The Bureau of Labor Statistics (BLS) is currently soliciting comments on the definition they will use in measuring green jobs, the industry list of green jobs, or any other aspect of the information provided in the Notice of solicitation of comments published in the Federal Register. I’ve decided this is an excellent opportunity to voice my thoughts to the BLS as well as with our readers.

I encourage you, too, to comment on the Notice; the deadline is April 30, 2010.

16 April 2010

Richard Clayton
Office of Industry Employment Statistics
Bureau of Labor Statistics
Room 4840
2 Massachusetts Avenue, NE
Washington, DC 20212

Dear Mr. Clayton:

Thank you for the opportunity to provide comments and recommendations on the definition, industry list, or other aspect of the information provided in the 16 March 2010 Notice of solicitation of comments concerning green jobs. The focus of my submission is on the latter, specifically, the approaches in identifying the environmental economic activity adopted in response to the challenge of defining the term “green jobs.”

BLS plans to use two approaches in identifying economic activity and quantifying the associated jobs: the output approach and the process approach.

The Notice describes the output approach as being concerned with identifying and counting those jobs related to producing a specific set of goods and services (i.e., those with a discernible positive impact on the environment or natural resources conservation) from economic activities (e.g., renewable energy, greenhouse gas reduction, pollution reduction and cleanup, and recycling and waste reduction). This description leaves open several gaps that could undermine the validity of the data collected in support of the goal to identify and quantify green economic activity and green jobs.

First, what does the BLS define as the “environment” and “natural resources conservation”? The definitions should include factors used to determine what an “impact” is and whether it is “positive.” Impacts are often difficult to quantify or qualify and may vary based on the population’s value system and the population’s demographics. Similarly, what may be a “positive” impact to one population may result in a negative impact to another population.

In addition, the definitions of “environment” and “natural resources conservation” should identify temporal and spatial characteristics (e.g., those with positive impacts as measured within the past decade in the continental U.S.), the population of concern (e.g., flora, aquatic ecosystems, children, workers), and the point at which the impact will be assessed (e.g., during manufacturing, during end-of-life management, or across the life cycle of the goods and services).

Absent further clarification, the BLS may misrepresent the true intention of its efforts. For example, per the current framework provided, solid waste collection jobs could be identified and counted as a green job. However, the BLS Census of Fatal Occupational Injuries reported 34 fatalities in 2008 in the solid waste collection industry (NAICS 562111). Does the BLS want to include in the category “positive impact” those goods and services produced in an industry with one of the greatest number of fatalities among workers in the Services sector?

The current framework also could include jobs in the nonhazardous waste disposal industry. Does the BLS consider the current end-of-life management techniques for electronic waste, a type of nonhazardous waste, as having a positive impact on the environment and natural resources conservation? Does shipping electronic waste away from the United States alleviate the BLS from having to consider environmental and natural resources impacts to other communities (e.g., those in Asia and Africa)?

I would hope that the answers to these questions would be “No.”

The Notice describes the process approach as being concerned with the identification and enumeration of those jobs that use environmentally-friendly production processes and practices, but not with what good or service are produced. Environmentally-friendly production processes and practices are defined by BLS as those that reduce the environmental or natural resources impact resulting from production of any good or service. Examples of processes include generating solar power for use within a retail establishment and recycling waste created during a manufacturing process. Workers who perform these processes would be counted.

It is noted that the process approach is still in development and that when the development process nears completion, BLS plans to publish a separate Federal Register Notice for public comment.

Until that time, I ask that the BLS consider the published data concerning the lack of statistically significant differences in OSHA lost time case rates between green projects (as identified by the U.S. Green Building Council’s LEED certification system) and nongreen projects (Rajendran S, Gambatese JA, Behm MG. Impact of green building design and construction on water safety and health. Journal of Construction Engineering and Management. 2009. 135(10):1058-1066). Workers who install equipment to reduce water pollution per LEED use standard construction work practices, not practices uniquely safe or “green.”

In addition, I hope that the BLS will consider using a life cycle or systems approach in its definition of environmentally-friendly processes and practices. Risks to environmental and occupational health across the entire life cycle (i.e., not just production) should be characterized, evaluated, and used to inform BLS decision making. The literature on life cycle assessment and integrated environmental assessment is robust. Subject matter experts in these interdisciplinary fields can be found in various academic and industry-based locations, some of whom are in Washington, DC.

I appreciate the opportunity to comment on this Notice. I trust that BLS personnel are equally appreciative of this opportunity to advance the theoretical and empirical approaches to defining, scoping, assessing, and evaluating green jobs. Now is the time for BLS to ensure that the data representing the economic, environmental, and social impacts across the life cycle of goods and services are considered.

I believe that we have already perfected decision making based on incomplete, inaccurate, or imprecise data (i.e., garbage in, garbage out). The planning and policy initiatives for green jobs should be informed by interdisciplinary frameworks and tools. I am confident that the BLS will leverage this opportunity to evolve its processes for collection and evaluation of new data on green jobs.

Thank you for your time and consideration.