Last issue, Machine Design carried an article about Underwriter Laboratories’ ULE 880 Sustainability for Manufacturing Organizations. It’s for manufacturers that want to tout their sustainability credentials to eco-conscious consumers. (UL is also working on a version for service-providing companies.)
Here’s a little about the standard. It covers five domains, which cover sustainability, the environment, and even human rights. The domains break down into seven prerequisites, 19 core indicators, 74 leadership indicators, and 25 innovation indicators, and companies can earn 1,025 points after totaling the score from all those indicators. With categories carrying ambiguous titles such as internal stakeholder engagement, product stewardship, workplace integrity, and human-rights issues, the process of filling out the form(s) to apply for certification will probably make income taxes seem simple. And companies must reapply every year or at least be reaudited, showing they improved to maintain ULE 880 certification. But is all this necessary?
There are already established standards that cover these factors. ISO 14001, for example, helps companies protect the environment. OHSAS 18001 covers workplace safety, and OSHA and states have reams of laws covering the same topic. Finally, for those who want proof they’re on the right side of human rights, there’s SA 8000.
It’s also fair to ask how another layer of nonvalue-adding bureaucracy will help companies survive and thrive. All the money, man-hours, and resources poured into gaining ULE 880 certification will not make products better or less expensive. Large companies, such as carmakers and telecommunication firms, might establish a new department to satisfy ULE 880 requirements and handle the paperwork. Some already have a Vice President of Sustainability. Meanwhile, smaller job shops and manufacturers looking to “brand” their sustainability will pile more “small tasks” on already overworked employees. This is yet another distraction from jobs they were hired to do.
If engineers are doing their jobs, products they design and manufacturing processes involved will use as little energy and as few raw materials as possible and still meet EPA, FDA, and applicable regulations. Good engineers also specify legally obtained materials that are least expensive but fulfill application requirements. They don’t get bonuses for increasing the amount of wasted materials or specifying rainforest woods and gold when pine and steel will do. Good engineering is inherently environmentally conscious. And no successful company exposed to real competition can tolerate wasteful designs and remain in business for long.
But sustainability certification has an upside: it creates new jobs. For example, one group of people ready to cash in are the consultants. They will happily become sustainability auditors, willing to oversee a company’s ULE 880 submission. Others will become sustainability facilitators who will gladly (for a fee) navigate companies around ULE 880 pitfalls and toward certification. And as sure as the sun rises, software companies will develop sustainability tools targeted at streamlining ULE 880 certification.
As an experiment, I’d like to run an ULE 880 audit on a medium-sized company’s efforts at gaining that ULE 880 certification. Tote up all the CO2 expelled by clerks verifying and compiling long lists of facts and figures, count the trees cut down to supply the paper, and the coal burnt to power the computers crunching the numbers and processing reports. And don’t forget to account for all productivity lost because the Dept. of Sustainability needs its figures ASAP. I think such an audit would reveal that sustainability isn’t quite sustainable.
— Stephen J. Mraz