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Driving Product Sustainability Through Environmental Material Requirements

USGBC (U.S. Green Building Council)'s picture

The U.S. Green Building Council is committed to transforming the way our buildings are designed, constructed and operated through LEED — the top third-party verification system for sustainable...

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Platinum sponsor Legrand North America now requires a set of Environmental Material Requirements for its suppliers.

Platinum member Legrand North America now requires a set of Environmental Material Requirements for its suppliers and shares lessons learned on facilitating its implementation.

Homeowners, home builders, architects, designers and facility managers continue to demand an increasing number of power, light and data technologies that adhere to expanding U.S. and international environmental regulations and play a central role in meeting the design and operations objectives of high-performance, sustainable buildings.

To address the push from regulatory requirements, the pull from customers and the elevated standards for product sustainability in high-performance buildings, Legrand North America set out to define a clear set of Environmental Material Requirements (EMR) against which suppliers could be held responsible, while also continuing to ensure that we deliver solutions that meet customer expectations for form and function.

In March 2016, Legrand published its first EMR, with the goal of defining the restricted materials and disclosure requirements for suppliers of materials, components and finished goods to Legrand. The EMR, which will continue to evolve based on government regulations and market forces, covers the following six areas:

  • The Restriction of Hazardous Substances Directive 2011/65/EU (also known as RoHS 2 or the RoHS recast)
  • Proposition 65 (also known as California’s Safe Drinking Water and Toxic Enforcement Act of 1986)
  • Conflict Minerals (Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act)
  • Chemical Reporting (including intentional and residual substances)
  • Recycled Content (including post-consumer and post-industrial recycled content)
  • Legrand North America Packaging Standard and U.S. State Rigid Plastic Packaging Container (RPPC) Laws

We know that the success of the EMR is highly contingent upon the relationship between us and our suppliers, and a clear communication of expectations for both parties, so we focused a considerable amount of effort on educating our top suppliers. As part of this effort, Legrand hosted a Supplier Conference this year, which included information sessions on recycled content analysis and reporting, Legrand North America’s Packaging Standard and RPPC requirements and California Prop 65 analysis and reporting. The leaders of these sessions provided in-depth information on each respective EMR requirement and the type of data that suppliers are required to submit, as well as answering questions. In March 2017, Legrand will be hosting a condensed version of the Supplier Conference and collaborating with its Asia-based suppliers on the EMR as well.

One of the most challenging aspects of the EMR is collecting the data required to validate supplier conformance. To facilitate this process, we are currently implementing a supplier information management software platform and rolling it out to suppliers across each division, who will now be able to report data related to our EMR. Despite the initial lift on the part of our suppliers, we believe that the data collected as a part of this effort will increase their competitiveness in the market by boosting their ability to respond to sustainable building certifications such as LEED® v4, as well as the dynamic nature of state, federal and international regulatory schemes.

Although the implementation of the EMR is still in its early stages, the collaboration and communication we have with our suppliers, and within our own departments, have been central to the program’s initial success. Members of our sourcing and sustainability teams have played a vital role in ensuring that the expectations of suppliers are clearly laid out, and that the information being requested does not become unnecessarily burdensome.

Internally, Legrand formed a cross-company team in 2013 to foster the sharing of best practices and to develop processes to support our product compliance efforts. Members of this team not only helped design the EMR, but are also now working to update the requirements as regulations and market expectations shift. The inclusion of professionals across various functions within Legrand helps ensure that the requirements are in line with shifting market, industry and regulatory demands, and that they are considered at each stage of a product’s life cycle.

Looking forward, the implementation of the supplier information management software platform will allow us to build on and expand data collection efforts and respond to non-conformance in a more streamlined and strategic manner. Our hope is that this proactive approach will continue to bolster Legrand’s efforts to monitor and enforce our EMR while also assessing the environmental impact of its products.

by Patrick Ford

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