Preparatory Document

Goal and Scope

The Charter is made of a set of requirements (indicated with a “shall”) that LCA Critical Reviewers (called “CR expert(s)” in the rest of the Charter), who claim to work “according to” the present Charter, bind themselves to apply.

They include also recommendations for Commissioners if they want to enable their CR expert(s) to apply the requirements of this Charter.

These requirements are set for fair and efficient CR practice. These requirements may partly overlap with contractual documents and applicable standards (indicated with a “S” in the title). No requirement of the present Charter is in contradiction with a requirement of an applicable standard.

Definitions

This Charter is redacted for LCA experts who plan to involve themselves in a CR process. LCA experts, if you have a doubt about the definition of a term used in the present Charter, please refer to the definitions of ISO 14044 and ISO/TS 14071.

C1. Knowledge of the relevant (last versions of) standards S

The expert having the role to provide the LCA expertise in a CR panel, or acting as a single CR expert, shall know and shall apply ISO 14040, ISO 14044 and ISO/TS 14071 requirements.

C2. Keeping competencies up to date in an ever evolving practice

A CR expert shall keep his knowledge up to date and make efforts to do so if he is not practicing LCA on a regular basis. Significant research is on-going about the LCA practice, and a lot of publications are done. These contributions are relevant for the CR process. A significant amount of the reference information (guidance, databases, orders of magnitude…) that a given CR expert uses to do his CR work becomes quickly obsolete.

From the practice: a CR expert who would no longer practice LCA would lose all recent feedback from the LCA practice. Some CR experts tend to do just CR… which is not really appropriate.

C3. Statement of competencies S

An expert involved in a CR panel, or acting as a single CR expert, shall clearly state its competencies at the beginning of the CR process, using for example the relevant annex of ISO/TS 14071.

C4. Limitation of expertise – nobody knows everything

An expert involved in a CR panel shall clearly state, during the CR process, when he is not competent to evaluate a given part of the LCA Report under CR. This warning may involve the fact that an additional expert is involved in the CR process to cover the given part of the LCA Report under. Otherwise, a limitation in the CR Report regarding the coverage of the CR shall be written.

From the practice: nobody feels comfortable saying: “I do not understand”… of course! But it would not be comfortable, after the CR, to understand that some obvious comments have been forgotten due to a lack of competency.

C5. Involvement of beginners – a long walk always starts with a first step

When an expert is involved for the first time as a CR expert, he shall be mentored by a more experienced CR expert during the CR process. That means that the overall workload will be higher than with an experienced CR expert. This mentoring may last for more than one CR process.

C6. Goodwill is key!

The CR expert(s) shall provide their comments in a professional way: not being too rude & aggressive at the Practitioner himself – the CR comments address the LCA report of the practitioner, not the practitioner himself… even when the CR expert(s) thinks that the competency of the practitioner could be higher…

From the practice: it is so simple to attack a LCA practitioner and say: you are not competent! (it might the case, by the way).

C7. Collaboration between CR expert(s) is better than competition

CR experts working together in a panel shall avoid competition between them during the CR process.

From the practice: CR experts are humans. Additionally, the might want to show to the Commissioner that they have high competency in order to get further contracts. Great! Then, their comments might become very elaborated in order to show that they are more competent than the other CR experts in the panel… Additionally, they might adopt a very demanding attitude (towards the Practitioner). This may become highly counterproductive in the scope of a CR, going against a lot of requirements of the present charter, such as C6, C14, C15, C19… This would be a pity!

C8. Confidentiality and respect to favor freedom of exchanges

The oral and written exchanges occurring during the CR process between the Commissioner, the Practitioner and the CR expert or panel shall remain confidential, apart from what is written in the CR Report. More specifically, the CR expert or panel shall expound no comment about the competency of the Commissioner or Practitioner apart from those that he has (maybe) put in its CR Report. Of course, if the Commissioner or the Practitioner put public any information regarding the CR process, then the CR expert(s) can comment that information.

C9. Independence S

The CR expert shall always care about his independence, and warn the Commissioner when he starts to feel no longer independent in order to avoid losing his independence. If one CR expert feels no longer independent, he shall stop his participation to the CR process and provide the Commissioner with the reasons why he feels no longer independent. The Commissioner cannot criticize the CR expert in that case.

C10. LCA practitioner lack of competency – a CR is not a LCA training!

If the LCA competencies of Practitioner (and the Commissioner) are low, there is a risk that the CR expert(s) become the project manager. Then, the CR expert(s) are no longer independent. If the CR expert(s) is aware of this situation before the start of the CR process, then the CR expert(s) shall reject the CR work, and warn the Commissioner that additional work is needed on the LCA Report before launching a CR process. An early warning is more than welcomed! In order to do so, the Commissioner is invited to provide the current LCA report (if available) to the CR expert(s) as early as possible.

From the practice: a draft final LCA report made of 4 pages is (“most often”) not sufficient to be the starting point of the CR process…

C11. A CR expert does not contribute to the LCA Report – a CR is not a LCA project

The CR expert(s) shall not redact any of the paragraphs of the CR Report. The CR expert(s) “suggestions of improvement” in the CR “detailed comments file” shall not include this kind of contribution.

From the practice: the tendency of some Commissioners is to ask the CR expert “can you tell me what you would have written here?” Of course, if the CR expert provides the paragraph, then he will agree with what is written! This is called auto-revision, and would be an evidence of dependence of the CR expert.

From the practice: of course, if a 4 pages report would have been used as the starting point of the CR process, the CR expert(s) would redact most of the final report! This is not acceptable.

C12. Avoid high number of iterations – the more you exchange, the closer you are!

When more than three stages of comments and answers are needed on the same CR detailed comments file, there is a risk that the CR expert(s) is no longer independent. A high number of iterations between the LCA expert(s) and the Practitioner shall be avoided. This high number of iterations is either due to the lack of competency of the Practitioner, the lack of willingness of the Practitioner to improve his LCA Report, or the lack of clarity of the comments of the CR expert(s)!

C13. CR comments nature S

The CR comments shall clearly state which comments are lack of compliance with requirements of the applicable standards and reference documents, and which comments are improvement suggestions (such as editorial comments).

The comments shall clearly indicate which part of the LCA Report is concerned. In order to enable this clear indication in an easy manner, the Practitioner is invited to provide to the LCA expert(s) the LCA Report with the indication of the line numbers.

C14. Avoiding personal views

A CR expert shall not promote his personal views, tools, databases, practices… within its comments. He shall base his comments on applicable standards, reference documents, and science.

From the practice: if the CR expert belongs to the company which sells given LCA data-sheets, he might think that they are the best to use within the LCA project he is currently reviewing (it might be true, by the way! But that is not the point).

C15. Keep options optional

When options are left opened by the applicable standards, the Practitioner may choose an option that the CR expert would not have chosen. In that case, the CR expert shall accept the approach.

C16. Clarity

The comments shall be redacted in a way that makes them unambiguously understood.

From the practice: writing “no” or “to be modified” as a CR comment is not enough!

C17. Generalization

When redacting a comment, the CR expert(s) shall envision how this comment may apply to the rest of the LCA report, and redact it in a general way. It is also recommended that the Practitioner consider each comment as a general one, and think of the way is applies to the rest of his LCA report.

From the practice: the CR process includes a data plausibility check. This can be done through sample tests. If there is a comment done during a sample test, generalizing the comments is key.

C18. Usefulness of the CR process S

The CR process is not a sanction. It is a way to let the Commissioner and the Practitioner improve their LCA Report. Then, the CR process shall always leave the possibility to the Commissioner and the Practitioner to make modifications to their LCA Report, and the comments shall strive to show to the Practitioner ways to improve.

From the practice: some verification processes of environmental information are not expecting any improvement.

C19. Check of integration of comments

The CR expert(s) shall exhaustively check the way the Practitioner has integrated his comments. This check will be done with goodwill. When a CR expert finds that one comment has not been integrated correctly, he shall explain why in the detailed comments file. This may be a cause of iteration of the CR process (see C12 about iterations).

In order to enable the CR expert(s) to do that check, the Practitioner indicates in the detailed comments file which action has been done, and where in the LCA Report this action has been done. When possible, the LCA report is provided with track changes after modifications according to the detailed comments file.

C20. Delay is needed

The CR expert(s) shall always warn the Commissioner and the Practitioner about the fact that he needs time to step back before redacting his CR comments. The CR expert(s) shall always use the appropriate time they need before redacting their CR comments.

C21. Urgency is not appropriated

A CR process cannot be held professionally in an urgent situation. The CR expert(s) shall always request the necessary time to do their work in a professional manner, and refuse to participate to the CR process if the timing of the CR process is too short to do their CR expert work in a professional manner.

C22. Final (potential) conflicts S

At the beginning of the CR process, the CR expert(s) will invite the Practitioner to integrate modifications in his LCA Report according to all the comments, if the Commissioner wants to avoid falling in a conflicting situation.

If modifications do not answer the expectations of the CR expert(s), the CR Statement shall always highlight the issues that remain, from the point of view of the CR expert(s), in the LCA report, even if the Commissioner and the Practitioner request the CR expert(s) to remove some issues from the CR Report. The CR expert(s) shall not voluntarily hide any issue in his CR Report. These issues are included in the detailed comments file, which is part of the CR Report.

This may result in the fact that the Commissioner and/or the Practitioner are not happy with the CR Report content.

Of course, in that case, the Commissioner and the Practitioner may redact some answers to the CR Report where they state why they have not solved the issue mentioned in the CR Report. These answers might be already included in the detailed comments file. These answers may be added after the CR Report in the LCA Report.