Good News for the Lumber Industry: Part 4
In an environment in which everyone in the supply chain has become “accountable for legal logging practices; from the lumberjack to the carpenter," it may be difficult to believe that there is really any “good news” for participants in the U.S. lumber industry.
Whether you’re a builder or a lumber dealer, hopefully any anxiety provided by the initial information about the extensive responsibilities brought out in the Lacey Act have given way to greater understanding and relief through our series on this topic. We have begun and continued to consider the provisions of the Lacey Act Compliance Program and how they relate to the already-in-place practices of J. Gibson McIlvain Lumber.
Step 5: Make a determination based on a review of all of the information collected.
While this might seem like a no-brainer, this step is absolutely necessary. Based on the combined findings of the previous four steps, this avenue might mean going with a different supplier or rejecting undocumented materials from a long-time supplier that fails to comply with new local legislation that puts the supplier in conflict with Lacey Act requirements.
Step 6: Maintain records documenting all efforts to ensure legality.
We admit it: This step is a pain. And it’s pretty ironic: lumber companies are required to retain hard-copy documentation, resulting in document storage facilities filled with would-be lumber. All research and supplier communications mean long e-mail trails, as well; the sheer length of the combined paper and digital records required are simply staggering.
Step 7: In the event uncertainty exists regarding satisfaction of the above criteria or the ultimate determination of legal compliance, a company’s policy should be that they should not pursue the purchase.
Like Step 5, this step is difficult but necessary. Believe it or not, here at J. Gibson McIlvain, we reject more lumber deals than we accept. Some species can be purchased from literally hundreds of different mills and land concessions, and we endeavor to ascertain the safest scenario and maintain close relationships with ideal suppliers whose compliance we know to be completely safe.
For everyone along the supply chain, Lacey Act implications can be frightening. After the Gibson Guitar raid and investigation, such fear seems more legitimate than ever. Thankfully, the resulting compliance program required by the DOJ provides some clarification about the expectations of the legislation.
If you’re a customer of J. Gibson McIlvain Lumber, you should be encouraged about the fastidious approach we’ve had in place for years, ensuring that your lumber has been legally harvested from responsibly managed forests. If you’re still in search of greater assurance about what exactly “due diligence” entails, European legislation has recently come to our rescue to that end (see Part 5).