i.
EPA/744/F-89/100
An Introduction to
EPA's Design for the Environment Program
Jean E. Barker and Beverly L. Boyd
with assistance from Lori E. Lacy
Design for the Environment Program
U.S. Environmental Protection Agency
401 M Street, S.W. (TS-779)
Washington D.C 20460
ABSTRACT- This article provides
efforts ained at designing pi
isflrodactio* to
chnotogies with environmental ubjuti** a* a f*]**llj.
ft describes the efforts of ETA'S Design tor the
Environment Program to atom and redace obstacles to
private sector environmcatal design initiatives.
L .INTRODUCTION
1 In today^ competitive trade environment, a
company's ability to respond to sophisticated easterner
demands for environmentally preferable products and react
to complex environmental rules and regulations can mean
the difference between a firm's ultimate success or failure.
In the future, t?H*«f!«fai opportunities will exist for
companies who can design high-quality, environmentally
sound products. Such efforts can create Jobs and provide
a comparative advantage in the international marketplace.
Previous methods of dealing with;«nvirca»enttl
problems, largely by controlling pollution through 'end-of-
the-pipe' regulatory approaches, have been expensive and
often less effective than hoped. With the advent of
pollution prevention philosophy, many firms have begun
directing their environmental efforts earlier in the
production cycle; from dean»up and control technologies,
to better management of manufacturing processes, to
reuse, source reduction, and ultimately to the very design
of their products. ; -
The design stage is the most critical and effective
time to address the environmental impacts of a product.
The National Research Council has estimated that
approximately 70 percent of the costs of a product's
development,,manufacture, and use is determined in the
initial, design of a product, making design a crucial
determinant 'of. a product's competitiveness [1]. In
addition, the design phase affords the greatest amount of
flexibility in choosing everything from raw materials to
manufacturing technique. Decisions made at the design:
stage affect -a product's impact on worker and consumer
safety, the risks and releases to human health and the
environment, and the characteristics of waste streams. [2].
Given the flexibility of the design stage, it is logical that
private sector efforts to "Design for the Environment* will
be increasingly important to environmental efforts in
fj. BACKGROUND
The term 'Design for the Environment' (DFE)
many **»*"p to many audiences. To the
mfniifc«tiirhi£ sector, DFE is most commonly viewed as
an adaptation of the "Design for X" (DFx) concept In
DFx, a desired product characteristic (Le, safety,
durability) is integrated as a goal into the design process.
In DFE initiatives, therefore, environmental considerations
become an integral part of the design of a producb , —
Ecology
Many DFE concepts have evolved out of the field
of Industrial Ecology (BE). Industrial Ecology, introduced
to the general public in 1989 by Robert A. Frosch and
Nicholas E. Gallopoulos [3], is a discipline that promotes
a cyclical mode! of manufacturing in which resources are
efficiently used and re-used. This contrasts with the
traditional linear model of manufacturing, in which
material are extracted, used in production, and then
discarded. Industrial Ecology, on the other hand, seeks to
emulate natural systems so that materials and energy are
used and recycled efficiently in ecological cycles.
The basis for Industrial Ecology is actually net
new. For years engineers have looked to nature, to aid in
making man-made systems work better. One example is
found in helicopter .design: dragonfly hovering mechanisms
have been studied meticulously in order to improve the
hovering ability of modern helicopters [4].
-------
In the 1970s, designers began calling for m broader
look at how organisms interact in natural systems in a way
that is. 'less concerned with the form of parts or shape of
thing?, but rather with possibilities of examining how
nature makes things happen.' [6] Distilling business
lessons from ecosystems became the goal since many
consider nature to be a, "great repository of wisdom about
efficiency, adaptation, competition, and sustainability." [7]
B. German Legislation
Interest in Industrial Ecology and DFE initiatives
has become more pronounced following the adoption of
German legislative measures which require manufacturers
and retailers to collect and recycle packaging for « wide
range of products. Finns will have to recycle 80 percent
beginning In 1995. As a result, many product
manufacturers are redesigning their products with
disassembly and recydabflity as design goals.
Probably the most well-known example of this
type .of effort is in the automobile industry. In 1988,
BMW introduced » limited production edition of a two-
seat roadster which can be quickly disassembled. The car's
plastic body panels are coded for easy recydinf [8].
Although BMW is furthest along in designing for the
recydabflity of its automobiles, some domestic car
manufacturen (such as Ford), as well as other foreign auto
manufacturers (L e, Toyota and Volkswagen) hope to
introduce recyclable can in the near future.
C The Montreal Protocol
Major redesign efforts in international
manufacturing have also been initiated as a result of the
Montreal Protocol of 1987, a treaty which requires
industrial nations, to discontinue production and use of
most CFCs by 2000. Drastic reductions in world CPC
production have challenged industries which utilize CFCs
to redesign their products and processes, in some cases to
yield even better products. For example, new (CFOfree)
gas-fired air-conditioners may prove more economical than
current models. ;
D. Derigatag far Oae Ejnrironaeatal Opadrtmrim
In cases of impetus provided -by German
legislation and the Montreal Protocol, design efforts have
focused on addressing only, one particular environmental
consideration. While these redesigned products may
create less waste or possess a reduced ozone depleting
potential, their overall environmental impact has not been
evaluated and they may create other significant
. environmental impacts. For example, a car designed for
recyclability may create hazardous waste while in
production. In addition, caution must be exercised to
avoid transferring an apparent reduction in pollution to a
greater impact elsewhere. [8]
E. Broad Interpretations of 'Design for the Environment'
Efforts
There are numerous examples of what could be
deemed "Design for the. Environment" 'work, underway in
sectors other tt»«" manufacturing. While traditional
manufacturing audiences concern themselves with the
design of a particular product or process, to others, DFE
can mean a whole variety of ambitious projects that
capitalize on the broadest interpretation of what "design"
and "environment* mean.
One example to the soon-to-open Denver
International Airport. This project was designed to
employ numerous energy conservation, water conservation,
air pollution prevention, waste reduction, and recycling
measures in the facility. [9]
Kruger National Park in South Africa has also
been featured to numerous publications because of the
environmental design and planning that went into
developing it The park was designed for functionality, so
that visitors can participate in all desirable activities, yet
advene impact on the land is minimiMd as much as
possible. [10]
Other examples are plentiful. The design of
energy conserving houses, integrated pest management
systems, and even 'environmentally sustamable
communities are also in the spirit of what many would
consider "Design for the Environment" efforts. These
protects have all achieved some degree of success and are
good examples of results that can be achieved by objective
driven design planning.
Many of these ambitious design initiatives are
forced to make decisions teased on incomplete information
because of the lack of environmental impact data on many
materials, chemicals, and processes and because of a tack
of time and money. Later it may become evident that
these design choices have created other significant
environment impacts. While such projects are important
. . _. *^«. •««• • ••CTtiit^y of assertive hypotheses,
amining the seemingly
environment impacts. While such projects are important
models because they test a number of assertive hypotheses,
there is also a crucial role in examining the seemingly
obvious "environmental answen/ Alternatives are rarely
as simple as they seem and the amount of environmental
data which should be incorporated into design decisions is
ciiHctantiaL
substantiaL
-------
F. Caution in Defining what a DFE
It is important to be cautious when using'the
term 'Design for the Environment' in its broadest context
One of the reasons we continue to grapple with today's
environmental problems is the, 'consistent failure on the
pan of the public, regulators and industry to think of the
environment as a complex system, rather than just a few
relatively independent media* {11].
If used in a broad and simplistic way, DFE can be
used to justify almost any efforts, even those that are not
in the best interests of environmental preservation. If no
control is used in defining the term, DFE am simply add
to false environmental marketing claims.
O.
to DFE
Growing concern for environmental issues oa the
part of the public has fueled industry uxl academic efforts
to develop ways to incorporate environmental objectives
into decision making. A variety of approaches to
evaluating options- has emerged, for example, life cycle
analysis, pollution prevention audit guidelines, and efforts
to design for a specific endpoint such as recvdabOity or
CFC substitution.
Wriiie much has been accomplished through these
developments, obstacles to implementing pollution
prevention schemes and to systematically evaluating
alternatives continue to hinder private sector efforts.
Studies evaluating alternative prodKts, technologies and
processes have been hampered by lack of comparative risk.
information, lack of a method for comparing unlike risks
and lack of a method for integrating risk, performance and
cost information into a decision-focused system.
In -addition, many barriers to . DFE are
institutionalized in current business practices. For
Cample, the organization of tip****** data in a company
may «Pake it impossible to adequately characterize the
regulatory and environmental costs of producing a
product .
ITL BPA*> DIE PROGRAM
A. The DfE Program1! Role
The Design for the Environment (DfE) Program
in the Office of Pollution Prevention and Tories (OPPT)
has been created to apply EPA's expertise and leadership
to inform and facilitate pollution prevention efforts. It
harnesses the expertise for which. OPPT is best known:
comparative and multi-media risk analysis, methods for
evaluating alternatives for risk reduction, knowledge of
regulatory requirements, and outreach to industry and the
public on pollution prevention topics.
The DfE Program focuses on areas it is most familiar with:
pollution prevention efforts and environmental risk areas. •
Thus, the DfE Program promotes the incorporation of
environmental considerations, and especially risk
reduction, in the u-rign and redesign of products and
services. The Program works on a voluntary basis through
partnerships with industry and the public formed to apply
EPA expertise to speciic issues. It builds on the spirit of
voluntary EPA programs like Green Lights and the 33/50
Program. ~ , •
B. Levels of Imotvemeat
The DfE Program has initiated a number of wide-ranging
projects which operate through three levels of
involvement:
• fnfpstmctnre projects are the broadest in scope and
limed at changing aspects of general business practices in
order to remove barriers to behavior change and to
provide incentives for undertaking environmental design
and pollution prevention efforts.
• Industry projects are joint efforts with trade associations,",
and businesses in specific industry segments to evaluate
comparative risks, performance and costs of alternatives
and to invoke behavioral change.
• Facflfty-based program activities win help individual
bushtoses undertake environmental design efforts of their
own through the development and application of specific
methods, tools, and models.
C TheNeedfora&dntiWeFcoB
As regulatory pressure has increased and private
sector efforts tp go beyond mere compliance have
multiplied, there has been a demonstrated demand for
information on substitution as a method of .achieving
pollution prevention. For example, the DfE Program
recently received a call from an Air Force Base engineer
who was looking for an alternative for toluene in rubber
molding; Similar questions are posed on a dafly basis at
EPA's Pollution Prevention Information Clearinghouse
(PPIQ.
Case studies available through many sources,
including PPIC, provide some helpful process modification
information and may direct inquiring companies to leads
on alternatives. However, there are significant barriers to
-------
behavioral change because information is often missing or
fails to be organized in a decision-focused format. The
DCE Program is structured to address these problems.
TV ANALYTICAL
PROGRAM
A. Use dusters
USED IN EPAVDffi
The DfE Program has developed a methodology
iminin; substitute chemicals, processes, and
technologies. luismetbxxtotogyisaiiTeatiybetogapplied
for
Drop-in substitutes tend to be rare. Therefore, it
is essential to systematically compare the trade-offs
associated with different alternatives. EPA's DfE Program
has developed a format, to help direct these types of
efforts, based on OPPTs Risk Management review for
existing chemicals.
B. Substitutes ASM
att
t{7V4l frfmtjf^igj^ JL-UJ" miwiar»r*»«ir«*»|y ^ • ™~• • ™ —-y j- ^ « •
in the DfE Program's Cooperative Industry Projects. Each
project has identified, with the help of industry partners,
problem environmental areas for which companies would
like to seek substitutes. Existing risk ranking systems can
help prioritize problem areas.
Through a process of collecting information on
currently existing alternatives and through a search for
other promising options, the DfE Program Usts all
alternatives in a "use clusar tree' for chemicals, processes,
and technologies that can substitute for one another in
performing'a particular function.
Sometimes, alternatives are not at all similar. For
example, the paint stripping function in maintenance
applications can be accomplished through the use of
chemical solvents such as methyiene chloride and NMP, or
through alternative practices such as sandblasting and
plastic pellet blasting, or can even be avoided all together
by using a surface preparation not needing paint.
Cleaner Technology Substitutes Assessments, or
CTSA's for short, are intended to provide! a flexible format
for systematically comparing the trade-off issues associated
with alternatives. Traditional trade-pffs such as cost and
performance are brought together with environmental
trade-ofis'including comparative risk, releases, energy
impact and resource conservation for each alternative. A
completed Substitutes Assessment should provide all the
information that \ designer needs to .decide among
alternatives.
_om_
P««lontorttn.Emf>fom
Printing taduMry OMMT T«chnok
Sututttu*3
SuteMuMJ
Sub*tiM»4
Too often in the past alternatives have been
adopted without an attempt to assess the impacts that the
change will bring. Companies also cite numerous
anecdotes in which, they have switched, from a regulated
chemical, only to find the alternative is regulated a few
•yean later. By considering the trade-ofis associated with
alternatives through a systematic format such as the
CTSA, such problems may be avoided, anticipated, or at
least minimized. Developing, answers to these problems
will be an ongoing process and will occur as the EPAs
DfE Program addresses specific application problems.
The CTSA is a flexible tool It fits many types of
issues and provides an outline of information needs which
-------
incorporate pollution prevention, life cycle analysis, and
DFE principles, rather than traditional cnd-of-pipe
pollution control strategies into courses in engineering,
business, and natural resources.
C Alternate Synthetic Pathways
The moment that a chemist puts pencil to paper
ta design how to make a chemical product, he also decides
whether or not that process will use or generate hazardous
substances that need to be treated, recycled, transported,
or disposed. Many of the traditional synthetic pathways
that are used to create high volume industrial chemicals
utilize toxic feedstocks, catalysts, or create hazardous and
toxic byproducts. The EPA is working to encourage.
University research into alternative methods for producing
many important chemicals which minimize or eliminate
hazardous substances, first by awarding six grants and now.
by working with the National Science Foundation to a
award additional grants. The results of this research will
provide the chemical production industry'with important
tools to reduce risr »ad prevent pollution.
D. Insurance Project
Incorporating pollution prevention principles into
the day-to-day practice* of insurance underwriters,
insurance brokers, and corporate risk managers could
provide significant opportunities to stimulate voluntary
changes in many businesses and industries. In the short
run, the EPA has entered into a cooperative effort with
the American Institute of Chartered Property and Casualty
Underwriters (AICPCU). AICPCU is a non-profit,
independent organization offering educational programs
and professional certification to people in the property
and liability insurance business. The Institute offers a
broad array of certification programs 'for insurance
underwriters and brokers, and corporate risk managers.
EPA is working with AICPCU to modify the curriculum
for the associates in Risk Management (ARM) program to
incorporate pollution prevention into their certification
program. • •
VTL CONCLUSION
A. Challenges
xtflf
Large challenges still exist to widespread adoption
of environmental design initiatives in the private sector.
EPA's DfE Program has developed the Substitutes
Assessments methodology in an attempt to lay out
environmental issues that should be integrated into design
decisions and also to provide a model for examining
substitutes in a systematic fashion. Although organizing
the information in this manner will highlight some.
desirable choices, due to.the complexity of the trade-off
issues involving risk, performance, and cost (which will .
vary from fadlir to facility), it will generally not prescribe
one alternative. This method, however, makes all of the
decision factors visible so that decisions can be made with
'full knowledge of available information and of the
uncertainty of some of that information.
• Companies have a challenge to .identify priority
areas of environmental concern and to change the mindset
of upper management and design engineers so that a
search for alternatives in problem environmental areas
becomes a priority.
R Moving in the right direction
While many challenges still exist, the EPA's DfE
Program is working to provide concrete examples for how
a company can design its products and services with the
environment in mind. Efforts to change the institutional
business infrastructure that supports such efforts are also
an important direction in which the Program focuses.
C Opportunities tor WE
Many American industries are driven by ever-
changing technology. Survival in these competitive
industries is now mandating that firms design'flexible
products which satisfy varying applications and consumers.
In addition, production methods are becoming more
flexible to accommodate new technologies, products, and
manufacturing techniques. High technology areas such as
electronics, computers, and automobile manufacturing are
particularly well suited for DFE efforts.
Other sectors, such as dry cleaning and printing,
require change much less frequently. In these cases, DFE
efforts are actually attempts to redesign products and
processes. Yet, even in slower changing sectors, many
companies are feting growing pressures to dramatically
change their products and services.
Substantial opportunities exist for companies who
can design high-quality, environmentally, sound products.
Those companies which are able to integrate
environmental objectives in the earliest design stages of
their products will profit from savings through regulatory
compliance, marketing advantages, and increased
competitiveness. EPA and the DfE Program are working
with industry partners to realize these opportunities.
-------
can be supplied in greater or lesser depth (or even left
out) depending on the specific example under
consideration. The document lays out the trade-offs and
highlights missing information. The missing pieces can be
used to design data collection efforts or simply to inform
companies about the degree of uncertainty surrounding the
choices.
D. Relative Risk Ranking
Many companies rind that quality information
about the relative risks of chemical alternatives is difficult
to access and understand. OPPT along with many
companies, defense contractors, federal agencies, and other
offices within EPA have developed computerized risk
ranking systems. The DfE Program is working to bring til
major players together in workshops aimed at
standardizing the approaches.
Publicly accessible ' computerized relative risk
ranking can provide a powerful tool for DFE efforts. It
can help prioritize problem environipental areas where a
search for alternatives may be necessary. In addition, it
can provide preliminary comparatne risk information
about different alternative chemicals Oat might serve as
substitutes.
VT
nfP. PROGRAM'S
PROGRAM
Many difficult issue* such as how to compare
unlike risks, how to calculate the risks of mixtures, how to
weigh risks in different media, and how to compare
chemical and process change options still east. .
The DfE Program is presently working with three-
industry segments who are already reevaluating their
current production and wotting practices.
These projects are working to apply the
methodology described above to specie use duster areas
and, through practical application, wffl address many of
the questions that must be worked out in applying this
methodology. Current cooperative industry projects
include: ' •
• Computers and Electronics
• printing, and
• Dry Cleaning
The DfE Program also hopes to establish working
relationships with other industry segments.
INFRASTRUrri IRE PROJECTS
Another major goal of EPA's DfE Program is 10
break down institutionalized barriers to DFE efforts. A
number of projects have been initiated for this purpose:
A Capital Budgeting and Environmental Accounting
Project
Every business collects information for its own
internal dedstonmaking, eg., cost and pricing decision,
(managerial accounting) and to provide to external
audiences such as bank stockholders, creditors, bankers,
and government (financial accounting). Every business also
must dedde how to invest its available capital m new
equipment and products.
- At present, many cost accounting systems and
capital budgeting processes do not provide enough
information to business managers to make optimal
decisions in increasingly competitive gtobal markets. In
the environmental arena, for cample, part or all
environmental costs for. treatment, disposal, and
administration are often allocated to overhead cost polls
which in torn mask the true environmental costs of a
particular product or process. Potential future liabilities
may not be accounted for at all
As long as this and other cost information is
bidden from managers, costing and pricing decisions will
underestimate the costs of some producB and overestimate
the costs of others. Managers face a similar lack of
information when they evaluate investment alternatives in
new equipment and products. Without adequate
information to indude in the financial analysis of capital
investments, and given problems in the methods of
analysis, managers »N «* .**' *» advantages of
investments that prevent pollution and minimize
environmental impacts. EPA's DfE Program seeks to
promote the designand development of better accounting
andcapital budgeting practices within firms' managerial
--- "ring systems.
B. Cnrricntam Development
EPA recognizes that many of today's companies
have trouble implementing pollution prevention and DFE
efforts bectfise their employees have not been educa«l or
trainedwiththeseobjectivesasapriority. To tegu. to fill
this «ademic vacuum, the EPA has f>b*h* *e.
National Pollution Prevention Center «JJ» U??""«JD°f
Michigan. The Center fe developing curricula in mutaple
disdpUnes (ie. business, accounting, marketing) which
-------
m National Research Council, Improving Engineering
Disifn: Designing for Competitive Advantage.
Washington, D.C: National Academy Press, 1991.
m U.S Congress, Office of Technology Assessment,
Green Products by Design: Choices for a Cleaner
Environment, OTA-E-541. Washington D.C: US.
Government Printing Office, pp. 144-152, September 1989.
[3] R. Frosch and N. Gallonoulos, ."Strategies for
Manufacturing,' Scientific American, VoL 261, No. 3, pp.
144-152, September 1989.
[4] Change Management Center, Applying Industrial
Ecology. Oakland, CA, 1993, pp. 2-3.
HV%««k, Design for the Re* World, Human
Ecology andSodal Change. NY: Bantam Books, 1973.
f61 Change Management Center, pp. 2.
[71J; Hoteha, -Making Disposal Easier, by Design,' New
York Times, pp. Dl, D3,28 May, 1991. ^
[81 American Electronics Association, The Howsand
Whys of Design far the Jnvironmenl: A Primff for
Members of the Electronics Association, Wa*hingtoaD.C,
November 1992, p. 8. 9^^.*
[91 J. McOraw, TTie Denver Airport: *****
Prevention by Design,' Potation Engineering, pp. 61-62,
1 January 1993. •...»,« *
[101 W. Van Riet and J. Cooks, "PlanningjUKl Design of '
Bci-en-D*l, A New dmp in Kroger National Put,-
EirvLnme7talMaiiag«iiait,VoL14;No.3,pp.359.365, *
May-June 199a
[11] Applying Industrial Ecology, p. 1Z
-------
------- |