Why "Buy Clean" Policies Should Consider Toxic Pollutants (And Much More)

Centering Health, Wellbeing, and Environmental Justice in Industrial Transformation 

Increasingly, those in the climate movement see industrial decarbonization as the next frontier of climate action. 

For many years, the focus of the climate movement has largely — and rightly — been on the power sector. But industry accounts for nearly a quarter of greenhouse gas emissions in the US, and we’re seeing growing awareness that meeting climate targets also entails cleaning up the industrial sector. The movement is leading a surge of interest in the decarbonization of heavily polluting industries as well as related policies such as clean government procurement, also known as Buy Clean. 

While the objective of decarbonizing industry is laudable, decarbonization policies may not effectively contribute to a more livable planet and healthy communities, and may even be counterproductive, unless they also incorporate and cohere with broader objectives — namely:

1. Tackling toxic land, air, and water pollution, resource and biodiversity depletion, and ecosystem resilience; and
2. Addressing the localized impacts of industrial production (and industrial transformation) on communities — including the disproportionate impact of pollution on Black, Indigenous, people of color, and low-income communities, and the impact of deindustrialization on workers.

A holistic approach to industrial transformation requires thinking about green industrial policy as more than pro-climate industrial policy and shifting to a framework that incorporates broader health, wellbeing, and environmental justice objectives. Neglecting to do so risks enabling solutions that fail to adequately address the impacts of industrial production on the wellbeing of communities — and on the ecosystems that sustain them. 

Specifically, the design of industrial policies like Buy Clean should be careful to avoid certain critical pitfalls:

1. Narrow boundaries and point source reductionism 

Policy solutions aimed at reducing CO₂ emissions from industrial production may effectively fail to reduce CO₂ if they do not account for CO₂ emissions along the full (local and global) value chain. For example, to effectively reduce CO₂ emissions from steel production, policy interventions should be based on an understanding of how much CO₂ is emitted from the beginning to the end of the steel production process. This means from the mining of raw materials, like iron ore and limestone, to the energy-intensive processing of those materials into steel, to the management of the ensuing pollution and waste.

However, CO₂ accounting tends to be limited to facility-level emissions, or at best incorporates emissions from associated electricity generation. Such narrow boundaries obscure the full emissions intensity of steel production and can mislead policymakers into solutions that may reduce "point source" facility-level emissions but increase overall emissions. For example, much hope has been placed on hydrogen as a means of reducing emissions by eliminating the need for coke (a fuel or feedstock derived from coal or petroleum) in steel production. But producing all steel this way would require almost tripling current global hydrogen production. Also, most cheap hydrogen today comes from highly polluting processes that rely on fossil fuels ("blue", "gray", or "brown" hydrogen) rather than "green” hydrogen (made with renewables). If policymakers indiscriminately incentivize hydrogen-based steel production without factoring in upstream emissions from hydrogen production, they could potentially create incentives for decarbonization that in fact increase CO₂ emissions. 

2.  CO₂ reductionism

Policy solutions exclusively targeted at CO₂ reduction may also fail to mitigate climate change (let alone adverse health impacts) if they do not factor in greenhouse gas emissions besides CO₂. For example, mining of metallurgical coke used in steel production is responsible for an enormous amount of methane emissions. Failing to account for such emissions may lead to solutions that are effective in reducing CO₂, but inadvertently increase emissions from other greenhouse gasses — some of which can have a far greater impact on global warming than CO₂. Methane, for example, is more than 25 times as potent as carbon dioxide at trapping heat in the atmosphere. 

3. Greenhouse gas reductionism 

Similarly, policies exclusively focused on reducing CO₂ and other greenhouse emissions may avoid all the above pitfalls and yet still fail to contribute to a more livable planet if they do not factor in highly dangerous pollutants that are not greenhouse gasses. Iron and steel facilities, for example, emit lead and other hazardous air pollutants, exposure to which has been demonstrated to cause adverse health effects like chronic and acute disorders of the blood, heart, kidneys, and reproductive system. Lead accumulates in bones, blood, and soft tissues of the body and can affect development of the central nervous system in young children, resulting in devastating neurodevelopmental effects even in minuscule amounts. 

Moreover, toxic pollutants like lead contaminate land and water in addition to air and can even be transmitted through consumer products. Therefore, industrial transformation policies that aim to mitigate the immediate, localized health impacts of pollution — and not only the systemic health impacts that arise from climate change — need to take into account, and aim to reduce, the full range of pollutants associated with particular industries, as well as the various vectors through which those pollutants impact human health. Failure to do this can lead to counterproductive measures like replacing coal with the burning of highly toxic waste in cement kilns.

4) Pollutant reductionism

Industrial transformation policies may adequately account for all relevant pollutants but still make matters worse for people and the planet if they fail to factor in the broader impacts of the industry they seek to transform on critical ecosystems and their services. 

For example, a policy intervention may succeed in reducing all manner of pollutants, but do so at the expense of unsustainable extraction of scarce resources. This policy may degrade the ability of ecosystems to produce critical goods efficiently (for example, depleting soil through tillage, threatening food security), or deplete aquifers in water-scarce areas for industrial production. The production of hydrogen through electrolysis, for instance, is highly water-intensive — supplying hydrogen for a 288-megawatt power plant using 100 percent hydrogen would require the equivalent of an Olympic-size swimming pool of water every 12 hours — so, unless it is produced in a setting with great water abundance, hydrogen production could potentially threaten neighboring food production or access to drinking water. 

Even more dramatically, industrial transformation policies could deplete biodiversity or damage ecosystems to such a degree that they are unable to support life at all. For example, in the lithium-rich Andean regions of Argentina, Bolivia, and Chile, Indigenous farmers increasingly compete with miners (and implicitly downstream industries like electric vehicle battery manufacturing) for highly scarce water supplies. In Chile's Salar de Atacama, lithium and other mining activities consumed 65 percent of the water, causing groundwater depletion and environmental degradation to the point that local communities were forced to abandon ancestral settlements. Policies aimed at industries like solar, which rely on large-scale expansion of mineral extraction in delicate ecosystems and vulnerable communities, must factor in such impacts into their accounting of costs and benefits. 

4) Environmental reductionism

Even if the primary function of green industrial policies is to reduce the negative environmental impacts of industrial production, there are good reasons — both ethical and practical — for those policies to contemplate non-environmental impacts in policy design, including human health, workers' rights, and the distribution of social and economic costs and benefits.

Some policy solutions may be so well designed that they improve environmental indicators across the board — simultaneously reducing greenhouse gas and toxic pollutants, as well as resource and biodiversity depletion and ecosystem resilience — but they may still make matters worse for workers and frontline communities. For example, transferring a dirty steel plant that provides well-paid jobs to a distant location with better access to clean energy sources may improve air, land, and water quality and create new jobs, but it could also have a devastating impact on the newly deindustrialized community, including the capacity of families to pay for food, shelter and and the capacity of local governments to provide public basic services. Unless industrial transformation policies are designed in close collaboration with the communities that will be directly impacted by the effects of those policy shifts, they are not only likely to have a net negative impact on wellbeing, but also to create strong — and valid — resistance to green transitions.

Avoiding industrial transformation pitfalls in Buy Clean policies

Discussions about clean procurement policies often focus exclusively on CO₂ reduction and tend to suffer from many of the pitfalls outlined above. To avoid those pitfalls, policymakers can, for example:

1. Base Buy Clean standards on Environmental Product Declarations that include comprehensive life cycle analysis of the environmental impacts of products, including greenhouse gas and toxic pollutant emissions, as well as resource and biodiversity depletion and ecosystem resilience; and 
2. Ensure that they combine Buy Clean standards with procurement standards that account for the health, socioeconomic, and distributional impacts of industrial production. Instruments like Health Product Declarations and Social Life Cycle Analysis may help to complement Environmental Life Cycle Analysis to form a basis for a more comprehensive accounting framework.

The politics (never mind ethics) of industrial decarbonization demand that green industrial transformation be paired with environmental justice, good union jobs, and support for workers and communities in transition. Though there can often be tradeoffs between climate and broader environmental and social objectives, these must be acknowledged and carefully weighed when designing policy.