Life cycle assessment (LCA) is increasingly being applied to support public policy making, to the consternation of some researchers and practitioners.
Initially during the 1990s LCA methodology helped to develop eco-labels and certification schemes, evolving to inform policy documents and eventually packaging legislation in Europe. It was also employed to guide alternative-fuel policies in the US.
LCA has continued to gain ground in the 21st Century and was incorporated into the ‘Integrated Product Policy’ of the European Union (EU). It was also intrumental in the establishment of several life cycle-based carbon footprint standards and regulations for transportation fuels in the US, EU and Canada.
Critics, however, have started to question the validity and usefulness of results from LCA.
The many studies on disposable and reusable diapers have been held up as a prime example of how widely varying conclusions can be drawn from LCA comparisons of competing products.
But it is especially the use of LCA findings to make performance-based regulations (PBRs) – such as in the European Renewable Energy Directive (RED) relating to biofuels – that the most concern has been voiced.
In addition, there are fears that the uncertainty of the results and subjective choices by the LCA practitioner – which can make the results seem more certain and scientifically objective than they actually are – is not being fully taken into account in the passing of such regulations.
The European Commission’s decision to now try and calculate the environmental footprint of consumer products based largely on an LCA approach has drawn particular opposition, notably from organisations such as ANEC – the European Association for the Co-ordination of Consumer Representation in Standardisation.
In North America too, there have been similar reservations expressed about Walmart’s Sustainability Index, introduced in 2009 and intended to eventually assess the environmental impacts of all of its products.
The idea was that every product in Walmart stores would eventually have something similar to a nutrition label detailing attributes like carbon inputs, recycled content and end-of-life options.
The Sustainability Consortium, hosted by the University of Arkansas and Arizona State University, has taken on the responsibility of providing the product sustainability data for Walmart.
The mission of the Sustainability Consortium (TSC) has been to design and implement “credible, transparent and scaleable” science-based measurement and reporting systems that will be accessible to manufacturers, retailers and users of consumer products.
Its stated aim is to establish its systems as the worldwide standard for sustainability measurement.
“Most retailers currently have their own systems and manufacturers have to spend a lot of time filling in a long list of questions with a great deal of overlap in them. There’s an obvious need for consolidation. The TSC’s Sustainability Measurement and Reporting System enables rigorous product level Life Cycle Assessments to be done at a fraction of today’s time and cost, and provides a platform for sustainability-related data sharing across the supply chain.”
The TSC has built up a membership representing around $1.5 trillion in combined annual revenues, and with Tier 1 membership fees at $100,000 a year, the organisation is certainly well resourced.
In addition to Walmart, Tier 1 retail members also include Tesco, Coca Cola, Kimberly-Clark, L’Oreal, Panasonic, Procter & Gamble, Reckitt Benckiser, Samsung, Unilever and more.
Walmart began piloting the TSC’s system in August 2012 with 3,000 suppliers, for an initial batch of 20 product categories that have subsequently been expanded.
The ‘broad brush’ approach of categorisation is immediately apparent, but perhaps entirely necessary in order to quickly implement such an all-encompassing system?
Or is this the actual problem?
According to one wipes manufacturer:
“A wipe convereted in the European Union compared to a wipe produced in China made of the same raw materials, of the same weight and with the same technology can look very different in terms of their LCA profiles.
It’s down to the comparison of many variable factors, including the use of proxy versus primary data, the energy data obtained from different grids and differing boundary definitions, to name but three. Yet we’re talking about identical products.”
Another worry that has been widely expressed is in respect of error margins - especially when considering certain areas as ecotoxicity and human toxicity.
These get a lot of attention in the environmental press but are in their infancy when it come to credible science for their measurement.
And the error margins can be huge.
LCA was standardised in ISO 14040 in 1997 and described as: “The compilation and evaluation of the inputs, outputs and the potential environmental impacts of a product system throughout its life cycle.”
A number of additional standards were developed and ultimately reviewed and compiled in 2006 in the form of ISO 14044
In order to measure a product’s environmental life cycle impact, an LCA calculates requirements in:
· Raw material production.
· The use and disposal of a product.
· All intervening transportation steps necessary or caused by its existence.
ISO though, acknowledges certain limitations of LCAs, not least that:
1. The results of two LCAs on the same subject may differ according to the objectives, processes, quality of the data and the impact assessment methods used. This is why ISO insists on transparency in life cycle assessment.
2. A detailed life cycle assessment requires inventory data of all of the elementary processes included within the parameters of the system. Databases, life cycle assessment software and even human resources are required to analyze all the data.
Variants of the LCA method have also been formulated to take account of time and cost constraints. The boundaries of a system can be limited to certain life cycle stages or to certain impact categories, or limited to the main contributors.
So inevitably there will be gaps in available data – especially in supply chains that are not well developed and structured.
And there is no escaping that fact that carrying out LCAs is extremely time consuming, nor can their complexity be ignored.
The more comprehensive an LCA is, the more time-consuming and expensive it will be. High costs are partly caused by the need for professional consultation and expert knowledge in the stages of impact and improvement analyses.
This makes the work carried out by organisations like EDANA and INDA particularly significant.
Members of EDANA were active very early in the game – the first EDANA LCA workshop held in 1992 attracted over 100 delegates from more than 60 EDANA member companies.
An initial EDANA LCA project started in June 1993, with 66 member companies participating. The single-use diaper was chosen as reference for the project since it involved the most EDANA members at the various stages of the value chain.
This initial project established:
• A common approach to LCA methodology.
• The adoption of a software system for calculations.
• The establishment of a database relevant to each company.
• A baseline for each company to measure future product and process improvements.
The companies involved confirmed that what was crucial to the success of the LCA method was the ability to collect reliable data.
This required a major contribution from the suppliers in respect of all of the raw materials involved, which has subsequently been ratified and employed in the development of the advanced Supplier Standards which have been established by the major consumer companies in baby diapers and other products.
The result is that today there is a tremendous degree of transparency within these supply chains and the consumer goods organisations can be very confident about the products they are ultimately providing to the consumer.
Other subsequent LCAs carried out by EDANA have included:
· An eco profile of polyester nonwovens for roofing membranes.
· Waste management alternatives for diapers.
· A trend analysis of the environmental performance of baby diapers and incontinence products.
· A life cycle inventory of superabsorbent polymer (SAP).
· Further LCAs on both baby and industrial wipes.
In summing up its high regard for LCA, EDANA says:
In over 20 years of use by EDANA and its member companies, life cycle assessment methodology has become a tool used not only to effectively model the environmental impact of products and processes, but also to deliver significant improvements of environmental performance thanks to better product design and process efficiencies.
In a materials-based industry, LCA is a major asset and a way to regularly challenge the nature and quantity of the materials used and the design of the products and production processes. LCA data has become the main scientific building block for the substantiation of environmental claims and sustainability-related communication.
INDA, meanwhile, has recently started working with Sustainable Minds (SM) which has developed LCA software that is already employed by industry and education in 600 locations in 60 countries and has proved particularly successful within the building products industry.
In presentations at the IDEA13 show in Miami, SM demonstrated the simplicity of its software, with which it’s easy to interpret and share graphical results and for non-experts in a given field to integrate the data into product development.
The SM nonwovens solution currently being developed will include a continually expanding dataset, example products, knowledge sharing, training and a platform for showcasing more sustainable materials and products, their uses and applications.
Inevitably, however, it’s when LCA results are used to directly compare competing products that the validity of the results come most into question.
The studies performed to compare disposable and reusable diapers over the years have certainly reached quite different conclusions.
A 1990 study commissioned by Procter & Gamble found significant advantages for disposables in terms of energy consumption, water use, air pollution and water emissions.
Supporters of reusables, however, decided to respond, and a 1991 study by the National Association of Diaper Services (NADS) concluded:
Considering the overall environmental burdens, and most notably the higher volumes of solid waste produced and energy and raw materials consumed by single-use diapers, reusable diapers are determined to be superior from an environmental perspective.
It was the 2005 LCA study by DEFRA, however, that appeared to settle the matter in finding “no significant difference between any of the environmental impacts of the disposable, home use reusable and commercial laundry systems that were assessed”.
An updated DEFRA study in 2008 came to the same conclusion, although it added that the results for reusable diapers strongly depend on assumptions about washing and drying.
This was not to the satisfaction of the US Real Diaper Association (RDA) which deemed both the data and assumptions flawed.
“When LCA is used for comparison, there are too many variables to result in an accurate comparison,” it concluded. “The UK studies tried to control for these variables, but those controls don’t resolve the issues of what impacts count. These are the foundational assumptions inevitable in any study. Compare two such different groups of products and the assumptions determine outcomes.”
Ironically Procter & Gamble may unwittingly be doing the reusable industry a favour through a separate initiative which may require the DEFRA LCA to be revisited once again.
Its promotion of the latest Ariel washing systems is proving highly successful at persuading consumers to wash their clothes at greatly reduced temperatures in order to reduce energy consumption and associated greenhouse gas emissions.
And presumably their reusable diapers too?
Single Market for Green Products
Meanwhile, the European Commission (EC) is currently at the pilot stage with its Single Market for Green Products initiative.
This has arisen following a study conducted which revealed that 48% of European consumers are confused by the stream of environmental information they receive.
There was a demand for a pan-European approach built on EU-wide science-based assessments and LCA. Fears were expressed that multiple initiatives at Member State level ran contrary to European Single Market principles, confusing consumers and increasing costs for industry.
Companies wanting to highlight the environmental performance of their products in Europe currently face numerous obstacles. They have to choose between several methods promoted by governments and private initiatives, are often forced to pay multiple costs for providing environmental information and face the mistrust of consumers confused by too many labels with information that makes products difficult to compare.
In a bid to provide harmonisation, the Single Market for Green Products initiative puts forward two methods for measuring environmental performance throughout the lifecycle – the Product Environmental Footprint (PEF) and the Organisation Environmental Footprint (OEF).
It also recommends the voluntary use of these methods and has commenced a three-year testing period to develop product and sector-specific rules through a multi-stakeholder process.
It is the PEF and OEF methods for testing products, however, that have drawn severe criticism from the European Association for the Co-ordination of Consumer Representation in Standardisation (ANEC) and specifically their over-reliance on LCA.
In its position paper on the subject, ANEC notes:
The precision of LCA results is limited by available resources, data gaps and data quality constraints such as temporal and geographical coverage, the need to use generic rather than site-specific data and complex and changing logistics and supply chains.
The error margin of an LCA will differ widely and will – in particular for complex products – easily exceed 10% for energy and greenhouse gases.
As a result of the lack of accuracy, LCA does not appear well suited for comparisons of similar products and will typically not allow for product differentiation.
Even if only primary data is used (rather than data from generic databases), the physical nature of these production processes makes it likely that the data is so similar that the identified differences are smaller than the error margin.
Hence, any labelling scheme will have to focus on issues such as material content or energy consumption in the use phase, meaning that LCA would not give any added value compared to current eco-labelling practices, but would simply require unnecessary efforts for data collection and compilation.
The history of LCA has clearly shown its limitations, ANEC adds, with the heated debates that have followed comparative studies to date and accusations of manipulation.
RED and biofuels
ANEC is most withering, however, about the EU’s Renewable Energy Directive (RED) which was inspired by a number of LCAs.
It provides that 20% of all energy used in the EU has to come from ‘renewable sources’ including biomass, bioliquids and biogas by 2020 and is effectively a subsidy scheme for biofuels.
The policy, ANEC asserts is “built on sand”.
RED is also seen as very unfair by the burgeoning bioplastics industry since it works to develop renewable alternatives to polymers for a wide range of products, including fibres and nonwovens and plastics.
The German Nova Institute has said that RED is leading to the systematic allocation of biomass to energy to the disadvantage of material use. It has triggered the development of national action plans and support systems for biofuels and in turn driven up biomass prices and agricultural leases. This is making it difficult for biopolymer developers to get their hands on biomass and distorting prices.
ANEC does not even raise this issue, but backs its own criticism up by citing a number of studies including one by the Institute for European Environmental Policy (IEEP). This finds that biofuels are actually leading to an increase of anywhere between 80 and 160% more greenhouse gas emissions than are generated by meeting the same needs through fossil fuel use.
University of Michigan analyst John M. DeCicco, meanwhile reaches this conclusion in his study ‘Biofuels and Carbon Management’:
While it may be discomfiting to some readers, the conclusion is that LCA is inappropriate for specifying regulations. Although LCA may be a useful research tool and can helpfully inform policy discussions, its literal application for policy specification is a mistake. Disputes over LCA regulatory outcomes are unproductive and ultimately unresolvable.
Urging a rethink
The issuing of consumer information based on a choice of LCA indicators, according to ANEC, is “useless and a step in the wrong direction”.
It is certainly not alone in this view and is directly supported by ORGALIME, the European Engineering Industries Association which represents 39 trade federations representing sone 130,000 companies, as well as ACEA, the European Automobile Manufacturers Association representing BMW, DAF, Daimler, Fiat, Ford, General Motors, Hyundai, Iveco, Jaguar Land Rover, Peugeot Citroen, Renault, Toyota, Volkswagen and Volvo.
In March last year ANEC, OEGALIME and ACEA wrote to the president of the European Commission urging a rethink on the Single Market for Green Products initiative.
They state a shared view that environmental footprint methodology based on an LCA approach:
· Creates unnecessary risk of disruption to the internal market for products and room for unfair competition, while providing questionable benefits – if any – for consumers or for industry.
· Undermines the EC’s wider Industrial Policy agenda, which requires policy makers to act in a coherent fashion.
· Undermines the EC’s sustainability agenda, which requires reliable information on environmental burdens associated with products and organisations.
· Will cause severe difficulties for enforcement and market surveillance authorities.
Notwithstanding the undoubted benefits of LCA as an internal environmental assessment instrument for manufacturers, its limits and shortcomings are said to be:
· The precision of the results provided by LCAs is limited by data constraints and LCA results can provide only a partial picture at best.
· LCA results are dependent on subjective choices made by manufacturers at the level of inputs into the model.
· LCAs are complex and costly, making them difficult for SMEs to undertake and to afford.
· LCAs do not allow consumers to make informed product comparisons or choices but lead to more confusion.
ANEC, ORGALIME and ACEA continue to consult with the EC on how best to overcome the problems it envisages.
Among the many recommendations ANEC is making are:
· Sound environmental assessments require a mix of tools, taking into account their strengths and weaknesses.
· Suitable production, consumption or disposal indicators can often be more robust and in many ways more meaningful or relevant than LCA data. In addition, they are cheaper, measurable and easier to verify.
· There is no point in collecting endless data to suit a ‘one-size-fits-all’ approach.
Adrian Wilson - Editor: Sustainable Nonwovens - Jan 2014
Click Here for Slides used by Calvin Woodings
Summaries of all papers from Vision 2014 Dallas will be appearing here soon.
Click Here for Slides used by Calvin Woodings
Summaries of all papers from Vision 2014 Dallas will be appearing here soon.