2. 3. 4. Avoiding excessive costs in standards implementation and making them flexible for smaller firms and organizations in developing areas of the world. Harmonizing international and national or regional Scientific understanding and methods are lacking in certain areas such as life cycle assessments and accounting for all health and ecological impacts from organizational activities. The USTAG has established a set of goals to guide its activities so as to maximize the benefits and satisfactorily deal with these concerns and challenges. These are listed below and described in greater detail in Attachment F: Establish voluntary international standards that effectively harmonize national and regional standards Minimize trade barriers that do not protect valid or significant environmental resources or goals Standards should be adaptable for either or both internal company or external third party verification Standards must be cost effective, performance based, and flexible Standards must leave the setting of performance levels, goals, objectives, rates of improvement, etc. to Individual organizations. The above goals reflect many of the concepts incorporated in principles of the "Rio Declaration on Environment and Development" from the 1992 UNCED Conference. (See Attachment G.) Comments on Proposed Legislation Thank you for the opportunity to comment on the draft legislation that was sent with the invitation to provide this testimony. Some of the provisions in the draft legislation have merit and should be further developed. However, a number of other provisions may be costly and perhaps counterproductive. The introduction of environmentally-sustainable products, processes and services is driven through the complex interplay of market forces and technological breakthroughs. Players in this arena have learned from experience that premature conclusions on product or process design features often results in unexpected impacts in other areas that had not been the subject of a full analysis. Accounting for the full array of environmental releases, energy consumption, and resources expended is a complex undertaking even for a simple product. The debates between polystyrene and paper products, and cloth versus disposable diapers have yet to be resolved. How much more difficult, then, will it be to compare one automobile against another or multiple television sets from different manufacturers from different continents? Government can encourage and create incentives to promote environmentally-sustainable technology but, it cannot lead or even coordinate such progress. Briefly, the following sections in the draft legislation should be further pursued: 2. 1. Section 503: "Performance Standards Programs." The federal labs should be encouraged to refocus their talents and energies on environmental technologies. Section 504: "Consumer Claims on Green Technologies." It would be useful to have explicit, scientifically based criteria to evaluate commercial performance claims. The market, as well as the product manufacturers, would benefit from more certainty. The LCA standards under development in ISO/TC-207 would assist greatly in accomplishing this goal. 3. 4. 5. Section 701: "Government as First Market." Providing that the criteria for evaluating "green" products is fair and scientifically based, there is no reason the government should not use its purchasing power to encourage further progress in this area. Section 702: "Technology and Regulation." Counterproductive regulations that stifle innovation in Section 703: "Alternative Environmental Technology provisions for regulatory relief and adjustments could, If the subcommittee so wishes, I can provide specific comments on these and other sections of this proposed legislation. In closing, I again wish to thank the Chairman for giving me this opportunity to testify here today. |