European Draft Environmental Handbook

The European Commission has invited Consultation on the International Reference Life Cycle Data System (ILCD) Handbook by 31 August 2009. Unfortunately the invitation to comment is written in almost unintelligible bureaucratic language. It was difficult to work out from the invitation what it was comments were being invited about. The documents themselves are much better written than the request for comment and are poorly served by it.

Five PDF files are provided, which appear to be the manual, although the word "manual" is not used:

1. General guidance document for Life Cycle Assessment (LCA)
2. Specific guidance document for generic or average Life Cycle Inventory (LCI) data sets
3. Analysis of existing Environmental Impact Assessment methodologies for use in Life Cycle Assessment (LCA) - Background Document
4. Framework and requirements for Life Cycle Impact Assessment (LCIA) models and indicators
5. Review schemes for Life Cycle Assessment (LCA) and annex on Reviewer qualification

Below is the executive summary of the general guidance document. While well written, it suffers from having been poorly formatted as large PDF files. The distribution of documents in this format is contrary to sound environmental practice. It should be replaced with an efficiently formatted web document which meets accessibility standards.

I have suggested the documents be reformatted to achieve 80/100 with the W3C mobileOK Checker and pass Priority 1 and 2 tests on a automated accessibility test. This will make it easier for people, and web search engines, to read the document and also reduce its carbon footprint by 90%.

Executive summary

Life Cycle Thinking (LCT) and Life Cycle Assessment (LCA) are moving into the core of modern environmental policies and business decision support.

Life Cycle Assessment is a structured, internationally standardised method and management tool for quantifying the emissions, resources consumed, and environmental and health impacts that are associated with goods and services (“products”). LCAs take into account the product’s full life cycle: from the extraction of resources, production, use and recycling, up to the disposal of remaining waste. LCAs help thereby to avoid resolving one environmental problem while creating another: They avoid the so-called “shifting of burdens”, e.g. from one part of the life cycle to another, amongst different types of impacts on the natural environment and on human health, and amongst countries.

This guidance document is a component of the International Reference Life Cycle Data System (ILCD). It provides a detailed technical guidance to the ISO 14040 and 14044 standards on LCA, differentiated by four main decision contexts. The overall objective is to provide a common basis for consistent and quality-assured life cycle data and robust studies. These are required in support of coherent and reliable policies and robust decision support in the public and private sectors and related to products, resources and waste management.

Background / The International Reference Life Cycle Data System (ILCD)

The International Reference Life Cycle Data System (ILCD) has been established to support the use of consistent and quality-assured life cycle data and methods in the public and private sectors.

The ILCD consists primarily of the ILCD Handbook and the ILCD Data Network: The Handbook is a series of technical guidance documents in line with the ISO 14040 series and developed through peer review and public consultation. The Data Network is a web-based, decentralised network of consistent and quality-assured life cycle inventory (LCI) data sets. This is ensured through compliance with the requirements of the ILCD Handbook. It is open for all data providers to join under their own terms and conditions.
Purpose and Addressees of this Guidance Document
Today, no commonly accepted guidance exists that complements the general framework given in the ISO 14040 series for ensuring consistent and reproducible life cycle data and robust assessments. However, for use in policy context and for reliable decision support in the public and private sectors, such foundations are indispensable.

This document provides guidance for the planning, performance, review, and documentation of life cycle emission and resource consumption inventory (LCI) data sets and life cycle assessments, as defined in the ISO 14040 and 14044 standards. Such data sets and assessments are the basis for all types of applications, such as e.g. ecolabels, carbon footprint declarations, eco-design studies.
The main target audience for this technical guidance document is the LCA practitioner. This document also serves as an introduction to the main technical principles and requirements of Life Cycle Assessment, providing many illustrative in-line examples and graphics. It is however not meant to be a comprehensive and detailed introduction or training material for beginners.


Approach and principles followed

The relevant ISO 14040 and 14044 standards, existing LCA handbooks, and the general LCA literature have been analysed to compile a set of “needs for guidance” and to obtain input in form of approaches and arguments.

Reflecting the global nature of product life cycles and the necessity of having globally agreed methods and data, the ILCD is developed through consultation with UNEP and with non-European national authorities developing LCA databases. This is currently facilitated by the European Commission, including interactions with representatives of its 27 Member States. The consultation on first drafts equally included the about 40 members of the advisory groups of business associations, LCA software and database developers, as well as life cycle impact assessment method developers. The development and consultation procedures can be found at http://lct.jrc.ec.europa.eu/eplca/deliverables/international-reference-life-cycle-data-system-ilcd-handbook .

Building on this state-of-the-art analysis and ISO 14044 as main basis, this guidance document has been developed towards a practical guidance. The stakeholder process (up to the achieved status) is documented in Explanatory Memoranda for each ILCD System component; access via http://lct.jrc.ec.europa.eu/eplca/deliverables/international-reference-life-cycle-data-system-ilcd-handbook .

The uptake or endorsement of this document and the other ILCD System components by governments and businesses as well as other stakeholders is independent of this technical development.

Key Issues Addressed in this Guidance Document

This document provides a complete technical guidance, based on the ISO 14040 and 14044 standards. It is further detailing and specifying the ISO provisions along four main decision-context situations that were identified as being of relevance in LCA and in need of differentiated guidance:

• Situation I ("Short-term product decision support"): Decision support for near future: LCI data for EPDs and Type I Ecolabel, weak-point analysis for eco-design, background LCI data for generic use, etc.
• Situation II ("Future product decision support"): Decision support for more remote future, scenario based: System changes with none or small scale effects on the background system
• Situation III ("Future strategy decision support"): Decision support for more remote future, scenario based: System changes with effects in the background system at society or sector level
• Situation IV ("Monitoring"): Monitoring (typically of past or present situation): Documentation of what has happened, not for direct decision support or comparisons

Focus is on issues that give rise to differences in current practice of developing life cycle data sets and in assessments. Among these the two main issues are around the questions:
- How to model the life cycle of a product (i.e. depicting the supply-chain or analysing expected consequences associated with changes), and closely related
- How to share the environmental impacts of a process among co-products if it has more than one (e.g. by allocation of impacts based on allocation criteria or by crediting for avoided production of replaced alternative products).

A detailed discussion of the advantages and disadvantages of the related methods and approaches and their applicability in practice provides the basis for this guidance, including which option to use when.

In addition, the following issues that need guidance are worked out in more detail as well:
- the question which kinds of activities are to be included in LCA, how to relate them to the analysed product, and how to quantify the completeness of the data,
- how to avoid misleading LCA studies,
- how to meet the requirements of transparency and reproducibility in context of potentially sensitive or proprietary process data and information,
- when to use primary data from goods producers and service operators and when secondary data can be used, and
- how to capture and evaluate the quality of life cycle data and assessment results.

The sub-structure of this document reflects the practical work-flow of performing an LCA. “Actions” at the end of chapters condense the guidance to a check-list style practice guidance. References to the corresponding chapter in the ISO 14044 standard are given in each chapter.

Open issues

The condensation of this main guidance into specific guidance documents for different types of LCI and LCA studies is ongoing and will be completed after the consultations.

The summary of the outcome of the parallel work on review is to be integrated into the “Review” chapter of this document.
A “translation” of this guidance into sector-specific manuals could be beneficial. ...

From: General guidance document for Life Cycle Assessment (LCA), International Reference Life Cycle Data System (ILCD) Handbook, Draft for Public Consultation, 1 June 2009