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, GreenBiz.com 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% 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 that presented in providing detailed comments. "It's a very extensive document," said Klafter. "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 both Brooks and Klafter for being pioneers (and for their frank feedback). 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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Introducing ULE 880 - Sustainability for Manufacturing Organizations

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.

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