Green Products by Design: Choices for a Cleaner ...

Chapter 1

Executive Summary

ContentsPagePROJECT DESIGN AND THE ENVIRONMENT ... ... o.. .*, *,, **, , e,+,,*,**,,***,+,,+, 4GREEN DESIGN ..0. ... .*. ... ... .*. .*. ,,**, *,, +*** *r** c,**, **e*, c4*, ,***, *,** *4 #e****,* 6Design Tradeoffs * *,. . . . . . . .*.*, . . , . . ... ... ... ... .,, .,, ..$**Qa, , *#**.**,++***,.*.,’*, 8Environmental Aspects of Products and Systems ... ... ... ... .*, .,, *,** **** ***, ,Q, ,Q **.* 8Policy Implications .4. ... ... **. ... ,**. ..*, *.**, ,., o**c*, c*. .ti, **** o*** *,@o**. **, *, *e* 10GROWING INTEREST IN GREEN DESIGN ..*. .**. ... **. .,, ,,**Q*, ***, ,*****cao**cao* 10SHAPING ENVIRONMENTAL POLICIES THAT ENCOURAGE GREEN DESIGN .,.... 13

Current Federal Efforts Related to Green Design ... ... ... .,. .,*. ***e c*4*a*o *a** *, *c*,*+ 14Long-Term Options ... ... ,.. ... .,. *.. .*. .,, ,*. .#*o,4* e,, .o. +o+**, **, +**, *cue**,+,+,.* 15GUIDING PRINCIPLES FOR POLICY DEVELOPMENT’ .4. ..*, .*, ... *.*. .**, ,0*, ,, **O* 18CONCLUSION● . . . . . . . . . . . . . . . . . . . . . ... .*. ... ... ... .., ..+*, +*** o*, o. G*****,*+.******. 20

BoxBox

Pagel-A. Design and Materials Management in the Auto Industry . ......*........,,,,,,.*.,** 11

Figure1-1. Stages of the Product Life Cycle . . . . .1-2. “Solid” Wastes as Defined Under the

Recovery Act (RCRA)● . . . . . . . . . . . . .

1-3. The Dual Goals of Green Design .,..1-4. Cross-Section of a Snack Chip Bag .,1-5. Eco-labels Around the World . . . . . . . .

Figures

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Page1-1. Federally Funded Programs Related to Omen Design● .*. ... ... .., .., *,** c*, *+c**, *4*m 151-2. Policy Options That Could Affect Materials Flows .*. .*. ... .,*. *,*. *,*, *40, *,, o,*,,., 17

Chapter 1

Executive Summary

Policymakers should be concerned with productdesign for two reasons. One is to improve U.S.industrial competitiveness. A strong domestic de-sign capability can slash product development time,improve quality, and reduce the cost of U.S.products. The National Research Council has esti-mated that 70 percent or more of the costs of productdevelopment, manufacture, and use is determinedduring the initial design stages. 1 Thus, design is acritical determinant of a manufacturer’s competi-tiveness.

The second reason is that product design is aunique point of leverage from which to addressenvironmental problems. Design is the stage wheredecisions are made regarding the types of resourcesand manufacturing processes to be used, and thesedecisions ultimately determine the characteristics ofwaste streams.2 By giving designers incentives toconsider the environmental impacts of their choices,policymakers can address environmental problemsthat arise throughout the product life cycle, from theextraction of raw materials to final disposal.3

The two design goals of enhancing competitive-ness and protecting environmental quality can beconsistent. Design strategies that reduce productioncosts and improve quality often have the benefit ofgenerating less waste and pollution. Moreover,many companies are already using the environ-mental attributes of their products in their marketingstrategies, and polls suggest that consumer demandfor “green” products is likely to grow. 4 M a n yobservers believe that those companies that are ableto design high-quality, environmentally sound prod-ucts will enjoy a competitive advantage in the 1990sand beyond.

In a recent review, the National Research Councilfound that the quality of U.S. engineering design is

generally poor, and recommended that the FederalGovernment make engineering design a nationalpriority to improve competitiveness.5 In the presentstudy, the Office of Technology Assessment (OTA)finds that better product design offers new opportu-nities to address environmental problems, but thatcurrent government regulations and market practicesare not sufficient to fully exploit these opportunities.Therefore, integrating an environmental componentinto policies to improve U.S. design capabilities isan important policy objective. But policymakersshould be careful in how they attempt to achieve thisobjective. Inappropriate regulation of the environ-mental attributes of products could perversely leadto more wastes being generated, and could alsoadversely affect competitiveness.

These findings are particularly relevant in thelight of congressional debate concerning the reau-thorization of the Resource Conservation and Re-covery Act (RCRA) of 1976, the major Federalstatute concerning solid waste. The reauthorizationdebate involves many issues that could affect thedesign of products, including mandatory recycledcontent, reduced toxic chemical content, govern-ment procurement of recycled products, and envi-ronmental labeling, as well as controls on productsthat cause special waste management problems suchas automobile batteries, used oil, and tires.

In reauthorizing RCRA and other environmentallaws, Congress can influence product design in twoways. First, it can enact additional environmental

—for example, requiring that manufac-regulationsturers incorporate recycled materials into new prod-ucts or take back discarded products from consum-ers. Second, Congress can move toward a strategy ofharnessing market forces to encourage manufactur-ers to make environmentally sound decisions—forexample, instituting a fee-rebate system based on the

1 National Research Council, Improving Engineen”ng Design: Designing for Competitive Advantage (Washington DC: National Academy Press,1991).

2 while this report focuses P rimarily on product design rather than process desigq it should be recognized that the two are closely related. Many ofthe reseamh needs and incentives discussed here for product design also apply to process design.

3 As used here, the term “designers’ refers to all decisionmakers who participate in the early stages of product development. This includes a widevariety of disciplines: industrial designers, engineering designers, manufacturing engineers, graphic and packaging designers, as well as managers andmarketing professionals.

4 Green products are those whose manufacture, use, and disposal place a reduced burden on the environment.5 National Research Council, op. cit., footnote 1,

–3–

4 ● Green Products by Design: Choices for a Cleaner Environment

Figure l-l-Stages of the Product Life Cycle

- -+

Material extraction Material processing Manufacturing

t tRecycle Remanufacture

Use Waste management

tReuse

Environmental impacts occur at all stages of a product’s life cycle. Design can be employed to reduce these impacts by changing theamount and type of materials used in the product, by creating more efficient manufacturing operations, by reducing the energy andmaterials consumed during use, and by improving recovery of energy and materials during waste management.SOURCE: Adapted from D. Navin chandra, The Robotics Institute, Carnegie Mellon University, personal communication, March 1992.

energy efficiency of products, or taxing the indus-trial emissions of certain toxic chemicals.

Each approach has advantages and disadvantages:regulations can produce swift and predictable re-sults, but they can also impose unnecessary costs onindustry and stifle environmentally innovative de-signs. Economic incentives can provide flexibility,but they can be expensive to administer and are oftenpolitically unpopular. The challenge for Congress isto employ a mixture of regulations and economicinstruments to give designers the incentives to makechoices that promote RCRA’s goals of protectinghuman health and the environment.

PRODUCT DESIGN AND THEENVIRONMENT

Products affect the environment at many points intheir life cycle (figure l-l). The most visible impactis municipal solid waste (MSW). The trash gener-ated by U.S. households and commercial establish-ments averages about 4 pounds per person each day.In 1988, the United States generated some 180million tons of MSW. Landfills in many States arereaching their permitted capacity, and there is

increasing public opposition to siting new wastemanagement facilities.

About one-third of MSW by weight consists ofproduct packaging, which has become a major targetof environmental policies around the world. Betterpackaging design can reduce the quantity of thiswaste significantly. For example, at a recent confer-ence, packaging designers concluded that—giventhe commitment of top management—new designscould reduce the weight of packaging by an averageof 10 percent in 1 year. This would mean a 3 percentdrop in MSW from this source alone.

Less visible but potentially more serious environ-mental impacts occur during raw material extrac-tion, material processing, and product manufactur-ing. U.S. industry generates some 700 million tonsof “hazardous waste” and some 11 billion tons of‘‘non-hazardous solid waste (figure l-2a).6 Al-though the weight of industrial and municipal solidwaste cannot be compared directly,7 these produc-tion wastes clearly dwarf municipal solid wastes intheir quantity and environmental impact (see figurel-2b). Product design decisions can have a direct

6 The terms hazardous and non-hazardous are defined by RCRA subtitles C and D, respectively. See U.S. Congress, OffIce of TechnologyAssessment, Managing Industn”al Solid Wastes From Manufacmring, Mining, Oil and Gas Production, and Utility Coal Combustion, OTA-BP-O-82(Washington, DC: U.S. Government Printing Office, February 1992).

7 Up to 70 percent of the weight of industrial solid waste (which includes mining, oil and gas, and manufacturing wastes) consists of wastewatercontained in sludges and aqueous solutions.


Figure 1-2–’’Solid” Wastes as Defined Under the Resource Conservation and Recovery Act (RCRA)

(a) All RCRA wastes (b) Non-hazardous RCRA wastes(billions of tons) (billions of tons)

Hazardous

Oil/gas (1.4)

Manufacturing (6.5)

/Agricultural (1

MSW (0.18)~ Other (0.13)

.0)

Much of the solid waste produced in the United States is not directly generated by consumers. Municipal solid waste, the focus of muchpublic concern, represents less than 2 percent of all solid waste regulated under RCRA. in contrast, Industrial activities produce about 700million tons of hazardous waste (a) and about 11 billion tons of non-hazardous wastes (b).NOTE: All numbers are estimates. The non-hazardous waste total has been rounded to reflect uncertainty. Much of the “solid” waste defined under RCRA,

perhaps as much as 70 percent, consists of wastewater. The terms hazardous and non-hazardous refer to statutory definitions of Subtitles C and Dof RCRA, respectively. The mining wastes shown in (b) exclude mineral processing wastes; the oil/gas wastes in (b) exclude produced waters usedfor enhanced oil recovery; the “other" category in (b) includes wastes from utility coal combustion.

SOURCE: Adapted from U.S. Congress, office of Technology Assessment, Managing Industrial Solid Wastes From Manufacturing, Mining, Oil and GasProduct/on, and Ut///ty Coa/ Cornbustlon, OTA-BP-O-82 (Washington, DC: U.S. Government Printing Office, February 1992).

influence on the manufacturing component of thesewastes (about 6.5 billion tons).

Finally, some of the most serious environmentalimpacts may occur during the actual use of theproduct. This is particularly true of products that areconsumed or dissipated during their use, for exam-ple, chlorofluorocarbon (CFC) solvents and cool-ants, fossil fuels, and pesticides. The environmentalreleases from these dissipative products can be muchlarger than those from the associated industrialprocesses. For example, the State of New Jerseycollects data on industrial inputs and outputs ofhazardous substances. The data indicate that in1990, 55 to 99 percent of industrial inputs of fivetoxic heavy metals (mercury, lead, cadmium, chro-mium, and nickel) was converted into products (i.e.,not released as industrial waste), depending on themetal.8 Product reformulation and substitution fortoxic constituents can help to address these prob-lems.

Behind each of these environmental impacts arecritical decisions made during product design. Thematerials used, energy requirements, recyclability,longevity, and many other environmental attributesof products result directly from design decisions.

Once a product moves from the drawing board intoproduction, its environmental attributes are largelyfreed; the key, therefore, is to bring environmentalconcerns into the front end of the design process.

GREEN DESIGNProduct design is a process of synthesis in which

product attributes such as cost, performance, manu-facturability, safety, and consumer appeal are con-sidered together. In general, products today aredesigned without regard for their overall impact onthe environment. Nevertheless, many health andenvironmental laws passed by Congress do influ-ence the environmental attributes of products. Some,such as the Clean Air Act, Clean Water Act andResource Conservation and Recovery Act, do soindirectly, by raising industry’s costs of releasingwastes to the air, water, and land. Others, such as theToxic Substances Control Act and the FederalInsecticide, Fungicide, and Rodenticide Act, controlthe use of hazardous chemicals and pesticidesdirectly.

Government regulations typically influence thedesign process by imposing external constraints, forexample, compliance by auto designers with Corpo-

8 Some heavy metals incorporated into products are eventually recycled, but recycling rates very substantially by material. For example, more than50 percent of lead is recycled, but nearly all cadmium is released into the environment.

Chapter 1--Executive Summary ● 7

Courtesy Magazine (July 1990)

Some bacteria can store energy in polymer-bearing granules that can be collected and made into truly biodegradablepackaging like these plastic bottles made from Alcaligenes bacteria by ICI, Ltd.

rate Average Fuel Economy (CAFE) standards, andwith auto emissions standards under the Clean AirAct. OTA uses the phrase “green design” to meansomething qualitatively different: a design processin which environmental attributes are treated asdesign objectives, rather than as constraints. A keypoint is that green design incorporates environ-mental objectives with minimum loss to productperformance, useful life, or functionality.

In OTA’s formulation, green design involves twogeneral goals: waste prevention and better materialsmanagement (figure 1-3).9 Waste prevention refersto activities by manufacturers and consumers thatavoid the generation of waste in the first place.Examples include using less material to perform thesame function (’‘light-weighting”), or designingdurable products so that faulty or obsolete compo-

nents can be readily replaced, thus extending theproduct’s service life. Better materials managementrefers to activities that allow product components ormaterials to be recovered and reused in their highestvalue-added application. Examples include design-ing products that can be readily disassembled intoconstituent materials, or using materials that can berecycled together without the need for separation.These goals should be viewed as complementary:while designers may reduce the quantity of resourcesused and wastes generated, products and wastestreams will still exist and have to be managed.

The idea of green design seems simple, but thereis no rigid formula or decision hierarchy for imple-menting it. One reason is that what is ‘‘green”depends strongly upon context. While some envi-ronmental design objectives are sufficiently compel-

9 This formulation appeared U.S. Congress, of Technology Assessment, Facing America’s Trash: What Next for Municipal SolidWaste, OTA-O-424 (Washington DC: U.S. Government Printing October 1989).


Figure 1-3-The Dual Goals of Green Design

Green design

I

Waste prevention Better materials management

Reduce: weight Facilitate: remanufacturingtoxicity recyclingenergy use comporting

Extend: service life energy recovery

Green design consists of two complementary goals. Design for waste prevention avoids the generationof waste in the first place; design for better materials management facilitates the handling of productsat the end of their service life. -

SOURCE: Office of Technology Assessment, 1992.

ling to apply to many different products (e.g.,avoiding the use of CFCs), in general OTA expectsthat green choices will only become clear withrespect to specific classes of products or productionnetworks. What constitutes green design may de-pend on such factors as: the length of product life;product performance, safety, and reliability; toxicityof constituents and available substitutes; specificwaste management technologies; and the localconditions under which the product is used anddisposed.

Design Tradeoffs

With technologies available to create new materi-als and to combine conventional materials in newways, designers are faced with more choices thanever before. One result is that products are becomingmore complex and specialized. For example, atypical laundry detergent now contains over 25different ingredients.

These choices often involve environmental di-lemmas. Tradeoffs may be required, not only be-tween traditional design objectives and environ-mental objectives, but even among environmentalobjectives themselves-for example, waste preven-tion versus recyclability.

As an illustration, consider the cross section of amodern snack chip bag depicted schematically infigure 1-4. The combination of extremely thin layersof several different materials produces a lightweightpackage that meets a variety of needs (e.g., preserv-ing freshness, indicating tampering, and providingproduct information). The use of so many materials

effectively inhibits recycling. On the other hand, thepackage has waste prevention attributes; it is muchlighter than an equivalent package made of a singlematerial and provides a longer shelf life, resulting inless food waste. Even this relatively simple productdemonstrates the difficulties of measuring greendesign.

Similar tradeoffs may occur between other attri-butes, such as energy efficiency and toxicity. Forexample, energy-efficient, high-temperature super-conductors contain a variety of heavy metals, andtoxic chemicals are required to manufacture pho-tovoltaic cells. In general, every design will have itsown set of environmental pluses and minuses.

Environmental Aspectsof Products and Systems

From an environmental point of view, it issimplistic to consider the impact of a product inisolation from the production and consumptionsystems in which it functions. Is a computer, forinstance, a green product? Considered on its own,probably not. The manufacture of a computerrequires large volumes of hazardous chemicals andsolvents, and heavy metals used in solder, wiring,and display screens are a significant contributor tothe heavy metal content of MSW.

But the same computer could be used to increasethe efficiency of a manufacturing process, thusavoiding the use of many tons of raw materials andthe generation of many tons of wastes. From thisperspective, the computer is an enabling technology


Figure 1-4-Cross-Section of a Snack Chip Bag

Polypropylene

r 7

● Machinability“ Adhesion

o Moisture barrier● Stiffness● Clarityo Puncture resistance

● Ink adhesion

o Graphics quality

● Interlaminar adhesion

● Barrier to oxygen,moisture, and light

● Metal adhesion

● Stiffness● Moisture barrier

● Seal integrity● t-tot seal strength—\ I

,. ! “ Easy opening● Tamper evidence

This cross-section of a snack chip bag illustrates the complexity of modern packaging. The bag is approximately 0.002 inches thick, andconsists of nine different layers, each with a specific function. While such complexity can inhibit recycling efforts, it also can reduce theoverall weight of the bag, and keep food fresher, thus providing waste prevention benefits.SOURCE: Council on plastics and Packaging in the Environment.

that reduces the environmental impact of the produc-tion system as a whole.

This illustrates an important OTA finding: greendesign is likely to have its largest impact in thecontext of changing the overall systems in whichproducts are manufactured, used, and disposed,rather than in changing the composition ofproducts per se. For instance, designing lighterfast-food packaging is well and good; but 80 percentof the waste from a typical fast food restaurant isgenerated behind the counter, where consumersnever see it. Addressing this larger problem requiresthat designers establish cooperative relationshipswith their suppliers and waste management provid-ers in order to manage materials flows in anenvironmentally sound way.

There may appear to be few incentives forindustry to consider such dramatic changes in

existing production networks. After all, longstandingrelationships among manufacturers and suppliersmay have to change, and millions of dollars maybeinvested in the existing infrastructure for productionand distribution. Such changes are not generallywithin the purview of product designers. Indeed, asystems design approach implies the elevation of theproduct design function to the level of strategicbusiness planning, and a shift in perception by topmanagement in which environmental quality isviewed not as a cost, but as a strategic businessopportunity.

But changes of comparable magnitude are alreadyunderway. Many manufacturers are rethinking theirbusiness relationships with suppliers and customersin order to implement total quality management andconcurrent engineering programs. New governmentregulations in Europe that give manufacturers re-

10 ● Green Products@ Design: Choices for a Cleaner Environment

sponsibility for the environmental fate of theirproducts are also encouraging this approach. Forexample, Germany’s proposed law requiring auto-makers to take back and recycle automobiles hasstimulated the German automobile industry to de-velop new cooperative strategies for auto design,manufacturing, and recycling (see box l-A).

Policy Implications

These findings have a number of policy implica-tions:

The environmental evaluation of a product ordesign should not be based on a single attribute,such as recyclability. Rather, some balancing ofpluses and minuses will be required over theentire life cycle.The trend toward increasing product complex-ity seems certain to make the environmentalevaluation of products more difficult and ex-pensive in the future.Policies to encourage green design should beflexible enough to accommodate the rapid paceof technological change and the broad array ofdesign choices and tradeoffs.The biggest environmental gains will likely——come from policies that provide incentives forgreener production and consumption systems,not just greener products.

GROWING INTEREST INGREEN DESIGN

The concept of green design is not new. Duringthe 1970s and 1980s, ideas such as design forremanufacturing and design for recycling weredeveloped in technical journals and conferences. Atthe time, the concept did not receive much attentionfrom policymakers or the public, but green designhas enjoyed a renaissance in the past few years.Rising interest among industry groups and designsocieties around the world is indicated by theproliferation of books, newsletters, and publishedpapers on the subject.

One area of particular interest is the awarding of‘‘eco-labels’ to products that are judged to beenvironmentally preferred compared with alterna-tive products. Germany, Canada, Japan, the Nordiccountries, and the European Community all eitherhave government-funded eco-labeling programs, orwill have them in the near future. The United States

Photo credit: Institute of Scrap Recycling Industries, Inc.

Photo credit: GE

Top; When automobile hulks are recycled, most of themetals are recovered. The nonmetal components (plastic,rubber, fabric, and glass) end up as shredder residue that

must be Iandfilled. Bottom: BMW has designed the21 Roadster so that external body panels and fascia

can be easily removed from the automobile frameand subsequently recycled.


Figure 1-5--Eco-labels Around t he World

Canada (Environmental Choice)

‘“} (Ic,, w, ,, , ,’ ~ ‘

West Germany (Blue Angel)

Nordic Countries (White Swan)

Japan (EcoMark)

United States (ScientificCertification Systems)* United States (Green Seal)

Eco-labels are intended to identify environmentally preferredproducts for consumers. Above are government-sponsored labelsfrom four foreign programs and two private U.S. labels.*NOTE: The SCS label will provide comparative data on environmental

attributes (see figure 4-l).

has no national program, but two private labelingefforts are underway (figure 1-5).

Product packaging, perhaps the most visiblecomponent of the post-consumer waste stream,

continues to be the target of control measures thatinclude bans, taxes, deposits, and recycling require-ments. One of the most dramatic initiatives isGermany’s Packaging Waste Law, which givesmanufacturers and distributors the responsibility forrecovering and recycling their own packagingwastes. In fact, the idea of shifting the burden ofdealing with discarded products from municipalitiesto manufacturers appears to be gaining momentumin Europe, and may soon be extended to durablegoods, such as household appliances and automo-biles. This statutory coupling of manufacturing withpost-consumer recycling is forcing manufacturers—including U.S.-based manufacturers with subsidiariesin Europe—to change the way they design products.

The European Community is wrestling with theproblem of harmonizing the different environmentalproduct standards and recycling laws of membercountries with the approach of the Single Market in1992. These laws have proved contentious in thepast, and harmonization is not yet in sight. Recentcontroversies over whether countries can restrictimports of goods deemed harmful to health or theenvironment, or whether such restrictions constitutenontariff barriers to trade, suggest that the harmoni-zation of international environmental product poli-cies is becoming a thorny problem that will have tobe resolved in future negotiations under the GeneralAgreement on Tariffs and Trade (GATT’) and otherinternational agreements.10

Many States within the United States are alsoenacting policies aimed at reducing the environ-mental impacts of products. These measures includemandating industry plans to reduce their use of toxicchemicals, mandating the disclosure of the use ofhazardous chemicals in products, and establishingstandard definitions for advertisers’ use of terms like“recycled.” States have also enacted some targetedproduct control measures such as recycled contentrequirements for newspaper, bans and taxes onspecific packages, mandated manufacturer take-back of batteries, and tax incentives for recycling.The lack of uniform Federal environmental stand-ards for products is alarming to industry, which fearshaving to satisfy 50 different State regulations. Thisprospect is especially of concern for productsdistributed through national networks.

10 For ~ Ovemiew of tie issues, see tie US. congress, Office of Technology Assessment Trade and Environment: conjlicts and Oppmunities,OTA-BP-ITE-94 (Washington DC: U.S. Government Printing Office, May 1992).


The United States cannot be said to be “behind”other countries in the development of environmentalpolicies that encourage green product design. In-deed, many European countries look enviously atU.S. environmental policies such as auto emissionsstandards, or the timetable for phaseout of CFCproduction and use, which are among the mostaggressive in the world. Some U.S. chemical compa-nies are acknowledged world leaders in wasteprevention techniques.

It is more accurate to say that the U.S. approachdiffers substantially from the approaches beingtaken abroad, and these differences could createconflicts in the future. Whereas some of the ‘greener’European countries (especially Germany, the Neth-erlands, and the Nordic countries) increasingly focuson the environmental attributes of products at thenational level, U.S. policies continue to focus onregulating industrial waste streams. Except in caseswhere products pose a clear threat to human health(e.g., some pesticides, PCBs, leaded gasoline andpaint), the Federal Government has been reluctant toregulate the environmental attributes of productsdirectly. For example, the Resource Conservationand Recovery Act regulates ‘‘hazardous” industrialwaste closely, but delegates the primary responsibil-ity for product disposal and ‘‘non-hazardous” solidwaste management to the States.11

OTA finds no compelling reason for U.S. policiesto necessarily imitate the product control policies inGermany or other countries (although monitoringthe implementation of these initiatives could providevaluable lessons for the United States). In fact, manyobservers believe that some of the more extrememeasures, such as Germany’s mandatory take-backprovisions for packaging waste, will prove to becostly and difficult to implement.

Nevertheless, the rapid evolution of environ-mental product policy, both in the States and abroad,suggests that the Federal Government needs tobecome more strongly involved for two reasons: 1)to keep abreast of technology and policy develop-ments, and 2) to help shape policies that reducebarriers to interstate commerce and internationaltrade. Options for greater Federal involvement arediscussed below.

SHAPING ENVIRONMENTALPOLICIES THAT ENCOURAGE

GREEN DESIGN

Some U.S. companies argue that existing marketforces and environmental regulations are sufficientto encourage green design. They tend to view newenvironmental constraints on the design of productsas a threat to their competitiveness and a drag oneconomic growth, especially during an economicrecession. These companies are reluctant to redesignestablished products to achieve environmental bene-fits that have little value or visibility to theircustomers.

In fact, companies already have a number ofincentives to move toward green design. By reduc-ing the quantity of materials used in products, theycan reduce manufacturing costs; by reducing thehazardous material content of products, they canreduce the rising costs of pollution control, wastedisposal, and potential liability. There are alsoopportunities to gain consumer loyalty by enhancingthe environmental attributes of their products. Theseincentives are already having an effect on the waymany companies do business: for example, less toxicsubstitutes for heavy metals are being adopted insuch products as inks, paints, and batteries; environ-mental advertising is being used to sell a range ofproducts from gasoline to fabric softener; and moreand more companies have recognized the linkagesbetween improved product quality and improvedenvironmental quality.

Even if Congress takes no further action, theseincentives can be expected to continue in the future.For example, as permitted landfill capacity contin-ues to shrink, waste disposal costs should increase,providing companies with greater incentives toreduce their wastes. Implementation of tougheremissions standards under the Clean Air Act Amend-ments of 1990 will increase pressures on companiesto reduce their use of hazardous solvents and othervolatile organic compounds. Various States will nodoubt continue to pass legislation to regulate theenvironmental attributes of products and wastestreams. And as consumers become more attuned toenvironmental concerns, they will increasingly de-

ll I-kNTwvm, the R- r~utho~ationdebate has involved a number of new proposals that would establish natior.ud requirements fOrPIOduCt desi~including man&tory recycled conten$ reduced toxic chemical content and government procurement of recycled products.


Photo credit: “Selling Green. ” Copyright 1991 by Consumers Union ofU. S., Inc., Yonkers, NY 10703-1057. Repnntedbypermission from

CONSUMER REPORTS, October 1991.

This collage of fictional packages illustrates the trendtoward environmental marketing.

mand that manufacturers take more responsibilityfor the environmental impacts of their products.

But OTA finds that there are four specific areas ofneed that existing market forces or regulations donot adequately address, and that are uniquely theresponsibility of the Federal Government:

Research—At present, policymakers don’tknow what materials or waste streams are ofgreatest concern, or about how product designsmight be changed to address them most effec-tively. Private companies have no incentive toconduct this research.Credible information for consumers-Surveysshow that consumers are interested in greenproducts, but most don’t know what is ‘green.’As discussed above, defining what’s green is amultidimensional problem. In the absence ofFederal action to establish consistent groundrules defining terms and measurement meth-ods, the growing interest of consumers couldbecome dissipated in confusion and skepticism.Market distortions and environmental exter-nalities—Despite the existing incentives forgreen design noted above, critics of presentconsumption patterns argue that importantmarket distortions and environmental external-ities remain that encourage inefficient use ofmaterials and energy. Failure to internalize

●

these environmental costs into design andproduction decisions can make environmen-tally sound choices seem economically unat-tractive.Coordination and harmonization-OTA foundthat several research projects related to greendesign are being sponsored by various Federalagencies and offices, but that there is little or nocoordination among them. And unlike its majorcompetitors, the United States has no institu-tional focus at a national level for addressingenvironmental product policy.

Current Federal EffortsRelated to Green Design

OTA identified a number of ongoing Federalactivities that partially address these needs (tablel-l). EPA is most directly involved. For example, itsOffice of Research and Development has severalprojects underway to develop generic guidelines forgreen design. However, there are relevant projectsscattered through several other agencies, includingthe Department of Energy (DOE) and the NationalScience Foundation.

Several recent initiatives could help to removesome of the barriers to green design that exist incurrent Federal rules and regulations. In October1991, President George Bush signed ExecutiveOrder 12780, the Federal Recycling and Procure-ment Policy, which requires Federal agencies toincrease recycling and waste reduction efforts, andto encourage markets for recovered materials byfavoring the purchase of products with recycledcontent. The Department of Defense has issuedrecent directives emphasizing waste preventionthrough the acquisition process and through militaryspecifications and standards. Some 40,000 militaryspecifications requiring the use of hazardous materi-als are currently under review. These initiatives willhelp to create markets for green products.

There are also several ongoing activities thatcould improve the quality of information availableto consumers and citizen groups. EPA and theFederal Trade Commission (FTC) are developingguidelines for advertisers’ use of environmentalterms such as “recycled.” National standards foruse of these terms in advertising can give consumersconfidence that a product advertised as “source-reduced” or ‘‘recycled’ is really better for theenvironment. In the Pollution Prevention Act of


Table l-l—Federally Funded Programs Related to Green Design

Agency/office Program/activity Comments

Department of EnergyOff ice of Industrial Technologies Industrial Waste Reduction Program

Environmental Protection AgencyOffice of Research and Environmental Resource Guide

Development

Dynamic Case Studies on EnvironmentallyAdvanced Product Design

Life Cycle Assessment Methodology

Clean Products Case Studies

Safe Substitutes

Life Cycle Design Guidance Manual:Environmental Requirements and theProduct System

National Pollution Prevention Center

American Institute for Pollution Prevention

Office of Pollution Prevention Design for the Environmentand Toxics

National Science Foundation Engineering Design Research Center

This research and development program aims toidentify priority industrial waste streams, assessopportunities for addressing these waste streamsthrough redesigning products and production proc-esses, and technology transfer from national labo-ratories.

Contracted to the American Institute of Architects, thisproject will provide information to architects on thelife-cycle environmental impacts of instructionmaterials.

Contracted to the Resource Policy Institute in LosAngeles and the Product Life institute in Geneva,this project will explore case studies involving greenproduct design.

Contracted to Battelle, this project will develop standardmethodologies for conducting product life-cycleassessments.

Contracted to INFORM Inc., this project will providecase studies of green design, especially the re-duced use of toxic substances in products.

Contracted to the University of Tennessee, this projectwill identify priority toxic chemicals and evaluatepossible substitutes.

Contracted to the University of Michigan, this manualwill explore how designers can incorporate Iife-cycleinformation into their designs.

Located at the University of Michigan, this center isdeveloping waste prevention information modulesfor industrial and engineering design courses.

in association with the University of Cincinnati, theinstitute serves as a liaison to a broad cross-sectionof industry, with projects involving four aspects ofwaste prevention: education, economics, implemen-tation, and technology.

Proposed program to gather, coordinate, and dissemi-nate information on green design.

Located at Carnegie Mellon University, the center isorganizing a program to explore methods for greendesign.

SOURCE: Office of Technology Assessment.

1990, Congress required manufacturers who reporttheir releases of toxic chemicals for the ToxicRelease Inventory (TRI)12 to also report how thesereleases were affected by product and processredesign. When this provision is implemented, itcould become a valuable source of information in anarea where little information currently exists: howproduct design choices affect industrial wastestreams.

In the short term, Congress can make a good starttoward encouraging green design by using itsoversight powers to ensure that these ongoingactivities are carried through to their conclusion, and

that the provisions of the Pollution Prevention Actare implemented expeditiously.

Long-Term Options

In the longer term, Congress may wish to addressthe needs identified above more directly. Theseneeds are discussed in greater detail below.

Research

Of critical importance is to identify what materi-als and products pose the greatest risks to humanhealth and the environment. Without this informa-tion, Congress cannot intelligently set priorities for

IZ ~ r~fied ~der Title III of tie sup-d Amendments and Reauthorization Act of 1986.


environmental policy. Congress could direct EPAand DOE to identify a short list of priority materials,products, and waste streams; identify areas whereadditional data are needed to assess their health andenvironmental impacts; and develop quantitativemodels showing how these high-risk materials flowthrough the economy.

Research is also needed to develop techniques formeasuring the environmental impact of products andsystems, to better understand how the businessclimate and corporate culture affect product designdecisions vis-a-vis the environment, and to explorethe costs and benefits of various policy options suchas manufacturer take-back requirements.

Credible Information for Consumers

As discussed above, national standard definitionsfor advertisers’ use of environmental terms couldalleviate consumer confusion associated with cur-rent environmental claims. An important goal for thefuture will be to determine how to credit productsthat feature waste prevention in regulations andgovernment procurement programs that are cur-rently focused on recycling and recycled content.For example, should waste prevention be measuredwith respect to waste generated in some previousbase year, or with respect to other comparableproducts in the current year?

The United States has two small, private eco-labeling efforts underway. One potential concern isthat a variety of private labels based on differentappraisal methods could lead to confusion aboutwhich products are actually better for the environ-ment. To address this problem, Congress coulddesignate EPA to develop standards for the certifica-tion of private eco-labeling programs. This mightgive consumers confidence that products carryingcertified eco-labels are in fact better for the environ-ment. Alternatively, it could appoint a blue-ribboncommission to oversee the establishment of anindependent, national eco-labeling program similarto those of other countries.

Where the disclosure of public information onindustrial waste streams has been mandated byCongress, e.g., through the Toxic Release Inventory,this has proven to be a powerful motivation forcompanies to change their designs and manufactur-ing processes. Expanded industry reporting require-ments under TRI could improve the information onmaterials flows available to public interest groups

I . . ., ,, . . . 4

Credit: Wayne Stayskal, T&npa Tribune

and ultimately to consumers. This might involveexpanding the number of reportable chemicals, thetypes of industries required to report, or expandingreporting requirements themselves to include theactual use of priority chemicals in products andprocesses, not just the release of these chemicals tothe environment. However, unless these require-ments are narrowly targeted on chemicals or materi-als of special concern (see research needs above),they would significantly increase industry’s report-ing costs, and might not result in a commensuratereduction of environmental risk.

Market Distortionsand Environmental Externalities

Products have environmental impacts at everystage of their life cycle. Yet, many of these are notaccounted for in the prices of materials and products.On the production side, there are governmentsubsidies or special tax treatment for the extractionof virgin materials (e.g., below-cost timber sales andmineral depletion allowances), and many “non-hazardous” industrial solid wastes (e.g., mine tail-ings or manufacturing wastes that are managedon-site) with significant environmental impacts arenot regulated at the Federal level. On the consump-tion side, consumers often do not pay the fullenvironmental costs of products that are consumedor dissipated during use (e.g., gasoline, cleaners,agricultural chemicals), or the full cost of solid wastedisposal.

Table 1-2 presents a menu of regulatory andmarket-based incentives that have been proposed toaddress environmental problems associated with theflow of goods and materials through the economy.


Table 1-2—Policy Options That Could Affect Materials Flows

Life-cycle stage Regulatory instruments Economic instruments

Manufacturing

Raw material extraction Regulate mining, oil, and gas non-hazardous solidand processing wastes under the Resource Conservation and Re-

covery Act (RCRA).Establish depletion quotas on extraction and import of

virgin materials.

Tighten regulations under Clean Air Act, Clean WaterAct, and RCRA.

Regulate non-hazardous industrial waste under RCRA.Mandate disclosure of toxic materials use.Raise Corporate Average Fuel Economy Standards for

automobiles.Mandate recycled content in products.Mandate manufacturer take-back and recycling of

products.Regulate product composition, e.g., volatile organic

compounds or heavy metals.Establish requirements for product reuse, recyclability,

or biodegradability.Ban or phase out hazardous chemicals.Mandate toxic use reduction.

Purchase, use, and Mandate consumer separation of materials for recy-disposal cling.

Waste management Tighten regulation of waste management facilitiesunder RCRA.

Ban disposal of hazardous products in landfills andincinerators.

Mandate recycling diversion rates for various materials.Exempt recyclers of hazardous wastes from RCRA

Subtitle C.Establish a moratorium on construction of new landfills

and incinerators.

Eliminate special tax treatment for extraction ofvirgin materials, and subsidies for agriculture.

Tax the production of virgin materials.

Tax industrial emissions, effluents, and hazardouswastes.

Establish tradable emissions permits.Tax the carbon content of fuels.Establish tradable recycling credits.Tax the use of virgin toxic materials.Create tax credits for use of recycled materials.Establish a grant fund for clean technology re-

search.

Establish weight/volume-based waste disposal fees.Tax hazardous or hard-to-dispose products.Establish a deposit-refund system for packaging or

hazardous products.Establish a fee/rebate system based on a product’s

energy efficiency.Tax gasoline.

Tax emissions or effluents from waste managementfacilities.

Establish surcharges on wastes delivered tolandfills or incinerators.

SOURCE: Offics of Technology Assessment.

These options are organized according to their pointof greatest impact in the product life cycle. Eachcould have an impact on product design, but ananalysis of the design implications of these optionsis beyond the scope of this report. However, OTAoffers three guiding principles that policymakersshould consider as they evaluate these options (seebelow).

Coordination and Harmonization

Green design is. a multidisciplinary subject thatdoes not fit comfortably within the mission of anysingle Federal agency. For instance, EPA is orga-nized around regulatory responsibilities for protect-ing air, water, and land; its technical expertise indesign and manufacturing areas is slight. TheDepartment of Commerce (DOC), on the other hand,is concerned with the competitiveness of industrialsectors, but has little environmental expertise. DOE’s

national labs have considerable experience thatcould be brought to bear on improving the efficiencyof industrial energy use and waste prevention, butenvironmental quality has not traditionally been apart of DOE’s mission. The story is much the samewith other agencies.

As described here, green design refers not to arigid set of product attributes, but rather to adecision process whose objectives depend uponthe specific environmental problems to be ad-dressed. This suggests that the most meaningful wayin which the Federal Government can encouragegreen design is through multiagency initiativesorganized around particular environmental prob-lems, policy issues, or industrial sectors. Thesecollaborations are beginning to be formed on an adhoc basis. For instance, EPA is working with theDepartment of Agriculture to promote waste preven-


tion in agricultural chemical use. EPA, DOE, andDOC are collaborating in a joint grant program withStates to fund research on reducing the environ-mental impacts of industrial processes.13 Theseefforts are a start; however, much more could bedone in the following areas:

●

●

●

●

Promoting information exchange-Current mech-anisms for disseminating information on rele-vant research activities in various agencies areonly partially effective. A central repositorycontaining information on all relevant Federalresearch activities would be helpful.Promoting system-oriented design solutions—A greener transportation sector, for example,may involve not only improved vehicle fuelefficiency, but better management of materialsused in automotive, rail, aviation, etc., as wellas changes in urban design. A multiagencyperspective could provide a more holisticanalysis of total sectoral issues, through fo-rums, grant programs, etc.Harmonizing State and Federal environmentalproduct policies—Policy guidance is needed tohelp define the circumstances under whichFederal standards preempting State and localproduct control laws may be justified, andwhere they are not.Coordinating policy development on interna-tional aspects of the environment, U.S. com-petitiveness, trade, and technology--At pre-sent, responsibility for development of U.S.policy in these areas is not clearly defined, witheach Federal agency having its own agenda.

To address these needs, Congress could:

*

●

●

Provide funding for a central electronic net-work listing current Federal research projects,case studies, and bibliographic materials relat-ing to green design.Use its oversight powers to clarify whichagencies have lead responsibility for policydevelopment on interstate and internationalaspects of U.S. environmental product policy.Ensure that green design considerations areintegrated into the charter of any new environ-mental or technological organizations nowbeing proposed before Congress, such as theNational Institutes for the Environment or aCivilian Technology Agency.

In the end, the institutional details are lessimportant than a recognition on the part of Congressand the Administration that Federal leadership isneeded to take advantage of opportunities such asgreen design that do not fall neatly within themission of any single agency.

GUIDING PRINCIPLES FORPOLICY DEVELOPMENT

The discussion above suggests three generalprinciples that Congress can use to develop environ-mental policies that encourage, rather than inhibit,green design.

Principle 1: Identify the root problem and defineit clearly.

One of the biggest challenges in selecting a policystrategy is clearly defining the problem to beaddressed. One difficulty is that products and wastestreams have multiple environmental impacts thatcannot be easily disentangled. Policymakers may beconcerned with the quantity of a particular wastestream, its toxicity, or persistence in the environ-ment. Policies aimed at solving one problem mayhave unintended negative effects on another; forexample, requiring automobiles to be made fromcurrently recyclable materials could adversely affecttheir fuel efficiency. Inevitably, tradeoffs and valuejudgments must be made as to which environmentalimpacts are the most important.

Disagreements about how to define the environ-mental problem may also reflect more fundamentalphilosophical differences. Industry tends to framethe problem in terms of reducing the quantity ofwaste destined for disposal, while environmentalgroups often focus on threats to natural resourcesand ecological “sustainability.” These differentproblem statements lead to different policy prescrip-tions and different ideas about what constitutesgreen design. Clearly defining the problem to beaddressed can help to elevate the level of debate andto identify possible areas of compromise.

In the absence of a clearly defined problem, itbecomes easy to confuse means and ends. Proxiesfor environmental quality, such as recycling, cancome to be perceived as ends in themselves, ratherthan as one of several strategies for reducing solid

13 me Pmwm i5 c~led NatiOn~ Industi Competitiveness through Efficiency: Energy, EnViromnenL fionomics ~~3).


waste. By mandating that products and packagingcontain a minimum recycled content, for instance,Congress would certainly encourage product design-ers to use recovered materials in packaging; but thiswould not necessarily result in less waste overall.Perversely, this could even lead to more waste,especially if designs featuring waste prevention arethereby discouraged. If the objective is to reduce theamount of solid waste generated, MSW policies andgovernment procurement programs should makeallowances for product designs that feature wasteprevention.

Defining the problem properly must entail someconsideration of environmental risks. OTA findsthat policymakers currently lack critical informationon how materials flow through the economy andabout the relative risks of different materials andproducts. For example, 10 States have passedlegislation banning the use of heavy metals inpackaging, even though this source contributes only4 to 7 percent of heavy metals in landfills andincinerators. Without research to develop informa-tion on materials flows and relative risks, resourcesare likely to be directed toward the most visible

Photo credit: Dupont Magazine (July/August 1991)

A thin plastic milk pouch uses less material than atraditional paperboard carton, and takes up lessspace in a landfill.

problems, rather than those that pose the greatestenvironmental risks.

Principle 2: Give designers the maximum flexi-bility that is consistent with solving the prob-lem.

Materials technology options are proliferatingrapidly, and product impacts on the environment arenearly always multidimensional. Policies should becrafted to give designers as much flexibility aspossible to find the best solutions, within a frame-work that protects human health and the environ-ment. Rigid Federal mandates that impose predeter-mined design solutions (such as bans on the use ofcertain materials) are likely to be inefficient, andshould be avoided if possible. Flexibility can beachieved through a variety of means, includingflexible regulations, economic instruments, andnegotiated voluntary agreements with industry.

One tradeoff for increasing policy flexibility islikely to be increased costs of policy monitoring andenforcement. For example, verifying compliancewith a ban on the use of a given material or chemicalrequires less information than verifying compliancewith voluntary agreements or flexible regulations.For this more flexible approach to work, the cost ofdemonstrating compliance will probably have to beborne by industry.

Principle 3: Encourage a systems approach togreen design.

20 w Green Products by Design: Choices for a Cleaner Environment

If policymakers focus exclusively on addressingthe environmental attributes of products, as opposedto the systems in which products are manufactured,used, and disposed, they are likely to miss thebiggest opportunities for green design.

A system-oriented design approach can be en-couraged either directly by regulation, or indirectlythrough economic incentives. Recycled contentregulations or manufacturer take-back requirementsare examples of a regulatory coupling betweenmanufacturing and waste management. The pro-posal of the German Government to require automanufacturers to take back and recycle their cars, forexample, has stimulated the German automakers torethink the entire ‘‘ecology’ of auto production anddisposal (box l-A). This approach may be moreappropriate for high-value, durable products than fornondurable or disposable products.

An alternative to take-back regulations is toindirectly encourage designers to take a systemsapproach by using economic instruments to internal-ize the costs of environmental services. This ap-proach would rely on market forces to sort out whatnew interfirm relationships make sense econom-ically, while giving designers the flexibility todesign products with the best combination of cost,performance, and least environmental impact. Forexample, a substantial carbon tax on fuels couldhave a dramatic impact on the systems by whichproducts are manufactured, distributed, and dis-

posed, because fuels are consumed at every stage ofthe product life cycle.

CONCLUSIONGreen product design offers a new way of

addressing environmental problems. By recastingpollution concerns as product design challenges, andparticularly by encouraging designers to think morebroadly about production and consumption systems,policymakers can address environmental problemsin ways that would not have been apparent from anarrow focus on waste streams alone.

The flow of materials and products through theworld economy has a critical influence on botheconomic growth and the environment. These flowsare determined in part by design decisions. There-fore, policymakers should strive to make greenproduct design an integral part of strategies toimprove competitiveness and environmental qual-ity. OTA’s analysis suggests that simply providinginformation to designers and consumers about theenvironmental impacts of products and wastestreams is not enough. To move ahead, the environ-mental costs of production, consumption, and dis-posal should be accounted for at each stage of theproduct life cycle. The challenge to policymakers isto choose a mix of regulatory and economic instru-ments that target the right problems and givedesigners the flexibility to find innovative, environ-mentally elegant solutions.

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