Life
Cycle Assessment, a must
Life Cycle Assessment (LCA) has been
around for ages or at least for a couple of decades. An ISO standard for LCA (ISO
14040) has been established and our (Dutch) government has funded extensive
research in the matter, resulting in guidance documents such as this one.
The site of the RIVM (http://www.rivm.nl/Onderwerpen/Onderwerpen/L/Life_Cycle_Assessment_LCA ) provides loads of information on LCA and available LCA
software. And still there are companies which do not use the tool. How can
government increase the use of this tool through external control and setting
boundary conditions?
Government? This may be a good
moment to remind the reader of the coordination mechanisms defined by Frank
Boons in Self-organization and sustainability: The emergence of
a regional industrial ecology (2008). Boons defines 4
categories;
1. actors can self-organize through
interaction (self-organization without
governmental involvement);
2. actors can self-organize and develop
monitoring and sanctioning rules (self-organization leading to self-governance);
3. actors can self-organize under
pressure of governmental legislation (self-organization with government
providing selection pressure), termed private interest
government
4.
actors organize under control of governmental initiative (absence of
self-organization); termed government
Assuming
that although some self-organization has taken place, the result in terms of
LCA is not satisfactory, what governmental initiatives could make it work?
In
this blog I will compare four governmental initiatives to increase the use of
LCA, both in ”pure” government (4) and in private interest government (3), as
defined by Boons.
Legislation
Government
in its purest form is legislation plus enforcement. An example of this is the chemical
safety assessment (CSA) in the EU REACH Regulation. The REACH Regulation (http://echa.europa.eu/web/guest/regulations/reach/legislation)
requires companies manufacturing or importing more than 10 tons annually of a
chemical substance to make exposure scenarios for these chemicals. These have
to be calculated from the chemical properties of the substances using paradigms
prescribed by the European Union. The result of this safety assessment
determines whether or not the company is allowed to manufacture/produce (this
quantity of) the substance.
The
Regulation is applicable in the whole of the European Union and it applies to
all companies that place chemicals in the EU market, so if you want to sell
chemicals in the EU, there is no escaping from REACH by producing outside the
EU. If the substance is produced outside the EU, still the importer will have
to do the CSA. In addition to that many other countries have developed
legislation similar to REACH but under different names. This means that
companies are actually making the CSA. The EU has specified the software in
which the information required is to be supplied to the European Chemicals
Agency, which means that it is all in a uniform format, allowing the EU to
aggregate the information in the future. Following the same method for the LCA
would definitely increase the number of LCA being made, but there would be some
disadvantages as well.
·
Making legislation for the European
Union is a very time consuming process. If similar legislation were to be made
for LCA it will take years before the Regulation is made and more years before
it is working and enforced.
·
Setting up the infrastructure is a
costly business, not only for the EU but also for the companies.
·
The national competent authorities
will have to enforce the Regulation
Alternatively
legislation could be by national law, but especially in smaller countries the
cost of compliance could be higher for a company than the benefit of selling in
the country. In addition to that, with the open borders that exist within the
EU a merely national LCA obligation would be very difficult to enforce.
Environmental permit conditions
In
The Netherlands the competent authorities for the environmental permits may be
the municipalities or the provinces. When a company applies for an
environmental permit the competent authority is entitled to setting permit
conditions. The competent authorities may tune these conditions with the
environmental level of the company, e.g. for companies which have an ISO 14001
environmental management system and which produce an environmental annual
report special conditions may apply. A similar policy could be adopted with
respect to LCA, Making LCAs would still cost the companies time and money, but
now it would also bring an advantage with respect to permit conditions. [we are
assuming that the intrinsic advantages of LCA have not been sufficient to
convince the companies to make use of LCA] An example of such an advantage is
the possibility to define improvements in terms of the complete life cycle
instead of specific aspects of it, e.g. accepting increased energy consumption
in the production stage if this results in reduced energy consumption in the
complete life cycle. If a competent authority were to make such a policy it
would take less time to obtain the first results, as the legal basis is already
there (in that the competent authority is authorized to set conditions), and
enforcement takes place by the same competent authority that issues the permit.
This policy could result in a win-win situation between competent authority and
company. Of course there would be disadvantages as well.
·
Although there is no possibility for
companies to choose their competent authorities shopping around will be less
difficult than in the legislation option above. It is easier to decide what to
produce where if you have more than one production unit, as the competent
authorities have a much smaller jurisdiction.
·
If a competent authority decides on
this policy on its own the effect is limited. For a considerable effect it is
necessary to combine efforts between provinces and municipalities. In that case
coordination, at least on a national level, would be required.
·
The environmental permit system is
for production units. Many of the products we use are produced elsewhere in the
world and imported here. These would remain outside the system.
Have LCA developed by industry
The
third option is a classic case of private
interest government; make covenants with the sectors of
industry to produce their own LCA standards, in the same way that Nedvang is
organizing the Plastic Heroes campaign in the Netherlands on behalf of the industry.
For most industries the national level will be too small-scale, European scale
would be the minimum, as the industry sectors have grown beyond the national
boundaries. Even the EU is not big enough for some industries, but it seems to
me that the EU is the biggest entity that is able to achieve something. [This
may sound negative, but I believe we should not rely on the United Nations for
environmental matters as some of the biggest countries have not ratified the
Kyoto Protocol yet.] The LCA need not be established for all sectors of
industry at once, but priority sectors may be defined. The companies can bundle
knowledge about their products and production in making LCAs that fit their
industry sector, which would save the government time and money. For the
industry sector it means they will (probably) have more freedom in giving shape
to the LCA. Especially if a sector of industry is already organized it may
prefer this system to having the national government or the EU set the
conditions for them. Of course this system has its disadvantages, or rather
uncertainties, as well;
·
The sector of industry may have more
influence on the format of the LCA than is desirable
·
Having the industry take the
initiative may increase their involvement, but who is going to enforce
compliance? Will the competent authorities have enough knowledge/involvement to
do that?
·
Will the sector of industry set
targets for itself that are challenging? And will it review the targets once
they are met? I believe it will still take government involvement to keep the
industry ‘sharp’.
Increase company awareness and consumer awareness
This
is the ‘softest’ approach of the four discussed here. In this approach the
government actively promotes LCA, creates information systems such as the
information on the RIVM website, develops LCA tools that are easy to use and
free, organizes courses and seminars etcetera and hopes for the best, much as
the Dutch government has been doing for years to discourage drinking and
driving. Would this be sufficient for the industries to self-organize and start
working with LCA? Even in times of plenty I doubt if it will have the desired
effect. [I am thinking of the government ideals to increase the number of women
in Boards of Directors of companies, which have had little effect.] I am afraid
that although in general LCA is considered a good idea it just will not happen
In practice. In the difficult times that
companies are experiencing today the focus is on cost and manpower reduction,
so for LCA to be introduced in a company it must create a return on investment
in terms of time and/or money.
Increasing
consumer awareness might work in the long run, but only for consumer products
and it would need to be combined with information on the product labels, which
I expect will only work if defined by government; else companies may define
their own labels, as they have done for health and sustainability claims which
has resulted in a great many different labels which most customers do not
understand (but which may look sustainable or healthy and thus boost sales).
What would work best?
Looking
at the examples, they are different in scale and flexibility. The ones on a
bigger scale will have a bigger range of effect, so to speak, but they may also
take much longer to achieve. The softer approach may take less time to
establish, but the effect may be limited.
What would make a company use LCA?
I
believe that there are two ways to make companies use LCC; one is to leave them
no other option and the other is to make it worth the while for them.
Legislation, therefore, will work anytime, although it depends on enforcement
and it will take time. If the legislation takes place at a European level it
does not interfere too much with the level playing field. Legislation at a
national or lower level may be hard to achieve because companies will claim
reduced competitiveness.
Legislation
could also work for products instead of production, which is a big advantage in
a time when many products are shipped around the globe.
In
making the legislation it would be wise to consult stakeholders in the relevant
industries, so they can have their say and make it workable.
What
if you are a municipality or province? Then your jurisdiction is too small for
legislation to be a useful tool, but you may still push a little by means of
the permits and I believe that increasing awareness might help – a little.
One
thing which governments of any size may do which will definitely increase the
use of LCA and which can be added to any of the above is decide for themselves
to use LCA as a tool in purchasing products and services. In that way the
companies who wish to supply these will be given an example of the tool and
they will realize that it makes a difference in their sales potential.
