Government Geared for Greening

In 1998, President Clinton signed Executive Order 13101, "Greening the Government Through Waste Prevention, Recycling and Federal Acquisition," which requires Federal agencies to consider a range of environmental factors in purchasing decisions.

In late 1999, the U.S. Environmental Protection Agency (EPA) published its final guidance document on implementing what is known as the Environmental Preferable Purchasing (EPP) program.

In 2000, Federal agencies continued to work to comply with this Order - and previous, related actions - while organizations such as The Society of the Plastics Industry, Inc. (SPI) continued to monitor their efforts, meet with officials and keep their members apprised of ongoing events.

Looking back

Executive Order 13101 builds upon and replaces a 1993 Order that first acknowledged the EPP concept in government procurement. That Order - "Federal Acquisition, Recycling and Waste Prevention" - followed the passage of legislation that allowed Federal government agencies to begin incorporating environmental considerations into their purchasing practices.

All these actions were based on the concept that the procurement decisions of the Federal government - a major purchaser of services and products - could have significant environmental consequences.

Among initial activities generated under this new approach were meetings with stakeholders, including SPI, and the launching of several pilot programs.

The EPP today

As directed by Executive Order 13101, EPA's final guidance on the EPP program provides a framework within which Executive agencies are to implement environmental purchasing. It does this by outlining a set of five key principles that are intended to drive Federal agency procurement planning. These principles are:

Environment + Price + Performance = EPP. Environmental considerations should be integrated into each agency's normal purchasing practices.

Focus on pollution prevention. Early in the acquisition process, pollution prevention should become the primary motivation and strategy for Environmentally Preferable Purchasing.

Consideration of life cycle perspective/multiple attributes. Environmental preferability is a function of multiple attributes, such as a product's toxicity, energy efficiency or impact on ecosystems. These attributes should be considered through the entire life cycle of the product. (There is a caveat here, however. Though the determination of environmental preferability is to be based on multiple environmental attributes, purchasing decisions by any Federal agency may be based on a single attribute "when that attribute distinguishes the product or service in a category.")

Comparison of environmental impacts of products. The nature and degree of potential environmental impacts should be compared, with the overarching goal of protecting human health. An "environmentally preferable product" is defined as one that has a lesser or reduced effect on the environment when compared with competing products or services that serve the same purpose.

Environmental performance information. Comprehensive, meaningful and accurate information about the environmental performance of products is needed in order for agencies to assess environmental "preferability" of products.

While agencies have considerable discretion in applying these guidelines, it is expected that Federal agency procurement plans will reflect these key principles.

One of the more active agencies to date has been the Department of the Interior, which considers itself a leader in the environmental purchasing arena.

The Department has particularly taken to heart the Order's directives to give preference to recycled-content products and those with bio-based content. Among its related projects, it has worked with the National Park Service to install plastic lumber made from recycled plastic materials, entered into a contract to buy "green" cleaning solutions and instituted renewable energy systems. It also launched a pilot project to test compostable plates and bowls in its headquarters cafeteria, in order to evaluate their environmental attributes in comparison to polystyrene foodservice materials.

The Ongoing Challenge

The EPP program could have significant implications for the plastics industry and its affiliates. This is not because the industry fears its materials cannot compete on this new playing field; it's because it knows the stereotypes that exist. There are numerous pre-conceived and ill-conceived notions that may need to be addressed in areas such as energy consumption, recyclability, solid waste management and the environmental impacts of plastic manufacturing processes.

Complicating industry's participation and response is the size of the U.S. government and the complexities inherent in the maze of procurement processes.

It also is important to note that the concept is trickling down, as the National Association of Counties has used an EPA grant to create an "Environmental Purchasing Starter Kit: A Guide to Greening Government Through Powerful Purchasing Decisions." The kit is designed to aid local governments and organizations in developing their own EPP practices.

Looking ahead

At this point, it is unknown how radically Executive Order 13101 and related efforts will change the way the government buys and, thus, the impacts - both beneficial and detrimental - it could have on various industries. Also unknown are the cascading effects these changes could have, as companies that sell directly to government agencies promote EPP concepts with their suppliers, and as consumers possibly follow suit. Yet another question mark is the role that third-party certification will play and the nature of those third-party certifiers of environmental claims.

Speculation also surrounds a related Executive Order - "Greening the Government Through Environmental Leadership" - which requires the Federal government to implement an environmental management system (EMS). Will there be a nexus here? Will a commitment to purchase environmentally preferable products be specified in agencies' environmental policies? Will agencies consider EPP requirements in the setting of their environmental objectives and targets? Will agencies, in turn, expect their suppliers to have effective environmental management systems? These are just some of the facets of this ongoing dilemma for affected manufacturers and industries and, ultimately, their own vendors and suppliers. And they are just some of the reasons it is important for affected industries and their advocates to be aware of EPP activity and prepared to answer all pertinent questions about their products and processes.

To maintain their market share, manufacturers may have to emphasize their products' positive environmental attributes more strongly than ever before.

Incorrect or incomplete information could lead to bad choices and/or unwarranted product de-selection by major purchasers, which could have both an immediate economic impact as customers are lost, and a long-lasting one as products are tainted by their rejection.

More importantly to the goals of EPP, ill-advised choices and unwarranted de-selection could work against the program's objectives, providing a market for products that, over their life cycle, actually are less environmentally beneficial than their alternatives.

The question may remain as to the degree of "greening" the government will pursue, the factors upon which it will make its procurement decisions and what those decisions will mean to the plastics industry. However, there is no question that this is an issue that must be watched. That's why SPI is following the process and working with its members to keep the industry informed.