Manual on Product-Oriented Environmental Work

5 Product Orientation in the Environmental Management System

5.1 Assumptions and purpose
5.2 How do you implement the product-oriented approach?
5.2.1 From company-oriented to product-oriented
5.3 Aspects to which you must pay particular attention
5.4 Review of environmental impacts
5.4.1 Environmental review
5.4.2 Environmental aspects outside the company
5.4.3 Environmental aspects within the company
5.4.4 Responsibility
5.4.5 What data must be included?
5.5 Evaluation, prioritisation, continual improvements
5.5.1 Evaluation and prioritisation
5.5.2 Continual improvement
5.6 Statutory requirements and other requirements
5.6.1 Statutory requirements and other requirements
5.6.2 Monitoring the situation
5.7 How might your environmental policy, targets and action plans look?
5.7.1 Objectives, targets and action plans
5.8 How do you organise the work on productoriented environmental action?
5.8.1 Organisation and allocation of responsibilities
5.8.2 Need for training and checklists
5.9 How should communication be organised and handled?
5.9.1 In-house communication
5.9.2 External communication/dialogue
5.10 The management's review
5.11 The other elements in the environmental management system

5.1 Assumptions and purpose

Earlier chapters in this manual focused on clarification, planning and preparation of action plans for product-oriented work (Chapter 3) and have given you some concrete tools for product-orienting different departments and activities in your company (Chapter 4).

It is assumed that you are already working systematically with environmental aspects wholly or partially on the basis of the requirements in ISO 14001 or that you are at least acquainted with management systems (e.g. ISO 9001 or 14001). If you are not already working with environmental management in your company, you will find in this chapter various matters to which you must pay attention or check when you introduce the system. The chapter does not, however, provide general guidelines on constructing and implementing environmental management. Methods and tools for that purpose have been developed elsewhere - see, for example, the Danish EPA's website for more information (www.mst.dk).The recommendations in the chapter have been written to suit an existing environmental management system based on ISO 14001. If you do not have such a system, you must instead "translate" the recommendations to suit your own situation.

You may decide to build up an environmental management system concurrently with your product-oriented work. ISO 14001 states that the system must also include the indirect impacts of the company's activities. In popular terms, that means the impacts that lie outside the company's place of production. This is precisely the product-oriented approach, with which - depending on your level of ambition - all phases of the product's life cycle are to a varying extent also managed.

Working in a product-oriented way means working on continual improvement of the product, seen in a life cycle perspective.

The purpose of incorporating the product dimension in a real environmental management system (ISO 14001) is to ensure a productoriented approach at the strategic (management) level in your company.

There are several reasons for that:
to incorporate environmental aspects in your marketing and business strategy
to save time and money
to avoid suboptimisation in connection with measures to improve environmental performance
to ensure continual improvement at the product level as well
to use well functioning routines and documentation
to ensure communication and responsibility across the organisation.

If you are already working with environmental management, the product oriented approach is really only a supplement to the existing system, so you do not have to make any fundamental changes to the structure.

5.2 How do you implement the product-oriented approach?

The recommendations given in the manual for implementing the product oriented approach in an environmental management system are in accordance with the structure in ISO 14001. Figure 5.1 below shows the elements in the management system.

Look her!

Figure 5.1:
The structure in ISO 14001

The figure also shows where to go in the chapter for more information about the individual elements.

Table 5.2 shows where and what there may be a need to develop when incorporating the product dimension in your environmental management system.

Table 5.2:
Product orientation in the environmental management system

The environmental management system

Product orientation

Reviewing and assessing environmental impacts

You extend reviewing and assessment to include environmental impacts during the product's life cycle, in cluding in any export markets.The scope and degree of detail will depend on your level of ambition for your product-oriented work.

You ensure that current and coming legislation relating to the product is included in the criteria for selecting significant environmental impacts.

Environmental policy

You describe the product-oriented work in your environmental policy statement.

Planning

Your objectives and action plans cover the specific product aspects that you prioritise.

Implementation and

The management assigns responsibility and operation delegates tasks to the parts of the organisation that are affected by the product-oriented work.

You expand your purchasing and supplier control to ensure purchasing that corresponds to the chosen product-oriented work.

You train the employees in the aspects that are important for the product-oriented work.

You inform all the company's employees about the product-oriented work.

You include in your external communication information about proper use and disposal and about the production of the raw materials.

You supply documentation for the product(s)' environmental impacts.

You record and answer external enquiries concerning the product(s).

Control and corrective

Your own internal control covers the productaction oriented work,including any requirements about using specific tests or methods of measurement

The management's review

The management prioritises resources so that the product-oriented work is maintained and expanded with new targets that are coordinated with the company's business strategy


5.2.1 From company-oriented to productoriented

In a "traditional" environmental management system constructed, for example, on the basis of the requirements in the ISO 14001 standard, the focus is naturally on the production and the environmental impacts from the production. In an environmental management context, other departments, such as purchasing, sales, marketing or product development, are often less directly involved.That is natural when the aim is to reduce the environmental impacts from the production.

When, on the other hand, you want to incorporate the life cycle approach and focus on the entire environmental impact of your products, the other departments - particularly the product development department - become more important. Similarly, the external relations - particularly in the product chain - also become more important. The process is shown in figure 5.3.

Look here!

Figure 5.3:
From companyoriented to product-oriented environmental management

The figure illustrates the various departments in a company that are usually involved on an ad hoc basis in the company-oriented environmental management. Market demands - for example, from customers and consumers - are incorporated, but the focus is on environmental impacts in the production process. In product-oriented environmental management, most of the departments in the company participate actively. Market demands and expectations are handled in relation to the entire life cycle of the product(s).

In connection with the product orientation you should decide which departments are most vital to your action and what they can/must do. This includes deciding on the responsibilities each of the departments is to have.

The most important department naturally varies from company to company and also depends on what you want to achieve with the product orientation. Here are some examples:
If you yourselves design the products, the product development department is vital. Your product developers should therefore be trained or helped to incorporate environmental considerations from the idea phase to complete prototypes. Many environmental problems later in a product's life cycle can be avoided or reduced by action at the development stage. During the development of the product, the marketing department should ensure that the users' wishes and needs are analysed and incorporated from the start because the launch of the product and any "training" of the users must be evaluated and planned on an equal footing with the product itself. For many products it is necessary to create a market or at least make a special effort to make the product's environmental qualities visible - particularly if the price or habit is the users' main reason for buying your types of products.

The customers are asked about the environment

In connection with product development, Grundfos works with customer panels, where a number of present and potential customers are asked about their attitudes, wishes and expectations in a variety of areas, including environment. Experience shows that the customers do not at present attach particular importance to environmental aspects, but when asked directly, they find energy consumption important. That supports Grundfos' continual action to develop pumps with a reduced energy consumption.

If you want action together with or concerning your suppliers, the purchasing department is important, and the buyers also need tools for incorporating environmental considerations in their daily work. Besides participating in your own product development strategy by translating product specifications into requirements for the suppliers, the buyers are important in themselves because they demand more eco-friendly products. Just as you yourselves are sensitive to the wishes of the market, you help to create a market for other companies' more environmentally sound alternatives by demanding them - even in the case of products that are not particularly important for you - for example, office supplies.
If the environmental impacts depend on how the product is used, the sales and service departments are important because they can inform and possibly train the customers in correct use. In addition, the marketing department can gather information on the importance of environmental aspects in the market, compare with competitors, etc.
The management is always important. Without visible prioritisation and backing by the management, the process is almost doomed to come to a standstill at some point or other.

The various departments and their opportunities are discussed in Chapter 4, section 4.2. There, you will also find suggestions for "tools" for use by the departments in their product-oriented environmental work.

If you already have an environmental management system, you must start by reviewing it with "product glasses" on. It is important to start by gaining a clear picture of the extent to which the system also includes the product dimension before you get down to revising existing procedures.

In the following we give some pointers concerning possible significant changes to your present management system and about things to which you must pay attention in your review of the system. Importantly, we also explain how to incorporate the product dimension in practice.

5.3 Aspects to which you must pay particular attention

The main purpose of the environmental management system is to establish responsibility and authority for specific tasks, including ensuring continual improvement and documenting the work.You must make sure that there is a unifying principle all the way from your productoriented environmental policy, through objectives and targets, to the action plans.

Remember that there must still be coherence between your environmental policy, your environmental objectives and targets and your action plans.

In connection with the product orientation, you should take a close look at your present distribution of responsibilities. If a large part of the responsibility for your company's environmental work lies with a central environmental department, experience shows that responsibility for the individual tasks in connection with product orientation should be decentralised. The responsibility must lie with those responsible for the tasks in the day-to-day work. At the same time, it is important to ensure good coordination and information across the organisation. Particularly if the organisation is so large that coordination does not take place naturally, you should consider incorporating it in the procedures themselves.

On the documentation side, there may be special requirements that you want to live up to - for example, eco-label criteria, specific information for use in an environmental product declaration or information requested by the customers. Where you previously presumably organised your documentation to meet official requirements and your own internal control needs, your documentation must now be much broader and satisfy more needs. These needs can easily change from time to time, so make sure that you have the necessary data and can adjust them as needed.

Figures 5.4 and 5.5 show some major differences and similarities between a "traditional" environmental management system and a productoriented system.

Figure 5.4:
The process towards environmental action plans in "traditional" environment management

The purpose of the associated documentation is:
to keep tabs on your own internal control
to document achievement of the prescribed targets.

External requirements are also included in a "traditional" environmental management system, but often at a very general level (e.g. a desire to have a certified environmental management system). The systematic dialogue with the stakeholders on product aspects seen in a life cycle perspective is less pronounced. The market's expectations concerning the product are not usually an important part of the basis for prioritisation.

Figure 5.5:
The process towards environmental action plans in product-oriented environmental management

The purpose of the associated documentation is:
to keep tabs on the product's total environmental impacts
to document achievement of the targets set
to meet external stakeholders' need for information.

Figures 5.4 and 5.5 show that the external requirements and expectations have greater weight in a product-oriented environmental management system, and the requirements will often be rather specific in selected areas. Reviewing, significant environmental impacts, key figures, prioritisation, targets and action plans are now related to the product's entire life cycle.

For Coloplast, the change from traditional to product-oriented environmental management has had an effect.

Integration of product-oriented considerations

Coloplast is changing its environmental management system, partly with a view to achieving satisfactory integration of productoriented environmental considerations.

The targeted action has resulted in:

a new procedure for integration of environmental considerations in product development

preparation and control of mass balances for specific key products

organisational changes


The individual elements/areas where special focus is required, and where supplementary tools/checklists etc. will be needed, are described in the following sections.

5.4 Review of environmental impacts

5.4.1 Environmental review

The general aim of the initial review is to create an overview of environmental impacts related both to your own production and to your product( s). On that basis you must arrive at the significant environmental impacts and identify where they come from (the company's own production or other links in the product chain). Supplemented by workplace assessments, this provides a good basis for deciding which environmental and occupational health and safety impacts you must start working on (see also Tool 1 in Part B).

As the basis for your product-oriented work you must collect and process data for the product action you have decided on. The data must then be incorporated, registered and monitored in your environmental management system.

If you have an environmental management system, you will also have a data registration system. This must be adjusted because the data can rarely be used directly in life cycle assessments.

If you do not yet have an environmental management system, you should build up a data registration system so that the product dimension is included from the start.

If you have an environmental management system you will already have a lot of data - particularly production data (illustrated in figure 5.5).You must then determine what data already registered can be used in the product-oriented context and what you lack.You thus already have an operating control and registration system. However, you may need to expand this - see section 5.4.3 - because you must monitor and measure new data relating to the product in order to achieve improvements and supply documentation for your products.You will also have to adjust the procedures and instructions for monitoring and measuring data.

If you have to begin building up an environmental management system, you have a good opportunity of incorporating the products' life cycle from the start.You must focus on creating a clear picture of environmental impacts throughout the products' life cycle.You must build up an operating control and registration system that ensures that you regularly monitor and measure key data. This is important because it is your tool for controlling environmental targets and action plans. However, it is also a tool for supplying documentation for your products.

In figure 5.6, the traditional approach is shown in the hatched area, where the small boxes are your environmental aspects (processes associated with consumption of resources and emissions/discharges to soil, air and water, together with waste etc.).

Figure 5.6:
Review products’ environmental aspects

Whether you already have an environmental management system or are getting ready to build one up, in your product-oriented environmental work you must to some extent widen your focus to cover all levels in the products' life cycle - that means not only the phases raw materials/production of raw materials, use and disposal, but also the transport phase, which covers all transports in the product system. The scope will naturally depend on your chosen level of ambition. Part B of the manual explains clearly what data you should procure and how. For example, the initial environmental review can be based on data from the purchasing and accounts departments, wastewater permits and similar. Experience shows that you undoubtedly have a great deal of life cycle data in your systems, but you have to dig them out from the different sources.

It is very important to start by establishing an overview so that you can identify the significant environmental impacts and concentrate on them. Otherwise, you may easily risk data death. Start by focusing on the data you can get hold of easily.

It is also important to note that you do not have to clarify all product aspects all at once or clarify all of them in an equally detailed way. Like other environmental work, product orientation is a phased process in which you gradually tighten what you require of yourselves and others.

5.4.2 Environmental aspects outside the company

Regardless of your choice of product-oriented action, you will need to look beyond your own four walls, as outlined in figure 5.5.You must, for example, look at the production of the raw materials used in your products and at the distribution, use and disposal of the products.Tool 1 in Part B explains how to establish a clear picture of your products' environmental aspects within and outside the company. It is a case of creating lists of materials and flow diagrams in which you go through the entire life cycle of each product, the inputs and outputs, thereby gaining an overview of consumption, emissions and waste.

Tools 2-4 in Part B explain what to do with respect to eco-labels, environmental product declarations and external expectations. The tools can be used as aids in your product-oriented data collection.

You will find it advantageous to include in your review documentation obtained from suppliers, e.g. specific requirements concerning test methods, as required in the eco-label criteria. In practice, you can prepare a standard letter (form) for the relevant suppliers in which you ask them to state whether they live up to the requirements as set out, for example, in the eco-label criteria.You should then register the replies in your system and check at least once a year that the suppliers still live up to the requirements. Chapter 4, section 4.2.5, deals with the design of questionnaires and matters to be considered in that connection.

5.4.3 Environmental aspects within the company

For environmental aspects that have already been mapped in the company you may have to increase the degree of detail.You must map the actual processes involved in the production of the product or products selected in sufficient detail for consumption and emissions to be attributed to the individual product. In connection with environmental management systems, one usually has key figures for consumption and emissions per tonne finished product, per surface area or similar, or has a total figure for consumption for the company. It is not certain, either, that all processes in the company are involved in the production of the product or products on which you are focusing. If your product-oriented work includes occupational health and safety, you may also need to include the working environment more actively.

You must therefore review your records to see whether they can be used as they are or need to be supplemented by more a detailed review. This is particularly relevant if you make several types of products and your present registration - of energy consumption, for example - is at a general company level. In that case, you must either measure or calculate the energy consumption for the individual process you use to make the product( s). If you make several products at the same facility, then, using the same example, you must allocate the energy consumption to the individual products.You can use a qualified estimate for this, based, for example, on the value of the product.

You must also decide whether you have all the data you need for the environmental assessment.You should remember, however, that you do not have to go into too much detail before you know whether it is a major environmental impact you are looking at:

Use your time on the main impacts

In its life cycle assessment of three types of paint, Technos Schou A/S spent a lot of time distributing the environmental impacts in the production between processes and products. It subsequently found that these were of very little importance compared with impacts in other phases of the life cycle.

Source: Environmental Project, No. 488, 1999. Danish EPA.


5.4.4 Responsibility

Before starting on the data collection you must decide who is to be responsible for and participate in the review. Since the review relates both to your own production and the products' life cycle, it is important for the employees involved in the work to have some knowledge of environmental impacts within the various areas.

New employee groups or key persons from different departments must be involved when the environmental work is product-oriented. For example, it is a good idea to make the buyer responsible for contact with the suppliers, the sales representative for contact with the users/customers etc. (see section 4.2 in Chapter 4).

It may be practical to have different employees participate in the collection of data, but you must establish who is to be responsible for evaluating the data collected.

5.4.5 What data must be included?

If you have decided on a specific product strategy, e.g. eco-labelling of the products, the criteria for this give a useful indication of the data that must be collected and registered. However, you should be aware that even though the phases and focus areas that are relevant in a product perspective are indicated in the different sets of requirements, that does not necessarily mean that they are the most important action areas seen from your point of view.You should therefore not focus exclusively on these requirements but use them as a guide in connection with a more integrated consideration of the company's environmental aspects and planning of environmental measures.

5.5 Evaluation, prioritisation, continual improvements

5.5.1 Evaluation and prioritisation

On the basis of the results of your environmental review, you must evaluate the direct and indirect environmental impacts with a view to identifying the significant ones and listing possible environmental improvements. If, in your product work, you are guided by externally defined requirements, it is particularly important to note that with environmental management, it is not necessarily enough simply to meet these requirements - certified environmental management requires you to consider the significant environmental impacts and continually reduce them.

You should therefore be able to document whether the externally defined requirements are also the most important or whether other environmental impacts should be included as well. For example, the revision of the eco-label criteria or a new procurement guide for a product group does not automatically guarantee continual reduction of your significant environmental impacts.

Identification of significant environmental impacts is vital for formulating your environmental policy, prioritisation, targets and action plans. On this point you may therefore also need to expand the list of environmental impacts when the product is incorporated and expand your criteria for prioritising significant environmental impacts.

As an aid in evaluating and identifying significant environmental impacts, you should prepare criteria for assessing the environmental impacts. The assessment criteria are almost the same as in ordinary environmental management - but seen in a life cycle perspective. In the subsequent prioritisation of action, the prioritisation criteria should reflect the purpose of your product work.

In both the eco-label criteria and the Green Buying Guides, the significant environmental impacts of a product in a life cycle perspective are listed and prioritised. In connection with the preparation of the set of requirements, the environmental impacts that you must be able to document (e.g. emissions, use of chemicals, etc.) have been found significant and been prioritised.You may nevertheless have to add other criteria for significance.Your company is perhaps subject to special restrictions concerning, for example, wastewater or to special conditions relating to disposal of the product.

You will need additional forms or checklists to carry out an assessment and the subsequent prioritisation. The following box gives some examples of where you can find the necessary information.

The Danish EPA's List of Undesirable Substances (see the reference list)

Statutory requirements

The result of the product screening (tool 1 in Part B)

Environmental projects (www.mst.dk)

Your trade association and any exchange of experience groups

Green Buying Guides

Eco-label criteria

Danish Working Environment Authority (WEA)'s List of Effects of Problematical Substances and Materials (see the reference list)

WEA's Order on Substances and Materials (www.arbejdstilsynet.dk)


The point of the prioritisation is that when working with the productoriented approach, you must include far more elements than your own environmental aspects/environmental impacts in the production, e.g. use and disposal or another product focus, when you are working with the product-oriented approach.

When prioritising your environmental aspects, you should at least include the following factors:
significant environmental impacts
statutory requirements
technical possibilities
financial framework
operational and business assumptions
stakeholders' requirements and views.

5.5.2 Continual improvement

To ensure continual improvement, you should set environmental targets for the various departments/areas that are essential for the product work, e.g. in connection with product development or purchasing or as part of your after-sales service and maintenance.

5.5.2.1 Product development

The product development department is vital for environmental improvement of the product. It is during development of the product, including the choice of design and function and the choice of materials, that you take vital decisions that affect the product's total environmental impact during its life cycle. The choice of materials and processes and the possibility of substitution will have an effect throughout the product's life cycle, while design will have a big effect on whether and, if so, how the product can be separated into components when the time comes to dispose of it. The department is of importance to the lifetime and use of the product.

With the product-oriented approach, new requirements will thus be made concerning areas/elements that are to be monitored, measured and controlled. Depending on the areas you prioritise, you will need to prepare procedures, special checklists and new forms to ensure and document that you include relevant environmental considerations in a structured and targeted way when changing existing products or developing new ones.

In procedures, instructions and forms you should decide what to do about:

  1. substitution or reduction of hazardous substances
  2. substitution or reduction of non-renewable resources
  3. reduction of energy consumption, including energy consumption for transport, where weight and volume may be of great importance
  4. design with a view to repair, reuse or recycling/recovery of materials - and the longest possible lifetime.

When considering the above points you must make sure that you look at the product in a life cycle perspective. See also section 4.2.3 for amplification.

These written procedures should naturally be designed in the same way as your other documents.

APC Denmark's environmental instruction to product developers

The product specification for a new product must include decisions on the following points:

  1. choice of materials

  2. consumption of materials

  3. recycling proportion

  4. energy consumption

  5. packaging

  6. disposal/recycling/return scheme

  7. lifetime/possibilities for repair/possibilities for upgrading

  8. information for environmental declaration

Each point must be specified, e.g. point 3:

All the materials used (metal/plastic) must as far as possible be labelled to enable reuse/recycling

Avoid mixing materials

The plastic materials used must contain >5% recycled plastic

Label plastic items >25g in accordance with ISO 11469 (EU's Waste Directive, 2nd draft)

Choose methods of assembly that will enable the appliance to be separated easily

Avoid polluting plastic with labels, metal inserts, coating, etc.


5.5.2.2 Raw materials

You may need a better dialogue with your suppliers concerning chemicals and materials in order to improve the environmental aspects of your product - for example, with respect to substitution of hazardous substances or non-renewable resources or with respect to access to information concerning environmental aspects in connection with the production of the raw materials.

In connection with your product work it is important to consider whether the methods and measurements used by your suppliers provide an adequate basis for their documentation of environmental impacts, i.e. whether the methods used for monitoring and measurement/registration are sufficient to enable you to achieve your environmental objectives.You should regularly review your relationship with your suppliers and develop and incorporate in your environmental management system a procedure for tackling suppliers, for following up on their documentation and, particularly, for deciding what questions you should ask your suppliers and what you should demand of them.You may therefore need to supplement your existing system with checklists for questions and requirements, together with new procedures and instructions.

In its environmental report for 1998 Grundfos set out the following targets and strategies for environmentally sound procurements:

Focus area

Target

Strategy

Carcinogenic substances

All carcinogenic substances must be removed from products and processes by the end of 2002

Identify high-risk substances and develop alternatives in cooperation with the suppliers. Matters concerning chemicals must be dealt with openly.

PVC

All products sold to Grundfos must be free of PVC by the end of 1999

Identify products containing PVC and develop alternatives in cooperation with the suppliers. Matters concerning chemicals must be dealt with openly.

Resource consumption

All suppliers must work actively to reduce their resource consumption and the associated impact on the environment

In all framework agreements for procurements,a paragraph will be added setting reduction requirements for selected environmental impacts

Packaging

Only packaging that meets Grundfos' environmental standards may be used

If the supplier is not able to supply environmentally approved packaging,he must undertake to take his packaging back.


5.5.2.3 Use and disposal

The same applies to information concerning use and disposal of the product. On the basis of feedback from customers and waste disposal companies (changed patterns of use or new waste technologies), you should regularly monitor and assess both with a view to determining whether there are grounds for adjusting the project.You can do the monitoring in different ways - either through direct dialogue with the stakeholders (e.g. customers) or through regular questionnaire-based surveys. You may therefore need special procedures and instructions for this area.

Dialogue with the customers is described in Chapter 4. Section 4.2.6 gives examples of actual tools.

You can find out more about waste from the Danish Centre for Waste (www.affaldsinfo.dk). There you will find information on handling different types of waste, methods of disposal and technologies, equipment suppliers, literature, etc.

5.5.2.4 New investments

An environmental management system usually also includes procedures for procurement of new equipment. Besides the technical/quality parameters, it is important that there is no significant increase in consumption of raw materials and ancillaries and, particularly, that energy consumption per unit produced remains unchanged. Before making major investments you should have procurement procedures and instructions in place to ensure that you assess needs and consequences in a life cycle perspective.

5.6 Statutory requirements and other requirements

5.6.1 Statutory requirements and other requirements

When environmental management is being introduced in a company it is important to list the environmental requirements to which the company is subject. The statutory requirements normally relate to the company's production and the associated emissions/discharges. They include requirements concerning handling of hazardous waste, limit values for substances contained in atmospheric emissions, wastewater, etc.When incorporating the product approach, you must remember that the product(s) is/are covered by special statutory requirements relating to production, use and disposal both in Denmark and in the export markets.

Statutory requirements must be complied with in order to gain and/or keep environmental certification. You must therefore also remember the statutory requirements concerning the products.

Statutory requirements concerning products are often in the form of requirements concerning specific constituents (chemicals) in the product and special rules concerning handling of these in connection with use and disposal - for example, the Nickel Directive and the battery collection scheme, handling of used electronic products and scrapping. A great deal of legislation does not relate to specific products because that would be difficult, but to the products' constituents. The Packaging Directive differs from this general picture by setting out specific requirements concerning both constituents, material consumption and, particularly, disposal.

Your customers are an important source of information. Establishing a dialogue with your customers' environmental managers would be a good way of obtaining information on local requirements, for example concerning waste handling, sorting and disposal. Another important source could be your trade association, which, among other things, perhaps enters into voluntary agreements on your behalf concerning phasing out specific substances - for example, the PVC Agreement.

If you use substances that are subject to regulation either as ancillaries or in the product, they are presumably already included in your environmental management system. However, you should make sure that requirements concerning product factors outside the company are also investigated and included - for example, requirements concerning emissions during use, including ozone emission from office machines, requirements concerning disposal - for example, requirements concerning reuse/recovery of materials or emission requirements relating to incineration etc.

5.6.2 Monitoring the situation

As in traditional environmental management, you must keep up to date on changes in statutory requirements and regularly update your legislation file.

For some chemicals there are statutory requirements concerning their use, but most have not yet been analysed and made the subject of statutory requirements. The Danish EPA has published a list of undesirable chemicals, which gives an indication of chemicals to which special attention will be paid in future. It is therefore a good idea to monitor requirements concerning substances and materials and to ensure that you know the legislation concerning use and disposal of the company's products. This will also significantly improve your possibility of informing customers and other stakeholders.

On the Danish State's website on legislation (www.retsinfo.dk) you can search for specific substances to gain an idea of what is happening with respect to legislation. Schultz Lovservice (Schultz Law Service) (www.schultz.dk) and others publish acts, executive orders, etc. (CDrom or paper format) on a commercial basis, so you can keep abreast of changes.

You must also keep an eye on what is on the way. You can do that through the Danish EPA and the Danish Energy Agency's strategies and action plans (www.mst.dk or www.energistyrelsen.dk) or at EU level through the Environment Commission's website (www.europa.eu.inc/comm./DGS/Environment/Index)

5.7 How might your environmental policy, targets and action plans look?

The chosen product-oriented action should appear from your environmental policy statement, as shown in the following examples.

Examples taken from different companies' environmental policy statements:

From Grundfos' environmental policy statement

"Within a financially sustainable framework, environmental impacts and resource consumption must be reduced throughout the company through the development of new products and processes. The environmental impacts throughout the life cycle of the products must be assessed and described. Where possible, the products must be designed for reuse or recycling. The company must ensure that products and packaging can be disposed of in an environmentally sound way."

From Berendsen's environmental policy statement

"To minimise the environmental impacts by optimising products, processes, services and transport on the basis of a life cycle approach."

From Henkel-Ecolab's environmental policy statement

"We market products and systems with documented performance with respect to both function and environmental impacts. Good hygiene and environmental care are prioritised criteria in the development of products and systems. We offer our customers information on the environmental aspects of our products, system and service."

From Coloplast's environmental policy statement

"Coloplast recognises its responsibility for controlling its environmental impacts. Besides complying with statutory requirements, trade agreements and customary rules, this means that we will seek - through prevention and continual improvement - to reduce the environmental impact of our production and the use of our products. We intend to be an environmental leader in the development of products and in the production through which our products are created..."

From Bang & Olufsen's environmental policy statement

"All human activity affects the environment. This also applies to the production and use of our company's products. Bang & Olufsen is constantly working to reduce its environmental impact and create a balance between this impact and consideration for our product's useful properties, economy, lifetime and design excellence, so that we are among the best in the industry...

... We want to participate in a global, sustainable development and see our activities in a life cycle perspective."


5.7.1 Objectives, targets and action plans

Environmental objectives, targets and action plans must be written down, reflect the company's environmental policy and prevent pollution.

If you use the product-oriented approach, you must also ensure continual improvement of the product, seen in a life cycle perspective.

Plans must therefore be drawn up for improving the company's environmental work on the product side as well. The action plans must include responsibility, time limits and a description of the specific measures. Remember to allow enough time and money.

Example of product-oriented target: to reduce the content of copper by 5% per product unit by the year 2001 compared with the year 2000.

In a traditional environmental management system, action plans are often limited to a single department or, in all cases, to a limited number of employees. With the product-oriented approach, action plans can be somewhat broader and cover more departments if you are going to achieve a real improvement.

The following example is of a company that has chosen to take action on chemical substitution in a specific product with a view, for example, to gaining an eco-label.

Table 5.7:
Example of an action plan

Target:

Substitution of chemicals x,y,z in product AA within a 1-year period

Action plan:

Substitution of chemicals x,y,z in product AA

Department

Activity
(What?)

Method
(How?)

Time limit
(When?)

Responsible
(Who?)

Sales

Are the customers asking for this?

Collecting enquiries from customers, question naire-based survey - are there particularly proble- matical substances?

3 months

 

Marketing

Can we sell it?

General market analysis - in what direction is the market moving?

3 months

 

Product development

Are the functional and quality properties met?

Will the lifetime be the same?

Analyses and tests of the product

Are there any design consequences?

max.1 year

 

Purchasing

Are there other chemicals or suppliers on the market?

Studies of suppliers

6 months

 

Production

Is it possible to make the new product?

Test productions of new products

2-3 years

 

Environmental manager

Are the alternatives better?

Preparation of environmental and health assessments of alternatives in a life cycle perspective

3 months

 


The example of the action plan to gain an eco-label does not differ in its structure from a traditional environmental management system. It is intended to stress the need for input from different departments in the company.

You must ensure in the underlying procedures and instructions that you follow up regularly on the progress being made and that the employees involved meet and exchange information regularly.

5.8 How do you organise the work on productoriented environmental action?

5.8.1 Organisation and allocation of responsibilities

If you already have an environmental management system, you may have to judge whether the person who is already responsible for tasks in connection with the environmental management system - typically an environmental manager or coordinator - is also going to be made responsible for the environmental aspects of products. Many small companies will find it natural to use the same person for both, while in larger organisations, it may prove useful to involve more people - for example, employees in product development, purchasing, sales/marketing, service, etc.

Whether you have an environmental management system or not, you therefore need to describe the competencies and responsibilities of the employees with tasks relating to the system.You can allocate competencies and responsibilities both to individuals and to whole groups.You should appoint an environmental coordinator for each department.

As mentioned, product-oriented environmental work requires several interdepartmental activities.We therefore recommend that you appoint an interdepartmental environmental group, in which the environmental coordinators from the various departments and your environmental manager discuss product aspects across the board. This will ensure that the information is passed on.

5.8.2 Need for training and checklists

It is important to consider how you are going to involve the employees in your product-oriented work and the competencies and responsibilities that should be allocated to them. This includes preparing/adding concrete training plans.

Your deliberations should result in written procedures and instructions in a form that suits your normal work procedures or the present system.

Your employees may need special training or special instructions and checklists to enable them to carry out the new tasks.

The level of training for the individual employee will naturally differ according to his or her intended role or function. For some of your employee categories you may need tailored courses (specialised courses), while for others, general knowledge will probably suffice.

All the employees in your company should not only be informed that you are now using the product-oriented approach in your work but also be instructed about the effect that will have on their daily work and what you expect of them. In the case of the employees to whom you intend to allocate specific tasks and responsibilities, you should ensure that they can rise to the task.

Several consulting firms and educational institutions (business schools, technical schools, etc.) offer both specialised and more general courses for different employee categories and functions. If you would like further information, you can contact them directly.

At APC Denmark ApS, the environmental coordinator has prepared a training plan in the form of a matrix of the different employee groups' need for training. As an element of the product orientation, the matrix will be supplemented by knowledge about the products' life cycle and actual product-oriented information. The training plan comprises a general module that all employee groups must take and a number of special modules designed for selected groups. Some of the special modules are designed for individual employee groups, while others will have participants from across the organisation. In the general module there are also participants from across the departments. Each module lasts for several hours and ends with a test to determine what the participants have learnt. The instruction is given primarily by in-house instructors because it is important to ensure that the content is as close as possible to the employees' daily work. Outside experts are invited for some subjects.

The principle behind the training plan is shown in the following diagram.

Look here!

5.9 How should communication be organised and handled?

Here, communication should be perceived in the broadest sense since it includes not only the command routes and dialogue across your organisation, but also your communication with the outside world - with your stakeholders.

It is important for you to decide whether your present environmental management system and the organisation of your environmental management work are geared for handling broad communication. The need to systematise the dialogue will naturally depend somewhat on the size of your company and the way your company is organised.

5.9.1 In-house communication

To ensure that important information reaches the relevant employee group or groups, it is a good idea to describe what types of information must be passed on to whom and how, preferably with a time limit.

It may also be important to discuss major product factors in a broader forum (with representatives of the relevant employee groups) at regular intervals or as needed.You should describe your information strategy on this point as well - what triggers a need for action and who is to take the action.

The descriptions should appear from your procedure for communication, possibly underpinned by instructions for different employee groups.

In the example of an action plan shown in section 5.7.1 you will see that many employee categories are needed in order to incorporate all environmentally relevant aspects of products.

5.9.2 External communication/dialogue

The external dialogue is an essential element of all environmental management work.That also applies to information and communication about the product's environmental performance, particularly because your product work is directly related to the market conditions.Your external communication/dialogue should be particularly with suppliers and customers, but your other stakeholders (neighbours, authorities, shareholders, etc.) may also wish to have life cycle-related information.

The Danish EPA has issued a number of publications on environmental dialogue (see the references).

Your product-related communication with your stakeholders can comprise many different components - for example:
training and guidance concerning use (e.g. visits to the customers)
supplier seminars
labelling of products (e.g. ecolabels)
environmental product declarations h directions for use.

It is important to gather up outside enquiries in order to pass them on systematically within your organisation. In this respect, productoriented environmental management does not differ from traditional environmental management.

Chapter 4 explains the importance of dialogue and tools for it.

5.10 The management's review

In a product-oriented environmental management system, the management's focus must be expanded to include the product-related objectives, targets and procedures.You must there expand the agenda for the management's periodical reviews.

With the product-oriented approach, new monitoring results from your sales, marketing, service and purchasing departments will be of particular interest:
What are the customers and the market demanding?
Is your "green" product profile selling?
Are you adequately monitoring new methods of disposal?
Are you able to supply the necessary documentation for your products' environmental performance - for example, in the form of directions for use?
Do you have sufficient control of the product's environmental properties in the use situation?
Do you have proper control of the suppliers and has there been a clear improvement in the documentation supplied for production of raw materials and chemicals?
Should some of the suppliers be replaced?

Your environmental manager/department will be able to provide important input concerning (expected) changes in statutory requirements at product level at home and abroad - for example, on new requirements concerning disposal of whole products or components or requirements concerning chemicals or materials. The environmental manager/department will also know about new or changed Green Buying Guides affecting your product and about any tightening of the criteria for ecolabels.

Monitoring the situation is naturally not enough in itself. It is also important for the management to decide whether the internal work procedures and instructions that are intended to ensure that information from the market and stakeholders is passed on, discussed and used actively are adequate. This information, which enters the company by different routes, and which is product-related, will very often be useful to several of your employee groups.

New items on the management's agenda could therefore be:
the sales and marketing department's periodical surveys of customer satisfaction and expectations concerning the development of the market for your "green" products
the purchasing department's periodical surveys of suppliers: prices and opportunities relating to the product work
the product development department's progress on environmental products
new statutory requirements, new requirements in Green Buying Guides and new or more stringent eco-label criteria
evaluation of communication, anchorage and use of information within the company in relation to the product work
evaluation of new training needs.

The new items on the agenda are intended to ensure that you maintain existing environmental targets and set up new ones that incorporate the product dimension in a life cycle perspective and that the management prioritises the action and ensures the necessary resources and competencies.

5.11 The other elements in the environmental management system

We have chosen to focus on those areas in the environmental management system where there is a need for special focus in order to incorporate the product dimension. The remaining elements, such as:
document management
operating control
contingency and remedial action
control and corrective action

must naturally also be adapted to the company's product-oriented work. For example, it should be checked in the internal audit that the employees know and understand the life cycle approach if that is part of your environmental policy and that your buyers, product developers, etc. really incorporate environmental considerations in their work to the extent prescribed by you.