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PAQ 808 Environmental Management and Sustainability

Sue Haile 2006

Sustainable Development
What is it? (an approach) - it is the route we take to reach sustainability (a goal) What do we mean by sustainability? Social progress recognising the needs of everyone Effective protection of the environment Prudent use of natural resources Maintenance of high and stable levels of employment and economic growth

Definitions are endless but the most commonly quoted one is from the Bruntland (a former Norwegian Prime Minister) Report. development that meets the needs of the present without compromising the ability and future generations to meet their own needs.

Others include:a dynamic process which enables all people to realise their potential and to improve their quality of life in ways which simultaneously protect and enhance the earths life support systems Not cheating on our children

http://www.sustainable-development.gov.uk/ A better quality of life for everyone, now and for generations to come. Why do we need sustainable development? To minimise our ecological footprint. This is the area of productive land and water a person needs for the resources they consume. It will depend upon your standard of living. Country Hectares USA 12 Brazil 4 India 1 The world wide average is 2.85 to be in balance we must have enough hectares in the world to support the population.

We over ran the available supply in about 1975 and we now need 30% more resources than the world can offer. In other words we are living off our capital not our interest. Discussion of Sustainable development really began with the first earth summit in Rio 1992. UK Guiding Principles and Approaches The Governments policies will also take account of ten principles and approaches which reflect key sustainable development themes. Some are established legal principles. Others might better be described as approaches to decision making. Putting people at the centre Taking a long term perspective Taking account of costs and benefits Creating an open and supportive economic system Combating poverty and social exclusion Respecting environmental limits The precautionary principle Using scientific knowledge Transparency, information participation and access to justice Making the polluter pay

The problem is that all of this assume a very long term systems based approach and as we all know a week is a long time in politics and most companies operate on maximum paybacks of 18 months! We need to go for long term system based thinking not short term quick fix. As an example consider the catalytic converter. Made of platinum it doesnt work effectively for the first 4 miles (most journeys are less than this), it generates hazardous dust and is very energy intensive to produce, producing 350,000 kg of waste for 1 kg of platinum. The mining also exploits people in Siberia and S Africa world.

Why is the environment and sustainability an issue?


LEGISLATION

Cost of consents ( water authority, EA) and authorisations (EA, LA) Cost of fines and prosecutions how rising! Impending legislation (be proactive 500 EU directives concern the environment)

ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS Not yet compulsory although required for IPPC Driven by supply chain and stakeholder pressure

COSTS

Energy (including CCL) Water Raw materials Transport Effluent disposal (plus you paid for the water in the first place) Insurance, (EIL) Investment (typical payback one year) Solid waste, (loss of product therefore embodied energy, as well as disposal costs and landfill tax)

PRODUCT

Raw Materials (sustainability, risk, health and safety) Processing material/energy intensity Reuse and ability to Recycle Market competition, edge and vulnerability

PUBLIC RELATIONS

Supply chain pressure, (esp from EMS registered companies) Customers Employees

Neighbours Shareholders Bad Press /Adverse Publicity (takes a very long time to recover)

In the UK 95% of companies are categorised as SMEs. Small and medium sized enterprises count for 99% of all businesses in the EU and the term 'SME' consequently covers a wide range of business types, from the self-employed through to multinational public limited companies with up to 250 employees. Small and medium-sized enterprises, hereinafter referred to as 'SMEs', are defined as enterprises which: - have fewer than 250 employees, and - have either:an annual turnover not exceeding ECU 40 million, or an annual balance-sheet total not exceeding ECU 27 million It is estimated that they contribute 70% of the environmental pollution but are always the most difficult to target for improvement as they are too busy sinking to swim. They often work on a pay back of 6 months and have no one dedicated or trained in environmental issues. About 40% of the UK workforce works for an SME. Global Environmental problems are discussed at http://lorien.ncl.ac.uk/ming/polmon/s1-polmon1.pdf )

How does industry effect the environment ?


Through what it makes Through how it operates Through what it uses Through what it discharges

Where are the controls and what are they?


Legislative Fiscal/taxes Economic costs Voluntary

Environmental issues and controls


Solid Waste Materials
Green Purchasing policies Environmental Protection Act 90 Cost Landfill Tax

Energy
Cost Climate Change Levy

Organisation EMS, Environmental / Sustainability Reporting

Air Emissions
Environmental Protection Act 90 Clean Air Act 93 Cost
IPC 90 IP PPC99 C IPP CP

Water
Cost Legislative Cost Fiscal Voluntary Voluntary/legislative

Liquid Effluent Product or Service


Producer Responsibility Product Stewardship Life Cycle Assessment Eco-design Water Industries Act91 Water Resources Act91 Cost

Drivers for sustainability


You would think that the best way to control the environmental impacts of a company or the product it makes or service it provides would be directly. However traditionally the only direct legislative controls (known as End of Pipe), have been on outputs and more latterly some inputs which are now subject to fiscal measures. Up until relatively recently virtually the only controls that existed concerning industrial activities related to legislative controls on emissions to air water and land and hence were based on compliance with environmental objectives. Financial constraints of course impacted on the business often in a way that hindered environmental improvement. Where opportunities for improvement were identified through perhaps purchase of capital equipment this was often turned down due to the very fast pay back times so many companies demand, (typically 6 months- one year). Societal interests were low priotiry until the company was forced to react the bad PR following an incident. The first indications that this view was changing came when the Chemical Industry set up the Responsible Care programme in 1989. The aim of Responsible Care is to earn public trust and confidence through a high level of HS&E performance in order to maintain the industry's licence to continue to operate safely, profitably and with due care for the interests of future generations. http://www.cia.org.uk/industry/care.htm

Legislative requirements
The emissions from a company in terms of potential pollutants have long been subject to environmental regulation/legislation which is being tightened up on all the time. The guiding principles for environmental regulation are:Polluter pays Pollution prevention pays Precautionary principle Most Environmental legislation now starts life as an EU Directive- there are over 500! This is a requirement (although not a direct) piece of legislation that comes from the EC where they EC decide what the member states must do and the date they need to do it by and the member states have to put in place measures, (laws or fiscal measures) to ensure the Directive is complied with. Examples are IPPC, WEEE, End of Life Vehicles etc. Examples of EU Regulations are the Eco- labelling Regulations 1992 Eco Management Audit Scheme 1993 both voluntary. In the UK most Directives are implemented by Acts see :http://europa.eu.int/comm/environment/law/4th_en.pdf The primary source of UK law is an Act of Parliament , this is brought about once it has been debated as a Bill in the House of Parliament. The legislation that is introduced to achieve the aims of the Act brought may be part of the Act itself or be in the form of a Regulation called a Statutory Instrument, (SI). SIs are usually introduced by the Secretary of State for the Environment or Department of the Environment, Food and Rural Affairs, (DEFRA) . Generally these are introduced after consultation with relevant bodies, e.g. Environment Agency(EA), Trade Organisations, NGOs. So a piece of legislation can be introduced under an Act some time after the Act itself came in to being. Details of environmental legislation may be accessed from http://cedrec.ncl.ac.uk Regulators The main regulatory authority in England and Wales is the Environment Agency, (EA) (made up of the former National Rivers Authority, (NRA), Her Majestys Inspectorate of Pollution (HMIP) and local authority waste regulators). They formed the EA through the Environment Act 1995 and regulate under IPC and IPPC processes. They have as many , (if not more!) powers than the police and can visit a site at any time without warning. In Scotland they are the Scottish Environment Protection Agency, (SEPA). Local Authorities, (LA) are responsible for Local Air Quality control. Discharges to controlled waters are regulated by the EA and discharges to sewers by the local sewerage companies.

Water Outputs to controlled waters or sewers are restricted by the Water Resources Act 1991 and Water Industries Act 1991. The Water Resources Act 1991 contains provision for the protection and improvement of controlled waters , (river, lakes, estuaries etc) makes it an offence to pollute them. Consents are obtained from the Environment Agency and costs based on volume, nature/content, strength of the effluent and nature of the receiving water. The Water Industry Act 1991 states trade effluents need consents for discharge. The cost is based on volume, content, strength of the effluent and capacity of effluent plant and is controlled by local Water Authority. Under the Trade Effluents (prescribed processes and Substances) Regulations 1989 industrial discharges which contain specified hazardous substances, must obtain consents from the Authorities, (EA). Land Legislation on Contaminated land is implemented under the Environment Protection Act 1990 Part 2A. Local Authorities have to identify contaminated land in their area and determine if it is a special site, i.e. severely contaminated if latter is case Consultation period will follow and remediation may be required. (EA responsible for severe sites, LAs for others). Responsibility for this will rest with the person who caused it or allowed it to happen in the first place. If this person cannot be found the current owner or occupier may be forced to do it. The Contaminated Land Regulations were published in April 2000.

The EU Landfill Draft Directive 1999 sought to reduce waste going to landfill. It requires reduction in organic waste going to landfill by 25% by 2006 from 1995 value rising to a reduction of 65% by 2016.(so Local Councils need to set up more composting schemes), a phase out of co-disposal of hazardous and non hazardous waste and restrictions on landfilling of liquid effluent. It also effectively bans tyres from being sent to landfills from mid-2006 as well as clinical waste and waste which is corrosive oxidising highly flammable or flammable . It is implemented by the Landfill (England and Wales) Regulations Solid Waste Disposal This is governed by EPA90 Part II: which deals with waste disposal e.g. Duty of Care Regulations 1991. This deals with controlled waste, (i.e. household, commercial and industrial), including special waste, (which is generally hazardous). Clinical waste must be dealt with separately. Discharges to land have to meet the Duty of Care requirements of the Environmental Protection Act 1990. Duty of Care as applied to waste means the person producing the waste has a legal obligation to ensure it is disposed of properly by a fit and proper person who has a waste licence to dispose of the waste. You also need to give them a waste transfer note saying what the waste is. They are responsible for ensuring it goes to the correct disposal site even if it passes through a third party. If you pass it to someone else and they get rid of it illegally you can still be held responsible. Charges are made not only by the person taking away the waste but also there is a need to pay an additional landfill tax under the Finance Act, (currently 13/tonne). 7

The Landfill Tax Regulations 1996 (Part of Finance Act 1996): imposed an additional cost to the price of landfilling by adding a tax of 2 per tonne for inert and 10 /tonne for other controlled waste, (rises se each year by 1/year until 2004 now 13) . This applies the principles of polluter pays and is essentially a Fiscal Policy and also sought to fulfil some of the requirements of the EU landfill Directive. .

Air Discharges to air are controlled partly by the Clean Air Act 1993 but also by the requirements of Integrated Pollution Control or latterly Integrated Pollution Prevention and Control. Councils now have an obligation to address Air Quality guidelines under the Governments Air Quality Strategy and this will have a knock on effect in terms of how they regulate local industry. Smaller less polluting industries,(e.g. small foundry) which release only to air are regulated under EPA 1990 as so called Part B processes, Local Air Pollution Control (LAPC, ). The Clean Air Act 1993 deals with restriction and prohibition of the emission of smoke, dust, grit and fumes. EPA 90 Part IV. Deals with Air and the Air Quality Regulations, (1995 and 1997) sets air quality objectives to be achieved by 2005 for CO, NOx, PM10, SOx, Benzene.

Volatile Organic Compounds e.g. solvent based paints, cause ozone depletion and , photochemical smog, In 1999 the EC Directive on Emissions of VOCs sought to tighten controls on the emissions of VOCs. It followed the United Nations Economic Commission for Europe protocol which requires countries to cut their VOC emissions by 70% by 1999 from a 1988 baseline. It also allowed us to follow the Montreal protocol on the phase out of chlorinated organic solvents. This could result in the price of solvents going up by a much as 8,000 per tonne, (to allow for abatement expenses to be included in the price of the solvent). It may also result in tradeable permits (as in US) or a solvent tax. Small companies may be exempt. All companies would have to produce a solvent management plan if they use more than 0.25 tonnes of solvent a year. The Directive had to be implemented by the member states by 2001. Statutory Nuisance EPA 90 Part III. Deals with statutory nuisance Deals with smoke, fumes, dust, animals, noise, etc.

Integrated Control over Emissions to Air, Water and Land


In 1990 for the first time the regulators sought to approach the control of pollution to air water and land in a more integrated way. This was introduced as Integrated Pollution Control (IPC) under Part 1 Environmental Protection Act 1990. Supervised by the EA, and covering all major solid, liquid and gaseous releases to all media, air water and land to prevent problems being transferred across environmental 8

media. The Worst polluters are so called Part A (e.g. large chemical plant) processes, (EA issues authorisation) Companies have to apply for Authorisation (guidance notes provided), and show they are using the BPEO to minimise pollution. Companies must also provide upgrade plans to show improvement based on BATNEEC, (not CATNELP!)

IPPC - a move to a more holistic approach


The EC Directive on Integrated Pollution Prevention and Control (IPPC) 1996 has been implemented in UK from 1999 by the Pollution Prevention and Control Act. It is a move away from traditional end of pipe legislation as it addresses pollution prevention at source although it does not apply to all companies only those with the greatest potential to pollute. The requirements will now incorporate waste minimisation, energy efficiency, noise and vibration, impact of pollutants, prevention of accidents. In addition, decommissioning requirements and their likely environmental effects will have to be considered. There are also requirements for an EMS. The main purpose of PPC is to develop a more integrated approach to controlling pollution from industrial sources and achieve a high level of protection of the environment as a whole through reducing emissions into the air, water and land. This is done through determining and enforcing permit conditions based on the Best Available Techniques (BAT).

EC Directive on Integrated Pollution Prevention and Control (IPPC) 1996: This EC Directive should have been implemented by Oct 1999. It affected a further 4,600 organisations with 7000 installations and move many Part B processes to part A. It includes he incorporation of waste minimisation, energy efficiency, noise, impact of pollutants, prevention of accidents and the requirement to have an EMS . Inspectors are allowed to review the permit procedure at any time. BAT(Best Available Technique) rather than BATNEEC must be proved. Phased in from 2000-2007 according to sector. Now cover additional processes to those affected by IPC such as food processing, intensive animal rearing. Came into force from Autumn 2000 under the Pollution Prevention and Control Act 1999.

Financial drivers
An organisation has to pay direct costs for the water and energy is uses. It also pays for consents to discharge effluent or for its waste to be taken away. If it is subject to either Environment Agency or Local Authority controls under IPC or IPPC it will also pay for the authorisations to operate. Tax incentives (or impositions) are a more recent indirect cost way of trying to reduce environmental impact. These may be through additional levies on resource use, (as with the climate change levy (see http://lorien.ncl.ac.uk/ming/cleantech/ccl.pdf) a tax

on gas and electricity usage), or on the cost of waste disposal (landfill tax) and need to purchase PRNs under the obligations of the Packaging Regulations. The additional costs that will be incurred through requirements for recovery and recycling under producer responsibility are other examples of fiscal measures. There are also proposals for example for taxes to reduce the use of pesticides and herbicides. Financial Drivers therefore include: Cost of Gas, Water, Electricity Climate Change Levy (tax) Consents for effluent disposal Solid Waste disposal charges Landfill tax on Waste Disposal (Tax) Packaging waste PRNs

Climate Change Levy A tax on energy usage UK legally bound by Kyoto protocol to reduce Greenhouse gas emissions by 12.5% by 2010 from a 1990 baseline But has set itself a domestic goal of 20% reduction in CO2 emissions Based on report by Lord Marshall, the UK Government decided to use an economic instrument to achieve this a tax on the business use of energy. i.e. a fiscal measure. Legislation for this Climate Change Levy came under the Finance Act 2000 As of April 2000 Levy rates are Electricity Gas Coal LPG 0.43 pence/kWh 0.15 0.15 0.07

Levy should be revenue neutral and costs will be : Returned by a reduction in employers NI (National Insurance). (depends therefore what your ratio of employees/energy bill is Plus an energy efficiency fund of 50 million to advise industry Plus a deduction in tax for those investing in Energy saving investments such as lighting, motors, CHP, boilers 10

Energy intensive sectors get a 80% discount on the levy if they agree targets for improving energy efficiency but these have to be met!

Controls on the product or service Producer Responsibility


PR is based on the "polluter pays" principle, entails making manufacturers responsible for the entire lifecycle of the products and packaging they produce and setting targets for their recovery and recycling. This may be either voluntarily or directly such as recent imposition of EU legislation on Waste Electrical and Electronic goods, (WEEE) and End of Life Vehicles as well as legislation concerning batteries and tyres. See http://lorien.ncl.ac.uk/ming/cleantech/eg-prop-legis.htm for WEEE and ELV. See http://lorien.ncl.ac.uk/ming/cleantech/packaging.htm for details of the packaging regulations. One aim of PR policies is to internalise the environmental costs of products into their price. Another is to shift the economic burden of managing products that have reached the end of their useful life from local government and taxpayers to product producers and consumers. The may be extended to all products through IPP. The Producer Responsibility Obligations (Packaging Waste) Regulations 1997, This came into force in March 1997 and amended in 1999 were made under the Environment Act 1995 to implement the recycling and recovery targets in the 1994 EU Directive on packaging waste which sought to reduce the enormous amount oif packaging waste going to landfill. They apply if a company handles more than 50 tonnes a year and has a turnover of >2million . The targets are to recover 59% of packaging and recycle 19% with a minimum of 15% of each type, includes paper, cardboard, plastic, wood.

The recycling and recovery obligations for different types of producer can be calculated from the information in Schedule 2 to the Regulations. The amount of waste which a producer must recycle or recover can be found by multiplying the national targets by the percentage activity obligations (see tables below). Year National targets: Recycling 10% 13% 18% 19%

Recovery 1999 2000 2001 2002 43% 45% 56% 59%

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Percentage activity obligations Raw material manufacturing 6% Converting 9% 37%

Packing/ filling Selling 48%

Secondary provider (ie supplier of transit packaging)

85%

Regulation 3 sets out three obligations with which producers must comply: (a) (b) (c) to be registered with the Environment Agency or SEPA to take reasonable steps to recover and recycle packaging waste to furnish a certificate of compliance to the relevant Agency.

Retailers have an additional duty to provide consumers with information about the available collection and recovery systems, and about what consumers can do to reuse, recycle and recover packaging. Companies which join a registered scheme (commonly known as a compliance scheme) are exempt from the obligations to recycle and recover the waste themselves which are instead carried out by the operators of a compliance scheme such as Valpak. They buy PRNs, (packaging Recovery Notes), form the operators of the compliance scheme to demonstrate they recycling/recovery has been carries out. Producers of packaging waste who are not members of compliance schemes must register with the Environment Agency or the Scottish Environment Protection Agency (SEPA).

The WEEE Directive Waste Electrical and Electronic Equipment Directive Manufacturer and importers will have to collect WEEE from retailers and local authorities When retailers sell a new item they will have to take the old one back. Manufacturers will have to set up recycling and reuse schemes

Targets for recycling and reuse: 90% for large household appliances like fridges and TVs 70% for smaller items Harmful components will have to be removed during dismantling. Lead, hexavalent chromium, cadmium, mercury and brominated flame retardants must be phased out by 2004 To increase the market for recycled plastic by 2004, 5% of the plastic in new equipment must be recycled.

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Proposed Directive on End of Life Vehicles To prevent old vehicles being a source of pollution and waste of resource Currently cause 9 million tonnes of waste per year in the EU By 2005, 85% of the vehicles weight should be reused/recovered and 80% reused/recycled. Collection and recycling of End of Life Vehicles to be responsibility of Automotive Industry

Organisational Initiatives and Requirements


Environmental and Corporate Social Responsibility Reporting Environmental reporting is yet to be compulsory in the UK (although is in some countries). Many large companies now produce environmental reports either separately or as part of their annual report. There is also a growing trend towards reporting on sustainability, the triple bottom line of environment, economics and social issues, these are often referred to as Corporate Social Responsibility reporting. Most of these are in the utilities, energy chemical or minerals sector. The financial sector and investment trusts are worst at producing environmental reports.

It is good PR, enhances their credibility and sets a focus for environmental activities within the company. Problems that may arise from disclosure include increased expectations from customers, what if it is worse next year? The UK Government has said most firmly it expects companies with >250 employees to produce reports hoping it will happen voluntarily, otherwise legislation may be brought in.

Environmental Management Systems These are voluntary for businesses but are becoming increasingly implemented due to supply chain pressure and the need to show stakeholders the company takes issues of sustainability and the environment seriously. Having an accredited system shows you have done this. An EMS is the organisational structure, responsibilities, procedures, processes and resources required for implementing environmental management. There are two accredited systems, the International one ISO14001 and the EC one EMAS (Eco Management and Audit Scheme), although companies may have an EMS without formal accreditation. The main difference is that EMAS asks for a publicly available and verified Environmental Statement which some companies see as a threat as good news and bad news on progress towards achieving targets has to be included. Up to now having an EMS has been voluntary although companies falling under IPPC regulations will have to have one. The EMS requires that the company has in place procedures to ensure compliance with relevant environmental legislation and has assessed their environmental aspects and impacts. Management structures must be put

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in place which will drive the company towards continuous environmental improvement through the setting of relevant objectives and targets. The EMS is concerned less with the sustainability or environmental performance of the product or service that the organisation provides itself, more with showing that the company recognises it has an impact on the environment and tries to reduce it. So two companies doing the same thing but with different environmental performance can still get the award. Details of ISO and EMAS at http://lorien.ncl.ac.uk/ming/cleantech/ISO-EMAS.htm

Where do environmental aspects and impacts arise? The Environmental Management Standard (EMS) ISO14001 gives guidance under ISO14004 on assessing aspects and impacts. Aspects being any element of the organisations activities, products or services (APS) that can interact with the environment. Impacts being any change in the environment, whether beneficial or detrimental, wholly or partly resulting from the organisations APSs. May be thought of equivalent to cause, (aspect) and effect (impact). e.g. emissions of solvent based paint, (aspect) release of VOCs potentially causing ground level ozone and photochemical smogs (impact). The activities, products and services within the organisation may be broken down into a series of blocks to make it easier to assess the relevant aspects and impacts. Within the structure of an EMS the organisation must assess which aspects are significant, as these are the ones that need to be controlled and are the basis for setting objectives and targets to show continuous improvement in their management. Assessing Significance of aspects is open to interpretation and is a vital part of an EMS. You can refer to authorisations, sector guidance notes, waste transfer notes, etc. For example you can use the following criteria: Is the aspect controlled by legislation or policy? Is it sensitive? Does it have heavy financial implications or is it large in scale or volume? Is there an element of environmental risk attached to it?

Risk is assessed as a consideration of the hazard, (for example how dangerous is a chemical? ) and the likelihood of occurrence, (is the chemical well stored? ). You may decide to assign a score to each criterion for example according to the degree of sensitivity or scale. However it is important that you do not just then sum all of the scores and address those with the highest total as you may miss something that score very highly on one aspect, (e.g. has a high legislative requirement) but score low on all other criteria.

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Generally in the context of an EMS the identification of aspects and impacts relates to inputs and outputs to the APS but not to the actual product or service itself. Most of the regulations and legislation relate to outputs with pollution potential. To make real environmental improvements it is necessary to address both inputs to the process, (materials, utilities etc) but more fundamentally the product or service itself. At the moment much of this is driven not by legislative requirements but by voluntary initiative by companies who are more proactive in their thinking and are responding to potential market opportunities or stakeholder pressures.

Changing the product or service


Perhaps the logical way of controlling our effect upon the environment is to change what we make or the service we provide rather than just going for end of pipe controls. The environmental improvement of the product or service may be addressed by tools such as eco-design or life cycle assessment, (LCA). At the moment neither are compulsory but companies wishing to eco-label their products need to fulfil set environmental criteria for their product type which are based upon LCA analysis. (Information on eco-labels is available at http://europa.eu.int/comm/environment/ecolabel/) Whether or not a product is made from a sustainable raw material is not currently subject to any legislation although some companies may have a green procurement policy or may adhere to schemes such as the forest stewardship programme.

Clean design is a method of systematically integrating environmental


considerations into the design of products, processes or services throughout their life time. Design determines function and operation, material selection, (including reduction of hazardous materials), process selection, energy requirements, remanufacturing, serviceability and suitability for recycling. More than 70% of product costs are determined at the design stage There is a need to design for disassembly, recyclability, serviceability and perhaps incineration. (More notes on clean design available at http://lorien.ncl.ac.uk/ming/cleantech/cleandesign.pdf)

Envop and Process Intensification


Both of these approaches apply only at the manufacturing stage and minimise environmental impact whilst at the same time optimising production.

Life Cycle Assessment attempts to predict the overall environmental impact


associated with a product, function or service. The impact of the product or service on the environment is measured at each stage from the cradle to the grave of the product, from manufacturing, through use, to ultimate disposal. Inventories are compiled of total energy requirements, raw materials usage the pollutants emitted during manufacture, use and ultimate disposal. It may be used to compare two or more products to decide which is the best environmental option or to decide where,

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throughout its life cycle greatest environmental impact of a single product occurs so this phase can be targetted. The process may therefore be very complex and costly. In practice most LCAs tend to focus on particular aspects of the life cycle, where it is thought the main environmental impacts or hot spots are likely. For packaging this may be both during manufacture and during disposal. For a washing machine it is during its use. LCA may also be used to compare two or more products to decide which has the least environmental impact. Having compiled a list of environmental impacts it is then necessary to decide which are considered to be the most important so they may be reduced. This stage is subjective and often driven by political or economic considerations, for example some countries need to reduce waste to landfill , others are more concerned with acid rain or eutrophication. (Extensive notes on LCA available at http://lorien.ncl.ac.uk/ming/cleantech/lcawhole.pdf )

Industrial Ecology goes beyond even the product, the process or the service and requires complete integration of manufacturing with the natural world. Demands a system change- business and the economy need to be seen as part of a larger economic and environmental system. Concept of industrial ecology developed by Robert Frosch in the late 80s. In industrial ecology unit processes and industries are interacting systems rather than isolated components. Based on the concept of ecological systems where through a web of connections organisms live and consume each others waste as in a food web. (notes on Industrial Ecology and Envop, as well as other approaches are at http://lorien.ncl.ac.uk/ming/cleantech/CleanerProduction1.htm ) Product Stewardship
Product Stewardship is the responsible and ethical management of the health safety and environmental impacts of a product throughout its life cycle. There is now a move towards companies providing a service rather than a product as they retain the ownership of the product itself and thus may find their responsibilities under producer responsibility easier to discharge. Companies are moving away from selling the product and are now selling the service instead by leasing for example photocopiers or even solvents which are taken back at the end of their useful life for recycling. This gives an incentive for manufacturers to increase the durability and recyclability of their products and into designing them for easy disassembly. Again there is yet to be a legal requirement for product stewardship but policy instruments are acting as an effective driver.

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