ULE 880: A New Year’s Report
Today marks another significant milestone in the development of ULE 880 – Sustainability for Manufacturing Organizations, the company-level standard we’ve been developing in partnership with UL Environment. Indeed, a great deal has been going on behind the scenes the past few months, so it’s time for an update.
First, a brief refresher. For more than a year, my team at GreenBiz Group has been engaged with UL Environment to develop and commercialize a company-level standard for sustainability — that is, environmental, social, and corporate governance issues — to be used as a tool for companies, government agencies, and other stakeholders. (I’ve previously provided a history of the project here.)
Last July, we released a draft of the standard for public comment. More than 700 individuals — representing companies, nonprofits, government entities, consultants, trade associations and concerned citizens — registered to review the draft. A subset of them submitted more than 1,500 individual comments on specific segments and indicators in the standard. Both numbers represent record stakeholder engagement in Underwriters Laboratories’ 116-year history.
In November, we convened a subset of stakeholders — roughly 20 representatives of major companies, accounting firms, consultancies, advocacy groups, and government agencies — to provide input to address some of the reviewers’ more challenging comments — ones where there was a wide range of conflicting opinion, for example. And at every step, the ULE-GreenBiz team waded through the feedback, making anything from minor tweaks to major adjustments along the way.
The fruits of those labors are being published today: ULE ISR 880. ISR stands for “Interim Sustainability Requirements,” part of the argot of UL’s standard-making process. If this were software, it would be the pre-release version.
The ISR will be used to pilot the standard with a small group of companies, which we’ll be announcing in the next couple months, and is also being made public for another round of comment. With the combination of additional comments and real-world piloting, the UL Environment-GreenBiz team will finish a final revision and issue the final ULE 880 standard this summer.
A lot has happened to the standard since its debut last summer. I can only summarize it here. The complete rundown can be found in a 256-page “response paper” published today. It provides details of the key comments and how they were addressed by the ULE-GreenBiz team, and includes a lengthy supplement that excerpts some of the 1,500-odd comments.
Among the key issues:
One Size Fits All. By far the most consistent feedback point was whether ULE 880 is applicable across all manufacturing sectors, specifically in the area of performance.
Organizational & Product-Level Indicators. Many stakeholders expressed concern about how and whether to integrate more product-specific indicators into ULE 880.
The Weighting of Domains. In the first publicly available draft of ULE 880, we sought to recognize social and environmental impacts equally, and highlighted governance as an area of particular emphasis in promoting sustainability within an organization. Stakeholders expressed a variety of competing opinions regarding the weighting across domains and indicators.
Organizational Boundaries. We received a number of comments related to setting the boundaries of an organization for the purposes of certification.
Baseline Years. The initial draft of ULE 880 attempted to treat the establishment of a baseline year on an indicator-by-indicator basis. In other words, an organization could have a baseline year of 2003 for a greenhouse gas inventory, but have a baseline year of 2006 for a water inventory. Many stakeholders pointed out how difficult and unmanageable such a mechanism would be for certification purposes, and suggested simplification. The simplest approach, they said, would be to establish a single baseline year for the scope of the standard, yet one arbitrary baseline year would potentially “penalize” companies by not rewarding them for work conducted prior to that date.
- Compliance and Regulation. Throughout the stakeholders comment process, many wanted greater understanding and explanation about how ULE 880 would address compliance and regulation.
I won’t address here how the ULE-GreenBiz team addressed each of these issues in the latest version of the standard — you’ll have to read the ISR, which can be downloaded on ULE’s CSDS, the online tool that we’ve used to collect stakeholder feedback. It’s free, though you’ll need to register. (If you registered previously as a reviewer, you’re already good to go.)
Much of these questions (and several others not mentioned above) point out the incredible complexity of creating a standard of this type. The ULE-GreenBiz team has navigated a thicket of such complexities since we set out on this course, and we feel confident that we’ve come up with practical and pragmatic solutions consistent with our original mission and values.
All told, it’s been a tremendous effort — not just on the part of our respective teams, but on the hundreds of individuals who devoted considerable time and effort to this. We were gratified, even surprised, by the passion and commitment with which people responded to the draft standard — clearly, hours of work for some of them. To all who participated, our sincere thanks.
What’s next? During the coming weeks and months, we’ll be announcing the companies that will be piloting the standard inside their own operations, as well as those that will begin to use it to assess their suppliers. We’ll also be announcing the first of the “Big Four” accounting firms that will sign on as independent auditors for the standard, along with several other parts of the system being built to support ULE 880.
For now, I encourage you to read the ISR document and let us know what you think.