SMART Building Product Committee:

We'll have a SMART Building Product Committee call on Tuesday November 28, 3:00 ET to vote to hold negative votes as nonpersuasive as decided by Committee Officers:  605-772-3001 Code 70369#

These votes were from form letters instigated by the American Forest and Paper Association's Sustainable Forestry Initiative (SFI) due to SMART's specification of FSC Certified Wood as sponsored by 60 environmental groups. 

As sent to you in documents attached to the email below, World Wildlife Fund (WWF) and the World Bank concluded that FSC is the best wood certification system from an on the ground analysis compared to the industry led certifications. 

Two of the voters, the State of Wisconsin and Province of British Columbia, withdrew their negative votes in return for MTS initiating a process to resolve the dispute/brand warfare among the competing certified wood brands.  To be effective, establishing this process is conditioned upon the need for a leading forest product company to withdraw its negative and participate as well in this process. 

We have repeatedly asked these companies and many associations to participate over the years including this year as it relates to the SMART Flooring and Building Products Standards, but heard no response.  Steve Castellanos and I are in discussions with the largest forest products company about withdrawing its negative to participate in a process to resolve the brand disputes and we'll let you know if our discussions are fruitful.

The negative votes are as follows and we recommend the Committee hold them nonpersuasive since they are false:

• FORM LETTERS OF:  American Forest & Paper Association/SFI/Canadian Standards Association/Engineered Wood Association
  
• There was improper notice and due process.  Proper notice and opportunity to participate was provided to affected parties consistent with ANSI Essential Requirements.
• Wood Industry certification schemes should also be recognized.  This is nonpersuasive since no companies wish to help MTS resolve the FSC/SFI/CSA brand warfare over a $trillion North American market which causes market confusion, harms the competitive advantage of the wood industry, and impedes much needed progress on illegal logging and global deforestation.  The market trusts the FSC label the most and FSC has caused all global improvement in sustainable forestry for over 15 years which needs to continue.
  
• FORM LETTERS OF:  American Chemistry Council/Vinyl Institute/American Plastics Council/Wallpaper Association/Molders Association/Chemical Fabrics & Films Association
  
• Cost Prohibitive.  This is false since many companies have already certified, helped develop SMART and its certification and auditing scheme, and voted for it unanimously in four SMART Ballot votes.
• Alternative certification schemes are necessary.  This false since the SMART certification scheme is very rigorous and consistent with ANSI Essential Requirements, and has been unanimously approved in four SMART Ballot votes.
• The Scope of the Standard is unclear and can't cover all building products and materials.  This is false because the scope clearly states it covers all products and materials in the whole building environment, and no bona fide reasons were given why it can't.  All issues in the standard are relevant for any product.
  
• Certifying manufacturers should not publicly disclose the basis of their certification.  This is false since a publicly disclosed summary of the nonproprietary basis of the certification increases the transparency, credibility and validity of the certification and has been unanimously approved in four SMART Ballot votes.
  
• Insufficient weight to LCA.  This is false since the Standard requires LCA and is LCA based, and the LCA scheme has been unanimously approved in four SMART Ballot votes.
• Overly and unnecessarily burdensome.  This is false since manufacturers help develop and approve the standard, are certifying to SMART and California Gold Standards, the minimum certification points are reasonable, and these requirements have been unanimously approved in four SMART Ballot votes.
• Standard doesn't address global climate change.  This is false since the greatest number of points in the Standard are awarded for climate change pollution reductions.
• Georgia Pacific:  Formaldehyde requirements are not clear and transparent.  This is false since the Standard incorporates the State of California's 1350 Formaldehyde Requirements, as also approved in the SMART Flooring Standard Ballot.
  

The negative voters have been contacted to see if they wish to defend their negative votes before the Committee on this call.  Please contact me ASAP if you object to holding these negatives nonpersuasive, and no later than Tuesday November 21.  Please confirm your participation on the call at your earliest convenience.  Thanks!  With best regards,



Mike
202-338-3131