The PEFC Council is willing to discuss with WWF and the World Bank both the structure and content of an objective questionnaire, which can be supported by all stakeholders to help the Alliance meet its certification aims. This should be done before any testing and usage of the QACC.

The PEFC Council has pointed out to the Alliance that the QACC cannot only be regarded as an "internal management tool" as maintained by the Alliance. In light of the World Bank's recognition as a leading financial institution and WWF's reputation as a global ENGO, a final Questionnaire for the Assessment of Certification Schemes will most definitely be noticed and referred to by many other stakeholders and institutions worldwide.

The possible future use of a final QACC for more than just internal WWF and World Bank purposes is underlined by the widely distributed Alliance press release of 30 June 2004 and subsequent press comments, stating that "the activity is expected to yield additional outcomes" and be a basis to provide "technical assistance and support". The PEFC Council also notes that the Alliance is on written record stating that "if the results are favourable [the Alliance] hopes to widen the uptake of this system beyond the Alliance and its immediate partners."

PEFC in its open letter to the Alliance has questioned the QACC and subsequent testing initiative due to the fact that the QACC was developed internally by WWF and the World Bank, with no external multi-stakeholder participation or consultation.

At the same time PEFC Council has repeatedly offered joint consultations to resolve the existing shortcomings and numerous open questions of the QACC. So far over 60 areas of concerns have been identified as laid down in the first PEFC comments. The main areas of concern are:

• The document was developed internally by WWF and the World Bank with no external multi-stakeholder participation or consultation and not following any of the normal processes to ensure openness and transparency,
• The QACC questionnaire is not free from conflict of interest as it has been drafted with a strong bias towards one international certification system which is obvious both in structural elements as well as in the use of specific terms and QACC requirements,
• The document is complex, highly repetitive and not user friendly in its structure and content with overlaps or even with conflicting questions in different parts,
• The document makes a number of references to ISO documents but uses different language, and appears to be reinventing the wheel without added value and conflicts the ISO documents approach and/or requirements.