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Two Steps Forward

ULE 880: The World Weighs In

We've just reached the halfway point in the public comment period for ULE 880 -- Sustainability for Manufacturing Organizations -- the company-level sustainability standard my colleagues and I helped develop -- so it's a good time to take stock.

First, some background. Three weeks ago, and UL Environment (ULE), part of the venerable standards organization Underwriters Laboratories, publicly released a draft of the above-named standard, which rates large and midsized manufacturers across more than 100 indicators covering environment, workforce, community, governance, and supply chain. ULE 880 is intended for use by companies, public agencies, and institutional buyers to assess themselves and their suppliers and trading partners.

As I've previously written, this is a project on which a small group of us have been toiling for as long as eight years. When we joined forces with UL Environment last year, it elevated the project to a new level, leveraging UL's long history of credibility and integrity. UL is a household brand that's historically been synonymous with "safety," its logo appearing on 20 billion products a year. In 2009, it entered the sustainability realm with the creation of UL Environment.

July 29, when the standard was released, was a rather anxious moment for the ULE-GreenBiz team. For the first time, this standard -- the first-ever comprehensive company-level sustainability standard from an independent, global certification agency -- would be available for review and detailed comment. Friends, colleagues, and outright strangers could have at it.

The commenting process, as previously described, takes place online (via a ULE Web-based tool), is open to everyone (you must register in order to receive access to the commenting tool), and is transparent (all comments and their authors are publicly viewable).

So, as we reach the halfway mark on the 45-day comment period, how's it going?

To date, nearly 600 individuals have registered to comment -- the largest public stakeholder response Underwriters Laboratories has had on any standard in its 116-year history. The registrants have come from 25 countries and six continents. (Apparently, no one in Antarctica is interested.) They represent a diverse range of organizations, including large companies (about 20 percent of the Fortune 500), smaller firms, national and subnational government agencies from around the world, nongovernmental organizations, academics, trade associations, and others.

All in all, a terrific turnout.

"It's generated a huge amounts of interest," says Craig Coulter, one of the project leads at UL Environment. "There's a great demand both for the content of what we're trying establish in the sustainability realm, and the excitement around UL's involvement in this space."

Of course, the record-breaking registration figures don't reflect the actual number of comments received. That is far smaller but is expected to grow as the September 14 deadline approaches.

I talked with two of the early commenters to get their feedback -- not necessarily about the standard, but about the commenting process.

"To be frank, it was a tad bit onerous because the standard is very detailed," said Sarah Brooks, Senior Advisor and Acting Senior Manager, Sustainable Business, at The Natural Step Canada. "That's, of course, to the benefit of the standard, but it puts the onus on the reviewer to be focused and to stay with it. I did it over two days."

Brooks' diligence paid off. She left a number of very insightful comments throughout the document.

"I think the standard is very ambitious," she told me. "I think it's something that will be both challenging and inspiring to those organizations that are ready. For those that aren't ready, it may be a little bit frightening for them but also perhaps a very necessary kick in the pants."

For the record, the standard will have three levels of certification: an entry level, a mid level, and a high level. The highest level, which might be likened to the "Platinum" level of the LEED green building standard, will be extremely hard to attain, while the entry level should be accessible to companies that have a solid sustainability framework in place and are proactively implementing it.

Bruce Klafter, Managing Director, EHS, and Head, Corporate Responsibility & Sustainability, at Applied Materials, Inc., had a positive experience with the online tool. "Mechanically, it was very easy," he told me. "The [tool] was set up very well. It took me just one or two tries before I figured it out."

Klafter appreciated that he was able to see everyone else's comments. "You could quickly pick up the flavor of where they were coming from and what sorts of issues they had. That was very useful."

Both Brooks and Klafter commented on the size of the standard -- more than 60 pages when printed out -- and the challenge it presented in providing detailed comments. "It's a very extensive document," said Klafter. "I think I first printed out portions, marking them up, then going back into the tool. I think you could easily get fatigued trying to march through the entire thing. So, I concentrated on sections that were of greatest interest to me."

I asked Klafter what he'd advise those who haven't yet dived in -- or weighed in -- on ULE 880. "I think you ought to read it through as carefully as you can before you jump in and start commenting on particular sections," he counseled. "The initial sections describing the intent and definitions and all the sections together give you a better understanding of where particular sections are going, and if you looked at just a few sections in isolation you might not get that."

Thanks to Sarah and Bruce for being pioneers. We'll be looking forward to more comments and feedback on the standard -- and the commenting process -- in the coming weeks. As I said, the comment period ends September 14.

What happens after that? Lots! Starting September 15, the ULE and GreenBiz teams will review the comments and make changes, then issue a revised draft. In mid November, we'll convene a Stakeholder Advisory Panel, at which a couple dozen or so individuals will hold a facilitated discussion about the more complex issues that arose from reviewers' comments. A final draft will follow.

Meanwhile, we're already holding conversations with major accounting and environmental auditing firms about providing verification services for ULE 880, and with major companies about piloting the standard and certification. We're talking with both companies and public agencies about serving as demand drivers -- that is, integrating ULE 880 into their procurement and supply-chain management processes.

But for now, it's all about hearing from a rich diversity of voices. I strongly encourage you to weigh in on the standard by registering to comment. I promise an educational and enlightening experience -- one that will give you deeper insight into the many facets of what it means in 2010 to be a sustainable business.

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