Good News for the Lumber Industry: Part 3
As we continue to consider the 7 steps of the “The Gibson Guitar Lacey Act Compliance Program,” here at J. Gibson McIlvain Lumber, we appreciate the opportunity to evaluate our own company policies. The good news, for our customers, is that we were already taking steps toward Lacey Act compliance — far before the century-old Lacey Act was amended in 2008 to apply to the lumber industry.
Of course, this information has value beyond individual companies like Gibson Guitars and J. Gibson McIlvain Lumber — since according to Lacey Act requirements, responsibility for “due diligence” extends to holding “everyone in the supply chain accountable for legal logging practices; from the lumberjack to the carpenter."
Step 3: Do not rely solely on the checklist to identify risky sources, but conduct independent research and exercise care before making a purchase. This may include internet research, consultation with U.S. or foreign based experts or authorities, arranging an on-site supplier/forest visit, if possible, or speaking with local authorities and/or experts on documentation required for legal export and the validity of such documentation received from the supplier.
We have traditionally utilized the thorough investigation of independent agents on the ground in the countries from which we source our lumber. These individuals provide expert insight into local laws and intimate insight regarding the practices and processes of each local saw mill.
In addition, J. Gibson McIlvain has employees visit each sawmill on an annual basis, in order to evaluate those practices on a first-hand basis. We also visit new suppliers in person before making an original purchase. After more than two centuries in the business, we can confidently supplement that research with input from outside sources.
Step 4: Request sample documentation prior to wood purchase to reasonably ensure that all forms provide sufficient information to comply with the Lacey Act requirement and to assist in verifying the validity of the documentation as described in step 3.
Here at J. Gibson McIlvain, we’re known to be sticklers about making sure that none of our lumber orders are shipped before we have the related documentation in our hands. If we don’t have the correct export/import documents, we will not claim the lumber at the port. Since the longer it sits at the port, the higher the storage fees we incur from the port, thus we do all we can to eliminate such unnecessary fees.
We also use several forms of certification and origination schemes. While FSC certification goes about halfway, we rely on the sometimes even more accurate and thorough certification and verification systems in place by many foreign mills.
Hopefully, you’re seeing how the 7 steps in the Gibson compliance program can be helpful in evaluating — or instituting — a similar program at any other company dealing with imported lumber protected by the Lacey Act. In Part 4, we’ll look at the final 3 provisions.