LCA, a must

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.

http://media.leidenuniv.nl/legacy/new-dutch-lca-guide-part-1.pdf

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.