A couple weeks ago, our friends at Greener World Media announced that a draft of the sustainability standard they developed in partnership with Underwriters Laboratories was available for review. Here’s my take on the most exciting components of the draft as well as some areas for improvement for future drafts.
First off, we were pleased that the draft was available for comment at all. In a world where the term Cradle to Cradle is trademarked by William McDonough’s firm it’s refreshing to see a more open approach to design of standards. That said, the process for viewing the standard and providing comments is a bit restrictive for my taste. One must register for a login and password to UL’s site with first and last name, company, title and e-mail. 24-48 hours later, UL sends a new login and password to their site. Potential commenters must login in order to view the standard and comments are only accepted via their special site. That’s a lot of hoops for potential commenters to jump through. You either have to be tremendously motivated (like me, or like a company who will be potentially affected by the standard), or have a heck of a lot of time on your hands to weigh in. GWM and UL are missing a large body of commenters with this approach: tremendously busy nonpartisan members of the sustainability community who aren’t very invested in whether this one standard is a good one or not. GWM and UL need those folks to make sure this standard is as rigorous and foolproof as it can be, but I worry that this official approach to commenting might turn off those individuals who can provide the most valuable feedback. That said, I made it through, and overall, I was pleasantly pleased and impressed with the draft.
The draft is an intimidating 66 pages long. Despite its length, it’s an easy read, the sections are well labeled and organized, and the writing is clear and straightforward. The overall idea is that this will be a rigorous standard for large manufacturing companies, that it will be tough but not impossible to achieve, and that it will encourage improvement over time. The standard doesn’t say outright why large manufacturing companies are the initial focus, but my guess is that these companies are in a sweet spot of relatively high environmental impact, relatively low environmental regulation (unlike energy and utility companies which are facing ever more stringent restrictions at the government level to curb their emissions), good data availability, and companies with the financial ability and incentive to pursue a voluntary certification.
The standard uses a point system, like LEED, to allow companies some flexibility in compliance, while ensuring an overall high level of attention to sustainability. The five components of sustainability are each weighted for importance via the point system– that is to say that the sections with lower weights have fewer possible points available. The five sections are: Governance for Sustainability (20%), Environment (40%), Workforce (10%), Customers and Suppliers (20%), Social and Community Engagement (10%). In drafting the standard an alphabet soup of other standards were consulted from GRI to ISO, US EPA, the UN, and a dozen others. It’s a solid mix.
Overall, I found the standard to be clear, rigorous and comprehensive.
The Strongest Elements
The attention to product design and packaging is appropriately comprehensive with points allocated for: evidence of design for the environment in product manufacturing, packaging design, design for disposal or reuse, and points allocated for an LCA based approach to packaging systems and materials. That’s pretty comprehensive.
Similarly, there are extensive point opportunities related to supply chain management and monitoring.
Waste reduction points are based on a stringent 50% of 2005 baseline.
Points go up for increasingly agressive GHG targets
Transparency (10 points) and Intent to Improve (13 points) have very high point values compared to the rest of the document, incentivizing companies to comply.
Room for Improvement?
GHG targets can be met entirely with RECs and carbon offsets, which is somewhat problematic since the market for RECs and offsets is unregulated. ULE 880 deals with this somewhat by requiring companies to purchase only those products that have been certified by the more rigorous certifiers, but the standard should incentivize companies to do at least some internal reductions in addition to buying credits.
There is a section dedicated to transportation of goods, however there are only 3 indicators for transportation (strategies and targets, distance optimization, and transportation management measurement). For a sector like manufacturing, transportation of goods is the largest source of carbon emissions, and that should be reflected in the standard with a few more point opportunities.
I dug through the standards looking for some mention of human rights related to supply chain issues, but I couldn’t find one. In fact the human rights section (7.3) is only about 1/3 of a page and includes only a brief mention of child labor (2 points for avoiding), and implementing a policy on avoiding forced labor (another 2 points). Given that human rights are a major issue for big manufacturers, the standard would be more robust if this were flushed out a bit more.
The Most Innovative
There were a few nuggets of innovation in the standard, items that were really exciting in the forward thinking approach to sustainable business they represent:
- 1 point for maintaining employee turnover of 10% per year or less
- Applicants get up to 2 points for linking executive level compensation to sustainability performance.
- point opportunities for flexible work schedules and support for childcare and eldercare.
All in all, there is a lot to be excited about here, and a great first draft.
Have you had a chance to read it? What are your thoughts?
A comment from Joel Makower:
Thanks for the extensive, thoughtful review on ULE 880. Just thought I’d point out that human rights appears in several places outside of Section 7.3, including related to supply chains.
For example, in 18.104.22.168, a company can earn 3 points for “showing evidence that a risk assessment has been conducted regarding human rights risk situations as described in ISO 26000/DIS, 6.3.4, Human Rights Issues, 22.214.171.124.” (This is one of many places that we leverage existing global standards and guidelines rather than reinventing the wheel.) It includes “Human rights policy for domestic and global operations, including linking to supply chain.”