Product Stewardship Stakeholder Group

Transcription

1 Prduct Stewardship Stakehlder Grup Perfrmance Measures A. Backgrund Perfrmance measures prvide a mechanism fr prgram management, versight, accuntability and a way t measure accmplishments. Perfrmance measures relate primarily t the prduct stewardship principles f gvernance and envirnmental and human health prtectin. Establishing perfrmance measures fr a prduct stewardship prgram slidifies the basic principle f allwing the prducers flexibility in hw they establish and run a prgram guided by pre-established and agreed upn perfrmance measures. When perfrmance measures relate t specific prduct and its impacts n human health and the envirnment, such as use f txics, safe management practices, r greenhuse gas, they directly address the principle f reduced envirnmental and human health impacts. Perfrmance measures are intended t prvide flexibility t the prducer as well as prviding a fundatin fr fcusing prgram activities, and tracking and prmting prgram accmplishments. The public interest is served by perfrmance measures because they can, depending n what is established, drive service standards and visibly demnstrate prgress in reducing the lifecycle impacts f prducts. Specific perfrmance measures may vary by prduct r material, recgnizing that each prduct has differences in cmpsitin, distributin channels, waste generatin rates, and end-f-life management ptins. Hwever, there are general types f measures that may be cmmn and useful fr many prducts. Land Quality Slid Waste 811 SW 6 th Avenue Prtland, OR Phne: (503) (800) Fax: (503) Cntact: J. Whitwrth DEQ is a leader in restring, maintaining and enhancing the quality f Oregn s air, land and water. B. Characteristics and types f perfrmance measures When identifying r defining perfrmance measures, key characteristics can help guide the selectin r develpment. The fllwing attributes r questins can help identify the characteristics and type f perfrmance measure that will be mst useful. Is the perfrmance measure useful fr prgram peratins, stewardship, and reprting t the public? Can the perfrmance measure help drive r imprve perfrmance? Can the perfrmance measure cmmunicate prgram utcmes r success clearly? Can data r infrmatin be cllected and reprted reliably and cst-effectively? Des needed data r infrmatin already exist? Can r is data r infrmatin cllected cnsistently ver time t enable trend evaluatins and year-t-year cmparisns? Prduct stewardship perfrmance measures may be quantitative r mre qualitative. Measures generally relate t several majr areas: 1) recvery, reuse, and recycling; 2) material; and 3) envirnmental/health impacts. Examples f the types cmmnly used in prduct stewardship prgrams are described belw: Recvery, reuse and recycling: Cllectin rate expressed as % cllected f the amunt generated r available fr cllectin r % cllected f amunt sld in a given time perid. Reuse, recycling r recvery rate expressed similar t cllectin rates r in per capita amunts. Number f units r weight f material/prducts cllected r recycled. 1 Last Updated: 07/28/10 By: J. Whitwrth

2 Amunt f greenhuse gas reduced, related t the amunt f recvery, reuse, r recycling f the prduct r grup f prducts ver a given time perid. Cllectin cnvenience, measured in terms f gegraphic distributin, ppulatin, distance frm ppulatin served, etc. Type and amunt f public utreach r awareness campaigns. Prduct design imprvements, such as design fr disassembly; design fr imprved durability, upgradeability, r ease f repair. Materials: Amunt f specific txic(s) cnstituents reduced r eliminated per prduct prduced. This culd relate t cnstituents in the prduct r cnstituents generated in the manufacture f the prduct r bth. Pst cnsumer recycled cntent r recycled cntent in a prduct. Greenhuse gas reduced related t the manufacture f the prduct. Prduct packaging imprvements, e.g. light-weighting, eliminatin f secndary packaging, etc. Prduct cntent transparency, e.g. labeling, disclsure, etc. Type and amunt f public utreach r awareness campaigns. Prduct design imprvements e.g. reduced use f txics and materials in prduct and prduct manufacturing prcess. Envirnmental impacts Gvernment prcurement requirements fr prducts that meet established envirnmental requirements such as Energy Star, EPEAT, RHS type txic reductin standards, etc. Txics reductin, prduct design imprvements, and greenhuse gas reductins as stated in the categries abve als are relevant in this categry. Belw is a list prvides examples f perfrmance measures used in existing prduct stewardship prgrams. The list is nt all inclusive, but intended t prvide sme samples t help understand hw perfrmance gals and measures can help establish prgram fcus and accmplishments. The examples d nt include measures related t prduct design r ther upstream lifecycle impact cnsideratins largely because mst f the examples fund fr existing prduct stewardship prgrams pertain t end-f-life management gals. If there is a desire t fcus n prduct design r ther upstream life cycle impacts in a prduct stewardship prgram, then develping perfrmance measures arund thse types f accmplishments shuld be cnsidered. C. Specific examples used by existing prgrams Oregn: The Oregn e-waste law has tw perfrmance measures: 1) each registered manufacturer is required t cllect at a minimum an annual return share by weight f cvered prducts, as determined by the Department based n brand sampling and the amunt f cvered prducts cllected the previus year. 2) Each manufacturer plan and the state cntractr prgram are required t prvide cnvenient and available cllectin ptins fr the public, at n cst t the public. Cnvenient is defined as statewide in urban and rural areas f the state with at least ne cllectin site in each city with a ppulatin f 10,000 r greater and cllectin service in each cunty. The Oregn paint law has ne very general perfrmance measure fr cllectin cnvenience t prvide cnvenient and available cllectin statewide in urban and rural areas f the state. In additin t the cllectin standard in law, the 2

3 apprved stewardship plan has a quantitative estimate set by the prducers t cllect 550,000 gallns f paint in year ne f the prgram, and increasing that amunt by 6% annually in the fllwing years f the pilt Oregn slid waste law, althugh nt a prduct stewardship prgram, establishes bth a statewide gal fr recycling and a gal fr waste generatin. These gals are phased-in and quantifiable. Recycling is 45% f waste generated in 2005 and 50% in Waste generatin is n annual per capita increase in generatin by 2005 and beynd and n annual increase in ttal waste generatin by 2009 and beynd. Wastesheds are als required t set their wn recycling rates, which have cnsequences if nt achieved. Other Prduct Stewardship Prgrams: Eurpean Unin s Waste Electrnic and Electrical Equipment (WEEE) Directive, cvering such prducts as cmputers, mnitrs, televisins, electrical appliances, and lighting, had a 2006 cllectin rate gal f 4kg (8.8 lbs) per persn frm husehlds by There is a new prpsed mandatry cllectin rate f 65% f the average weight f electrical and electrnic equipment placed n the market ver the previus tw years. The WEEE directive has a cmpanin directive, the Restrictin f Hazardus Substances (RHS), which sets restrictins n the use f different hazardus substances in the cvered prducts. Washingtn s Mercury Cntaining Lights Act 2010 has a gal f recycling all end-f-life mercury cntaining lights by Maine s Mercury-added Lamps Law directs husehld mercury-added lamps t be recycled at a rate f 75% f what is sld. The cnsequence if nt achieved is that the state may require mdificatins t the prgrams. The Maine law als establishes mercury cntent standards fr lamps sld in Maine. Minnesta E-waste law sets a graduated gal fr recycling cvered prducts. In year 1 manufacturer s must recycle an amunt equal t 60% f what is sld by weight the previus year. In year tw that amunt increases t 80%. British Clumbia Prduct Stewardship Prgram establishes a general gal fr all prduct specific prgrams f achieving a 75% r higher recvery rate fr prducts sld. In additin prduct specific plans must prvide infrmatin n hw that gal will be achieved ver a reasnable timeline, and may establish additinal perfrmance standards. Ontari Prduct Stewardship Prgram des nt set gals but requires prducers t set targets r gals in their plans. Natinal Carpet MOU has an verall gal f 40% diversin f discarded carpet frm landfilling by There are als sub-gals fr reuse, recycling, and waste-t-energy. (Vluntary prgram) End f Life Vehicle Slutins (ELVS) Prgram has a cllectin target f 80 t 90% f available mercury switches by (vluntary prgram) In additin t the examples abve, it shuld be nted that many prduct stewardship laws in the United States and abrad, as well as vluntary prgrams, d nt require r have perfrmance measures. Reprted infrmatin suggests that prgrams with gals and/r standards perfrm at a higher level than thse withut. Fr example, the EU WEEE prgrams recycle between 55% and 86% f waste prducts, depending upn the cuntry. The British Clumbia prgram cllects 77% f available waste paint and 70% f pesticide cntainers. 3

4 In the mre recent prduct stewardship prgrams adpted in the US it appears that setting a cllectin r recycling rate based n % f waste cllected ut f amunt f prduct sld ver sme established time perid is ften used as the metric. D. Cnsideratins fr use f perfrmance measures Fllwing the adage that yu get what yu measure, deciding what perfrmance measures t put in place fr a prgram requires careful cnsideratin f what the purpse f the prgram is and what is trying t be accmplished. In additin t answering the questin, there are ther cnsideratins t weigh in designing the apprpriate perfrmance measures. The list belw is nt intended t be inclusive, but t tuch n sme f the key pints t cnsider. Benefits Fcus prgrams n results Useful fr public reprting f prgram perfrmance Assure key prgram elements are prvided, e.g. cnvenient cllectin Allw fr prducer flexibility in hw they implement the prgram Target mst imprtant envirnmental sustainability and human health prtectins by putting the fcus n the mst imprtant cncerns related t a specific prduct. Prvide infrmatin that can be cmpared frm year t year and can be used t make adjustments t prgrams as they mature. Cncerns/issues Unintended cnsequences. Fr example, establishing a perfrmance measure fr a particular prduct t increase, by weight, per capita recycling f a prduct might discurage r penalize the light-weighting f a prduct which may result in a greater reductin f envirnmental impacts. It is imprtant t examine the pssible multiple impacts f a perfrmance measure befre deciding n which measure best drives the desired results. If the primary gal f the prgram is t imprve envirnmental sustainability and increase human health prtectin, it is imprtant t cnsider the full life cycle impacts f a prduct in rder t help establish a perfrmance measure that puts the fcus n addressing the impacts that are f greatest cncern. Cst vs. benefit. Cllecting data and infrmatin can be cstly. Imprtant t try and wrk with infrmatin and data already being cllected if pssible. T the extent there are multiple prgrams in varius states and natins that impact the same prducers crdinated measures and data/infrmatin reprting shuld be evaluated. Calculatin f cllectin, reuse, recycling rates based n amunt generated r available fr cllectin can be difficult. Estimating what is available fr cllectin based n hw much is in strage in hmes and businesses, prduct life span, and availability f dispsal data can be cmplicated and highly variable. Measurements based n sales can als be difficult if sales data is nt available n a state by state basis. Requiring disclsure abut txics in prducts r their manufacture can be sensitive and difficult t track and reprt. Cnsistency in data and infrmatin cllectin acrss an industry sectr is challenging when it relates t what is in a prduct and what impacts are generated in the manufacturing prcess and supply chain. E. Variatins n apprach 4

5 In additin t the varius types f perfrmance measures described in sectin B f this paper, there are sme additinal basic pints t cnsider when establishing a prduct stewardship prgram. Use bth quantifiable measures alng with mre subjective quality measures. One des nt have t be used exclusive f the ther if bth will help achieve the prgram purpses. Cnsider phasing in perfrmance measures r establishing a far reaching gal with interim sub-gals. Cnsider wh can best establish the perfrmance measures, the timing f the measures, and the need fr cnsequences and rewards when measures are and are nt met. The vehicle fr perfrmance measure establishment will als impact the ptins fr public input, enfrceability, and the ease f adjusting measures. Optins may include: Prducers as part f their plan Legislatin Cmbinatin apprach with metric in legislatin and prducers in plan setting the actual gal Cnsider prvisins fr adjustments t perfrmance measures ver time bth in terms f what the measure is and/r what the amunt is. Cnsider the link between perfrmance measures and incentives fr accmplishing the prgrams intended purpse. In sme cases it may make sense t establish incentives t achieve an intended purpse f the prgram instead f a perfrmance measure with cnsequences. Or, it may make sense t begin with incentives and ver time mve t perfrmance measures. This will depend n such things as the prduct, the purpse, established prgrams elsewhere, and the state f the industry related t the purpse. F. Discussin Questins Hw imprtant are perfrmance measures fr a prduct stewardship prgram? Shuld they generally be quantifiable, like rates and dates, r mre descriptive in nature, r a cmbinatin f bth? Wh shuld establish perfrmance measures fr a prgram? Shuld measures be set in legislatin, set by the versight agency, set by the prducers in their plans, r sme cmbinatin f these appraches? D prgrams need perfrmance measures t help drive bth upstream and dwnstream prgram achievements? When is it useful t have aspiratinal gals and when shuld perfrmance measures be enfrceable r have cnsequences if nt achieved? G. References and resurces 1. Oregn Dept. f Envirnmental Quality. Review f Prduct Stewardship Prgrams. By K. Panciera. April pp. 2. Envirnment Canada. Envirnmental Stewardship Branch. Perfrmance Measurement and Reprting fr Extended Prducer Respnsibility Prgrams. By Strats, Inc. Octber pp. Appendices 3. Nrthwest Prduct Stewardship Cuncil. Prduct Stewardship in Canada, Legislative Framewrk f Prvincial Prgrams. By Cascadia Cnsulting Grup. March pp. 5

6 4. Canadian Cuncil f Ministers f the Envirnment. Extended Prducer Respnsibility Prgram Measurement and Tracking. By Kelleher Envirnmental and Rbins Envirnmental. December pp. Appendices. 5. Rhde Island Dept. f Envirnmental Management. Cmprehensive Prduct Stewardship Apprach fr Rhde Island: Study and Optins. By Prduct Stewardship Institute, Inc. April pp. 6. Handbk n Husehld Hazardus Waste. Prduct Stewardship: Shared Respnsibility fr Managing HHW. Chapter 7. By Sctt Cassel Published by Gvernment Institutes. 7. Assciatin f State and Territrial Slid Waste Management Officials. Prduct Stewardship Framewrk Plicy Dcument. By the Prduct Stewardship Task Frce f the Sustainability Subcmmittee. Adpted Octber Prduct Stewardship Institute. Recmmendatins fr Cllectin and Recycling Perfrmance Metrics. A presentatin by Jennifer Nash at the 2009 NW Hazardus Materials Cnference. June 3, Califrnia Integrated Waste Management Bard. Prducer Respnsibility: Overview f Plicy Cnsideratins Backgrund Paper Strategic Plicy Cmmittee. June pp. PSSGPefrmanceStandardsWhitepaperfinal72810.dcx Whitwrth July 28,