2516.01_Attachment 7-3

May 18, 2015
Document Control Office
Mail Code 7407M
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE: Docket Identification Number EPA-HQ-OPPT-2014-0838. Agency Information
Collection Activities; Proposed Collection and Comment Request; Assessment of
Environmental Performance Standards and Ecolabels for Federal Procurement. 80
Federal Register 14372, March 19, 2015
Dear Sir/Madam:
The Sustainable Forestry Initiative® Inc. (SFI) is writing in regards to EPA’s planned
testing of draft guidelines for federal procurement of environmental standards and
ecolabels, and specifically the request for volunteer standards development
organizations to be assessed per the draft guidelines. SFI® Inc. would appreciate the
opportunity for our standards to be assessed against the guidelines.
SFI Inc. is an independent, nonprofit organization that is solely responsible for
maintaining, overseeing and improving the internationally recognized SFI program.
Across the United States and Canada, over 250 million acres are certified to the SFI
Forest Management Standard. In addition, the SFI program's unique fiber sourcing
requirements promote responsible forest management on all suppliers' lands. SFI
chain-of-custody (COC) certification tracks the percentage of fiber from certified
forests, certified sourcing, and post-consumer recycled content. SFI on-product labels
identify both certified sourcing and COC claims to help consumers make responsible
purchasing decisions. SFI Inc. is governed by an independent three-chamber board of
directors representing environmental, social and economic sectors equally.
SFI released its 2015-2019 Standards and Rules at the start of January, further
enhancing the vital link that exists between healthy forests, responsible purchasing,
and sustainable communities. The SFI Standards are revised and updated every five
years to incorporate the latest scientific information and to respond to emerging
issues. As part of this process, comments were received during two 60-day public
comment periods in 2013 and 2014, and input was received from 12 public workshops
across the United States and Canada. About 10,000 stakeholders were invited to
submit comments. Stakeholders included public and private landowners, forest sector
representatives, indigenous communities, conservation groups, industry, academia
and government officials.

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Independent oversight of this entire process was provided at each stage of the revision process by the SFI External
Review Panel, a distinguished group of independent experts representing conservation, professional, academic and
public organizations, operating at arm’s length from SFI. In addition to this oversight the SFI External Review Panel
reviewed every public comment submitted during the public comment periods to guarantee the Standard revision
process was transparent, objective and credible.
The SFI Forest Management Standard requires third-party independent certification audits by competent and
accredited certification bodies. Certification bodies conducting audits to the SFI Forest Management Standard must
be accredited by a member of the International Accreditation Forum; either the ANSI-ASQ National Accreditation
Board (ANAB) or the Standards Council of Canada (SCC). To ensure conformance and continual improvement,
organizations certified to the SFI Forest Management Standard are subject to a 3 year audit cycle with third-party
annual audits to verify the conformance of their forest management practices and processes. In keeping with
globally established practice certification bodies conducting audits to the SFI Forest Management Standard are
guided by the ISO 17021-2011 Standard, which is a normative requirement of the SFI Forest Management Standard.
Given that the focus of the SFI standards are on forest management, responsible sourcing of forest fiber, and
tracking of forest fiber, SFI standards are applicable to both the Furniture product category and the Building
Flooring category that are part of the pilot testing.
We look forward to the opportunity to participate in the pilot project assessment. I can be reached by phone at 202596-3456 and by email at [email protected].
Regards,

Nadine Block
VP, Government Affairs, and COO