Today, a new sustainability standard for companies is being released for public comment: ULE 880 - Sustainability for Manufacturing Organizations, a partnership between UL Environment, a division of Underwriters Laboratories, and my colleagues at GreenBiz.com.
It is a day that I've been awaiting for the better part of a decade.
A 45-day comment period opens today, during which we're hoping you will review the draft standard and provide detailed feedback. (More about that in a minute, but if you're in a rush to get there, click here.)
ULE 880 is the first in a series of company-level standards and certifications that are being produced by this ULE-GreenBiz partnership. It results from about eight years of work — initially by a small team of us in Alameda County, California, and starting last year, between ULE and GreenBiz. (I previously provided the back story to this project here.)
The first draft of the standard is now complete, the product of a Herculean effort spearheaded by my friend and colleague Rory Bakke, director of sustainability at GreenBiz. Rory was lead author of the ULE 880, with assistance from me, a terrific team from UL Environment, and a small group of advisors.
ULE 880 covers five domains of sustainability:
- Sustainability Governance: how an organization leads and manages itself in relation to its stakeholders, including its employees, investors, regulatory authorities, customers, and the communities in which it operates
- Environment: an organization's environmental footprint across its policies, operations, products and services, including its resource use and emissions
- Workplace: issues related to employee working conditions, organization culture, and effectiveness
- Customers and Suppliers: issues related to an organization's policies and practices on product safety, quality, pricing, and marketing as well as its supply chain policies and practices
- Social and Community Engagement: an organization's impacts on its community in the areas of social equity, ethical conduct, and human rights
All told, there are 102 questions (or "indicators") in ULE 880, including 18 in Governance, 45 in Environment, 15 in Workforce, 15 in Customers and Suppliers, and 9 in Social and Community Engagement. The number of indicators doesn't reflect the weight each of these categories holds in the overall standard, however. Environment covers 80 points, Governance and Customers/Suppliers 40 each, and Workplace and Social/Community 20 each. There are also 18 "Innovation Points" — 3 points each for 6 different indicators — that reward companies for going above and beyond the standard.
But that doesn't mean the core standard is a low bar. It was designed to be comprehensive — that is, to the extent that indicators are measurable and verifiable. Among the core principles of ULE 880 is that it be both reasonably attainable (at the lowest level of certification) and a high bar of excellence (and the highest level of certification). This and other core principles behind the standard are spelled out in the document's introduction.
Why does Environment carry a disproportionate weight — 40 percent of the total? Therein lies one of many challenges the GreenBiz-ULE team faced. We set out to create a standard that is comprehensible, consistently applied, credible, measurable, relevant, and for which data is obtainable. As a rule, company environmental data is more widely tracked, analyzed, quantified, and defined consistently than social and governance data. For that reason, this version of ULE 880 is more heavily weighted toward environmental indicators. Over time, as companies seek certification under ULE 880 and the sustainability field continues to mature, we expect to refine the standard and potentially adjust its weighting of specific indicators and across issue areas.
Of course, all of this is subject to feedback, and that's where you come in. The stakeholder feedback period launching today — ending September 14 — is free and open to all. To participate, you must register, after which you'll receive a link to ULE's Collaborative Standards Development System, or CSDS, an online tool Underwrites Laboratories uses to develop its standards. Already, more than 100 companies and thought leaders have registered to review and comment.
In the CSDS, you'll be able to download ULE 880 or read an online version, the latter of which enables you to enter comments. You'll be able to read others' comments, and others will be able to read yours — an open and transparent process. Comments can be as broad or as specific as you wish.
"There's really no comment of a constructive nature that isn't potentially valuable," Daniel P. Ryan, Standards Technical Panel Chair at UL Environment, told me recently. Ryan — who's been with UL for 27 years, most of it in the standard-development process — continued:
"We want the standard to be clear and concise in language so that manufacturers can read a clause and understand what it means, clearly and without ambiguity. Similarly, we want auditors who might be assessing manufacturers to that standard to have the same understanding. So, even if we get comments from someone who is confused, that's really valuable input because it points us to something we thought was clear but obviously needs work."
This is just the beginning of the review process. "After the comment period closes, we'll sort through all of the input, break it down by topic and try to see the different facets of an issue various stakeholders are arguing," explains Ryan. "And then engage a smaller team of sustainability experts of diverse interests that will help guide the standard forward — how we should address the input we received."
The plan is to announce the first pilot companies for ULE 880 later this fall.
During the next 45 days, we're hoping to hear from a broad cross-section of those affected by or interested in ULE 880: manufacturers, assessment and standards groups, regulators, policy makers, procurement officers, sustainability professionals, the socially responsible investing community, and nonprofit sustainability interest groups.
I sincerely hope you will weigh in — and encourage your colleagues and stakeholders to do so, too.


















































































































It's a good question, Claus
Claus,
Thanks for weighing in. The rise of ULE 880 is bringing to the fore a number of great questions, including this one. Creating a certification for a sustainable business is a very tricky matter. On the one hand, it IS a certification. On the other, it isn't exactly claiming that the company is sustainable -- which, as you note, is near impossible.
We certainly don't need reminding about the risks of greenwashing -- that's been at the forefront of our minds since we set out on this course several years ago. But there is a critical need for measuring and assessing companies, even if none of them is -- or ever will be -- perfect. The bigger risk of greenwash comes not from companies that are certified under a measurable, verifiable, and comprehensive standard. It comes from having no standards at all, enabling any company to make claims of environmental leadership, social responsibility, or -- yes -- sustainability.
I would encourage you to join nearly 500 of your colleagues by registering to provide feedback on the actual standard (as opposed to the IDEA of the standard). You can do so at this address: http://www.greenbiz.com/ratings.
Thanks again,
Joel Makower
Executive Editor
GreenBiz.com
Can any company be sustainable?
Dear Joel,
While I don't want to comment necessarily whether yet another standard for manufacturing companies such as ULE 880 is needed beyond ISO 14001, OHSAS 18001 and SA 8000, the headline in Jonathan Bardelline's "Greener Design" editorial attracted my attention: "What makes a sustainable company?"
My counter question would be: Is it possible to define what a "sustainable company" would look like?
Looking at ISO 14021 on environmental claims, my interpretation is actually NO. This standard states that “No claim of achieving sustainability shall be made”, which is based on the insight that “the concepts involved in sustainability are highly complex and still under study... there are no definitive methods for measuring sustainability or confirming its accomplishment”. The deeper reason why I believe no company, product or even individual can claim "absolutely sustainability" any time soon is that what may be sustainable with three, five or seven billion people on the earth may not be sustainable once we reach a population of nine billion with the same material aspirations as the West.
It seems that these days it's up to corporate sustainability managers to remind their friends in the green media about the risks of "greenwashing".
Claus Conzelmann
VP Safety, Health & Environmental Sustainability at Nestlé (a company voted by Sustainable Life Media as food sector leader in its recent "2009 Sustainability Initiatives Report", but that doesn't claim to "achieve sustainability" any time soon, even though we're trying hard).