United States
           Environmental Protection
           Agency
           Office of Research and
           Development
           Washington, DC 20460
EPA/600/2-90/048
October 1990
&EPA
Background Document on
Clean Products
Research and
Implementation

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                                      EPA/600/2-90/048
                                      October 1990
          BACKGROUND DOCUMENT
           ON  CLEAN PRODUCTS
      RESEARCH AND IMPLEMENTATION
                   by
            Beverly J. Sauer
             Robert G. Hunt
         Marjorie A. Franklin
       Franklin Associates,  Ltd.
    Prairie Village, Kansas  66208
      EPA Contract No.  68-01-7310
            Project Officer

            Mary Ann Curran
 Pollution Prevention Research Branch
Risk Reduction Engineering Laboratory
        Cincinnati, Ohio  45268
RISK REDUCTION ENGINEERING LABORATORY
  OFFICE OF RESEARCH AND  DEVELOPMENT
U.S.  ENVIRONMENTAL PROTECTION AGENCY
       CINCINNATI,  OHIO  45268
                          , ..
          Printing office, Washington, D.C. 20402
                                        Printed on Recycled Paper

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                       DISCLAIMER

The information in this document has been funded wholly
or in part by the United States Environmental Protection
Agency under EPA Contract  No.  68-01-7310 to NUS Corpora-
tion.   It has been subjected to the  Agency's peer and
administrative  review, and  it has  been approved for
publication as an EPA document.  Mention of trade names
or commercial products does  not constitute endorsement
or recommendation for use.
                           11

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                             FOREWORD
     Today's rapidly developing and changing technologies and
industrial products and practices  frequently carry with them the
increased generation of materials  that,  if  improperly dealt with,
can threaten both public health and the  environment.  The U.S.
Environmental Protection Agency is charged  by Congress with
protecting the Nation's land, air, and,water resources.  Under a
mandate of national environmental  laws,  the agency strives to
formulate and implement actions leading  to  a compatible balance
between human activities and the ability of natural systems to
support and nurture life.  These laws direct the EPA to perform
research to define our environmental problems, measure the
impacts, and search for solutions.

     The Risk Reduction Engineering Laboratory is responsible for
planning, implementing, and managing research, development, and
demonstration programs to provide  an authoritative, defensible
engineering basis in support of the policies, programs, and
regulations of the EPA with respect to drinking water,
wastewater, pesticides, toxic substances, solid and hazardous
wastes, and Superfund-related activities.   This publication is
one of the products of that research and provides a vital
communication link between the researcher and the user community.

     This report, Background Document: on Clean Products Research
and Implementation,, explores one of the newer types of programs
aimed at reducing the harmful impacts on the environment
resulting from the production, use, and disposal of goods.  Clean
products programs are set up to identify products which cause the
least negative impact on the environment and to encourage and
support environmentally sound products and technology.  Results
of an effective clean products prodgram may include reduction in
the quantity and toxicity of solid waste; reduction of air,
water, and soil pollution; and conservation of energy and
resources.  This report, prepared for the Pollution Prevention
Research Branch of the U.S. Environmental Protection Agency,
provides background information which may be useful in the
conduct of clean products research in the United States.
                         E. Timothy Oppelt, Director
                         Risk Reduction Engineering Laboratory
                               iii

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                            ABSTRACT


     The concept of "clean" or "environmentally friendly"
products, or those which cause the least negative impact on the
environment, has become a major issue in the marketplace in
recent years.

     A product and its packaging may impact the environment in
many ways (air, water, and soil pollution; resource and energy
usage, etc.) at any or all stages of its life cycle, from raw
material extraction through disposal.  Assessing all the
environmental impacts and comparing products on a technically
justifiable basis is very difficult.  As a result, most "clean
product" claims are made on the basis of only one or a few
environmental impacts.

     The two main purposes of a clean products program are to
identify products which cause less damage to the environment and
to encourage the development of environmentally sound products
and technology.  In order to direct the power of consumer
spending toward clean products, environmental impacts must be
accurately evaluated and the information communicated to
consumers.

     Several countries have official programs in place or
proposed to award environmental labels to products that meet
specified environmental requirements.  Programs in West Germany,
Canada, Japan, the Nordic countries, and Australia are discussed
in some detail in this report. Various types of efforts in the
U.S. are covered, including environmental action books and
shopping guides, legislative efforts, and individual
manufacturers' and retailers' programs.  Types of products which
have been evaluated and the reasons for their selection are also
discussed.

     The criteria and methodologies used to evaluate products are
critical elements of a clean products program.  Various criteria
are listed, along with discussions of how criteria have been
applied to various product groups.  This report also examines a
variety of methodologies, ranging from the comprehensive and
complex product life cycle approach  (covering environmental
impacts at each stage from raw materials extraction through
disposal) through various simplified approaches, each with its
own limitations. Advantages and disadvantages of each method are
                                rv

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examined.  A section is devoted to problematical issues that must
be addressed when establishing a clean products program.

     An annotated bibliography provides summaries of the articles
and reports researched to prepare this document, including the
most recent information from other countries on their clean
products programs.

     This report is submitted in fulfillment of EPA Contract No.
68-01-7310, Work Assignment No. 125, by Franklin Associates, Ltd.
under subcontract to NUS Corporation under the sponsorship of the
U.S. Environmental Protection Agency.  The report covers a period
from January 9, 1990 to June 29, 1990, and work was completed as
of June 29, 1990.

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                        TABLE OF CONTENTS
Foreword
Abstract
Acknowledgements

Chapter 1 - INTRODUCTION AND OVERVIEW

PURPOSE OF THE REPORT
THE LIFE CYCLE OF PRODUCTS
OVERVIEW OF CRITERIA AND METHODOLOGIES USED TO EVALUATE
  PRODUCTS

Chapter 2 - EXISTING AND PROPOSED CLEAN PRODUCTS PROGRAMS

COUNTRIES AND GROUPS THAT HAVE IMPLEMENTED PROGRAMS
     Germany:  Blue Angel
     Canada:  Environmental Choice
     Japan:  EcoMark
     Nordic Countries
          Sweden
          Norway
     Australia:  Green Spot
     U.S. States and Regional Organizations
     Environmental Groups
     Private Organizations  (Companies, Supermarkets,  etc.)
PRODUCTS FOR WHICH CRITERIA/METHODOLOGIES HAVE BEEN
  DEVELOPED

Chapter 3 - CRITERIA THAT HAVE BEEN USED TO EVALUATE
              PRODUCTS

RECYCLED CONTENT
RECYCLABILITY/REUSABILITY
DEGRADABILITY
HAZARDOUS/TOXIC MATERIAL CONTENT
WATER  POLLUTION IMPACTS
SOIL POLLUTION  IMPACTS
AIR POLLUTION IMPACTS
NOISE  POLLUTION IMPACTS
PRODUCTION  PROCESSES USED
USE OF RESOURCES  (INCLUDING ENERGY)
OTHER  CRITERIA
     Use  of More  Benign Products/Processes
     General Requirement of Safety, Usability
     Amount or  Type of Packaging
Page

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                                vi

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                                                             Page

     Provision of Information for the Consumer                32
     Overall Corporate Reputation                             32
     Effect on Rainforest                                     33
     Longer Lasting or Repairable Products                    33
     Weight or Volume Contribution to Landfills or
       Waste Streams                                          33
     Disposal Problems                                        33

chapter 4 - METHODOLOGIES THAT HAVE BEEN USED TO
              EVALUATE PRODUCTS                               34

PRODUCT LIFE CYCLE ANALYSIS                                   34
     Natural Resources                                        35
     Environmental Impacts                                    39
     Life Cycle Analysis                                      39
     Application of Life Cycle Analysis                       41
MATRIX APPROACH (Pass/Fail)                                   44
WEIGHTING SYSTEMS                                             42

Chapter 5 - ISSUES/TECHNICAL PROBLEMS TO BE RESOLVED          44

SELECTION OF PRODUCTS TO BE EVALUATED                         44
     Products That Are A Significant Factor in the
       Waste Stream                                           44
     Products That Are Simplest To Do Are Often Done First    45
     Whether To Include Hazardous Products                    45
COMPLETE LIFE CYCLE ANALYSIS VERSUS EASIER, QUICKER •
  METHODOLOGIES                                               46
HANDLING TRADE-OFFS                                           47
     Weighting Systems                                        48
     Pass/Fail Systems                                        48
     Letting the Consumer Decide                              49
     Using Only One Easily Determined Criterion               50
LEGAL IMPLICATIONS OF MAKING SUBJECTIVE JUDGMENTS             50
IMPLEMENTATION ISSUES                                         50
     Agencies That Might Implement Programs                   50
POLICY IMPLICATIONS                                           51
RECOMMENDATIONS                                               51

Appendix A - ANNOTATED BIBLIOGRAPHY                           54

ENVIRONMENTAL BOOKS, SHOPPING GUIDES, AND CATALOGS            54
ENVIRONMENTAL LABELING                                        56
ENVIRONMENTAL IMPACT INFORMATION                              66
STATE, GOVERNMENT LEGISLATIVE ACTIVITY                        71

Appendix B - PERSONAL CONTACTS                                74
                               vii

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                          LIST OF TABLES

Table                                                       Page

1-1       Overview of Criteria Used by Various Groups
            to Evaluate Products                               3
2-1       Guidelines Issued by Canada's Environmental
            Choice Program                                     9
2-2       Data and Recommendation on Diapers Presented by
            Environmental Guides                              21
4-1       Energy Profiles for the Delivery of 1,000 Gallons
            of Soft Drink in 2-Liter PET Plastic Containers,
            1987                                              38
4-2       Energy Consumption Associated with the Delivery
            of 1,000 Gallons of Soft Drink in All PET,
            Aluminum, and Glass Containers at Various
            Recycling Rates                                   39
4-3       Energy Consumption of Container Systems at
            Example Recycling Rates                           40
4-4       List of Known Life Cycle Analyses                   42
Figure

2-1
4-1

4-2
                         LIST OF FIGURES
Environmental Labels Used in Other Countries
General Materials Flow for "Cradle-to-Grave"
  Analysis of Soft Drink Distribution System
Summary Diagram for the Production and Recycling
  of PET Soft Drink Containers
Page

   5

  36

  37
                               viii

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                    ACKNOWLEDGEMENTS
     Franklin Associates,  Ltd.  gratefully acknowledges
the numerous organizations and individuals who provided
information about their clean products programs for this
report, particularly the individuals listed in Appendix
B.

     Thanks also to Project Officer Mary Ann Curran and
David G. Stephan of the U.S. EPA Office of Research and
Development in Cincinnati and peer reviewers Michael R.
Overcash of North Carolina  State University and Bruce E.
Jones  of  Procter  &  Gamble  Company  for  their  careful
review and constructive comments.
                          IX

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                            Chapter 1

                    INTRODUCTION AND OVERVIEW
PURPOSE OF THE REPORT

     The concept that products can be made "environmentally
friendly" or "clean" has been attracting much attention and
action in the United States and abroad.  This clean products
approach can potentially be applied at all stages in the waste
management hierarchy as established by the Environmental
Protection Agency: source reduction, recycling, treatment, and
disposal.  The approach goes well beyond solid waste management
issues, since other environmental considerations such as impacts
on the air and water should be included.

     While the concept of environmentally friendly products is
easy to endorse, there is as yet no universally accepted
definition of what is meant by "environmentally friendly" or
"clean," nor any agreement on how to achieve clean products as an
objective.  This report has been prepared to provide background
information on the current state of research activities and
implementation on the subject of clean products, and to identify
issues that must be resolved as programs are implemented.  The
focus of this report is on consumer products, although the same
methodologies and criteria can be used for any product or
process.

THE LIFE CYCLE OF PRODUCTS

     For at least two decades there has been recognition, at
least among thoughtful people, that the manufacture, use, and
disposal of products can impact on resources and the environment
at every stage in the product's life cycle.  The life cycle of a
product moves from extraction of raw materials to processing
stages and on through manufacture of the product (or package for
a product). The product then goes through the distribution
channels (wholesaler, retailer) to the consumer.  Finally the
product is consumed, disposed of, or perhaps recycled.  At every
stage in the product's life cycle, the environment may be
affected (e.g., through air emissions, effluents, solid waste
generated, etc.). Also, energy can be required for every step in
the life of a product and, of course, raw materials are used to
manufacture the product.

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     While there is general agreement that it is desirable to
minimize a product's overall impact on resources and the
environment, it is not so easy to determine what the impacts
really are, and how one product compares to another.  Many claims
that a given product is "environmentally friendly" are based on
only one of the many possible points of impact or types of impact
on the environment. The chapters that follow describe in more
detail the currently used and planned criteria and methodologies
for evaluating clean products.

OVERVIEW OP CRITERIA AND METHODOLOGIES USED TO EVALUATE PRODUCTS

     There is a well developed life cycle analysis methodology
that has been used to evaluate products for about 20 years.  This
methodology considers environmental impacts and resource use at
all the steps ("cradle to grave") in a product's life.  This
evaluation methodology and the products to which it has been
applied are described in much more detail in later chapters.

     Many other efforts have been made to categorize products as
clean or environmentally friendly using one or only a few
criteria.  A feel for the variety of criteria used and products
evaluated can be gained by examining Table 1-1.  The potential
for polluting water, soil or air or the potential for reduced
resource or energy usage are the most prevalent criteria used in
a variety of programs, including those in other countries.  A
wide variety of consumer products have been evaluated.

     In the chapter that follows, existing and proposed clean
product programs in the United States and abroad are briefly
discussed as well as products for which criteria/methodologies
have been developed.  Separate chapters are devoted to more
detailed discussions of the criteria and methodologies that have
been used and proposed.  Finally, some of the issues and
technical problems remaining to be resolved are addressed.

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                            Chapter 2

          EXISTING AND PROPOSED CLEAN PRODUCTS PROGRAMS



COUNTRIES AND GROUPS THAT HAVE IMPLEMENTED PROGRAMS

     With the rising tide of green consumerism, the marketing of
products as "clean" or "environmentally friendly"  is growing
exponentially.  Existing labeling programs range from well-
controlled national programs and simple shopping guidelines
recommended by various consumer/environmental groups to labeling
claims with undefined technical basis made by manufacturers and
retailers trying to cash in on consumers' rising concern for the
environment.  Unfortunately, it is difficult for the consumer,
confronted with a vast array of products and conflicting or
incomplete information, to assess the technical accuracy of
labeling claims and make an educated decision as to which
products are better for (or more accurately, least harmful to)
the environment.

     In this chapter, a number of the "environmentally friendly"
labeling programs in existence as well as some shopping guides
are described, with particular emphasis on their technical basis,
and, if known, the sources of environmental impact data and the
techniques used to evaluate them.

Germany; Blue Angel (11, 23, 25, 32, 60)

     The Federal Republic of Germany is clearly the pioneer in
the field of national environmental labeling.  Its "Blue Angel"
program has been in existence since 1978 and is widely used as a
model by other countries and organizations in developing their
own labeling systems.  Over 3000 products in 57 product
categories now carry the Blue Angel label, which was adapted from
the logo of the United Nations Environment Programme.  The logo
consists of a blue angel flanked by stalks of grain with the
words "Environmental label because..." and a short general
description of the product's environmental impact (Figure 2-1).
Originally, the label's wording was "Environment-friendly
because..." but was changed in 1988 because of the consensus that
products are not beneficial to the environment, but more or less
harmful (25).

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WEST GERMANY - Blue Angel
CANADA -  Environmental Choice
      JAPAN - Ecomark
                                     Nordic Environmental Label
                          Figure 2-1
                ENVIRONMENTAL LABELS USED
                     IN  OTHER  COUNTRIES

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     The Blue Angel program defines clean products as those which

          "when compared with other products fulfilling
          the same function and when considered in their
          entirety, taking  into  account  all aspects of
          environmental   protection   (including   the
          economical use  of raw materials), are,  as a
          whole,  characterised by a  particularly high
          degree  of  environmental  soundness  without
          thereby significantly reducing their practical
          value and impairing their safety." (60)

     The labeling process involves three groups: the Federal
Environmental Agency (FEA), the Environmental Labeling Jury (Jury
Umweltzeichen), and the Institute for Product Safety and Labeling
(RAL).- Briefly, the process works this way:  The FEA appoints a
group of experts who define the detailed criteria for each
product category.  Upon approval of the criteria by the EL Jury,
the RAL then assesses products against the criteria.  Testing may
also involve the Stiftung Warentest, a consumer quality test
organization.

     It is claimed that a cradle-to-grave approach is used in
evaluating products for the label; however, it appears that,
lacking any outstanding environmental impacts in other areas,
differentiation of products in a given category is usually made
on a single criterion.  This criterion may be recycled content,
reusability, or some other environmental concern.  A report
presented by Dr. Edda Muller at the European Free Trade
Association  (EFTA) countries'  labeling seminar in August 1989
(25) stated that product testing is comprehensive, and includes
consideration of

     "the whole production cycle  (choice  of raw materials,
     manufacture,  utilization,  disposal),  all   aspects  of
     environmental   protection    (content   of   hazardous
     substances,  emissions  of  pollutants into the air, water
     and the soil, noise emissions, waste avoidance, reduction
     and  recycling,   sparing  use   of   natural  resources
     particularly in the consumption of energy, water and raw
     materials),   and   aspects  of  useability  and  safety
      (industrial  safety and protection of health)."  (25)

     Additionally, it was stated that, for  a specific group of
products, the requirements  may be narrowed  down because

     "one   particular  environmental  aspect,   e.g.  noise
     emission,  may not be relevant  for the  group  of  products
     concerned;   products  offered  on  the   market  defy
     differentiation  with  regard  to  their  environmental

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properties  (although products  showing serious problems
are already discarded in the earlier stage of selection
as being unsuitable for the granting of an environmental
label); or there is a lack of available information, for
example  in the  manufacturing  process  (should  serious
problems be  suspected,  the product group  is discarded
during the selection process)." (25)

Criticisms of the program include the following:

     Failure to update  (tighten) criteria frequently enough
     to keep them relevant to technical progress (23).   For
     example, only last year was the requirement for
     recycled paper content in various paper products raised
     from 51 percent to 100 percent (11).

•    Not enough emphasis on quality and useability of
     labeled products (23).  It was stated in the report by
     Environmental Data Services Ltd.  that acrylic paints
     bearing the Blue Angel label have been inferior in
     performance to traditional products.  For this reason,
     a consumer testing organization has now been included
     in the testing process to verify overall quality.   It
     is important that consumers do not associate an
     environmental label with products that do not work.

     Using a single environmental criterion (23).  While
     this may simplify product evaluation and make clearcut
     choices easier for the consumer by indicating exactly
     what product trait the label has been based on, it
     fails to adequately take into account other potentially
     significant environmental impacts of a product. For
     example, the label may be awarded to recycled paper
     products made by several different manufacturers,  but
     it is not clear that any real,  in-depth comparison has
     been made of their deinking,  bleaching,  and other
     manufacturing processes,  and whether they may not  in
     fact use more energy or produce  more waste than a
     process using virgin material.

•     Failure to provide labeling opportunity for all
     products in a product group.   Specifically, criteria
     were developed for low-solvent paints,  allowing them to
     qualify for an environmental label,  while
     environmentally preferable water-based dispersion
     paints were not labeled.   The response to this
     criticism was that water-based paints are not suitable
     substitutes for all low-solvent paint applications, and
     water-based paints already dominated the market in
     those applications where they compete with low-solvent

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         paints; therefore, it was not considered necessary to
         label water-based paints  (32).

         Since the  label award is based on voluntary
         participation  of companies  (with a licensing  fee
         involved), there is no guarantee that an unlabeled
         product may  not be equally  as environmentally sound as
         a  labeled  one, or even superior, but perhaps  its
         manufacturer has not chosen to apply for a label  (23).
         This is unfortunate from  a  pure environmentalist,
         informational  point of view, although companies which
         do not choose  to apply for  the label must realize that
         they may  lose  some market share because of this.

         Because of restrictions on  some product categories
         which have excluded them  from consideration  for the
         Blue Angel,  some manufacturers are using their own
         labels, which  may  lead to consumer confusion (23).  For
         example,  the guidelines  for non-CFC  aerosol  products
         excluded  any products containing  harmful substances.
         Therefore, manufacturers  of some  cleaning products have
         used their own CFC-free  labels.   In  the  absence  of the
          officially approved label with  its clearly defined
          criteria  to which consumers have  become  accustomed,
          shoppers  now do not know whether  product improvements
          in the one area have been offset  by  problems in
          another,  and may understandably become confused.

     This last issue is not intended as a criticism of the Blue
Angel program, but rather as an indication of  the value
manufacturers are now placing on consumers1 environmental
concerns and the effect on their purchasing decisions.  In some
cases, this has been sufficient motivation for manufacturers  to
make large investments in equipment to manufacture more
environmentally sound products that can be marketed with the Blue
Angel logo.

Canada; Environmental Choice (11,  15, 20, 21,  22,  23,   39)

     Canada's Environmental Choice program produced its first
three guidelines last summer, and as of May 15, 1990 had 11
approved product category guidelines and six draft issues out for
public review (Table  2-1)(15, 20).

     The Environmental  Choice logo is a maple leaf made of three
doves, representing the interaction  of government, industry, and
consumers  (Figure 2-1).  The program literature discourages use
of the term "environmentally friendly" in favor of referring to
products which "reduce  the burden  on the environment." A product
which is a  good environmental choice is "any product which is

                                8

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made, used or disposed of in a way that causes significantly less
harm to the environment than other similar products." (22)
                              Table 2-1

                    GUIDELINES ISSUED BY CANADA'S
                    ENVIRONMENTAL CHOICE PROGRAM
     FINAL GUIDELINES

     Re-refined lubricating oil (ECP-01-89)
     Construction materials from wood-based cellulose fiber
      (ECP-02-89)
     Products made from recycled plastic (ECP-03-89)
     Batteries:  zinc-air (ECP-04-89)
     Paint:  water-based (ECP-07-89)
     Fine paper from recycled paper  (ECP-08-89)
     Miscellaneous products from recycled paper (ECP-10-89)
     Newsprint from recycled paper  (ECP-11-89)
     Heat recovery ventilators (ECP-13-89)
     Diapers:  cloth (ECP-14-89)
     Solvent-based paints (ECP-12-89)
     DRAFT GUIDELINES

     Out for Public Review
     Energy-efficient major appliances (ECP-18-90)
     Reusable shopping bags (ECP-17-90)
     Composting systems for residential use (ECP-15-90)
     Alternative fuels: ethanol-blended gasoline  (ECP-16-90)
     Sanitary paper from recycled paper (ECP-09-89)
     Diaper services (ECP-21-90)
     The labeling process is similar to West Germany's, involving
three main organizations:  The Environmental Choice board,
consisting of experts from various fields; a secretariat within
Environment Canada; and an independent testing organization, the
Canadian Standards Association (CSA).  The Board reviews product
category reports containing information on the product's
environmental impact throughout its life cycle and related
opportunities to reduce the burden on the environment.  The CSA
then drafts a set of criteria, which, after approval by the
Board, is released for 60-day public review.  The Board may
revise the guidelines based on input during the public review,
then submits the final guidelines to the Minister of the

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Environment for approval.  As in the Blue Angel program, a
licensing fee is involved for use of the Ecologo, and use of the
logo is granted for a limited time.

     Technical criteria are specified in the individual product
guidelines.  Canada also claims to use a cradle-to-grave approach
in assessing products.  The guidelines typically contain a
general statement that "based on a review of currently available
product life cycle information, the product category requirements
will produce a net environmental benefit or improvement."  Each
guideline also contains specific requirements for the product
category, such as the requirements that labeled lubricating oil
must have been manufactured using over 50 percent by volume re-
refined oil in the base stock and must contain less than 5 ppm
chlorinated compounds and less than 25 ppm metals (15).
Guidelines also contain a statement that various stages of the
life cycle (specified for each product category) must be
accomplished in such a manner that all steps of the process meet
the requirements of the Canadian Environmental Protection Act and
all applicable governmental regulations.

Japan; EcoMark (11, 23, 32, 33)

     Japan's environmental labeling program, based on the West
German Blue Angel program, was launched in February 1989.  The
program aims to promote "clean" innovation by industry, heighten
consumers' environmental awareness, recommend products which
contribute to environmental protection and conservation, and
symbolize an ecological lifestyle.

     The logo consists of arms encircling the earth, forming an
"e" shape  (Figure 2-1).  The wording consists of the statement
"Gentle to the Earth" along with a specific reason associated
with each product category.  "Clean" products considered for the
label are those which cause little or no pollution when used or
discarded, improve the environment in use, or otherwise
contribute to conservation of the environment.  The logo's use
will also be applied to environmentally favorable activities such
as recycling programs.

     The Ecomark Office at the Environmental Agency plays the
central coordinating role.  The Environment Agency selects
product groups, and the Japan Environment Association approves or
disapproves them, with input from the expert Ecomark Promotion
Committee.  The Committee sets standards for product approval and
is responsible for approving certification of applicants for the
label (33).

     To qualify for the Ecomark, products must have been
manufactured with attention given to the following:

                                10

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          Preventive measures must be taken against environmental
          pollution in manufacturing.

      •    Disposal of the product must not involve difficult
          processing.

      •    There must be an opportunity for conserving energy or
          resources through use of the product.

          Compliance with quality and safety laws, standards, and
          regulations must be demonstrated.

          Price must not be excessively higher than that of
          comparable products.

     The Ecomark only distinguishes products on the basis of
environmental protection and does not attempt to set standards
for quality and safety (33).  As in the West German and Canadian
programs, use of the labels is voluntary, involves a fee, and is
valid for a limited number of years.

     The program started in February 1989 with seven product
groups, and six more were added in August.  In the first six
months, 151 products were approved.  Product groups which have
been labeled include books and magazines from recycled papers,
personal care aerosol products with no CFC propellants, kitchen
strainers and filters, and compost makers.  Detailed criteria for
various products have not been made available.

Nordic Countries (11, 25, 32, 41, 42, 54)

     The most recent entrants into the field of organized
environmental labeling are the Nordic countries.  On November 8,
1989, the Nordic Council of Ministers agreed to implement a
voluntary and positive environmental labeling program. The
program will use common criteria developed with the cooperation
of all participating Nordic countries and a common label, a green
and white striped circle with a swan, based on the emblem of the
Nordic Council of Ministers (Figure 2-1).  The environmental
performance of selected product groups will be assessed in terms
of such factors as raw material extraction, production processes,
and product use and disposal, and a set of minimum requirements
will be established.  In some cases, the label will be granted to
the least harmful product in a group, while in other cases the
label will be granted to products that represent an alternative,
more environmentally sound means of satisfying consumer needs
(41).
                                11

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     Participation of individual Nordic countries will be on a
voluntary basis.  Norway, Sweden, Iceland, and Finland have all
indicated that they will participate, while Denmark is waiting to
see whether the European Economic Community will adopt a labeling
program before it decides whether to participate (41).

     A Nordic Environmental Labeling Committee will be
established under the Council of Ministers, with a secretariat in
the Council of Ministers.  Each participating country will
organize its own national committee to run the program.  The
national committee will define product groups and criteria,
subject to approval by the Nordic labeling committee, which will
have the final say.

     All Nordic countries may participate in meetings of the
Nordic Environmental Labeling Committee, but only those
participating in the labeling program may vote.  The national
committees will also handle individual applications for use of
the label.  An application approved by any country's national
committee will automatically be valid in all of the participating
Nordic countries.  The first labeled products are anticipated to
be on the market toward the end of 1990.

     The Nordic countries also plan to keep well-informed on
developments in environmental labeling on a European Community
level, with an eye to future coordination with an EC system.

     So far, Sweden and Norway have set up national committees;
Finland is expected to join later this year, although there
appear to be some reservations on Finland's part regarding the
use of a simple symbol to represent the sum of all the
complicated environmental impact factors associated with a given
product or product group.  The main concern is that
oversimplification may mislead consumers.  The Swedish Society
for Conservation of Nature, addressing the same issue of how to
compare all environmental impacts, has suggested that the
starting point  for labeling criteria be focused on what is
believed to be the most  important aspect of the product group's
environmental impact.  Evaluations  (subject to revision as
knowledge increases) should be made upon the most extensive
background information available, but some subjective decision
will necessarily be involved  (32).

     Following  are brief summaries of the structure  and status of
the national labeling committees  formed in Sweden and Norway.

     Sweden.  In Sweden, the well-established Swedish Standards
Institution  (SIS) will coordinate the labeling system.  An
environmental labeling board set up within SIS will  consider
proposals of product groups for  labeling  and set up  working

                                12

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groups to come up with product specifications.  Final decisions
will, as previously stated, be made on a Nordic level. Recognized
testing institutions will perform the tests to verify that
products applying for labels meet the specifications.  At its
first meeting on February 5, 1990, the Swedish Environmental
Labeling Board decided to form expert groups to develop criteria
for labeling of paper products, batteries, and detergent.

     Norway.  Norway has created the Norwegian Foundation for
Environmental Product Labeling, composed of a secretariat, board,
and council.  The secretariat will administer daily activities,
while the board will appoint expert groups to define criteria for
product groups and handle applications for use of the label; the
council will deal with appeals of label applicants and handle
budgeting and accounting activities.  As of April 1990, the
secretariat, board, and council had been established, and an
expert group for paper products was being formed (42).

Australia; Green Spot (28)

     Australia is preparing to launch a national environmental
labeling program known as "Green Spot" later this year.
Originally the program was to proceed on a national basis in July
1990, but the start may be delayed due to some unresolved issues.

     In response to growing consumer concern about products'
environmental impacts, the Victorian Government initiated the
Green Spot consumer awareness program in March 1989 to promote
environmentally sound products.  The first stage of the program
involved publication of a series of Green Spot Bulletins,
advising consumers how to make environmentally sound purchasing
decisions regarding various products.   The second stage of the
program involved the formation, in May 1989, of an advisory panel
to investigate the feasibility of a national environmental
labeling program and to make conclusions and recommendations.  A
final report, published in December 1989, presented proposals for
an environmental labeling program's structure, operation,
funding, selection of product groups, product criteria and
evaluation, and marketing (28).  As in other countries' programs,
manufacturers' participation would be voluntary, with fees
charged for application and for use of the label; licensing
agreements would be valid for a limited time period.

     The Green Spot program is proposed to identify and label
consumer products which are environmentally sound in terms of
four broad impacts:

          "They cause substantially less pollution than other
          comparable products in production, usage and disposal."
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     •    "They are recycled and/or recyclable where comparable
          products are not."

     •    "They make a significant contribution to saving non-
          renewable resources or minimising use of renewable
          resources compared with other comparable products."

     •    "They contribute to a reduction of adverse
          environmental health consequences." (28)

     Types of products which are considered universally
environmentally benign are not to be included in the labeling
program.

     Primary environmental criteria will be defined for each
product category, addressing the most significant environmental
issues associated with that particular product.  In addition, the
following general environmental criteria will be considered for
every product on a "cradle-to-grave" basis:

     •    "The source of raw materials and the likely impact on
          the environment in accessing those materials."
     •    "The energy used for production of a product."
     •    "The environmental effects of wastes arising from the
          production process and methods used to dispose of
          gaseous, liquid or solid wastes.  In these respects,
          product manufacturers must comply with State and
          Federal environmental regulations."
          "The risk of environmental effects arising from the
          physical, chemical or biological properties of the
          product or of its breakdown products."
     •    "Indication of an established route for acceptable
          recycling or acceptable disposal of products and any
          environmental impact of such disposal."
     •    "Appropriateness of any packaging of the product and
          its suitability for recycling."
     •    "The product's capacity for multiple use as opposed to
          single use and disposal."  (28)

     In addition to environmental criteria, safety of the product
must not be compromised, and issues of price, performance,
convenience, and durability may be considered as well.
     Draft criteria for four initial product categories have been
developed and are to be published for public review.  The first
four product categories are unbleached paper products, chlorine-
free paper products, recycled paper, and products made from
recycled plastics.  Future product categories may include
household cleaning products, batteries, and paints.
                                14

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 U.S.  States and Regional Organizations

      In the absence of a nationally authorized environmental
 labeling program in the United States and in response to rising
 public concern about environmental  issues,  individual states  and
 regional organizations have begun to attack the issue of
 "environmental friendliness" on local and regional  levels.  In
 the past few years,  hundreds of pieces of legislation have  been
 proposed,  attempting to reduce the  harmful  environmental effects
 of various products or materials.

      Legislative efforts have primarily been directed at defining
 and banning environmentally unacceptable  goods,  rather than
 promoting "clean" products.   Judgments of whether or  not goods
 are environmentally friendly are usually  based on recyclability
 (either the perceived ability of the material to be recycled  in
 general,  or qualified by the local  availability of  a  recycling
 program),  degradability (of plastics),  and  reusability
 (returnable,  refillable packaging).   Some bills begin with  broad
 statements such, as "Plastics and foam packaging causes litter and
 environmental problems because it is not  biodegradable or
 recyclable" (89)  (emphasis  added).   Such  statements lead one  to
 question the technical research on  which  the legislation was
 based.

      Perhaps more than any  other, the issue  of degradability
 illustrates the  extreme differences in perceptions  of what  is
 better for the environment.   While  many states have bills seeking
 to ban nondegradable  plastics (notably the corn belt  states,
 producers  of the cornstarch  often used to promote
 biodegradation),  many bills  have also been introduced to ban
 degradable plastics because* of the  lack of information on the
 identity and effect of products  which may be mobilized by the
 breakdown  of the material, and because  of the  possibility of
 contamination of plastics recycling operations.

      Proposed legislation often  does  not specify a  preferred  or
 optimum substitute material  for  banned materials, or  indicate
 that  the environmental  effects of substitute products  have been
 thoroughly considered  (92) ;  for  example, what  are the
 environmental  impacts  of repeatedly transporting and washing
 heavier, reusable glass bottles when  substituted for plastic  soda
 bottles?

      CONEG (Coalition  of Northeastern Governors) has  focused  its
 attention  on the  issue of environmental responsibility in
packaging.  Its preferred packaging guidelines, in order of
preference, are:  no packaging; minimal packaging; consumable,
returnable, refillable/reusable packaging; and recyclable
packaging  or recycled material in packaging.  Decisions on what

                                15

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amount of packaging is necessary and what can be eliminated can
be a subjective decision; however, packaging for consumer
convenience and attractiveness is considered to present the
greatest opportunity for reduction.  In addition to these
packaging guidelines, CONEG is also supporting requirements for
removal of toxic agents such as lead, cadmium, and mercury from
packaging (68).

     In March, the Attorneys General of California,
Massachusetts, Minnesota, Missouri, New York, Texas, Washington,
and Wisconsin held a public forum on environmental marketing in
St. Paul, MN.  Information on the results of the forum was not
available at the time this report was prepared.

     The Pennsylvania Resources Council (PRC) is also active in
environmental issues relating to consumer products.  PRC
sponsored an environmental shopping seminar in March of this
year.  They also publish an environmental shopping guide, which
recommends buying items packaged in recycled or recyclable
materials or reusable containers, and avoiding mixed material
packaging and excessive packaging.  PRC recently published a
special addendum to this shopping guide, revising its previous
recommendation favoring paper bags over plastic.  Degradable
plastics are not recommended, and reusable cups, plates, etc. are
favored over polystyrene.  PRC provides a list of brand name
items packaged in recycled or recyclable materials, namely glass,
aluminum, and paperboard made from recycled paper, and will
update the list to include products packaged in recyclable
plastic and ferrous metals (7, 8).

     The New York Public Interest Research Group  (NYPIRG) has put
out a pamphlet, "Plagued by Packaging," which is similar to PRC's
guide in its recommendations on packaging.  Consumers are urged
to avoid single-use, disposable items, difficult-to-recycle or
non-recyclable packaging, and toxic packaging, and to look for
reduced, reused, and recycled products.  The pamphlet provides a
list of toll-free numbers for manufacturers of offending products
and encourages consumers to call and demand corporate action
(40).

     The most recent entrant into the field of product
certification and labeling is Scientific Certification Systems of
Sacramento, California, with its "Green Cross" labeling program
(19, 29, 52).  The program is being supported by the National
Toxics Campaign and four West Coast supermarket chains.  Two
seals of approval will be awarded, one for recycling (product
must contain highest possible level of recycled material), and
one for overall environmental acceptability  (product must be
environmentally benign, manufactured in a responsible manner, and
free of excess packaging)(19).  The group will perform its own

                                16

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 product testing and assessment, but will also accept evidence
 from credible  independent testing laboratories.  The program is
 intended to  fill the need for a strict independent system to
 direct  consumers toward environmentally preferable products, but
 critics fear that recommendations may be made on oversimplified
 evaluations, further misleading and confusing consumers.  Labeled
 products may start appearing in stores before the end of this
 year.

 Environmental  Groups

      Among environmentalists, enthusiasm for green marketing is
 particularly high.   In an informal telephone survey, when
 contacted and  asked about environmentally friendly products and
 labeling, many environmental organizations, although not actively
 involved in  such programs, were eager to hear of any developments
 in this area,  particularly regarding the possibility of the
 beginning of a standardized approach to environmental labeling
 claims.   The widely expressed opinion is that environmental
 labeling is  a  great idea and has the potential to make
 significant  environmentally beneficial effects on consumer
 purchasing decisions, but, with everyone jumping on the green
 bandwagon, environmental labeling needs to be standardized before
 it gets completely  out of control and consumers lose faith in its
 integrity.

     Many environmental shopping guides are now widely available,
 as well  as "save the world" books that contain product/packaging
 recommendations  among other socially beneficial activities (1, 2,
 3, 4, 5,  6,  7, 8, 9, 10, 40).  Shopping and environmental action
 guides  include books and pamphlets published by various
 individuals  and  environmental groups, intended to provide the
 reader with  information to use in making purchasing decisions,
 investments, lifestyle adjustments,  etc.  that will have the least
 negative  impact  on  the environment.   Most of these publications
 do not  claim to provide the answer of what is environmentally
 best, but rather  aim to help readers make informed choices or
 modify their habits in order to minimize waste and pollution and
 conserve  resources.

     For the most part, it is difficult to determine the source
 and extent of technical justification behind the shopping guide
 recommendations.  Many appear to use the simplified "plastics are
bad" approach,  based on the nondegradability of plastics compared
to paper  (regardless of studies which show that the actual
decomposition rates of paper in sanitary landfills are slow)  and
the "nonrecyclability" of plastics (or the limited availability
of plastics recycling programs).   Judgments appear to be based on
one or a few criteria, and not on a  thorough environmental impact
evaluation.   Criteria most frequently used are weight or volume

                               17

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contribution to municipal solid waste, recyclability, recycled
content, minimized packaging, degradability, elimination or
reduction of potentially hazardous or toxic materials, or reduced
energy usage. Emphasis is most often exclusively on the solid
waste impact of the products without regard for their potential
impacts on air, water, or other pollution problems during
manufacture, use, or disposal.

     The following paragraphs provide a brief summary of
shopping/environmental action guides with regard to the following
issues:

     •    Basis on which products are discussed/compared (is an
          attempt made to rate products on overall environmental
          acceptability, or are products rated as better or worse
          on individual environmental impacts?)

     •    Use of technical data to support recommendations
          (evidence and source of supporting technical data,
          evaluation techniques such as cradle-to-grave or single
          criterion)

     •    Treatment of sample category (diapers)

     •    Other evidence of technical research.

Shopping for a Better World.
Council on Economic Priorities  (1).

     This "socially responsible" shopping guide rates brand name
products not on their individual merits, but by their
manufacturer's performance in individual categories such as
environmental performance, animal testing, charitable
contributions, and advancement of women and minorities.  The
matrix  format allows consumers to select products based on a
favorable rating in any category or categories of their choice.
Environmental criteria are somewhat different depending on the
size of the company:

     Criteria for large companies (more than 100 employees)
     BEST - "Positive programs, such as the use and encouragement
     of: recycling, alternative energy sources, waste reduction,
     etc.  A record relatively clear of major regulatory
     violations."
     FAIR - "A mixed record: some positive programs such as use
     and encouragement of recycling, alternative energy sources,
     waste reduction, etc.   Problems such as accidents,
     regulatory infractions, fines, complaints, etc."
     POOR - "Company has consistently poor public record of
     repeated violations and/or major accidents; or  is a

                                18

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     cigarette manufacturer.
     positive effort."
Relatively little effective
     Criteria  for small companies  (100 employees or less)
     BEST -  "Makes strong effort to: 1) use biodegradable and/or
     recyclable materials in packaging products, 2) dispose of
     waste produced in manufacturing process in an
     environmentally sound way, and 3) use only natural
     ingredients."
     FAIR -  "Moderate effort to achieve above."
     POOR -  "Little or no effort to achieve above."

     The section entitled "About the Research" states that
"Categories  such as Environment and Community Outreach are
extremely complex, so that even with substantial information,
data were not  comparable company to company.  The reader should
be aware that  ratings in these two categories are less precise."

     Specific  sources of data are not clear, although a
disclaimer lists the general sources of information (companies
themselves,  public information, and advisors).  A list of
advisors is  also included.

The Green Consumer.
John Elkington, Julia Hailes, and Joel Makower. (2)

     The book  presents two basic considerations for "greenness":
environmentally sound contents or environmentally sound
packaging. Ideal green products are described as those that:

          "are not dangerous to the health of people or animals"
     •    "do  not cause damage to the environment during
          manufacture, use, or disposal"
          "do  not consume a disproportionate amount of energy and
          other resources during manufacture, use, or disposal"
     •    "do  not cause unnecessary waste, due either to
          excessive packaging or to a short useful life"
     «    "do  not involve the unnecessary use of or cruelty to
          animals"
     •    "do  not use materials derived from threatened species
          or environments."

     In addition,  a green product ideally should not trade price,
quality, nutrition, or convenience for environmental quality.

     The book  states its goal as presenting different sides to
some controversial issues and letting the consumer make decisions
and show support of companies that attempt to improve the
environmental quality of their products.
                               19

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     Materials and products are generally evaluated on a single
criterion at a time, with no overall summary of environmental
pros and cons associated with all environmental impacts of a
product.

     This book's data and recommendations on diapers are
summarized in  Table 2-2.

     Sources of data and information in tables and charts are
identified; other statistics and figures are quoted without
source identification.

The Green Consumer's Supermarket Shopping Guide.
John Elkington and Julia Hailes. (3)

     Given that the authors also helped write The Green Consumer
discussed above, it is not surprising that the definition of a
green product is almost identical; however, this book also adds
the condition that a green product should not "adversely affect
other countries, particularly in the Third World."

     The book's stated purpose is to make environmentally
friendly choices as clear as possible. It generally considers
several (but not nearly all) of a product category's
environmental impacts at a time, often presenting the information
in matrix form.

     Little actual data are presented on diapers; instead,
environmental issues such as use of forest resources, chlorine
bleaching and resultant pollution and residual dioxin, volume and
pollution effects in landfills, and possible recycling of wood
pulp from used diapers are mentioned.  No final recommendations
or conclusions are made.

     Sources of data are not usually identified.

50 Simple Things You Can Do To Save The Earth.
The Earthworks Group.  (10)

     No attempt is made to define environmentally friendly or
clean products.

     Very limited discussion of environmental impacts of
products; usually concentrates on most visible detrimental
effects.

     Data and recommendations on diapers are summarized in Table
2-2.  Many high-emotional-impact statistics quoted without source
identification.
                                20

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                                  Table 2-2



DATA AND RECOMMENDATIONS ON DIAPERS PRESENTED BY ENVIRONMENTAL GUIDES
Product/Criterion
Regular Disposable Diapers
% of waste stream
Untreated fecal matter
Wood pulp/year
Trees/year
Paper/year

Plastic/year
Time to decompose (years)
Cost
Energy required
Waste produced



% deqradable content
Degradabta Diapers
Time to degrade (years)
% degradable content
Recommended?

Cloth Diapers
Home cost

Diaper service cost
Number of uses
Time to decomoose
Green Consumer

Just under 2%
2.8 million tons




67,500 ton*
300-500
$1,533 (30 months)





72.3 (Pamoers)

2 - 7 (theoretical)
92.4% (Nappies)
May be slightly better
than reaular disoosables

$284 (30 months)

$975 (30 months)
Up to 200

50 Simple Things
to Save the Earth

1% of all landfill vol.
3 million tons
1,265,000 metric tons
> 1 billion


75,000 metric tons
500









No





Up to 100
- 6 months 	
How to Make the
World a Better Place

3%

1,265,000 tons
> 21 million


75,000 metric tons
200-500
About $800/year
21 trillion Btu
6.3 millions pounds (air)
2,700 pounds (water)
1 3.2 million pounds
(solid waste)


2-5
Yes, but doth better


20-30 % less than diaper
service
$400-600/year


750 Ways to
Save Our Planet


84 million pounds
800,000 tons

800 million pounds
(nonrecydable)
100,000 tons
500








2 - 5 (in laboratory)
No


$12-50/monthless
than disposables

80-200
6 months in landfill
                                     21

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How to Make the World a Better Place.
Jeffrey Hollender. (4)

     No attempt is made to define environmentally friendly
products. A single-criterion approach is used when discussing
environmental impact of products.
2-2.
     Data and recommendations on diapers are summarized in Table
     Identifies sources of some information and data; refers
readers to additional sources.

Save Our Planet - 750 Everyday Wavs You Can
Help Clean UP The Earth.  Diane MacEachern.  (5)

     Stated purpose of book:  "Though this book has not attempted
to provide a comprehensive list of  'ecologically correct'
consumer products, where particular items or companies stand out
as being significantly  'better' or  'worse' than their
counterparts, they are mentioned."

     Generally  focuses on a  single, high visibility  criterion  in
analyzing products.
 2-2.
      Data and recommendations on diapers  are  summarized  in Table
      Quotes some sources of information and directs  readers  to
 others.

      In summary, environmental books appear to use a single-
 criterion approach to evaluating products.   None of  these books
 attempted even a simplified life cycle analysis.  When more  than
 a single criterion is used, the presentation of data is often
 one-sided.  Data on a single topic may vary considerably from
 book to book depending on its source.  In all fairness, most
 guides do not claim to provide the answer of what is
 environmentally best from a comprehensive standpoint but rather
 provide limited data for the consumer to use in making purchase
 decisions.

 Private Organizations (Companies. Supermarkets, etc.)

      Naturally, many manufacturers are eager to respond to the
 rising tide of environmental concern by labeling their products
 "environmentally friendly," "better for the environment," etc.
 Many manufacturers are sponsoring evaluations of the
 environmental implications of their products, often performed by
 independent research groups (17, 30, 71, 74).  The results of

                                 22

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these evaluations may be published in a private report, in an
informational pamphlet for general release, or as an
advertisement in a trade journal or popular publication.  It is
interesting to note, however, that some manufacturers are still
hesitant to advertise products' recycled content out of concern
that the customer might perceive them as inferior in quality to
products made of virgin material.  In particular, this was
mentioned as a concern regarding consumers' perceptions of
sanitary paper products (31).

     In general, however, manufacturers have been putting more
emphasis on promoting the environmental benefits of their
products, as evidenced by the ever-increasing number and size of
environmental ads in trade journals and popular publications.  It
is not easy for the consumer to tell whether these claims have
been backed up with investments in more environmentally sound
manufacturing processes and equipment, more environmentally
benign ingredients, more environmentally acceptable packaging,
etc.

     Manufacturers' environmental labels typically are based on a
single environmental criterion, providing no clue as to whether
any other environmental impacts were considered in making their
advertising claim.  Common criteria for labeling claims are those
with high public interest or visibility, such as recycled
content, degradability, and lack of CFCs in content or
manufacture.

     Some grocery and retail stores are addressing their
customers' environmental concerns by stocking more products which
have been labeled "green" by their manufacturers or providing
their own "green" lines, supplying shoppers with environmental
shopping guidelines, providing drop-off points for recyclable
materials, and promoting paper bags and reuse of shopping bags
(26, 46, 52, 56, 61).  Customer response to the paper shopping
bag campaign at Big Bear markets in California has been
enthusiastically positive.  Big Bear's advertising contains the
following justification for the promotion of paper bags (made
from 38 percent recycled paper):

     "One of the most pressing local environmental concerns
     is the rapid depletion of landfill in which to dispose
     of our waste.  The use of plastics is a major
     contributor to this problem.  Most plastics are
     difficult to recycle and do not easily break down and
     become absorbed in a natural environment.  They can
     also create serious marine pollution.   But paper, as
     litter, breaks down easily and appears to be less
     harmful to wildlife,  fish,  and game."  (61)
                               23

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       A senior scientist at the National Audubon Society agrees
that paper bags are a better environmental choice in locations
near a coastline where the bag might end up in water, but advises
that otherwise plastic shopping bags, which are lighter and cause
less pollution per pound, are the preferred choice.  The chain
continues to provide photodegradable plastic bags upon request.

     In addition, the stores' environmental campaign includes
substitution of paper containers for foam in the store deli, CFC-
free meat containers, and requests to suppliers to package their
products in environmentally safer packaging, Fuch as pulp egg
cartons instead of foam.  Big Bear also provides shelf tags with
guidelines to help shoppers select environmentally preferable
products based on recommendations by San Diego's Environmental
Health Coalition.

PRODUCTS FOR WHICH CRITERIA/METHODOLOGIES HAVE BEEN DEVELOPED

     As mentioned in previous sections, 57 product categories
have been defined for environmental labeling in West Germany, and
product category guidelines have been approved or proposed for a
total of 16 product areas in Canada.

     In these programs, criteria have been developed for the
various product groups.  These groups have been selected for one
or more of the reasons listed below, each of which is discussed
with examples given.

     1.  The product is a major constituent of the waste stream
by volume or weight.  Products which have been selected for this
reason include recycled paper and plastic products, recycled
glass, and cloth diapers as a substitute for disposables.

     2.  The product has a significant impact on the waste stream
due to toxicity, disposal problems, etc.  Products in this
category include motor oil, batteries, asbestos-free automotive
products, and PCB-free cooling and insulating liquids for
electrical appliances.

     3.  Product use provides a substantial environmental
benefit. Canada recently withdrew its proposed guideline for
recycled rubber products because the environmental benefits of
rubber recycling were not considered adequate to justify, the
energy consumption of the recycling process (20).

     4.  The product meets overall safety and quality
requirements for normal use.  As stated above, it has been
reported that there were some performance problems with acrylic
paints labeled under the Blue Angel program, and as a result, a
consumer quality testing organization has been included in the

                                24

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 product  evaluation process  (11).  Canadian guidelines specify
 that  each product must meet or exceed all applicable Canadian
 governmental  and industrial safety and performance standards.

      5.  Product requirement levels  for the label are high in
 order to challenge industry to meet  or exceed the current levels
 of clean technology  (25).  This includes periodic review and
 revision of requirements, such as the recent raising of the
 required recycled content of Blue Angel-labeled paper products
 from  51  to 100 percent (11).

      6.  The  product is  easy to evaluate.  Although existing
 programs claim a cradle-to-grave approach in evaluating products,
 usually  products are differentiated  on the basis of a few well-
 defined  or easily determined criteria.

      7.  The  product is  commonly used.  Even though a product is
 commonly used, there is  not much point in going through the
 expensive and time-consuming procedures of setting criteria and
 evaluating products if there will be no significant impact on the
 environment as a result.

      8.  The  product does not shift  environmental impacts from
 one area only to create  problems in  another (25).  For example,
 an increase in recycled  paper content should not result in
 increased water pollution due to the bleaching and deinking of
 recycled fiber. Use of a life cycle  approach to product
 assessment avoids overlooking shifts in environmental impact.

      In  addition to the  above, the West German program considers
 the following requirements (25):

          The product must already be on the market.  If an
          environmentally preferable product is new, with no
          competing products, it is  not considered to need a
          label to boost its market  share.

          There must be  a need to promote the product - the
          environmental  label should not be awarded to product
          categories with too large  a market share.

          All products in competition with one another because of
          their sphere of use must be included.

     It  is important that this last consideration be kept in mind
when deciding whether or not to label a product based on its
market share.   Otherwise, consumer confusion may result.  As
previously mentioned, the West German program has been criticized
for its  failure to label water-based dispersion paints while low-
solvent paints considered more environmentally damaging are

                               25

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eligible for the label.  Because water-based paints are not
suitable for all applications in which low-solvent paints are
used, and because water-based paints already dominate the market
in the applications for which they are suitable, labeling of
water-based paints was not considered necessary (32).  This seems
at least somewhat in violation of the "include all competitive
products" requirement, and undoubtedly has confused some
shoppers.

     As another example, if only non-CFC aerosol personal care
products are labeled, a consumer shopping for deodorant may find
himself faced with an aerosol spray, a liquid roll-on, and a
solid stick applicator, with only the aerosol bearing an
environmental label.  Does the consumer interpret this to mean
that use of the aerosol is better for the environment than the
roll-on or stick versions with no chemical propellants and less
packaging volume?  The purpose of "clean" labeling is to aid the
consumer in making environmentally beneficial decisions, rather
than misleading or confusing him; unfortunately, accomplishing
this effectively is one of the major challenges of such a
program.
                                26

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                            Chapter 3

        CRITERIA THAT HAVE BEEN USED TO EVALUATE PRODUCTS
     In this chapter, criteria that have been used to evaluate
"environmentally friendly" or "clean" products are discussed.
Primary emphasis is placed on consumer products, although the
same criteria can apply to most products or processes.  Most
"clean products" recommendations are based on one or a few of
these criteria rather than a total environmental impact
evaluation.

RECYCLED CONTENT

     Recycled content is the most popular and widespread
criterion used to classify products as environmentally friendly.
It is used by nationally-regulated labeling programs,
manufacturers, and political, legislative, and environmental
groups.  It is a popular criterion because of wide recognition
and support by consumers; however, different groups may use
different definitions or requirements for recycled content,
depending on their definitions and percentage requirements of
postconsumer material. (Generally, postconsumer material includes
only that which has passed through end usage as a consumer item;
it does not include scrap and waste associated with manufacturing
operations, such as cutting and printing.) The Canadian
guidelines for recycled paper and plastic products contain the
working definition of postconsumer material and specify the
amount that must be present in each product subcategory (15).

     Products in the German and Canadian programs that use
recycled content as a major criterion include various paper
products (sanitary paper, wallpaper, construction materials,
cardboard, fine paper, newsprint, and miscellaneous products
including craft forms) and recycled plastic products.

RECYCLABILITY/REUSABILITY

     In the United States, recyclability and reusability are
widely used as criteria in legislation for banning
environmentally "unfriendly" materials, although definitions may
vary somewhat from place to place.  For example, recent proposals
in Massachusetts and Oregon to ban environmentally unacceptable
packaging differed in their definitions of recyclable.  In

                               27

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Massachusetts, a recyclable package is one made of a material
that will have achieved a recycling rate in the state of at least
35 percent before the year 2000, and 50 percent after that.
Oregon defines both recyclable packages and packages made of
recyclable materials.  The former is defined as one that is
itself included in an effective recycling program, while the
latter includes packaging made of materials that are effectively
recycled in Oregon.  "Effective recycling" means a 15% recycling
rate by 1993, 30% by 1996, 45% by 1999, and 60% by 2002.

     Obviously, standard definitions of terms would be a step in
the right direction.  In addition, proposed legislation is not
specific on the materials or containers that are to replace those
deemed unacceptable; increases in volume, weight, and energy
usage in production or transportation which may result from
substituting traditional recyclable materials such as glass or
paper for plastics are not addressed.

     Canada's guideline for reusable cloth diapers specifies that
the diaper must be able to endure a minimum of 75 uses and must
not include a non-reusable component.  Canada's Environmental
Choice program also has issued a draft guideline for reusable
shopping bags  (15).

     Recyclable/reusable products labeled with the West German
Blue Angel include reusable capsules for whipped cream makers and
soda siphons, reusable drop boxes for food, reusable packings for
transportation, reusable trays and industrial packaging, reusable
or refillable typewriter ribbon cassettes and toner cartridges,
recyclable printed material, and returnable glass bottles  (also
collection bins for glass).

DEGRADABILITY

     Degradability is an extremely popular and widely disputed
criterion for environmental friendliness.  It has been heavily
used as an advertising point, but is currently being questioned
or even denounced by many  environmentalists.  Many manufacturers
and retailers  focus on degradability as a positive
characteristic, especially in the great war of "plastic versus
paper"; however, at least  one "environmentally conscious"  mail
order company has  temporarily withdrawn its biodegradable  plastic
bags for re-evaluation of  their environmental effects  (49), and
several companies  have indicated that they will  no longer  market
their plastic bags as biodegradable or photodegradable  (35).
Some legislative proposals have called for bans  on nondegradable
plastics, while others have attempted to eliminate degradables.
Arguments for degradability include permanence of nondegradable
plastic waste in landfills or as  litter, breakdown of degradable
plastics  into harmless byproducts, and benefits  to composting

                                28

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 programs by eliminating the need to separate bags from yard waste
 (63,  71).

      Arguments  against degradability include contamination of
 plastics recycling  systems, lack of knowledge about decomposition
 products and their  effects on soil and groundwater, encouraging
 the throwaway mentality, and contributing to loss of nonrenewable
 petroleum resources.  Degradability also focuses attention away
 from  real waste solutions such as source reduction and increased
 recycling  (66,  71,  78, 79, 83).  It is interesting to note that
 neither the Canadian nor West German environmental labeling
 program has any product categories based on degradability.

      Degradability  continues to be used by some manufacturers and
 retailers as a  key  advertising point for disposable diapers,
 plastic bags, and virtually any other application where paper and
 plastic may compete, such as in packaging.  An additional problem
 is the lack of  definition or consistent definition of conditions
 under which degradability is to be measured, time intervals for
 specific levels of  decomposition, identity of decomposition
 products and determination of their environmental effects, and
 definition  of similar issues for substitute products.

 HAZARDOUS/TOXIC MATERIAL CONTENT

      This criterion can be used as justification for the
 necessity of environmental labeling of a product category, or can
 be used to  disqualify products from eligibility for labeling, as
 in the case of  West German aerosol products, where non-CFC
 aerosol products were not considered if they contained harmful
 substances  (23). Of course, the term "harmful" (or even "toxic")
 also  requires definition for its use to be meaningful.

      Reduction  or elimination of toxic materials or "substitution
 of a  more benign substance has been the primary criterion for
 "environmentally friendly" product categories such as zinc-air
 batteries;  lithium  batteries free of mercury and cadmium;
 asbestos-free floor coverings, brake linings, and clutch linings;
 corrosion protection coatings low in lead and chromates; PCB-free
 cooling and  insulating liquids for electrical appliances; and low
 formaldehyde products from wooden material, all labeled under the
West  German program.

WATER POLLUTION IMPACTS

     Water pollution has not been an obvious major criterion in
either the Canadian or West German labeling programs, although it
 is given specific attention in several environmental guides,
particularly those having to do with phosphates and bleaches in
detergents and biodegradability of various household cleaning

                               29

-------
products (2, 3, 5f 10).  Of course, the pollution of water, air,
and soil associated with all stages of a product's life cycle
must be considered in a true cradle-to-grave analysis, but it is
questionable how much attention is given to these matters in
evaluating a product's environmental friendliness, other than
assuring that emissions do not exceed regulatory limits.

SOIL POLLUTION IMPACTS

     This is another criterion that is an integral part of a
cradle-to-grave analysis but is not a popular single criterion
for labeling or a strong advertising point, except perhaps in the
case of organically grown foods (3).  Here advertising is usually
focused on health, rather than environmental, benefits.

     Soil pollution is given secondary attention as an issue
associated with the disposal of batteries and resultant leaching
of heavy metals, and the concern about the effect of fecal wastes
in disposable diapers  (2, 4, 5, 10).  It is also being mentioned
more frequently as a concern in the issue of degradable plastics,
due to lack of knowledge about the identity and effect of
degradation products (2,66,78,83).

AIR POLLUTION IMPACTS

     By far, the most popular air pollution issue in the past few
years has been the CFC content or "ozone friendliness," which has
been covered by labeling programs (both national and individual
manufacturers' own), environmental shopping guidelines, and
proposed legislation, particularly with regard to foam plastics
production and content.

     Air pollution effects are also used as a criterion when
discussing disposal of products by incineration.  Claims are
often made about the likelihood of toxic substances being
produced or released by the incineration of plastics (2, 3, 4,
5).

     Labeled products with air pollution as the primary criterion
include non-CFC aerosols, low-emission burners, motor vehicles
with exhaust treatment, and public transportation tickets (when
public transportation  is used, auto emissions are reduced because
fewer individuals operate private vehicles).

NOISE POLLUTION IMPACTS

     This criterion is little used in the United States; however,
it has been used as the primary criterion in labeling West German
products in the categories of lawn mowers, car mufflers, sound-
proofed glass collection bins, mopeds, construction machines, and

                                30

-------
garden chaff cutters.  Judging from the types of products to
which this criterion has been applied, it appears that noise
pollution is only used as a criterion associated with use of the
completed product.  It is hard to imagine how a life cycle noise
pollution analysis could be performed.  Other environmental
pollution impacts such as air, water, and soil pollution would
seem to be more environmentally significant, as well as more
easily tracked and quantified over a product's life cycle.

PRODUCTION PROCESSES USED

     The draft issues of the Canadian Environmental Choice
guidelines for re-refined oil and recycled cellulose construction
materials specified acceptable processes for oil demetallization
and hydrotreating and for use of a dry process to produce
recycled paper products.  These specifications were removed from
the final approved and officially issued guidelines (15).  The
reason for this is not yet known.

USE OF RESOURCES (INCLUDING ENERGY)

     This criterion can be subdivided into use of energy and use
of raw materials and resources.

     Unless energy usage is the primary evaluation criterion, it
is hard to tell whether it has been addressed in assessing the
product's environmental impact.  Cradle-to-grave energy
consumption is rarely mentioned when comparing plastic to paper
bags, although a German study showed that polyethylene bags are
more advantageous than paper bags in terms of energy usage (67).
In addition, it is difficult to determine whether the increased
energy usage for collection/ transportation, cleaning, and
distribution of reusable products such as refillable glass
bottles has been considered by legislative bodies seeking to ban
nonreusable, nondegradable, or nonrecyclable materials (92).

     Energy-conserving products that are covered by West German
or Canadian environmental labels include energy efficient
applian9es, heat recovery ventilators, solar power operated
products and mechanical watches, and highly insulating window
glass.

     Product recommendations on the basis of resource
conservation are most often directed at plastics as a user of
petroleum, considered a non-renewable resource, and paper as a
user of wood, considered a renewable resource.  Products such as
fast-food beef and exotic woods, associated with rainforest
destruction, are also considered users of non-renewable
resources. Water conservation also shows up as an issue in
German-labeled products.

                                31

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     Product categories that have been deemed environmentally
better based on resource usage include water-conserving car
washes, water-saving flush tanks, flow restrictors and
pressurized flushers, and low-waste personal care products.

OTHER CRITERIA

     Various other criteria that have been used less extensively
to judge a product or material's "environmental friendliness" are
listed below.

Use of More Benicrn Products/Processes

     An example of this is the West German product category
"thermal processes  (using hot air) to combat xylophagous  [wood-
boring] insects."

General Requirement of Safety. Usability

     This is stated as part of the charter of the West German
Blue Angel program and is specifically stated as a requirement in
each of the Canadian Environmental Choice guidelines.

Amount cr Type  of Packaging

     Packaging  is an area widely targeted by environmental groups
in shopping recommendations.  Consumers are advised to look  for
minimal packaging,  easily recyclable packaging, or packages  with
recycled content  (2, 3, 4, 5, 7, 8, 10, 40).  Manufacturers
advertise the environmental benefits of their products with
reduced packaging,  such as juice concentrates and concentrated
fabric softeners  (29,  34, 45, 47).

Provision of Information  for  the consumer

     The Canadian guideline for paint  requires manufacturers to
provide  information on environmentally responsible methods of
disposal of  the product (15).

Overall  Corporate Reputation

      The Council  on Economic  Priorities' booklet  "Shopping for a
 Better World"  (1)  rates brand-name products not on their
 individual merits but on  their manufacturer's performance in
 areas including environmental performance,  animal testing,
 charitable contributions,  and advancement  of women and
 minorities.
                                 32

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Effect on Rainforest

     Environmental action books and shopping guides frequently
address this  issue, usually advising consumers to avoid fast-food
beef (grazed  on deforested land) and products made of exotic
woods, and encouraging purchase of products that favor rain
forest preservation, such as cashews and brazil nuts, which are
not easily grown outside the rain forest (2, 3, 4, 5, 10).

Longer Lasting or Repairable Products

     Another  criterion frequently recommended in shopping guides
as an environmentally preferable characteristic is durability or
repairability.  This contributes to source reduction by
preventing products from entering the waste stream by prolonging
their useful  life.

Weight or Volume Contribution to Landfills or Waste streams

     This, combined with nondegradability and "nonrecyclability,"
is one of the major criteria used against plastics and packaging
in general.

Disposal Problems

     Judgments and recommendations made on this issue involve
perceptions and beliefs on nondegradability, toxic emissions when
products are incinerated, and the environmental effects of
improper disposal techniques such as littering and disposal of
household hazardous wastes in sanitary landfills.   Disposal
problems are often used as an argument against plastics in
general,  particularly concerning effects of plastic litter on
wildlife (2,  4, 5, 10,  61).
                               33

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                            Chapter 4

                METHODOLOGIES THAT HAVE BEEN USED
                      TO EVALUATE  PRODUCTS
PRODUCT LIFE CYCLE ANALYSIS

     Environmental problems potentially can be alleviated by
either direct or indirect means.  A direct means would include
bans or economic incentives or disincentives (such as taxes or
grants) which have an immediate or direct effect.  For example,
if a battery contains a toxic fluid or metal, the banning of the
particular product from disposal sites would prevent it from
contaminating a landfill or incinerator.  Source separation for
recycling purposes is another example of a direct means of
alleviating the identified environmental problem of filling up
landfills; however, the alternative to disposal will create
impacts of a different kind.

     Examples of indirect means include the banning of a product
(or discouraging or encouraging its use by incentives or
disincentives), or the substitution of one product for another in
order to correct some problem not as clearly linked to the
product.  For example, the environmental problem of carbon
dioxide in the atmosphere and its possible role in global warming
can be addressed by the banning of a product or products that are
thought to be responsible for large amounts of carbon dioxide
emissions during their manufacture.  In this case the linking of
carbon dioxide production with a consumer product is inferred.

     For example, consider the burning of coal (which results in
carbon dioxide) to produce electricity to manufacture a packaging
product.  The banning of the product may or may not result in
reduction of electricity usage.  The utility may undertake
marketing strategies to replace any lost sales and continue to
produce as much carbon dioxide as before the product was banned.
It is not certain that reduced product use will result in less
carbon dioxide, since the indirect process may simply be used for
something else and continue to produce carbon dioxide. Therefore,
it is not nearly as clear that benefit will result from any
indirect action taken as it is from direct action, nor is the
magnitude of the benefit as easily determined.
                                34

-------
      The worth of either a direct or an indirect approach can
 only be assessed by a life cycle analysis which examines the
 entire complex of operations associated with a product.   The
 theory is that consumption of products drives an array of
 extraction,  manufacturing, processing, transportation, and
 disposal operations.  Figure 4-1 illustrates the life cycle
 approach, using soft drink packaging as an example.   Products
 begin their "life" with the extraction of raw materials,  which
 includes operations such as mining minerals and drilling for oil
 and gas.  These materials are then transported to other  locations
 for processing and for manufacture into finished materials.
 Typically,  these materials are then fashioned into products at
 still other locations.

      Eventually these products are purchased by wholesalers,  then
 by retailers and,  finally, by consumers.   After use,  the  products
 are then discarded and go to final disposal or are recovered for
 recycling.   For each step and for transportation between  steps
 there are natural  resource requirements,  as well as outputs  to
 the environment in the form of air pollutants,  water  pollutants,
 and solid waste.    All  of these steps  produce negative
 environmental consequences.

      The theory behind  the use of product substitution or banning
 as a means for environmental benefit is that if the product  is
 not purchased,  then the manufacturing  and processing  will cease
 and,  along with it,  the environmental  consequences will cease.
 However,  the substitute product also produces  environmental
 consequences that  need  to be evaluated.

      A specific product example of Figure 4-1  is  shown as Figure
 4-2.   The example  product is plastic soft drink bottles.  The
 life cycle analysis  begins with the extraction  of natural gas  and
 crude oil from  the ground to serve as  the raw material.
 Additional oil  and gas  are required as the energy for the various
 processes and for  transportation.  Coal must also be mined to
 produce electric power  and to serve as a minor energy source for
 other processes.

      The  raw materials  are processed and transported to other
 stages of manufacture until the bottle is finally ready to be
 filled with product, shipped to retail establishments, and
 finally used by the end consumers.  The bottle "life" ends with
 final disposal, or the bottle is returned for processing and
 remanufacture through recycling.

Natural Resources

     Natural resources are consumed in each step, and energy is
required for any process or transportation,  other natural

                                35

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resources in the form of minerals removed from the earth or
harvested resources such as wood or corn are needed to meet the
material requirements for the bottle itself as well as for
painting and decorating, labels, packaging, and for many other
purposes required to make the bottle a successful product.  Water
is also required at every point.

     The life cycle product analysis includes aggregating the
natural resource requirements of every step. For the example
given here, the product unit chosen for analysis is 1,000 gallons
of beverage delivered to the consumer.  For that product unit,
Table 4-1 shows the energy requirements in terms of total Btu as
well as the Btu by fuel type.  These values result from summing
the energy requirements for each process in the system as shown
in Figure 4-2.  The other natural resources can also be
summarized for comparative purposes, although this is not shown
here.

     One important question is how to ensure that all pertinent
information is considered. For example, what about the resources
expended in manufacturing the steel frames used in trucks that
haul the bottles?  Such questions must be researched in each
instance.
                            Table 4-1

        ENERGY  PROFILES FOR THE DELIVERY OF  1,00.0 GALLONS
      OF  SOFT DRINK IN 2-LITER PET PLASTIC CONTAINERS,  1987
                  (million Btu per 1,000 gallons)
                Natural  gas
                Petroleum
                Coal
                Hydropower
                Nuclear
                Wood

                TOTAL
 6.5
 7.5
 3.8
 0.2
 1.3
20.0
      An important general finding is that a truck hauls literally
 tens or hundreds of thousands of tons of cargo over its lifetime,
 so that impacts allocated to any one load are extremely small
 compared to others.  In other words, manufacturing systems not
 directly required by the bottle system alone are likely not
 creating significant impacts when compared to the "mainstream"
                                38

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 processes.   However,  these  assumptions need to be  checked  in
 every case.   The criterion  is  that potential  impacts can be
 ignored only if their contribution is clearly insignificant to
 the  final total impact for  the entire system.

 Environmental
     For each part of the system shown in Figure 4-2, air and
water pollutant discharges were researched and reported in pounds
per 1,000 gallons of beverage.  For example, the pounds of sulfur
oxides discharged to the air from power plants are included to
the extent that the allocated power from that plant was used for
the product system.  Only pollutants discharged to the
environment after pollution controls have been applied are
measured.  Residues such as sludges or solids remaining after
pollution control are also included.  Solid wastes are included
in terms of both pounds and in terms of the cubic yards of volume
occupied.

     As with the natural resources, these values may now be
summed to arrive at an overview for the 1,000 gallon product unit
system.

Life Cycle Analysis

     The life cycle analysis is useful as a comparative tool.
The numbers presented in Table 4-1 are not meaningful in
themselves,  but need to be compared to others.   Table 4-2  shows a
life cycle energy consumption of plastic  beverage bottles
Table 4-2
ENERGY CONSUMPTION ASSOCIATED WITH THE DELIVERY OF
1,000 GALLONS OF SOFT DRINK IN ALL PET, ALUMINUM,
AND GLASS CONTAINERS AT VARIOUS RECYCLING RATES
(Million Btu per 1,000 gallons)
Recvcliner Rates

Virgin
System
0%
PET (plastic) 21
Aluminum 50
Glass 49
25% 50%
20 18
41 33
42 35
Recycled
System
75% 100%
16 15
24 16
28 21
                               39

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compared to other containers.  In this comparison,  it is clear
that plastic bottles require much less energy than aluminum and
glass at zero percent recycling, but they require only slightly
less energy than aluminum at 100 percent recycling.

     A critical point here is what conclusions can be reached
from this table.  Under example recycling rates of 20 percent for
plastic. 50 percent for aluminum, and 10 percent for glass, Table
4-3 shows that plastic bottles require substantially less energy
than other containers.  Does this mean that only plastic
containers should be allowed?  Should they be substituted for all
other containers?  Most would agree that this table is not
sufficient for decision making of that type for several reasons.
                            Table 4-3

            ENERGY CONSUMPTION OP CONTAINER SYSTEMS
                  AT EXAMPLE RECYCLING RATES
                (Million Btu per 1,000 gallons)
          PET  Plastic  (all  sizes)
          Aluminum cans  (12 fl oz)
          Glass bottles
Recycling Rate

     20%
     50%
     10%
Energy

  20
  33
  46
           Source: Table  4-2
      One reason is that energy is  not the  only  important  issue.
 Other important issues include solid waste and  air  and water
 pollution.   Other natural resource issues  may also  be relevant,
 such as depletion of fossil reserves, cutting of  forests,  or  use
 of scarce water supplies.  In the  life cycle analysis, each of
 these factors can be addressed separately, but  the  question of
 the weighting of factors arises.   For example,  if one system  is
 better on energy but worse on solid waste, how  do you weight
 these two factors?  At present there is no scientific methodology
 to decide whether energy or solid  waste is more important. The
 problem of  weighting also exists within a  single  environmental
 category.  If you measure air pollutants,  such  as carbon  monoxide
 or ozone in pounds, how do you compare one pound  of each?  Which
 is worse or better?
                                40

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      Another issue that arises with life cycle analysis decisions
 is that the favored or encouraged substitute system precludes
 improvements in other systems or potential  new systems  in the
 marketplace.  For example,  glass bottles are lighter in 1990 than
 they were in 1970,  thus resulting in less solid waste,  less
 energy,  and so on for a given bottle.   If they had  been banned in
 1970,  those improvements would have never been made.  It is also
 possible that if their competitors had  been banned,  the lack of
 competitive pressure may have prevented these improvements.
 Either way,  the results may not have been as favorable  in the
 long term.

      Other issues associated  with the decision making are
 economics,  employment,  and  social issues.   Product  substitution
 will result in economic and social dislocations if  a  plant is
 closed at one location,  and another opened  for the  favored
 product at another location.  However, many  of these  issues are
 societal and subjective in  nature,  and  do not lend themselves  to
 scientific,  objective analysis in the same  way as the impacts
 previously described.

      It  appears that when focusing on a single issue, such as
 energy or nonhazardous  municipal  solid  waste,  only a  life cycle
 analysis can provide information  on the broad range of  direct  and
 indirect consequences.   This  is because of  the complexity of
 operations  involved in  the manufacture,  use,  and disposal  of any
 product.  A  narrow  focus analysis  can greatly err in  assessing
 the  actual  impact of any action that affects  purchasing habits.

     However,  in the complex  arena  of comparing a given product
 or a set of  products on  two or more environmental issues, the
 technical power of  life  cycle analysis may not be enough to give
 adequate guidance.   The  reason for this  is that there are no
 analytical weighting factors that tell how to compare
 environmental  impacts of one pound of toxic heavy metal sludge to
 one  gallon of water  usage or consumption of one Btu of  energy.
 While there  are  analytical risk assessment techniques which can
 be applied to these  issues, many consider them controversial and
 subjective. Judgments are still being made,  but primarily in the
 political arena without any technically defensible basis.

Application of Life Cvele Analysis

     The use of this type of analysis has been widely accepted as
a planning tool to determine objective environmental parameters
associated with product manufacture and use.  Table 4-4  is a list
of generalized categories that cover in excess of 100 specific
studies performed since 1969.   However,  most of these studies
have been privately funded and are not generally available to  the
public.

                                41

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                           Table  4-4

                LIST OP KNOWN LIFE CYCLE ANALYSES

          Soft drink bottles  and cans*
          Juice containers
          Milk containers
          Children's diapers
          Detergent boxes and bottles
          Grocery sacks
          Fast food packaging                   _          .
          All major categories of  plastic  products and their
            alternatives (energy only)*
          Wind energy systems
          Common disposable household  products*
          Recycling of common materials
          Food production systems
          *studies generally available
           to the public
MATRIX APPROACH (Pass/Fail)

     While the life cycle analysis approach just described is the
most comprehensive methodology for evaluating products, yielding
Quantitative results, a more common approach is use of a matrix
with "yes/no" or "pass/fail" ratings.  For example, a widely used
book in England (The Green consumer's Supermarket Shopping Guide
[3]) presents a table listing a variety of packaging materials
(plastic bags, glass bottles, etc.) with a series of
environmental criteria (recyclable? degradable? etc.) with yes/no
answers and some comments.  Other products are treated in the
same manner.  For the most part, no quantitative information is
provided in this type of analysis.

WEIGHTING SYSTEMS

     A problem with either the life cycle analysis approach or
the matrix approach is that decisions as to which criteria are
most important are left to the reader or consumer of the product.
For example, two products  (say aluminum cans and glass bottles)
can be compared using a life cycle analysis.  One product may
"win" based on air pollution impacts and the other may "win"
based on the amount of solid waste to be disposed.  Which is more
important, cleaner air or minimizing solid waste disposal?
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     In the 1970s, when the life cycle analysis methodology, was
being developed by EPA and others, some attempts were made to
devise a weighting system for comparing impacts. (Hunt, R.G. et
al., Resource and Environmental Profile Analysis of Nine Beverage
Container Alternatives. Midwest Research Institute for the U.S.
Environmental Protection Agency. 1974.) Because of the
difficulties encountered, the effort was abandoned.  The renewed
interest in evaluating products will probably lead to new
attempts to weight the various criteria.  It has been reported
that Canada is working on a rating system (11, 23), but details
are not yet available.

     There may be some useful precedents in hazardous waste
minimization programs.  EPA's Waste Minimization Opportunity
Assessment Manual (82) includes as an option a Weighted Sum
Method for screening and ranking waste minimization options.  The
manual does not, however, provide any guidance as to which
criteria should receive higher or lower rankings.
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                            Chapter 5

             ISSUES/TECHNICAL PROBLEMS TO BE RESOLVED
     This chapter will summarize problematic or controversial
issues discussed in previous chapters and present some of the
various concerns associated with each.

SELECTION OP PRODUCTS TO BE EVALUATED

     The purpose of product evaluation is twofold: 1) to identify
products which are less damaging to the environment or offer an
opportunity to decrease harmful environmental impacts and 2) to
encourage actions that minimize environmental damage and
encourage further development of clean technology and clean
products.  It is necessary to keep these points in mind when
selecting products to be evaluated. Following are discussions of
several of the criteria used in product selection that may be
somewhat vague or controversial.

Products That Are A Significant Factor in the Waste Stream

     The key issue here is definition of the term "significant."
Products may be considered significant due to:

          •    Large weight or volume contribution to waste
                (includes contributions to air, water, and soil
               pollution, and consumption of landfill space)

          •    Hazardous or toxic content

          •    High potential for improper disposal  (such as
               littering)

               Mobility in the environment, particularly of
               hazardous materials

     Significance should not automatically be assumed based on
the cost of the product to the consumer or the cost to the
manufacturer to make the product environmentally acceptable.  The
cost to the environment is the key issue.  Environmentally
acceptable products may cost somewhat more if the manufacturing
process has to be redesigned or new equipment purchased, or may
cost less, if environmentally acceptable manufacturing causes the
manufacturer to identify and reduce sources of waste.
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 Products That Are Simplest To Do Are Often Done First

      The problems here may arise from oversimplification of
 criteria used to assess products, or the selection of products
 which may be easily and accurately evaluated but do not have a
 significant effect because of low environmental impact,  low
 sales,  lack of consumer support,  or other reasons.

      In starting up an environmental labeling program,  for
 example,  the tendency is to choose easily evaluated products in
 order to gain experience and introduce the program without long
 delays (25,  32).   This is fine as long as criteria and judgments
 are not oversimplified.   For example,  products made from recycled
 paper must not be judged solely on recycled content.   As thorough
 an attempt as possible should be  made  to assess the product's
 entire life cycle,  cradle to grave,  and at the least,  assure that
 minimum environmental standards are being met everywhere in the
 life cycle.

      Ideally,  each stage of the life cycle would be thoroughly
 evaluated quantitatively for all  its environmental  impacts,
 including resource and energy usage, air,  soil,  and water
 pollution.   Until suitable methodologies are developed for
 comparison of different  environmental  impacts,  however,  it should
 at least  be  assured that an improvement in the  selected  area has
 not resulted in an environmentally damaging shift in another
 area.   If this is not verified, there  may be no net environmental
 improvement  associated with a product,  and possibly increased
 harm.

      For  the second scenario above,  consider a  theoretical
 product manufactured by  only a few companies, with  a single
 manufacturing  process used  by all  manufacturers,  involving the
 same  resources and  raw materials.  It would  be  relatively easy to
 conduct a thorough  life  cycle analysis  on  each manufacturer's
 version of the product and  compare them.   But suppose sales of
 the product  are typically low, the product has no toxic content
 or emissions associated with  its use, and the container is
 recyclable or  reusable.  Little would appear to be gained
 environmentally by  labeling this product.

Whether To Include Hazardous  Products

     There are two schools of thought on this issue:  l)
products containing hazardous materials are environmentally
damaging, regardless of minor differences among brands, and
should not be called  "clean products" in any instance,  and 2)
because products containing hazardous materials are
environmentally damaging, it is important that the least damaging
                               45

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be identified and promoted to minimize the negative impact on the
environment.  Both of these approaches have been used.

     West Germany chose to exclude products containing harmful
materials from its labeled category for non-CFC aerosols, thus
excluding products such as some household cleaners (23).   What
options would a consumer have if he or she wished to purchase an
oven cleaner and found none with an environmental label?
Possible reactions include a) assume no significant environmental
difference among brands and select any one, b) read the labels to
try to determine which ones are least harmful, or at least do not
contain CFCs, c) assume all must be bad for the environment,
purchase none, and attack the oven with steel wool and elbow
grease (probably the best option from an environmental
standpoint, unless the life cycle environmental impact of steel
wool is greater than the life cycle environmental impact of any
of the cleaning products available).

     On the other hand, the West German program does label
products such as low-pollutant coatings and corrosion protection
coatings low in lead and chromates.

     Probably the most practical basis for deciding whether or
not to label a product with hazardous or harmful content is to
examine the possible substitute products or processes.  It may
not be possible, for example, to find a suitable corrosion
protection coating for a given application which does not contain
any lead or chromates, so it would be important to know which
products contain the least of these harmful materials.  On the
other hand, perhaps all oven cleaners contain environmentally
harmful materials, but the desired result can be obtained without
using chemical cleaners, and therefore labeling of chemical
cleaners is not necessary.

COMPLETE LIFE CYCLE ANALYSIS VERSUS EASIER, QUICKER METHODOLOGIES

     The main two issues here are time and expense involved in
analysis versus environmental benefit, and consumer loyalty and
possible disillusionment or confusion.

     As discussed in Chapter 4, a true cradle-to-grave life cycle
analysis is time-consuming, expensive, and raises difficult
questions about weighting the relative importance of  various
environmental impacts.  Quick and easy judgments made on the
basis of one or limited criteria tend to give clearcut "black and
white" answers, which may, however, be misleading in  terms  of
overall environmental impact.  Unfortunately, the less technical
research that goes into an evaluation, the sooner the potentially
erroneous conclusion can be  released to the public—a public
increasingly eager to do the right thing environmentally.

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      Once environmentally-committed consumers  have  embraced an
 idea,  it may be difficult to change their minds with the  facts.
 A case in point is shopping bags.   "Everybody  knows" that paper
 shopping bags are better than plastic  because  paper bags  are
 degradable and recyclable (judgment based on limited criteria).
 Supermarkets began courting environmentally conscious consumers
 by promoting the use  of  paper bags,  with  enthusiastic public
 response.   Environmental groups published shopping  guides urging
 consumers to refuse plastic and demand paper.  Sometime later,
 several life cycle studies were released  showing that
 polyethylene bags use less energy and  resources than paper bags
 (67).   Where are the  "demand plastic"  campaigns?  Instead,  some
 stores are providing  bins to collect used plastic bags for
 recycling,  and environmental guides  are advocating  reusable cloth
 bags  over paper and plastic (8, 10).

      The time,  expense,  and resolution of gray areas involved in
 life  cycle analysis compared to limited criteria evaluations is
 also  a controversial  point for clean product programs.  Some
 argue  that consumers  want information  now, and that delays  for
 comprehensive evaluations will result  in  impatient  consumers
 using  unsubstantiated, unregulated manufacturers' claims  as a
 basis  for  their purchasing decisions.  This may result in no net
 environmental benefit or even conceivably harm, and may leave
 consumers  so confused or cynical that  they lose faith  in  the
 effort.  The Attorneys General of several states are currently
 investigating the substantiation for environmental  claims
 associated with several  types of products including trash bags
 and diapers  (19,  35).  The opposing  argument is that it is most
 important  to ensure that information supplied to the consumer be
 correct, reliable,  and as  complete as possible; otherwise the
 program becomes nothing  more  than a marketing gimmick  (25, 32).

 HANDLING TRADE-OFFS

     In  complete  life  cycle analyses, summaries of environmental
 impacts  such as total  energy usage or water usage associated with
 one product  can be directly compared to the same impacts
 associated with another.    Problems arise over weighting different
 impacts  relative to each other, such as different categories
 (less energy usage but more solid waste produced),  different
 streams  (less air pollution but more water pollution), and
 different components in the same stream (less heavy metals but
more toxic organics in the wastewater stream).   There are no
established  scientific methodologies for deciding which is more
 important.   Following are discussions of some ways to handle
these trade-offs, and some pros and cons of each.
                               47

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Weighting Systems

     Two ways to handle environmental impact trade-offs are by
designing a weighting system, which is likely to involve at least
some subjective judgment as to which components are least
desirable or most harmful, or, in particularly difficult areas,
by abandoning quantitative comparison of each individual
component in favor of combining several under minimum or maximum
allowable limits.  For example, the allowable limit for
production may specify "less than x pounds of toxic materials in
effluent water," which would lump together heavy metals, toxic
organics, and all other toxic materials without making a direct
comparison or requiring a decision on which is more harmful.
This in itself represents an unspoken subjective decision that
all toxic materials in the effluent water are equally damaging.
While this is certainly not entirely accurate, it does provide a
simplified and practicable approach.

     Standard methodologies for assessing risks from toxic
substances do exist and could potentially provide guidance in
weighting environmental impacts.  These studies generally must be
very carefully applied, however; they may contain subjective
elements, and may be based on limits that may or may not be
directly tied to real risks.

Pass/Fail Systems

     Carrying the previous method a little  further and  replacing
most quantitative comparisons with minimum  or maximum allowable
level«Twould result in a  pass/fail system.  This would  require
less collection and evaluation of quantitative data, but would
effectively  mask environmental differences  among products  as  long
as they did  not exceed the  limit allowable.  Advantages in
simplification and consistency of evaluation using this method
could be  outweighed by misleading conclusions on overall
environmental  impact.

     For  example, suppose manufacturers A and B are both
 interested in  obtaining  an  environmental  label  for their  recycled
product.   Recycled content  requirement is 70 percent.
Manufacturer A is running at or  just below  all pass/fail  emission
 limits, but his  product  has 70 percent recycled content,  and so
he is  awarded  a  label.   Manufacturer B runs all his processes
with pollution well below all pass/fail  limits, but his recycled
 content is only 50 percent.   When he raises .re?y^d  c^^t J*
 70 percent,  one waste stream slightly exceeds  the  limit,  but all
 others remain well below.  B is  denied the  label.  Whose Process
 is more environmentally sound?  (Note:  Pass/fail  limits should
 be set tighter than government regulatory standards,  otherwise
 meeting the labeling requirements means nothing more than

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 operating legally. Environmental labels are intended to identify
 and encourage the development of products that significantly
 reduce negative environmental impact.   Awarding a label for
 merely meeting regulatory requirements does not encourage
 innovation in environmental excellence, unless significant
 improvements are made in other areas while emissions remain
 constant.)

 Letting the consumer Decide

      Another way of dealing with trade-offs is to abandon the
 idea of a  simple environmental logo in favor of presenting more
 environmental impact information on a  label and letting the
 consumer decide what is environmentally preferable (25).   This
 would be similar to nutrition labeling.  Products do not claim  to
 be "nutritionally superior" or "best for health"; rather)
 information on calories,  fat,  cholesterol,  vitamins,  minerals,
 etc.  is provided for the consumer to judge.   Food products
 provide an  interesting parallel to "environmentally  friendly"
 products in terms of single criterion  advertising, such as "No
 Cholesterol" (with no mention of fat calories)—comparable to "No
 CFCs" (with no mention of other toxic  chemicals).

      Research on nutrition labeling has shown,  however,  that  many
 consumers are confused by so much information,  or do  not know how
 to use it to make effective decisions  (11).   There is no reason
 to suspect  that the same  would not be  true  of a detailed
 environmental labeling program.   Additional consumer  research
 could be conducted to determine what types  of information
 consumers would consider  most  useful in making environmentally
 beneficial  purchasing decisions—would they prefer a  simple "seal
 of approval"  or more detailed,  factual  information?   A survey
 conducted by the Michael  Peters Group  indicated that  the majority
 of consumers  would pay extra for products in  degradable or
 recyclable  packaging,  but the  survey did not  appear to address
 issues  such as  where consumers  get their information  on products'
 environmental aspects,  and how  they  use this  information to make
 purchasing  decisions (43).

 Using Only  One  Easily Determined Criterion

     The advantage  of a single  criterion approach is that it  is
 easily  evaluated  and easily understood by consumers.   As
 discussed in several  preceding  sections, the primary danger of
 single  criterion  evaluation  is the possibility that judgments
will be oversimplified and erroneous conclusions on environmental
 impact will be reached; therefore, consumer actions based on this
will not have the desired environmental effect.
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LEGAL IMPLICATIONS OF MAKING SUBJECTIVE JUDGMENTS

     No matter which of the previously discussed methods is used
to evaluate the environmental friendliness of products, there
will be those who do not agree with criteria, evaluation methods,
or both.  Since it is impossible to be completely objective in
evaluating and comparing products because of lack of complete
knowledge about all environmental impacts, a highly advisable
course of action for groups involved in clean product efforts
would appear to be to publish as complete as possible a statement
of their evaluation policy.  This would include specifying the
evaluation method(s) used and the requirements for each: for
example, single criterion (define criterion and specify
requirements), pass/fail (specify limits and components which
they cover), and weighting systems (specify weighting factors for
each stream).  While this will not prevent disagreement, it will
be useful in the event of potential lawsuits.  If evaluation
policy is not specified in detail, the evaluating organization
will be leaving itself open for legal action by disgruntled
manufacturers who feel they have been unfairly treated.

IMPLEMENTATION ISSUES

     Many criteria can be used for evaluating whether products
are "clean"  or "environmentally friendly," and some methodologies
exist for implementing the evaluations. One of the problems to be
resolved is  the issue of who or what agency should implement the
programs. There are several options.

Agencies That Might implement: Programs

     Some of the Clean Product programs that have been
implemented  in other countries are being  done at the national
level  (e.g., Germany and Canada). In the  United States, programs
of this kind have not been implemented at the federal  level, but
there is precedent  in some of the activities of the Food and Drug
Administration and  regulation of toxic substances.  This negative
type of labeling is clearly different  from a program in which the
government recommends preferred products, thus  influencing
consumer purchasing decisions.

     A number of states are moving  in  the direction of some kind
of  "environmentally friendly" product  regulations. The states
that are members of the Coalition of Northeastern Governors
 (CONEG) have been particularly active  in  this regard,  but  others
 (Minnesota,  for example) are also pursuing programs of this sort.
Packaging of consumer products has  most often been the focus  of
efforts at  the state  level.
                                50

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      Environmentalist or other nonprofit groups also are involved
 in studying Clean Product/source reduction issues. Examples
 include the Conservation Foundation and the Pennsylvania
 Resources Council. These groups often are in a formal or informal
 dialogue with EPA and organizations like CONEG.

      Finally, private companies are very aware of the Clean
 Products issue,  and many of them have been carrying out their own
 initiatives,  sometimes in connection with groups like CONEG.

 POLICY IMPLICATIONS

      There would be some advantages to implementing a Clean
 Product program  nationwide.  Manufacturers generally find it
 easier to comply with one consistent nationwide program than  a
 fragmented,  state-by-state mixture of regulations.  However,
 having a federal program would not necessarily preclude states or
 other organizations having their own programs  as well.   There are
 many examples of states enacting more stringent regulations than
 those promulgated at the federal level.

      There would also be the necessity of determining which
 agency(ies) would implement  the program.  Extensive  research would
 be  required,  but also an implementation mechanism would have  to
 be  developed  and administered.  Implementation  could be  through
 regulations or restricted to educational  programs,  or some
 combination of measures.

      Another  issue with administering a program of  this sort  is
 the necessity to update the  criteria  used to measure products.
 These criteria can change with  time as research provides new
 information on environmental phenomena. Also,  new products are
 continually being developed,  and processes used to manufacture
 products also evolve  over time.  For example, many commonly used
 packages today (e.g.  microwaveable containers)  hardly existed 10
 years ago. New recycling  programs are  announced almost  daily by
 industrial organizations. The evaluation process  would  have to  be
 quite flexible to keep  up with new development, or run  the risk
 of  stifling creativity.

 RECOMMENDATIONS

      In summary,  manufacturers and consumers, the two groups upon
whom  the success of clean or environmentally friendly products
depends, generally appear to recognize the potential benefits of
 such  a plan and indicate that they are eager or at least willing
to participate.  As yet, however, no universally accepted and
supported course of action has been identified.  Current efforts
by various individual groups may be well-intentioned, but do not
adequately address the comprehensive environmental impacts

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associated with a product's entire life cycle, and therefore may
offer consumers misguided direction.

     Additional research and effort in several areas could aid in
the development and support of a clean products program with less
room for erroneous conclusions and consumer confusion. These
areas include:

     •    Standardized definition and usage of environmental
          impact terminology

     •    Survey of consumers to find out what types of
          information/education would be most useful to them in
          making environmentally beneficial purchasing decisions

          Further development of methodologies to thoroughly and
          effectively evaluate products on a life cycle basis

     •    Development of a standardized environmental labeling
          program

     •    Other reward incentives for manufacturers providing
          cleaner products or technologies

     Instituting and enforcing standard definitions, evaluation
methodologies, etc. and communicating information to consumers
will be no small task. The ultimate goal, of course, is to reduce
the harmful environmental effects of the production and
consumption that fuel our economy and current lifestyle.

     Additional measures that could minimize environmental
impacts of consumer products might include:

     •    Education on proper use and disposal of products.  A
          manufacturer of concentrated fabric softener which
          requires 75 percent less packaging than traditional
          products expresses concern that the environmental
          benefits associated with reduced packaging may be
          negated by consumers failing to dilute the product
          properly and hence using more of the product than
          required.  As far as disposal, it is important that
          even cleaner products, such as batteries with reduced
          levels of heavy metals, be disposed of in a responsible
          manner.

      •    Elimination of high environmental impact products for
          which acceptable, less damaging alternatives exist.
          For example, aerosol deodorants could be replaced by
          existing solid and liquid deodorants which  require less
          non-recyclable packaging and no chemical propellants.

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           Decisions on suitability of substitutes  for some
           products will be more subjective  than  for other
           products—for example,  should  battery-operated  watches
           be  eliminated in favor of mechanically wound watches?
           What  about exceptions for consumers with physical
           handicaps or allergies to certain products?

           Elimination of excess packaging.  This issue is already
           being addressed  by CONEG and others (7,  8,  40,  68).  it
           also  involves subjective decisions on  what  packaging is
           necessary and what is excessive,  particularly when it
           comes to convenience  packaging and packaging to enhance
           attractiveness to consumers.

           Efforts  to reshape today's convenience-oriented
           consumer perspective  to  a more environmentally
           responsible attitude.  Manufacturers,  motivated by
           profit rather than social concerns, are  likely  to
           resist any change that will  reduce sales and income.
           Ways must be found to make this change financially
           attractive.   Some companies, such as The Body Shop in
           the United Kingdom, have managed to adopt an
           environmentally responsible theme and become very
           profitable  (2, 4, 5).

     The benefits to the environment,  and consequently to
mankind, that may be gained by support of clean  products are
considerable.   The  information provided and issues raised in this
report can serve as a starting point.
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                           Appendix A

                     ANNOTATED BIBLIOGRAPHY
ENVIRONMENTAL BOOKS, SHOPPING GUIDES, AND CATALOGS

1.   Council on Economic Priorities.  Shopping For a Better
     World.  1989.  This guide to "socially responsible shopping"
     rates name brand products according to the performance of
     their parent company in areas such as environmental
     performance, animal testing, charitable contributions, and
     advancement of women and minorities."  Data on
     characteristics of individual products are not presented;
     rating criteria are not always clearly defined.

2.   Elkington, John; Hailes, Julia; and Makower, Joel.  The
     Green Consumer.  Tilden Press, 1990.  Defines ideal "green"
     products and offers suggestions for environmentally
     responsible driving, shopping, and traveling.  Contains
     tables and matrix presentation of data and information to
     use in assessing environmental impact of products.

3.   Elkington, John, and Hailes, Julia.  The Green Consumer's
     Supermarket Shopping Guide.  London:  Victor Gollancz Ltd,
     1989.  While much of this book is devoted to issues
     unrelated to this clean products report (e.g., animal
     cruelty, nutrition), it does include some interesting matrix
     tables in which certain products and their packaging are
     rated according to several relevant criteria.  In most
     instances the ratings are in a "pass/fail"  (yes/no) mode,
     but some criteria  (e.g., energy use) are stated
     quantitatively.

4.   Hollender, Jeffrey A.  How To Make The World A Better Place.
     William Morrow and Company, Inc.  1990.  Contains
     suggestions for addressing and alleviating world problems in
     areas such as environmental protection, world hunger, peace,
     and human rights.  The environmental section contains
     information on various categories of products, effects on
     the environment, and suggestions for individual action.

5.   MacEachern, Diane.  Save Our Planet - 750 Everyday Ways You
     Can Help Clean UP The Earth.  Dell Publishing, 1990.  This
     book assesses the general health of the planet, identifying
     problems such as "garbage overload," global warming, and

                                54

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8.
      acid  rain.   Lifestyle  adjustments  and  actions  are
      recommended  to  alleviate various environmental concerns.

      Manning, Anita.   "Ecology Books Are A  Plentiful Resource."
      USA Today.   February 28, 1990.  Reviews  several recently
      published books with environmental themes,  including guides
      for environmentally safe shopping.

      Pennsylvania Resources Council, Inc.   Become An
      Environmental Shopper.  September  1988.  Shopping guide
      makes recommendations  for environmentally responsible
      shopping based on the  "Four R's":  Reduce (amount of trash),
      Reuse (products and containers) , Recycle (as much as
      possible) , Reject (excessive packaging, nonrecyclable
      packaging, and products harmful to the environment) .
      Provides information on tactics to increase manufacturer
      awareness of consumer  concerns about environmental  issues,
      and information on organizing an environmental  shopping
      campaign.

      Pennsylvania Resources Council, Inc.   How to Become an
      Environmental Shopper  - Special Addendum.  March 1990.  In
      light of studies  showing that virgin paper bags have greater
      negative impact on environment than polyethylene bags, PRC
      recommends demanding (and reusing)  bags that can be reused
      and recycled.  Other recommendations include favoring
      reusable containers to degradable throwaways and polystyrene
      (at least until polystyrene recycling becomes commonplace) ,
      and supporting CONEG legislation to phase out heavy metals
      in packaging.

     Ryan,  Frank,  and Ray,  Stephen, for the Ministry for Planning
     and Environment and the Victorian Association for
     Environmental Education.   10 1 Wavs to Protect Our
     Environment.   Melbourne,  Australia, 1989.  Contains
     suggestions on environmental shopping,  product substitution,
     and resource conservation steps.   Shopping tips include
     using energy efficiency ratings on appliances,  avoiding
     excess packaging,  and rbuying the best quality goods for a
     longer lifetime.

10.  The Earthworks Group.   50 Simple Things You  Can Do To Save
     The Earth.   Earthworks  Press,  Berkeley, CA,  1989.   Assesses
     environmental problems  and gives suggestions for
     remedial/preventive  action.
9.
                               55

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ENVIRONMENTAL LABELING
11,
12,
13,
 14,
Applied Decision Analysis, Inc.  Environmental Labeling in
the United States - Background Research. Issues, and
Recommendations.  Draft report for Office of Pollution
Prevention, U.S. Environmental Protection Agency. December
5, 1989.  Presents an overview of existing and proposed
environmental labeling programs in other countries,
including goals and structures, and briefly discusses a few
environmental shopping and labeling programs in the U.S., as
well as California Proposition 65.  Second section discusses
general elements of labeling effectiveness and summarizes a
literature review on the effectiveness of several types of
existing labeling programs, including food and nutrition
labels.  Concludes with recommendations as to the goals,
functions, and structure of a U.S. environmental labeling
program.

Associated Press.  "Ads With Environmental Claims Must Be
Accurate, FTC Warns."  The Kansas City Star.  March 17,
1990, p. 3.  The Federal Trade Commission announced that
they will vigorously pursue deceptive environmental claims
in advertising and packaging.  Various environmental groups
and individuals have criticized environmentally-oriented
marketing for making misleading claims.

Austrian Ministry of Environment, Youth, and Family.
Environmental Labelling; Representative Model as of December
1989.  Covers various aspects of proposed labelling system,
including sections on legal-administrative framework for
awarding environmental label, awarding criteria/fundamental
guidelines of assessment, and accompanying
measures/protection against abuse.
     The proposed structure and procedures are  similar to
West Germany's Blue Angel program.  Generally,  the product
and its packaging are to be evaluated together,  although in
a few cases labelling may be awarded for the packaging only.
An interesting concept in this model is the use of different
colors in the label to designate different categories of
environmental soundness;  for example, blue for  air and
water, red for conservation of energy, etc.

Beverage Industry.  "Environmental concerns boost use of
plastic trays."  April 1990, p. 39.  Environmental concerns
are fueling the move toward reusable tertiary packaging  in
the beverage industry.  The shift has mainly occurred in the
bottle market, but plastic trays  for cans are now being
introduced.
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 15.   Canadian  Department  of  the Environment.   Environmental
      Choice  Product  Guidelines.  Under Canadian Environmental
      Protection Act,  Section 8.(l)(b).  Approved Guidelines  ECP-
      01-89 through 04,  07, 08, 10,  11, 13, and 14.  Discussion
      Draft Guidelines ECP-01-89 through 03, 09, and ECP-15-90
      through 18.  Documents  contain requirements that products  in
      various categories must meet in order to  qualify for an
      environmental label.

 16.   Clarke, Marjorie J.  "The Paradox and the Promise of Source
      Reduction."  Solid Waste & Power.  February 1990.  Discusses
      various methods  for  achieving  source reduction, including
      government standards for environmentally  sound packaging and
      products, and public education on how to  evaluate the
      environmental merits of purchases.

 17.   Drayna, Jonathan.  "Fort Introducing Recycled At-Home
      Goods."  Marketplace Magazine.  Volume 1, Number 6, March
      1990.   Based on marketing success in environmentally
      conscious Europe,  Fort  Howard  Corp. has introduced "Green
      Forest" tissue and paper towels from recycled paper without
      inks or scents.  Fort Howard also plans to test market a
      toilet paper from recycled newsprint made without bleaching,
     which is a major source  of the water pollution associated
     with paper recycling.

18.  Emissions Standards  Division,  Office of Air Quality Planning
     and Standards.   Consumer Product Comparative Risk;   Market-
     based Pollution Prevention.   Outlines proposed project with
     objective to examine full risks of some home-use products
     from cradle to grave, screen them to obtain a focus group,
     perform a detailed risk scoring of alternative products, and
     examine how to perform and distribute comparative risk
     analysis for consumer products.  Evaluation would include
     human health risks and environmental risks.   Aim is to
     prevent pollution by eliminating market demand for products
     with the most human and environmental health risks.

19.  Environment Reporter.  "Group  Plans Product Labeling
     Campaign to Combat Deceptive Environmental Claims."   The
     Bureau of National Affairs,  Inc.   Washington,  D.C.   April
     20,  1990.   The  National  Toxics Campaign launched a  drive
     April 13 to standardize  environmental claims  on consumer
     products and stop manufacturers from making false and
     deceptive claims.  The Green Cross  Certification Company
     will award two  seals  of  approval:  for recycling (product
     must contain highest  possible  recycled content),  and total
     environmental impact  (product  must be environmentally
     benign,  manufactured  in  a responsible manner,  and be free of
     excess packaging).  The  labeling program  is being supported
                               57

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     by four Western grocery companies.   Labeled products may
     appear in stores later this year.   The Attorneys General of
     eight states are investigating companies suspected of making
     false environmental claims, specifically, claims regarding
     plastic bags, disposable diapers,  polystyrene fast-food
     containers, and "ozone-friendly" aerosol sprays.  New York
     Attorney General Abrams is pushing for a state law to ban
     unsubstantiated "environmentally friendly" claims, and hopes
     for action on this issue from the Federal Trade Commission.

20.  Environmental Choice, Canada.  Ecologo - The Environmental
     Choice Newsletter.  Issue 3.  February 1990.  Summarizes
     content and current status of approved, proposed, and
     withdrawn guidelines for environmentally labeled products.

     Environmental Choice, Canada.  Media Backgrounder -
     Environmental Choice.  Overview of program's purpose, type
     of products considered and effects, and organizational
     structure.

     Environmental Choice, Canada.  Questions & Answers Sheet.
     Answers basic questions about the Environmental Choice
     program, such as purpose, who sets criteria and how, and how
     to apply for an ecologo.

     Environmental Data Services, Ltd.  Eco-Labels,:—Product
     Management in a Greener Europe.  London, 1989.  Overview of
     eco-labeling - manufacturers' response to growing consumer
     demand for environmentally responsible products.
     Description of existing national programs in West Germany,
     Canada, and Japan.  Extensive information on West German
     Blue Angel program, including manufacturers' response to the
     program, listing of the program's successes, and  in-depth
     discussion of several areas  for improvement.

     Environmental Data Services  Ltd, London.  ENDS  Report.
     Newsletter number 180, January  1990.  Newsletter  contains
     updates on environmental  labeling in  industry,  government,
     and the European Economic Community.

     Environmental Labelling  in the  KFTA-Countries.   Seminar at
     the TEM-Centre, Sjobo, Sweden,  arranged by  the  Foundation
     TEM - University  of  Lund.   August 28-29,  1989.   Contains
     presentations on  the  current status or proposed
     implementation  of environmental labeling programs in
     Austria,  Finland, Norway,  Sweden, Switzerland,  West Germany,
     and the European  Community.   Presentations  include
     information  on  organizational structure and administration,
     selection of product categories and criteria,  and product
     evaluation.
21,
22,
23,
24,
25.
                                58

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 26.   Erickson,  Greg.   "New Trends  Make Food A Challenging Game "
      Packaging.   January 1990.   Discusses  current major trends in
      food packaging,  including  environmental concerns.   Many
      merchandisers  such as Wal-Mart  are giving increased
      attention  to "green"  products and packaging;  however,
      environmental  acceptability often conflicts  with consumer
      values  such  as convenience and  single serving packaging.

 27.   Ferretti,  Will.   New  York  State Department of Economic
      Development, Office of Recycling  Market Development.
      Memorandum to  Source  Reduction  Council  Board of Directors.
      February 9,  1990.   Proposes a "labeling summit" for Source
      Reduction  Council  and Northeastern Recycling Coalition  to
      meet and mutually  establish a consensus program on labeling.

 28•   Final Report of  the Green  Spot  Advisory Panel. December
      1989. Mark Wahlgyist,  chairman. Printed by Jean Gordon,
      Government Printer: Melbourne,  Australia.  In  March 1989,  in
      response to growing consumer  concern  about products'
      environmental  impacts, the  Victorian  Government initiated
      the  Green Spot consumer awareness  program  to  promote
      environmentally  sound products.  The  first stage of the
      program involved publication  of a  series of Green  Spot
      Bulletins, advising consumers how  to make  environmentally
      sound purchasing decisions  regarding various  products.  The
      second stage of  the program involved  forming  an advisory
      panel in May 1989 to  investigate the  feasibility of a
      national environmental labeling program and to make
      conclusions and  recommendations.  This  final  report contains
      proposals and  recommendations for an environmental labeling
      program's structure, operation,  funding, selection of
      product groups, product criteria and evaluation,  and
     marketing.  Annexes to the report include comments of
     various Australian manufacturers,  trade associations, and
      other groups; discussion of environmental labeling programs
      in other countries  (only Canada covered in any depth); and
     the Green Spot draft criteria for unbleached paper products,
     chlorine-free paper products,  recycled paper, and products
     made from recycled plastics.

29.  Flam, Faye D.  "At the Supermarket: A Confusion of Green."
     Chemical Week.   April 25,  1990,  p. 13.  Scientific
     Certification Systems of Sacramento, Cal. has been appointed
     by four West Coast supermarket chains to evaluate the
     environmental friendliness  of consumer goods  and  award
     "Green Cross" seals of approval.  Green Crosses will be
     awarded to products that contain an acceptable proportion of
     "sustainable material and/or recycling material"  and are
     manufactured using processes that  omit no toxic substances.
                               59

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     Companies must pay to have their products considered.
     Supporters, including the National Toxic Campaign Fund,
     believe that the program will discourage false and
     misleading claims and guide consumers toward environmentally
     safe products, while critics contend that the complexity of
     environmental concerns makes it difficult to label products
     as good or bad, and will confuse consumers.

30.  Fort Howard Corp.  Brochures on Envision and Green Forest
     products.  Stresses environmental friendliness of these
     products based on 100 percent recycled content and resulting
     reduction of paper in municipal solid waste.

31.  Goel, Vindu P.  "Fort Howard Corp. Introduces 100% Recycled
     Toilet Tissue, Paper Towel."  Wall Street Journal.  March 2,
     1990.  Fort Howard industries, which has based its business
     on recycled rather than virgin paper pulp, has launched a
     major line of bathroom tissue and paper towels made entirely
     of recycled paper fibers.  They are the first major paper
     manufacturer to use recycled paper content of bathroom
     tissue as a marketing point to appeal to environmentally
     concerned consumers.  Competitors contend that consumers do
     not associate softness, quality, and absorbency with
     recycled products.

32.  Hirsbak, Stig; Nielsen, Birgitte B.; and Lindhgyist, Thomas.
     SCO-Products;  Proposal for a European Community
     Environmental Label.  Prepared for the Commission of the
     European Communities.  Danish Technological Institute,
     Department of Environmental Technology, January 1990.  The
     European Community Commission believes that environmental
     labeling should constitute an essential element of the
     Single Market, starting in 1993.  This report focuses on the
     status of environmental labeling  (both existing and planned)
     in EC member states, recommendations on how to establish and
     select criteria for different product groups, and
     recommendations for structure and financing of an EC
     environmental labeling system. The  following paragraphs
     summarize the research team's views and conclusions.
          Criteria should distinguish between products with
     different environmental properties  but common fields of
     application, and must be defined  in such a way that they are
     measurable.  In establishing criteria, the environmental
     impact of a product at all stages of its life cycle should
     be considered; it may then be possible to narrow the
     criteria to a  few crucial areas.  Since there are no general
     rules as to which phase of the life cycle or which aspect of
     environmental  impact is most important, each product group
     must be analyzed to determine its most important
     environmental  impacts and develop the methodology to assess

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33
34,
35,
36,
 these impacts.   In addition,  the  amount  and  costs  of  product
 testing must be realistic when  compared  to the price  of  the
 product and the size  of  its market.  Criteria used or
 proposed by various countries are discussed.  Problems of
 establishing criteria are exemplified by considerations
 applied to  real products such as  batteries,  detergents,  and
 paints.
      The structure proposed for an EC labeling program
 consists of two central  bodies  to decide upon criteria and
 advise in criteria development  and labeling  system
 operation,  as well as national  advisory  committees in the
 member countries to pre-select  product groups and  criteria
 and handle  label applications.
      The labeling  program should  be self-financing within a
 few years of startup,  with fees for use  of the label
 corresponding to the  costs of operating  the  system,
 including testing,  salaries,  etc.  It is proposed  that the
 fee consist of  a basic annual fee plus an additional  fee
 based on product sales.  Additional funding  could  be
 obtained by imposing  charges  on heavily  polluting
 manufacturers:  the "polluter  pays" principle, or "PPP."
      Annexes to the report provide additional useful
 information on  environmental  labeling in EC member states,
 Nordic and  other EFTA countries,  and other countries  such as
 Canada and  Japan.

 Japan Environment  Association.  The Ecomark System.
 Translation provided  by  Chris Semonsen,  Dynax Urban
 Environmental Research Institute, Japan.  Basic information
 on Ecomark  program, including history, objective,  selection
 of products, and approval process.

 Larson, Melissa.   "Environmental  Concerns Are The  Cleaner
 Trend."  Packaging.   December 1989.   Environmental concerns
 are influencing packaging for household cleaning products,
 specifically use of recycled  PET  in packaging and
 superconcentrated  refills to  cut down on packaging.

 Lipman, Joanne.  "Trendy Environmental Themes Hit Sour Notes
 Among Public."  Wall Street Journal.   May 3,  1990.   So many
 companies have  rallied around the environmental cry that a
 skeptical public is wondering just how meaningful many of
 these  claims are.  Companies that have abandoned or modified
various environmental claims  include Mobil,  Dow Chemical,
and First Brands.

Harder, Howard.  "It Isn't Easy Being Green."  Presentation
at the Environmentally Conscious Consumer Revolution
Seminar.  January 9, 1990.   While consumers  claim to be
eager to support environmentally friendly products, they
                               61

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37,
38,
39,
40,
41.
must be wary of irresponsible or misleading claims.
Exploitative environmental marketing has the danger of
resulting in consumer cynicism and resulting loss of
effectiveness of environmental advertising.  Companies which
make environmental claims should be prepared for thorough
scrutiny and resulting negative public relations impact if
found lacking in environmental commitment and performance,
even in other areas of their company.  Realistically, a
company cannot expect its environmental efforts to please
everyone, and must be prepared to deal with criticism.

Marinelli, Janet.  "Garbage at the Grocery."  Garbage.
September/October 1989.  Reviews solid waste situation,
giving particular attention to plastic packaging.  Advises
shoppers to reject overpackaged products, reuse containers,
and recycle as much as possible.  Supports legislation to
make the price of a product reflect the cost of disposal,
and challenges packaging designers to work toward single
material packaging, refillable containers and reusable
containers.

McGrath, Regina.  "Changing the Big Yawn to Big Bucks."
Pulp & Paper.  November 1989.  Discusses environmentally
friendly paper products in Sweden, made with nonchlorine-
bleached pulp.  U.S. companies are selling these products in
Sweden and stand to gain consumer support and increased
market share if they would offer similar products in the
U.S.

Minister, Environment Canada.  Release;  First Three
Products Proposed for Environmental Choice Program.  March
20, 1989. Announces re-refined motor oil, insulation
material made from recycled paper, and selected products
from recycled plastics as the first products proposed  for
Environmental Choice logo.  Briefly discusses anticipated
environmental impacts of the product categories.  Solicits
public comment on draft guidelines.

New York Public Interest Research Group, Inc.  Plagued bv
Packaging.  January 1990.  This guide addresses products and
packaging that produce the most waste and present the  most
disposal problems.  Included are disposables  (cameras,
razors, diapers), laminated plastic squeeze bottles, mixed
material juice boxes, and degradable plastic bags.  Guide
publishes manufacturer hotline numbers and urges consumers
to call and demand company action.

Norwegian Foundation for Environmental Product Labels.  A.
Better Environment!  The National Foundation  for
Environmental Product Labels.  Kristian  Augusts gate  5, N-
                                62

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      0164,  Oslo  1 Norway.  General  information  on purpose  of
      environmental  label, participating Nordic  countries,  product
      eligibility, and  effectiveness of environmental  labeling,
      with reference to German Blue  Angel program.

42.   Norwegian Foundation for Environmental Product Labels.
      Norwegian Foundation for Environmental Product Labels -
      Status per  April  1990.  Kristian Augusts gate 5, N-0164,
      Oslo 1 Norway.  Voluntary Nordic environmental labeling
      scheme will be introduced in 1990.  Labels will  be awarded
      to products least harmful to the environment, with a  fee
      charged for use of the label.  The structure and function of
      the Norwegian  labeling foundation is explained.  The  first
      products carrying the label should be on the market in late
      1990.

43.   Packaging.  "Americans Will Pay Extra For  'Green' Products."
      October 1989.  Michael Peters  Group survey shows that the
      majority of American and Canadian consumers would pay extra
      for products in degradable or  recyclable packaging and would
      support government legislation requiring manufacturers to
      use such "green"  packaging.

44.   Packaging.  "City of Berkeley  Calls for Precycling."  October
      1989.  The  city of Berkeley, CA, is trying to encourage
      consumers to make environmentally wise purchasing decisions.
      Along with  technically valid suggestions, endorses
      biodegradability  and criticizes plastics for not being
      degradable.

45.   Packaging.  "Special Report:   Packaging Under Attack."
      August 1989.  Various articles address the environmental
      impacts of packaging, including misconceptions about various
      materials,  legislation aimed at banning or restricting
      packaging, consumer attitudes,  environmentally sound
      disposal methods,  and package design to address
      environmental concerns.

46.   Powell, Jerry.   "The Eco-Labelers Are Coming."  Beverage
     World.   November  1989.   Reviews West German and Canadian
      eco-labeling programs and growing momentum for similar
     program in U.S.  Speculates on labeling results for beverage
      containers:  Glass and aluminum would receive label because
      of high recyclability and recycled content, possible
      labeling of PET bottles (highly recyclable but no recycled
     content),  and rejection of aseptic packaging.

47.  Private Label.   "Green Products Taking Root."
     November/December 1989.   America following Europe in trend
     toward making both products and packaging environmentally
                               63

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48.
49,
50
51
52
sound.  Popular products marketed as "environmentally
friendly" include degradable plastic bags and diapers,
refillable concentrated pouches, and dioxin-free paper
products.  Manufacturers and supermarkets alike are getting
involved.

Salimando, Joe.  "Green Labels Can Be Problems, Swedes
Learned."  Recycling Times. January 16, 1990.  Reviews
Mikael Backman's presentation at the Fifth International
Conference on Solid Waste Management and Secondary
Materials, warning against confusion fro.ii uncontrolled
market use of "environmentally friendly" terms.  Examples
include recycling symbols on products for which recycling
capacity does not exist in Sweden, advertising focusing on
compliance with all environmental regulations  (if not
meeting requirements, would be illegal), and "No CFCs" label
on products where CFC use has been banned in Sweden since
1975.

Seventh Generation Catalog.  Earth Day 1990 Edition: Seventh
Generation, Colchester, VT  05446.  Offers environmentally
friendly products for sale, along with brief explanations of
their environmental benefits.

Sharkey, Betsy.  "A New Leaf."  Continental Profiles.  March
1990.  Dennis Farrier, former executive director of the
Smithsonian Mariculture Institute, is now an environmental
marketing consultant, helping corporations find a balance
between environmental responsibility and economic realities.
Smart companies are beginning aggressive moves into the
environmental arena.

Smith, Randolph B.  "Environmentalists, State  Officers See
Red As Firms Rush to Market  'Green1 Products."  Wall Street
Journal.  March 13, 1990.  Concerns are mounting about
misleading environmental claims associated with such  items
as degradable plastic bags and diapers and "ozone friendly"
hairspray and deodorant.

Smith, Randolph B.  "Rush to Endorse  'Environmental1 Goods
Sparks Worry About Shopper Confusion."  Wall Street Journal.
April 16, 1990.  Environmentalists, government officials,
and manufacturers are voicing concern about environmental
labeling.  Specific areas of concern include consumer
confusion, claims of unfair or misleading labels,
inconsistency in seals or labels  awarded by different
groups,  and how to set definitions and requirements  for
terms such as "recycled."  Article reviews current status of
various  environmental, manufacturer, and retailer programs
and proposed legislation, including Green Seal, Inc., Green
                                64

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      Cross labeling (recently supported by four Western
      supermarket chains),  and CONEG action.

 53•   Solid Waste Report.   "Green Marketing Challenged  by
      Attorneys  General."   March 19,  1990,  p.  94.   Eight states'
      attorneys  general  are conducting hearings  in  St.  Paul
      concerning standards  for environmental marketing,  based  on
      concern  about  advertisers' growing claims  about
      "environmental friendliness" of their products.   Hearings
      will  focus on  how  to  label products claiming  environmentally
      protective qualities.

 54.   Swedish  Ministry of Public Administration.  Environmental
      Labelling  in Sweden.   November  29,  1989.   Discusses plans
      for a coordinated  Nordic environmental labeling system.

 55.   U.S.  Environmental Protection Agency.  Promoting  Source
      Reduction  and  Recvclabilitv in  the Marketplace.   September
      1989.  Sections of the report relevant to  clean  products
      include  information on consumer education  and  influencing
      the relationship between consumers and marketers.  Education
      should be  aimed at increasing awareness of municipal solid
      waste crisis and environmental  consequences of purchasing
      decisions.   Reviews some environmental shopping campaigns
      and Canadian Environmental Choice  program.  Problems include
      lack  of  standard definitions and labeling  for recycled
      content  or recyclability.  Does not contain much technical
      information  on clean products, rather focuses on
      opportunities  for  promoting environmentally acceptable
      products through consumer education and motivation, and
      resulting purchasing decisions.  Lists suggested activities
      for consumers, industry, and government.

56.  Venture Stores.  "Color  It Green" brochure.  Kansas city
     Star.  April 15, 1990.   States Venture stores' environmental
      commitment,  including stocking "products which may be safer
      for the environment," increasing internal use of recycled
     paper and paper products, and using shopping bags made with
     recycled plastic.   Advertises "environmentally friendly"
     products such a phosphate-free detergent in recycled
     containers, paper plates and cups  ("recyclable dinnerware"
     that will "degrade easily"),  non-fluorocarbon "ozone-
     friendly" hairspray,  and aluminum foil in recycled packaging
     with water-based inks.

57.  Wall Street Journal.   "Aerosol Alternatives Rush Into the
     Market."  May 7, 1990.  Although CFCs  have been banned as an
     aerosol propellant, current hydrocarbon propellants still
     contribute to smog, leading manufacturers to search for new
     ways to dispense aerosols.  Methods under development

                               65

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     include use of mechanical methods or liquefied
     hydrofluorocarbons, which don't hurt the ozone layer or
     cause smog.

58.  Watkins, Angela.  "Gaining an Environmental Edge."  Beverage
     Industry.  February 1990.  Spokesmen for Pepsi-Cola and
     Coca-Cola say they do not plan to extend their "green"
     marketing past current reminders to customers to recycle
     their beverage containers.  Both companies also encourage
     in-house recycling, reduced packaging, and recycled
     packaging materials.

59.  Watson, Tom.  "Product Labeling Efforts Are On The March
     Worldwide."  Resource Recycling.  October 1989.  Discusses
     status of national environmental labeling programs in West
     Germany and Canada, and considerations for program xn U.S.
     Issues raised include need for standardization of terms such
     as "recyclable" and "degradable," participation of a
     credible and respected third party such as Underwriters
     Laboratory to handle testing and certification, and
     likelihood of confrontational debate about criteria.

60.  West German Federal Environmental Agency.  Information Sheet
     on the Environmental Label. August 1989.

61.  Zwiebach, Elliott.  "Big Bear's New Environmental Style."
     supermarket News.  September 4, 1989.  Outlines Big Bear-
     supermarkets' actions to portray the whole store as being
     environmentally sensitive.  Actions include paper bags to
     replace plastic, elimination of foam deli trays, use of
     shelf talkers to promote environmentally safe products, and
     encouraging customers to recycle plastic and glass
     containers.
ENVIRONMENTAL  IMPACT  INFORMATION
 62,
 63
Backman, Mikael, et al.  Preventative Environmental
Protection Strategyi  First Results of an Experiment in
Landskrona. Sweden.  TEM/University of Lund.  Outlines case
studies of several manufacturing companies assisted by TEM
in redesigning their manufacturing processes to reduce
negative environmental impacts.

Bal, Raj.  "Degradable Bags Help The Environment."  USA
Today.  March 16, 1990.  Author's firm, Webster Industries,
manufactures degradable bags with 50 to 100 percent recycled
plastic.  A harmless additive allows bags to degrade in
landfills even with no moisture or light.  After
degradation, only carbon dioxide, water, and harmless soil-

                           66

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      like  residue  remain.   Degradable bags  are not  the  single
      solution but  combined  with source reduction and  recycling
      can make a pro-environment contribution.

 64.   Boustead, I.  The Environmental Impact of Liquid Food
      Containers in the U.K.  The Open University, East  Grinstead,
      U.K.  October 1989.  Assesses environmental impacts of  10
      types of containers for 14 types of liquid foods.  Provides
      general discussion of  raw materials (renewable,  non-
      renewable, mineral), waste (materials, heat),  and  post-
      consumer waste.  Lists factors and assumptions used in
      calculations.  Tabulated results include total system energy
      by container  and by liquid, raw material requirements for 26
      raw materials by container and by liquid, mass and volume
      contribution  to refuse by liquid, relationship between
      package size, energy/container and energy/liter, and energy
      savings per kg of container material recovered.

 65.   Council on Plastics and Packaging in the Environment
      (COPPE).  Questions & Answers on Plastics Packaging and the
      Environment.  July 1988.  (COPPE, 1275 K Street NW, Suite
      300,  Washington, DC  20005) General information on plastics
      in the waste  stream, opportunities for recycling and waste-
      to-energy incineration; also, benefits and drawbacks of
      degradabi1ity.

 66.   Denison, Dr.  Richard A.  "Right Question, Wrong Answer."
      U.S.  EPA Pollution Prevention News.   February  1990.
      Biodegradable plastics are not environmentally preferable
      because sanitary landfills do not promote biodegradation,
      degradable plastics provide a threat to plastics recycling,
     may release toxic substances into the environment when they
      degrade, and may encourage littering.

 67.   Federal Office of the Environment,  West Germany.   Comparison
      of the Effects on the Environment from Polyethylene and
      Paper Carrier Baas.   1986.   Study investigated the input of
      raw materials and energy,  damage to environment during
     manufacture and waste management,  possibilities of recycling
     and influences on environment from recycling.   Assumptions
     and sources of data listed.   Concludes that use of plastics
      is ecologically justifiable,  and with respect to
     environmental parameters is more advantageous than
     alternative products.   Any significant relief to the
     environment,  however,  is only achieved by repeatedly use of
     a reusable carrier bag, regardless  of its material.

68.  Final Report of the fCONEGI  Source Reduction Task Force.
     Coalition of Northeastern Governors.   September 8,  1989.
     Contains preferred packaging guidelines aimed at  reducing

                               67

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69,
70.
71,
72,
disposal impacts of packaging waste by changing to more
environmentally benign materials, reducing volume and weight
of disposal packaging, increasing recyclability and recycled
content of packaging, all without impairing the necessary
functions of packaging.  Packaging guidelines in order of
preference are 1) no packaging 2) minimal packaging
3) consumable, returnable, or refillable/reusable packaging,
and 4) recyclable packaging/recycled material in packaging.
In addition, the Source Reduction Task Force recommends that
the CONEG governors direct the Northeastern Source Reduction
Council to draft state legislation to reduce to the maximum
extent possible toxics such as lead, cadmium, and mercury in
packaging.

Flexible Packaging Association.  Flexible Packaging...Less
Does More.  Discusses benefits of flexible packaging
including energy consumption, volume, weight, and cost in
comparison to similar packaging using alternative materials.

Goldstein, Nora.  "The Packaging Challenge."  In Business.
January/February 1990.  Suggestions for environmentally
sound packaging.  Discusses current legislative efforts and
criteria aimed primarily at plastics packaging.  Recommends
using fewer layers of packaging, selling refills, and
encouraging customers to bring their own containers for
filling.

Hamilton, Martha M.  "Advertisers' Environment Claims Hit."
The Washington Post.  March 15,  1990.  Biodegradability of
plastics is under attack by environmentalists and government
regulators.  A Greenpeace study  indicates that biodegradable
plastics merely break down into  smaller pieces, with no
evidence so far that it degrades as do plant and animal
products.  The vice president of Archer Daniels Midland
Company, a manufacturer of cornstarch additives for
degradable plastics, says that the company's product tests
have not been underway long enough to demonstrate the final
results of the decomposition process, but that their studies
show the products break down in  a way that will result in  a
complete biodegradable decomposition.  A senior scientist
for the Audubon Society considers current biodegradable
plastics a hoax, but thinks the  concept is valid.  Audubon
Magazine switched from paper wrappers to polyethylene
because it is less polluting on  a life cycle basis than
paper.

Industry Committee for Packaging and the Environment.
Packaging Saves Waste.  London,  1987.  Analysis of
composition and  quantity  of household wastes, benefits of
packaging and recycling.  Predicts  future trends toward more
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      lightweight  and  combination material packaging  as well  as
      more  recycling of  single polymer plastics  and waste-to-
      energy  conversion  of  combination packaging.

73.   Levy, Michael  H.   U.S. EPA Briefing - Source
      Reduction/Plastics Packaging.  January  15, 1988. Prepared
      for Office of  Solid Waste and Emergency Response.  Lists
      plastics packaging contributions to source reduction,
      advantages of  plastics packaging.  Discusses more plastics
      being recycled and converted to energy, and the unknown
      effect  of elimination of convenience packaging.

74.   McDonald's Environmental Affairs.  McDonald's and the
      Environment.   Pamphlet published by McDonald's  Corporation,
      McDonald's Plaza,  Oak Brook, IL 60521.  1990.   Outlines
      environmental  considerations taken into account by
      McDonald's regarding  polystyrene foam packaging (effect on
      ozone,  percent of  solid waste stream, efforts to recycle),
      other reductions in packaging, company  policy refusing  to
      purchase beef  from deforested rain forest  land, and
      contributions  to public environmental education.

75.   Packaging Aae.  "Solid Waste - The Packaging Challenge  of
      the Eighties."   August-September 1988, pp. 6-11.  Gives
      overview of packaging contribution to solid waste problem
      and discusses  government and industry attitudes and programs
      under consideration to address the problem.  Preferred
      course  of action:  Recycling, Reuse, Reduction.

76.   Polystyrene Packaging Council, Inc. (1025 Connecticut Ave.
      NW, Suite 513, Washington,  DC,  20036)   Polystyrene Foam
      Food Service Products:  Environmental Impact and Waste
      Disposal Implications.  Lists benefits of foam products:
      cost, sanitation, performance qualities, and energy savings.
      Concerns about usefulness of degradable products.   Discusses
      alternatives to landfill disposal:   recycling into non-food
      service products, waste-to-energy incineration.  Banning is
      not solution to solid waste dilemma.

77.   Procter & Gamble.  (1 Procter & Gamble Plaza,  Cincinnati,
     Ohio, 45202)  Solid Waste Solutions;  Procter & Gamble's
      Commitment.   Discusses each of the following approaches to
      solid waste problem:  Source reduction,  recycling,  reusing,
     composting,  incineration,  landfill.

78.  Rapaport,  David.   "Degradable Plastic Bags Are A Scam."  USA
     Today.  March 16, 1990.   "Degradable"  plastics are not
     actually biodegradable,  according to a study conducted for
     Greenpeace by the Center for Biology of Natural Systems at
     Queens College.  Under ideal conditions they break into

                               69

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79,
80.
81.
82.
83.
small plastic fragments that may release new toxic
pollutants into the environment.  It is better for consumers
to avoid unnecessary disposable products in favor of
products such as reusable cloth bags and diapers.

Statler, Jean C.  "Is Degradability a Solid Waste Solution?"
U.S. EPA Pollution Prevention News.  February 1990.
Biodegradability of plastics is not a solid waste solution.
Increased recycling of plastics, along with source reduction
and waste-to-energy incineration are more valuable, workable
solutions.

Time Magazine. Special Advertising Section sponsored by the
Council for Solid Waste Solutions.  "The Urgent Need to
Recycle."  July 17, 1989.  Recycling requires collection,
sorting, reclamation, end-use.  More and more uses being
developed for recycled plastics.  Brief discussion on
degradable plastics.

U.S. Congress, Office of Technology Assessment.  Facing
America's Trash;  What Next for Municipal Solid Waste.  U.S.
Government Printing Office.  October 1989.  While this
report contains little reference to "clean" products and
labeling, it provides a wealth of information on waste
composition and various waste prevention and disposal
scenarios often used to assess products' or materials'
"environmental friendliness."

U.S. Environmental Protection Agency: Hazardous Waste
Engineering Research Laboratory.  Waste Minimization
Opportunity Assessment Manual.  July 1988.  Does not
directly address clean products, but contains information  on
tracking wastes, prioritizing waste streams, etc. and
worksheets including evaluation by weighted sum matrix that
could be adapted for use in evaluation of clean products.

Warmer Bulletin.   "Degradability:  A False Prophet."  Spring
1990.  Discusses disadvantages of degradable plastic,
including potential to contaminate plastic recycling,
epitomizing and perhaps encouraging throw-away mentality
 (since they are not recoverable or reusable), wasting
nonrenewable petroleum resources, possibility of releasing
heavy metal contents or environmentally harmful organic
compounds as they  break down, and hygiene risks associated
with packaging which degrades.  Proclaims recycling and
energy recovery are better solutions than degradability.
                                70

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STATE, GOVERNMENT LEGISLATIVE ACTIVITY

84.  ASTM Standardization News.   "Packaging Recycling and
     Disposability Subcommittee Forms."  February  1990.
     Subcommittee D10.19 on Packaging Recycling and Disposability
     will develop standards to assist governments  in managing
     solid waste issues.  The subcommittee will standardize terms
     such as recycled material, degradability, etc. and  form task
     groups on methodology for determining degradability and
     methodology for determining  toxic content in  packaging
     material.  The group will work with CONEG Source Reduction
     Council to draft legislation for reduction of toxic content
     in packaging.

85.  Batdorf, Tracey L.  "Maine ban could force changes  in
     aseptics."  Beverage Industry.  April 1990, p. 40.  Maine's
     ban of aseptic packaging, effective September 1, 1990, is
     stimulating manufacturers to make aseptics more
     environmentally friendly.  International Paper is looking at
     replacing the aluminum in its containers so they are more
     recyclable, or composting them.  Tetra Pak claims to be very
     close to being able to recycle aseptics and is involved with
     a pilot plant that manufactures particle board from 100
     percent aseptics.

86.  California Legislature.  Assembly Bill Number 3994.
     Introduced by Assembly Member Sher.  March 2, 1990.  Bill
     would declare legislative intent to establish California
     Environmental Choice Labeling Program to identify products,
     processes, services, and packaging provided by businesses
     which comply with specific environmental protection
     principles.

87.  California Legislature.  Assembly Bill Number 3030.
     Introduced by Assembly Member Hansen.   February 20, 1990.
     Bill would require California Integrated Waste Management
     Board to license use of environmentally safe product labels.
     Board would establish labeling program and Source Reduction
     Advisory Committee would advise board on the design,
     application for licensing (fee involved),  and standards for
     product to meet in the program.

88.  Franklin Associates, Ltd.   Recent Restrictive Legislation on
     Plastics Packaging and the Solid Waste Consequences.  Draft
     report,  September 1989.   Summarizes recent state and
     congressional legislative activity.  Motivation for
     legislation and perceived advantages for general categories
     and specific products are discussed.   Also examines
     environmental consequences of restrictive legislation.

                               71

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89.
90,
91.
92,
93,
Various packages affected by restrictive legislation are
examined, along with possible substitute packages, for their
environmental impact in scenarios such as incineration,
recycling, and degradability.  This report is notable as it
presents rarely encountered direct comparisons of the
environmental impacts of substitutes, which are rarely
specified in any detail in restrictive legislation.

General Assembly of Pennsylvania.  Senate Bill Number 1219.
Introduced by Fisher et al.  September 25, 1989.  Act would
provide for labeling of recyclable products and plastic
containers, mandate the use of environmentally acceptable
packaging in retail food establishments, and encourage
cooperation among the states to set uniform policies to
reduce unnecessary packaging.

Minneapolis City Council.  An Ordinance of the City of
Minneapolis ra new chapter 2041.  March 27, 1989.  Ordinance
seeks to minimize nondegradable, nonreturnable, and
nonrecyclable food and beverage packaging at retail food
establishments.

Oregon State Senate.  SB 990A - The Solid Waste Reduction
Act of 1989.  April 30, 1989.  Prohibits use of polystyrene
foam packaging unless on-premises collection program for
recycling exists, requires labeling of plastics to
facilitate recycling, prohibits stores from using plastic
bags unless paper bags also offered.

Parker, Bruce J.  "Suffolk Ban Null and Void, But the  Debate
Goes  On."  Recycling Times.  April 10, 1990, p. 2.  Supreme
Court of New York has overturned Suffolk county's ban  on
non-biodegradable plastic packaging.  The local legislature,
which had intended the ban to encourage the use of
recyclable paper products and thus slow the filling of
landfill space, did not prepare an environmental  impact
statement to prove that the effect of the ban on the
environment would actually be beneficial.  Meanwhile,  in
Oregon, Portland's ban of polystyrene foam in food service
industries has been upheld by a state circuit court.

Sternberg, Ken.  "Canada Gets Friendly, Environmentally."
Chemicalweek.  April  11, 1990, p. 12.  Environmental
minister Lucien Bouchard, aiming to make  Canada  "the
industrial world's most environmentally friendly  country"  by
the year 2000, has put together a "Green  Plan" of proposed
policies,  including taxes on waste effluents and  hazardous
chemicals, emissions  trading program, and requiring industry
adoption of specific  goals and operating  procedures.
                                72

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94.  Suffolk County, New York.  Intro.  Resolution No.  1869-87 - A
     Local Law to Simplify Solid Waste Management by Requiring
     Certain Uniform Packaging Practices within the County of
     Suffolk.  Introduced by Legislators Englebright et al.
     August 25f 1987.  Seeks to eliminate use of nonbiodegradable
     packaging at retail establishments.
                               73

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                            Appendix B

                        PERSONAL CONTACTS
Assarsson, Bo.  Head of SIS  (Swedish Standards Institution)
Environmental Labelling Program.  Personal correspondence.

Burger, Alyssa.  E Magazine.  Personal communication.

Dahlen, Tom.   Executive Vice President, Big Bear Markets, San
Diego.  Personal communication and correspondence.

Donahugh, Don.  Minnesota Attorney General's Office.  Personal
communication.

Egli, Norbert.  Swiss Association for Waste Reduction.  Personal
correspondence.

Jensen, Birger.  Swedish Ministry of Public Administration.
Personal correspondence.

Labovitz, David.  Member of Board, ASHDUN Industries.  Personal
communication.

Lindhqvist, Thomas.  TEM/University of Lund, Sweden.  Personal
correspondence.

Harder, Howard.  Senior Vice President, Hill & Knowlton, Inc.
Personal communication and correspondence.

Mason, Peter.  ICI Plastics, Melbourne, Australia.  Personal
correspondence.

Muller, Dr. Edda.  Federal Ministry for Environment, Nature
Conservation, and Nuclear Safety, West Germany.  Personal
correspondence.

Oberle, Alexandra Halkett.  Marketing Officer, Environmental
Choice, Canada.  Personal communication and correspondence.

Omernik, Beth.  New York Public Interest Research Group.
Personal communication.

Peikoff, Christina.  Assistant to Professor Gerhard Vogel,
University of Vienna.  Personal correspondence.
                                74

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Seroonsen, Chris.   Dynax Urban Environmental Research Institute,
Japan.  Personal  correspondence.

Stavely, Janice.   Program Director, Pennsylvania Resources
Council, Inc.   Personal communication and  correspondence.

Stokke, Jan Erik.   Norwegian Foundation  for Environmental Product
Labels.  Personal  correspondence.
                                 75
                                          U.S. GOVERNMENT PRINTING OFFICE: 1991—548-187/20525

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