Canadian Wood Packaging Certification Program Client Base Risk Analysis September 6, 2013

CWPCP SURVEY METHODOLOGY Methodology Used Criteria Goal Definition Develop profile of industry by size and type of risk Determine purchasing levels of HT and Non-HT Lumber Provide aid to inspection process Survey Design Closed ended question survey Designed by ISO trained CWPCP Lead Inspector Ensure stringent controls on confidential purchasing data Survey Population Cohort study of 474 CWPCP registered facilities in Canada Data to Be Collected Data on facility size, complexity and staffing levels HT and Non-HT Lumber purchase Jan.- May 2013 Data Collection & Accuracy Qualitative survey verified by ISO trained inspectors during site visits Lumber Logs Analyzed by ISO trained inspectors CWPCP Lead Inspector & Program Co-ordinator scrutinized data reported for accuracy Measurement Instruments Questionnaire /Personal Interview Lumber Log Analysis Data Analysis Aggregated data and analyzed trends Response Rate Questionnaire 98% (464 of 474 registered facilities) Lumber Logs 76% (358 of 474 registered facilities )

Registered Facilities Profile Analysis Facility Demographics 74% of CWPCP registered facilities are small manufacturers with staff of ten employees or less. 125 facilities are crating departments within larger businesses. 101 of these 125 facilities have less than 10 employees in their crating departments. 3% key staff turnover 29 facilities use lumber from a regulated area

Risk Factor: Heat Treatment Analysis of CWPCP Kiln Facilities Only 22 out of 474 registered facilities are engaged in heat treatment. 3 facilities are in the process of adding a kiln to their operations 5 facilities heat treat packaging only 3 facilities heat treat lumber only 14 facilities treat both packaging and lumber The total volume in kiln charges for twelve facilities reporting was 7,824,267 bf which amounts to an average of 652,022 bf per facility.

Risk Factor: Recycling Only 23% or 107 out of 464 registered facilities do WPM repairs Most facilities do not re-certify what they repair, they sort out stamped pallets for international shipment and use other non-stamped and repaired pallets for domestic use. Only 8 facilities report re-certifying repaired WPM. Only 6 facilities use reclaimed HT lumber for repairs

Risk Factor: Segregation of lumber Between Jan.-May 2013 there was 94 M bd ft of HT lumber and 23M bd ft of Non-HT lumber purchased On a 12 month basis this represents 225M bd ft of HT lumber and 55M bd of non-HT lumber purchased with 75 % of registered facilities reporting 28 facilities bought no HT lumber (5 are kilns, 16 bought no lumber during survey period) 81% or 290 of 358 facilities responding indicated they purchased less that 250,000 bd ft of HT lumber over the last five months Registered Facilities Lumber Purchases (Mbf) Time Frame Heat Treated Non-Heat Treated Jan-May (5 month Actual) 94 23 Annual (12 month Estimate) 225 55

Risk Factor: Segregation of lumber 76% or 274 of 358 facilities reporting lumber consumption indicate no non –HT lumber purchases over last five months . The non-HT lumber consumed appears to be 20% of all lumber purchased over the last five months but less than half (42%) of registered facilities report using non HT lumber in their operations. Non-HT lumber is characterized as rough mill run or hardwood as opposed to softwood D4S KD lumber inside the yards of registered facilities

Risk Factor: Performance The blue line in the adjoining graphs represent the clients inherited when CWPCA took over the program. The surge in non-conformances represent the work necessary to convert quality manuals to the current format in order to meet the new requirements of D-01-05. As demonstrated, facilities who have subsequently joined the program have not received a significant amount of non-conformances in general, nor in their first three years of registration.

Survey Results Survey results indicate that the majority of CWPCP’s registered facilities are low risk based on the following: 74% have 10 employees or less Only 21 facilities have heat treatment capabilities Only 23% do repairs, most do not re-certify what they repair Only 6 facilities use reclaimed HT lumber in their repairs Only 42% of facilities use raw (green) lumber in their operations Non-HT lumber represents only 20% of green lumber purchased The low level of risk and low likelihood supports a lower frequency of inspection The data on non-conformances does not support the need for a three year probation period The graphs demonstrate that the majority of non-conformances do not occur within the first three years of certification Compliance has improved significantly over time 81% of facilities registered in the last four years have yet to receive a non-conformance