Life Cycle Thinking Blog Moves

Life Cycle Thinking blog is moving.

I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.

Georjean Adams

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“Product Stewardship” – ECOS

ECOS – Environmental Council of the States (an organization of state environmental agency leaders) adopted a definition of “product stewardship” as:

“…the act of minimizing health, safety, environmental, and social impacts, and maximizing economic benefits of a product and its packaging throughout all lifecycle stages. The producer of the product has the greatest ability to minimize adverse impacts, but other stakeholders, such as suppliers, retailers, and consumers, also play a role. Stewardship can be either voluntary or required by law”

This in conjunction with their real interest of Extended Producer Responsibility (EPR – aka you-made-it-you-eat-it):

“…a mandatory type of product stewardship that includes, at a minimum, the requirement that the producer’s responsibility for its product extends to post-consumer management of that product and its packaging. There are two related features of EPR policy: (1) shifting financial and management responsibility, with government oversight, upstream to the producer and away from the public sector; and (2) providing incentives to producers to incorporate environmental considerations in the design of their products and packaging”

ECOS almost got product responsibility right.  Except that it isn’t “an act,”  it’s acting on an ongoing basis using life cycle thinking.  It isn’t something that other stakeholders “play a role” in – it’s a shared responsibility of everyone involved with a product – everyone who can affect the life cycle (including the public sector).  At least they acknowledged that there are benefits associated with products – but they aren’t only economic benefits, unless they mean to cover quality of life and the pursuit of happiness under the term.  Mandatory product stewardship is also a nonstarter for me.  Product stewardship is an ethic.  While society can set regulations and punish violators, “mandating” how one should think doesn’t work.

EPR – another blog for another day.  EPR may or may not make sense as a tool of product stewardship in limited cases, but thank you, ECOS, it is not the same as.  I’m not convinced that “incenting” product stewardship this way is desirable or effective.  See an interesting report on EPR here showing it may not be such a cost-effective solution after all.  Mostly, I have issues with the fantasy that the consumer doesn’t pay for EPR take-back programs (customers pay for everything a company does) and that government knows what its doing in setting up false markets. Previous moaning here.

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Product Stewardship & Chemicals Management

Nice blog by Michael Kirschner summarizes steps to take to deal with all the challenges  that are threatening products containing chemicals “of concern.”  He advises manufacturers to take the following steps:

1. Collect full material disclosure from your suppliers. Simple declarations and certificates are useless. If your suppliers insist on continuing to provide this level of information in light of the changing marketplace, make sure you understand why they’re doing it and whether you can move to a different supplier that will give you what you need.
2. From this information, produce a list of the chemicals that are used in your product.
3. Prioritize the chemicals in terms of toxicity, potential for exposure, amount, and potential for future regulation.
4. Understand why those chemicals are used.
5. Understand what it would take to replace these chemicals in your product.
6. Assess any marketing or competitive value this could have for your company.
7. Make a plan for what to replace, how, and why. [I would argue you should also consider whether it is worth it to try to defend the use of the chemical.  He seems to be in the "just bail" club.]
8. Get it funded and move ahead.

Knowing what is in your products, designing them to be safe  in the first place and continuous management are core to product stewardship.  Challenges abound in setting up ongoing supply chain communication systems, confidentiality,  information awareness and management systems and the ever-changing set of societal expectations that throw your priorities out of whack.  

     You need explicit and fairly sophisticated systems (including people) to keep up with it all unless you just sell one or two simple component products. Will the exponential growth in public chemophobia and complicated regulatory schemes (e.g., REACH) result in product manufacture being done by only the really big companies that have the resources to cope?  The best a little guy can do is try to find or hook up with big guys in his supply chain and hope they will help him.

EHS Strategies, Inc. can help you get your product stewardship program in shape.

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Product Stewardship: Design with LC Thinking

Interesting presentation by Bresseler company in how they do quick versions of life cycle analysis in an iterative process in doing product design:  http://www.bresslergroup.com/webinar/cut-the-crap/video.php

I don’t know the company, but I like their way of thinking.

This is not unlike the product stewardship processes I’ve long supported.  See my paper on

Product Development with Life Cycle Thinking

While you are designing processes to serve customer needs, keep you eyes wide for more sustainable solutions and keep checking as you go, including after the product is out there and new information and technologies point toward even better solutions.

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LCA and Sustainability

I agree with the article by Mark McElroy “Do LCAs Measure Up To Sustainability?”  He says they do not, because they are too narrowly focused on eco-efficiency only and ignore context.

As I’ve blogged before, sustainability should be about how we do what we do and not a collation of LCA’s.  At best LCA’s help inform decisions as we try to understand the dynamic systems of which products and users are a part.  I use the phrase “life cycle thinking” to describe how we need to recognize the potential intended and unintended consequences of our actions.  Understanding contexts and consequences.

There is no such a thing as a “sustainable product” (see comments into EPA on their proposed efforts here).  We each bear responsibilities as product stewards in how we manage a product throughout its life cycle – whatever our role might be.

McElroy also hits the mark that LCA’s and too many “sustainability” efforts focus only on environmental issues .  Probably because they are  easier to measure than social and economic impacts.

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Current Events and Articles

Current and recent events and articles:

January 22, 2013  Once again I’m teaching “Regulations and Corporate Environmental Management” at the University of Minnesota Spring Smester (ESPM 3602/5602 MGMT 3602).  My goal is to expose students to the power and frustration of public rulemaking in the environmental arena and how corporations cope.

January 18, 2013, article in MA Insider: “Greening Your Supply Chain.”

November 15 and 17, 2011 Dept of Commerce, US Commercial Service webinar “EU REACH – What You Should be Doing.”   I spoke on the 17th on “Protecting Your Supply Chain.”

August 18, 2011 Spoke on “Greening Your Supply Chain” for the Environmental Initiative’s Business & Environment Session.  Slides here.

August 17 and June 15, 2011 Minnesota Trade Office Updates of EU WEEE and RoHS Recasts and REACH Regulation  I focus on REACH article requirements.

March 21, 2011 PDMA (Product Development and Management Association) talk on “Opportunities and Challenges: Making it ‘GREEN‘”

March 29, 2011 Filter Manufacturers Council presentation in Chicago on chemical regulatory and customer pressures.

April 14, 2011 TSCA Overview for the Minnesota chapter of Certified Hazardous Materials Managers training class.

I spoke at the I spoke at the Minnesota Green Chemistry Forum’s “Adding Value Through Green Chemistry” conference January 7, 2011, on the topic of environmental marketing claims opportunities and challenges for companies.

Past Events and Articles

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EPA DfE Alternatives Assessment Methodology

EPA has just posted its draft Alternatives Assessment Methodology on how it will compare the hazards of alternate chemicals in deciding whether or not to designate a product as “Designed for the Environment.”    DfE is geared to identifying alternatives that work and are available and are greener than the current chemicals that are being used.  The methodology guide offers how to classify hazards as very high-high-moderate-low and has many useful resources for those of you trying to decide which alternatives are “safer.”  EPA will be using alternatives analysis when looking at safer alternatives for the Chemical Action Plan priority chemicals.

The related GCI-NSF proposed standard “Greener Chemical and Process Information” identifies the same kinds of hazard elements, in addition to other process-related information, that a customer would use to compare alternate sources for the more “green” or safer product.  See blog

Product stewards can use this as a tool when designing or redesigning their own products.  I’m less concerned at where EPA is drawing the lines between very high-high-moderate-low as the importance of comparing alternatives and going with those that work the best for your business and have the best safety profile.

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Greener Chemicals and Processes Standard Proposal

I’m on the joint committee that developed the following proposed standard on “greener” chemicals and processes.  Our intent is to have a standard that can be used by customers of chemical manufacturers to decide who has the “greener” chemical and process.  This is an information standard and does not weight any of the metrics per se, so no total “green score.”  That would be left up to customers. Your comments would be greatly appreciated!

The American Chemical Society, Green Chemistry Institute and NSF International would like to announce the ANSI public comment period has opened for the Greener Chemicals and Processes Information Standard, NSF/GCI 355.  You may view the draft and submit your comments via the link below:

http://standards.nsf.org/apps/group_public/document.php?document_id=9409>http://standards.nsf.org/apps/group_public/document.php?document_id=9409
(Please only comment on the most recent version of the draft)

Consider the standard both as a chemical manufacturer who would claim conformance and as a customer who would look at the information on raw materials. (We started with the chemical transformation life cycle stage and hope to extend the concept to upstream extraction and downstream formulation and fabrication later.)  We ask that you provide feedback specifically on the following items:

1. Chemical Characteristics, section 5 – which are unlikely to have data for most chemicals?
2. Process Mass Efficiency (PME) calculation – ease of use
3. Energy derivation and calculation
4. Inclusion of bio-based input
5. Inclusion or exclusion of Social Responsibility section 7
6. Additional guidance you would like to see provided – calculations, examples, reporting format, algorithms for scoring, etc.
7. Would you use it? If not, why?

The public comment period closes November 16, 2010.

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10 Principles of Responsible Product Stewarship

See my article in GreenBiz.com: http://bit.ly/agKUDI

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California Safer Alternatives Draft Regulation

California released its draft regulation to implement the Green Chemicals Initiative June 23, 2010. Find it here: http://bit.ly/9BV64N

It’s stunning in its reach (makes EU’s REACH look like a walk in the park).  Pretty much everything is a “consumer product” despite the name of “Safer Consumer Product Alternatives” – if someone uses it in California it’s covered (Except: drugs, pesticides, food and dental restorative.  Must be a dentist in the state legislature).  And the chemicals that are to be “Under Consideration” (CUC) could potentially include anything and everything that could go to California that has any toxicity – including releasing non-ionizing radiation (like cell phones and microwaves).

But the initial focus will be on Prop 65 carcinogens and reproductive toxins that are persistent and bioaccumulate present in products at >0.1%.  These will become “Chemicals of Concern” – COC.  The products containing them will be “Priority Products.”  Given the hurdles to conduct life cycle assessments by 2 different certified Alternate Assessment professionals (one has to be an accredited 3rd party) and the unlimited information that can be demanded by DTSC, followed by restrictions in use and mandatory take-back programs for old products – companies should find something else now before the rule goes into effect or quit selling in California.

There is a long set of criteria to conduct prioritization of chemicals and products but, regardless,  DTSC is going to be overwhelmed. California is beyond broke and not likely to have the staff to process all this stuff,. So the lists may be a shorter to start with.  On the other hand, when has an agency not demanded a lot of reporting from companies and just let it pile up?  All they have to do is post the lists on their website and scan in the info being sent by companies and stand back and let the blacklisting do its thing.

I support the emphasis on life cycle thinking and looking at the potential impacts of the safer alternatives vs the not-so-safe products.  And they do acknowledge technical and market feasibility.  But it is the scale of effort that is mind-boggling.

You almost wonder if it would be easier for California to issue the short list of what can be used to make products for California.  Not sure what that might be though.  Certainly not water, given the drought conditions of the state and you need water to grow all those bio-based chemicals, so not sure they are possible either.  It’s not clear from the rule is the life cycle impacts include resource use and emissions that occur outside the state – but as California is championing GHG reduction, surely they are concerned with global impacts.

Saddest piece was this definition: “Make available for use in California” means that a person sells, offers for sale, distributes, leases, offers to lease, supplies, or otherwise transfers control over the disposition of a consumer product directly to a California consumer; or to another person without maintaining sufficient control over the distribution, sale, lease, supply, or other transfer of the consumer product by that person to prevent the use of the consumer product by a California consumer.” No more Christmas presents to my brother and sister, just to be safe.

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