Do you think Volkswagen could use a Code of Good Practices? I mean a REALLY GOOD code of Good Practices.
Robert Crockett, Virginia Biosolids Council, rekindled my interest in the Code of Good Practice as a good practice. He discussed how the code adopted by biosolids practitioners in Virginia was an active tool for the council’s monthly meetings and for the self-organizing of its members’ activities.
I will come back to the VBC code later, but at the time Crockett was discussing the code, I realized that the Code of Good Practice that a decade before seemed so important to me as part of the National Biosolids Partnership had faded from my notice. Who IS paying attention to the NBP Code of Good Practice? Is it still an active tool? It seemed before like a necessary and significant part of our industry’s advancement, but, as I said, the NBP Code of Good Practice seems to have faded from our industry’s conversation.
I wondered, where else are Codes of Good Practice deployed? Is this turf that is common ground to most industries? How are they used in different circumstances? Can we learn something for how it ought to be used in the biosolids industry?
Does the “manure spreading industry” have a code of good practice? One example of a code is from the European community, in its AGRICULTURAL CODE OF GOOD PRACTICE. “The purpose of this booklet is to give farmers and growers and all those involved in land management activities (including pig and poultry keepers, horse owners, livery stables, agricultural contractors, as well as those involved in the application of organic manures to land), practical guidance on how to prevent pollution of soil, air and water.
So this code is more like a manual of practice.
Then there is the “fracking industry?” I found a code, not one developed for fracking in Pennsylvania, but rather one for fracking in Europe. This is the Good practice guidelines for the development of shale oil and gas: “These guidelines provide stakeholders with an overview of how the oil and gas industry manages the risks associated with its operations. For the majority of issues, good practices for shale oil and gas will be identical to those for ‘conventional’ operations.”
This code is about describing to the public how the fracking industry is currently operating, with a presumption that it believes all is well with fracking. Well, if you believe that...?
Moving beyond environmental-type codes, examples abound of good practices statements in other industries. Here are a few.
The Distilled Spirits Council has had for more than 80 years a voluntary code of responsible practices after the repeal of prohibition. The 2011 Code applies to all activities undertaken "to advertise and market distilled spirits, malt beverage and wine brands." As a mature code system, this council has an internal compliance system, a code review process and a review board.
This code is, I guess, centered on "don’t get the industry into trouble by promoting booze to kids."
I found a code for “memorialists.” What are memorialists, you might ask? Well, that is the industry that supplies gravestones.
You can be designated a Certified Memorialist (CM) through the Monument Builders of North America if you subscribe to its Code of Good Practice and complete the a “CM Application, which includes the initial participation activity form, and return it to MBNA Headquarters along with a signed Code of Good Practice form and a $250 USD processing and examination fee."
This code sends the basic message "don’t be a schmuck and sell shabby headstones for outrageous prices." The code asks its members to ensure that customers get what they are bargaining for in monument purchases. It also asks them to pay money.
Several features seem to make these approaches “codes of good practice” distinctive.
In some cases, the codes seemed design to establish the common practices that an industry hopes will, if implemented, minimize bad raps about bad actors.
In a few notable cases, the codes seem aspirational. That is, the codes declare how all participants ought to act, with a mechanism to lead, or beat, the profession along this path.
Back to the VBC. Its code of good practice is definitely aspirational. Virginia Biosolids Council Code of Good Practice, approved December 3, 2009, "provides voluntary guidance to Council members for responsibly generating and beneficially recycling biosolids in the Commonwealth of Virginia." Here is one provision that stood out for me: “Quality practices should be implemented to minimize impacts of biosolids generation, transportation, storage and recycling on neighbors and other stakeholders. These practices include, but are not limited to: minimizing odors, dust, and dirt on roads at application and storage sites; implementing transportation schedules to minimize disturbances to neighbors; and implementing training programs to improve driver safety and emergency response.”
Did you catch that – “minimizing odors”?
Let me contrast this with the National Biosolids Partnership Code of Good Practice. First, the NBP Code does not mention by word that one attribute of biosolids that creates the most upset – odors. Secondly, its principal concept is one of regulatory compliance. For example:
“Compliance: To commit to compliance with all applicable federal, state, and local requirements regarding production at the wastewater treatment facility, and management, transportation, storage, and use or disposal of biosolids away from the facility.”
“Product: To provide biosolids that meet the applicable standards for their intended use or disposal.”
So today, when I read the NBP Code of Good Practice, it seems bland and insubstantial. It is has a procedural orientation, rather than an outcome orientation, with no statement about odors, nor any statement about building community acceptance. It doesn’t acknowledge the potential for going well beyond regulatory compliance. The code is written rather like the one for the European fracking industry, to support a status quo for conventional practices. It is one designed to not leave any agency outside the tent.
When Crockett explained that the VBC code is the foundation for continuing dialogue among members, one that is continually evolving and self-policing, I realize that a code which is a static description of conventional operations does not drive progress. Could it then really be expected to achieve public acceptance. Crockett holds as one example of the VBC code effectiveness that odor complaints are down 90% compared to a decade ago.
If your code is not aspirational, why bother, as your actions will speak louder than your words.
If what we are learning about VW is true, that entire enterprise was oriented toward selling high-priced cars, not delivering great quality cars. If it had an aspirational code of good practice I doubt that it read "conduct honest testing and deliver lowest possible diesel emissions."
The NBP Code of Good Practice has been unchanged since about 2000. What is more, the National Manual of Good Practice, which is an implementing document, has not been updated for about a decade. To my knowledge, no initiative has been embraced to update, revisit, or upgrade the standards or codes, despite a decade of technology and science advancements, and despite many additional cases of community concern and political challenge.
For that matter, Mid Atlantic Biosolids Association doesn’t even have a Code of Good Practices. So what does that say about our own association’s commitment? Hmmm???!
It says that we need to have a standard for good standards.