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Posts Tagged ‘Product Stewardship’

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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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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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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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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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 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 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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