Miljøprojekt, 1063/2006 - Integrated Supply Chain Information

Integrated Supply Chain Information

9 Conclusion and recommendations

9.1 The Framework

9.1 The Framework
9.2 The instruments

1. An integrated environmental and health communication system should be developed and agreed upon in EU. The Commission should therefore take initiative to elaborate a strategy for how to implement an “Integrated product chain environmental and health communication system”.

The results of the analysis clearly document the need for a stronger coordination of information systems that have similar target groups and objectives. Highest priority should be given to Eco-labels, EMAS and EPD's, but also the IPPC data collection and the Safety Data Sheet have many aspects, which should be co-ordinated with the 3 other schemes. The primary elements to be targeted are: 1) framework and guidelines, 2) data collection, management and reporting and 3) verification.

There are obvious benefits for the stakeholders – both those who apply the schemes (enterprises) and those who receive the information (down stream users, authorities and consumers). Perhaps one of the most important benefits is the maintenance of credibility and thus the future applicability and success of the systems.

2. Commission should initiate work for the preparation of an EU regulation for environmental product declarations (EPDs) based on the eco-label and EMAS framework

A prerequisite for the establishment of a coherent product (value) chain information system is the existence of an EPD system. An EPD may deliver LCA based data from the company to its suppliers and professional customers. EPD may therefore link together Eco-labels (target group: the consumers) and EMAS (target group: enterprises) and may be the system needed for EMAS to further develop into an environmental product management system (EMAS II).

3. The Competent bodies for EMAS, Eco-labels and EPD should merge into one single body to promote coherence between the schemes

The present management of the schemes is often governed by competent bodies from different agencies or sectors. To achieve a coherent EMAS, Eco-label and EPD system, one competent body should be given the responsibility for the maintenance and promotion of the schemes.

4. A common life cycle analysis (LCA) framework should be established at the community level.

A second prerequisite for a coherent system is the establishment of common data collection framework. Presently, the background documents for the elaboration of Eco-label criteria are based on life cycle thinking – although the present analysis documents that this is not the case for all product groups partly due to the lack of appropriate requirements and guidelines. Some member countries are in the process of establishing their own LCA based national EPD schemes (e.g. Italy, Sweden and Denmark) which to some extend is informal co-ordinated. If no initiative is taken by the Commission to elaborate a common understanding of life cycle analysis there will soon be a number of more or less different national schemes which to some extend may interfere with one of the most important objectives of the EU: The free movement of goods and services. The work for a common EU LCA framework should be based on the relevant ISO standard and should ideally be co-ordinated with related product policy areas.

5. A common framework for verification of environmental and health information systems should be established.

A third prerequisite is that the extent and quality of the third party verification of the various systems are coherent. Systems with a weak independent verification may not be viewed as credible. Presently, the SDS scheme is presumably the weakest verified system as only a retrospective spot-check is performed. But also the third party verification system of Eco-labels is problematic as there has been established no common requirements and guidelines for the verification performed by the various verification bodies.The basis for the establishment of a credible common third party verification system may be EMAS, as all needed requirements and guidelines for certification and accreditation have been established.An accredited certification system ensures that the same level of verification is performed in all member countries and thus that the burden for the users are the same to achieve and maintain licences.

6. Guidelines and other background documents elaborated for the purpose of a single scheme should be made available for users of other relevant schemes.

In all schemes a number of documents are elaborated to support the implementation, e.g. background reports and criteria documents for the eco-label; BREF documents for identification of best available cleaner technology (IPPC), guidance documents for environmental management (EMAS), and PCR documents for EPD. These documents - although targeted at a specific scheme - are valuable for all IPPC, EMAS, EPD and eco-label users and should therefore be disseminated to a broader user group, i.e. by elaboration and distribution of easy-to-read summaries of the documents to the users or target groups of all schemes.

9.2 The instruments

9.2.1 IPPC and EMAS

7. The regulatory requirements and guidance regarding EMAS initial review and the application for IPPC should be co-ordinated to facilitate a straightforward reuse of the documents

There are advantages and benefits for companies working with both the IPPC requirements and EMAS in a co-operated manner, because the schemes are site and facility based and both have focus on improving environmental performance of the production site.

Implementing EMAS makes it easier to comply with the requirements of the IPPC Directive, for example regarding the preparation of applications and elaboration of monitoring reports. EMAS brings the company a management system by which the work may be organized and structured in a systematic approach. This is also valid the other way around. Having an IPPC application in place provides a quick start to the initial environmental review in EMAS.

8. The BREF documents should be disseminated in an appropriate way to assist also companies working with EMS, as these documents include valuable information regarding up-front technology.

The idea of the BREF documents describing BAT is useful for EMAS companies defining new targets for environmental performance. The documents should be used more widely and published in a form and a language, which can be applied by a broader audience, in a product chain perspective in relation to supply chain management and dialogue.

9. EPER type information should be applied in downstream product chain communication provided that the data may be converted from emission to product related.

EPER type information (emissions of up to 50 hazardous substances) is a part of the EMAS statement and should be applied in down stream product chain communication tools (EPD, eco-label) as well. The EPER information can be used as an assessment tool to estimate environmental impacts for products e.g. by determination of toxicity scores for the 50 substances and conversion of EPER site specific data to product specific data. The procedures for converting the data may be collected from existing guidelines for life cycle assessments.

9.2.2 EMAS and Eco-label

10. As complementary schemes with similar objectives, EMAS and the Eco-label should be strongly co-ordinated and anchored in the same competent body forum. A strong co-ordination will be efficient, as it will prevent the duplication of work and ease interpretation by the users of both schemes

EMAS and the various eco-label schemes are in the principle complementary tools.

EMAS serves as an instrument to ensure that the environmental data are collected and managed according to established procedures and to ensure a process towards continual improvement of the environmental performance.
The Eco-label criteria assist companies identifying significant environmental aspects, setting targets for the environmental improvements and – by the product label - communicating the achievements to the end-user.

Both schemes require that the participant collect data on its environmental aspects. In EMAS, the participants must identify their significant environmental aspects and document and how they were identified. The eco-label criteria as well as the background document for establishing the criteria point out several issues that could be significant for environmental improvement for any company, within the product group. Therefore, the Eco-label assists the EMAS company (or other enterprises working with environmental improvements) identifying the significant aspects.

The criteria is regarded as highly credible as they are stringent and set by an authority competent body. Therefore, the criteria are valuable bench markers for the product group in question.

Many criteria documents refer to Environmental Management System as helpful for complying with an Eco-label. EMAS does not yet have the same recommendation regarding the Eco-label, although the product dimension is included in EMAS II. EMAS has a set of guidelines on several issues of building up a management system but still not a guide on how to incorporate the product dimension. On this item, a reference to the EU-Eco-label should be made.

11. The elaboration of documents defining the requirements under both EMAS and the Eco-label should be strongly coordinated.

There are many examples of EMAS and Eco-labels setting similar requirement for the same issues. The requirements may not be expressed in precisely the same manner, but there is a clear correspondence. For example, some Eco-label criteria documents have requirements for compliance monitoring procedure, training and awareness among employees – aspects that are covered by the EMAS requirements as well.

For other product groups there is a complete overlap in requirements (although in different wording). These are found in service oriented product groups e.g. the tourist accommodation sector. In other sectors the requirements are very far from each other.

9.2.3 Environmental Product Declaration (EPD) and the EU Eco-label

12. The EU Eco-label should be based on a strong LCA framework and should Commission decide to establish an EPD scheme, the LCA framework should apply for the EPD as well.

It is absolutely essential to establish common procedures and guidelines for the LCA-foundation of the EU Eco-label. For some of the Eco-label criterion documents today, the recentness and the quality of the applied lifecycle investigations may be questioned. An example is the background document for indoor paints and varnishes. The criteria are reviewed every 6 years, latest 2002. Although product innovation has been high within this product group, the categories are identified from an LCA conducted in 1991.

Eco-labels and EPD should make use of the same LCA framework for developing background documentation and for the Product Category Rules (PCR) respectively.

A common well-defined LCA fundament facilitates the use of PCR for the elaboration of eco-label criteria and eco-label background documentation for PCR.

13. A future EU-EPD scheme should build upon the present EU Eco-label organisational framework.

If the Commission decides to implement an EPD scheme, it is strongly recommended that the Eco-label and the EPD schemes be merged to provide a coordination of technical tools, activities and procedures.

The two schemes should share a common product sector PCR foundation. This relative broad PCR may be further specified to cover the need for establishing Eco-label criteria for sub-categories of a product area. An example is the Swedish EPD scheme PCR for chemical products. The PCR is relatively broad covering chemical products in general. This PCR may be subdivided into narrower product categories in order to define EU Eco-label criteria for chemical/technical products.

9.2.4 Safety Data Sheets and the EU Eco-label

14. Verification of SDS should be strengthened by the EU member countries to reach a similar stringency and credibility as other EU based information schemes.

The present authority control of SDS is in the form of infrequent spot check of compliance. This compliance control should be strengthened to be at the same level as Eco-labels and EMAS, e.g. either by establishing a 3rd party verification system or to follow the authority verification system applied for IPPC. The reported high frequent non-compliance for SDS is a barrier for making direct use of the included information by other schemes like EMAS and Eco-labels.

15. Requirements in Eco-label criteria documents regarding chemicals should as far as possible reuse the information included in SDS. This would ease the possibility for the applier to collect data.

The information needed in order to prepare a SDS and to examine whether a product is in compliance with Eco-label criteria is basically the same (detailed information on the chemical composition). The criteria for chemicals are often defined in a way, which is not in accordance with the requirements for the SDS, e.g. lower limit values for reporting the concentration of dangerous substances in SDS compared to the limit values required by Eco-labels.

Some information has to be added to the SDS, if it is to be used as bearer of information relating to Eco-label criteria. Guidance should be given regarding which type of information may be requested by the supplier as a part of the Safety Data Sheet, including how and where to incorporate this information

16. SDS and the requirements in the coming new EU chemical legislation (REACH)

According to REACH, SDS' are to be the core communication tool regarding safe handling of chemicals (chemical substances, chemical preparations) and articles liberating chemical substances during use and disposal. As the aim of both REACH and the Eco-label is to promote the market mechanism to increase the use of products giving rise to less environmental and health impact, the role of SDS as a tool for documentation of products' compliance with Eco-labels may therefore be strengthened in the future. Competent authorities for Eco-labels and EMAS should analyse the need for input in relation to the preparation of the new chemicals regulation

9.2.5 Verification of EMAS, Eco-labels (and EPD)

17. A coordinated verification practice should be established between the 3rd party verified voluntary schemes.

Most companies are interested in a coherent verification system, especially the SMEs. In the SMEs it is often one single person who is in charge of and carries out all the work in relation to environmental management, including dialogue with authorities, application for Eco-label, internal audits in the EMS etc. etc. When it comes to verification by the authorities, the Eco-label controller and the EMAS verifier have their site visits at different times and the environmental manager must prepare each meeting individually although they are looking for more or less the same issues and the same documentation.

A common and integrated verification process of the voluntary information schemes could be established and would create benefits especially for SME's. A coordinated process may lead to an increased credibility of the individual schemes, especially the Eco-label scheme, which today have no common European verification framework, which may lead to different procedures in member countries.

There are no formal restrictions in EMAS regarding an integrated verification process. On the contrary, EMAS already provides for inclusion of the product-oriented issues.

Many elements in a verification process are identical and have the same headings. A closer look reveals a number of differences, however:

Document review is a significant part in all three schemes – but the verifier has to look through different documents
Validation of data is included in all three schemes – but it is not the same data. EMAS requires data at an annual basis as well as total volume at the site, the Eco-label and the EPD require data related to the product and the two latter have different functional units
Site and control visits are elements in EMAS and the Eco-label and an option in the EPD.
Only EMAS has surveillance audits

The benefits might still depend on how the audit team is set up and on the personal skills of each auditor: That he is able to understand both the idea of a management system audit and a performance audit in relation to a product and able to create trust and confidence in the relationship with the client. This requires focus on both technical qualifications and personal skill.

18. Verification stringency and procedures should be similar for both voluntary and mandatory schemes having similar focus.

All 5 schemes analysed in the present study share the same overall objectives: To promote a reduction of loads influencing environmental and health quality. The efficiency of the schemes is among others dependent on the stringency of the applied verification systems. To increase the general understanding and the results of the effort in relation to the overall objectives, the verification systems of both mandatory (authority controlled) and voluntary schemes should be coordinated to achieve a similar stringency.