Green Products by Design: Choices for a

Cleaner Environment

September 1992

OTA-E-541

NTIS order #PB93-101715

GPO stock #052-003-01303-7
Foreword

As the United States and other nations begin to get serious about an array of potentially

significant environmental threats, from global climate change to local groundwater

contamination, traditional formulas of environmental management are being reassessed. The

remediation or ‘‘end-of-pipe’ strategies of the past 20 years are unlikely to provide

satisfactory, cost-effective protection of ecosystems and human health in the future.

Systematic change is needed.

Increasingly, product design is being viewed as a possible catalyst in transforming

societal patterns of production and consumption. Product design is an important environmental focal point, because design decisions directly and indirectly determine levels of

resource use and the composition of waste streams. By placing a greater emphasis on design,

environmental problems can be addressed in a proactive manner.

In this report, OTA provides a conceptual overview of how designers might integrate

environmental concerns with traditional design objectives, and how policymakers can best

take advantage of such opportunities. Although the concept of “green” design is gathering

momentum, a number of technical, behavioral, economic, and informational barriers need to

be addressed. By relying solely on existing policies and industrial practices, the full potential

of green design will not be realized.

Because product design encompasses the most crucial decisionmaking activities of

companies, the consideration of environmental objectives by designers could have important

competitive implications. Market opportunities for environmentally sensitive goods and

services are expanding. Examples of “green’ products and “clean” technologies are

beginning to appear across a wide spectrum of industries.

This study, requested by the House Committees on Science, Space, and Technology, and

on Energy and Commerce, builds on previous OTA work dealing with U.S. hazardous waste

and municipal solid waste policy. These previous studies acknowledged the importance of

product design as a tool for reducing wastes and managing materials, but did not explore the

idea in detail.

OTA appreciates the assistance provided by its contractors and the advisory panel, as

well as the many reviewers whose comments helped to ensure the accuracy of the report.

u JOHN H. GIBBONS

Director

iii
Advisory Panel—Green Products by Design:

Choices for a Cleaner Environment

Indira Nair, Chairman

Carnegie Mellon University

Frank van den Akker

Ministry of Housing, Physical Planning,

and Environment

Harvey Alter

U.S. Chamber of Commerce

David Chittick

AT&T

Michael DeCata

GE Plastics

Michael A. Gallo

Robert Wood Johnson Medical School

Robert Garino

Institute of Scrap Recycling Industries

Gil Gavlin

Gavlin Associates, Inc.

Denis Hayes

Green Seal

Kenneth Hunnibell

Rhode Island School of Design

Richard L. Klimisch

General Motors Corp.

Michael H. Levin

Nixon, Hargrave, Devans & Doyle

Stewart Mosberg

Walter Dorwin Teague Associates, Inc.

Thomas Rattray

Procter and Gamble Co.

Cliff Russell

Vanderbilt Institute for Public Policy Studies

Mary T Sheil

New Jersey Department of Environmental

Protection and Energy

T.S. Sudarshan

Materials Modifications, Inc.

Don Theissen

3M Co.

Jeanne Wirka

Consultant

Dennis A. Yao

Federal Trade Commission

NOTE: OTAappreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members.

The panel does not, however, necessarily approve, disapprove, or endorse this nqmrt. OTA assumes Ii.dl responsibility for the

report and the accuracy of its contents.

iv
OTA Project Staff—Green Products by Design:

Choices for a Cleaner Environment

Lionel S. Johns, Assistant Director, OTA

Energy, Materials, and International Security Division

Peter D. Blair, Energy and Materials Program Manager

Project Staff

Gregory Eyring, Project Director

Matthew Weinberg, Analyst

David Jensen, Analyst

Joe Raguso, Contractor

Administrative Staff

Lillian Chapman, Office Administrator

Linda Long, Administrative Secretary

Tina Aikens, Secretary

Contractors

Jill Watz and Thomas Nunno John KUSZ

ChemCycle Corp. Independent Consultant

Frank Field Robert Kerr and Lisa Lambrecht

FieldWorks Kerr and Associates, Inc.

William Franklin and Robert Hunt Jill Shankleman and David Festa

Franklin Associates Environmental Resources Limited
Outside Reviewers

Frank Ackerman

Tellus Institute

Braden A1lenby

National Academy of Engineering

John Atcheson

U.S. Environmental Protection Agency

Jesse Ausubel

Rockefeller University

Robert Ayres

Carnegie Mellon University

Charles Burnette

Philadelphia College of Art and Design

Richard Denisen

Environmental Defense Fund

Tom Donnelly

Council for Solid Waste Solutions

Pat Eagan

University of Wisconsin at Madison

John Ehrenfeld

Massachusetts Institute of Technology

Peter Eisenberger

Princeton University

Michael Fischer

Society of the Plastics Industries

Walter J. Foley

Coalition of Northeastern Governors

Ken Geiser

University of Massachusetts

Eun-Sook Goidel

U.S. Environmental Protection Agency

Paul Kaldjian

Montgomery Department of Environmental

Protection

Greg Keoleian

University of Michigan

David Lennert

Procter and Gamble Co.

Howard Levenson

California Integrated Waste Management Board

Mark Mazur

Joint Tax Committee

James McCarthy

Congressional Research Service

D. Navin chandra

Carnegie Mellon University

Doug Nutter

GE Plastics

Winfred Phillips

University of Florida

David Ruller

City of Alexandria

Walter Shaub

Solid Waste Association of North America

Ann Speicher

American Society for Engineering Education

Ed Stana

Council on Plastics and Packaging in the

Environment

Arthur J. Zadrozny

ARCO Chemical Co.

vi
Contents

Chapter Page

Chapter 1: Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Chapter 2: Environmental Aspects of Materials Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Chapter 3: Product Design and the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Chapter 4: Strategies for Green Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Chapter 5: International Comparison of Policies Affecting Green Design . . . . . . . ...*.**. . .

Chapter 6: Policy Options and the Challenge of Green Design . . . . . . . . . . . . . . . . . . . . . . . . . . .

Chapter 7: Guiding Principles for Policy Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

23

35

53

67

79

113
Chapter 1

Executive Summary
Contents

Page PROJECT DESIGN AND THE ENVIRONMENT ... ... o.. .*, *,, **, , e,+,,*,**,,***,+,,+, 4 GREEN DESIGN ..0. ... .*. ... ... .*. .*. ,,**, *,, +*** *r** c

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

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

. G*****,*+.******. 20

Box

Box

Page l-A. Design and Materials Management in the Auto Industry

. ......*........,,,,,,.*.,** 11

Figure

1-1. 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

● ✎✎✎ ✎✎✎ ✎✎✎ ☛✎✎ ✎☛✎ ✎☛☛✎ ☛☛✎ ☛☛✌ @e,   ac** . e,** **ac*

Resource Conservation and

... ... ... ..*. ... ,*. .., .***, +,** *oo*, +,e*, ,* 4,*,

... ... .O. *,. ... ... ... .**. *,. +*** *,* Be******,,+

. . . . . . . . . . . . . . .....,........*,,.****.*,*,*****

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Page

. 4

+ 6

. 8

. 9

. 12

Tables

Table

Page 1-1. Federally Funded Programs Related to Omen Design

● .*. ... ... .., .., *,** c*, *+c**, *4*m 15 1-2. Policy Options That Could Affect Materials Flows .*. .*. ... .,*. *,*. *,*, *40, *,, o,*,,., 17
Chapter 1

Executive Summary

Policymakers should be concerned with product

design for two reasons. One is to improve U.S.

industrial competitiveness. A strong domestic design capability can slash product development time,

improve quality, and reduce the cost of U.S.

products. The National Research Council has estimated that 70 percent or more of the costs of product

development, manufacture, and use is determined

during the initial design stages. 1 Thus, design is a

critical determinant of a manufacturer’s competitiveness.

The second reason is that product design is a

unique point of leverage from which to address

environmental problems. Design is the stage where

decisions are made regarding the types of resources

and manufacturing processes to be used, and these

decisions ultimately determine the characteristics of

waste streams.2 By giving designers incentives to

consider the environmental impacts of their choices,

policymakers can address environmental problems

that arise throughout the product life cycle, from the

extraction of raw materials to final disposal.3

The two design goals of enhancing competitiveness and protecting environmental quality can be

consistent. Design strategies that reduce production

costs and improve quality often have the benefit of

generating less waste and pollution. Moreover,

many companies are already using the environmental attributes of their products in their marketing

strategies, and polls suggest that consumer demand

for “green” products is likely to grow. 4 Man y

observers believe that those companies that are able

to design high-quality, environmentally sound products will enjoy a competitive advantage in the 1990s

and beyond.

In a recent review, the National Research Council

found that the quality of U.S. engineering design is

generally poor, and recommended that the Federal

Government make engineering design a national

priority to improve competitiveness.5 In the present

study, the Office of Technology Assessment (OTA)

finds that better product design offers new opportunities to address environmental problems, but that

current government regulations and market practices

are not sufficient to fully exploit these opportunities.

Therefore, integrating an environmental component

into policies to improve U.S. design capabilities is

an important policy objective. But policymakers

should be careful in how they attempt to achieve this

objective. Inappropriate regulation of the environmental attributes of products could perversely lead

to more wastes being generated, and could also

adversely affect competitiveness.

These findings are particularly relevant in the

light of congressional debate concerning the reauthorization of the Resource Conservation and Recovery Act (RCRA) of 1976, the major Federal

statute concerning solid waste. The reauthorization

debate involves many issues that could affect the

design of products, including mandatory recycled

content, reduced toxic chemical content, government procurement of recycled products, and environmental labeling, as well as controls on products

that cause special waste management problems such

as automobile batteries, used oil, and tires.

In reauthorizing RCRA and other environmental

laws, Congress can influence product design in two

ways. First, it can enact additional environmental

regulations —for example, requiring that manufacturers incorporate recycled materials into new products or take back discarded products from consumers. Second, Congress can move toward a strategy of

harnessing market forces to encourage manufacturers to make environmentally sound decisions—for

example, 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 of

the 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 wide

variety of disciplines: industrial designers, engineering designers, manufacturing engineers, graphic and packaging designers, as well as managers and

marketing 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 t

Recycle Remanufacture

Use Waste management

t

Reuse

Environmental impacts occur at all stages of a product’s life cycle. Design can be employed to reduce these impacts by changing the

amount and type of materials used in the product, by creating more efficient manufacturing operations, by reducing the energy and

materials 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 industrial emissions of certain toxic chemicals.

Each approach has advantages and disadvantages:

regulations can produce swift and predictable results, but they can also impose unnecessary costs on

industry and stifle environmentally innovative designs. Economic incentives can provide flexibility,

but they can be expensive to administer and are often

politically unpopular. The challenge for Congress is

to employ a mixture of regulations and economic

instruments to give designers the incentives to make

choices that promote RCRA’s goals of protecting

human health and the environment.

PRODUCT DESIGN AND THE

ENVIRONMENT

Products affect the environment at many points in

their life cycle (figure l-l). The most visible impact

is municipal solid waste (MSW). The trash generated by U.S. households and commercial establishments averages about 4 pounds per person each day.

In 1988, the United States generated some 180

million tons of MSW. Landfills in many States are

reaching their permitted capacity, and there is

increasing public opposition to siting new waste

management facilities.

About one-third of MSW by weight consists of

product packaging, which has become a major target

of environmental policies around the world. Better

packaging design can reduce the quantity of this

waste significantly. For example, at a recent conference, packaging designers concluded that—given

the commitment of top management—new designs

could reduce the weight of packaging by an average

of 10 percent in 1 year. This would mean a 3 percent

drop in MSW from this source alone.

Less visible but potentially more serious environmental impacts occur during raw material extraction, material processing, and product manufacturing. U.S. industry generates some 700 million tons

of “hazardous waste” and some 11 billion tons of

‘‘non-hazardous solid waste (figure l-2a).6 Although the weight of industrial and municipal solid

waste cannot be compared directly,7 these production wastes clearly dwarf municipal solid wastes in

their quantity and environmental impact (see figure

l-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 Technology

Assessment, 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 wastewater

contained in sludges and aqueous solutions.

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

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 much

public concern, represents less than 2 percent of all solid waste regulated under RCRA. in contrast, Industrial activities produce about 700

million 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 D

of RCRA, respectively. The mining wastes shown in (b) exclude mineral processing wastes; the oil/gas wastes in (b) exclude produced waters used

for 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 Gas

Product/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 these

wastes (about 6.5 billion tons).

Finally, some of the most serious environmental

impacts may occur during the actual use of the

product. This is particularly true of products that are

consumed or dissipated during their use, for example, chlorofluorocarbon (CFC) solvents and coolants, fossil fuels, and pesticides. The environmental

releases from these dissipative products can be much

larger than those from the associated industrial

processes. For example, the State of New Jersey

collects data on industrial inputs and outputs of

hazardous substances. The data indicate that in

1990, 55 to 99 percent of industrial inputs of five

toxic heavy metals (mercury, lead, cadmium, chromium, and nickel) was converted into products (i.e.,

not released as industrial waste), depending on the

metal.8 Product reformulation and substitution for

toxic constituents can help to address these problems.

Behind each of these environmental impacts are

critical decisions made during product design. The

materials used, energy requirements, recyclability,

longevity, and many other environmental attributes

of products result directly from design decisions.

Once a product moves from the drawing board into

production, its environmental attributes are largely

freed; the key, therefore, is to bring environmental

concerns into the front end of the design process.

GREEN DESIGN

Product design is a process of synthesis in which

product attributes such as cost, performance, manufacturability, safety, and consumer appeal are considered together. In general, products today are

designed without regard for their overall impact on

the environment. Nevertheless, many health and

environmental laws passed by Congress do influence the environmental attributes of products. Some,

such as the Clean Air Act, Clean Water Act and

Resource Conservation and Recovery Act, do so

indirectly, by raising industry’s costs of releasing

wastes to the air, water, and land. Others, such as the

Toxic Substances Control Act and the Federal

Insecticide, Fungicide, and Rodenticide Act, control

the use of hazardous chemicals and pesticides

directly.

Government regulations typically influence the

design process by imposing external constraints, for

example, compliance by auto designers with Corpo8 Some heavy metals incorporated into products are eventually recycled, but recycling rates very substantially by material. For example, more than

50 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 biodegradable

packaging like these plastic bottles made from Alcaligenes bacteria by ICI, Ltd.

rate Average Fuel Economy (CAFE) standards, and

with auto emissions standards under the Clean Air

Act. OTA uses the phrase “green design” to mean

something qualitatively different: a design process

in which environmental attributes are treated as

design objectives, rather than as constraints. A key

point is that green design incorporates environmental objectives with minimum loss to product

performance, useful life, or functionality.

In OTA’s formulation, green design involves two

general goals: waste prevention and better materials

management (figure 1-3).9 Waste prevention refers

to activities by manufacturers and consumers that

avoid the generation of waste in the first place.

Examples include using less material to perform the

same function (’‘light-weighting”), or designing

durable products so that faulty or obsolete components can be readily replaced, thus extending the

product’s service life. Better materials management

refers to activities that allow product components or

materials to be recovered and reused in their highest

value-added application. Examples include designing products that can be readily disassembled into

constituent materials, or using materials that can be

recycled together without the need for separation.

These goals should be viewed as complementary:

while designers may reduce the quantity of resources

used and wastes generated, products and waste

streams will still exist and have to be managed.

The idea of green design seems simple, but there

is no rigid formula or decision hierarchy for implementing it. One reason is that what is ‘‘green”

depends strongly upon context. While some environmental design objectives are sufficiently compel9 This formulation appeared U.S. Congress, of Technology Assessment, Facing America’s Trash: What Next for Municipal Solid

Waste, OTA-O-424 (Washington DC: U.S. Government Printing October 1989).
8 ● Green Products by Design: Choices for a Cleaner Environment

Figure 1-3-The Dual Goals of Green Design

Green design

I

Waste prevention Better materials management

Reduce: weight Facilitate: remanufacturing

toxicity recycling

energy use comporting

Extend: service life energy recovery

Green design consists of two complementary goals. Design for waste prevention avoids the generation

of waste in the first place; design for better materials management facilitates the handling of products

at 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 expects

that green choices will only become clear with

respect to specific classes of products or production

networks. What constitutes green design may depend on such factors as: the length of product life;

product performance, safety, and reliability; toxicity

of constituents and available substitutes; specific

waste management technologies; and the local

conditions under which the product is used and

disposed.

Design Tradeoffs

With technologies available to create new materials and to combine conventional materials in new

ways, designers are faced with more choices than

ever before. One result is that products are becoming

more complex and specialized. For example, a

typical laundry detergent now contains over 25

different ingredients.

These choices often involve environmental dilemmas. Tradeoffs may be required, not only between traditional design objectives and environmental objectives, but even among environmental

objectives themselves-for example, waste prevention versus recyclability.

As an illustration, consider the cross section of a

modern snack chip bag depicted schematically in

figure 1-4. The combination of extremely thin layers

of several different materials produces a lightweight

package that meets a variety of needs (e.g., preserving freshness, indicating tampering, and providing

product information). The use of so many materials

effectively inhibits recycling. On the other hand, the

package has waste prevention attributes; it is much

lighter than an equivalent package made of a single

material and provides a longer shelf life, resulting in

less food waste. Even this relatively simple product

demonstrates the difficulties of measuring green

design.

Similar tradeoffs may occur between other attributes, such as energy efficiency and toxicity. For

example, energy-efficient, high-temperature superconductors contain a variety of heavy metals, and

toxic chemicals are required to manufacture photovoltaic cells. In general, every design will have its

own set of environmental pluses and minuses.

Environmental Aspects

of Products and Systems

From an environmental point of view, it is

simplistic to consider the impact of a product in

isolation from the production and consumption

systems in which it functions. Is a computer, for

instance, a green product? Considered on its own,

probably not. The manufacture of a computer

requires large volumes of hazardous chemicals and

solvents, and heavy metals used in solder, wiring,

and display screens are a significant contributor to

the heavy metal content of MSW.

But the same computer could be used to increase

the efficiency of a manufacturing process, thus

avoiding the use of many tons of raw materials and

the generation of many tons of wastes. From this

perspective, the computer is an enabling technology
Chapter 1--Executive Summary ● 9

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

Polypropylene

r 7

● Machinability

“ Adhesion

o Moisture barrier

● Stiffness

● Clarity

o 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, and

consists of nine different layers, each with a specific function. While such complexity can inhibit recycling efforts, it also can reduce the

overall 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 production system as a whole.

This illustrates an important OTA finding: green

design is likely to have its largest impact in the

context of changing the overall systems in which

products are manufactured, used, and disposed,

rather than in changing the composition of

products per se. For instance, designing lighter

fast-food packaging is well and good; but 80 percent

of the waste from a typical fast food restaurant is

generated behind the counter, where consumers

never see it. Addressing this larger problem requires

that designers establish cooperative relationships

with their suppliers and waste management providers in order to manage materials flows in an

environmentally sound way.

There may appear to be few incentives for

industry to consider such dramatic changes in

existing production networks. After all, longstanding

relationships among manufacturers and suppliers

may have to change, and millions of dollars maybe

invested in the existing infrastructure for production

and distribution. Such changes are not generally

within the purview of product designers. Indeed, a

systems design approach implies the elevation of the

product design function to the level of strategic

business planning, and a shift in perception by top

management in which environmental quality is

viewed not as a cost, but as a strategic business

opportunity.

But changes of comparable magnitude are already

underway. Many manufacturers are rethinking their

business relationships with suppliers and customers

in order to implement total quality management and

concurrent engineering programs. New government

regulations in Europe that give manufacturers re-
10 ● Green Products@ Design: Choices for a Cleaner Environment

sponsibility for the environmental fate of their

products are also encouraging this approach. For

example, Germany’s proposed law requiring automakers to take back and recycle automobiles has

stimulated the German automobile industry to develop new cooperative strategies for auto design,

manufacturing, and recycling (see box l-A).

Policy Implications

These findings have a number of policy implications:

The environmental evaluation of a product or

design should not be based on a single attribute,

such as recyclability. Rather, some balancing of

pluses and minuses will be required over the

entire life cycle.

The trend toward increasing product complexity seems certain to make the environmental

evaluation of products more difficult and expensive in the future.

Policies to encourage green design should be

flexible enough to accommodate the rapid pace

of technological change and the broad array of

design choices and tradeoffs.

The biggest environmental gains will likely —— come from policies that provide incentives for

greener production and consumption systems,

not just greener products.

GROWING INTEREST IN

GREEN DESIGN

The concept of green design is not new. During

the 1970s and 1980s, ideas such as design for

remanufacturing and design for recycling were

developed in technical journals and conferences. At

the time, the concept did not receive much attention

from policymakers or the public, but green design

has enjoyed a renaissance in the past few years.

Rising interest among industry groups and design

societies around the world is indicated by the

proliferation of books, newsletters, and published

papers on the subject.

One area of particular interest is the awarding of

‘‘eco-labels’ to products that are judged to be

environmentally preferred compared with alternative products. Germany, Canada, Japan, the Nordic

countries, and the European Community all either

have government-funded eco-labeling programs, or

will 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 the

metals are recovered. The nonmetal components (plastic,

rubber, fabric, and glass) end up as shredder residue that

must be Iandfilled. Bottom: BMW has designed the

21 Roadster so that external body panels and fascia

can be easily removed from the automobile frame

and subsequently recycled.
Chapter 1--Executive Summary ● 11
12 ● Green Products by Design: Choices for a Cleaner Environment

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 (Scientific

Certification Systems)* United States (Green Seal)

Eco-labels are intended to identify environmentally preferred

products for consumers. Above are government-sponsored labels

from 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 labeling

efforts are underway (figure 1-5).

Product packaging, perhaps the most visible

component of the post-consumer waste stream,

continues to be the target of control measures that

include bans, taxes, deposits, and recycling requirements. One of the most dramatic initiatives is

Germany’s Packaging Waste Law, which gives

manufacturers and distributors the responsibility for

recovering and recycling their own packaging

wastes. In fact, the idea of shifting the burden of

dealing with discarded products from municipalities

to manufacturers appears to be gaining momentum

in Europe, and may soon be extended to durable

goods, such as household appliances and automobiles. This statutory coupling of manufacturing with

post-consumer recycling is forcing manufacturers—

including U.S.-based manufacturers with subsidiaries

in Europe—to change the way they design products.

The European Community is wrestling with the

problem of harmonizing the different environmental

product standards and recycling laws of member

countries with the approach of the Single Market in

1992. These laws have proved contentious in the

past, and harmonization is not yet in sight. Recent

controversies over whether countries can restrict

imports of goods deemed harmful to health or the

environment, or whether such restrictions constitute

nontariff barriers to trade, suggest that the harmonization of international environmental product policies is becoming a thorny problem that will have to

be resolved in future negotiations under the General

Agreement on Tariffs and Trade (GATT’) and other

international agreements.10

Many States within the United States are also

enacting policies aimed at reducing the environmental impacts of products. These measures include

mandating industry plans to reduce their use of toxic

chemicals, mandating the disclosure of the use of

hazardous chemicals in products, and establishing

standard definitions for advertisers’ use of terms like

“recycled.” States have also enacted some targeted

product control measures such as recycled content

requirements for newspaper, bans and taxes on

specific packages, mandated manufacturer takeback of batteries, and tax incentives for recycling.

The lack of uniform Federal environmental standards for products is alarming to industry, which fears

having to satisfy 50 different State regulations. This

prospect is especially of concern for products

distributed 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).
Chapter 1--Executive Summary ● 13

The United States cannot be said to be “behind”

other countries in the development of environmental

policies that encourage green product design. Indeed, many European countries look enviously at

U.S. environmental policies such as auto emissions

standards, or the timetable for phaseout of CFC

production and use, which are among the most

aggressive in the world. Some U.S. chemical companies are acknowledged world leaders in waste

prevention techniques.

It is more accurate to say that the U.S. approach

differs substantially from the approaches being

taken abroad, and these differences could create

conflicts in the future. Whereas some of the ‘greener’

European countries (especially Germany, the Netherlands, and the Nordic countries) increasingly focus

on the environmental attributes of products at the

national level, U.S. policies continue to focus on

regulating industrial waste streams. Except in cases

where products pose a clear threat to human health

(e.g., some pesticides, PCBs, leaded gasoline and

paint), the Federal Government has been reluctant to

regulate the environmental attributes of products

directly. For example, the Resource Conservation

and Recovery Act regulates ‘‘hazardous” industrial

waste closely, but delegates the primary responsibility for product disposal and ‘‘non-hazardous” solid

waste management to the States.11

OTA finds no compelling reason for U.S. policies

to necessarily imitate the product control policies in

Germany or other countries (although monitoring

the implementation of these initiatives could provide

valuable lessons for the United States). In fact, many

observers believe that some of the more extreme

measures, such as Germany’s mandatory take-back

provisions for packaging waste, will prove to be

costly and difficult to implement.

Nevertheless, the rapid evolution of environmental product policy, both in the States and abroad,

suggests that the Federal Government needs to

become more strongly involved for two reasons: 1)

to keep abreast of technology and policy developments, and 2) to help shape policies that reduce

barriers to interstate commerce and international

trade. Options for greater Federal involvement are

discussed below.

SHAPING ENVIRONMENTAL

POLICIES THAT ENCOURAGE

GREEN DESIGN

Some U.S. companies argue that existing market

forces and environmental regulations are sufficient

to encourage green design. They tend to view new

environmental constraints on the design of products

as a threat to their competitiveness and a drag on

economic growth, especially during an economic

recession. These companies are reluctant to redesign

established products to achieve environmental benefits that have little value or visibility to their

customers.

In fact, companies already have a number of

incentives to move toward green design. By reducing the quantity of materials used in products, they

can reduce manufacturing costs; by reducing the

hazardous material content of products, they can

reduce the rising costs of pollution control, waste

disposal, and potential liability. There are also

opportunities to gain consumer loyalty by enhancing

the environmental attributes of their products. These

incentives are already having an effect on the way

many companies do business: for example, less toxic

substitutes for heavy metals are being adopted in

such products as inks, paints, and batteries; environmental advertising is being used to sell a range of

products from gasoline to fabric softener; and more

and more companies have recognized the linkages

between improved product quality and improved

environmental quality.

Even if Congress takes no further action, these

incentives can be expected to continue in the future.

For example, as permitted landfill capacity continues to shrink, waste disposal costs should increase,

providing companies with greater incentives to

reduce their wastes. Implementation of tougher

emissions standards under the Clean Air Act Amendments of 1990 will increase pressures on companies

to reduce their use of hazardous solvents and other

volatile organic compounds. Various States will no

doubt continue to pass legislation to regulate the

environmental attributes of products and waste

streams. And as consumers become more attuned to

environmental concerns, they will increasingly dell 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.
14 ● Green Products by Design: Choices for a Cleaner Environment

Photo credit: “Selling Green. ” Copyright 1991 by Consumers Union of

U. S., Inc., Yonkers, NY 10703-1057. Repnntedbypermission from

CONSUMER REPORTS, October 1991.

This collage of fictional packages illustrates the trend

toward environmental marketing.

mand that manufacturers take more responsibility

for the environmental impacts of their products.

But OTA finds that there are four specific areas of

need that existing market forces or regulations do

not adequately address, and that are uniquely the

responsibility of the Federal Government:

Research—At present, policymakers don’t

know what materials or waste streams are of

greatest concern, or about how product designs

might be changed to address them most effectively. Private companies have no incentive to

conduct this research.

Credible information for consumers-Surveys

show that consumers are interested in green

products, but most don’t know what is ‘green.’

As discussed above, defining what’s green is a

multidimensional problem. In the absence of

Federal action to establish consistent ground

rules defining terms and measurement methods, the growing interest of consumers could

become dissipated in confusion and skepticism.

Market distortions and environmental externalities—Despite the existing incentives for

green design noted above, critics of present

consumption patterns argue that important

market distortions and environmental externalities remain that encourage inefficient use of

materials and energy. Failure to internalize

●

these environmental costs into design and

production decisions can make environmentally sound choices seem economically unattractive.

Coordination and harmonization-OTA found

that several research projects related to green

design are being sponsored by various Federal

agencies and offices, but that there is little or no

coordination among them. And unlike its major

competitors, the United States has no institutional focus at a national level for addressing

environmental product policy.

Current Federal Efforts

Related to Green Design

OTA identified a number of ongoing Federal

activities that partially address these needs (table

l-l). EPA is most directly involved. For example, its

Office of Research and Development has several

projects underway to develop generic guidelines for

green design. However, there are relevant projects

scattered through several other agencies, including

the Department of Energy (DOE) and the National

Science Foundation.

Several recent initiatives could help to remove

some of the barriers to green design that exist in

current Federal rules and regulations. In October

1991, President George Bush signed Executive

Order 12780, the Federal Recycling and Procurement Policy, which requires Federal agencies to

increase recycling and waste reduction efforts, and

to encourage markets for recovered materials by

favoring the purchase of products with recycled

content. The Department of Defense has issued

recent directives emphasizing waste prevention

through the acquisition process and through military

specifications and standards. Some 40,000 military

specifications requiring the use of hazardous materials are currently under review. These initiatives will

help to create markets for green products.

There are also several ongoing activities that

could improve the quality of information available

to consumers and citizen groups. EPA and the

Federal Trade Commission (FTC) are developing

guidelines for advertisers’ use of environmental

terms such as “recycled.” National standards for

use of these terms in advertising can give consumers

confidence that a product advertised as “sourcereduced” or ‘‘recycled’ is really better for the

environment. In the Pollution Prevention Act of
Chapter 1--Executive Summary ● 15

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

Agency/office Program/activity Comments

Department of Energy

Off ice of Industrial Technologies Industrial Waste Reduction Program

Environmental Protection Agency

Office of Research and Environmental Resource Guide

Development

Dynamic Case Studies on Environmentally

Advanced Product Design

Life Cycle Assessment Methodology

Clean Products Case Studies

Safe Substitutes

Life Cycle Design Guidance Manual:

Environmental Requirements and the

Product System

National Pollution Prevention Center

American Institute for Pollution Prevention

Office of Pollution Prevention Design for the Environment

and Toxics

National Science Foundation Engineering Design Research Center

This research and development program aims to

identify priority industrial waste streams, assess

opportunities for addressing these waste streams

through redesigning products and production processes, and technology transfer from national laboratories.

Contracted to the American Institute of Architects, this

project will provide information to architects on the

life-cycle environmental impacts of instruction

materials.

Contracted to the Resource Policy Institute in Los

Angeles and the Product Life institute in Geneva,

this project will explore case studies involving green

product design.

Contracted to Battelle, this project will develop standard

methodologies for conducting product life-cycle

assessments.

Contracted to INFORM Inc., this project will provide

case studies of green design, especially the reduced use of toxic substances in products.

Contracted to the University of Tennessee, this project

will identify priority toxic chemicals and evaluate

possible substitutes.

Contracted to the University of Michigan, this manual

will explore how designers can incorporate Iife-cycle

information into their designs.

Located at the University of Michigan, this center is

developing waste prevention information modules

for industrial and engineering design courses.

in association with the University of Cincinnati, the

institute serves as a liaison to a broad cross-section

of industry, with projects involving four aspects of

waste prevention: education, economics, implementation, and technology.

Proposed program to gather, coordinate, and disseminate information on green design.

Located at Carnegie Mellon University, the center is

organizing a program to explore methods for green

design.

SOURCE: Office of Technology Assessment.

1990, Congress required manufacturers who report

their releases of toxic chemicals for the Toxic

Release Inventory (TRI)12 to also report how these

releases were affected by product and process

redesign. When this provision is implemented, it

could become a valuable source of information in an

area where little information currently exists: how

product design choices affect industrial waste

streams.

In the short term, Congress can make a good start

toward encouraging green design by using its

oversight powers to ensure that these ongoing

activities are carried through to their conclusion, and

that the provisions of the Pollution Prevention Act

are implemented expeditiously.

Long-Term Options

In the longer term, Congress may wish to address

the needs identified above more directly. These

needs are discussed in greater detail below.

Research

Of critical importance is to identify what materials and products pose the greatest risks to human

health and the environment. Without this information, Congress cannot intelligently set priorities for

IZ ~r~fied ~der Title III of tie sup-d Amendments and Reauthorization Act of 1986.
16 ● Green Products by Design: Choices for a Cleaner Environment

environmental policy. Congress could direct EPA

and DOE to identify a short list of priority materials,

products, and waste streams; identify areas where

additional data are needed to assess their health and

environmental impacts; and develop quantitative

models showing how these high-risk materials flow

through the economy.

Research is also needed to develop techniques for

measuring the environmental impact of products and

systems, to better understand how the business

climate and corporate culture affect product design

decisions vis-a-vis the environment, and to explore

the costs and benefits of various policy options such

as manufacturer take-back requirements.

Credible Information for Consumers

As discussed above, national standard definitions

for advertisers’ use of environmental terms could

alleviate consumer confusion associated with current environmental claims. An important goal for the

future will be to determine how to credit products

that feature waste prevention in regulations and

government procurement programs that are currently focused on recycling and recycled content.

For example, should waste prevention be measured

with respect to waste generated in some previous

base year, or with respect to other comparable

products in the current year?

The United States has two small, private ecolabeling efforts underway. One potential concern is

that a variety of private labels based on different

appraisal methods could lead to confusion about

which products are actually better for the environment. To address this problem, Congress could

designate EPA to develop standards for the certification of private eco-labeling programs. This might

give consumers confidence that products carrying

certified eco-labels are in fact better for the environment. Alternatively, it could appoint a blue-ribbon

commission to oversee the establishment of an

independent, national eco-labeling program similar

to those of other countries.

Where the disclosure of public information on

industrial waste streams has been mandated by

Congress, e.g., through the Toxic Release Inventory,

this has proven to be a powerful motivation for

companies to change their designs and manufacturing processes. Expanded industry reporting requirements under TRI could improve the information on

materials flows available to public interest groups

I

. . ., ,, . . . 4

Credit: Wayne Stayskal, T&npa Tribune

and ultimately to consumers. This might involve

expanding the number of reportable chemicals, the

types of industries required to report, or expanding

reporting requirements themselves to include the

actual use of priority chemicals in products and

processes, not just the release of these chemicals to

the environment. However, unless these requirements are narrowly targeted on chemicals or materials of special concern (see research needs above),

they would significantly increase industry’s reporting costs, and might not result in a commensurate

reduction of environmental risk.

Market Distortions

and Environmental Externalities

Products have environmental impacts at every

stage of their life cycle. Yet, many of these are not

accounted for in the prices of materials and products.

On the production side, there are government

subsidies or special tax treatment for the extraction

of virgin materials (e.g., below-cost timber sales and

mineral depletion allowances), and many “nonhazardous” industrial solid wastes (e.g., mine tailings or manufacturing wastes that are managed

on-site) with significant environmental impacts are

not regulated at the Federal level. On the consumption side, consumers often do not pay the full

environmental costs of products that are consumed

or dissipated during use (e.g., gasoline, cleaners,

agricultural chemicals), or the full cost of solid waste

disposal.

Table 1-2 presents a menu of regulatory and

market-based incentives that have been proposed to

address environmental problems associated with the

flow of goods and materials through the economy.
Chapter 1--Executive Summary ● 17

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 solid

and processing wastes under the Resource Conservation and Recovery Act (RCRA).

Establish depletion quotas on extraction and import of

virgin materials.

Tighten regulations under Clean Air Act, Clean Water

Act, 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 recydisposal cling.

Waste management Tighten regulation of waste management facilities

under RCRA.

Ban disposal of hazardous products in landfills and

incinerators.

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 of

virgin materials, and subsidies for agriculture.

Tax the production of virgin materials.

Tax industrial emissions, effluents, and hazardous

wastes.

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 research.

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 management

facilities.

Establish surcharges on wastes delivered to

landfills or incinerators.

SOURCE: Offics of Technology Assessment.

These options are organized according to their point

of greatest impact in the product life cycle. Each

could have an impact on product design, but an

analysis of the design implications of these options

is beyond the scope of this report. However, OTA

offers three guiding principles that policymakers

should consider as they evaluate these options (see

below).

Coordination and Harmonization

Green design is. a multidisciplinary subject that

does not fit comfortably within the mission of any

single Federal agency. For instance, EPA is organized around regulatory responsibilities for protecting air, water, and land; its technical expertise in

design and manufacturing areas is slight. The

Department of Commerce (DOC), on the other hand,

is concerned with the competitiveness of industrial

sectors, but has little environmental expertise. DOE’s

national labs have considerable experience that

could be brought to bear on improving the efficiency

of industrial energy use and waste prevention, but

environmental quality has not traditionally been a

part of DOE’s mission. The story is much the same

with other agencies.

As described here, green design refers not to a

rigid set of product attributes, but rather to a

decision process whose objectives depend upon

the specific environmental problems to be addressed. This suggests that the most meaningful way

in which the Federal Government can encourage

green design is through multiagency initiatives

organized around particular environmental problems, policy issues, or industrial sectors. These

collaborations are beginning to be formed on an ad

hoc basis. For instance, EPA is working with the

Department of Agriculture to promote waste preven-
18 ● Green Products by Design: Choices for a Cleaner Environment

tion in agricultural chemical use. EPA, DOE, and

DOC are collaborating in a joint grant program with

States to fund research on reducing the environmental impacts of industrial processes.13 These

efforts are a start; however, much more could be

done in the following areas:

●

●

●

●

Promoting information exchange-Current mechanisms for disseminating information on relevant research activities in various agencies are

only partially effective. A central repository

containing information on all relevant Federal

research activities would be helpful.

Promoting system-oriented design solutions—

A greener transportation sector, for example,

may involve not only improved vehicle fuel

efficiency, but better management of materials

used in automotive, rail, aviation, etc., as well

as changes in urban design. A multiagency

perspective could provide a more holistic

analysis of total sectoral issues, through forums, grant programs, etc.

Harmonizing State and Federal environmental

product policies—Policy guidance is needed to

help define the circumstances under which

Federal standards preempting State and local

product control laws may be justified, and

where they are not.

Coordinating policy development on international aspects of the environment, U.S. competitiveness, trade, and technology--At present, responsibility for development of U.S.

policy in these areas is not clearly defined, with

each Federal agency having its own agenda.

To address these needs, Congress could:

*

●

●

Provide funding for a central electronic network listing current Federal research projects,

case studies, and bibliographic materials relating to green design.

Use its oversight powers to clarify which

agencies have lead responsibility for policy

development on interstate and international

aspects of U.S. environmental product policy.

Ensure that green design considerations are

integrated into the charter of any new environmental or technological organizations now

being proposed before Congress, such as the

National Institutes for the Environment or a

Civilian Technology Agency.

In the end, the institutional details are less

important than a recognition on the part of Congress

and the Administration that Federal leadership is

needed to take advantage of opportunities such as

green design that do not fall neatly within the

mission of any single agency.

GUIDING PRINCIPLES FOR

POLICY DEVELOPMENT

The discussion above suggests three general

principles that Congress can use to develop environmental policies that encourage, rather than inhibit,

green design.

Principle 1: Identify the root problem and define

it clearly.

One of the biggest challenges in selecting a policy

strategy is clearly defining the problem to be

addressed. One difficulty is that products and waste

streams have multiple environmental impacts that

cannot be easily disentangled. Policymakers may be

concerned with the quantity of a particular waste

stream, its toxicity, or persistence in the environment. Policies aimed at solving one problem may

have unintended negative effects on another; for

example, requiring automobiles to be made from

currently recyclable materials could adversely affect

their fuel efficiency. Inevitably, tradeoffs and value

judgments must be made as to which environmental

impacts are the most important.

Disagreements about how to define the environmental problem may also reflect more fundamental

philosophical differences. Industry tends to frame

the problem in terms of reducing the quantity of

waste destined for disposal, while environmental

groups often focus on threats to natural resources

and ecological “sustainability.” These different

problem statements lead to different policy prescriptions and different ideas about what constitutes

green design. Clearly defining the problem to be

addressed can help to elevate the level of debate and

to identify possible areas of compromise.

In the absence of a clearly defined problem, it

becomes easy to confuse means and ends. Proxies

for environmental quality, such as recycling, can

come to be perceived as ends in themselves, rather

than as one of several strategies for reducing solid

13 me Pmwm i5 c~led NatiOn~ Industi Competitiveness through Efficiency: Energy, EnViromnenL fionomics ~~3).
Chapter 1--Executive Summary ● 19

waste. By mandating that products and packaging

contain a minimum recycled content, for instance,

Congress would certainly encourage product designers to use recovered materials in packaging; but this

would not necessarily result in less waste overall.

Perversely, this could even lead to more waste,

especially if designs featuring waste prevention are

thereby discouraged. If the objective is to reduce the

amount of solid waste generated, MSW policies and

government procurement programs should make

allowances for product designs that feature waste

prevention.

Defining the problem properly must entail some

consideration of environmental risks. OTA finds

that policymakers currently lack critical information

on how materials flow through the economy and

about the relative risks of different materials and

products. For example, 10 States have passed

legislation banning the use of heavy metals in

packaging, even though this source contributes only

4 to 7 percent of heavy metals in landfills and

incinerators. Without research to develop information on materials flows and relative risks, resources

are likely to be directed toward the most visible

Photo credit: Dupont Magazine (July/August 1991)

A thin plastic milk pouch uses less material than a

traditional paperboard carton, and takes up less

space in a landfill.

problems, rather than those that pose the greatest

environmental risks.

Principle 2: Give designers the maximum flexibility that is consistent with solving the problem.

Materials technology options are proliferating

rapidly, and product impacts on the environment are

nearly always multidimensional. Policies should be

crafted to give designers as much flexibility as

possible to find the best solutions, within a framework that protects human health and the environment. Rigid Federal mandates that impose predetermined design solutions (such as bans on the use of

certain materials) are likely to be inefficient, and

should be avoided if possible. Flexibility can be

achieved through a variety of means, including

flexible regulations, economic instruments, and

negotiated voluntary agreements with industry.

One tradeoff for increasing policy flexibility is

likely to be increased costs of policy monitoring and

enforcement. For example, verifying compliance

with a ban on the use of a given material or chemical

requires less information than verifying compliance

with voluntary agreements or flexible regulations.

For this more flexible approach to work, the cost of

demonstrating compliance will probably have to be

borne by industry.

Principle 3: Encourage a systems approach to

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

If policymakers focus exclusively on addressing

the environmental attributes of products, as opposed

to the systems in which products are manufactured,

used, and disposed, they are likely to miss the

biggest opportunities for green design.

A system-oriented design approach can be encouraged either directly by regulation, or indirectly

through economic incentives. Recycled content

regulations or manufacturer take-back requirements

are examples of a regulatory coupling between

manufacturing and waste management. The proposal of the German Government to require auto

manufacturers to take back and recycle their cars, for

example, has stimulated the German automakers to

rethink the entire ‘‘ecology’ of auto production and

disposal (box l-A). This approach may be more

appropriate for high-value, durable products than for

nondurable or disposable products.

An alternative to take-back regulations is to

indirectly encourage designers to take a systems

approach by using economic instruments to internalize the costs of environmental services. This approach would rely on market forces to sort out what

new interfirm relationships make sense economically, while giving designers the flexibility to

design products with the best combination of cost,

performance, and least environmental impact. For

example, a substantial carbon tax on fuels could

have a dramatic impact on the systems by which

products are manufactured, distributed, and disposed, because fuels are consumed at every stage of

the product life cycle.

CONCLUSION

Green product design offers a new way of

addressing environmental problems. By recasting

pollution concerns as product design challenges, and

particularly by encouraging designers to think more

broadly about production and consumption systems,

policymakers can address environmental problems

in ways that would not have been apparent from a

narrow focus on waste streams alone.

The flow of materials and products through the

world economy has a critical influence on both

economic growth and the environment. These flows

are determined in part by design decisions. Therefore, policymakers should strive to make green

product design an integral part of strategies to

improve competitiveness and environmental quality. OTA’s analysis suggests that simply providing

information to designers and consumers about the

environmental impacts of products and waste

streams is not enough. To move ahead, the environmental costs of production, consumption, and disposal should be accounted for at each stage of the

product life cycle. The challenge to policymakers is

to choose a mix of regulatory and economic instruments that target the right problems and give

designers the flexibility to find innovative, environmentally elegant solutions.
Environmental

Chapter 2

Aspects

of Materials Use
Contents

Page

HOW PRODUCT DESIGN AFFECTS THE ENVIRONMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

TRENDS IN MATERIALS USE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Increasing Variety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 . *, . . . . + * .,, ....,... 26

Increasing Efficiency ... .*** . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Increasing Complexity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Driving Factors ... ... ..*. **. *.. .*. ... ..*. ... *.. ... *.*. ... ... ... ... ... ... ... .$ooo4*o. o* 29

ENVIRONMENTAL POLICY IMPLICATIONS OF MATERIALS TRENDS .............31

Looking Ahead . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Figures

Figure Page

2-1. Stages Of the Product Life Cycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2-2. Municipal Solid Waste Management (1960-90) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

2-3. “Solid” Wastes as Defined Under the Resource Conservation and Recovery Act . . . . . . . 26

2-4. U.S. Raw Material Consumption (1900-89) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

2-5. Materials Used for Manufacturing Telecommunications Cables

by AT&T Technologies ● . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . * * . . . . . . . . . . . . . 29

2-6, Cross-Section of a Snack Chip Bag ,***. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Chapter 2

Environmental Aspects of Materials Use

The world economy is consuming resources and

generating wastes at unprecedented rates. In the past

100 years, the world’s industrial production increased more than 50-fold,l releasing some materials to the environment at rates that far exceed

releases occurring naturally. Human activities are

estimated to release several times as much chromium, nickel, arsenic, and selenium to the atmosphere as do natural processes, and over 300 times as

much lead.2 Carbon dioxide levels in the atmosphere

are increasing at a rate 30 to 100 times faster than the

rate of natural fluctuations observed in the climatic

record.3

The U.S. economy is among the most material

intensive economies in the world, extracting more

than 10 tons (20,000 lb) of “active” material per

person from U.S. territories each year.4 Most of this

material becomes waste relatively quickly. By one

estimate, only 6 percent of this active material is

embodied in durable goods; the other 94 percent is

converted into waste within a few months of being

extracted. 5

These statistics on material flows do not directly

measure the increased risks to human health or

ecosystems, but recent experience with ozone depletion and the threat of global warming indicates that

such explosive growth in materials flows could have

profound and possibly irreversible environmental

consequences. This growth is expected to continue;

by the middle of the next century, the world

population is expected to double,6 and the global

economy could be five times as large.7

The environmental risks posed by increasing

materials flows can be addressed both by improving

industrial efficiency and by substituting less damaging materials for those currently in use. For example,

substitutes for chlorofluorocarbons (CFCs) are becoming available as the production of these ozonedepleting chemicals is phased out. However, such

actions tend to be taken only in direct response to

government regulations or after some specific environmental problem has reached threatening dimensions. Industrial production decisions have generally

not considered the environmental impacts of materials and process choices in a proactive way.

HOW PRODUCT DESIGN

AFFECTS THE ENVIRONMENT

Product design decisions have impacts on the

environment at each stage of the product life cycle,

from extraction of raw materials to final disposal

(figure 2-1). Ideally, one would like design decisions

to take account of both the “downstream” impacts

(product use and disposal) as well as the “upstream” impacts (materials extraction, processing,

and manufacturing).

The most publicly visible environmental impacts

associated with products are the “downstream”

impacts, particularly municipal solid waste (MSW).

U.S. households and commercial establishments

generate about 4 pounds of trash per person each

day. In 1988, the United States generated some 180

million tons of MSW (figure 2-2). This amount is

expected to increase by about 1.5 percent per year,

resulting in total MSW generation of over 215

1 Baaed on data from W.W. Rostow, The WorZd Economy: History and Prospects (Austin, TX: University of Texas Press, 1978), pp. 48-49.

z J~es N. G~oway, J. David ~orntom Stephen A. NortoQ Herbert L. Volcho~ and Ronald A.N. MC~~AfwSphetiCEnVirOn~nt 1W):16T8,

1982. See also Robert U. Ayres, “’lbxic Heavy Metals: Materials Cycle Optimization” Proceedings of the NationaZAcademy of Sciences, vol. 89, No.

3, Feb. 1, 1992, pp. 815-820.

3 U*S. COwe55, ~lce of TW.olomA~~=~mm~ c~nging @Degree~: steps TORe&ce Greenhouse Gases, oTA-o-4g* (Washington, DC: U.S.

Government Printing Office, Febmary 1991), p. 45.

g “~tive’~ ~te~ ~cludes fo~, fiel, foms~ pr~ucts, ores, and nonmetallic. It excludes inert construction Wterids such * sand Wvels ~d

stone, as well as atmospheric oxygen and fresh water. Robert U.“Industrial Ayres, Metabolisnq” Technology and Environment (Washington DC:

National Academy Press, 1989), p. 25.

5 lbi~ p. 26.

s Ufited Nations, DW~~t of ~ter~tion~ Economic and Social Affairs, Long-Range World Population Projections: TWO Ce?ltin”f?s Of

Population Growth 1950-2150 (New Yorlq NY: United Nations, 1992), p. 14.

7 G~rge Hea@u Ro&~ RepettO, and RO~eY sob~ TranSfO~”ng Technology: An Agenda for Environmentally Sustainable Growth in the 21st

Century (WashingtorL DC: World Resources Institute, April 1991), p, 1.

–23-
24 ● Green Products by Design: Choices for a Cleaner Environment

Figure 2-l-Stages of the Product Life Cycle

Material extraction Material processing Manufacturing

t t

Recycle Remanufacture

Use

t

Reuse

Waste management

Environmental impacts occur at all stages of a product’s life cycle. Design can be employed to reduce these impacts by changing the

amount and type of materials used in the product, by creating more efficient manufacturing operations, by reducing the energy and

materials 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.

million tons by the year 2000.8 Landfills in many

States are reaching their permitted capacity, and

there is increasing public opposition to siting new

waste management facilities. One major reason for

this opposition is concern about toxic materials

released from these facilities, e.g., when batteries are

incinerated, or when household hazardous waste is

placed in landfills.

Less visible but potentially more serious environmental impacts occur during raw material extraction, material processing, and product manufacturing. U.S. industry generates some 700 million tons

of “hazardous waste” and some 11 billion tons of

‘‘non-hazardous’ solid waste.9 Although the weight

of industrial and municipal solid waste cannot be

compared directly,l0 industrial wastes dwarf municipal solid wastes in their quantity and environmental

impact (see figure 2-3).11 Product design decisions

have a direct influence on the manufacturing component of these wastes (about 6.5 billion tons).

Finally, some of the most serious environmental

releases occur during the actual use of the product.

This is particularly true of products that are consumed or dissipated during their use (e.g., volatile

solvents and propellants, fuels, cleaners and paints,

and agricultural fertilizers and pesticides) .12 Prime

examples are CFCs used as coolants, solvents, and

8 U.S. Environmental Protection Agency, Characterization of Municipal Solid Waste in the United States: 1990 Upalxe, June 1990, pp. ES-3 and

75; U.S. Congress, Ofllce of Technology Assessmen4 Facing America’s Trash: What Nextfor Municipal Solid Waste, OTA-0+24 (Washington DC:

U.S. Government Printing Ofilce, October 1989).

g The terms hazardous and non-hazardous are defiied by the Resource Conservation and Recovery Act (NRA), Subtitles C and D, respectively.

Industrial solid wastes not defined as hazardous under Subtitle C fall under Subtitle D of RCM. See U.S. Congress, Office of Technology Assessmen~

Managing Industrl”al Solid Wastes From Manufacturing, Mining, Oil and Gas Production, and Utility Coal Combustion-Background Paper,

OTA-BP-O-82 (Washington DC: U.S. Government Printing OffIce, February 1992), pp. 4-15.

10 Up @ 70 ~rwnt of tie weight of indmtrial solid waste (which includes mining, oil and gas, and ~UfachKiUg wastes) co~iss of w~te~~r

contained in sludges and aqueous solutions.

11 A fiwe 2.3 ~dicates, indus~ w~tes clearly dwarf MSW by weight. In terms of environmental tipacti even if M ~W wem “kdous,”

industrial “hazardous” wastes alone would still be three times as large. Furthermore, some of the “non-hazardous” wastes do not differ substantially

horn wastes designated as “hazardous” under the Resource Conservation and Recovery A@ or they may exhibit other characteristics of concern (see

OTA, h4anaging Industrial Solid Wastes From Manufacturing, Mining, Oil and Gas Production, and Utility Coal Combustion-Background Paper, op.

cit., footnote 9, p. 12).

12 For c~plc, the energy r~cd @ manufacture motor vehicle components and assemble those components into ftished vehicles totdd ahut

1.5 quadrillion Btu (quads) in 1985. However, the fuel used in motor vehicles totaled more than 10 times that amount. Sources: U.S. Congress, OffIce

of Technology Assessment Energy Use and the U.S. Economy, OTA-BP-B57 (M%hingto% DC: U.S. Government Printing Office, June 1990), p. 3;

U.S. Department of Energy, Energy Information Administratio~AnnuaZEnergyReview 1990, DOE/EIA-0384(90) (Washington DC: U.S. Gov anment

Printing OffIce, May 1991), p. 53.
Chapter 2--Environmental Aspects of Materials Use ● 25

200

180

160

140

2 120

~

~ 100

2

~ 80

2

60

40

20

0

Figure 2-2—Municipal Solid Waste Management (1960-90)

1960 1965 1970 1975 1980 1985 1990

The generation of municipal solid waste (MSW) roughly doubled in the last three decades, increasing from 88 million tons in 1960 to 196

million tons in 1990 (population growth accounts for roughly one-third of the increase). Techniques of managing MSW changed somewhat

during this period: recycling and comporting increased substantially; total incineration remained roughly constant but nearly all incineration

now occurs with energy recovery; Iandfilling increased for most of the period, but has leveled off in recent years.

SOURCE: Franklin Asm”ates, Ltd., personal communication, August 1992.

blowing agents, which have been linked to depletion

of the stratospheric ozone layer.

In some cases, the environmental releases from

products can be larger than those from the associated

industrial processes. For example, heavy metals

(e.g., mercury, lead, cadmium, chromium, and

nickel) are among the most toxic constituents of

industrial wastes.13 Although complete data on

industrial inputs and outputs of heavy metals are

scarce, data collected under New Jersey’s Worker

and Community Right to Know Act of 1983 indicate

that most heavy metals that enter industrial processes end up in products, not industrial wastes. In

1990, for example, at least 55 to 99 percent of

industrial inputs of these five heavy metals were

used in products, depending on the metal.14 While

some of these products are recovered and recycled,15

much of the heavy metal content of products is

released into the environment (e.g., in paints and

coatings) or enters landfills and incinerators (e.g., in

plastics).

TRENDS IN MATERIALS USE

During this century, dramatic changes have occurred in the nature of the materials Americans use

to manufacture products. Figure 2-4 shows the

consumption of different classes of materials in the

United States between 1900 and 1989.16 The top half

of the figure shows consumption in absolute terms.

During the past 90 years, consumption of raw

materials derived from agricultural and forestry

commodities has grown slowly. In contrast, there

has been dramatic growth in consumption of raw

13‘rhese five heavy me~s Me all targeted in the Environmental Protection Agency’s 33/50 progr~ an effort aimed at encouraging industry to

vohmtarilyreduce releases of 17 priority chemicals 33 percent by the end of 1992 and 50 ptxcentby the end of 1995. See U.S. Environmental Protection

Agency, Office of Pollution I%evention and Toxics, Pollution Prevention Resources and Training Opportunities in 1992, January 1992$ pp. 84-85.

14 J.)abfrom Andrew opperma~ New Jersey Department of Environmental Protection and Energy, Community Right to mow pro= BIUCXUI of

Hazardous Substances InformatiorL personal commurdcatio~ August 1992.

15 Rqc@ ~tes Vw subs~nti~ly by ~terial. For example, more than 50 percent of lead is reCyCkd, but nmly ~ cadmium is rela ~to the

environment.

16 Figures 2-4s and 2-4b measur e material consumption by value to allow aggregation of diverse material types such as bales of cotto~ barrels of oil,

tons of ore, and cubic feet of gas. The figure only includes materials consumed for uses other than food and fuel. Source: David Berry, Program Manager,

Material Use Trends and Patterns, Bureau of Mines, U.S. Department of the Interior, personal communication July 1992.
26 ● Green Products by Design: Choices for a Cleaner Environment

Figure 2-3-’ ’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 (0.7)

hazardous (11)

t--

Manufacturing (6.5)

.0)

Much of the solid waste produced in the United States is not directly generated by consumers. Municipal solid waste, the focus of much

public concern, represents less than 2 percent of all solid waste regulated under RCRA. In contrast, industrial activities produce about 700

million 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 D

of RCRA, respectively. The mining wastes shown in (b) exclude mineral processing wastes; the oil/gas wastes in (b) exclude produced waters used

for 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 /ndustria/ Solid Wastes Fmm Manufacturing, Mining, W and Gas

/%duct/on, and Wity Coa/ Combustion, OTA-BP-O-S2 (Washington, DC: U.S. Government printing Office, February 1992).

materials derived from ores and minerals (used in the

production of steel, aluminum, and asbestos) and of

raw materials derived from organic feedstocks (used

in the production of plastics, fibers, petrochemicals,

and asphalt).

The bottom half of figure 2-4 shows these shifts

in comparative terms. In 1900, the majority of the

raw materials consumed were derived from agricultural and forestry products. By the late 1980s,

materials derived from ores and minerals constituted

about 50 percent of all raw materials, up from only

about 30 percent in 1900; materials derived from

organic feedstocks (such as plastics, fibers, petrochemicals, and asphalt) comprised about 15 percent

of the total, while in 1900 these materials practically

did not exist.

A closer examination of these changes reveals

three important trends in materials use: increasing

variety, increasing efficiency, and increasing complexity. These trends are closely related, but each is

significant in its own right.

Increasing Variety

Materials use has changed not only in terms of the

relative amounts of different materials, but also in

the variety of materials available. A century ago,

U.S. industry utilized only about 20 elements of the

periodic table; today, virtually all 92 naturally

occurring elements are used.17 Moreover, with

advances in the understanding of the structure of

physical matter, researchers have created thousands

of chemical compounds and a broad array of novel

materials. In chemicals alone, it is estimated that

over 60,000 have been synthesized and roughly

10,000 are produced in commercial quantities.18

About 1,000 new chemicals are introduced each

year, and are incorporated into products as diverse as

pharmaceuticals, superadhesives, and agricultural

pesticides. 19

Remarkable advances in structural materials technologies have led to the development of ceramics

and composites that offer superior properties (e.g.,

high-temperature strength, high stiffness, and light

weight) compared with traditional materials such as

17 A4aterials andMan’sNe~s: The History, Scope, and Nature of Materials Science andEngineering, VO1. L (wSSh@tOLL m: Natiod M$.W

of Sciences, September 1975), ch. 1, p. 2.

1S ~c~el Shapiro, “Toxic Substances Poficy,” Public Policiesfor Environmental Protection, Paul R. Portney (cd,) (WsshingtoQ DC: Resources

for the Future, 1990), p. 195.

19 Ibid.
Chapter 2--Environmental Aspects of Materials Use ● 27

Figure 2-4--U.S. Raw Material Consumption (1900-89)

1900 1910 1920 1930 1940 1950 1960 1970 1980 1989

1900 1910 1920 1930 1940 1950 1960 1970 1980 1989

U.S. raw material consumption has changed dramatically in this century. In absolute terms (top), raw material consumption has increased

by a factor of 4 (population has increased by roughly a factor of 3 during the same period). The largest increases were in materials derived

from mining operations (metals and nonmetallic ores) and from organics (plastics and petrochemicals). In relative terms (bottom), the

sources of raw materials consumed in the United States have gone from predominantly agriculture and forestry to predominantly mining

and organics.

NOTE: The data measure material consumption by value to allow for aggregation of diverse material types. The data oniyinclude materials consumed for uses

other than food and fuel.

SOURCE: Data prior to 1978 from Vivian E. Spencer, %w Materials in the United States Eoonomy, 1900-1977 (Washington, DC: U.S. Department of

Commerce, Bureau of the Census, 1980); data after 1978 from Bureau of Mines, op. cit., footnote 16.
28 ● Green Products by Design: Choices for a Cleaner Environment

steel and aluminum.20 These materials can be

engineered to have the precise properties required

for a given application. Use of such designed

materials can lead to higher fuel efficiency, lower

assembly costs, and longer service life for many

manufactured products.

Recent developments in materials technology are

impressive in terms of both breadth and ingenuity.

High-temperature superconductors offer the promise of extremely efficient electronic devices and

power transmission systems.21 Conductive plastics

may someday combine the electrical characteristics

of copper with the strength of steel, and may lead to

lightweight batteries and electric motors.22 ‘Smart’

materials-materials that sense and react to changes

in their operating environment-may result in helicopter rotors that stiffen in response to turbulence or

temperature fluctuations, or shock absorbers that

automatically adjust to changing driving conditions.

Molecular beam epitaxy techniques allow semiconductor devices to be built atom by atom, suggesting

the possibility of hand-held supercomputers and

ultra-small, low-power lasers for use in communications. 23

Even the profound impacts of these so-called

“engineered materials” may eventually be overshadowed by biologically derived substances. By

harnessing the enzymes of nature, an entirely new

range of nontoxic, renewable, biodegradable, and

biocompatible materials may be on the horizon.

Researchers are looking at how biopolymers might

be used for applications as diverse as artificial skin,

superabsorbants, dispersants, and as permeable coatings for agricultural seed. Several biologically

derived polymers are already in production.24 Ultimately, plants may be genetically programmed to

produce plastic instead of starch.25 Such developments could potentially reduce society’s dependence on petroleum-based materials.

Increasing Efficiency

New processing technologies, more sophisticated

materials, and improved product design have resulted in the more efficient use of materials. For

example, an office building that can be built with

35,000 tons of steel today required 100,000 tons 30

years ago.26 similarly, aluminum cans today weigh

30 percent less than they did 20 years ago.2728

Traditional materials have been displaced in

many applications by new light-weight materials

such as high strength alloys and plastics. For

example, telecommunications cables in the 1950s

consisted mostly of steel, lead, and copper, with a

small percentage of aluminum and plastics (figure

2-5). By the 1980s, the plastics content of cables had

increased to more than 35 percent and the lead

content had dropped to less than 1 percent. If

polyethylene had not replaced lead as cable sheathing, AT&T’s lead requirements might have approached a billion pounds annually.29 The process of

substitution continues: today, 2,000 pounds of

211 See U.S. Cogess, Offlce of Technology Assessment, Advanced MateriuZs by Design, OTA-E-351 Of@hington, DC: u-s. Gov~nm~t W*

CM&e, June 1988).

21 U.S. Congress, mice of Technolo~ Assessmen~ High-Ternpet-ature Superconductivity in Perspective, OTA-E-44(I (wwhingto~ DC: U.S.

Government Printing Office, April 1990).

22 ~~~e ~ofie of Conductive Pl@ics,” EPRIJournal, Jdy/August 1991, PP. 5-13.

~ U.S. Co=ess, offke of Technolog Assessment, Miniaturization Technologies, OTA-TCT-514 (Washington DC: US. Government ~@g

Oflke, November 1991).

m The chemi~ fii ICI is producing about 50 tons of polyhydroxybutyzate-valerate (PHBV) annually. See William D. Lufier, “wtti~s D~ved

From Biomass/Biodegradable Materials,’ Proceedings of the National Academy of Sciences, vol. 89, No. 3, Feb. 1, 1992, pp. 839-842.

~ “In Search of the Plastic Potato,” Science, Sept. 15, 1989, pp. 1187-1189,

~ Milton Deaner, ~esiden~ American Iron & Steel Institute, presentation at the Bureau of Mines Forum on Materials Use, Washhgton, XSept.

17, 1991.

~ S. Dotidpitts, Vice ~esidm~ AlumjxuunA ssociatiow presentation at rhe Bureau of Mines Forum on Materiak Use, Washington, DC, Sept. 17,

1991.

2s ‘rh.is ~aeu~g materi~s efficiency is a component of what some observers call ‘ ‘dematerialization”-a decrease in the matefia.k consumed per

unit of GNP. See Robert H. Williams, Eric D. Larsou and Marc H. Ross, “Materials, Affluence, and Industrial Energy Use,” AnnualReviewofEnergy

12:99-144, 1987; Robert H~ Siamak A. Ardekani, and Jesse H. Ausubel, “Dematenalizatio~” Technology and Environment (Washingto% DC:

National Academy Press, 1989), pp. 5069. Dematerialization offers the possibility that economic growth may not inevitably lead to more materials use.

29 Jesse H. Ausubel, “Re@uities in Technological Development: An Environmental View,’ Technology and the Environment, Jesse H. Ausubel

and Hedy E. Sladovich (eds.) (Washingto~ DC: National Academy Press, 1989), pp. 70-91.
Chapter 2--Environmental Aspects of Materials Use ● 29

Figure 2-5—Materials Used for Manufacturing Telecommunications Cables by AT&T Technologies

Plastics

Lead

Aluminum

Copper

Steel

1955 1984

The composition of telecommunications cables illustrates the changing use of materials. Polyethylene has replaced lead as the dominant

material in the cables’ sheathing. This shows how material substitution can reduce the use of materials with adverse environmental impacts.

SOURCE: P.L. Key and TD. Schiabach, “Metals Demand in Teleeommunieations,” Mater/a/s and Soeh?fy 10(3):433-451, 1986.

copper can be replaced by 65 pounds of fiber-optic

cable, with the production of fiber consuming only

5 percent of the energy required for copper.30

Increasing Complexity

Statistics concerning materials consumption do

not capture a more subtle change with potentially

important environmental consequences: a trend

toward increasing complexity of materials use. As

noted earlier, advances in chemistry, materials

science, and joining technology have made it

possible to combine materials in new ways (e.g.,

anticorrosion coatings on metals, or fiber-reinforced

composites) to meet performance specifications

more cheaply. This creates products that are more

complex from a materials point of view.

As an illustration, consider the modern snack-chip

bag depicted schematically in figure 2-6. The

combination of extremely thin layers of several

different materials produces a lightweight package

that meets a variety of needs (e.g., preserving

freshness, indicating tampering, and providing product information) .31 The use of so many materials

effectively inhibits recycling. On the other hand, the

package has waste prevention attributes; it is much

lighter than an equivalent package made of a single

material and provides a longer shelf life, resulting in

less food waste.

Other products exhibit similar complexity. For

example, automobiles are composed of a vast array

of different materials, including high-strength steel,

aluminum, copper, ceramics, metal-matrix composites, and more than 20 different types of plastic.32

Even household laundry detergents contain many

different components, each with a specific function:

enzymes to dissolve biological stains, bleaches to

whiten cleaned garments, and ‘builders’ to prevent

dislodged dirt from resettling on fabrics.33 The

greater complexity of these products offers benefits

to consumers, but this complexity also makes it

more difficult to evaluate their environmental attributes.

Driving Factors

While these trends have important implications

for future environmental policy, they are evolving

independently of environmental considerations. Instead, they are driven by economic factors, by

w U. COIODM, PKXCC@S oftie sixth Convocation of the Council of Academies of Engineering and Technological Sciences, pp. 26-27,1988, cit~

in Hermaq Ardekani, and Ausubel, op. cit., footnote 28.

31 Coun~l on plastics and packaging in the Environment COPPEInfo Backgrounder, “The Search for the Perfect Package: Packaging Design and

Developmen~’ Mamh 1992.

32 FrW R. Fiel~ Materials Technology: Automobile Design and the Environment, contractor report prepared for the ~lm of TCZhUOIOSY

Assessment, May 6, 1991.

m ~dy Cow ‘lIt My Be Green But Is It Clean?” New Scientist, M.Sy 4, 1991, P. 22.
30 ● Green Products by Design: Choices for a Cleaner Environment

Figure 2-6-Cross-Section of a Snack Chip Bag

● Machinability

c Adhesion

● Moisture barrier

● Stiffness

● Clarity

“ Puncture resistance

● Ink adhesion

● Graphics quality

o Interlaminar adhesion

● Barrier to oxygen,

moisture, and light

● Metal adhesion

Polypropylene I

● Stiffness

● Moisture barrier

I I

● Seal integrity

● Hot seal strength

Q 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, and

consists of nine different layers, each with a specific function. While such complexity can inhibit recycling efforts, it also can reduce the

overall weight of the bag, and keep food fresher, thus providing waste prevention benefits.

SOURCE: Council on Plaetics and Packaging in the Environment.

advances in technology, and by competition to

satisfy changing consumer needs. For example, high

repair costs prompt many customers to buy new

goods rather than repair old ones. 34 This has

encouraged the design of more sophisticated, selfcontained products (e.g., consumer electronics with

batteries sealed inside) that are intended to be used

and thrown away. The creation of nonrepairable,

nonserviceable items has also been motivated by

liability concerns relating to product safety .35 Meanwhile, improved manufacturing technologies have

brought down the cost of such products, and more

consumers can afford to purchase them, resulting in

a greater number of goods that are discarded.36

The application of information technology to all

stages of the production and marketing process has

made shorter production runs affordable, enabling

manufacturers to differentiate their product offerings and aim at narrower market niches. This has

resulted in a proliferation of product lines (e.g., in

automobiles, appliances, and computers). The increased ability to tailor products to individual needs

comes at a time when changing lifestyles and a more

diverse population are fueling demand for a wider

~ ~emcycle Corporation Environmentally SoundProductDevelopment in the ConsumerE1ectronics andHouseholdBattery Indutties, con~cmr

paper prepared for the OffIce of Technology Assessment July 1991.

35 AS goods Mve bmome mom complex, the potential for consumer injury during repair has in many cases increased. It is not surprising Wew @t

manufacturers are designing products so as to discourage consumer repah. Ibid.

~ Ibid.
Chapter 2--Environmental Aspects of Materials Use ● 31

range of goods and services.37 Elaborate production

networks have been developed to meet the demands

of these diverse markets (see chapter 4).

ENVIRONMENTAL POLICY

IMPLICATIONS OF

MATERIALS TRENDS

Are these trends good or bad for the environment?

The answer is not always clear. Although complex

products may be less recyclable, they may at the

same time be more efficient in their use of energy

and materials. For instance, advanced composite

materials allow lighter components to be used in cars

and aircraft, and consequently can lead to significant

lifetime fuel savings and reduced air emissions.

Multilayer food packaging can extend food shelf

life. Steel-belted radial tires can be used year round,

and are more durable than previous generations of

tires.

With technologies available to create new materials and to combine conventional materials in new

ways, designers are faced with more choices than

ever before. Increasingly, these choices involve

environmental dilemmas. Energy-efficient compact

fluorescent bulbs, for example, contain mercury, a

toxic heavy metal. In cases such as this, tradeoffs

will be required, not only between traditional design

objectives and environmental objectives, but among

environmental objectives themselves: for example,

waste prevention vs. recyclability, or energy efficiency vs. toxicity. In general, every design will

have its own set of environmental pluses and

minuses. This suggests several conclusions:

● The environmental evaluation of a product or

design should not be based on a single attribute,

such as recyclability; rather, some balancing of

●

●

pluses and minuses will be required over its

entire life cycle.

The trend toward complexity seems certain to

make the environmental evaluation of products

more difficult and expensive in the future.

Policies to encourage green design should be

flexible enough to accommodate the rapid pace

of technological change and a broad array of

design choices and tradeoffs.

Looking Ahead

The pace of materials technology innovation

continues to accelerate. As this chapter has shown,

these innovations can lead to greater efficiency in

materials use and less waste generated, measured per

unit of production. This is an environmental triumph

of a sort, since it means that environmental quality

is greater than it would have been had these

innovations not occurred. Policymakers should encourage these changes, but they must also recognize

that what matters for future environmental quality is

not just industrial efficiency, but the absolute

quantity of resources used and wastes released to the

environment. In absolute terms, more goods and

services are being produced, and more wastes are

being generated every year.

It is an open question whether present policies

regarding economic growth can avoid irreversible

environmental impacts or whether a drastic change

is required. Conventional economic indicators do

not address issues such as species loss and global

climate change. To effectively face these challenges,

measures of economic progress will have to be

broadened to include not only industrial efficiency,

but the overall health of human populations and

ecosystems. 38 The next chapter explores how designers can begin to address these issues.

37 More women WOrking outside the home and less leisure time translates into increased demand for convenience products SU* W S@Jle_

packages and microwaveable dinners. See U.S. Congress, Wlce of Technology Assessmen6 Technology and the American Economic Tranm”tion:

Choicesfor the Future, OTA-TET-283 (Washington, DC: U.S. Government Printing Office, May 1988), p. 22.

38 ~ae is a v~e~ of ongoing work in this area. See Robert Repetto, “Accounting for Environmental Assets,” Scientij’7c Ameri”can, June 1$IZ PP.

94-1oo.
Chapter 3

Product Design and

the Environment
Contents

Page WHAT IS GREEN DESIGN? *.. *.. ,*s, .., *,. ..*4. .*, ..*. .*** 4m, ,*qt, ****, **, **ea. ,**ae 36

Design for Waste Prevention **. *.. ... *.. ..*. ... ,.. .*. ,.m***o **** *+** .*,4

, *,*4 c**+,*** 37

Design for Better Materials Management ... ..#. ... ... ... .,**, *e** .++, o***, **++ *****m,* 39

HISTORY OF GREEN DESIGN .*. ... ... *.. ... ... **. ,*. ,.*4, **+#, ***, a**, *a

, ***a +*o. m, 43

ALTERNATIVE VIEWS OF GREEN DESIGN + *.**,**,+.,..**..**,****+*,+,*,*,***,  44

Paradigm 1: Environmental Protection ** . *,. .*. ..** .*. ... +

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Paradigm 2: Resource Management *.. ... ... +*. ... ... ... .+

. *., *.*e*, *m** c*a. ,,a Q* *#a** 45

Paradigm 3: Eco-Development ***. *.*, ..*. .*. .*. .*, ***, *e** ***, ,.***, ******e,********* 45

Analysis *,*. ,,. ... ... +

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APPENDIX A: THE AUTOMOBILE DEVELOPMENT’ PROCESS . . . s ...................47

Boxe s

Box

3-A. Getting the Lead Out . ..*.**..*...**.*,.*.,.**,

3-B. Modular Design in the Housing Industry . . . . . . . .

3-C. Remanufacturing ● ........,*.....**.,+,.*.*,.*

Design Helix . . . . . . . . . . . . . .

Figures

Figure

3-1. The ● . . . . . . . . . . . . . .

3-2. The Dual Goals of Green Design . . . . . . . . . . . . . . .

- Table

Table

3-1. Principles for Disassembly . . . . . . . . . . .

.*. *.+* *.#, .., *.*, ***+ .*+* a*, *e*,*** . 3 9

4 .*4*.**.*...*.+.,....,..*.**,***.* 4

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Chapter 3

Product Design and the Environment

Product design

product attributes

is a process of synthesis in which

such as cost, performance, manufacturability, safety, and consumer appeal are considered together.1 These principal design parameters

are often constrained by regulatory requirements—

for example, fuel efficiency targets, building codes,

or tamper-proof packaging specifications. Thus, in

virtually all cases, designers are forced to make

tradeoffs among competing criteria.2 At each stage

of the design cycle, solutions are evaluated and

reevaluated in light of a diverse ensemble of

technical, economic, and social objectives. (For a

discussion of how the design process works in the

automotive industry, see appendix 3-A.)

The National Research Council has estimated that

70 percent or more of the costs of product development, manufacture, and use are determined during

the initial design stages. 3 Design is therefore a

critical determinant of a manufacturer’s competitiveness. Because of the strategic importance of

design, many corporations are adopting comprehensive programs for developing and introducing products. 4 With greater attention being given to the

design process, new approaches to product development are emerging.

Companies are discovering that they cannot

afford to have designers develop a concept in

isolation and then toss it “over the wall” to

production engineers. Instead, a “concurrent” design process is increasingly used, as depicted in

Figure 3-1.5 The product evolves continuously

through a spiral of design, manufacturing, and

marketing decisions. As a product progresses along

the “design helix” toward commercialization, multidisciplinary product development teams take part

in every major design iteration. This multifunctional

approach safeguards product integrity and expedites

product development from stage to stage. Implementation of concurrent design methods have allowed many firms to dramatically cut product cycle

times, while delivering goods of superior performance and quality.6

The changing nature of design provides new

opportunities for integrating environmental concerns into the product development process. The

concurrent design methodology, with its multidimensional orientation, lends itself to the consideration of environmental impacts at every decision

point. Similarly, total quality management (TQM)

programs, which stress that quality must be “designed in,” rather than tested for at the end of the

production process, allow for a natural extension to

1 Historically, design has been divided into the fields of engineering design and industrial design. Engineering design primarily specifies a product’s

technical characteristics, while industrial design is principally concerned with the ‘feel” of a product, such as styling and ease of use (ergonomics). Most

products embody in varying degrees the inputs of these two disciplines. As used here, the term ‘designers” refers to all decisionmakers who participate

in the early stages of product development. This includes a wide variety of disciplines: industrial designers, engineering designers, manufacturing

engineers, graphic and packaging designers, as well as managers and marketing professionals.

2 For a general discussion of the design process, see Nam S@ The Principles of Design (New York, NY: Oxford University Press, 1990).

3 National Research Council, Zmproving Engineering Design: Designing for Competitive Advantage (Washingto~ DC: National Academy Press,

1991), p. 1.

4 For instance, Hewlett Packard, AT&T, and Ford have adopted such extensive product development strategies, sometimes known as “product

realization” programs. Ibid.

S See, e.g., “Concurrent Engineering,” IEEE Spectrum, July 1991, p. 22.

s Using concurrent pl tig techniques, Siemans Automotive has achieved extraordinary improvements in both productivity and quality. In 1975,

Siemansproduced 30,000 fuel injectors a month. In 1991, the company manufactured 30,000 fuel injectors a day with defect levels of 20parta permillion

(.002 percent). Through the collaboration of designers and process engineers, the number of grinding steps was reduced six-fold. Over that same period,

the direct human labor required for each fiel injector was reduced from 13 minutes to less than 2 minutes. Similarly, Motorola Inc., at one time mqdred

30 days to build a pager. By implementing cross-functional design techniques and introducing significant levels of automation a single pager can now

be manufactured in 30 minutes. PBS Series: “Quality or Else! Challenge and Change,” Oct. 18, 1991.

–35–
36 ● Green Products by Design: Choices for a Cleaner Environment

MANUFACTURING

SERVICE m

Figure 3-l—The Design Helix

ENGINEERING

DESIGN

m

.,

. .

;.. ,..:.” :.” :.

w-. :,,.

In a concurrent design process, each product discipline provides input into major design decisions. The

interchange between disciplines reduces the time required for product commercialization.

designing in

ity. "78 

SOURCE: GVO Design, Inc., Palo Alto, CA.

the product’s ‘‘environmental

WHAT IS GREEN DESIGN?

TING

qual- industry’s costs of releasing wastes to the air, water,

and land. Others, such as the Toxic Substances

Control Act and the Federal Insecticide, Fungicide.

and Rodenticide Act, control the use of hazardous

In general, products today are designed without chemicals and pesticides directly.

regard for their overall impact on the environment. Government regulations typically influence the

Nevertheless, many health and environmental laws design process by imposing external constraints, for

passed by Congress do influence the environmental example, requirements that automobile manufacturattributes of products. Some, such as the Clean Air ers comply with Corporate Average Fuel Economy

Act, Clean Water Act, and Resource Conservation (CAFE) standards, and with auto emissions standand Recovery Act, do so indirectly, by raising ards under the Clean Air Act. The Office of

7 See, e.g.: Global Environmental Management Initiative, Proceedings of the First Conference on Corporate Quali@Environmental Management,

Washingto~DC, Jan. 9-10, 1991; Charles M. Overby, “QFD and ‘lhguchiforthe Entire Life Cycle,” ASQC Quality Congress Transactions, Milwaukee,

WI, 1991; and W. David Stephenso~ “Environmentalism’s Strategic Advantage,” Quulity, November 1991, p. 20.

8 Contemporary designers have available an array of tools that can simultaneously improve product quality while reducing environmental impacts.

The use of computer-aided design and manufacturing tools can result in more effective utilization of materitdbfor example, Levi Strauss is using

computers to test out new fabrics, patterns, and designs before ever cutting apiece of cloth. The use ofjust-in-time delivery methods optimizes inventoxy

flows, and the integration of suppliers into the product development process ensures low defect levels and greater compatibility of product

subeomponents. Finally, statistical quality control methods that ident@proeess defects can improve factory efficiency andpromotepollution prevention.
Chapter 3--Product Design and the Environment ● 37

Figure 3-2—The Dual Goals of Green Design

Green design

Waste prevention Better materials management

Reduce: weight Facilitate: remanufacturing

toxicity recycling

energy use comporting

Extend: service life energy recovery

Green design consists of two complementary goals. Design for waste prevention avoids the generation

of waste in the first place; design for better materials management facilitates the handling of products

at the end of their service life.

SOURCE: Office of Technology Assessment, 1992.

Technology Assessment (OTA) uses the phrase

“green design” to mean something qualitatively

different: a design process in which environmental

attributes are treated as design objectives or design

opportunities, rather than as constraints. A key point

is that green design incorporates environmental

objectives with minimum loss to product performance, useful life, or functionality.

In OTA’s formulation, green design involves two

general goals: waste prevention and better materials

management (Figure 3-2).9 Waste prevention refers

to activities by manufacturers and consumers that

avoid the generation of waste in the first place.l0

Better materials management involves coordinating

the design of products with remanufacturing operations or waste management methods so that after

products have reached the end of their service life,

their components or materials maybe recovered and

reused in their highest value-added application.11

These goals should be viewed as complementary:

while designers may reduce the quantity of resources

used and wastes generated, products and waste

streams will still exist and have to be managed.

Design for Waste Prevention

The old dictum that “an ounce of prevention is

worth a pound of cure” is finding new relevance as

industries attempt to modify traditional design and

manufacturing practices. Examples of design for

waste prevention include reducing the use of toxic

materials, increasing energy efficiency, using less

material to perform the same function, or designing

products so that they have a longer useful life.

When a designer specifies a smaller quantity of a

material, that decision has a multiplier effect on both

the industrial and post-consumer waste streams.12

Waste discharges, emissions, and energy consumed

at each stage of the materials life cycle will decrease

in proportion to the amount of material used (see box

3-A). Similarly, increasing the lifetime of products

can result in direct waste reduction. Over a given

time interval, less waste is generated during materials extraction, product manufacturing, and disposal.

Related energy costs associated with processing and

transport are also reduced.13

Product life extension can be achieved through

use of more durable materials or through modular

g ‘rhis fom~ation first ap~~ in U.S. Congress, Oftlce of Technology Assessment, Facing America’s Trash: What Nextfor Munz”cipaZ Solid

Waste, OTA-O-424 (Washington DC: U.S. Government Printing OflIce, October 1989).

IQ See U.S. ConpSSs, ()~lce of Twhnology&s~~ent, SeriousReduction ofHazardous Waste: For Pollution Prevention andIndustrial Eflciency,

OTA-ITE-317 (Washingtorq DC: U.S. Government Printing Gff3ce, September 1986).

11 The &vi@ tie btw=nw=te preventiona~ better materials management is not always sharp. Forinstanee, remanufacturing helps to comae

resourees, and to avoid the generation of wastes that would otherwise have oecurmd. But OTA believes the distinction is nevertheless important to make.

Waste mamgement technologies generate environmental risks in their own right by designing for waste preventio~ these risks can be avoided.

12 For e~ple, for every ton of copper extracted in Own-pitg, 550 tons of materials are moved and processed. Mining and processing wastes

include substantial emissions of arsenic, sulphur dioxide, and other byproducts. These wastes could be drastically reduced if copper was used more

efilciently. See Robert Ayres, “Toxic Heavy Metals: Materials Cycle Optimization” Proceedings of the National Academy of Sciences, vol. 89, No,

3, February 1992.

13 w~tersfiel, “Design~ an Environmental Strategy,” Paper presented at the Industrial Designers Society of kencaNational Conference, Santa

Barbar4 CA Aug. 8-11, 1990.
38 ● Green Products by Design: Choices for a Cleaner Environment

Box 3-A--Getting the Lead Out

The General Motors Delco Remy Battery Division has made significant strides in reducing

hazardous constituents in both its products and

processing operations. In 1974, a typical battery

contained about 30 pounds of lead, whereas today

a battery with much improved performance weighs

only 19.5 pounds, This resulted in over 6 million

pounds of lead waste prevention during 1990. In

addition, the reformulation of alloy materials,

changing from antimony-arsenic to calcium-tin,

eliminated over 1 million pounds of antimony and

arsenic waste in that same year.

Pollution prevention strategies have also involved an increased emphasis on in-process recycling. In one facility, 4.2 million pounds of lead,

730,000 gallons of sulfuric acid, and 250,000

pounds of polypropylene were reclaimed and

reused. A new wastewater treatment process increases the percentage of lead in the resulting solids.

This allows the lead to be more readily recycled.

The solid precipitates are sent to a secondary lead

smelter rather than a hazardous waste landfill.

~OU’R~: GM ~~CO R@my ~ViS@.

designs that facilitate repair or upgrading of product

components (see box 3-B). Products that are designed in a modular fashion have components of

definable functionality that can be easily replaced or

upgraded without affecting other components. This

permits both products and product subcomponents

to be easily serviced or refurbished.14 It also allows

product performance to be maintained over a longer

time period, thereby obviating the need for buying

entire new systems.15

However, the actual useful life of a product is

affected by a number of external factors including

maintenance practices, conditions of use, and the

rate of technical or stylistic obsolescence.l6 While a

Photo credit: Office of Twhnology Assessment

Some products can be redesigned to reduce the use of

toxic substances. Over the past 5 years, manufacturers

have reduced the level of mercury in household batteries

by more than 85 percent.

number of industries have improved the durability of

their products in recent years, a large percentage of

materials that are extracted and processed through

the economic system are still transformed into waste

almost immediately.17

The belief that companies cynically pursue strategies of planned obsolescence in order to maximize

profits is overstated.18 Companies do shape consumer demand through their marketing strategies,

but they also respond to customer demand for

convenience and ease of product use. Since many

consumers exhibit a greater sensitivity to a product’s

initial cost rather than its lifetime costs, this can

inhibit the design of more durable, but expensive

products. This sensitivity to cost is particularly

evident in the area of energy-efficient home appliances and equipment-for example, air condition14 De~i@gprodUctss. that theyan~ ~ervi~d is notmu~lyexclusivewith designing forre~bi~ty+ But due topmficientlnantiacturing methOdS

and high labor costs, many complex products are designed to be extremely reliable over a given time period and then disposed (e.g., eonsumerelectronics

goods).

15 For example, “modular upgradability” is quickly becoming a de facto standard in the personal computer industry. Fast growth companies such

as Dell Computer Corp. and ASTRese.srch Inc. have based their success ondesigningmodular machines. The designs permit customers to take advantage

of the latest advances inmieroprocessor and memory technologies without buying anew computer. See Wall Street JournuZ, Sept. 10, 1991, p. Bl, and

Electronic Engineering Times, Oct. 28, 1991, p. 1.

16 For e~ple,st~l-belted tires have twice the durability of tires that were made 20 years ago. If maintained properly, modern raw tira cm ~t

60,000 to 80,000 miles. In practice, however, consumer misuse and neglect results in the tires wearing out much sooner. See ‘The Bumpy Road to Tire

Recycling in America, ” Garbage, May/June 1991, p. 37.

17 Robert Ayers, Tec~nology andEnviron~nt (Washingto~ DC: National Ademy of Engineering, 1990)> PO 26”

1s T. Teitenberg, Environmenfaz and Natural Resource Economics (Glenview, IL: Scotti Foresman and CO., 1988), P. 191.
Chapter 3--Product Design and the Environment ● 39

 credit: GE 

General Electrlc Plastics has constructed a 2,900 squarefoot home that Is designed to provide a “living

laboratory” for the development of advanced building

ers, refrigerators, and light bulbs. Consumers usu- how their products will be managed as wastes after

ally do not invest in energy efficiency unless it offers their useful life is over. And waste management

a fairly short payback--typically less than 2 years providers tend to accept the composition of waste

for home appliances.19 streams as a given. If product design and waste

management were coupled more closely, this could

Design for Better Materials Management reduce the cost of materials to industry and address

environmental problems at the same time. This will

By and large, resources flow through our society require coordinated research on both principles of

in one direction only. Designers rarely think about design and improved waste management processes.

 U.S. of Technology Assessment Building Energy OTA-E-518 DC: U.S. 

Office, 1992).
40 ● Green Products by Design: Choices for a Cleaner Environment

Photo credit: NCR Canada Ltd.

The NCR 7731 Personal Image Processor features the

latest in optical imaging technology and incorporates a

number of green design concepts. The product features

modular components that can be readily disassembled,

parts consolidation, and the use of recycled materials.

The modular design allows the device to be configured

to meet specific customer needs, and so avoids

unnecessary hardware and reduces waste.

Examples of design for better materials management include making products that can be remanufactured, recycled, composted, or safely incinerated

with energy recovery. Broadly speaking, these

management options are listed in order of preference, both from a business perspective and an

environmental perspective. One model of plastics

management, for instance, envisions a life cycle in

which virgin plastic components are reused as long

as possible, then the materials are repeatedly recycled through lower and lower value-added applicaTable 3-l—Principles of Design for Disassembly

Minimize material variety

Use compatible materials

Consolidate parts

Reduce number of assembly operations

Simplify and standardize component fits and interfaces

identify separation points between parts

Use water-soluble adhesives when possible

Mark materials to enhance separation

SOURCE: General Electric Plastics, Pittsfield, MA.

tions until the plastic is finally incinerated to recover

the chemical energy .20

Design for Remanufacturing and Recycling

Giving consideration to how product components

or materials can be reclaimed will likely cause

companies to alter conventional design and manufacturing strategies. 21 Although not widely practiced, design for remanufacturing can be attractive

from both an environmental and a business point of

view (see box 3-C). Similarly, recycling offers a

number of potential benefits. Recycling can reduce

virgin material extraction rates, wastes generated

from raw material separation and processing, and

energy use associated with manufacturing. It can

also divert residual materials from the municipal

waste stream, relieving pressure on overburdened

landfills.

Products that can be rapidly disassembled into

their component parts lend themselves both to

remanufacturing and recycling (see table 3-l). Design for disassembly can go a long way toward

establishing both closed-loop production-reclamation systems where components and materials are

reused in the same products, and open-loop systems

where materials are recycled several times for use in

different products. A number of durable products

including automobiles, refrigerators, and cooking

appliances are beginning to embody aspects of this

design approach.22 However, durable products present special problems because it is difficult for

designers to anticipate how waste management

 of materials management has been proposed by GE Plastics, Pittsfield, MA.

 E. First Cost and Recyclability in the Design of Manufactured Resources 

September 1978, pp. 160-165; “Design for Recycling, ’’Institute of Scrap Recycling Industries, vol. 21, No. 1, winter 1989; and Rick

 “Environmentally Responsible Product paper presented at the National Academy of Engineering Workshop on Engineering Our Way

Out of the Dump, Woods Hole, MA, July 1-3, 1991.

 “Built to Last-Until It’s Time To It Business Week, Sept. 17, 1990, pp. 102-106.
Chapter 3-Product Design and the Environment ● 41

Box 3-C—Remanufacturing

When durable goods such as kitchen appliances or machine tools wear out, they are usually discarded But there

exists another option that may offer considerable economic and environmental benefits: remanufacturing.

Remanufacturing involves the restoration of old products by refurbishing usable parts and introducing new

components where necessary. It simultaneously results in product life-extension (a form of waste prevention) and

promotes reuse of subcomponents and materials. Thus, in the case of remanufacturing, waste prevention and

materials management strategies can be mutually reinforcing.

Because of the economic advantages that can accrue from remanufacturing, a variety of different industries

are embracing the concept For example, Xerox Corp. restores and remanufactures many used parts from its copiers,

including electric motors, power supplies, photo-receptors, and aluminum drums. Xerox is now recycling about 1

million parts a year in this way, resulting in savings around $200 million. The parts are used as both replacement

components and in new equipment. To facilitate the refurbishing and recycling of various components and product

subsystems, Xerox is standardizing its designs so that a larger number of parts can be used in a variety of different

products. The company has setup its remanufacturing lines in parallel with its new production lines to achieve the

same levels of high quality. It has also involved its suppliers more directly in the design process, so that

opportunities to use recycled components and materials, especially plastics, will not be overlooked.

The use of replacement parts for automobiles and trucks is one of the most prevalent applications of product

remanufacturing. For instance, Arrow Automotive Industries, a company that remanufactures automotive

components such as starter motors, clutches, and carburetors, has annual sales of approximately $100 million.

However, the largest single remanufacture in the United States is the Department of Defense. Military equipment

and systems ranging from aircraft and radar to rifles are remanufactured on a regular basis to extend the life of

expensive technological hardware.

Apart from the economic benefits that can accrue to a manufacturer, the reuse of high value-added components

takes advantage of the original manufacturing investment in energy and materials. This yields greater environmental

benefits than simply recycling the constituent materials of the components. In most cases, the energy embodied in

a new product is many times that needed to remanufacture the same product.

SOURCES: Jack Azar, Xerox Corporat.io~ personal communicatio~ Aug. 15, 1991; Robert T Lund, “R manufacturing,” TechnologyReview,

Febroary/March 1984, pp. 19-29.

practices might change by the time the product benefits. While the primary barriers to recycling are

enters the waste stream.23

Just as important as designing for materials

recovery is designing for the use of recovered

materials. Developing design configurations that

facilitate the disassembly and separation of product

components is not enough. Companies must actually

incorporate recycled materials and components into

their products to bring about true environmental

economic, 24 the limited availability of high-quality

recovered materials can also complicate efforts to

introduce recycled materials into new designs.25

Contamin ation and indiscriminate mixing of materials during collection and separation can undermine

recycling efforts, and chemicals added in the original manufacturing process may be difficult to

remove, or may degrade the properties of reprocessed materials.26 Even if materials are free of

23 For ~xmple, even ifd~i~er~ ~adi~y ~t~red the de~iw of automobiles ad household appli~ces to&y, c~nt models would continue tO eIlter

the waste stream well into the next decade. Other products, such as household chemicals and batteries, can linger in basements and garages for years

until eventual disposal. Thus, such time lags can complicate the efforts of designers to incorporate environmental objectives into their designs.

x William L. Kovacs, “Dark Clouds Carry Silvtx Linings: Recyclable Materials Are the Basis for a Competitive Industrial Policy,” Resource

Recovery, August 1989, pp. 5-6.

z The problems ~s~~ted with the Coll=tion and processing of recycled materials are discussed extensively h the OTA rePort, Facing Amen”ca’s

Trash, op. cit., footnote 9, pp. 135-190.

26 AS ~i~us~atioq glass c~letitselfis loop~cent~cyc~ble, but it is difficult to make glass entirely from culletbecause c~etlacks “f-” %~ts

that are needed to reduce bubbles in the glass. (See Testimony of the Glass Packaging Institute before the Subcommittee on Environmental Protection

of the Senate Committee on Environment and Public Works, June 6, 1991; Also see OTA, Facing America’s Trash, op. cit., p. 151). In the case of

aluminum, the presence of mixed alloys in discarded aluminum goods complicates the secondary production process. Unless the alloy mix is controlled

precisely, the recovered aluminum will fail to meet product specflcations. (See R.E. Sanders and A.B. Trageser, “Recycling of Lightweight Aluminum

Containers: Present and Future Perspectives, ‘‘ Proceedings of the Second International Symposium-Recycling of Metals and Engineered Materials, held

by the Minerals, Metrds & Materials Society, October 1990).
42 ● Green Products by Design: Choices for a Cleaner Environment

Photo credit: Xerox 

Xerox reuses and remanufactures many of the

sophisticated components from Its copiers.

Remanufactured machines and new machines are

assembled on the same production Iine to the same quality

standards. Top left: “Remanufactured” and “new build”

assemblies on the same cart adjacent to the production

line. Above: In the middle of the production line the two

machines appear similar—’’remanufactured” on the left

and “new build” on the right. Bottom left: At the end of the

production line the two machines are indistinguishable.

external contamination, recycling processes may

degrade the materials; for instance, paper fibers

degrade with each successive reuse.

If designers are to use recovered materials more

extensively, they must have confidence that these

materials can provide similar performance and

properties as virgin materials. This may be best

achieved if their accustomed materials suppliers

offer recovered materials with guaranteed properties

alongside their offerings of virgin materials.27

Design for Comporting and Incineration

Apart from recycling and remanufacturing, there

are two other materials management options that

designers can consider: comporting and incineration. 28 Designers can facilitate comporting by

making products entirely out of biodegradable

materials.29 For example, starch-based polymers and

films can substitute for plastic in a variety of

applications. 30 These starch-based polymers are

inherently biodegradable, and easily composted.31

Similarly, products could be designed for safe

 Industrial The University of the Arts, Philadelphia PA, 

 t. of biological decomposition of solid organic materials 

“Compost” is the humus or soil like product of this process.

29 & Pampers But the On 

diapers are not Thus, the material must be the backsheetbefore comporting. eliminate this separation stage,

P&G is currently developing made from material. See the comments of Edward L. Chief Executive Officer, &

Gamble New View of the Environment, Bruce Smart (cd.) ( DC: World Resources Institute, April 1992),

pp. 36-40.

 to derived polymers. The trade

name of the polymer is Novon.

31 “Bioremediation/Biodegra&tion of Plastic Wastes by Composting,” Proceedings of the Global Pollution Prevention

Conference and Exhibition, Washington DC, Apr. 3-5, 1991.
Chapter 3--Product Design and the Environment ● 43

 E I E A J-U . , . , , . , . * , . , ,

Photo credit: GE 

The modern-day refrigerator is typically not designed for

recyclability, and consequently is almost impossible to

disassemble. Refrigerators use large amounts of

polyurethane foam (this foam contains CFCs) that

cannot be easily separated from different metal

components. New refrigerator designs are beginning to

incorporate modular concepts, as well as alternative

forms of insulation such as silica aerogels or

vacuum-based insulation.

incineration by avoiding the use of heavy metals and

chlorinated organics.

For these opportunities to be realized, though,

requires that product design changes be coordinated

with new systems of product disposal and integrated

waste management (see ch. 4). If products are

designed for comporting or safe incineration, but

end up being landfilled, the design improvements

are effectively nullified.32 Historically, there has

been little, if any, coordination between the stages of

design and waste management. This situation needs

to change if society is to benefit from the environmental leverage afforded by design. Promoting

greater coupling between manufacturing and waste

management is a major challenge for policymakers

(see ch. 6).

HISTORY OF GREEN DESIGN

The idea of green product design is not new. It was

developed in the late 1960s and early 1970s, along

with the explosion of environmental consciousness

that led to the creation of the Environmental

Protection Agency and to the passage of laws such

as the Clean Air Act, Clean Water Act, and the

Resource Conservation and Recovery Act.33 During

the 1980s, ideas such as design for remanufacturing

and design for recycling were developed in technical

journals and conferences, but the concept did not

receive much attention from policymakers or the

public.34 Perhaps because of recent alarming headlines about global climate change, ozone depletion,

and overflowing landfills, the issue has enjoyed a

renaissance in the past few years. Several recent

books and articles have explored how architects,

engineers, industrial designers, packaging designers, and graphic designers can incorporate environmental attributes into their designs.35

Despite this 20 year history, however, the concept

of green design has not yet been integrated into

engineering education or practice. Indeed, until

recently, “design for the environment” meant a

design that protects the product against the effects of

 landfills is potentially But even the most of

the waste stream, like yard clippings, are rarely because of poor public education and inadequate waste management. (See Facing

America’s Trash, op. cit., footnote 9.)

33 of Jacob and 

“Environmental Dangers Challenge Design Engineers,” Mechanical Engineering, November 1970, p, 15, A discussion of environmentally sound

product design and policy options to encourage it appears in the Second Report to Congress, “Resource Recovery and Source U.S.

Environmental Protection Agency, 1974. See especially “Product Design for Resource Recovery, Source or Solid

Waste Purposes.”

 for Life Society for Conference

Proceedings, 1979, p. 181; Robert Lund, “Remanufacturing,” Technology Review, 1984, p. 19.

35 Green and Dorothy Mackenzie, 

Environment (New NY: International publications, Inc., 1991); David Biologic: Environmental Protection Design (Johnson

Books, 1990); Charles the Entire Life Cycle: A New Paradigm?’ Society for Engineering Education Annual Conference

proceedings, 1990, and references The World Wildlife Fund and Conservation “Getting at the Source: Strategies for

Reducing Municipal Solid Waste,” DC, 1991; Tedi Bish and Sherman, “Design To Save the World,” International 

November/December 1990, p. 49.
44 ● Green Products by Design: Choices for a Cleaner Environment

Photo credit: Office of T&nology Assessment

Consumers sometimes can leave separated materials at

igloos or other containers placed in conspicuous areas

by communities or firms running recycling programs.

moisture, corrosion, or weather. Designers’ use of

materials have undergone dramatic changes over the

past 50 years, but these changes have evolved

independently of environmental concerns, being

driven primarily by technological innovation and

economic competition among materials (see ch. 2).

This situation is changing rapidly, however.

Many companies, large and small, are starting to

change their process and product designs in ways

that reduce both their own waste disposal problems

and those of their customers.

36 Several governmentfunded projects are underway in the United States

and Europe to develop environmental handbooks or

checklists for designers (see chs. 5 and 6). For

example, researchers in the Netherlands have developed computer software to assist designers in

making environmentally sound choices.37

ALTERNATIVE VIEWS OF

GREEN DESIGN

The idea of green design seems straightforward,

but there is no rigid formula or decision hierarchy for

implementing it. One reason is that what is “green’

depends strongly upon context. While there are

some environmental design imperatives that are

sufficiently compelling to apply to many different

products (e.g., avoiding the use of chlorofluorocarbons), in general green choices will only become

clear with respect to specific classes of products or

production networks. What constitutes green design

may depend on such factors as the length of product

life, product performance, safety, and reliability;

toxicity of constituents and available substitutes;

specific waste management technologies: and the

local conditions under which the product is used and

disposed. For example, designing a product to be

recyclable makes little difference if the infrastructure for collecting and recycling the product do not

exist.

On a deeper level, though, one’s philosophical

view of the relationship between the economy and

the environment strongly conditions one’s view of

green design and the environmental “problems” it

should address. One taxonomy of this relationship

employs a set of five paradigms, ranging from

“frontier economics’ to ‘deep ecology. ’ ’38 Here we

will discuss alternative views of green design for the

three intermediate paradigms: “environmental protection, ’ “resource management, ” and “ecodevelopment.”

Paradigm I: Environmental Protection

In this paradigm, the environment is recognized as

an economic externality that must be safeguarded

through laws and regulations. Tradeoffs are seen

between industrial competitiveness and protecting

the environment (e.g., employment vs. protecting

endangered species), and cost-benefit analysis is

offered as a means of balancing the two. This view

is fundamentally anthropocentric, with the principal

concern being the effect of pollution on human

health and welfare.

The “problem” in this case is that human society

produces too much waste. This concept leads to

policies that focus on reducing the quantity or

toxicity of waste: e.g., waste prevention, recycling,

or treatment. Similarly, the objective of green design

should be to reduce the quantity and toxicity of

36A diverse set of companies including 3M, Xerox, AT&T, Procter & Gamble, S.C. Johnson Wax, and Eveready have implemented progrm of

process and product reformulation to reduce levels of waste generation at both the manufacturer and post-consumer stages. See Beyond Compliance:

A New Industry View of the Environment, op. cit., footnote 29.

%’ The Progm, @ed SiIIMRo, is available iiom PR6 Consultants, Amersfoorti The Ne~erl~ds.

38 @e ex~eme,fiontier economics, focuses on econo~c ~~~d ernphasi=s free markets ad ~bridl~ exploitation of resources. The other

extreme, deep ecology, focuses on harmony with nature and emphasizes drastic reductions inhuman population and the scale of human economies. See

Michael E. Colby, “Environmental Management in Development” World Bank Discussion Papers, Washington DC, 1990.
Chapter 3-Product Design and the Environment ● 45

wastes requiring disposal, e.g., making products

more recyclable, light-weighting, etc. Progress is

measured in terms of increasing the efficiency of

energy and materials use, i.e., reducing the quantity

of energy and materials required per unit of production. This view does not concern itself explicitly

with whether the physical flows of energy and

materials through the economy are ecologically

‘‘sustainable.

Paradigm 2: Resource Management

In this view, the environment is recognized as an

economic externality that must be internalized in

measures of economic performance and policy

decisionmaking. The earth is seen as a closed

economic system, and therefore the main challenge

is to ‘‘economize ecology. ’ If those who use

resources and generate pollution are made to pay the

true price of those environmental services, this will

lead to sustainable industrial development. Advancing technology is seen as an integral part of

achieving more efficient use of energy and materials. Technologically advanced countries should

aggressively transfer new, more efficient technology

to developing countries, and assist them in stabilizing their populations.

The “problem“ in this paradigm is that human

society is managing its resources poorly, generating

pollution that threatens to undermine the ecological

productivity upon which the economy depends. The

solution is to “get the prices right’ through taxes on

resource use and pollution, or perhaps tradable

permits to pollute within sustainable limits. Such

economic incentives are seen as providing more

flexibility than regulations, so that industry can

respond in the most cost-effective way.

This view assumes that environmental services

can be monetized, and that functioning markets for

these services can be created. It does not address

uncertainties in the valuation of these services or in

the correct determination of the relevant ecological

thresholds or carrying capacities. It is primarily

anthropocentric, since it is concerned with the stock

of ‘resources’ available for human use, but extends

its concern to quality of life of future generations as

well as the present generation. Sustainable development is defined as maintaining a nondecreasing

stock of human plus natural capital, implying some

substitutability between the two.39

In the resource management paradigm, green

design involves choices that conserve resources as

well as reduce wastes. Emphasis is on the materials

inputs in products, e.g., avoiding the use of materials

that are toxic or become dispersed in the environment. In principle, the prices of material inputs

would reflect their demand on environmental services, thus providing the correct signals to the

designer. The resulting price changes would cause

reorganization of the production system toward

cleaner technologies and discarded materials would

have a higher value, thus encouraging recovery and

recycling.

Paradigm 3: Eco-Development

The eco-development paradigm stresses the coevolution of human society and ecosystems on an

equal basis. The earth is seen as a closed ecological

system and therefore the principle challenge is to

“ecologize the economy. ” This view is less anthropocentric than the resource management view,

emphasizing that nature has an intrinsic value that is

independent of the value placed upon it by the

human economy. Thus, this view has a moral or

ethical dimension that implies a transformation of

societal attitudes toward nature (not assumed in the

previous paradigms).

The “problem“ in this case is that the scale of

human economic growth is inconsistent with the

long-term coexistence of man with nature. Sustainability is defined as nondecreasing stocks of human

and natural capital maintained independently; that

is, no substitutability between technology and natural resources is assumed.40 In the face of uncertainty

about ecological thresholds and the world’s carrying

capacity, the “precautionary principle” applies:

new technologies or development projects must

demonstrate that they are consistent with sustainability as defined above before they are adopted.

Progress is measured not in terms of efficiency, but

in terms of the health of regional ecosystems as well

as human health.

Policy objectives for development under this

paradigm include moving toward a closed materials

39 TMS has been called the criterion of “weak sustainability. ” See Herman E. Daly and John B. Cobb, For the Common Good: Redirecting the

Economy Toward Community, the Environment, anda Sustainable Future (Bosto~ MA: Beacon Press, 1989).

@ ~s has been c~ed the criterion of ‘‘strong sustainability.” Ibid.
46 ● Green Products by Design: Choices for a Cleaner Environment

cycle. The economy would rely principally on

renewable sources of energy and materials, extracted

at rates that would not affect ecological health.

Nonrenewable resources would be recovered and

recycled indefinitely. Instead of tradable pollution

permits, tradable permits might be issued for the

extraction of a freed quantity of nonrenewable

materials. 41 The production/consumption system

would be restructured to optimize the utilization of

goods to satisfy essential human needs, rather than

the ownership of goods to satisfy frivolous ‘wants.’

Green designs would avoid use of materials that are

toxic to humans or ecological systems, substitute

renewable for nonrenewable materials, and ensure

that nonrenewable materials could be readily recovered for recycling.

Analysis

These three paradigms illustrate the different

assumptions that underlie the environmental policy

debate. They reflect different views of mankind’s

place in the natural world, and of its obligations to

future generations as well as to other species. Present

U.S. policy is most closely approximated by the

environmental protection paradigm, while many

environmental groups espouse the eco-development

perspective. Resource management is the theme of

reports such as the Brundtland Commission’s “Our

Common Future,” the Worldwatch Institute’s annual ‘State of the World,’ and the World Resources

Institute’s annual “World Resources.”42

These paradigms also suggest different criteria for

defining green design. In the environmental protection view, a product design maybe considered green

if it results in 10 percent less waste than last year’s

design over its entire life cycle (waste prevention).

The same design may be rejected from the ecodevelopment perspective because it uses nonrenewable materials that are not recycled and do not

biodegrade. Evidently, green product design within

each succeeding paradigm involves satisfying a

correspondingly broader set of criteria for compatibility with the natural environment.

In this chapter, we have defined green design as an

extension of traditional design to include the goals

of waste prevention and better materials management. This formulation might be criticized as being

too conservative, since it suggests a narrow focus on

the “outputs” of the production system that is

characteristic of the environmental protection paradigm. Certainly, other formulations are possible. For

example, an alternative definition focusing more on

the “inputs” might involve reducing the use of toxic

materials, and relying more on resources that are

managed in a “sustainable” way. Such a definition

might be more consistent with the eco-development

paradigm.

In some cases, designers may have information

about materials choices that bear directly on the

destruction of irreplaceable resources, or the extinction of endangered species. An example might be

avoiding the use of tropical hardwoods that are

harvested from environmentally sensitive rainforests.

In most cases, though, it will not be clear which

choices are more ecologically “sustainable.” It

seems most practical to address global issues of

ecological sustainability at the level of national

policy, rather than at the level of the individual

designer.

OTA chose a formulation of green design that

suggests the most concrete actions available to the

designer. A narrower focus on waste prevention and

better materials management provides tangible criteria for evaluating the choices that designers make

every day. The next chapter discusses various

strategies that designers and companies can employ

to reduce the environmental impacts of their products.

41 See He-n E. DaIy, Econo~”cs, Ecology, and Ethics: Essays Toward a Steady State Economy (San Francisco, CA: W.H. RMXIMX4 1980), PP.

337-348.

42 Co]by, op. Cit., foo~ote 38.
Chapter 3--Product Design and the Environment ● 47

APPENDIX 3-A:

THE AUTOMOBILE

DEVELOPMENT PROCESS1

Introduction

The automobile sold in the United States today is

a complex product, not only in terms of the functions

that it performs, but also in terms of the marketplace,

and in terms of the wide set of goals, both private and

public, that it is expected to meet. This appendix is

intended to convey the many factors that influence

automobile design decisions, and how environmental concerns enter the process. The following

description of the automobile design process is

necessarily generalized, but it captures the key

issues and tradeoffs that govern contemporary automobile development.2

Automobile Product Development

Concept—The first stage in automobile design

and development can be called “concept development.” This stage in the process is essentially a

strategic effort, which can take one of two forms.

Most commonly, a particular set of market segments

is identified, defined not only by demographics like

age and marital status, but also by income, spending

characteristics, and stylistic trends. The car concept

that evolves from these considerations is a combination of appearance, features, and cost that is expected

to attract enough purchases from the targeted groups

to justify the development effort and to make the

automaker money. As Charles Centivany, a Ford

product planning manager, said, “In one sense we

are looking for customer demand to pull us along,

while looking for pockets not being filled, or that

could be filled better. ’

Another concept stratagem is to develop a product

which can be used as a testbed for innovative vehicle

technologies, either in manufacturing or in the

product itself. The classic example of this kind of

development in the domestic automobile industry

has been the Chevrolet Corvette and, more recently,

the Pontiac Fiero. Because the production volume is

low, limited testing of innovative automobile technologies can be performed with low risk to the

producer, and a wide range of innovations can be

easily tested. For example, the composite automobile leaf spring was first introduced on the Corvette,

although it now can be found in several other

General Motors vehicles. Of late there has been

considerable use of this stratagem at General Motors

to develop manufacturing technologies. The Fiero

introduced the space-frame vehicle manufacturing

process, which has been considerably refined in two

current General Motors products, the Saturn and the

All Purpose Vehicles (APVs).

Whatever the original source of the ideas, the

purpose of a vehicle concept is to supply an outline

of the basic characteristics of the product under

development, and a set of guidelines against which

the results of the design process are to be measured.

Design Studio-The automobile concept is then

passed to the design studios, where the concept is

fleshed out on paper and, ultimately, in clay for

review by the concept team and upper management.

The focus at this phase of the process is to develop

a vehicle shape that can accommodate the concept

requirements while achieving those intangible characteristics known as “style.” As a consequence, the

studio draws upon a wide range of inputs in the

course of developing the shape of the vehicle. These

include past features of the product line as well as

competitive product lines.

Although the design studio has historically drawn

from U.S. sources, the recent globalization of the

automotive market has led to international partnerships and outright acquisition of centers of styling

excellence. In particular, the U.S. original equipment manufacturers (OEMs) have focused this effort

on Italian and British design shops, although many

elements of Japanese design have also been incorporated. Although the nation of origin of most designs

can still be identified on sight, there has been a trend

toward blurring the distinctions between the different schools of design. However, the Japanese have

proven to be most mutable, as they have located

many elements of their design effort in the United

States, particularly California. For example, the

1 This discussion is &awn ftom Frank Field, “Automobile Design and the Environmen~” contractor report prepared for the Office of Technology

Assessmen~ May 1991.

Z For ag~ over~vim of the process, see James P. Womac~ Daniel T Jones, and Daniel Roos, The Machine Thut Changed the Wodd(New York

NY: Rawson Associates, 1990).

s Christopher A. Sawya, “It’s All in the Planning,” Automotive Indusn”es (Radnor, PA: C!hilton Co., January 1991), p.20.
48 ● Green Products by Design: Choices for a Cleaner Environment

popular Mazda Miata is the product of a U.S. design

shop, and its appearance reflects these origins.

Frequently, the design studios will devise several

potential vehicles for any one concept. These

alternatives are winnowed down within the design

studios and by corporate decisions until a single

vehicle geometry is settled upon, usually following

the presentation of a full-scale clay mock-up of the

vehicle. Once the clay models have been approved

by concept and the higher levels of management, car

development is turned over to advance engineering.

Advance Engineering—Advance engineering is

the stage in the vehicle development process where

what most people think of as product design really

happens. Here, the product of the design studios and

the concept teams is converted into the first real

engineering drawings of the automobile.

The classic approach to this problem is to divide

the vehicle into functional subsystems, such as the

body, the chassis, the powertrain, and the interior.

The division of the vehicle into subsystems is a

critical organizational simplification of the vehicle

development process. These subsystems are defined

to isolate engineering decisions within the subsystem design group. Without this isolation, the engineering problem is simply too large to be satisfactorily resolved. Instead, specific requirements (known

as ‘‘design bogeys’ are developed at the advance

engineering level which must then be implemented

by the product engineers. Provided that these bogeys

accurately reflect the objectives devised at the

concept level, and are satisfactorily backed up with

good engineering practice, the automobile can be

successfully designed.

Two of the most critical design bogeys established at advance engineering are cost and weight.

Both of these are central to the success of the

designers in meeting the requirements of the vehicle

concept. Cost targets must be met in order to meet

the pricing objectives that underlie the marketing

strategy, and weight targets are critical to assuring

that the vehicle performance (i.e., fuel economy and

vehicle handling) will meet the concept goals.

Since 1978, fuel economy specifications have

been principally dictated by Federal Corporate

Average Fuel Economy (CAFE) requirements. No

automaker can afford to ignore CAFE when devising

its vehicle designs. CAFE enters into the automobile

design cycle at its inception. The strategists, in the

course of defining the vehicle concept and the

product strategy, must establish a target fuel economy for the product. The design studios are not

directly affected by this target, although aerodynamic drag and vehicle rolling resistance (two key

factors along with engine performance that determine vehicle fuel economy) are a direct consequence

of vehicle shape and weight, respectively. However,

once the concept is passed to advanced engineering,

the need to meet CAFE becomes one of the critical

design parameters, probably second only to cost.4

Thus, weight bogeys become the primary way in

which fuel economy is managed by the advance

engineering departments. For a new design, the

advance engineering groups will establish weight

targets for each of the major vehicle subsystems. At

the same time, the materials composing those

subsystems are largely determined, particularly for

the body and the chassis. CAFE has thus encouraged

automakers to use more lightweight materials like

plastics or plastics composites. This has raised a

number of concerns about the recyclability of

automobiles. With a decreasing metal content in

cars, existing auto scrap dealers are finding it

increasingly difficult to maintain business viability.5

Apart from CAFE requirements, designers must

also give consideration to vehicle emission and

safety regulations. The need to meet certain emission levels affects engine performance specifications, 6 while safety standards affect a number of

design parameters including the choice of materials.

4 CAFE regulations have a ripple effect all the way down to automobile suppliers. For example, Goodyear’s new “environmental tire’ is designed

to improve fuel efficiency. The tire weighs less and has reduced rolling resistance.

5 Auto~ers we wor~ with the plastics industry to develop the technologies necessary to make the recovery of plastics eCOnOmiCd, but Wldt

barriers remain to be overcome (see box 4-C, ‘‘Design and Materials Management in the Auto Industry”).

6 The aims of limiting emissions and improving fuel economy have a peculiar interaction. On one hand, improved fuel economy implies that energy

is more efficiently extracted from the fuel. If so, a greater fraction of the available fuel is burned (reducing hydrocarbon emissions) and a larger fraction

of the fuel is completely combusted (reducing the amount of carbon monoxide released). On the other hand, this improvement in efficiency is generally

achieved by operating the engine at a higher temperature, which unfortunately increases the amount of nitrogen oxides that are produced. Additionally,

changes in the operating condition of the engine (higher speeds, acceleration etc.) require changes in the way in which combustion is affected (spark

advance, timing, etc.).
Chapter 3--Product Design and the Environment ● 49

Once the basic design bogeys are established, the

advance engineering groups turn to developing the

first engineering drawings of the vehicle subsystems. These drawings are fairly general, since much

of the detail work requires more resources than are

usually available at this level. However, it is at this

stage in the design that the basic shapes of the critical

vehicle elements are devised, and where the majority

of the vehicle material specifications are made.

The most important element of engineering design at this and subsequent stages in the automobile

design process is past experience. Vehicle designs

almost always start with a consideration of past

designs having similar requirements. Automobile

designers rarely start from “blank paper” when

designing vehicles, primarily because it is inefficient for them to do so. There are several reasons for

this:

1.

2.

3.

Time pressure: A crucial element of the

automobile development process is the issue

of time. Automakers have found that, like so

many other industries, time to market is central

to market competitiveness. While tooling acquisition and facilities planning are major

obstacles to shortening the development cycle,

they tend to be outside direct control of the

automaker. Design time, however, is directly

under the control of the automaker, and

reduction of design time has been a major goal

in vehicle development.

Cost pressures: The reuse of past designs also

saves money. In addition to the obvious time

savings described above, the use of a proven

design means that the automaker has already

developed the necessary manufacturing capability (either in-house or through purchasing

charnels). Furthermore, because the old part

has a known performance history, the product

liability risk and the warranty service risk are

also much reduced.

Knowledge limitations: Underlying factors 1

and 2 is the fact that the automobile engineering design community is still developing the

information and analysis base needed to do

analytical design of automobile components.

This limitation does not arise from a lack of

engineering talent, although some of the domestic OEMs have had a tendency to lay off

engineering staffs when times get hard. Rather,

the limitation is a consequence of a real lack of

knowledge of the structural loads that the

various automobile subsystems must be able to

sustain. In other words, the automakers have

only a rough idea of what loads a car will

experience in service. Given this limitation, it

is far more efficient to start with a past design

which has proven to be successful, and to

modify it to meet the geometric limitations of

the new vehicle. Starting at this point, and

backing up the design with prototyping and

road testing, has proven to be far more

efficient.

This normative design process has been central to

automobile design for decades. While it may seem

to be an unsophisticated way to design, it is

important to recognize that designing a car is not the

same as designing an airplane. The scale of production, the cost of the product, and the manufacturing

technologies demand a completely different approach to the problem, particularly in the absence of

inexpensive, widely distributed computing power.

With the availability of such tools, the automakers

have begun to incorporate more analytical design

approaches, but the normative approach has continued to serve automobile engineering well, in the

main.

Product Engineering/Manufacturing Engineering—The advance engineering group subdivides the

automobile into functional subassemblies, which are

passed to individual product engineering groups for

final, detailed designs. The broad outlines of the

advance engineering drawings are filled in, and the

details of tolerance and material are worked out in

the product engineering groups.

Again, past designs play a large role in defining

these designs, but a harder look at the individual

elements can be taken at this level. This effort will

be taken, for example, when design bogeys prove

difficult to meet using the historical designs. The

changes may involve changing a material specification, although they usually focus upon changing the

geometry of the part.

Manufacturing engineering becomes a major part

of the work done by the product engineers. Although

all phases of product development are geared to

maintain manufacturing feasibility, the product engineers have to work closely with manufacturing

engineering, not only to assure that the components

that they design can be manufactured, but also to

guarantee that the assembly of the rest of the car is

not compromised. For example, while the engineer
50 ● Green products@ Design: Choices for a Cleaner Environment

designing the inner panel of an automobile door

might want to reduce the thickness of the panel to

reduce weight, the production engineers require that

the inner door has enough openings to assure that the

door mechanisms can be easily installed, thus

requiring a thicker, stiffer panel.

Non-OEM Contributions to Product Development—

There are two major classes of actors in the

automobile product design and development process

who are not directly a part of the automobile

companies. The first of these is the custom design

house. These houses offer freelance services which

support the design studios or the engineering designers. In the former case, these groups are called upon

to bring particular knowledge or awareness of the

automobile marketplace to enhance the appearance

of the studio product. Although these operations can

exist almost anywhere, they have historically been

located either in Michigan, near the OEMs, or, more

recently, in California, near the largest market.

Engineering support has become an increasingly

important supplement to the OEM product development cycle. This is a consequence of the increasing

engineering difficulty associated with the increasing

demands being placed on the performance of the

automobile, and the decline in the amount and

breadth of engineering talent within the OEMs who

have been forced to trim engineering and development effort to maintain financial goals.

These specialty engineering shops are not the only

manifestation of this development. The other major

actors in this area are the material and parts supplier

industries. All of the major material supplier companies have followed the lead of the plastics suppliers

and have made engineering, manufacturing, and

design support of their material an integral part of

their material selling efforts. Today, most of the

major material suppliers not only offer their materials, but also finished designs of components which

use these materials, backed up with complete

engineering analyses. Similarly, major component

and subassembly suppliers have also taken on many

elements of product development and design that

have traditionally been associated with the automobile companies.

In conjunction with this change has come the

trend toward what has come to be called “modular

design. ” Essentially, modular design focuses on the

idea that the automobile is composed of components

of definable functionality which can be designed and

developed in isolation from the rest of the vehicle.

Although this strategy has really only come to full

expression in the electrical system and in parts of the

powertrain, the idea has particular attraction in the

current design framework. By adopting such a

strategy, a number of subassemblies or modules can

be easily mixed or matched, thus retaining economies of production while offering a diverse family of

products.

Summary

The process of automobile design and development is a complex endeavor that takes a product

concept through stages of increasingly detailed

engineering and manufacturing specifications, based

on product performance and cost goals. But these

performance and cost targets are affected by a

number of external constraints. Because of federally

mandated fuel economy and emissions requirements, environmental considerations are a major

factor underlying almost every stage in the vehicle

development process. This inevitably results in

design tradeoffs among such factors as performance,

fuel efficiency, and recyclability.
Chapter 4

Strategies for Green Design
Contents

Page

PRODUCT-ORIENTED GREEN DESIGN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

SYSTEM-ORIENTED GREEN DESIGN . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Incentives for System-Oriented Green Design . . . . . . . .

... ... ... ... ... ... ..+. .., 56

MEASUREMENT ISSUES ... ... ... .*. ... ... ... ... ... *e. e*. .*. 60

Measuring Product-Oriented Green Design ... o.. .*. .., .*, . . . . . . . . . 60

Life-Cycle Analysis ... ... ... ... ... ..** O.*. *O . * ., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

Measuring System-Oriented Green Design ● . * . * . . * . . * . . . * . . * . . . . . . . . . . . . . 62

SUMMARY . . . . . . . . . . . . . ... ... ..*. ... ... ... ... ... ... ... Q**, o*** c<** *a, *o, *,*, **, e+*. 62

Boxes

Box Page

4-A. Networks . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ● . . . . . . . . . . . . . . . . . 54

4-B. Designing a Green Energy System: Demand-Side Management . . . . . . . . . . . . . . 57

4-C. Design and Materials Management in the Auto Industry . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Figure

Figure Page 4-1. Life-Cycle Inventory . . . . . . . . . * . . . . . . * . . . * . ., . . . . . . . . . . * . . * * * ., . .*,*,*... . . . . . . . . . 61

Photo credit: Records

The “long box” package design for compact discs was developed to fit into existing LP record bins. The design has been criticized

for its excess packaging. This example illustrates how product distribution systems can constrain design solutions. While some

efforts are being undertaken to develop alternative designs that use less packaging, considerable industry resistance to anew

package approach remains. Consequentlyr some retailers are initiating recycling programs to address consumer concerns.
Chapter 4

Strategies for Green Design

Designers do not in general have free rein in

conceiving and developing products.1 Some constraints relate to the products themselves: for example, marketing requirements, producer capabilities,

and government regulations. Other constraints relate

to the systems in which products must function.

Numerous examples can be cited: compact disc

package specifications are determined by the size of

old record bins; software applications have to

conform to operating system restrictions; movie

cassettes are made in VHS format despite the

apparent superiority of “Beta” technology.2 It is

therefore simplistic to encourage designers to “do

the right thing” without considering the constraints

they face.

In fact, design choices affect-and are affected

by-extremely complicated production and consumption networks (see box 4-A). As might be

inferred, these networks impose constraints on the

designer that have important implications when

attempting to integrate environmental objectives

into the design process.

Accordingly, designers can use two different

strategies to integrate environmental concerns into

their choices of materials and processes. One, a

product-oriented approach, is to optimize the environmental attributes of the product within the

constraints of the existing production/consumption

network. The second strategy, a systems-oriented

approach, is to broaden the scope of optimization to

include changes in the production/consumption

network itself. The first option is easiest, since it can

be accomplished within the context of an individual

firm. The second is more ambitious, because it

implies a new way of looking at products, and may

require new patterns of industrial organization, such

as the formation of cooperative relationships among

suppliers, manufacturers, and waste management

providers.

PRODUCT-ORIENTED

GREEN DESIGN

In the product-oriented approach, designers begin

with a product concept and develop a design solution

within the framework of the existing production/

consumption system. Designers might ask questions

such as:

●

●

●

●

●

●

What are the waste streams from alternative

manufacturing processes?

What substitutes for toxic constituents are

available?

How is the product managed after its disposal?

How does the design affect recyclability?

What are the environmental impacts of the

component materials?

How is the product actually used by consumers?

Answering these questions may involve significant extra effort on the part of designers, and may

even require new company practices, such as changing cost accounting systems to explicitly reflect a

product’s environmental costs, or initiating waste

stream audits. But many companies are accepting

this challenge, and there appear to be significant

near-term benefits that could result from widespread

adoption of such a design approach. For instance, at

a recent conference of packaging designers, there

was a consensus that-with the commitment of

upper management--companies could reduce the

volume of their packaging by at least 10 percent in

a single year through better design.3 Since packaging

typically accounts for around 30 percent of municipal solid waste (MSW) by volume, this would mean

an overall reduction of 3 percent of MSW volume in

1 year from this source alone (and perhaps a

significant reduction in the industrial waste stream

as well).4

1 See the following OffIce of Technology Assessment contractor reports on the packaging, automobile, and electronics industries: Franklin

Associates, “PackagingDesign and the Environment” April 1991; Frank Field, “Automobile Design and the Environment,” May 1991; Chemcycle

Corp., “Environmentally Sound Product Development in the Consumer Electronics and Household Battery Industries,” July 1991.

z Recent work provides intriguing evidence that once a particular technology path is choseu the choice rniiy become ‘‘locked-b” reg~dless of the

advantages of the altermtives. See W. Brian Arthur, “Positive Feedbacks in the Economy,” Scientific American, February 1990, pp. 92-99.

3 Robert Hunt Franklin Associates, personal communication, February 1991.

4 In reality, these design changes would not all occur in a single year. Redesign can cost up to $1 million per package. Thus, manufacturers are likely

to be most receptive to making changes in new package designs, or during the normal redesign cycle for existing packages.

–53–
54 ● Green Products by Design: choices for a Cleaner Environment

Box 4-A—Networks I

Technological advances in information technologies (computers, communications, etc.) are changing the

nature of the U.S. economy, making it more complex and interdependent. These advances have led to the creation

of elaborate networks that link consumers with retailers, retailers with manufacturers, and manufacturers with

suppliers. 1 Virtually all sectors of the economy now depend on these production/consumption networks, with many

of the networks being global in nature.2

As an example, consider the likely chain of events involved in the production and delivery of a frozen pizza.

The pizza contains tomatoes from Mexico or California, and cheese from Wisconsin. Wheat for the pizza crust is

grown in Kansas using sophisticated seeds and pesticides that are themselves the products of elaborate production

networks. The pizza is assembled automatically with equipment from Germany, and wrapped in multilayered

materials that are the result of considerable research and development. The pizza is probably purchased at a grocery

store where a clerk passes it over a laser scanner (a device with components from Japan), which enters data into a

computer and communication system designed to adjust inventories, restock shelves, and reorder products. This

computer tracking system in turn makes it possible to operate an efficiently dispatched transportation system that

places a premium on timely and safe delivery rather than on low bulk hauling charges. The checkout data is also

used to analyze consumer response to the previous day’s advertisements and to ensure that the store is closely

following trends in local tastes. Any significant change in consumer buying patterns will quickly ripple throughout

the production chain. So even in the case of a relatively simple product such as a pizza, the strong interconnections

between disparate sectors of the economy become apparent.

Such tight linkages among industries present both opportunities and challenges for designers. Because of the

flexibility they provide, networks can increase the range of possible product design options. For example, designers

can choose from a wider base of materials or components suppliers. On the other hand, networks can create

additional design constraints because of special distribution requirements, or greater variation in customer

preferences. In many cases, networks can play a decisive role in shaping design solutions. Thus, to make significant

environmental improvements, designers need to look beyond products and consider how networks themselves can

be changed.

1 See U*S, Conpws, Of&X of TcchnoIo~ Assesamen~ Technology and the Amenkafi &OFWdc ~a~~fl.’ CfiQice$fOr t~ ‘~e~

OTA-TET-283 (Wshingtom DC: U.S. Government Printing Of&e, May 1988).

SYSTEM-ORIENTED

GREEN DESIGN

From an environmental perspective, it is simplistic to view products in isolation from the production

and consumption systems in which they function. Is

a fuel injector, for instance, a green product? From

the vantage point of its component materials,

probably not. But since it is designed to improve

automobile fuel efficiency it could be considered

“green’ from a broader “systems” perspective.

Similarly, a computer, considered on its own,

would probably not qualify as an environmentally

sensitive product. The manufacture of a computer

requires large volumes of hazardous chemicals and

solvents, and heavy metals used in solder, wiring,

and display screens are a significant contributor to

the heavy metal content in landfills. But the same

computer could be used to increase the efficiency of

a manufacturing process, thus avoiding the use of

many tons of raw materials and the generation of

many tons of wastes. From this perspective, the

computer is an enabling technology that reduces the

environmental impact of the production system as a

whole.

This illustrates an important Office of Technology Assessment (OTA) finding: green design is

likely to have its largest impact in the context of

changing the overall systems in which products

are manufactured, used, and disposed, rather

than in changing the composition of products per

se. For instance, designing lighter fast-food packaging is well and good; but 80 percent of the waste

from a typical fast-food restaurant is generated
Chapter 4--Strategies for Green Design ● 55

 credit: McDonald’s Corp.

In cooperation with its suppliers, and with the assistance of the Environmental Defense Fund, McDonald’s Corp. has implemented

both waste reduction (left) and recycling (right) programs. By changing its sandwich packaging, McDonald’s has reduced its

“behind-the-counter” waste (e.g., smaller corrugated boxes) as well as Its post-consumer waste.

behind the counter, where consumers never see its

Addressing this larger problem requires that designers establish cooperative relationships with their

suppliers and waste management providers to manage materials flows in an environmentally sound

way.

Product design that accounts for the dynamic

relationships among all companies involved in a

production system has the potential to produce less

waste than product design that only takes account of

an individual company’s waste stream. The study of

the relationships among firms in production networks, and the effects of these relationships on the

flow of energy and materials through our society, is

an emerging field called ‘‘industrial ecology” or

‘‘industrial metabolism."6

The opportunities for linking product design with

system-oriented thinking have not been fully explored, but examples are beginning to appear in

different sectors of the economy. For instance,

pesticide use has declined dramatically where farmers have adopted integrated pest management

schemes involving crop rotation, and the use of

natural predators.7 Due to the success of these new

methods, chemical companies are no longer simply

supplying pesticides to farmers, but are also providing expertise on how to use those chemicals in

conjunction with better field design and crop management. Similarly, in the energy supply sector,

utilities are providing energy audit services, and are

promoting customer use of energy-efficient equipment, instead of building new generating plants (see

box 4-B).

A systems approach to design thus involves a

unified consideration of production and consumption activities: supply-side and demand-side requirements are treated in an integrated way. This is a more

far-reaching design approach in which designers

might ask:

●

●

●

How would new supplier and customer relationships affect the management of product

materials throughout their life cycle?

How could the same consumer need be fulfilled

in a “greener” way (i.e., thinking about a

product in terms of the service it provides,

rather than as a physical object)?

How could other companies’ waste streams be

used as process inputs?

 For about 35 percent of the waste generated by McDonald’s restaurants is corrugated boxes, and another 35 percent is 

address these problems, McDonald’s, in cooperation with the Environmental Defense Fund, has been the dynamics of its food distribution

and production systems. By working with its suppliers to change delivery methods, and by developing comporting strategies, McDonald’s is taking steps

to reduce these large “behind-the-counter” wastes. See the “Final Report of the Environmental Defense Fund/McDonald’s Corporation Waste

Reduction Force,” Washington DC, April 1991.

6 of production that would emulate the web of 

“Colloquium on Industrial Ecology,” Proceedings of the National of Sciences, vol. 89, No. 3, Feb. 1, 1992, pp. 793-884; and Robert Ayres, “Industrial Metabolism,” Technology and Environment DC: National Academy 1989), pp. 23-49. 7 See U.S. Congress, Off&of Technology Assessment, Beneath the Bottom Line: To 

of OTA-F-418 DC: U.S. Government Printing November 1990), pp. 115-118.
56 ● Green products by Design: Choices for a Cleaner Environment

A refillable bottling system can offer significant energy

and materials savings in comparison with nonreturnable

beverage containers. The impact-resistant, lightweight

polycarbonate bottles shown here can be reused up to 50

times. Institutional users of refillable bottle systems,

such as schools, have in some cases reduced solid

waste volume by 50 percent.

. How might product design changes alter the

waste stream so that it could become a useful

input into another industrial process (i.e.,

wastes should be regarded as potential products, not just residuals of a particular industrial

process)?

If the potential environmental benefits of a

system-oriented approach are greater, then so are the

challenges. The creation of new networks of production or distribution may be required, and longstanding relationships among manufacturers and

suppliers may have to change. Such changes are not

generally within the purview of product designers,

and millions of dollars may be invested in the

existing infrastructure for production and distribution. A systems design approach implies an unprecedented elevation of product design to the level of

strategic business planning, and a new way of

thinking about the environment at the highest

echelons of a corporation.

Incentives for System-Oriented Green Design

There may appear to be few incentives for

industry to consider such dramatic changes in

existing production networks.8 But changes of

comparable magnitude are already underway. Many

manufacturers are rethinking their business relationships with suppliers and customers in order to

implement total quality management and concurrent

engineering programs. 9 The traditional adversarial

relationship between manufacturers and suppliers is

giving way to a more cooperative business paradigm. 10

General Motors, for example, has adopted an

approach where it relies on a single supplier for its

chemical requirements. A single chemical firm,

rather than a group of suppliers, is chosen to provide,

coordinate, and manage all the chemical needs of a

plant and to provide continuous, on-site technical

support. The supplier is remunerated according to

the productive output of the plant. The supplier’s

profits are thereby based on the services it provides

to meet a factory’s production requirements, rather

than the amount of chemicals sold. This cooperative

strategy has reduced chemical usage by approximately 25 percent within GM facilities.11

The formation of environmental networks among

producers, suppliers, and waste management providers could allow industry to more effectively address

environmental problems. Integrated networks, in

s In fac~ in some cases, there may exist regulatory disincentives. For example, it is the view of many in industry that the Resource Conservation and

Recovery Act (RCRA) has impeded the reuse of spent materials. When a hazardous material falls out of a given manufacturing process, it becomes by

legal definition a “waste,” and is subject to stiff regulation. Because of potentially sign.ifkant liability penalties, the effect of this regulation is to limit

any further industrial uses of the material, and by defaul~ the material really does become a waste. See Institute of Scrap Recycling Industries (ISRI),

testimony of Herschel Cutler before the Subcommittee on Environmental Protection of the Semte Committee on Environment and Public Works, June

1991. Also see Braden Allenby, “The Design for Environment Information System,” an interim report prepared for the Rutgers University

Environmental Science Departmen~ 1991.

g See ‘A Smarter Way To Manufacture,” Business Week, Apr. 30, 1990; Genichi lhguchi and Don Clausing, “Robust Quality,” Harvard Business

Review, January-February 1990; Daniel Whilney, “Manufacturing by Desi~” Harvard Business Review, July-August 1988; “Concurrent

Engineering,” ZEEE Spectrum, July 1991, p. 22; “Manufacturing: The New Case for Vertical Integration” Harvard Business Review, March-April

1988; “Stress on Quality Lifts Xerox’s Market Share,” New York Times, Nov. 9, 1989, p. D1.

10 See U.S. Congress, officeof Technology Assessment, Making Things Better: Competing in Manufacturing, OTA-ITE-443 (wm~gto~ DC: U.S.

Government Printing Office, February 1990), p. 129.

11 Joh Ogdeq General Motors, personal COmuIlk3tiOL JUIY q, 1991.
Chapter Strategies for Green Design ● 57

Box 4-13-Designing a Green Energy System: Demand-Side Management

Faced with rising demand, spiraling construction costs, and strict pollution control laws, some electric utilities

are trying a new strategy: they are convincing customers to buy less electricity. The strategy may seem strange, but

it employs some of the central ideas of green design. In the end, it helps customers, the environment, and,

surprisingly, the utilities themselves.

The strategy is known as demand-side management (DSM)---a set of techniques intended to alter how a

utilitys customers use electricity. Utilities using DSM do more than meet the electricity demands of their customers,

they also help customers reduce or better distribute that demand. Examples of DSM include low-interest bans or

rebates to homeowners who install energy-efficient heat pumps and compact fluorescent lights, and free energy

audits. Like many innovative efforts at green design, DSM focuses on services, rather then goods; it encourages

utilities to focus on the services provided by electricity (e.g., heating and lighting), rather than on electricity itself.

While environmentally desirable, DSM seems an unlikely strategy for a utility to pursue. Electric utilities

operate as regulated monopolies, and their profits traditionally depend on sales. However, regulators in more than

30 States have adopted provisions to financially reward utilities for DSM activities. Many of these incentives treat

DSM as an investment rather than an expense, allowing utilities to earn returns in the same way they do from

powerplants. These regulatory incentives, coupled with high construction costs and strict pollution control laws,

make DSM an attractive alternative to building new generating plants.

To influence electricity demand, many DSM programs encourage the use of energy-saving technologies.

According to studies from the Electric Power Research Institute (EPRI) and the Rocky Mountain Institute,

widespread adoption of these technologies could reduce total electricity demand by 24 to 75 percent. However,

utility customers are often slow to adopt energy-efficient technologies, even though they provide long-term

financial benefits. Customers may face institutional or financial barriers, or they may lack information on potential

savings. DSM programs aim to provide information and incentives to overcome these barriers.

While DSM itself is directly applicable only to regulated utilities, its success demonstrates how economic

incentives can affect large, often conservative, organizations. Some utilities undertook DSM because of its positive

public relations value, but many others responded to provisions that allow them to profit directly from DSM

programs. The success or failure of DSM programs may point the way toward government programs that can

influence individuals and companies to adopt ‘‘green’ technologies.

SOURCES: U.S. General Accounting Office, “Electricity Supply: Utility Demand-Side Management Programs Can Reduce Electricity Use,”

October 1991. Paul Klebnikov, “Demand-Side Economics,” Forbes, Apr. 3, 1989, pp. 148-150. Leslie Lamarre, “Shaping DSM

as a Resource,’ EPRI Journal, October/November 1991, pp. 4-15.

essence, expand the scale of a firm’s operations and arrangement in energy and materials management

permit a firm to consider design solutions that would

otherwise not be possible. In the housing industry,

for example, an alliance of companies, the Integrated

Building and Construction Companies (IBACoS)

consortium, is developing new home concepts that

promote energy and materials efficiency (see box

3-B). Ultimately, tighter inter-industry linkages

could encourage the creation of closed-loop industrial systems where manufacturing byproducts from

one industry are used as inputs for other industrial

processes.

In Kalundborg, Denmark, an “industrial ecosystem’ has been created where manufacturing wastes,

surplus energy, and water are traded among a variety

of different economic actors. This cooperative

involves a powerplant, a plasterboard maker, a

cement factory, a pharmaceutical firm, an oil refinery, a collection of farmers, and the local heating

utility .12 Similar, but less elaborate efforts have been

undertaken in the United States. In past years,

Meridian National, an Ohio steelmaker, has sold its

waste ferrous sulfate to magnetic tape manufacturers. Also, the Atlantic Richfield oil company has

sold its spent silica catalysts to cementmakers. If

they had not been sold, these materials would have

been disposed as hazardous wastes.13

Product Take-Back and the Rent Model

New government regulations giving manufacturers responsibility for the environmental fate of their

products are also likely to bring about systems-based

12 See ‘‘A Rebirth of the Pioneering Spirit,” Financial Times, NOV. 11, 1990, p. 15.

13 See Robert Frosch and Nicholas Gallopoulos, “Strategies for Manufacturing,” Scientific American, September 1989, pp. 144-152.
58 ● Green Products by Design: Choices for a Cleaner Environment

design solutions. For example, Germany’s proposed

law requiring automakers to take back and recycle

automobiles has stimulated the German automobile

industry to develop new cooperative strategies for

auto design, manufacturing, and recycling (see box

4-c).

Perhaps the ultimate extension of the manufacturer take-back concept is the “rent model,” in

which manufacturers retain ownership of products

and simply rent them to customers. This gives

manufacturers incentives to design products to

maximize product utilization, rather than simply

sales. 14

This idea was implemented in the telephone

industry for many years. Before divestiture, AT&T

leased virtually all telephones and thus was able to

readily collect them. AT&T designed its phones

with a 30-year design lifetime, and collected almost

every broken or used telephone. The phones were

either refurbished or were processed for materials

recovery. However, with the end of AT&T’s regulated monopoly and the creation of a competitive

market, the number of telephone manufacturers

dramatically increased. Consumers were given a

wide variety of product choices. The number of

phones purchased by consumers, as opposed to

leased from the Bell System, grew rapidly. Accordingly, the proportion of telephones that were thrown

away rather than fed back to the Bell System also

increased, with a corresponding drop in the number

of units available for reuse or recycling. It is

estimated that approximately 20 to 25 million

phones are now disposed of each year.15

This concept of selling product utilization rather

than products per se currently applies to a variety of

durable goods. Computers, copiers, aircraft, and

sophisticated medical equipment are being leased

rather than sold to customers. For example, Xerox

leases copiers on ‘a “total satisfaction guarantee”

basis, where customers pay a certain fee for each

copy and do not have to take responsibility for

product operation. Some of the latest machines are

even equipped with communication lines to service

centers to allow automatic equipment monitoring.

By retaining ownership of the products they lease,

companies have a strong incentive to design goods

so that they can be reused or remanufactured. In

some firms it has caused a fundamental reassessment

of design procedure.

When a product is viewed as an agency for

providing a service or fulfilling a specific need, the

profit incentive changes; income is generated by

optimizing the utilization of goods rather than the

production of goods.l6 While the fundamental goal

of a firm would still be profit maximization, this

objective could be met by marketing services as well

as products. As an illustration, when a large Swiss

chemical company began selling guarantees of

“pest-free” fields instead of pesticides, it was able

to maintain previous profit levels while reducing

pesticide usage by 70 percent.17 Thus, instead of

selling as much pesticide as possible to customers,

it sold a systems solution. In essence, services were

substituted for chemicals.

The notion of thinking about a product in terms of

the function it performs is a logical extension of total

quality management (TQM) philosophy. The aim of

total quality management is to satisfy customer

needs. Customers usually do not care how their

needs are met, as long as they are indeed met. Thus,

it should not matter whether a customer’s requirements are satisfied by a specific product, or by a

service performed in lieu of that product.

Although the renting versus selling idea offers the

possibility of reducing resource consumption rates

while still meeting the needs of consumers, its range

of applicability may be limited. It may work better

on the corporate level than on the level of individual

consumers. Average consumers may be reluctant to

purchase used or refurbished goods, and divorcing

products from consumer ownership could result in

more careless use of those products. This model is

probably more appropriate for high-value, durable

products than for nondurable or disposable products.

14 wd~rs~el, The Product.LJfebtimtq Geneva, personal communicatio~ Nov. 8, 1991 .Formoreonthis ideaj see Grio Gkiniand Walter Stid,

The La”m”ts to Certainty: Facing Riskx in the New Service Economy (Bosto~ MA: Kluwer Academic Publishers, 1989).

15 Brad~ Allen@, Senior Attorney, AT&~ personal communication, Sept. 13, 1991.

16 S@el, op. cit., footnote 14.

17 mid.
Chapter Strategies for Green Design .59

Box 4-C—Design and Materials Management in the Auto Industry

When an old car is junked, it is often first sent to a dismantle, who removes any parts that can be resold, as

well as the battery, tires, gas tank, and operating fluids. The hulk is then crushed and sent to a shredder, which tears

it into fist-sized chunks that arc subsequently separated to recover the ferrous and nonferrous metals.

Presently, about 75 percent by weight of materials in old automobiles (including most of the metals) are

recovered and recycled. The remaining 25 percent of the shredder output, consisting of one-third plastics (typically

around 220 pounds of 20 different types), one-third rubber and other elastomers, and one-third glass, fibers, and

fluids, is generally landfilled. In the United States, this shredder “fluff’ amounts to about 1 percent of total

municipal solid waste. Sometimes, the fluff is contaminated with heavy metals and oils, or other hazardous

materials.

As automakers continue to search for ways to improve fuel efficiency and reduce manufacturing costs, the

plastic content of cars is expected to increase. This will not only increase the amount of shredder fluff sent to

landfills, it threatens the profitability of shredder facilities, which currently depend on metals recovery to make

money.

In Germany, the landfilling of old automobile hulks and the shredder residues from automobile recycling

operations is a growing problem, The German Government has proposed legislation that would require automakers

to take back and recycle old automobiles at the end of their lifetime. This has stimulated German automakers to

explore fundamental changes in automobile design that could result in more efficient materials management, These

changes would involve new relationships among auto manufacturers, dismantles, and materials suppliers.

To avoid dealing with the auto hulks themselves, the automakers propose to take better advantage of the

existing infrastructure for auto recycling, Manufacturers will design cars that can be more cheaply disassembled,

and will educate dismantles as to how to efficiently remove plastic parts. They will encourage their material

suppliers to accept recovered materials from dismantlers, and will specify the use of recovered materials in new car

parts, thus “closing the loop.”

Green automobile design within this new framework of coordinated materials management has a very different

character than auto design within an isolated firm. Instead of just thinking about how to design a fender or bumper

using 10 percent less material, the designer also thinks about how the fender or bumper can be constructed from

materials that can be co-recycled, and readily separated from the car body.

Several German companies, including BMW and Volkswagen, have begun to explore this system-oriented

approach. BMW recently built a pilot plant to study disassembly and recycling of recovered materials, and

Volkswagen AG has constructed a similar facility. The goal of the BMW facility is to learn to make an automobile

out of 100 percent reusable/recyclable parts by the year 2000. In 1991, BMW introduced a two-seat roadster model

whose plastic body panels are designed for disassembly, and labeled as to resin type so they may be collected for

recycling.

Interest in improving materials management in the auto industry is not limited to Europe. Japan’s Nissan Motor

Co. has announced research programs to explore design for disassembly, to reduce the number of different plastics

used, to label those plastics to facilitate recycling, and to use more recovered materials in new cars. In the United

States, Ford, Chrysler, and General Motors plan to label plastic components to identify the polymers, and have

recently established a consortium with suppliers and recyclers (called the Vehicle Recycling Partnership) to address

the recycling issue.

Autos are already one of the most highly recycled products in the United States, This success is largely due

to the efficiency of shredder technology; a single facility can process up to 1,500 hulks per day. This level of

productivity is not consistent with labor-intensive disassembly operations. Although research on recycling

automotive plastics is ongoing, it is not yet economically feasible to separate and recycle these materials, even when

avoided landfill tipping fees are included. Thus, it seems clear that a change in materials management in the U.S.

auto industry is unlikely to emerge without substantial new economic or regulatory incentives.

SOURCE: Officc of Technology Assessment, 1992.
60 ● Green Products by Design: Choices for a Cleaner Environment

Photo credit: U.S. Department of Energy

Compact fluorescent bulbs, which are available in a variety

of designs, use 75 percent less energy than standard

incandescent lamps, but contain small amounts of

mercury. The mercury produces the ultraviolet

radiation that causes fluorescence.

MEASUREMENT ISSUES

Measuring Product-Oriented Green Design

With all of the choices available, how can

designers and consumers determine what a‘ ‘green’

product is? As discussed in chapter 2, there maybe

design tradeoffs among alternative environmental

attributes of a product—for instance, between waste

prevention and recyclability. As an illustration, 3

pounds of a multilayered “polyester brick” packaging material can deliver the same amount of coffee

as 20 pounds of metal.18 Unlike the metal can, the

polyester brick is not currently recyclable. However,

to achieve equivalent levels of waste, a recycling

rate of 85 percent for the metal can would be

required, far higher than current rates.

Tradeoffs may also exist between other environmental attributes, such as toxicity and energy

efficiency. For example, the new high temperature

superconductors, which potentially offer vast improvements in power transmission efficiency, are

quite toxic; the best of them is based on thallium, a

highly toxic heavy metal. Similarly, the use of

compact fluorescent bulbs in lieu of incandescent

bulbs can result in substantial energy savings.19 But

compact fluorescent lamps contain small amounts of

mercury. 20 In this case the use of a toxic substance

has measurable environmental benefits.

Life-Cycle Analysis

The existence of these tradeoffs highlights the

need for analytical tools for weighing the environmental costs and benefits of alternative design

choices early in the design process. One methodology that is receiving increasing attention is product

life-cycle analysis (LCA). LCAs attempt to measure

the “cradle-to-grave” impact of a product on the

ecosystem. 21 In principle, LCAs could be used in the

design process to determine which of several

designs may leave a smaller “footprint” on the

environment, or after the fact to identify environmentally preferred products in government procurement or eco-labeling programs.22

Conceptually, the life-cycle approach has helped

to illuminate the environmental impacts of some

products that had not been considered before,

especially the ‘‘upstream” impacts associated with

material extraction, processing, and manufacturing.

By comprehensively accounting for materials inputs

and outputs, LCAs can keep track of impacts that are

merely shifted from one stage of the life cycle to

another, or from one environmental medium to

another. Qualitative LCAs are already being used by

some companies as an internal design tool to help

identify the environmental tradeoffs associated with

design decisions. The life-cycle perspective also

seems essential for a credible eco-labeling scheme.

The first step is to develop an inventory of the

18 T’hebl-ickcomists of polyester, aluminum foil, nylo~ and low-density polyethylene laminated together. It should be noted titthe wffeebrickw~

developed to preserve product freshness, and not beeause of environmental considerations. See Franklin Associates, op. cit., footnote 1.

19 ova ~ lo,~ho~ p~od, one l&w~tt fluorescent l-prep~cing a 75-watt in~ndes~nt ~results in energy savings Cif 570 kilOwatt hours.

This translates into approximately 500 fewer pounds of coal consumed, and 1,600 pounds less carbon dioxide released. Paul Walitsky, Manager

Environmental Affairs, Philips Lighting Co., personal communicatio~ May 1991.

20A co~pactb~b ~i~lycon~s about 5 q of mer~ryo ~emercury, whenva~~ed ~ the ~p’s electric ~, prduces the UbViOktEidhdO12

that causes fluorescence. (There are some data that indicate that the amount of mercury released from coal combustion for electricity generation exeeeds

the amount of mercury that would be used if incandescent bulbs were systematically replaced by compact fluorescent). Ibid.

21 I&..y, the a~ysis Comists of ~= stws: an inventory of msour~ inpu~ and w~te outputs for each shge, an assessment Of the Ikks MSOC~ted

with these inputs and outputs, and an assessment of possible options for improvement. However, virtually all LCAS attempted to date have consisted

only of the first step. See Society of Environmental Toxicology and Chemistry,‘‘A Technical Framework for Life-Cycle Assessments,’ Washingto@

DC, January 1991.

22 ~~fi@hhls~~ ~envhomen~ se~s of approv~ tit~awuded to products whose manufacture, use, ~d dispos~ ~ve fewer fiPacts ‘n ‘ie

environment than comparable products.
Chapter 4--Strategies for Green Design ● 61

resource inputs and waste outputs over the entire

life cycle. One approach to collecting and displaying

this information is shown in figure 4-1.

If an accurate inventory can be assembled, this

can provide preliminary insights into the environmental attributes of a product. But to determine

definitively whether one product is “greener” than

another, it is also necessary to know how the

quantities in figure 4-1 should be weighted to reflect

their relative health and environmental risks. For

example, how should a pound of sulfur dioxide

emitted to the air during manufacture be compared

with a pound of solid waste going to the landfill? Is

it more desirable to use laundry detergents that

contain phosphates or phosphate-free detergents that

release volatile organic compounds? To resolve

such questions, additional information about environmental fate, exposure pathways, and doseresponse data for each environmental release is

required.

Another serious limitation is that the data requirements of a comprehensive LCA can quickly get out

of hand. A major problem is where to draw the

boundaries of the analysis. Can certain materials and

energy flows be ignored without overlooking some

significant environmental effects? For example,

should one consider the energy required to produce

the fertilizer that is used to grow the cotton that is

used in cloth diapers? And if the energy is derived

from coal as opposed to hydroelectric power, should

one count the sulfur dioxide emissions associated

with the combustion of coal?23 Moreover, data

uncertainty can be compounded by the fact that

life-cycle analysis is sensitive to changes in inputs

over time. If a few material or technology inputs

change, initial assumptions may no longer hold, and

the inventory might require a complete updating.

When applied to more complicated products like

televisions and automobiles, the LCA methodology

might become hopelessly difficult to implement.

Precisely because LCAs are multidimensional, interest groups are free to emphasize the aspects most

favorable to their own agendas, thus providing

almost limitless potential to confuse consumers.24

Before LCAs (inventory and risk assessment) can

become a complete tool for comparing the greenness

Figure 4-l-Life-Cycle Inventory

PRODUCT NAME -.

RESOURCES DEPLETED

Benchmark*

Non-fuel Petroleum. 370.6 g

Wood / Paper .........270.5 g

Minerals . . . . . . . . . . . . . . . . . . 116.5 g

< WORSE I BETTER p

ENERGY USED

Nonrenewable Energv 41.3 MJ I ..: I

Carbon Dioxide .....2577.5 g

Sulfur Oxides ............25.9 g

Nitrogen Oxides ........19.0 g

Hydrocarbons ..............9.1 g

Dust ............................4 .3 g

Non-Hazardous Chem. .0 .164 g

Hazardous Chemicals ...0 .017 g

WATER EMISSIONS

Suspended Solids .......10.6 g

Non-Hazardous Chem ..0 .76 g

Hazardous Chemicals ...0 .093 g

Hazardous Waste ........5.9 g I

100% 100%

Worse Better

One approach to reporting the results of a life-cycle inventory is

illustrated by this hypothetical comparison of a product against a

benchmark product. For each product, the resource depletion,

energy consumption, air emissions, water emissions, and solid

wastes associated with manufacture and product use are tabulated. The inventory approach shown here will be used by SCS in

lieu of a simple eco-label.

SOURCE: Scientific Certification Systems.

of products after the fact, these issues will have to be

resolved. Less information will probably be required, not more. LCAs may have to be streamlined

to focus on a few critical dimensions of a product’s

environmental impact, rather than all dimensions.

One possibility might be to limit the analysis to three

dimensions: a product’s contribution to catastrophic

or irreversible environmental impacts (e.g., ozone

destruction, species extinction), acute hazards to

human health, and life-cycle energy consumption.

23 ~ese methodologic~ issues will be discussed in the upcoming Environmental Protection Agency repor4 “Life-Cycle Assessment: ~vento~

Guidelines and Principles,” Battelle and Franklin Associates, contractor report for U.S. EPA OffIce of Researeh and Development.

w ‘‘Life-Cycle Analysis Measures Greenness, But Results May Nol Be Black and White,” Wall Street Journal, Feb. 22, 1991, p. B1.
62 ● Green products@ Design: Choices for a Cleaner Environment

Any such “partial” LCA can be criticized as being

incomplete; for example, according to the criteria

above, chronic health effects of long-term exposure

to low concentrations of chemicals would not be

considered. But some such simplification seems

essential if LCAs are to be widely used.

There are further difficulties. Because they are

inherently product-focused, LCAs are consistent

with the product-oriented design approach. But in

focusing attention on the environmental attributes of

products per se, the LCA approach to design may

divert attention from larger opportunities available

by designing products in concert with new systems

of production, consumption, and waste management.25 Fundamentally, LCAs are “static” in that

they provide a snapshot of material and energy

inputs and outputs in a dynamic production system.

LCAs therefore do not capture the opportunities for

new technologies and new production networks to

reduce resource use and wastes. In assuming that the

product will be offered with certain characteristics to

perform a certain service, LCAs may limit the scope

of designers to consider ways of providing the

service in more environmentally sound ways.

In the near term, life-cycle comparisons of products are likely to be limited to comparisons of

resource and waste inventories. For designers’

purposes, the inventory need not be exhaustive to be

useful. For the purpose of product labeling, the

inventory should be rigorous, easily verifiable, and

periodically updated. Even so, at best, the inventory

will clarify environmental tradeoffs, rather than

provide definitive conclusions.

Measuring System-Oriented Green Design

How do we measure the environmental impact of

alternative systems, as opposed to alternative products? Product characteristics are tangible and can—

at least in principle-be quantified through lifecycle analysis; systems characteristics are less

tangible. To measure the environmental performance of systems (say, transportation systems or

telecommunication systems), new metrics will be

required. Perhaps aggregate indicators like “energy

intensity’ and “materials intensity” could be used

to compare “green systems.”26

Another useful aggregate measurement tool might

be provided by input-output analysis. Input-output

analysis models the exchanges (inputs and outputs)

between producers and suppliers. It can be used to

examine the exchanges among a small group of

companies, or the workings of national economies.

In principle, input-output techniques could be used

to correlate both intermediate and final products

with emissions of various pollutants.27 Using these

models, it might be possible to track the pollution

associated with alternative production networks.

With an emphasis on service, we may be more

concerned about product utilization rates rather than

disposal rates or quantities of emissions. For instance, a measure of environmental performance

might be product lifetime, or how effectively a

product performs its designated task (e.g., the

efficacy of a pesticide as part of an integrated pest

management scheme). Credible measurement tools

to evaluate the environmental performance of networks are an important research topic for the future,

as discussed in chapter 6.

SUMMARY

Green design thinking can occur on several levels.

At the product level, designers can optimize designs

so as to improve materials and energy efficiency, or

product longevity. A more ambitious approach is to

think about how product designs might be optimized

in a context of reorganized production and consumption systems. Such an approach suggests a design

philosophy that places primary emphasis on the

service a product provides rather than the product

itself. Thus, systems solutions require real behav-

~ Is it co~ctto comiderthe LCA restits of a particular product in isolation from the ripple effects of that product in the economy? The envkonmenti

externalities associated with a product might be outweighed by the greater efficiencies achieved when that product is incorporated into other products;

a good example would be computer chips and the automated systems that use those chips to improve manufacturing eftlciency.

~ Enmgy ~temi~ refers to the BtUS used to produce a dollar’s worth of gross domestic product (GDP); materials intensity refers to the qmtities

of materials (metals, lumber, cemen~ etc.) used to produce a dollar’s worth of economic output. In recent decades, both energy intensity and materials

intensity in the United States have declined. See U.S. Congress, OffIce of Technology Assessmen6 Energy Use and the U.S. Economy, OTA-BP-E-57

(Washington, DC: U.S. Government Printing Office, June 1990); and Eric Larson, Marc ROSS, and Robert Williams, “Beyond the Era of Materials,”

Scientific American, June 1986, pp. 34-41.

Z’ With the av~ability of ~n~ted ti~b~es on industrial waste streams such as EPA’s Tbxics Release Inventory, it is becotig feasible tO

incorporate pollution data into these economic models. See Faye Duchiq “Industrial Input-Output Analysis: Implications for Industrial Ecology,” op.

cit., foomote 6, pp. 851-855.
Chapter 4--Strategies for Green Design ● 63

ioral change on the part of producers and consumers, and disposed can be modified, the environmental

and can be difficult to implement. However, if the benefits will likely go well beyond what is possible

systems in which products are manufactured, used, by focusing on products alone.
Chapter 5

International Comparison of

Policies Affecting Green Design
Contents

ENVIRONMENTAL POLICIES

Europe . . . . . . . . . . . . . . . . . . . . . .

Japan . . . . . . . . . . . . . . . . . . . . . . .

ANALYSIS . . . . . . . . . . . . . .

CONCLUSION

Box

5-A.

5-1.

. . . . . . . . . .

Packaging

5-l. Environmental

.+,..

Page

AFFECTING PRODUCT DESIGN . . . . . . . . . . . . . . . . . . . . . . 67

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .* 67

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O..**... ..*,,... . . 73

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

Box

Page

Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

the World . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Table

Products in Other Industrialized

. . . . . . . . . . . . . . . . . . . . 72

Page

Countries . . . . . . . . . . 68
Chapter 5

International Comparison of Policies Affecting Green Design

In recent years, interest in green product design

has increased dramatically in the United States and

other industrialized nations. Historically, environmental policies have focused on protecting air,

water, and land from ‘‘point’ sources of pollution

(e.g., factories and powerplants). But countries are

now recognizing the importance of nonpoint sources,

including products (e.g., chlorofluorocarbons (CFCs)

and pesticides). Many countries with stringent

environmental protection standards show a growing

tendency to extend the traditional emphasis on

pollution control to include standards for the environmental attributes of products.

The environmental product policies of other

nations have important implications for the United

States. First, these policies are shaping international

markets in which U.S. goods must compete. The

policies of other nations on issues such as packaging, mercury in batteries, and automobile recycling

have the potential to change the competitive landscape of foreign markets. The success of U.S.

companies in these markets will depend, at least in

part, on their ability to employ green product design.

Second, product policies may act as nontariff

barriers to trade.1 They are often seen by critics as

giving domestic industries an unfair advantage.

Examples include the recent U.S. attempt to ban

imports of Mexican tuna because of concern about

dolphins killed during tuna fishing,2 Denmark’s

decision to ban the sale of beer in nonrefillable

containers, and Germany’s new law requiring companies to recover and recycle their packaging waste.3

Finally,studying the experience of other industrialized nations can provide lessons for U.S. policymakers.

This chapter surveys some of the more notable

policies affecting green design in industrialized

countries, with a view toward understanding how

U.S. activities compare with those in other countries.4 Table 5-1 provides a summary.

ENVIRONMENTAL POLICIES

AFFECTING PRODUCT DESIGN

Europe

Nearly all European countries are building up a

body of product-related environmental law that

extends beyond traditional areas of pollution control. There is a strong positive correlation between

national wealth and environmental awareness in

Europe; thus Germany, the Netherlands, and the

Nordic countries (Norway, Sweden, Finland, and

Denmark) are in the forefront.

Germany

Germany is particularly active in environmental

product policy. In May 1991, Germany enacted its

Waste and Packaging Law that gives manufacturers

and retailers responsibility for recovering and recycling their own packaging wastes (see box 5-l). This

statutory coupling of manufacturing with postconsumer recycling forces manufacturers to account

for the solid waste implications of packaging.

Germany is considering similar laws that would give

manufacturers the responsibility for collecting and

recycling durable goods, such as household appliances and automobiles (see below).

Besides recycling, Germany has an active program for labeling environmentally preferred products. The “Blue Angel” eco-labeling scheme has

been in operation since 1978 and is the only example

of a well-established eco-labeling scheme in Europe.

The award is not given to individual products, but to

categories of products that meet certain criteria.

Supporters of the Blue Angel scheme point to

several successes: paint, lacquers, and varnishes that

are low in solvents and other hazardous substances

1 For an overview of the issues involving trade and the enviromnen$ see: U.S. Congress, Office of Technology Assessment, Trade andEnvironment:

Conflicts and Opportunities, OTA-BP-ITE-94 (Washingto~ DC: U.S. Government Printing Office, May 1992).

2 The ban was imposed under the Marine Mammal Protection Act of 1972, Public Law 92-552. Later, a panel of the General Agreement on ‘hri-ffs

and Trade (GATT) determined that the ban violated GATT’s rules of international trade. Ibid.

3 Frances Cairncross, Costing the Earth: The Challenge for Governments, the Opportunities for Business (Boston, MA: Harvard Business School

Press, 1992).

4 The discussion of activities in foreign nations draws heavily from Environmental Resources Limited, Erwiromnenta21y Sound Product Design:

Policies and Practices in Western Europe and.lapan, contractor report prepared for the Ofllce of Technology Assessment July 1991.

-67–
Table 5-1-Environmental Policies Relating to Products in Other Industrialized Countries

Policy Comment

Economic Commission for Europe (United Nations)

A task force is developing guidelines for “environmental product profiles,” a

qualitative description of the environmental impacts of a product for use by

commercial and institutional buyers.

European Community

Draft law requiring specific percentages of recovery (recycling, incineration, and

comporting) for product packaging.

EC eco-label.

EUREKA

Eco-design project to gather information and develop methods to stimulate the

design of environmentally sound products.

Canada

The National Packaging Protocol is a voluntary program with packaging

reduction targets and dates.

Environmental Choice eco-label.

Denmark

Ban on domestically produced nonrefillable bottles and aluminum cans.

Fee imposed on waste delivered to landfills and incinerators as an incentive to

recycling and to support dean technology.

Clean Technology Action Plan (1990-92).

Germany

Packaging Waste Law, passed in 1991, gives manufacturers responsibility for

oollecting and recycling various kinds of packaging at specified rates by certain

dates.

Manufacturer take-back-and-recycle laws have been proposed by the government for automobiles, electronic goods, and other durables.

Mandatory deposit refund on plastic beverage containers (except milk).

Blue Angel product coo-label.

Researchers from the Netherlands and Sweden have been among the most active

participants in the Task Force.

The draft has been driven largely by German packaging legislation.

Principles of the program have been agreed upon, but no date for implementation

has been set.

Under the Euro-Environ umbrella program, this project is led by Dutch researchers.

By the year 2000, packaging sent to disposal is to be no more than 50 percent of

the amount sent in 1988. Half of this reduction is targeted to come from waste

prevention and re-use, and half from recycling. Regulations are to follow if targets

are not achieved.

Over 400 product categories have been recommended for labelling.

The EC took Denmark to the European Court over this ban, which originally revered

foreign-produced containers as well, claiming it was an unwarranted restriction on

trade. Denmark won the case. Now, deposit, return, and recycling schemes must

be setup for imports.

130 DKr ($19) per ton is earmarked for subsidies for dean technology.

A principal aim of the plan is to reduce consumption of nonrenewable materials and

to reduce the use of heavy metals and other toxic substances.

This legislation is being considered as a model for EC-wide packaging legislation.

The packaging collection rates and target dates are considered very ambitious.

Concerns have been raised that this law could create special problems for imported

goods.

These proposals, which have not yet been passed, would go into effect in 1994.

They have already stimulated auto and computer companies to begin to redesign

oars and computers to facilitate recovery and recycling of components and

materials.

Established in 1989, the deposit of DM 0.5 (.$0.28) will remain in place under the

new packaging waste law.

Begun in 1978, this was the first national eco-label program; it now covers 400

products in 66 categories.
Japan

Recycling Law, passed in 1991, sets target recycling rates around 60 percent

for most discarded materials by the mid-1990s. Includes product redesign

strategies for packaging and durable goods.

Em-mark product eco-label.

Netherlands

National Environmental Policy Plan sets national targets and timetables for

implementing dean technology, including redesign of products.

Voluntary agreements reached with industry targeting 29 priority waste streams

and reduction of packaging waste.

Norway

Tax on nonreturnable beverage containers.

Deposit-refund on old car bodies.

Sweden

Ban “in principle” on the use of cadmium.

Voluntary deposit-refunds for glass and aluminum beverage containers.

United Kingdom

Gas tax differential of around 10 percent between leaded and unleaded gas.

SOURCE: Offica of Technology Assessment, 1992.

The law gives the Ministry of International Trade and industry broad powers to set

recycling guidelines for specific materials and industries.

The label covers more than 850 products in 31 categories.

The most comprehensive national environmental policy planning document

anywhere in the world. The Netherlands Government has a budget of around$100

million per year to support development of clean technologies and products.

Voluntary agreements are considered a more effective means of achieving

environmental goals than command-and-control regulations.

This tax, which can be as high as $.52 per container, is intended to encourage

producers to use refillable packaging.

The deposit of NKr 1,000 (U.S. $1 43) is refunded with a bonus; the return rate is 90

percent.

A number of exemptions are permitted.

Return rates of 80 to 90 percent have been achieved.

Several other countries have similar policies. Sales of unleaded gas rose from

negligible to 36 percent in 3 years.
70 ● Green Products by Design: Choices for a Cleaner Environment

Box 5-A-Germany’s Packaging Law

Germans generate about 32 million tons of municipal waste per year, About 30 percent of that waste is

incinerated and nearly all the rest, about 22 million tons annually, ends up in landfills. At this rate, about half of

Germany’s landfills will fill to capacity and be forced to close within 5 years.

Because packaging accounts for 30 percent of German municipal waste by weight, the country recently enacted

a prominent new law regarding the collection and recycling of packaging. The law (The German Federal Ordinance

Concerning Avoidance of Packaging Waste) gained final legislative approval in April 1991, and its first provision

took effect in December 1991. The law redefines the responsibilities of companies and requires recycling on a

massive scale.

The fundamental philosophy behind the German packaging law holds product manufacturers and distributors

responsible for the packaging they create and use. The law requires little from consumers, but mandates that

companies take back and recycle used packaging, For some types of packaging, the law gives industry an

opportunity to establish its own collection and recycling system. If such self-management fails, however, it compels

manufacturers and distributors to collect the packaging themselves and arrange for recycling.

The law defines three types of packaging: transport, secondary, and sales. Transport packaging refers to items

used to protect or secure products during transportation from the manufacturer to the distributor (e.g., large

corrugated shipping containers and wooden pallets). Secondary packaging refers to items used to group, protect,

and display the product at the point of sale (e.g., exterior cartons and packaging components that make products

tamper-proof). Sales packaging refers to items in direct contact with the product itself (e.g., liquid containers and

food wrapping).

The law contains separate deadlines for each type of packaging. Collection of transport packaging by

manufacturers and distributors was required beginning December 1, 1991. Collection of secondary packaging by

distributors was required beginning April 1, 1992. Sales packaging must be taken back beginning January 1,1993.

Collected packaging must be reused or recycled to the greatest extent possible. Materials not recycled or reused

must be materials that: 1) cannot be separated manually or by machine; 2) are soiled or contaminated by substances

other than those that the package originally contained; or 3) are not integral parts of the packaging. Recycling must

be accomplished independently of the public waste disposal system. Incineration is specifically prohibited.

Additional provisions apply to specific packaging types. Secondary packaging must be removed by

distributors (including retailers) before products reach consumers or distributors must provide an opportunity for

consumers to remove and return the packaging at the point of sale. The law requires that distributors provide separate

containers for different packaging materials and post signs indicating that consumers may return secondary

packaging.

The law also contains additional provisions for sales packaging. As with secondary packaging, distributors

must accept returned sales packaging at the point of sale. The law also mandates a deposit-refund scheme covering

containers for beverages, household cleaners, and spray paints.

The sales packaging previsions can be avoided by manufacturers and distributors who are party to an

alternative collection system. First, the alternative system must collect packaging directly from households or

establish collection centers. Second, the system must meet strict collection and sorting targets. These targets will

be assessed by weight within each “Lander’ or district within Germany, and require at least 60 percent collection

of most materials by January 1993 and at least 80 percent collection of all materials by July 1995. Third, existing

levels of reusable beverage containers must be maintained. This alternative system exempts companies from the

provisions for sales packaging only; companies must still take back transportation packaging and secondary

packaging directly,

Under pressure from retailers, industry moved rapidly to establish an alternative system under the terms of the

law: the Duales System Deutschland (DSD). DSD is a private company established to collect packaging of

participating companies. Participating companies pay a licensing fee to use a‘ ‘Green Dot’ label that identifies their

packages as eligible for collection. Licensing fees of up to 20 pfennig (U.S. $0. 12) per package are expected to raise

about 2 billion DM (U.S. $1.2 billion) per year.
Chapter International Comparison of Policies Affecting Green Design ● 71

Whether reality will match the law’s lofty goals remains to be seen. The law faces several hurdles. First, the

mandatory 1995 collection rate of 80 percent for all sales packaging materials far exceeds the rates currently

achieved For example, Germany recycled just over 40 percent of paper and paperboard recycling in 1987 and just

over 53 percent of glass in 1989. Internationally, 80 percent recycling rates for any material are ram, even in highly

motivated neighborhoods. Overall rates of 80 percent are unheard of on a national scale.

Second, although the stated goal of the law is source reduction, it focuses almost exclusively on recycling.

Whether the costs of collection and transportation will encourage source reduction remains to be seen. Third, the

law does little to enlist the help of consumers in recycling. The entire burden for ensuring the success of the law

rides on the efforts of manufacturers and retailers. Finally, the law raises thorny issues regarding international trade.

The law’s provisions apply to any goods sold within Germany, regardless of their country of origin. Thus,

companies that export goods to Germany must arrange for collection and recycling of their packaging.

While the European Community has been working on unified solid waste guidelines to facilitate free trade,

the German law has leapt ahead with the strictest plan of any EC nation, Whatever the outcome, Germany’s

packaging law represents a bold experiment that will be closely watched on both sides of the Atlantic,

SOURCES: James E. McCarthy, Recycling and Reducing Packaging Waste: How the United States Compares to Other Countries, 91-802 ENR

(Washington, DC: Congressional Research Service, Nov. 8, 1991). “Translation of the Ordinance on the Avoidance of Packaging

Waste’ ‘in Environmental Resources Limited, Environmentally Sound Product Design: Policies and Practices in Western Europe

and Japan, contractor report prepared for the Office of Technology Assessment, July 1991. “Recycling in Germany: A Wall of

Waste,” The EconomiSt, Nov. 30, 1991, p. 73. Kerstin Wessel, “The German ‘Dual system’--An Instrument To Promote waste

Minimization in the Packaging Sector?’ Packaging and the Environment--Policies, Strategies and Instruments,Invitational Expert

Seminar, Trolleholm Castle, Sweden, Feb. 7-8, 1991 (Lund, Sweden: Department of Induatrial Environmental Economics, Lund

university).

now command 50 percent of the German do-it- The Netherlands

yourself market, compared with just over 1 percent

in the 1970s; over the same period, emission The Dutch Government produced the National

standards for oil and gas heating appliances have Environmental Policy Plan (NEPP) in 1989 and

improved by more than 30 percent. The program NEPP Plus in 1990. These are major policy docureceives only 8 percent of its income from Federal ments outlining plans for harmonizing economic

subsidy, with 57 percent coming from the sale of development with the environment through the year

publications and certification.5 2010. They are widely acknowledged to be the most

detailed and comprehensive example of environHowever, the Blue Angel program is not an mental planning anywhere in the world.7 The plans

explicitly include product policy and green design as unqualified success. Despite its longevity, the pro- part of a preventive strategy using “processgram only covers a small percentage of consumer integrated environmental technology” to achieve

products. 6 Although the initial intention was to “sustainable development. ” The Dutch plan looks

consider all of a product’s environmental impacts forward to “an alternative way of living” with

when awarding the Blue Angel label, in practice investment in ‘‘clean’ technologies coming to attention usually focuses on one or two environ- dominate new capital investment. The Dutch budget

mental impacts. For example, the program judges for development of clean technology was about $90

spray cans on the elimination of aerosol propellants million in 1990. No other country has long-term

and judges detergents on wastewater load. Environ- policies that address environmental aspects of prodmental groups have criticized the program, contend- uct design as specifically as the Netherlands.

ing that it should consider the entire product life

cycle. The feasibility of broadening the selection Dutch environmental policy relies increasingly on

criteria to include life-cycle impacts is presently voluntary agreements negotiated with industry, rather

under study. than on command-and-control regulation. For exam5 Ibid., pp. 11-12

6 Of the labels issued, over half have been in only four product categories (recycled paper, low-pollutant varnishes and coatings, low-emission gas

burners, and pH neutral stripping agents for wastewater treatment). Environmental Labelling in OECD Countries (Paris: Organisation for Economic

Cooperation and Development, 1991), p. 48.

7 ERL, op. cit., footnote 4, p. 22.
72 ● Green products by Design: Choices for a Cleaner Environment

Figure 5-1—Eco-labels Around the World

A

Canada (Environmental Choice) Nordic Countries (White Swan)

West Germany (Blue Angel) Japan (EcoMark)

United States (Scientific

Certification Systems)* United States (Green Seal)

Eco-labels are intended to identify environmentally preferred

products for consumers. Above are government-sponsored labels

from four foreign programs and two private U.S. labels.

*NOTE: The SCS label will provide comparative data on environmental

attributes (see figure 4-l).

pie, it is part of government policy to identify

hazardous substances (e.g., cadmium and chlorine),

and to eliminate these substances from every stage

of the production process. The Dutch Government

has established waste reduction targets for 29

priority waste streams, with action plans to be

negotiated as voluntary agreements with industry.

The government has recently signed a voluntary

agreement on packaging waste, which could be

backed up by regulations if negotiated targets are not

met within the specified time. Environmental groups

in the Netherlands also negotiated a voluntary

agreement with retailers on the elimination of

polyvinyl chloride (PVC) from packaging in September 1990.

The Netherlands has begun work on a national

eco-labeling scheme for products, but has expressed

a preference for a harmonized European Community

(EC) program. Dutch researchers are active in the

area of life-cycle analysis. The Netherlands initiated

a task force under the aegis of the United Nations

Economic Commission for Europe (ECE) to develop

guidelines for product “profiling,” a descriptive

form of life-cycle analysis intended for use by

professionals such as designers and procurement

agents. In addition, the Dutch have initiated research

projects to develop guidelines and information

resources to assist designers in making better

environmental choices.8

Nordic Countries

Sweden, Norway, and Denmark have all been

active in the area of environmental product policy.

For many years, these countries have employed a

wide range of taxes and deposit-refund schemes to

limit packaging waste (see below). They have also

used a combination of bans and voluntary agreements with industry to encourage green design.9

Sweden banned “in principle” the use of cadmium

in many products over a decade ago, and the idea of

“sunsetting" or phasing out the use of various toxic

chemicals is quite popular there. Denmark banned

nonrefillable beverage containers for beer and soft

drinks, and required that bottle designs be governmentapproved. 10 Denmark has announced a Clean Technology Action Plan to run through 1992 that focuses

on reduced consumption of nonrenewable materials

g ERL, op. cit., footnote 4, p. 23.

9 See Christian Ege Jorgeme~ ‘Sunset Chemical~From a Danish Perspective, ” Proceedings of the Global Pollution Prevention ’91 International

Conference & Exhibition, Lorraine R. Penn (cd.), Washington, DC, Apr. 3-5, 1991.

10 Denmarkwastakento the EC Court over the b~ which allegedly constituted arestrictionontrade. ‘Ihe court mledinfavorof DemnaxL butr~titi

that designs of imported bottles be exempted from the approval requirements as long as they were nonmetal and were subject to a deposit-refund

scheme.
Chapter 5--International Comparison of Policies Affecting Green Design ● 73

and reduced use of heavy metals and other toxic

substances in a variety of products.

The Nordic countries decided in November 1989

to “implement a harmonized, voluntary, and positive Nordic environmental labeling system for

products.’’11 Criteria for product categories are

currently being drawn up, although this program is

now at least partially on hold, pending

decision on an EC-wide labeling system.

European Community

an EC

The European Community is increasingly a driving force behind environmental law in Europe. The

number of EC environmental laws adopted has risen

from one per year in the 1960s to between 20 and 30

per year in the 1980s.

EC environmental policy has always included a

strong emphasis on harmonizing product standards

among countries, but such harmonization can be

difficult. Much EC environmental legislation and

planning has been inspired by Germany (e.g.,

manufacturer responsibility for packaging waste),

the Netherlands (e.g., waste stream prioritization),

and the Nordic countries (e.g., reduced heavy metal

content and separate collection of batteries). However, the range of environmental legislation varies

greatly among European countries, as does the

willingness of different countries to pursue future

action.

Some countries already have substantial environmental standards in place, and have expressed fears

that their own higher standards maybe compromised

by a lower EC-wide standard.12 As a result, the EC

tends to set minimum standards that may be

exceeded by “greener’ countries. Some poorer

countries have not placed as high a priority on

environmental policy, and they find their national

legislation increasingly driven by EC requirements.

While EC standards have tended to be relatively

stringent, they often acknowledge that poorer countries may have difficulty meeting the standards. The

EC sometimes adopts a two-tier approach that gives

poorer countries more time to achieve standards

demanded by wealthier countries.

The EC began discussions on eco-labeling in

1988, prompted by the need to coordinate product

labeling before the advent of the Single European

Market in 1992. Plans to launch the system were

formally unveiled in November 1990. The criteria

for granting the label will be harmonized throughout

the EC and will be decided by the European

Commission with the assistance of an Advisory

Committee. The decision to adopt life-cycle criteria

was made after pressure from the Nordic countries

(though they were not EC members), who expressed

criticism of the more limited criteria applied by

Germany’s Blue Angel program. At this writing, no

date had been set for implementing the EC eco-label

(a daisy surrounded by 12 stars).

Japan

Japanese industry’s interest in green products has

lagged somewhat behind that in Europe and the

United States, in part because of a lower level of

consumer activism, and in part because there has

been little government policy leadership in this area.

However, Japan recently identified environmentally

sound products and technologies as a major new

market opportunity, and is investing large sums in

research and development.13 The close relationship

between government and industry in Japan suggests

that government proposals-as they develop-may

be implemented more quickly than is the case in

Europe or the United States.

One motivation for Japanese environmental policy is an acute crisis of landfill space. Although

Japan incinerates 70 percent of its municipal solid

waste, major urban areas are having difficulty even

finding space to dispose of the incinerator ash

residue. 14 In response, the government passed a

recycling law in April 1991 that is designed to

promote waste recycling.l5 The recycling law mandates recovery rates of around 60 percent for most

discarded materials (including glass, paper, aluminum cans, steel cans, and batteries) by the mid1990s, and it includes product redesign strategies for

11 Notic COUIKU of Wters, written procedure, Nov. 6, 1989. Cited in ERL, op. Cit., fOOttIOte 4, p. 12.

12 For e=ple, tie cod c= stemming from Denmark’s ban on nomefiible ~Mes.

13 Jacob M. sc~es~er,6c-@&n: ~ Jap~, ~viro~entM~~~oppo~ty for New Tw~o@y,” Wa/JStreetJour@ June 3, 1M2,

p. Al. Neil Gross, “The Green Giant? It May Be Japtuq” Bum”ness Week, Feb. 24, 1992, pp. 74-75.

14 ~, op. cit., fOO~Ote 4, P. 74”

15 It is fo~ly known ss the ‘{JAW for Promotion of Utilization of Recyclable Resources,”or more commonly as the “Recycling Law.”
74 ● Green products by Design: Choices for a Cleaner Environment

both packaging and durable goods. Sponsored by the

Ministry of International Trade and Industry (MITI),

the law provides MITI with broad powers to set

recycling guidelines for specific industries and

materials. Those interviewed by the Office o f

Technology Assessment felt that MITI’s involvement, as well as its extensive discussions with

industry prior to the law’s passage, would mean that

Japanese industry would move relatively quickly to

implement the law. 16

The ability to move quickly was certainly illustrated in the case of Japan’s environmental labeling

scheme, the Eco-mark. The details of the scheme

were published in February 1989, along with an

initial list of approved product categories. In March

1989, 46 products in 7 product categories were

approved, including aerosols containing no CFCs.

One year later, there were 850 labeled products in 31

categories. 17 The Eco-mark is usually awarded to

product categories based on a single environmental

attribute, and thus is less rigorous than criteria

proposed in EC draft legislation or other national

labeling schemes based on the cradle-to-grave approach. However, the Eco-mark was quickly implemented and is reportedly popular with Japanese

consumers, who have not traditionally been associated with strong environmental awareness.

ANALYSIS

The integration of product policy into environmental policy and the role of product design in

making products more “friendly” to the environment are areas of considerable policy ferment

around the world. Twenty-two of the major industrialized countries either have a national eco-labeling

program for products, or will have one soon.18 There

are a growing number of product control policies in

effect, ranging from outright bans on materials to

economic instruments such as product taxes (see

table 5-l). All of the countries are attempting to

boost recycling; many of these initiatives focus on

packaging, which constitutes about one-third of

post-consumer waste by weight in many countries.l9

There are some important differences between the

U.S. approach and the approach taken by other

countries. In some countries, environmental and/or

economic conditions have forced policies that encourage green design. While shrinking permitted

landfill capacity is a growing problem in the United

States, it is already very serious in Northern Europe

and Japan. As a result, the pressure on manufacturers

to design smaller, more efficient products and

packages is greater than in the United States.

Another difference is the dramatically higher fuel

prices in Europe and Japan, due in large part to

government taxes.

20 These high prices encourage the

design of fuel-efficient automobiles, contribute to

greater use of public transportation, and promote

more energy-efficient buildings and appliances.

The political atmosphere surrounding waste management in Europe has forced drastic policy measures such as Germany’s Packaging Waste Law. This

law has set the tone for a common policy theme

emerging in several European countries: the idea of

giving manufacturers responsibility for recovering

and recycling their products at the end of their useful

life. Manufacturer take-back requirements have

intuitive appeal because they give designers direct

incentives to consider how the product will be

recovered and recycled, thus “closing the loop”

among design, manufacturing, and waste management.

The idea of shifting responsibility for managing

these materials to manufacturers can be expected to

have a growing appeal in the United States as well,

particularly given that U.S. cities are collecting

recyclable materials at a rate much faster than they

are being used. Many U.S. manufacturers, especially

those of durable goods, feel that similar legislation

is inevitable in the United States in a few years.

There are also social and cultural differences in

Europe and Japan that may foster the development

16 ERL, op. cit., footnote 4, p. 76.

17 Em, op. cit., footnote 4, p. 80.

18 Cathefie AMS~ “some 22 Natiods Could Have ‘Green Label’ Schemes by ‘93,” Toronto Star, NOV. 6, 1991, P. D6.

19 J-es E. Ikf&~y, Re~c@ and Reducin8 Packaging Waste: How the United States Compares to Other COuntiie& 91-802- (wSStigto%

DC: Congressional Research Service, Nov. 8, 1991).

m For e=ple, gasoline prices in E~oWan r@ons are two to four times the price of gasoline in the United States, with host d of the difference

due to government taxes. Japanese gasoline prices are more than three times higher, with about half of the difference due to taxes. Energy Information

Adminstratio~ Indicators of Energy Efi”ciency:An International Comparison, EIA Semice Repofi SRIEMEU/90-02, July 1990.
Chapter 5--International Comparison of Policies Affecting Green Design ● 75

of green design more rapidly than in the United

States. In many other countries, government and

industry work together more comfortably than in the

United States, where the relationship tends to be

more confrontational. Although Europe continues to

rely heavily on command-and-control environmental

regulations, the greener European countries are more

likely to seek voluntary agreements with industry to

achieve environmental goals, rather than enforcing

compliance with regulations through the legal system. Large government subsidies to industry for

development of ‘clean technology’ are prevalent in

the Netherlands and Denmark.21 The closer relationship between government and industry may explain

why several other countries have national eco-labels

for products, while the United States leaves labeling

efforts to the private sector.

Attitudes toward weighing environmental risks

and benefits also differ somewhat between the

United States and some European countries. New

initiatives in Europe, such as the German packaging

waste law or carbon taxes on fuels, tend not to be

subjected to the kind of cost-benefit analysis that

would be expected in the United States.

Finally, in countries like Germany, Sweden,

Denmark, and the Netherlands, the policy debate is

qualitatively different from that in the United States.

These European nations produce national policy

documents that state broad environmental goals

such as resource conservation and “sustainable

economic development’ ‘—with explicit targets and

timetables. U.S. policies focus more narrowly on

protecting consumers from harmful products and

protecting the environment from various waste

streams. Using the terminology of chapter 3, these

countries are developing policies from the perspective of the resource management and ecodevelopment paradigms, while the United States is

operating from the environmental protection paradigm.

With the approach of the Single Market in 1992,

the member counties of the European Community

are wrestling with the problem of harmonizing their

different environmental product standards and recycling laws. These laws have proved contentious in

the past, and no resolution is in sight.22 The United

States faces similar problems in managing the

multitude of divergent environmental product regulations in various States. Recent controversies over

whether countries can restrict imports of goods

deemed harmful to health or the environment, or

whether such restrictions constitute nontariff barriers to trade, suggest that the harmonization of

international environmental product policies will be

a thorny problem for future negotiations under the

General Agreement on Tariffs and Trade (GATT)

and other international agreements.

CONCLUSION

On the whole, the United States cannot be said to

be “behind” other countries in the development of

environmental policies that encourage green product

design. Indeed, many European countries look

enviously at U.S. environmental policies such as

auto emissions standards, or the timetable for

phaseout of CFC production and use, which are

among the most aggressive in the world. Some U.S.

companies are acknowledged world leaders in waste

prevention techniques.

After investigating the policies of other nations,

the Office of Technology Assessment finds no

models that the United States should directly imitate. In fact, many observers believe that some of the

more extreme measures, such as Germany’s mandatory take-back provisions for packaging waste, will

prove to be costly and difficult to implement.23 This

does not mean that the United States should ignore

the potential of green product design, only that the

policies pursued abroad should not be copied

wholesale.

The rapid evolution of environmental product

policy, and its increasingly international flavor,

suggests that the United States needs a proactive

Federal involvement. First, such involvement can

ensure that the experiences of other nations are

closely monitored. Second, Federal involvement can

provide a focal point for policies that protect the

environment while reducing barriers to international

trade. In the next chapter, options for greater Federal

involvement are discussed.

21 For e~ple, tie Ne~~lan& Government provided $90 million in 1990 to subsidize clean technology development. AS a permntige of gross

mtional produc~ this would be the equivalent of about a $2 billion program in the United States.

22 Fr~ces Ctthncross, ‘‘How Europe’s Companies Reposition ‘lb Recycle,’ Harvard Business Review, March-April 1992, p. 34.

~ ,, fivkommtism Runs Riot! “ The Econom”st, Aug. 8, 1992, pp. 11-12.
Chapter 6

Policy Options and the

Challenge of Green Design
Contents

Page

CURRENT INCENTIVES FOR GREEN DESIGN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79

Federal Statutory/Regulatory Incentives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79

State and Local Laws and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .81

Market Incentives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Corporate Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Response of Educational Institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82

Information Resources Available . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

CONGRESSIONAL ROLE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

RESEARCH NEEDS . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .89

Technical Research . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

Applied Social Science Research . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

CREDIBLE INFORMATION FOR CONSUMERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .93

Individual Consumers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

Eco-Labels . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

Institutional, Commercial, and Government Buyers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

Government Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

MARKET DISTORTIONS AND ENVIRONMENTAL EXTERNALITIES . . . . . . . . . . . . . . . . 97

Recycled Content . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

Use of Hazardous Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100

Product Taxes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104

Manufacturer Take-Back . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . 105

COORDINATION AND HARMONIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105

New Institutions for Environmental Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106

Interagency Groups . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

Technology With a Green Lining . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

A STARTING POINT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

Boxes

Box Page

6-A. Survey of Engineering School Deans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

6-B. Toxics Use Reduction vs. Waste Minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102

Tables

Table Page

6-1. Federal Health and Environmental Laws Affecting Product Design . . . . . . . . . . . . . . . . . . . . 80

6-2. Examples of State or Local Laws Affecting Product Design . . . . . . . . . . . . . . . . . . . . . . . . . . . 82

6-3. Industry and Professional Organizations Concerned With Green Design . . . . . . . . . . . . . . . . 83

6-4. Environmental Education Programs in Design, Engineering, and Business Schools . . . . . 86

6-5. Federally Funded Programs Related to Green Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88

6-6. Policy Options That Could Affect Materials Flows . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
Chapter 6

Policy Options and the Challenge of Green Design

Several examples have already been cited in

which Federal regulations inject environmental considerations into product design. For instance, the

effect of Corporate Average Fuel Economy (CAFE)

standards on automobile design is described in

appendix 3-A. Should Congress consider taking any

further action to encourage green design? While

some in industry argue that existing market incentives and environmental regulations are sufficient,

the Office of Technology Assessment (OTA) finds

that further Federal action is necessary to ensure that

the full potential of green design is realized. This

chapter examines current incentives for green design

and identifies four areas of need that only Congress

can address.

CURRENT INCENTIVES FOR

GREEN DESIGN

Federal Statutory/Regulatory Incentives

Many health and environmental laws passed by

Congress influence the environmental attributes of

products (table 6-1).1 Some, such as the Clean Air

Act (CAA), Clean Water Act (CWA), and Resource

Conservation and Recovery Act (RCRA) do so

indirectly, by raising industry’s costs of releasing

wastes to the air, water, and land. Others, such as the

Toxic Substances Control Act (TSCA) and the

Federal Insecticide, Fungicide, and Rodenticide Act

(FIFRA), control the use of hazardous chemicals and

pesticides directly.2

Sometimes, design changes have resulted from

“sunshine” laws that simply require the public

disclosure of information about industry’s use of

toxic chemicals. For example, Title III of the

Superfund Amendments and Reauthorization Act of

1986 requires manufacturers to report environmental releases of 322 listed chemicals to a public

database managed by the Environmental Protection

Agency (EPA) called the Toxics Release Inventory

(TRI). In several cases, the prospect of public

disclosure of these releases stimulated companies to

switch to more environmentally sound processes

and product formulations.3 Companies are also

reformulating products to reduce potential liability

for improper waste disposal under RCRA and the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or “Superfund’’ ).4

Of those laws listed in table 6-1, the Clean Air Act

Amendments of 1990 may have the largest impact

on product design, since they will result in restrictions on volatile organic compounds (Title I),

hazardous air pollutants (Title III) and chlorofluorocarbons (CFCs) and other ozone-depleters (Title

VI). These chemicals are used widely in manufacturing processes, as well as in paints, coatings, cleaners,

pesticides, and household products.5

In listing the environmental laws in table 6-1,

OTA does not intend to suggest that all environmental impacts of products are already regulated or

that existing regulations provide adequate protection

for the environment. Rather, the intent is to show the

range of Federal laws that already affect product

design.

Federal Disincentives?

Critics charge that some Federal regulations

provide disincentives to green design. Examples

often cited are government procurement policies

(e.g., military specifications that require the use of

virgin materials, CFC cleaners, and leaded paints

where these materials are not necessary for product

performance), RCRA regulations that make the

I For an ove~iew of the tiuence of Fede~ laWS on the formulation of various chemical products, See Km ~d Associates, rnc., “Eff~t of

Environmental Statutory/Regulatory Requirements on Product Formulation/Process Design: Inforrnationon Solvents, Agricultural Chemicals, Products

Containing Heavy Metals, and Related Household Cleaning Products,” contractor report prepared for the OflIce of Technology Assessmen~ April 1992.

z pad R. po~ey (cd,), Public policiesfor Environmental Protection (Washingto% DC: ReSowceS for the Fu~> 1~)”

s For a discussion of how TRI reporting requirements changed the corporate culture at Monsanto and other companies, see Bruce Smart (ed.), Beyond

Compliance:A New Zndusrry View of the Environment (Washington DC: World Resources Institute, 1992), p. 87.

A Ka and Associates, op. cit., footnote 1.

5 As one example, the total U.S. market for coatings in 1990 was $11.9 billion, but only about half of these coatings meet current environmental

regulations for volatile organic compounds. Cited in promotional literature for a report by Business Communications Company, Inc. NorwallL m

“Environmentally Acceptable Coatings: The Industry,” LC-136, May 1991.

–79–
80 ● Green Products by Design: Choices for a Cleaner Environment

Table 6-l—Federal Health and Environmental Laws Affecting Product Design

Statute Impact on design Agency

Clean Air Act of 1970 (and Amendments of 1977

and 1990)

Clean Water Act of 1977 (and Amendments of

1987)

Resource Conservation and Recovery Act of 1976

(and Hazardous and Solid Waste Amendments

of 1984)

Comprehensive Environmental Response,

Compensation, and Liability Act of 1980 (and

Superfund Amendments and Reauthorization

Act of 1986)

Federal Insecticide, Fungicide, and Rodenticide Act

of 1972 (and Amendments of 1988)

Toxic Substances Control Act of 1976

Federal Food, Drug, and Cosmetics Act

Consumer Products Safety Act of 1978, Federal

Hazardous Substances Act, Poison Prevention

Packaging Act of 1970

Occupational Safety and Health Act of 1970

Encourages reduction in the use of solvents, volatile

organic compounds, and phases out

chlorofluorocarbons.

Encourages reduction in the use of toxic chemicals

that become water pollutants.

Encourages redesign of products and processes to

reduce generation of hazardous solvent,

pesticide, and metal-bearing wastes, and to

avoid liability for cleanup of wastes improperly

disposed.

Encourages reduction in use of listed hazardous

substances to avoid reporting requirements for

releases of these substances, and Iiability for

cleanup of Superfund sites.

Encourages reformulation of pesticides to ensure

safety and efficacy of active ingredients (and to

avoid inert ingredients of toxicological concern),

through a registration program.

Requires manufacturers to obtain approval from

EPA (which may require submission of test data)

before producing new chemicals that may pose

an unreasonable risk to human health or the

environment.

Regulates allowable pesticide residues in food, as

well as the formulation of various solventcontaining cosmetic products.

Regulate the use of hazardous substances in

consumer products.

Encourages manufacturers to avoid use of

EPA

EPA

EPA

EPA

EPA

EPA

FDA

CPSC

OSHA

materials or processes that might expose

workers to hazardous substances in the

workplace.

KEY: CPSC-Consumer Product Safety Commission; EPA—Environmental Protection Agency; FDA—Foodand Drug Administration; OS HA-Occupational

Safety and Health Administration.

SOURCE: Kerr and Associates, “Effect of Environmental Statutory/Regulatory Requirements on Product Formulatiorr/Process Design: Information on

Solvents, Agricultural Chemicals, Products Containing Heavy Metals, and Related Household Cleaning Products,” a contractor report prepared for

the Office of Technology Assessment, April 1992.

recycling of hazardous wastes more costly than

disposing of them ,

6 and the failure of RCRA

regulations to distinguish between high-risk and

low-risk chemicals and waste streams. 7 OTA did not

attempt to evaluate these claims in this study, but

Congress may wish to initiate further research in this

area.

Several recent initiatives could help to remove

some of the barriers to green design that exist in

current Federal rules and regulations. In October

1991, President Bush signed Executive Order 12780,

the Federal Recycling and Procurement Policy,

which requires Federal agencies to increase recycling and waste reduction efforts and to encourage

markets for recovered materials by favoring the

purchase of products with recycled content.8 The

order creates a Federal recycling coordinator and a

Council on Federal Recycling and Procurement. It

also requires each agency to designate its own

recycling coordinator. Recently, the Department of

Defense issued directives emphasizing waste prevention through the acquisition process and through

G See testimony of Herschel Cutler, Institute of Scrap Recycling Industries, before the Subcommittee on Environmental Protection of the Senate

CommitSee on Environment and Public Works, June 5, 1991.

T J-s Bovmd, *’R-: @@of ~ Enviro~en@ Debacle,” Journal of Regulation and SociaZ costs, vOl. 1, No. 2, Jan- 1~1~ P. ST.

s EnVirOn~ntal Qulity 1991, 22nd Annual Report of the Council on Environmental Quality (Washington+ DC: U.S. @vernrnent ~ting Office,

March 1992), p. 113.
Chapter 6--Policy Options and the Challenge of Green Design . 81

military specifications and standards. Some 40,000

military specifications requiring the use of hazardous materials are currently under review.9 10 These

initiatives could help to stimulate market demand for

green products.

State and Local Laws and Regulations

Many State and local governments are also

enacting policies aimed at reducing the environmental impacts of products (table 6-2). These

measures include mandatory industry plans to reduce the use of toxic chemicals, requirements for

industry disclosure of hazardous chemicals in products, and creation of-standard definitions for advertisers’ use of environmental terms such as “recycled." States have also enacted some targeted

product control measures such as recycled content

requirements for newspaper, bans and taxes on

specific packages, mandated manufacturer takeback of batteries, and tax incentives for recycling. In

some cases, these laws regulate products and processes more strictly than do Federal laws. Notable

examples are California’s regulations on auto emissions, permissible volatile organic compound content of products, and labeling requirements for

products containing carcinogens and reproductive

toxics.11

The lack of uniform Federal environmental standards for products is alarming to industry, which fears

having to satisfy different regulations in each

State.1213 This prospect is especially of concern for

products that are distributed through national networks. Companies are faced with the choice of

redesigning products to meet the most stringent

State requirement, or changing their distribution

systems. OTA did not evaluate these concerns in this

study, but Congress may wish to investigate further

the extent to which the diversity of State regulations

may impose unnecessary additional costs on industry, and where Federal intervention maybe appropriate to establish national guidelines for environmental product policy (see section on coordination

and harmonization below).

Market Incentives

Manufacturers already have a number of economic incentives to move toward green design. By

reducing the quantity of materials used in products,

they can reduce their manufacturing costs. This

incentive partially accounts for the trend toward

increasing efficiency of materials use described in

chapter 2. Manufacturer’s waste disposal costs are

also increasing as permitted landfill capacity continues to shrink and waste is shipped greater distances

for disposal. This provides an incentive for waste

prevention and in-process recycling of scrap.

There are also marketing opportunities to gain the

loyalty of environmentally conscious consumers.

Surveys indicate that consumer interest in the

environmental attributes of products is on the rise,

and that a substantial segment is willing to pay a

premium for environmentally sound products.14

Environmental regulations are also creating new

market opportunities for small firms with innovative

environmental technologies.15

Corporate Responses

Manufacturers are responding to these incentives

in many ways. For instance, less toxic substitutes for

heavy metals have been adopted in such products as

inks, paints, plastics, and batteries; the electronics

industry has redesigned its manufacturing processes

to drastically reduce the use of CFCs; and several

companies are redesigning products and packaging

to be lighter, more compostable, or to use recovered

materials. l6 Environmental advertising is now being

used to sell a broad range of products, from gasoline

to fabric softener.17 A growing number of companies

9 Ibid., p. 157.

10 See testiony of David J. Berteau, Principal Deputy Assistant Secretary of Defense (Production and r..OgiStiCS) before the SUbcohttee on

Oversight of Government Management of the Senate Committee on Governmental Affairs, Nov. 8, 1991.

11 See Kerr and Associates, op. cit., footnote 1, and Paul R. Portney, op. cit., footnote 2, P. 282.

12 John HOIUS@ “States Lead on Environment and Industries Compti” The New York Times, Apr. 1, 1991, p. D1.

13 Gary D. Sesser, “Just Who’s in Charge Here?” Across thel?oard, July/August 1991, p. 11.

14 S=, e.g., The Roper @tltimtiorh ‘CO* ‘‘The Environment: Public Attitudes and Individual Behavior,” a study conducted for S.C. Johnson and

Soq Inc., July 1990.

15 -k Fischetti, “Green fitrepreneurs,” Technology Review, April 1992, p. 39.

lb See, e.g., Bruce Smart (cd.), op. cit., footnote 3.

‘7 See, e.g., “Selling Greew” Consumer Reports, October 1991, p. 687.
82 ● Green products by Design: Choices for a Cleaner Environment

Table 6-2—Examples of State or Local Laws Affecting Product Design

Provision State Comments

Packaging

Ban on multilayered aseptic beverage containers.

Ban on polystyrene-foam food packaging.

Ban on the use of toxic heavy metals in packaging.

Volatile organic compounds

Mandatory reductions in VOC content in consumer

products.

Environmental labeling

Regulations on the use of environmental terms,

such as “recyclable” or “recycled.”

Labeling requirements for products that contain

chemicals listed as carcinogenic or causing birth

defects.

Newsprint

Recycled content requirements for newspapers.

Batteries

Limits on mercury in household batteries.

Requirements for manufacturers to take back and

recycle rechargeable batteries.

Requirements for all batteries to be “easily

removable” from products.

Toxic use reduction

Requirements for companies to submit plans for

reducing their use of listed toxic chemicals.

Maine

Minneapolis/St. Paul, MN

and Portland, OR

10 States

California

13 States

California

10 States

4 States

4 States

Connecticut and

New York

5 States

No other States have followed Maine’s example.

These local bans, which have not been enforced,

are giving way to recycling mandates.

These laws are based on model legislation

developed by the Coalition of Northeastern

Governors.

Reductions may require reformulation costing $100,0OO

to $2 million per product.

States vary in the requirements that a product must

meet to qualify for use of environmental terms

and symbols.

The list of chemicals differs substantially from

Federal lists. Products must be labeled even if

listed chemicals are present in trace amounts.

These requirements have driven substantial

industry investment in newsprint recycling

equipment.

Mercury has largely been removed from household

batteries in recent years.

Rechargeable batteries currently contain the toxic

heavy metals nickel and cadmium.

May require significant design changes.

Involves “voluntary” industry goal-setting with

public disclosure of progress toward the goals.

SOURCE: Office of Technology Assessment, 1992.

are participating in waste exchanges, where one

company’s waste becomes another’s raw material.18

Recognizing that customers and government regulators will be paying greater attention to the

environmental attributes of products in the future,

numerous industry trade associations, professional

engineering and design societies, and consortia are

addressing these issues (table 6-3). Activities of

these organizations include programs to promote

“product stewardship” (manufacturer responsibility beyond the factory gate), standards for labeling

of recyclable materials, design concepts for product

disassembly, etc.

The existence of these private organizations does

not necessarily mean that the participating companies have all taken the environmentalists’ agenda to

heart. On the contrary, some are participating for

defensive reasons, to promote the environmental

benefits of current materials and products, or to

lobby against new environmental regulations. Nevertheless, the existence of these programs is evidence that the companies believe that increased

environmental scrutiny of products and processes is

inevitable, and that they are better off taking the

initiative rather than merely reacting. In the future,

these industry organizations could provide useful

forums for information exchange on green design.

Response of Educational Institutions

Although the concept of green design was articulated more than 20 years ago, it has not been

integrated into the education and training of designers, engineers, and business managers. A recent

survey by the EPA’s National Advisory Council on

Environmental Policy and Technology found that

only 10 to 15 of the nearly 400 engineering schools

18 Rodney Ho, “WasteExchanges Help More Companies Bag a Treasure From Another’s Traslq” Wall Street Journal, Aug. 2, 1991, p. A5B.
Table 6-3—industry and Professional Organizations Concerned With Green Design

Organization Activities Comments

Industry Trade Associations and Coalitionsa

American Electronics Association/Task Force on

Design for the Environment

Chemical Manufacturers Association (CMA)

Chemical Specialties Manufacturers Association

(CSMA)

Council on Plastics and Packaging in

the Environment (COPPE)

Global Environmental Management Initiative

(GEMI)

Institute of Scrap Recycling Industries (lSRI)

National Paint and Coatings Association (NPCA)

Society of the Plastics Industry (SPl)/Partnership for

Plastics Progress (PPP)

Vehicle Recycling Partnership (VRP)

HoIds regular meetings to share information on activities in the

member companies, and to develop strategies for green

design.

Initiated the Responsible Care Program, a code of

management practices developing the idea of “product

stewardship,” which extends company responsibility for a

product beyond the factory gate.

Promotes waste prevention activities such as product

reformulation or process modification. Provides

information through brochures and conferences to educate

membership and consumers on proper use, storage,

recycling, and disposal of products.

Promotes waste prevention and recycling of plastic packaging.

Sponsors meetings and provides information on plastic

packaging and solid waste issues.

Promotes a worldwide environmental ethic in business

management. Sponsors conferences examining the

connections between product design, total quality

management, and environmental excellence.

Promotes design for recyclability and removal of hazardous

materials from products

Paint Pollution Prevention Program aims to reduce

environmental impacts of paints through efficient material

utilization, toxic use reduction, and product stewardship.

Promotes plastic recycling programs. Has developed a

labeling system to identify plastics by resin type to facilitate

separation for recycling. Is developing design strategies for

better management of plastics used in durable goods.

Sponsors meetings and funds research on methods to

enhance auto recycling and better management of

materials through better design.

Membership includes the major electronics and

computer companies, as well as representatives

from aerospace and automotive industries.

Membership includes major manufacturers of

chemical products.

Represents companies engaged in the formulation,

manufacture, packaging, marketing, and

distribution of products to households,

institutions, and industries. Membership

includes 80 percent of the domestic aerosol

industry production capacity.

Coalition of plastic resin producers, packaging

manufacturers and users, and trade

associations.

Coalition of 22 leading companies including

chemical and consumer product manufacturers.

Represents 1,800 firms involved in all major

recycled commodities.

National umbrella group for regional paint and

coatings associations.

PPP is a task force representing major companies

in the plastics industry.

Consists of Ford, Chrysler, and General Motors, as

well as materials suppliers, dismantles, and

recyclers.

(continuedon rwdpage)
Table 6-3-industry and Professional Organizations Concerned With Green Design-Continued

Organization Activities Comments

Professional Societies

American Institute of Architects (AIA)

American Institute of Chemical Engineers (AIChE)

Industrial Designers Society of America (IDSA)

Institute of Packaging Professionals (loPP)

Society of Environmental Toxicology and Chemistry

(SETAC)

Society for the Advancement of Material and

Process Engineering (SAMPE); Society of

Plastics Engineers (SPE); American Society of

Mechanical Engineers (ASME); Society of

Automotive Engineers (SAE)

Developing environmentally sound approaches to the design

of buildings. With funding from EPA, is developing an

Environmental Resource Guide, containing environmental

information on building materials and case studies in green

design.

Established the Center for Waste Reduction Technologies,

whose goal is to integrate the design of production facilities

with waste management requirements. The Center is an

umbrella organization to conduct research and education

with funding from government, universities, and industry.

Sponsors conferences on product design and the

environment, and has devoted several issues of its journal

Innovation to discussions of green design.

Issued “Packaging Reduction, Recycling, and Disposal

Guidelines.”

Sponsored meetings to develop a technical framework for

Iife-cycle assessments.

All have sponsored conferences on issues related to green

design.

Professional society representing architects.

Professional society of chemical engineers.

Industry sponsors of the Center include

chemical companies, manufacturers, and

engineering services firms.

Professional society representing industrial

designers.

Organization for packaging professionals for

consumer, industrial, and military products.

Professional society of 2,000 members that

provides a forum on resource use issues for

environmental scientists and engineers from

academia, industry, government, and public

interest groups.

Professional societies representing various

engineering specialties.

a In a~ition t. th~e ~rely industry organizations, there are also several hy~d organizations in which industry groups WO~ together Mth government or eWkOfltTIWltd gKXlpS tO prOfTIOte

environmentally sound business practices. Examples include the Coalition of Northeastern Governors (CO!4EG) Source Reduction Council, which has developed “preferred packaging guidelines,”

and the Conservation Foundation/World Wildlife Fund, which has developed environmental curricula for use in business schools.

SOURCE: Office of Technology Assessment, 1992.
Chapter 6-Policy Options and the Challenge of Green Design .85

in the United States offer significant coursework in

waste prevention.19 The Management Institute of

Environment and Business has estimated that only

about 25 of the 700 schools of management and

business have a course on business and the environment, and none requires the course for graduation.20

This is beginning to change, though: OTA found

that interest in this topic among design, architecture,

engineering, and business schools is high, and

several schools have begun to integrate environmental issues into their curricula (see table 6-4).

This may be an opportune time to inject an

environmental dimension into the educational experience of designers and engineers. Many schools are

reevaluating their curricula in light of growing

criticism that students are not being prepared in the

‘‘best practice’ design techniques used by the most

competitive companies.

21 22 This reevaluation process could provide a window of opportunity to add

environmental courses or projects.

As part of this study, the American Society for

Engineering Education’s Engineering Deans Council conducted an informal survey of Engineering

School Deans on behalf of OTA (see box 6-A).

Fifteen of the twenty respondents indicated that their

institution already offers some sort of environmental

program for students. In most cases, however, these

programs take the form of optional classes on

pollution control or “environmental engineering. ”

Only five respondents reported that they are actively

incorporating environmental concerns into their

standard engineering courses. Lack of funding and

lack of faculty training were cited as significant

barriers to further progress.

These needs are beginning to be addressed by

both Federal and private programs. EPA has funded

the National Pollution Prevention Center at the

University of Michigan, which is developing waste

prevention curriculum materials for colleges and

universities, including modules for industrial design

and engineering design courses.23 The center also

plans to provide information and education to

university faculty through interdepartmental seminars. In another example, the National Wildlife

Federation’s Corporate Conservation Council has

sponsored a pilot program to introduce environmental issues into business school education.24 25

Information Resources Available

A variety of information resources relevant to

green design are becoming available. These include

books that offer general guidelines for green design, 26 as well as information more appropriate for

specific industries and manufacturing processes.27

Experimental computer programs are being developed to assist designers in evaluating their choices

according to life-cycle criteria.28 Information is also

available on a variety of related topics, such as how

to evaluate design decisions by total cost assessment

29 and how to conduct materials balance

assessments and waste stream audits.30 31

Electronic Networks

Electronic networks can provide useful forums for

information exchange among those interested in

19 ~~ony D. Cortese, “Education for an Environmentally Sustainable Future,” Environmental Science and Technology, vol. 26, No. 6, 1992, p.

1108.

m Ibid.

21 Joti Il. ‘Dixo~ “New Goals for Engineering Education,” Mechanical Engineering, March 1991, p. 56.

22 Natio~ Resemch Council, Improving Engineering Design: Designing for Competitz”ve Mvantage (Wash@to% DC: Natiomd ~d~y Mess,

1991), p. 35.

23 Environmen~ Protection Agency, “Pollution Prevention Resources and Training Opportunities in 1992,” EPA/560/8-92-(X12, January 1992, p.

94.

~ J-es E. POS~ “The Greening of Management, ’ Issues in Science and Technology, summer 1990, p. 68.

25 At ~~ ~fig, tie ~uwtion and ~qcommitt~ of ~A’s Natio~ Adviso~ Councfl for Environmen~ Po1.icy ~d Technology W=

completing work on a national strategy to encourage waste prevention education and training.

~ See, e.g., Doro~y Mackenzie, DesigII for the Environment (New York, NY: Rizzoli, 1991), ~d refmences cited herein.

27 Environmen~ Protection Agency, “Pollution Prevention Resources and Training Opportunities in 1992,” op. cit., footnote 23, p. 13.

~ me sof~=e, c~led Simapro, is available flom PR6 Consultants, Amersfoor4 The Netherlands.

29 Env~onmen@ Protection Agency, “Total Cost Assessment: Accelerating Industrial Pollution kevention Through Innovative Project Financial

Analysis,” a report prepared by Tellus Institute, Bostou MA, May 1992.

~ Envfionmen~ Protection Agency, “Facility Pollution Pnxention Guide,” EPA/600/R-92/088, May 1992.

31 ~wen Kenwofiy ~d E1.ic &-~ffw, “A Citizen’s Guide to ~omofig ~fic waste Reductioq” published by hlfO~ rIIC., 1990.
86 ● Green Products@ Design: Choices for a Cleaner Environment

Table 6-4-Environmental Education Programs in Design, Engineering, and Business Schools

Institution Activity

Boston University

Carnegie Mellon University

Grand Valley State University

Loyola University

Massachusetts Institute of Technology

Rhode Island School of Design

Tufts University

University of the Arts (Philadelphia)

University of California at Los Angeles

University of Miohigan

University of Minnesota

University of Rhode Island

University of Wisconsin

Offers graduate business courses on managing environmental issues.

A variety of courses and seminars are being developed around the idea of design for the

environment, involving the Center for Solid Waste Management Research, the

Environmental Institute, and the Engineering Design Research Center.

The Waste Reduction and Management Program is developing engineering curricular

materials on green design and provides seminars for engineers and faculty on “cutting

edge” design approaches.

Offers graduate business courses on managing environmental issues.

The Technology, Business, and the Environment Group offers workshops and seminars

for engineers and managers, and works to integrate waste prevention concepts into

undergraduate and graduate courses.

Incorporates environmental concerns into the industrial design curriculum through course

material and projects.

The Tufts Environmental Literacy Institute seeks to incorporate environmental concerns

throughout the curriculum; the Center for Environmental Management provides

education and training programs for engineering students.

Incorporates environmental concerns into industrial design curriculum through course

material and class projects.

Integrates environmental concerns throughout engineering disciplines through problem

sets and projects.

The Pollution Prevention Center for Curriculum Development and Dissemination is

developing curriculum modules for undergraduate and graduate courses in

engineering, business, and science. Summer workshops and seminars are also

offered.

Offers graduate business courses on managing environmental issues.

Students in the Chemical Engineering Department evaluate waste prevention

opportunities for Rhode Island firms.

The Engineering Professional Development Program offers short courses to engineering

students on waste prevention and green design.

SOURCE: Offlcs of Technology Assessment, 1992.

green product design. One existing governmentfunded network is EPA’s Pollution Prevention

Information Exchange (PIES), which is part of the

Pollution Prevention Information Clearinghouse.32

PIES contains bibliographic materials, industry case

studies, announcements, and an electronic bulletin

board that allows users to send messages to one

another. Although PIES was not organized specifically with the needs of designers in mind, it contains

a considerable amount of relevant information, and

in the future it could be expanded to include

comparative environmental information on alternative materials, substitutes for toxic chemicals, etc.

Consumer Information

One of the most powerful determinants of product

design is consumer preference. Yet unless consumers are able to recognize green products in the store,

this potentially powerful incentive for green design

is neutralized. To fill this need, several ‘‘green

consumer guides’ have become available in recent

years,

33 though some of the recommendations in

these guides have been controversial.34

It is especially important to reach the-next

generation of consumers early. As authorized by the

National Environmental Education Act of 1990,

32 fiv~nmen~ ~t~tion Agency, “Pollution Prevention Resources and Training Opportunities in 1992,” op. cit., footnote 23, p. 100.

33 See, e.g., Joel Makower, John Elkingtou and Julia Hades, The Green Consumer, Penguin Books, New York 1990; The -works ~oup, 5~

Simple Things You Canllo To Save fhe Z3arfh (Berkeley, CA: Earthworks Press, 1989); Debra Lynn Dadd, “Nontoxic and Natural,” Jeremy P. Thrcher,

Jms Angeles, 1984.

34 WA ~~&ew copi~ of its publication “The Environmental CO nsumer’s Handbook” (EPA/530-SW-9(L034B, October, 1990) after industry

protested the implication in the report that disposable or multi-material products are environmentally less desirable.
Chapter 6--Policy Options and the Challenge of Green Design .87

Box 6-A--Survey of Engineering School Deans

On behalf of OTA, the American Society for Engineering Education’s Engineering Deans Council undertook

a survey of the views of Engineering Deans regarding the need to integrate environmentalconcerns into engineering

school curricula. Of the 20 respondents, 17 considered such integration to be very important, and 16 believed that

environmental courses or program would help attract new engineering students.

when the Deans were asked to comment on how their institutions were addressing this issue, 15 cited some

form of ongoing environmental program, and several more citedprograms being planned. The most common

approach was to offer optional courses on environmental topics within chemical, mechanical, or civil engineering

programs (11 schools). Seven schools reported that new majors or degree programs were being developed (typically

in ‘‘Environmental Engineering’ ‘). Only 5 schools indicated that they are integrating environmental concerns into

their standard engineering courses through modules, projects, or problem sets.

The Deans were also asked to comment on what barriers exist to incorporating a stronger environmental

perspective into engineering programs. The two most frequently cited responses were the lack of money and the

availability of appropriately trained faculty (each cited by five respondents). Other answers included a lack of course

materials, and a curriculum already crammed with other topics.

When asked what the Federal Government could do to help engineering schools incorporate environmental

concerns into engineering education and research, 10 of the respondents indicated that more Federal funding was

necessary (research funds, scholarships, training). Seven indicated that Federal assistance with curriculum

development, course development, or new program would be beneficial. Other suggestions included having the

Federal Government increase national awareness and concern regarding green design, to establish new research

centers through the National Science Foundation, to create a competitive award to highlight work in this area, and

to identify more clearly the Nation’s most pressing environmental problems.

SOURCE: ASEE Engineering Deans council survey for OTA.

EPA has established an Office of Environmental underway with the American Institute of Architects

Education to

. . . foster an enhanced environmental ethic in society

by improving the environmental literacy of our

youth and increasing the public’s awareness of

environmental problems.

The primary focus will be on grade levels K-12. EPA

has also established an agencywide National Pollution Prevention Environmental Education Task Force

to develop educational materials for students and

teachers in grades K-12.35

Ongoing Activities

Finally, OTA identified a number of ongoing

Federal activities that will provide additional information for designers in the near future (table 6-5).

EPA is the agency most directly involved; for

example, EPA’s Office of Research and Development is supporting the development of a Life Cycle

Design Guidance Manual, which is intended to

explore how designers can incorporate life cycle

assessment into their designs. EPA also has a project

to develop an Environmental Resource Guide, to

assist architects in making environmentally sound

choices of construction materials. Table 6-5 also

identifies several relevant projects in other agencies,

including the Department of Energy and the National Science Foundation.

In the Pollution Prevention Act of 1990, Congress

required that manufacturers who report their releases

of toxic chemicals for the TRI must also report how

these releases were affected by waste prevention

activities, including product and process redesign.

When these data become available (probably some

time in 1993), they could provide valuable insight

into an area where little information currently exists:

how product design choices affect industrial waste

streams.

CONGRESSIONAL ROLE

These ongoing activities suggest that green design

is a concept that is gathering momentum. Even if

Congress takes no further action, the incentives

35 Environmental Protection Agency, Pollution Prevention Resources and Training Opportunities in 1992, op. cit., footnote 23, p. 95. See also

Environmental Protection Agency, “Environmental Education Materials for Teachers and Young People (Grades K-12),” 21K-1OO9, July 1991.
Table 6-5-Federally Funded Programs Related to Green Design

Agency/Office Program/activity

Department of Energy

Office of Industrial Technologies Industrial Waste Reduction Program

Environmental Protection Agency

Office of Research and Development Environmental Resource Guide

Life Cycle Assessment Methodology

Clean Products Case Studies

Safe Substitutes

Life Cycle Design Guidance Manual:

Environmental Requirements and

the Product System

National Pollution Prevention Center

American Institute for Pollution

Prevention

Office of Pollution Prevention and Design for the Environment

Toxics

National Science Foundation Engineering Design Research Center

Comments

A research and development program to identify priority industrial waste streams,

assess opportunities for addressing these waste streams through redesigning

products and production processes, and assess technology transfer from

national laboratories.

Contracted to the American Institute of Architects, this project will provide

information to architects on the life cycle environmental impacts of construction

materials.

Contracted to Battelle and Franklin Associates, Ltd., this project will develop

standard methodologies for conducting product life-cycle assessments.

Contracted to IN FORM inc., this project will provide case studies of green design,

especially the reduced use of toxic substances in products.

Contracted to the University of Tennessee, this project will identify priority toxic

chemicals and evaluate possible substitutes.

Contracted to the University of Michigan, this manual will explore how designers

can incorporate life-cycle information in their designs.

Located at the University of Michigan, this center is developing waste prevention

information modules for industrial and engineering design courses.

in association with the University of Cincinnati, the institute serves as a liaison to a

broad cross-section of industry, with projects involving four aspects of waste

prevention: education, economics, implementation, and technology.

Scheduledtobe launched in September 1992, this program will gather, coordinate,

and disseminate information on green design.

Located at Carnegie Mellon University, the center is organizing a program to

explore methods for green design.

SOURCE: Office of T~nology Assessment, 1992.
Chapter 4-Policy Options and the Challenge of Green Design . 89

discussed above can be expected to continue in the

future. Implementation of tougher emissions standards under the Clean Air Act Amendments of 1990

will increase pressures on companies to reduce their

use of hazardous solvents and other volatile organic

compounds. New regulations requiring liners and

leachate collection systems in landfill construction

will increase the costs of solid waste disposal and

provide increased incentives for waste prevention.36

Various States will no doubt continue to pass

legislation to regulate the environmental attributes

of products and waste streams. And as consumers

become more attuned to environmental concerns,

they will increasingly demand that manufacturers

take more responsibility for the environmental

impacts of their products.

Despite these incentives, though, OTA finds there

are four areas where congressional action is needed

to maintain existing momentum and foster further

progress:

●

●

●

●

Research. At present, designers and policymakers

don’t know what materials or waste streams are

of greatest concern, or how product designs

might be changed to address them most effectively. Private companies have little incentive

to conduct this research.

Credible information for consumers. Surveys

show that consumers are interested in green

products, but most don’t know what is ‘green.”

As discussed in chapters 3 and 4, defining

what’s green is a multidimensional problem. In

the absence of Federal action to establish

consistent ground rules defining terms and

measurement methods, the growing interest of

consumers could become dissipated in confusion and skepticism.

Market distortions and environmental externalities. Most observers agree that the prices of

materials and energy do not reflect their true

environmental costs. Failure to internalize these

environmental costs into design and production

decisions can make environmentally sound

choices seem economically unattractive. Further, they argue that some government policies,

such as subsidies for the extraction of virgin

materials, also distort prices.

Coordination and harmonization. OTA found

that several research projects related to green

design are being sponsored by various Federal

agencies and offices (table 6-5), but that there

is little or no coordination among them. And

unlike its major competitors, the United States

has no institutional focus at the Federal level

for addressing environmental product policy

(see chapter 5).

These issues are discussed in greater detail below,

and options for addressing them are presented. The

chapter concludes with a short list of relatively quick

and inexpensive options Congress could choose to

encourage green design.

RESEARCH NEEDS

To take full advantage of the potential of green

design, both designers and policymakers need more

information about where the major opportunities lie

and the most cost-effective ways of addressing them.

This information must be developed through research. Below, OTA discusses research needs in two

categories: technical research and applied social

science research. In this study, OTA has made no

attempt to evaluate how much additional funding

may be necessary to fully address these needs.

Technical Research

Setting Priorities Based on Risk

Beyond certain obvious imperatives such as

avoiding the use of CFCs, designers and policymakers have little information as to what materials and waste streams pose the greatest health and

environmental risks. Current lists of hazardous

substances subject to various State and Federal

regulations contain hundreds of chemicals, each

having different uses and posing different risks to

health and the environment.

Several research efforts funded by the Department

of Energy (DOE) and EPA are attempting to identify

priority products and waste streams (see table 6-5).

Congress could require EPA and DOE to jointly

identify a short list of products and production

processes that appear to pose the greatest health

and environmental risks. This would be consistent

with EPA’s stated goal of reevaluating its priorities

~ EPA’s fdtie spec~g minimum Federal criteria for municipal solid waste landfill design was published in the Federal Register, vol. 56, No.

196, Oct. 9, 1991, and becomes effective on October 9, 1993.
90 ● Green Products by Design: Choices for a Cleaner Environment

based on riskassessment.3738 In the case of chemicals, a possible starting point might be the list of 17

categories of chemicals that EPA has targeted in its

33/50 Program.39 Armed with this information,

designers can find appropriate substitutes and avoid

dissipative uses of these materials.

Safe Substitutes

To reduce overall environmental risks, the risk

tradeoffs of switching from one chemical to another

must be understood. Currently, designers may be

substituting regulated chemicals of relatively known

risk with unregulated chemicals of unknown risk.

The assumption is often made that the new chemicals are safer, but this may not be the case. Although

the Toxic Substances Control Act of 1976 requires

EPA to consider the net risk of chemical substitution

in regulating chemicals, most chemicals have been

tested on a one-at-a-time basis.40 Congress could

direct EPA to evaluate the risks of the priority

chemicals in “use clusters”—groups of chemicals that can substitute for one another (e.g.,

solvents or coolants) .41 This comparative information could then be made available to designers

through such mechanisms as EPA’s Pollution Prevention Information Exchange.

Understanding Materials Flows

Policymakers need better models of how various

materials and wastes of concern flow through the

economy and into the environment. These models

can help identify the major sources of environmental

pollutants and the most cost-effective ways of

reducing them. Without this information, resources

may be diverted to address the most visible problems, rather than the most serious ones. For instance,

10 States have banned the use of toxic heavy metals

in packaging, yet this source contributes only a few

percent of heavy metals in landfills and incinerators. 42 43 As another example, there has been

considerable concern expressed about the release of

mercury from the incineration of municipal solid

waste, yet these releases may be small compared

with mercury releases from coal combustion in

power plants.44

These examples underline the need for detailed

“materials balance” analyses that quantitatively

track materials of special concern through initial

production, use in industrial processes and products,

and disposal.45 Preliminary materials balance studies have been carried out for several hazardous

substances, % 47 but a more systematic approach is

needed. For the short list of high-risk materials

identified above, Congress could direct EPA and

ql’ W~am Reilly, ‘6-~Toward 2000: Re_tie Nation’s Environmental Agen@” EnvironmentaZLuw, VO1. 21, No. 4, 1991, p. 1359.

For a discussion of the limitations of risk reduction as a strategy for the future, see also John Atcheson, “The Department of Risk Reduction or Risky

Business,” ibid., p. 1375.

38 T=~Wes for ev~ua~ env~wm~ ~s~sti~ evolving. ~A’s Risk As=ssment Fo~ is spoIIsoring SCVA case studies that could help

to establish a framework for ecological risk assessment. Preliminmy results are expected in 1994. See “Environmental Agency Launches a Study in

Ecological Risk Assessment,” Science, Mar. 20, 1992, p. 1499.

39 me ~o~s of tie 33/50 fiog~ ~ t. ~~uce industly rel~s of tie 17 ~get chemi~s 33 p~ent by 1993 and S(I percent by 1W5,- on

1988 levels. In selecting these chemicals, EPA started with the list of 322 TRl chemicals and employed a screening process based on volume of

productio~ volume of releases, and hazardous properties. See Environmental Protection Agency, “Pollution Prevention Resources and Thin@

Opportunities in 1992,” op. cit., footnote 23, p. 84.

a Michael Shapiro, “1’bxic Substances Policy, ‘‘ in Paul R. Portney, op. cit., footnote 2, p. 224.

41 EpI$s ~lw of po~utionfimmtion and ~fics~anno~c~ plans to -ploy me “use clust~” concept forev~~ting substitutes for hazardous

chemicals in the future. Jean E. Parker, Gfflce of Pollution Prevention and ‘Ibxics, personrd communication August 1992.

42 ~ae kws are based on model legislation developed by the Source Reduction Council of the Coalition of Northmt- Governors (CONEG).

43 me dominant sowce of lead and cadmium in mticipal solid waste is in batteries, especially lead-acid automobile batteries. Some 38 StatCS now

have laws regulating the disposal of batteries. Another major source is cmsurner electronics, whose disposal is generally not regulated. See Franklin

Associates, Ltd., “Characterizationof Products Containing Lead and Cadmium in Municipal Solid Waste in the United States, 1970-2000,” a report

prepared for the Environmental protection Agency, January 1989.

44 ~cor~ t. one ~~te, about 65 percent of anthropogenic mercury emissions to the atmosphere is due to COal bd

is due to waste incineration. F. Slemr and E. Langer,

g, and anoticr25 pement

“Increase in Global Atmospheric Concentrations of Mercwy Inferred From Measurements Over

the Atlantic Ocean,” Nafure, vol. 355, Jan. 30, 1992, p. 436.

45 TMS is not a nw ideq but it has nevm been pursued systematically. See Allen V. ICneese, Robert U. Ayrtx, and Wph C. d’~ge, “fionom.im

and the Environment: A Materials Balance Approach” a monograph published by Resources for the Future, Washington, DC, 1970.

~ R.U. Aps et al., “Industrial Metaboli~ the Environment, and Application of Materials-Balance Principles for Selected Chemicals,”

International Institute for Applied Systems Analysis, RR-89-11, Laxenburg, Austr@ 1989.

47 Da~d T. ~em ~~wwtes as ~~ ~te~,~t pre~nted at he Natio~ Academy of sci~~swor~op on kdusw ECology/DCsigIl fOr thC

Environment, Woods Hole, ~ July 16, 1992.
Chapter 6--Policy Options and the Challenge of Green Design ● 91

DOE to conduct detailed materials balance studies showing how these materials flow through the

economy and into the environment.

A significant barrier to better modeling of materials flows is the quality of data on industrial waste

streams. More than 20 national sources of data are

available (e.g., the TRI, or the biennial survey of

hazardous waste generators required by RCRA).48

These databases, which were established for different purposes, cover different waste generators, waste

types, and time periods. This makes it difficult to get

a coherent picture of materials flows, whether one is

interested in tracking specific materials or the

performance of specific industrial sectors. Congress

could direct EPA, DOE, and the Department of

Commerce (DOC) to jointly explore how existing

waste stream reporting requirements might be

harmonized to provide a more coherent picture

of waste flows.49

A Scientific Basis for

Better Materials Management

OTA found few examples of research relating to

better materials management at the Federal level.

Instead, most Federal research projects relating to

green design appear to be oriented toward preventing the release of toxic or hazardous materials (see,

for instance, table 6-5). This is also reflected in the

solid waste dichotomy defined by RCRA, in which

‘‘hazardous’ solid waste is regulated by the Federal

Government, while responsibility for “nonhazardous’ solid waste management is delegated to

the States.

To improve the connectivity between product

design and waste management, Congress could

establish a grant program for joint research and

demonstration projects having both a design

component (e.g., to develop principles of design

for remanufacturing, disassembly, compostability, etc.) and a waste management component

(e.g., to develop improved recycling, comporting,

and incineration technologies). Examples of the

fruits of this research might be adhesives, paints, or

coatings that do not inhibit recycling processes;

mixed materials that can be co-recycled without

sacrificing the properties of the finished product; or

materials that generate fewer toxic residues when

incinerated. Materials derived from biological sources

are another important category; this could lead to a

class of renewable materials that might be extremely

durable or fully biodegradable.

One mechanism for funding such joint projects

may be the National Science Foundation’s Engineering Research Centers.50 Another avenue maybe

the Advanced Materials and Processing Program, an

interagency materials research initiative for materi-

als science and engineering announced by President

Bush in 1992.51

Applied Social Science Research

A 1990 National Research Council workshop

concluded that EPA’s waste reduction research

program emphasizes technical issues to the exclusion of applied social science research. 52 T h e

workshop participants singled out three categories

of special need: measurement techniques for evaluating progress, institutional and behavioral barriers,

and the need for more analysis of policy incentives.

OTA finds that these same research needs apply to

green design, as discussed below.

Measurement Techniques

Measuring what is “green” is one of the most

difficult challenges facing designers and policymakers.

Designers must have targets for weight reduction,

and substitution for toxic chemicals. Public interest

groups need criteria against which to evaluate

industry progress, and companies need criteria to be

able to claim credit for legitimate environmental

improvements.

4s JackEise~uer and Richard Cordes, “Industrial Waste Databases: A Simple Roadmap,’ Hazardous Waste andHazardoush4aterials, vol. 9, No.

1, 1992, p. 1.

49 Preliminary work along these lines is currently being funded by the Department of Energy’s OffIce of Industrial Technologies. See Alan Schroeder,

“Industrial Waste Sources in the U. S.A.,“ in the Proceedings of Global Pollution Preventio~’91, Waahingto~ DC, Apr. 3-5, 1991, p. 229.

50 The Engineering Design R~~ch center at c~egie Mellon university is developing ~ indm~ cOIISOrdlllll interested in @P1oriW pficiples

of design for disassembly and recycling.

51 WA ~ proposed a projat on Environmen~y Benign Materials and Processes as paxt of the f~cal year 1993 enhancements to the Advmcd

Materials Processing Program. See ‘‘Advanced Materials and Processing: the Fiscal Year 1993 Progr~” a report by the Federal Coordinating Council

for Science, Engineering, and Technology’s Committee on Industry and Technology, Office of Science and Technology Policy, April 1992.

52 Natio~ResewchCoUcil, co~tt= onoppo~ties in Applied Enviro~en~Res~ch ~dDevelopment, WasteReduction: Research Need

in Applied Social Sciences, a Workshop Report (Washingto& DC: National Academy Press, 1990).
92 ● Green Products by Design: Choices for a Cleaner Environment

As discussed in chapter 4, green design always

involves making tradeoffs. In principle, a comprehensive life-cycle analysis (LCA) of a product or

process can indicate how to make these tradeoffs.53

A challenge for the future is to develop streamlined

LCA methods that focus on a few critical parameters. It may also be possible to develop narrower

design rules of thumb or “green indicators’ for use

by designers for specific products or facilities (e.g.,

a tire design might be evaluated based on its

expected service life divided by its weight) .54 These

green indicators would be expected to vary for

different products.

A central measurement issue for policymakers is

how to measure the waste prevention attributes of a

product. Whereas recycling rates or recycled content

are relatively easy to measure, quantifying waste

prevention is notoriously difficult.5556 Yet if waste

prevention is indeed preferred to recycling in the

solid waste management “hierarchy,” as stated

both by EPA and by Congress in the Pollution

Prevention Act of 1990, it is important that

mechanisms be found to credit waste prevention

in government procurement programs and legislation that aim to increase recycling rates.

Finally, to support system-oriented product design (see chapter 4), new macro-level metrics will be

required that can characterize the environmental

performance of alternative production and consumption systems (e.g., alternative ways of providing the

same service), rather than just alternative products.

Suggestions for such metrics include dematerialization (reductions in the weight of materials used to

provide a given level of goods and services),

decarbonization (reduction in the quantity of fossil

fuels consumed to provide a given level of goods and

services), and input-output analysis of production

systems, accounting for both products and waste

streams.57

Many of these measurement issues are controversial, and are probably best addressed through a

consensus-building process involving government,

industry, universities, and public interest groups.

Congress could provide funding to EPA to

convene a series of consensus-building workshops involving all interested stakeholders to

resolve these measurement issues.58

Institutional and Behavioral Research

To explore the full potential of green design, a

better understanding is needed of how companies

manage the design function and how design decisions vis-a-vis the environment are affected by such

factors as type of product, company size, and

corporate culture. For example, barriers to green

design arise from cost accounting procedures59 and

other institutional or behavioral factors. Research is

also needed to understand how companies shape and

are shaped by customer needs. In particular, this

research could include how individual consumers

and large-volume commercial buyers view environmental risks and make decisions to purchase environmentally preferred products (see below).

Congress could provide funding through EPA,

the National Science Foundation (NSF), or the

National Institute for Standards and Technology

(NIST) for a series of industry case studies to

analyze how institutional and behavioral factors

influence design decisions vis-a-vis the environment in a variety of industry settings (including

53 See the upcoming report, “Product Life-Cycle Assessment: Inventory Guidelines and Mciples, ’ a study prepared for EPA’s OffIce of Reseamh

and Development by Battelle and Franklin Associates, Ltd.

54 D. Navinc~n&a, ‘JDesiWfor Environmen@bfli~,~ in proceedings o~theAsMEDe~ign Theo~andMethodology Conference, AIIlelkWISOCiety

of Mechanical Engineers, Miami, FL, 1991.

55 U.S. ConWess, OffiW of Technolo~ Assessmen~ Serious Reduction of Hazardous Waste: For pollution prevention and Industrial Eflciency,

OTA-ITE-317 (Washingto~ DC: U.S. Government Printing OffIce, September 1986), p. 124.

56 For fi~ce, sho~d Prevmtion be mem~ by Compfison with other comp~able products, or by comparison with the same product hl SOme

previous base year? Using a base year as a standard of measurement may discriminate against companies that had already made si@lcant reductions

in product weight or toxicity before the base year, and reward those who did not.

57 See Jesse H. Ausubel, ‘Industrial Ecology: Reflections On a Colloquium, ” Proceedings of the National Academy of Sciences, vol. 89, February

1992, p. 879; and Faye Duchin, “Industrial Input-Output Anrdysis: Implications for Industrial Ecology,” p. 851 in the same volume.

58 One exmple is the ‘‘Pellston-~e” workshop organized by the Society of Environmental Toxicology and Chemistry ifl Au@st 1990 to develop

guidelines for li.bcycle assessment methodology. See Society of Environmental Toxicology and Chemistry, “A Technical Framework for Life-Cycle

Assessment,” a workshop repo~ Washingto~ DC, January 1991.

59 Areviewof themleof environmen~ factorsin traditional cost accounting systems isprovidedby Rebecca Todd, ‘cAccountingfor tie Environmmt:

Zero-Loss Environmental Accounting Systems,” presented at the National Academy of Engineering’s Workshop on Industrial Ecology/Design for the

Environment, Woods Hole, MA, July 13-17, 1992.
.

Chapter 6--Policy Options and the Challenge of Green Design ● 93

both industrial and engineering design). These

case studies could provide excellent course materials for business schools and design schools.

Policy Research

Although many policy options have been suggested to control the environmental impacts of

products, little is known about the costs and benefits

of these options--especially the costs of monitoring

and enforcement. In Germany, for example, requirements for manufacturers to take responsibility for

recovering and recycling their packages appear to

have been passed with little cost-benefit analysis.60

Yet the costs may vary greatly depending upon the

kind of product, its distribution network, and the

waste management infrastructure. Congress could

require that EPA identify some of the more

promising proposals being discussed around the

world and analyze their likely costs and benefits.

As indicated at the beginning of this chapter, the

existing regime of environmental regulations, Federal and State procurement policies, and military

specifications already have a profound influence on

design decisions. A useful starting point might be

for Congress to direct EPA to coordinate a

comprehensive review of how existing Federal

and State regulations affect materials management decisions in the United States. This could

help consolidate reviews already ongoing in various

agencies and provide a basis for government-wide

administrative changes.

As shown in table 6-2, many States have initiated

innovative programs to control the health and

environmental impacts of products, including taxes

on hard-to-dispose products, labeling requirements,

and outright bans (e.g., Maine’s ban on aseptic

beverage containers). As these State programs

develop, Congress could direct EPA to evaluate

their results. Congress may also wish to have

EPA investigate the extent to which compliance

with the growing diversity of State environmental

initiatives is imposing a serious financial burden

on industry, with a view toward identifying areas

where national standards are desirable.

CREDIBLE INFORMATION

FOR CONSUMERS

The second unique role that the Federal Government can play in supporting green design is to ensure

that consumers have reliable information about the

environmental attributes of products, and to ensure

that its own procurement of goods and services is

consistent with environmental concerns. A significant fraction of consumers prefer to buy environmentally sound products,61 and manufacturers are

responding by touting the environmental benefits of

their products, using terms like “recyclable,” “biodegradable,” and “ozone-safe."62 63 But becaus e

the impacts of products on the environment are

complex and multidimensional, there is tremendous

potential for consumers to be confused by these

diverse environmental claims.64 In principle, LCA

techniques can be used to determine the overall

environmental quality of a product, but these techniques are still at an early stage of development, and

it seems unlikely that definitive LCA results will be

available for most products in the foreseeable future.

In general, two kinds of customers can be

distinguished: individual consumers, and largevolume buyers for commercial firms, institutions, or

government agencies. Options to address the information needs of these two groups are discussed

below.

Individual Consumers

Environmental Advertising Claims

There is now a broad consensus on the part of

industry, States, and environmental groups that

Federal standards or guidelines of some sort are

needed to regulate environmental advertising.65

Industry wants national guidelines that prevent

@SW “EnViromnen~sm Runs Riot,” The Economist, Aug. 8, 1992, P. 11.

61 k~or~ to a survey conducted in 1990 by the Roper mgtition for S.C. Johnson and Son (op. cit., footnote 14), 29 percent of participants

reported purchasing a product beeause advertising or labeling said the product was environmentally safe.

62 “Selling Green,” Consumer Reports, op. cit., footnote 17.

63 ~cor~ t. one SWW, 26 ~rcent of tie 12,000 new household items launched in 1990 made some environm~ti claim. See Jaclyn FiermaU

“The Big Muddle in Green Marketing,” Fortune, June 3, 1991, p. 91.

64 A Smey by Rnv~omen@ Research &S~iates of princeto~ NJ found that 47 percent of consumers dismiss environmental claims as ‘‘mere

gimmickry.” Jaclyn Fierma~ ibid.

a For a good overview of the issues, see Ciannat M. Hewett, “The ‘Green Labeling’ Phenomenorx Problems and Tnmds in the Regulation of

Environmental Marketing Claims,’ Virgini”a Environmental Law Journal, vol. 11, spring 1992, p. 401.
94 ● Green Products by Design: Choices for a Cleaner Environment

deceptive claims and bring more uniformity to the

current patchwork of State environmental labeling

regulations. 66 However, industry generally opposes

any regulations that would go beyond requirements

for factual and verifiable statements about environmental attributes. Environmental groups want to

establish a‘ ‘floor’ of Federal standards for advertisers’ use of environmental terms that can be exceeded

by States desiring to impose higher standards.67 The

underlying debate is between those who would treat

environmental claims in the same way as any other

form of advertising, and those who see it as a public

policy tool for changing the behavior of manufacturers and consumers.68

In May 1991, a task force of 11 State attorneys

general called for Federal standards for environmental advertising and recommended interim guidelines for use by manufacturers.69 The task force

recommended that environmental claims be as

specific as possible, substantive (not trivial or

irrelevant), and reflect current waste management

options.

Also in May 1991, the Federal Trade Commission

(FTC) published proposed guidelines for environmental advertising and held hearings in July to

receive public comment. EPA published proposed

guidelines for use of the terms “recyclable” and

“recycled’ and the use of the recycling emblem,70

which industry critics charge go well beyond preventing deception. The FTC also joined with EPA

and the U.S. Office of Consumer Affairs to form the

Federal Interagency Task Force on Environmental

Labeling, to coordinate Federal efforts.

In July 1992, the FTC issued final guidelines for

environmental marketing claims.71 The guidelines

are intended to prevent deceptive environmental

advertising, and are based on the principles that

claims of environmental benefits must be factual and

verifiable. The guidelines are not intended to

preempt State regulation of environmental advertising claims.

These FTC guidelines are an important step,

especially because they encourage manufacturers to

qualify broad claims of environmental benefits so as

to be specific and verifiable. But Congress may wish

to go beyond preventing deception; even if a claim

is not overtly deceptive, it still may not convey

sufficient information to enable consumers to evaluate the environmental benefits of the product or

package. One criticism of FTC guidelines is that

they do not provide standard definitions of environmental terms based on scientific criteria.72 Critics

argue that in any case, the FTC does not have the

scientific expertise to evaluate such claims, and that

the technical expertise of EPA is needed to develop

credible scientific definitions.73 Congress could

require that EPA work with the FTC to develop

"official" definitions of environmental terms

based on the best scientific information available.

In OTA’s view, it is especially important to decide

how terms relating to waste prevention (e.g., “sourcereduced”) should be defined and communicated to

consumers.

Another criticism of the FTC guidelines is that

they do not challenge manufacturers to make continuous improvements in order to be able to claim

environmental benefits. Congress could require

EPA to develop minimum standards for unrestricted use of environmental terms in advertising. For example, a product labeled as “recycled”

might have to contain at least 10 percent postconsumer material.74 These minimum standards

could then be ratcheted up over time.

66 ~ tie absence of Fedtird standards, some 13 States have developed their own regulations on the Use Of environmental t-s.

67 S=, e.g., tes~ony of tie Envi.ronrnen~ Defmse Fund on environmental labeling and S. 615 before the SUbCOmmitiw on Envifonmenti

Protection of the Senate Committee on Environment and Public Works, July 31, 1991.

6s Ctiet M. Hewett, op. cit., footnote 65, p. 460.

@ “The Green Report II: Recommendations for Responsible Environmental Advertising,” May 1991.

TO ~viromen~ Protection Agency, “Guidance for the Use of the Terms ‘Recycled’ and ‘Recyclable’ and the Recycling Emblem in Environmental

Marketing Claims,” FederaZRegister, vol. 56, No. 191, Oct. 2, 1991, p. 49992.

71 Fede~ Trade Commission, “Guides for the Use of Environmental Marketing Claims,” July 1992.

~ For e~ple, a ~rm~ “dcgratiblc” might be defined differently by different manufacturers, giving consumers little information about tie tie

of degradation or the nature of the end products.

73 ~viromen~ Defense Fund, op. cit., footnote 67.

74 ~is me deffition of “rewcl~$~ tit ~5 hen adopt~ ~ c~ifor~o EPA is SW- comm~t on a si.mi~ propos~. &X EPA Guidelines, Op.

cit., footnote 70.
Chapter 6--Policy Options and the Challenge of Green Design .95

Industry generally objects to the idea of minimum

standards, arguing that they could actually result in

less information for consumers. For instance, if a

product contains recycled content but does not quite

meet the standard, manufacturers might be prevented from communicating this information to

consumers. Environmental groups counter that this

problem can be avoided if standards are applied only

to unqualified use of terms; attributes not meeting

minimum standards would have to be described in

specific detail on the label (e.g., “This product

contains 5 percent recycled industrial scrap and 5

percent post-consumer material.”).

Eco-Labels

Even if consumers fully understand the environmental claims made by manufacturers, they are still

faced with the problem of how to trade off one

environmental benefit or cost versus another. For

instance, it may be impossible for consumers to

decide whether a product that contains “20 percent

recycled content” is better for the environment than

a similar one that uses 10 percent less packaging.’

Ideally, green products would carry a single indicator of overall environmental quality .75

According to the Organization for Economic

Cooperation and Development, at least 22 countries

are expected to develop green product labeling

schemes by 1993.76 As discussed in chapter 5,

Germany, Canada, and Japan award an “eco-label”

to products that are judged to have reduced environmental impact compared with competing products .77

Properly constructed, environmental labels can provide consumers with an indicator of a product’s

overall environmental quality. Most analysts now

agree that a properly constructed labeling program

should be based on a life-cycle perspective (see

chapter 4), rather than on a single environmental

attribute such as recycled content. Initial efforts have

focused on collecting an inventory of resource

inputs and waste outputs. These inventories can

provide useful insights, but the scope and interpretation of inventories completed so far have been

controversial. 78 Nevertheless, at least the qualitative

perspective of evaluating the entire life cycle of a

product seems essential.

Although EPA once proposed the establishment

of a U.S. national eco-label, it has since dropped the

idea. 79 Instead, it is supporting research to develop

LCA methods (see table 6-5). Two private sector

labeling efforts, Green Seal and Scientific Certification Systems, are underway in the United States.80

These efforts are still quite small, and at the present

rate at which labeling guidelines are being developed, consumers should not expect to see eco-labels

on a wide range of products in the near future.81

Congress could appoint a blue-ribbon commission to oversee the establishment of an independent, national eco-labeling program. A wellfunded national program could accelerate the delivery of environmental information to consumers,

especially if it borrowed the best from the experiences of existing programs around the world. A

single national program would also have the credibility of the Federal Government behind it. As an

alternative, Congress could require EPA to develop standards for the certification of the product evaluation methods used by private ecolabeling programs. A certification process would

avoid the expense and bureaucracy of a national

eco-labeling program, and avoid preempting private

efforts that are already underway. For example,

eco-label programs that are based on a legitimate

life-cycle approach might receive government certification, while those based on a single environmental attribute might not.

By themselves, eco-labels are not likely to have a

large impact on environmental quality. Indeed, only

a small fraction of all products are likely to be

75A 1990 survey of 1-,514 COIISUmCrS conducted by Advern”sing Age and the Gallup org an.ization found that 34 percent indicated that an ecdabel

program would have a great impact on their purchasing decisions. Cited in Ciarmat M. Howa% op. cit., footnote 65, p. 451.

76 Cathetie ~~“some 22 N~o~s Cotid Have ‘Green Label’ Sch~= by ‘93,” Toronto Szar, NOV. & 1991, p. DG.

77 b most co~~es, me label is awaded by a nongovernmental, independent institute according tO StXiCt MtiOMl deS.

78 Consumer Repo~s, op. cit., foo~k l’.

79 Hannah Holmes, “The Green Police: In the Environmental Holy War, Who Can Tell the Good Guys From the Bad Guys?” Gurbuge,

September-October 1991, p. 44.

w ~y Lynn !hlzhauer, “Obstacles and Opportunities for a Consumer Ecolabel,” Environment, vol. 33, No. 9, November 1991, p. 10.

‘1 Ibid., p. 36.
96 ● Green Products by Design: Choices for a Cleaner Environment

considered for an eco-label. 82 There is also a

question about the extent to which manufacturers of

environmentally harmful products will be motivated

to redesign products and processes to become

eligible for a label. Nevertheless, eco-labels may

provide public policy benefits that reach beyond the

labeled products themselves. A highly visible ecolabeling program could become a useful educational

tool to raise consumer awareness about the environment that could spill over to other purchasing

decisions.

Institutional, Commercial, and

Government Buyers

OTA estimates that over 40 percent of all goods

and services (by value) produced in the U.S.

economy are ‘‘intermediate’ goods and services

(e.g., industrial equipment, chemicals, etc.) that are

purchased by businesses, institutions, or government agencies, rather than by individual consumers.

83 Therefore, these large-volume buyers are an

important target for environmental information.

While the “green preferences” of individual

consumers have been the subject of numerous

studies, OTA is unaware of any systematic studies

on how environmental concerns are factored into the

purchasing decisions of commercial or institutional

buyers. This is an important area for further research

(see section on institutional and behavioral research

above).

There is anecdotal evidence that these largevolume buyers are beginning to request more

information about the environmental attributes of

products and packaging. But since these intermediate goods are not advertised in the same way as

consumer goods, eco-labels or environmental advertising standards may not be appropriate. In the case

of chemicals, EPA has studied the possibility of

increasing information to users of TRI chemicals by

expanding Material Safety Data Sheets to include

environmental hazards,84 or requiring manufacturers

to provide “product stewardship” information to

their customers.85 In Europe, the idea of requiring

manufacturers to provide a‘ ‘product environmental

profile” to their customers is being explored (see

chapter 5).86

These proposals should be evaluated carefully

and full advantage should be taken of voluntary

industry efforts that are already ongoing.87 Federal

regulations requiring the transmission of additional

environmental information between suppliers and

manufacturers could create additional paperwork

without addressing the specific concerns of individual buyers. However, it is important that the Federal

Government incorporate environmental criteria into

its own purchasing decisions.

Government Procurement

About 20 percent of the purchases of all U.S.

goods and services is made by government at the

Federal, State, and local levels. Section 6002 of

RCRA requires EPA to establish procurement guidelines for government agencies to purchase products

made with recovered materials. At this writing, EPA

had published guidelines for paper products, lubricating oils, retreaded tires, building insulation, and

cement or concrete containing fly ash. Several more

guidelines are expected in 1992.88 Congress could

require EPA to identify additional product categories and establish deadlines for issuance of

“green” procurement guidelines.

To date, government procurement guidelines for

green products have been based almost exclusively

on recycled content. In the future, it will be

important to broaden these guidelines to include

other environmental attributes, especially waste

prevention (toxicity reduction, energy efficiency,

etc.). Congress could require that EPA undertake

82 rn 1991, after 13 years in operation, GermarI y’s Blue Angel program had awarded eco-labels to some 3,600 products in 66 product categories.

However, more than half of the labels awarded fall into only four product categories.

83 ~~ es~te w= obt~ed ~m the Dep~~@ of co~eme’s Use of Commo&ties ~ble of 1987. Divid@ total intermediate use by tOti

commodity output yields a ratio of 43.6 percent.

a Rquired by the occupatio~ Safety and Htxdth Atistration.

85 David Hanson, “EPA Develops Product Stewardship, Hazard Communication Regulations,” Chem”cal and Engineenng News, Nov. 19, 1990.

86A ~mduct Proffle is a ~~~tive description of the li,fe.cycle environmen~ impacts of a product, intended for use by professional buyers, mth~

than individual consumers.

87 See, e.g., Janice R. ~ng, “Standard for Material Safety Data Sheets in the Offing,” Chemical and Engineenng News, May 18, 1992, p. 7,

88 Ta~ony of RiChmd D. MOrgeMtem, &ing ASSiS~t Administrator, ~lce of poficy pl-~d Ev~uation, EPA, before the fhlbCOhttee

on Oversight of Government Management, Semte Committee on Governmental Affairs, Nov. 8, 1991.
Chapter 6-Policy Options and the Challenge of Green Design ● 97

studies to determine how procurement guidelines

might be broadened to account for waste prevention.

In response to congressional pressure, the General

Services Administration (GSA) has begun to highlight the environmental attributes of products in its

regular supply catalogs.89 This has helped to ensure

that procurement agents in various agencies have

access to environmental information on the products

they buy. Congress could formalize this process

by requiring that all Federal procurement catalogs contain information on environmental attributes alongside performance and cost information.

MARKET DISTORTIONS

AND ENVIRONMENTAL

EXTERNALITIES

The third major area in which Congress can

encourage green design is by shaping environmental

policies that better account for the environmental

impacts of products throughout their life cycle.

Providing better information to designers and consumers on the environmental impacts of materials

and processes is important, but if this information is

not backed up by appropriate price signals, environmental concerns are likely to be overwhelmed by

many other design requirements and consumer

demands.

Economists have long argued that efficient use of

energy and resources requires that the prices of

goods and services reflect their true social (and

environmental) costs.9091 These costs are partially

accounted for through health and environmental

laws such as those in table 6-1. For example,

emissions control technologies required by the

Clean Air Act raise the price of electric power and

automobiles. Nationwide, it is estimated that compliance with pollution control laws costs industry

and consumers $115 billion per year.92

But most observers agree that many environmental costs remain external to economic transactions, and in some cases government policies distort

market price signals. On the production side, there

are government subsidies or special tax treatment for

the extraction of virgin materials (e.g., below-cost

timber sales and mineral depletion allowances);93

and many “non-hazardous’ industrial solid wastes

(e.g., mine tailings or manufacturing wastes that are

managed on-site) with significant environmental

impacts are not regulated at the Federal level.94 On

the consumption side, consumers often do not pay

the full environmental costs of products that are

consumed or dissipated during use (e.g., fuels,

cleaners, agricultural chemicals),95 or the full cost of

solid waste disposal.96

There are two general policy mechanisms for

internalizing environmental costs: regulations and

economic instruments. Historically, the basis of

environmental policy in the United States has been

regulation (see, for example, table 6-1). But in recent

years, there has been a growing interest in the use of

market-based incentives such as pollution taxes,

tradable pollution permits, and deposit-refund systems, that can—in principle at least—provide the

same environmental protection as regulations at less

cost.97 Table 6-6 presents a menu of regulatory and

market-based incentives that have been proposed to

internalize the environmental costs associated with

the flow of goods and materials through the economy. These options are organized according to their

point of greatest impact on the materials life cycle.

Each could have an impact on product design, but an

89 see, ~.g., GSA supply Catiog, my 1992. See ~o “Buying Green: Federal purc~ing fiactices and the Environmen~” a hearing of the

Subcommittee on Oversight of Government Management of the Senate Committee on Governmental Affairs, Nov. 8, 1991.

~ FOr a remnt review, see William D. Nordhaus, “me ~OIOSY of ~kets~ “ Proceedings of the National Academy of Science, vol. 89, February

1992, P. 843.

91 For ~ ~g~y r~&ble discussion of environmen~ policy instruments to prot~t he environment from an economist’s perSptXtiVe, S= Frances

Cairncross, Costing the Earth: The Challenge for Governments, the Opportunities for Business (Boston, MA: Harvard Business School Press, 1992).

n Environmen~ Protection Agency, “Environmental Investments: The Costs of a Clean Environment,” EPA 230-12-90-084, December 1990.

93 Jessica Matthews, “OIL Give Me a Home Where the Subsidies Roam,” Washington Post, Oct. 3, 1991.

94 Us. ConPeSS, offIce of TeC~ology Assessment, Ma~ging I&usfrial Solid wastes From Alanufactu~ng, Mining, oil and Gas Production, and

Utility Coal Combustiotiackground Paper, OTA-BP-O-82 (Washingto~ DC: U.S. Government Printing OffIce, Febraary 1992).

95 See, e.g., Harold M. Hubbard, “The Real Cost of Energy,” Scientific American, vol. 264, No. 4, April 1991, p. 36.

% A. Clark Wisemam “1.mp~iments to Economically Efllcient Solid Waste Management,” Resources, fall 1991, P. 9.

97 Ro~fi we ~and Ro~fiNo s~v~, “~~ntive-Bas~ Bnvhonmenti Re@tion: A New Era From an Old Idea?’ Energy and Environmental

Policy Center Discussion Paper, John F. Kennedy School of Government, Harvard University, August 1990.
98 ● Green Products by Design: Choices for a Cleaner Environment

analysis of the design implications of all of them is

beyond the scope of this report. Here we focus

especially on those options that would affect product

design directly: i.e., options primarily affecting the

manufacturing stage of the life cycle. Many of these

instruments have been discussed in detail elsewhere.98

Recycled Content

With the proliferation of State and local recycling

collection programs in recent years, cities are

collecting recyclable at a pace that far exceeds the

use of these recovered materials in new products.

Cities are now faced with increasing costs of

managing recovered materials at a time when they

are already strapped financially.w As more and more

large cities implement collection programs, the

volume of recovered materials can be expected to

increase; without new markets for these materials,

prices will drop. This has led to increasing pressure

on Congress to enact legislation to create markets for

recovered materials through recycled content requirements.

Recycled content requirements can help to solve

the immediate problem of the lack of markets for

recyclable. But by creating markets for recovered

materials through regulation, policymakers are imposing a predetermined solution to the solid waste

problem that ignores market forces.100 This solution

may be inefficient for several reasons:

● With many thousands of products likely to be

covered by such regulations, the transaction

costs of administration, monitoring, and enforcement on a per-product basis may be

unacceptably high.

●

9

Across-the-board content requirements do not

account for the fact that some companies may

be able to incorporate recycled content more

cheaply than others, or that costs may vary

significantly by geographical region.

Finally, by focusing exclusively on a single

environmental attribute, recycled content requirements may preclude environmentally preferred designs, especially those featuring waste

prevention.

Congress could choose not to address this

problem, in which case many communities may

be forced to curtail their recycling collection

programs until stronger markets for these materials develop. If Congress does choose to pursue

recycled content requirements, either in government procurement programs or as part of RCRA,

it can address the inefficiencies noted above in

several ways.

Crediting Waste Prevention

Congress can exempt products from recycled

content requirements that feature waste prevention. 101 This would provide more flexibility to

manufacturers, but the viability of this option

depends on developing criteria for measuring waste

prevention. For instance, how should the various

aspects of waste prevention (e.g., weight or volume

reduction, toxicity reduction, and energy efficiency)

be factored in? And what should be the baseline for

measuring reductions? A system of complicated

exemptions for waste prevention could make recycled content regulations administratively unworkable, especially if applied on a per-product basis. One

alternative would be to offer companies the

option of avoiding per-product regulations by

committing to companywide reductions, and

9s see, e.g., Resource Conservation Colnlnitt*, “Choices for Conservatio~” Final Report to the President and Congress, SW-779, July 1979

(available from the U.S. EPA Engineering Research Center Library, Cincinnati, OH); Robert N. Stavins, Project Director, “ProjWt 88, Harnessing

Market Forces lb Protect Our Environment: Initiatives for the New presiden~” Washingto~ DC, December 1988; Robert N. Stavins, Project Director,

“Project 88-Round II, Incentives for Actiorr De@@ Market-Based Environmental Strategies,” Washington, DC, May 1991; Environmental

Protection Agency Science Advisory Boar~ “Reducing Risk: Setting Riorities and Strategies for Environmental fiotectio~” (especially Appendht

C), EPA-SAB-EC-90-021C, September 1990, U.S. Environmental Protection Agency, “Economic Incentives: Options for Environmental protectio~”

PM-220, Washingto~ DC, March 1991; Organisation for Economic Cooperation and Development, “Environmental Policy: How lb Apply Economic

Instruments,” Paris, 1991.

99 me Nation~ Solid Wrote -merit Association noted in a recent survey of the IWiOn’s cities @t solid WW@ management costs are second

only to education in public expenditure of funds. David Ruller, Recycling Coordinator for the City of Alexandri% VA, personal communicato~ August

1992.

~m <CHow ~ mow -sAwaY, “ The Econonu”st, Apr. 13, 1991, p. 17.

lol me ~sach~etts public Interest Research Group (MASSPIRG) has developed legislation proposing that pactiging be considered “-n” if

it met one of several alternative criteri~ made from a specified percentage of recovered material, made fkom a material that was recycled at a specifkd

rate, or reduced in weight or volume by a specifkd percentage. Such “MASSPXRG bills” have been introduced in several States, and the idea became

part of the RCRA reauthorization debate in the l(Y2d Congress.
Chapter 6--Policy Options and the Challenge of Green Design .99

Table 6-6-Policy Options That Could Affect Materials Flows

Life-cycle stage Regulatory Instruments Economic instruments

Raw material extraction

and processing

Manufacturing

Purchase, use, and

disposal

Waste management

Regulate mining, oil, and gas non-hazardous solid

wastes under the Resource Conservation and

Recovery Act (RCRA).

Establish depletion quotas on extraction and import of

virgin materials.

Tighten regulations under Clean Air Act, Clean Water

Act, 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.

Mandate consumer separation of materials for

recycling.

Tighten regulation of waste management facilities

under RCRA.

Ban disposal of hazardous products in landfills and

incinerators.

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 of

virgin materials, and subsidies for agriculture.

Tax the production of virgin materials.

Tax industrial emissions, effluents, and hazardous

wastes.

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

research.

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 management

facilities.

Establish surcharges on wastes delivered to

landfills or incinerators.

SOURCE: Office of Technology Assessment, 1992.

requiring them to document compliance with

these agreements in publicly available databases.

l02

Tradable Recycling Credits

Another option for reducing the burden of

industry compliance with recycled content requirements would be to couple them with a

tradable recycling credit mechanism similar to

the emissions trading program for sulfur dioxide

under the Clean Air Act Amendments of 1990.103

Manufacturers would be required either to use a

specified percentage of recycled content in their

products, or to purchase recycling credits from other

manufacturers who exceed the percentage requirement.

Such tradable recycling credit mechanisms encourage those manufacturers that can incorporate

recovered materials most cheaply to do so. However,

due to the administrative costs of setting up and

monitoring these programs, they are not feasible for

all of the many thousands of products on the

market. 104 Rather, they may be most suitable for a

limited number of materials or waste streams of

special concern, e.g., old newspapers, used oil, or

lm Model legis~tion d~eloped by the Source Reduction Task Force of the Coalition of Northeastern Governors (CONEG) would wow comptim

to avoid all packaging recycling requirements by committing to reduce paclmging on a companpvide basis by 15 percent between 1988 and 1996. See

CONEG Source Reduction Task Force-Model Legislatio~ “An Act Concerning Reduction in Packaging Waste,” Feb. 11, 1992.

103 s= “RojWt 88—Rod II,” op. cit., footnote 98, p. 55.

IM Fora discussion of tie appropria~ use of marketable permits, see Organisation for Economic Cooperation and Development, op. cit., fOO~Ote 98.
100 . Green Products by Design: Choices for a Cleaner Environment

automobile batteries.105 Congress could mandate

that EPA set up a limited number of pilot

tradable recycling credit programs to evaluate

the effectiveness of this approach.

A Market-Based Alternative

The extraction of raw materials and their initial

processing are two of the most environmentally

destructive phases of a product’s life cycle.l06 Yet

many of these environmental costs are not reflected

in the price of materials. As an alternative to

recycled content requirements, Congress may

wish to move toward a system of indirect incentives aimed at internalizing the environmental

costs of virgin materials use, thus making virgin

materials more expensive and the use of recovered materials more economically attractive.107

This might include eliminating subsidies and special

tax treatment for the extraction of virgin materials,

taxing the production of virgin materials of special

concern, or regulating more strictly the wastes and

other environmental impacts of extractive industries. 108

Such a market-based strategy has the advantage

that it does not impose a predetermined solution on

the solid waste problem, and would begin to

internalize the costs of some of the most environmentally destructive practices. However, the size of

its impact on the solid waste problem and the timing

of that impact is much less predictable. Several

studies suggest that simply removing government

subsidies for virgin materials is unlikely to change

the price of processed materials by more than a few

percent. 109 110 Attempting to replicate the incentives

of recycled content requirements through taxes on

virgin materials might require taxes to be so high as

to cause significant economic disruption in the

domestic materials extraction industries, with serious implications for U.S. resource security. Nevertheless, given that current policies were established

at a time when the goal was to encourage the

exploitation of resources,lll it is appropriate for

Congress to reevaluate these policies in light of

current concerns about the environmental impacts of

resource use and ecological sustainability.

Use of Hazardous Chemicals

Since the 1940s, when the chemical industry

began an era of explosive growth, more than 60,000

chemical substances have been synthesized, and

more than 1,000 new chemicals are proposed for

manufacture each year.112 These chemicals are

responsible in large part for the high standard of

living in industrialized countries, and for many of

the conveniences of modern life. Contemporary food

production, medicines, building materials, and many

consumer products (e.g., nylon hosiery and laundry

detergents) depend on use of these chemicals.

This dramatic growth in chemical use has also

raised health and environmental concerns. For the

most part, these chemicals pass through the economy quickly, whether in the form of industrial

wastes or products. 113 Some have very long lifetimes

in the environment (e.g., CFCs and polychlorinated

biphenyls (PCBs)) and may become distributed

globally. 114 In some cases, a hazardous substance

may achieve widespread use before its health or

environmental implications are realized; for example, CFCs were believed to be quite safe at the time

they were introduced. Toxic substances initially

released in low concentrations may also become

reconcentrated in sediments or through bioaccumu105 ~gislation to establish ~adable r~cling credit programs for old newspapers, tires, used oil, and automobile batteries was introduced ti tie 102d

Congress by Representative Esteban ‘Ibrres. See, e.g., H.R. 872.

106 Joim E. Young, “’Ibssing the Throwaway Habit,” IVorZd Watch, May-June 1991, p. 26.

10T Steven fiatem “Market Failure and the Economics of Recycling,” ~nvironmntal~ecisions, April 1990, P. 20.

10S me advantages and disadvantag~ of these options are discussed extensively in the references of footnote 98.

IW For a brief discussion of tie impact of virgin material subsidies on recycling, see U.S. Congress, ~lce of Technology Assessment Facing

America’s Trash: Whar Next for Municipal Solid Waste, OTA-O-424 (Washingto~ DC: U.S. Government Printing OffIce, October 1989), p. 200.

110 Otier observe~ counter, though, that the largest government subsidies go to the energy and transportation WXors, not to v@@ materi~s Per se.

111 Forexamp]e, tielaw that governs the extraction of gold, silver, and other “hardrock” minerals is the General-g LWv of 1872. Bills to r~orm

the Mining Law were introduced in both the House and Senate in the 102d Congress.

112 Michael Shapiro, “Toxic Substances Policy, “ in Public Policies for Environmental Protection, Paul R. Portney (cd.), op. cit., footnote 2, p. 195.

1]3 Robert U. Ayres, “Industrial Metabolism,” Technology and Environment (Washington DC: National Academy Press, 1989), p. 23.

114 Cufis C. Travis ~d Shefi T. Hestm, “Global Chemical Pollutiorq” Environmental Science and Technology, VO1. 25, No. 5, 1991, p. 814.
Chapter 6--Policy Options and the Challenge of Green Design ● 101

lation to levels that pose significant risks to human

health.115

In 1976, Congress passed the Toxic Substances

Control Act (TSCA) to address these concerns. Yet

little is known about the long-term implications of

the dissipative use of these substances for human

health and the environment. Toxicity data are

lacking on many, if not most of the chemical

products used in the United States.116 In 1991, GAO

reported that 15 years after the enactment of TSCA,

EPA had received test results for only 22 chemicals,

and had assessed the results for only 13 of the 22.117

Manufacturers have begun to respond to these

health and environmental concerns in a variety of

ways, such as the “Responsible Care” program of

the Chemical Manufacturers Association (see table

6-3). As of February 1992, 734 companies had

joined EPA’s 33/50 Program, pledging to reduce

their releases of 17 toxic materials by 50 percent

(relative to 1988) by 1995.118 But in spite of these

efforts, large volumes of hazardous chemicals continue to flow through the economy into the environment. According to data collected in 1990 on

industrial use of hazardous substances in the State of

New Jersey, for example, at least 83 percent of the

cadmium, 92 percent of the nickel, and 99 percent of

the mercury used by industry was converted into

products (e.g., paints, coatings, plastics, and batteries), not released as wastes.ll9 These heavy metals

are released to the environment when these products

are discarded; however, these environmental releases are not addressed by programs such as the

33/50 program, which is concerned only with

industrial waste streams. This example illustrates

that if we are concerned about the dissipation of

hazardous materials into the environment, we must

be concerned not only with industrial wastes, but

with the use of these materials in products as well.

Toxics Use Reduction

Recognizing the importance of toxic materials

flows in products as well as in industrial wastes,

environmental groups are promoting reduction in

industry use of toxic chemicals in the frost place.120

The rationale is that once toxic materials are

introduced into the economy, they are likely to be

released into the environment. Therefore, environmental groups argue, the best way to prevent toxic

releases is to limit the use of these materials from the

outset. Some advocates envision a world in which

certain toxic materials would be “sunsetted” or

phased out entirely.121

The distinction between waste minimization and

toxics use reduction is important because toxics use

reduction is a much more radical concept than waste

minimization (box 6-B). Whereas Federal policy has

long been concerned with protecting the environment from the release of hazardous and nonhazardous wastes by industrial generators (e.g., EPA’s

33/50 Program), the choice of what materials should

be used in products has usually been a private sector

decision. Thus, toxics use reduction implies government intrusion into areas that have traditionally been

considered the province of private industry. In other

words, toxics use reduction involves a more prescriptive approach to product design than does waste

minimization.

Policy Approaches

The use of hazardous or toxic chemicals must be

understood in the context of risks and benefits.122

Clearly, the environmental risks of using some

materials are so great that they outweigh any

possible benefits, and they must be banned-as in

Ils For e~ple, merc~ vola~~d by fossil fuel burning or municipal solid waste incineration retis in the atmosphere for about a year. After

mercury from the atmosphere is deposited in lakes, it is methylated and bioaccurmdates in fish as methyl mercury, the form most toxic to humans. About

15 percent of Michigan lakes, 30 percent of Wisconsin lakes, and 50 percent of Florida lakes contain fish with mercury levels exceeding State health

standards. Curtis C. Travis and Sheri T. Hester, op. cit., footnote 114, p. 816.

116 Mckl Shapiro, op. cit., footnote 112, p. 221.

117 U.S. Conmess, Gener~ Accounting OffIce, Toxic Substances: EPA’s Chemical Testing Program Has Not Resolved Safety Concerns,

GAO/RCED-91-136 (Washington, DC: U.S. Government Printing Off@ 1991), p. 2.

118 Environment Protection Agency, “33/50 Program Pledges on the Rise,” Pollution Prevention News, March/April 1992, p. 1.

119 Dam supplied by Andrew Oppem, New Jer8ey Department of Environmental Protection and Energy, personal commtimtio% Au@st 1992.

IZO SW, e.g., testimony of Hillel Gray, Natioti Environmental Law Center, before the Subcommittee on Transportation and Hazardous Miite* of

the House Committee on Energy and Commerce, Mar. 10, 1992.

121 Jeffrey A. Forq ‘The Sunset Chemicals prOpOSd,” International Environmental Afiairs, vol. 2, No. 4, fall 1990, p. 303.

122 ~5 p~ciple i5 at he root of tie Toxic Substices Con&ol At ~d tie Feder~ ~secticide, Fungicide, and Rodenticide Act, which regulate

chemicals and pesticides on the basis of “unreasomble risk” to health or the environment.
102 ● Green Products by Design: Choices for a Cleaner Environment

Box 6-B—Toxics Use Reduction vs. Waste Minimization

Waste minimization and toxic use reduction are related concepts, but they are not identical. Waste

minimization refers to all activities that reduce the quantity or toxicity of waste released from a facility to the

environment As such it is concerned with reducing the waste outputs of industrial processes. Toxic use reduction

refers to reducing the inputs of toxic materials into industrial processes, thereby avoiding their release as wastes or

in products,

Industry has been generally supportive of the idea of waste minimization, at least in principle. Companies

object strongly, though, to government requirements for toxic use reduction. They argue that society’s legitimate

concern is with the release of toxic materials, not their use per se. For example, two toxic chemicals can react to

produce a nontoxic product; and toxic solvents can be recovered and reused many times. Thus, they argue, the mere

use of a toxic material may not affect the environment, Furthermore, companies argue that the term ‘‘toxic’ is

imprecise because most substances are toxic in sufficient concentrations, while some highly toxic chemicals can

be beneficial in low concentrations. Finally, industry argues that regulations restricting the use of materials would

hurt their international competitiveness, since the same restrictions would not apply to their competitors overseas.

Environmentalists counter that industry cannot be entrusted with protecting the environment from toxic

materials, especially when it is not profitable to do so. They point to historical examples of polluted rivers and

abandoned toxic waste dumps. And even if toxic materials are released in small quantities, they may persist for a

long time in the environment and become reconcentrated in sediments or through bioac cumulation. Little is known

about the risks of long-term exposure to low concentrations of toxic chemicals.

These two views-waste minimization and toxic use reduction--illustrate the clash between two of the

philosophical paradigms discussed in chapter 3. Waste minimization, with its concern with industrial waste outputs,

arises from the environmental protection paradigm, Toxic use reduction, on the other hand, with its precautionary

emphasis on resource inputs, reflects the eco-development paradigm.

soURCE: Office of Technology Assessment, 1992.

the case of CFCs. For most chemical substances, effects of most chemicals is sketchy at best, and the

though, more flexibility is appropriate. Products that environmental risks to ecosystems have hardly been

use toxic materials can perform socially useful considered. These uncertainties suggest that a prefunctions or even have (comparative) environmental cautionary policy that encourages designers to avoid

benefits. For instance, the recently discovered high- the dissipative use of hazardous materials (insofar as

temperature superconductors could potentially lead possible) is warranted.

to more efficient power generation and transmission,

resulting in less pollution from power plants. Yet the More than a dozen States have enacted laws that synthesis of these superconductors involves use of

toxic chemicals, and the materials themselves con- promote toxics use reduction or related approaches.124

tain a variety of toxic heavy metals; for instance, the The Massachusetts Toxics Use Reduction Act,

compound currently with the highest critical transi- which is widely agreed to be the most aggressive,

tion temperature is based on thallium, a highly toxic requires industrial facilities to develop toxics use

heavy metal.123 reduction plans and document progress toward

self-set goals. The overall goal of the legislation is

On the other hand, it must be recognized that there to reduce the use of listed toxic chemicals by 50

is considerable uncertainty about the health and percent by 1997. To protect proprietary information,

environmental impacts of the dissipative use of the plans themselves are confidential, although the

hazardous or toxic materials. As noted above, plan summaries and the goals are to be made

information on the toxicity and long-term health public.125

123 U.S. Congress, office of Technology Assessment, High-Temperature Superconductivity in Perspective, OTA-E-440 (Washington, DC: U.S.

Government Printing Office, April 1990).

124 William Ryan and R.ichard Schrader,"An Ounce of Toxic Pollution Prevention: Rating States’ Toxic Use Reduction Laws,”available from the

Center for Policy Alternatives, Washington, DC, Jan. 17, 1991, p. 1.

125 Ken Geiser, “The Greening of Industry,” Technology Review, August/September 1991, p. 68.
Chapter 6--Policy Options and the Challenge of Green Design .103

California has tried another approach aimed at

informing consumers of the use of toxic chemicals

in products. Under the Safe Drinking Water and

Toxic Enforcement Act of 1986 (Proposition 65),

products that contain even minute amounts of any of

420 chemicals determined to be carcinogenic or

posing reproductive toxicity must be labeled with

warnings. 126 This has stimulated some companies to

reformulate products to avoid the labeling requirements. 127 However, because so many chemicals are

covered, and in such low concentrations, the effect

of the labeling requirements may be to desensitize

consumers to actual risks.128

In addressing health and environmental concerns

relating to toxic or hazardous chemical use in

products, Congress can choose a variety of options,

ranging from further research to mandatory toxics

use reduction requirements. By initiating a research program to identify high-risk materials

and products, and to model the flows of these

materials through the economy (see research

discussion above), Congress can ensure that

regulations result in cost-effective risk reduction.

Congress can act to increase available information about the flows of toxic materials by expanding industry’s reporting requirements under TRI

to include additional facilities, industrial sectors,

and chemicals not covered under the original law.

The 1986 Superfund Amendments and Reauthorization Act requires manufacturers in 20 manufacturing

industries to report annually to EPA on their releases

of 322 chemicals or chemical categories. However,

many environmental releases of these chemicals are

not covered under TRI. Not included are nonmanufacturing sources such as mines, waste treatment

plants, public utilities, farms, and government facilities. Manufacturers with fewer than 10 employees or

using less than 10,000 pounds of TRI chemicals

annually are exempted from reporting. Critics also

charge that hundreds of chemicals listed as toxic

under other environmental laws are excluded from

the TRI reports.129

Congress could expand facilities’ reporting

requirements under TRI to include the use of

toxic materials, not just their releases to the

environment. This “materials accounting” approach could lead to a valuable database on toxic

chemical flows.130 However, comprehensive reporting on the use of hundreds of chemicals for

thousands of facilities would involve a huge paperwork burden, both for companies and for EPA

reviewers. 131 Unless these requirements are narrowly targeted on chemicals or materials of special

concern, they would significantly increase industry’s reporting costs, and might not result in a

significant reduction of environmental risk.

Congress could mandate a national requirement for industry toxics use reduction plans,

modeled on the Massachusetts Toxics Use Reduction Act. Again, however, the law would have to be

carefully structured to make the paperwork burden

manageable. If Congress does decide to pursue

mandatory toxics use reduction, it may wish to

consider market-based incentives such as tradable toxic use permits to achieve reductions at the

lowest cost to industry.132 This approach was used

successfully in the phase-out of leaded gasoline

126 Wilh S. p-, c<~e~~ ~d~ and the ~b~c’s Right ~ Know: How ~ective ~ c~ofia’s ~position65?” Environment, vO1. 33, No.

10, December 1991, p. 12.

127 For e=ple, Gille~e ~fom~at~ is Liq~d pqm product to remove ~chlomethyl~, ou of the ~t~ ckm.i~s. The substitute W~ 1,1,1

trichlorethane, which is not on the list. Robert Healey, Gillette, personal cmnmunicatio~ August 1992.

12S me ~w s~testit ~sted ~~c~~ fo~ must not be present at a level gr@~ ~one onetho~~d~ of the level at whkh there SK 110

observable health effects. Industry representatives claim that this is too restrictive, arguing, for example, that ethyl alcohol, one of the listed chemicals,

is mturally present in soft clrinks, carrots, ice cream, and bread at levels that would trigger a warning under Reposition 65. See Conrad B. MackerroU

“Industry Is Learning ‘Ib Live With Proposition 65,” Chem”caZweek, July 12, 1989, p. 19.

129 ~or~ to one es~te, TRI excludes 140 chemicals regulated as hamrdous under R- 64 substances listed as *dous ~der he ~lWI

AirAc~ 56 priority pollutants under the Clean Water and Safe Drink@ Water Acts; 69 apecialrcwiew pesticides under FIFWl; and hun&eds of probable

carcinogens and reproductive toxicanta listed by scientiilc authorities and government agencies. See Hillel Gray, op. cit., footnote 120.

1~ For ex~ple, New Jersey’s Worker and Community Right to Know Act of 1983 requires tidustry to report hpus ~d ou@t5 of 165 -dom

chemicals, all of wbich are on the TM list. These materials accounting data are necessary to track the flows of these chemicals through the economy

and into the environmen~ whether in the form of products or waste streams.

131 me ~wleu ~W~, for ~s~nce, ~estit cmde oil contains millioIM of differ~t hydroc~bom ~d o~er ~~~Y Occti compo~~

that are never fully separated during the manufacturing process. Petroleum products such as gasoline, fuel oil, and others are also complex mixtures that

donothave standard compositions. Accounting for all of these chemicala would be impractical. See testimony of thelirnerican Petroleum Institute before

the Subcommittee on Transportation and Hazardous Materials of the House Committee on Energy and Commerce, Mar. 10, 1992.

132 Molly K. ~ca~ey and Karen L. Palmer, “Incentive-based Approaches to Regulating lbxic Substances,” Resources, Summer 1992, p. 5.
104 ● Green Products by Design: Choices for a Cleaner Environment

during the early 1980s.133 Finally, if new bans are

deemed necessary, they can be targeted on specific products, rather than generic materials.

This can help to target specific risks, while not

foreclosing the economic and environmental benefits that these materials may have in other

applications.

Product Taxes

Environmental product fees or taxes are-in

principle, at least—an efficient way to encourage

designers and consumers to make greener choices.134

Taxes can be applied to hard-to-dispose products or

to products that pose special risks as a result of their

use. The best example in the United States is the

excise tax on CFCs, which is intended to remove

windfall profits as the production of these chemicals

is phased down under a marketable permit system.135 As discussed in chapter 5, several European

countries impose hefty taxes on nonreturnable

beverage containers and other packaging to encourage returnable and reusable packaging. Several

countries in Europe impose a tax on leaded gasoline

(with a corresponding subsidy for unleaded gasoline), which has resulted in a significant decline in

demand for leaded gas.136

More often, fees are imposed on products to raise

finds for recycling or safe disposal programs, and

are too small to influence product design decisions.

Several States have fees on products that cause

special waste problems, such as tires, batteries, and

used oil. At this writing, Florida is the only State

with an advance disposal fee on packaging.137

Industry has lobbied heavily to quash proposals

for new environmental product taxes, arguing that

taxes on narrow categories of products (e.g., packaging) are unfair, while taxes on a large number of

different products could involve unacceptable administrative costs. There is, however, widespread

agreement among industry and environmentalists

that weight- or volume-based trash disposal fees

provide an excellent incentive for consumers to send

less trash to the landfill-provided they have access

to curbside recycling programs (for which no

disposal fee is charged). An increasing number of

communities have implemented these pay-per-can

programs.

138 However, while these programs may

encourage the separation of trash for recycling, they

seem unlikely to influence consumer buying habits

(and thus product design) in a dramatic way, because

solid waste disposal costs are relatively small

compared with the price of most products.139

In the short term, Congress could set up a

national waste disposal fee that would fund a

grant program for research, demonstration, and

education projects for clean manufacturing technologies and green product design in universities,

national laboratories, and industry. For example,

a Federal charge of $1 per ton of municipal solid

waste delivered to landfills and incinerators would

raise on the order of $100 million annually. Such a

charge would not discriminate against specific

products, and the infrastructure for collecting the

charge already exists in most states, so collection

costs would likely not be prohibitive.140

In the longer term, if Congress decides to

address energy conservation and global warming

concerns through an environmental tax on fossil

fuels, this could have a dramatic impact on

product design, since fuels are consumed at every

stage of the product life cycle. Such a tax could

encourage not only the design of more energy133 R. Hahn and G. Hester, “Marketable Permits: Ussons for Theory and Practice, “ Ecology Luw Quarterly, vol. 16, No. 2, 1989.

MI Te~ D~m CtSolid Wrote: ~cativw ~tCotid Lighten the Load,” EPA Journal, VO1. 18, No. 2, ~yfl~e 1992. P. 12.

135 David ~e, “ozone LOSS: Modern Tools for a Modem Problem,” EPA Journal, My/J~e 1992, p. 16.

136 See Environmental Resources Ltd., ‘‘Environmentally Sound Product Design: Policies and Practices in Western Europe and Japau” contractor

report prepared for OTA, July 1991, p. 45.

137 me fee is $().()1 per con~m by 19$)2 unless the container material reaches a so percent reCYClfig rate.

138 &x, e.g., Environmental Protection Agency, “Economic Incentives: Options for Environmental Protection op. cit., footnote 98, p. 2-7.

139 Comider a family of four that annually purchases $10,000 of goods r-disposal. Annual discards (at a rate of 4 pounds per person per day,

the mtional average) amount to 2.92 tons of trash. At a weight-based fee of $100 per tom this amounts to an annual trash bill of $292, about 3 percent

of purchases. By carefid shopping for recyclable and light-weight products and packaging, consumers might save 10 percent on their trash bill (about

$30 per year), or 0.3 percent of total purchases.

140 Denmark imposes a mtional tax on the weight of solid wastes delivered to landfiis and incinerators. The tax is e armarked to pay for recycling and

environmental research programs.

141 As one exmple, btitig airctit witb new, light-wei@t composites can signitlcantly improve their fuel eiliciency, but with he dectie of r~

jet fuel prices since the late 1970s, the higher initial cost of composites compared with aluminum cannot be recouped through fuel savings.
Chapter 6-Policy Options and the Challenge of Green Design ● 105

efficient products, but more material-efficient products as well.141

Manufacturer Take-Back

Take-back regulations give manufacturers responsibility for recovering and recycling the products they produce. By shifting the burden of solid

waste management from beleaguered municipal

governments to industry, the costs of solid waste

management are internalized and manufacturers

have direct incentives to design products that are

recyclable. As discussed in chapter 5, Germany has

established a take back program for packaging, and

is considering the idea for a variety of durable goods

as well. The takeback idea appears to be gathering

momentum throughout Europe,

142 and many observers believe its introduction in the United States is

just a matter of time.143

Manufacturer take-back regulations have considerable intuitive appeal. By assigning manufacturers

the responsibility for recovering their own products,

rather than telling them how to do it, manufacturers

have some flexibility to find the least-cost solution.

This may involve collecting and recycling the

product themselves, or paying a third party to do so.

Durable goods may be especially good candidates

for take-back programs, because they are inherently

longer lasting, are generally made from higher value

materials, and often consist of “knowledgeintensive’ components that command a high recovery value. Indeed, some manufacturers of leased

office equipment have already initiated design for

recycling and remanufacturing programs (see chapter 3). Products that pose special solid waste disposal

problems, such as batteries and tires, may also be

good candidates for take-back regulations.

However, take-back requirements may not be

cost-effective for all products. Requiring manufacturers of many nondurable goods to take back and

recycle their products could simply impose additional costs without clear corresponding environmental benefits. For instance, it would probably not

be efficient to collect and recycle potato chip bags;

doing so would be likely to cause more pollution

from transporting the bags to a recycling facility

than would result from landfilling or incinerating

them. And of course, take-back schemes could not

be applied to products that are consumed or dissipated during their use.

Take-back requirements have several other limitations. In effect, they impose a predetermined

solution (recycling) to the problem of solid waste.

They elevate the solid waste aspects of the product

above other environmental and performance attributes that may be relevant. If there are design

tradeoffs between recyclability and waste prevention, or recyclability and energy efficiency, design

decisions may be biased in favor of recyclability, to

the detriment of the environment.

Manufacturer take-back programs appear to be

moving forward in Europe without any serious

attempt at cost-benefit analysis.

144 OTA suggests

that while take-back schemes may be a good

option for some products, further research on the

costs and benefits for a range of products is

needed before they are implemented in the

United States (see the discussion of policy research needs above). These studies should consider

the relative merits of market-based incentives such

as deposit-refund systems or tradable recycling

credit programs as alternatives to take-back regulations.

COORDINATION AND

HARMONIZATION

The final area where Congress has a unique role

is in coordination and harmonization of policies

affecting green design. Green design involves bringing together two policy objectives (industrial competitiveness and environmental protection) that in

the past have been seen as separate or even

conflicting. It is not surprising, then, that the Federal

Government is poorly organized to take advantage

of opportunities such as green design. For example,

EPA is organized around regulatory responsibilities

for protecting air, water, and land; it does not address

industrial competitiveness in a natural way, and its

technical expertise in design and manufacturing is

minimal. The Department of Commerce, on the

other hand, is concerned with the competitiveness of

industrial sectors, but has little environmental expertise. DOE’s national laboratories have a wide range

142 Frances Cairncross, “How Europe’s Companies Reposition to Recycle,” Harvard Business Review, March-April 1992, p. 34.

143 SW- S~~s me emc~ tieback laws, such as New Jersey’s take-back requirement for rechargeable nickel-cadmium batteries.

144 ,,En~omentiim R~ Riog’” Op. Cit., foo@ote ‘.
106 . Green Products by Design: Choices for a Cleaner Environment

of technical capabilities that could be brought to bear

on improving design for energy efficiency and solid

waste recycling processes, but environmental quality has not traditionally been a part of DOE’s

mission.

Throughout this report, a number of areas have

been cited where green design could benefit from a

stronger, more coherent Federal approach:

●

●

●

Coordinating research. Projects related to green

design are underway in several agency offices

(e.g., EPA’s Office of Research and Development, Office of Solid Waste, and Office of

Pollution Prevention and Toxics; DOE’s Office

of Industrial Technology; and the National

Science Foundation’s Engineering Research

Centers, see table 6-5), but OTA found that the

efforts sponsored by different offices and

agencies have often been undertaken independently with little or no coordination among them.

Promoting system-oriented design solutions.

Taking advantage of the opportunities for

system-oriented green design requires that the

economic performance and environmental impact of industries or sectors be viewed in an

integrated way. Individual companies have

little incentive to promote an overall greener

vision of their sector. A greener transportation

sector, for example, may involve not only

improved vehicle fuel efficiency, but better

management of materials used in automotive,

rail, and aviation applications, as well as

changes in urban design. A coordinated, interagency perspective could spur a more holistic

analysis of total sectoral issues, through forums, grant programs, etc.

Harmonizing State and Federal environmental

product policies. In the absence of Federal

guidance, State and local governments have

passed a diverse array of laws affecting the

●

environmental attributes of products (table

6-2). Industry objects to the prospect of having

to comply with a different environmental regime in each State or county, arguing that this

is inefficient and inhibits interstate commerce.145

Environmentalists generally defend the right of

each local community to set environmental

standards as it sees fit. An interagency forum

for discussion and policy development could

help define the circumstances under which

Federal standards preempting State and local

environmental laws may be justified, and

where they are not.

Coordinating policy development on international aspects of the environment, technology,

and trade. At present, responsibility for development of U.S. policy in these areas is not

clearly defined, and each Federal agency has its

own agenda.146

New Institutions for

Environmental Technologies

In Japan, the Ministry of International Trade and

Industry (MITI), which has responsibility for both

trade and competitiveness, is also involved in

implementing Japan’s new recycling law. MITI’s

involvement is expected to be a strong inducement

for companies to comply in a timely way.147 In 1992,

a new MITI-run laboratory, the Research Institute

for Innovative Technology (RITE) was launched to

promote new technologies for improving environmental quality.148 149 In the United States, however,

there is no comparable institution that can address

trade, competitiveness, and the environment in a

coherent way.

Recently, several proposals have been made to

establish anew institutional focus within the Federal

Government for integrating environmental and tech145 For=mple, the~emi~ Sp~~tie5~~ac~a5 Association hasfded suit in California alleging that California’s label@ rec@rementsunder

Proposition 65 should be preempted by Federal precautionary labeling requirements of the Federal Insecticide, Fungicide, and Rodenticide Act and the

Federal Hazardous Substances Act.

146 Wm A. Ni~, “rmprovirlg U.S. ~t~agency Coorwtion of Internatioti Environmental policy Development” Environment, VO1. 33, No.

4, May 1991, p. 10.

147 ~vironmen~ Rmomccx Limited, op. cit., footnote 136.

14S Jamb Mc sc~w~er,~~q~een: ~Japa Environment MMm anoppo~~ forNew Technolo@es,* WazzstreetJour@ Junes, 1992,

p. Al.

149 m’srese~chobj~tives include developmmtof biodegradable plastics, bioproduction of hydrogen fuels, newmetalrecovery methods, ~dnew

carbon dioxide fixation processes.
Chapter 6--Policy Options and the Challenge of Green Design . 107

nological concerns.

150 These include creating a new

Office of National Environmental Technologies

within EPA, an independent National Environmental Technologies Agency, a National Institutes

of the Environment (analogous to the National

Institutes of Health), and a National Environmental

Technologies Laboratory within DOE’s national

laboratory system.151

A new institutional focus within the Federal

Government for environmental technology could

help coordinate Federal efforts to promote various aspects of green design, and provide a home

for promising new fields of research such as

industrial ecology (see chapter 4), that do not fit

readily within any agency’s mission. However,

OTA does not foresee that a separate institution

dedicated exclusively to green design would be

appropriate. By its nature, green design is problemoriented: the appropriate design choices depend on

the specific environmental problems to be addressed, and on the particular requirements of

various products and industries. For example, packaging designers, auto designers, pesticide formulators, and architects have different information requirements, and operate under different constraints.

These would be difficult to address through a single,

generic institution.

Interagency Groups

Interagency task forces and committees also

provide a mechanism for improving Federal coordination in areas such as environmental policy where

no single agency has jurisdiction. In recent years,

several interagency groups have been formed to

address environmental concerns,152 for example: the

Council on Federal Recycling and Procurement

Policy (created in October 1991 to oversee agency

recycling actions); the Federal Interagency Task

Force on Environmental Labeling (EPA, FTC, and

the U.S. Office of Consumer Affairs); the Ad Hoc

Committee on Risk Assessment (established in 1990

to harmonize risk assessment approaches among

Federal agencies); the Interagency Committee on

Environmental Trends (ICET was reactivated by the

Council on Environmental Quality in 1991 to

coordinate the environmental information activities

of various Federal agencies); and the Interagency

Task Force on Trade and Environment (led by the

Office of the U.S. Trade Representative (USTR)). In

1990, the White House established a subcabinetlevel Environmental Policy Review Group under the

Domestic Policy Council to review domestic policy

issues and improve coordination.153

Some relevant interagency collaborations are also

being formed on an ad hoc basis. For instance, EPA

is working with the Department of Agriculture to

promote waste prevention in agricultural chemical

use. EPA, DOE, and DOC are collaborating in a joint

grant program with States to fund research on

reducing the environmental impacts of industrial

processes.

154

Congress could establish a permanent cabinetlevel council charged with the responsibility of

ensuring that environmental concerns are integrated into all Federal policies. This might take

the form of an expanded Council on Environmental Quality, or a new Environmental Policy

Council with its own permanent staff.155 156 To be

taken seriously, though, such a council would have

to enjoy the full support of the President.

Alternatively, Congress can use its oversight

powers to ensure that the activities of existing

interagency groups are consistent with green

design. For example, it can ensure that: waste

prevention is incorporated into procurement initiatives developed by the Council on Federal Recycling

and Procurement Policy; mechanisms for coordinating Federal data collection on toxic materials flows

are considered by the Interagency Committee on

Environmental Trends; and that the USTR-led Task

Force on Trade and the Environment has adequate

150 SCX “Se~te, Ho~Mem~rsCr~tBi~ To Push Federal ‘Green’ Technology Policy,’* Znside EPA, July 3, 1992, p. 17; Flelen Gwmgb “G=

Research Gains Ground in Americ~” New Scz’enzist, Apr. 18, 1992, p. 8; BradenAllenby, AT&~ “Why We Need a National Environmental Technology

Laboratory (And How To Make One),’ unpublished draft.

151 At r.his writig, these and other propos~s wme under review by the Task Force on Environmental Research and Development of the @egie

Commission on Science, Technology, and Government, and Natiomd Academy of Sciences’ Committee on Environmental Research.

152 Co~ciI on Env~o~en~ Quality, op. cit., footnote 8.

153 Wilfim A. Nive, op. cit., foomote 146, p. 32.

154 The prowm is @I~ Natioml Industrial Competitiveness through Eftlciency: Energy, Environment, Economics (NICE3).

155 MV& L. ~“A Ned for New Approaches,” EPA Journal, Mayi3une 1992, p. 7.

156 U.S. EnV~O~en~ Protwtion Agency, Science Advisory Board, op. cit., footnote 98, appendix C, p. 56.
108 ● Green Products by Design: Choices for a Cleaner Environment

policy guidance in international negotiations on

environmental product policies.157

Technology With a Green Lining

Regardless of whether Congress creates any new

environmental technology institutions, OTA believes it makes sense to integrate environmental

concerns more thoroughly into each agency’s ongoing programs. One recent study has developed a list

of ‘‘environmentally critical technologies. ’’158 But

ideally, there should be an environmental component to each of the “critical” technologies on the

lists already assembled by the Office of Science and

Technology Policy, the Department of Commerce,

and the Department of Defense. The goals of waste

prevention and better materials management could

be integrated thoroughly into NIST’s Advanced

Technology Program,159 the recently announced

Manufacturing Technology Initiative,160 and the

Advanced Materials and Processing Program.161

Congress can use its oversight powers to ensure

that both new and existing technology development programs have an environmental dimension.

In the end, the institutional details are less

important than a recognition on the part of Congress

and the Administration that Federal leadership is

needed to take advantage of opportunities like green

design that do not fall neatly within the mission of

any single agency.

A STARTING POINT

Many of the options discussed above would not

immediately affect the way products are designed.

Research to define environmental risks and understand life-cycle materials flows will take time.

Changes in the curricula of design and engineering

schools will affect the next generation of designers.

And changes in the tax code to internalize the

environmental costs of materials and energy use and

product disposal do not appear to be on the political

horizon, particularly in an era of concern about

economic growth and U.S. industrial competitiveness.

OTA believes that such long-term changes are

essential if the United States is to be a world leader

in green design. But a shorter-term strategy is also

important to ensure that existing momentum is not

lost. The following is a package of options Congress

might consider that could be implemented relatively

quickly, and would not be very expensive:

Require all Federal agencies to conduct a

thorough review of their regulations and procurement policies (including military specifications) that may discourage waste prevention

and better materials management, and make

recommendations for changes. These changes

would be consistent with the Federal Recycling

and Procurement Policy (Executive Order 12780)

and would not require any new legislative

authority.

Provide funding to EPA to expand the Pollution

Prevention Information Exchange System to

include all Federal and State activities relevant

to green design in a single place. An electronic

network would stimulate cross-fertilization of

current projects and help eliminate duplication

of effort.

For products with significant environmental

impacts (e.g., autos, paper, pesticides, etc.),

provide funding through the appropriate agencies for intensive workshops that would bring

together professionals associated with various

phases of a product’s life cycle (e.g., designers,

suppliers, manufacturers, distributors, consumer

advocates, and waste management providers)

to discuss opportunities for coordinated action

for waste prevention and better materials management.

157 u.S. con~us, C)fflceof Technology Assessment Trade andEnvironment: Conjlicts andOpportunities, 0~-BP-ITE-94(Washingtow DC: U.S.

Government Printing Office, May 1992).

158 George R. Heato~ Jr. et al., “Backs to the Future: U.S. Government Policy Toward Environmentally Critical Technology,” World Resources

Institute, Washington, DC, June 1992.

159 neA~proFmisp rimarilyonented toward enhancingU.& competitiveness. Ofthe27ATPgrants awarded in 1992, severrdareindirectly related

to environmental concerns, though only one is directly related (a project on plastics recycling).

~m (,T=~oloW ~tiative ~~t~,~~ Science, vol. 255, w. 13, 1992* P. 1350.

161 A n~er of envfioment-relat~ projects are propo~d in Adv~ced ~te~ and proc&w@: me Fiscal Year 1993 prOgr~ Op. Cit., fOOIIIOte

51.
Chapter 6--Policy Options and the Challenge of Green Design ● 109

● provide funding for a national green design A design competition and national award would

competition and establish a prestigious Nation- generate new ideas for designers across the

al Green Design Award similar to the Mal- country, and give consumers a better sense of

colm Baldridge National Quality Award.162 163 the possibilities.

162 U.S. congress, Offke of Technology Assessmen~ Facing America’s Trush, op. cit., foo~ote 109, P. ~.

163 me ~~lmB~~dgeAW~d does include criteria such as waste preventio~ but the environment is not actmtral focus. StX “MakmlmBsltidge

National Quality Award, 1992 Award Crite~” available from the U.S. Department of Commerce, Technology A&mm“ “Stratioq Washington DC, 1992.
Chapter 7

Guiding Principles for

Policy Development
Contents

Page

GENERAL PRINCIPLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113

Principle 1: Identify the Root Problem and Define It Clearly. . . . . . . . . . . . . . . . . . . . . . . . . . . . 113

Principle 2: Give Designers the Maximum Flexibility That Is Consistent

With Solving the Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 114

Principle 3: Encourage a Systems Approach to Green Design . . . . . . . . . . . . . . . . . . . . . . . . . . 115

GREEN DESIGN IN PERSPECTIVE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116
Chapter 7

Guiding Principles for Policy Development

As discussed in the preceding chapter, the flow of

materials and products through the economy gives

rise to environmental impacts that are not adequately

accounted for under current environmental policies.

Table 6-6 lists a variety of regulatory and marketbased options that have been proposed to address

these impacts. These involve government intervention at various stages of the product life cycle,

ranging from taxes on production of virgin materials

to waste disposal fees. All of these options could

have an impact on the product design process.

What criteria can policymakers use to evaluate

these options? The Office of Technology Assessment (OTA) suggests three guiding principles that

can help to shape environmental policies that

encourage, rather than inhibit, green design:

. Identify the root problem and define it clearly.

. Give designers the maximum flexibility that is

consistent with solving the problem.

. Encourage a systems approach to green design.

These principles are developed further below. The

chapter concludes with a broader perspective on the

significance of green design for U.S. competitiveness and environmental quality.

GENERAL PRINCIPLES

Principle 1: Identify the Root Problem and

Define It Clearly

One of the biggest challenges in developing a

policy is clearly defining the environmental problem

to be addressed. Often, products and waste streams

have multiple environmental impacts that cannot be

easily disentangled. For example, policymakers may

be concerned with the quantity of a particular waste

stream, its toxicity, or its persistence in the environment. Policies aimed at solving a problem at one

stage of the life cycle may have unintended negative

effects at another stage: for example, requiring

automobiles to be made from currently recyclable

materials could adversely affect their fuel efficiency.

Inevitably, tradeoffs and value judgments must be

made to determine which environmental impacts are

the most important.

Despite the difficulty, the discipline of defining

the problem clearly is critical to defining an appropriate policy response. In the absence of a clearly

defined problem, it becomes easy to confuse means

and ends. In the Resource Conservation and Recovery Act (RCRA) reauthorization debate, for example, the problem is often framed in terms of the large

quantity of municipal solid waste being generated.

But a solution often put forward is to mandate higher

recycling rates—as if the problem was that recycling

rates are too low. The figure of merit for measuring

progress then becomes higher recycling rates, instead of less waste generated.

This approach misses the point that recycling is

only one of several means to reduce the quantity of

solid waste destined for disposal. Perversely, an

exclusive emphasis on recycling could even lead to

more waste being generated, especially if such

emphasis discourages designs featuring waste prevention. If the objective is to reduce the amount of

solid waste generated, municipal solid waste policies and government procurement programs should

make allowances for product designs that feature

waste prevention.

Without a clearly defined problem, there is a

tendency to focus on the most visible environmental

issues, rather than those that are the most important.

Recent examples include proposals to ban heavy

metals from packagingl (despite the fact that packaging is a minor source of heavy metals in landfills and

incinerators) and proposals to regulate municipal

trash (while the much larger problem of industrial

solid waste has not been addressed). 2

A clearly defined problem can also help to set

priorities. For example, although the dissipation of

toxic materials in the global environment is a

growing problem, not all toxic chemicals an d

products are of equal concern. Treating them as

equal can divert attention and resources from truly

1 Model legislation developed by the Coalition of Northeastern Governors’ Source Reduction Task Force has been passed in 10 States,

z U.S. Cogess, OffIce of TechnoIo~ Assessment Managing Industrial Solid Wastes From Man~actunng, Mining, Oil and Gas production, ati

Utility Coal Combustion, OTA-BP-O-82 (Washington, DC: U.S. Government Printing OffIce, February 1992).

–113–
114 . Green Products by Design: Choices for a Cleaner Environment

high-risk chemicals and waste streams.3 Similarly,

comprehensive reporting requirements on industrial

use of all toxic materials are not necessarily cost

effective. Proposals to require companies to report

on their use of hundreds of additional chemicals,

without distinguishing those chemicals that are of

greatest concern, could generate a massive paperwork burden without significant environment benefits. 4

In reauthorizing RCRA and other environmental

legislation, Congress has an opportunity to refocus

attention and resources on the key problems associated with current materials flows. If it frames the

objective in terms of reducing the generation of

wastes, especially those that pose the greatest risks,

it will encourage the design of products that use

resources efficiently and waste management programs that are cost-effective. If, on the other hand,

it frames the objective in terms of increased recycling rates, and if it fails to distinguish high-risk

waste streams from low-risk waste streams, it may

encourage less efficient product designs and less

efficient waste management programs.

Principle 2: Give Designers the Maximum

Flexibility That Is Consistent With

Solving the Problem

Materials technology options are proliferating

rapidly, and product impacts on the environment are

multidimensional. This suggests that policies should

be crafted to give designers as much flexibility as

possible, within a framework that protects human

health and the environment. This can be accomplished by several means, as discussed below.

Voluntary Agreements With Industry

Perhaps the greatest flexibility can be achieved

through negotiated voluntary agreements between

government and industry. Such agreements tend to

be easier and faster to implement than legislation

and regulations, and may be attractive to industry

because it has more control over the targets and

timetables. Several countries in Europe are relying

more heavily on voluntary negotiations with industry to achieve waste reduction goals, especially the

Netherlands, Germany, Sweden, and Denmark (see

chapter 5). In the case of the German proposals

requiring manufacturers to take back packaging and

automobiles, industry has been given the opportunity to develop its own system for collecting and

recycling the products before more heavy-handed

regulations or mandatory deposit-refund systems go

into effect.

In the United States, the Environmental Protection Agency (EPA) is also moving in the direction of

voluntary programs; examples include the 33/50

Program and the Green Lights Program.s An example at the State level is Massachusetts’ Toxics Use

Reduction Act, which emerged from negotiations

involving government, industry, and public interest

groups. Under this law, companies are required to

develop facility plans with self-set goals to reduce

the use-not just the release-f toxic chemicals.6

It must be said that in most cases, such voluntary

agreements are driven by public and political

pressure, the threat of tough new laws and regulations, or imminent enforcement actions. In general,

credible mechanisms for monitoring and enforcement of voluntary agreements are still being developed.

Flexible Regulations

Regulations affecting product design can be

crafted with built-in flexibility. For instance, an

important policy objective is to find ways to credit

waste prevention in recycling legislation and in

government procurement programs for recycled

goods. One option is to provide alternative criteria

for acceptable products; instead of imposing mandatory recycled content requirements for packaging,

acceptable packaging could contain a certain percentage recycled content or a certain percentage

weight reduction, etc.7 This more flexible approach

takes into account the inherently multidimensional

3 Michael M. Segal, “Spilled Some Salt? Call OS~” Wall Street Journal, July 9, 1991, p. A16.

g S=, e.g., te5~ony of the m~mn Petroleu Institute, before the Subcommittee on Thnsportation ~d H-dous w~fis,HOW Committ=

on Energy and Commerce, Mar. 10, 1992.

s U.S. Environmental Protection Agency, “Pollution Prevention Resources and Training Opportunities in 1992, ’’EPA/56O/8-92-OU2, January 1992,

p. 84; John S. Hoffmaw “Pollution Prevention as a Market-Enhancing Strategy: A Storehouse of Economical and Environmental Opportunities,”

Proceedings of the National Academy of Sciences, vol. 89, February 1992, p. 832.

G Km @iser, “ne Greening of Industry,” Technology Review, August/September 1991, p. 64.

T ‘rh.is approac~ Originally develo~ by the Massachusetts Public Interest Research Group (MASSPIRG), h become Pm of the R~

reauthorization debate.
Chapter 7--Guiding Principles for Policy Development ● 115

nature of green design, and helps to avoid forcing

suboptimal design solutions to the solid waste

problem.

One difficulty with this approach is that a more

flexible regulation may be more expensive to

monitor and enforce. For example, waste reduction

is difficult to measure. It is likely to be easier to

verify that a package contains a certain percentage of

recycled content than to verify that it uses a certain

percentage less material than a comparable package

did 5 years ago. It seems likely that industry will

have to bear the burden of demonstrating compliance with flexible regulations if this approach is

going to work.

Economic Instruments

Market-based policy instruments such as emissions taxes, tradable emissions permits, or depositrefund systems will generally provide a more

flexible environment for product design than regulations, because designers are free to make choices

based on minimizing overall costs. Economic instruments may be used in place of regulations or as a

supplement to make their implementation more

flexible and cost effective. For example, a regulation

requiring recycled content in products may be

implemented more cost effectively by establishing a

tradable recycling credit scheme to encourage those

manufacturers who can incorporate secondary materials most cheaply to do s0 .

8

A potential disadvantage of market-based instruments such as tradable recycling credits is the cost

of monitoring and enforcement. For example, verifying that a manufacturer has purchased sufficient

credits to cover the virgin material content of his or

her product may be difficult. Such market-based

instruments may work best for a limited number of

products of special concern. 9

Principle 3: Encourage a Systems Approach

to Green Design

Designers can control many of the environmental

attributes of products, but they have only a limited

ability to influence the systems by which products

are manufactured, used, and disposed (see chapter

4). For example, a designer can make a product more

recyclable by making it easier to disassemble into

component parts, but if there is no infrastructure in

place to recover and recycle the product, the benefits

of the design changes are nullified. Coupling product design with recycling implies the formation of

new relationships among materials suppliers, manufacturers, and waste management providers. Often,

however, the incentives for changing these interfirm

linkages are lacking; companies may also have large

capital investments in existing production and distribution networks. Therefore, policy incentives are

needed to provide the impetus for change.

Incentives for a Systems Approach

A system-oriented design approach can be encouraged by improving the linkages between design

decisions and their environmental consequences.

This can be accomplished either directly by regulation, or indirectly through taxes or other economic

instruments that internalize environmental costs.

Recycled content regulations or manufacturer

take-back requirements are examples of regulatory

coupling between two stages of the product life

cycle: manufacturing and waste management. These

regulations can help make solid waste concerns a

key design consideration. For example, the proposal

of the German Government to require auto manufacturers to take back and recycle their cars has

stimulated designers to rethink the entire ‘ecology’

of auto production and disposal (box 4-F). Perhaps

to head off similar regulation in the United States,

Ford, General Motors, Chrysler, their suppliers, and

the auto recycling industry have formed a consortium called the Vehicle Recycling Partnership to

address the recycling issue.10 However, as discussed

in chapter 6, such take-back regulations may be

more efficient for some products (especially highvalue durable goods or products that pose special

waste management problems) than others.

Economists have long argued that it is not

necessary to close materials cycles through recycling regulations if the prices of goods and services

reflect their full social costs .11 If the economic circle

g Michael H. Lev@ “Implementing Pollution Prevention: Incentives and Irrationalities, ” Journal ofAir and Waste Management Association, vol.

40, No. 9, September 1990, p. 1227.

9 Organisation for Economic Opportunity and Development, Environmental Policy: How To Apply Econom”c Instruments, Paris, 1991, p. 107.

10@March 16, 1992, organizers held the First Vehicle Recycling Partnership Forum in IJ=bom, ~.

11 Willim D. Nortius, “The Ecology of Markets,” Proceedings of the National Academy of Sciences, vol. 89, February 1992, p. 843.
116 . Green Products by Design: Choices for a Cleaner Environment

is closed, they say, the market will sort out the most

efficient systems of production and materials management. Notwithstanding these advantages, however,

environmental policies in all countries are primarily

based on regulations. In part, this is due to the fact

that no mechanism exists to establish the “true”

value of environmental services. Another reason is

that environmental taxes tend to be politically

unpopular.

However, there is now renewed interest in the use

of economic instruments in environmental policy, if

not to replace regulations, at least to supplement

them and help make them work more efficiently.12

There is also interest in the idea of shifting the tax

burden from socially desirable activities such as

savings and work to undesirable activities such as

pollution. 13

Such a shift could have a dramatic impact on the

systems by which products are manufactured, distributed, used, and disposed. For example, a phasedin $100 per ton carbon tax on fuels could not only

encourage more efficient use of materials and energy

in production systems, but could also transform

consumption patterns and raise over $100 billion in

government revenues.14

GREEN DESIGN IN PERSPECTIVE

How should one view the significance of green

design as a competitive and environmental strategy?

As a competitive strategy, green design can help

manufacturers generate less waste and reduce production costs at the same time.15 As waste disposal

costs and regulatory compliance costs go up, the

environmental attributes of products will necessarily

become more important to consumers and investors.

Europe and Japan are already moving aggressively

to integrate ‘‘clean’ technology and products into

their industrial strategies for future competitiveness,

l6 and international trade will increasingly be

influenced by environmental concerns.17 All of these

trends suggest that having an environmental dimension to one’s design capabilities will be an important

competitive asset in the future.

As an environmental strategy, green product

design offers a new way of addressing environmental problems. By recasting pollution concerns as

product design challenges, and particularly by encouraging designers to think more broadly about

production and consumption systems, policymakers

can address environmental problems in ways that

would not have been apparent from a narrow focus

on waste streams alone.

However, the significance of green design for

overall environmental quality is harder to assess.

Individual designers will no doubt find many

opportunities to reduce wastes and increase production efficiencies. But designers operate within the

constraints of available manufacturing process technologies, waste management infrastructure, and

government policies on resource use and economic

development. For instance, a housing development

built on an environmentally sensitive wetland can

hardly be considered green, even if the units are

energy efficient and made with recycled materials.

The potential of green design to address environmental problems is therefore contingent on broader

environmental policies.

As discussed in Chapter 3, U.S. environmental

policies are currently based on the environmental

protection paradigm, being concerned mainly with

ameliorating the effects of human activities on the

environment. 18 Generally, this has meant end-ofpipe pollution controls and after-the-fact cleanups

where allowable pollution limits have been exceeded. Recently, however, the emphasis has begun

to shift toward waste prevention strategies.

12 RobertWo~~d RobertN. StaVinS, “Incentive-BasedE nvironmental Regulations: ANew EraFrom an Old Idea?” Energy @Enviromentd

Policy Center, John F. Kennedy School of Government Harvard University, E-90-13, Cambridge, MA, August 1990.

13 See, e.g., @orge Heaton et al., Tran~orming Technology:An AgenalaforEnvironmentally Sustainable Growth in the 21st Century (washgto%

DC: World Resources Institute, April 1991).

14 U.S. co~ess, co~ssio~ Budget Office, Carbon Charges asa Response to Global Warming: The Efiects of Taing Fossil Fuels (was~gto~

DC: U.S. Government Printing Offke, August 1990).

15 Bmce Smart (cd.), Beyond compliance: A New Industry View of the Environment (Washington DC: World Resources ~ti~te. APfl 1992).

16 See, e.g., Jacob M. Schlesinger,”~ Green: InJapm Environment Means an GpportunityforNew Technologies,’ Wall StreetJournal, June

3, 1992, p. Al.

17 U.S. Congres5, C)illceof T~~ology Assessmen~ Trade andEnvirontnent: Conj7icts and Opportunities, OTA-BP-ITE-94 (Wi_iSh@tOU Dc: Us.

Government Printing Office, May 1992).

18 MiC~elE. Colby, EnVirOn~ntal~a~ge~ntin Development: TheEvolution ofParadigms (Washington, DC: T’he World Bmk, D=ember 19~).
Chapter 7-Guiding Principles for Policy Development ● 117

In the context of the environmental protection

paradigm, green design can be a useful tool to

increase industrial efficiency and to complement

waste prevention strategies. But critics of this

paradigm argue that simply increasing the efficiency

of materials and energy use and reducing pollution

rates may not be enough to ensure the future survival

of the ecological systems upon which the economy

and human life depend. It is quite possible to destroy

the environment while continuing to become more

efficient. Progress must be measured, these critics

say, not by marginal reductions in pollution based on

last year’s levels, but by cumulative damage to

ecological systems and their general sustainability.

Over the years, several national commissions and

studies have examined the appropriate Federal role

in managing resource use and materials flows.19 The

focus of these studies has gradually shifted from a

concern with ensuring the availability of future

resources for industry to a concern with managing

materials use under an increasing number of constraints, including environmental constraints .20 Nevertheless, current U.S. environmental policies are

not explicitly concerned with managing the physical

flows of energy and materials through the economy

in ways that are ecologically ‘‘sustainable. ” The

Federal Government has been reluctant to address

issues of materials management directly, preferring

to leave these decisions to the States and private

industry. 21 Despite its title, for instance, the Resource Conservation and Recovery Act is primarily

concerned with regulating the disposal of hazardous

wastes, not conserving or recovering resources.

Both the resource management and the ecodevelopment paradigms are explicitly concerned

with conservation and sustainability of materials

use. In the case of the resource management

paradigm, this is accomplished through closing the

economic loop by internalization of environmental

costs; in the eco-development paradigm, the emphasis is on substituting renewable for nonrenewable

resources, reducing use of toxic chemicals, and

closing materials loops through recycling of nonrenewable resources. 22 Under either of these paradigms, green design is not simply a useful tool, but

an essential strategy for resource conservation and

sustainable materials management.

In a world where population growth and economic

growth put increasing pressures on natural resources

and ecosystems, the dominant paradigm upon which

environmental policies are based can be expected to

evolve from environmental protection toward resource management and eco-development.23 Policies in several countries, especially Germany and the

Netherlands, are already beginning to reflect this

shift (see chapter 5). As this evolution occurs, the

importance of green design can be expected to grow.

Therefore, policymakers should strive to make green

product design an integral part of strategies to

improve competitiveness and environmental quality.

OTA’S investigations suggest that simply providing better information to designers and consumers

about the environmental impacts of products and

waste streams will not be enough. To move ahead,

policies must provide a closer coupling between

design decisions and their environmental consequences. The challenge to policymakers is to choose

a mix of regulatory and economic instruments that

target the right problems and give designers the

flexibility to find innovative, environmentally elegant solutions.

19 Forareview, see Resource Conservation COmmit@% “Choices forConservatioq’ ‘FinalReport to thePresident andCongress, SW-779, July 1979,

p. 33.

~ Ibid.

21 OTA ~previously discus~d tie v~ue of a natio~ mate~ management policy in the context of municipal solid waste. See U.S. Congress,

Office of Technology Assessmen~Facing America’s Trash: WhatNextforhfunicipal So2id Waste? (Washingto~ DC: U.S. Government Printing Office,

October 1989), p. 6.

22 ~c~el E. Colby, op. cit., fOOmOte 18.