Proposed UK Sustainable Steel Scheme - Consultation
Consultation Open 1 March - 30 April 2019
Objectives and Drivers
Recent developments specific to the UK market over the last few years include the implementation of the Social Value Act 2012, the Modern Slavery Act 2015, Gender Pay Reporting Regulations, the UK governments PPN/1116 Procuring Steel in Major Projects and the Welsh Assembly Procurement Advice Note - Supporting the sourcing of steel in major construction and infrastructure projects in Wales. Taken together, these drivers lead to an expectation that UK construction and infrastructure projects, will endeavour to source steel from producers able to evidence and deliver the highest levels of social value and sustainability performance.
Internationally, various local and regional markets may have differing expectations related to local conditions and local sourcing needs. Reflecting these requirements and that the maturity of sustainability management varies regionally, the CARES Board has decided to adopt a strategy of regional scheme development consistent with it’s ‘Think Global, Act Local’ strategy. The first such scheme under development, focused on steels for construction, is for the UK market which is at a higher level of maturity compared to other markets, having been using responsible sourcing/sustainability criteria since 2008.
The scheme scope will be for constructional steel producers and fabricators to the UK market. The intention is that there will be mandatory performance thresholds in the scheme in line with the drivers of the scheme above.
The Standard Setting Process
CARES is committed to stakeholder engagement to inform decision making for setting standards and continual improvement in all aspects of its operations.
The Timeline and opportunities to contribute to the development of the standard are outlined here. Please note that this is subject to change depending on the development process:
|Tasks||Timing||Opportunity to feed into process?|
|Social Value consultation||February 2018||Yes|
|Initial consultations that established need for scheme as part of CARES stakeholder outreach||Spring/Summer 2018||Yes|
|Initial Draft scheme||July-Nov 2018||No|
|Plans presented to Sustainability Committee||Nov 2018||Yes – for members of Committee representing various stakeholder groups|
|Further scheme development||Dec 2018 - Feb 2019||No|
|Open Consultation on initial scheme documentation||March - April 2019||Yes|
|Piloting of scheme with producer(s)||March - April 2019||Yes, from producers|
|Piloting of scheme (including Appendix 2 – steel processing) with fabricator(s)||May 2019||Yes, from fabricators|
|Updates to scheme documentation and plans further to consultation||May 2019||No|
|Next versions of scheme documentation and plans released for review and feedback, including by Sustainability Committee||May 2019||Yes|
|Consideration of feedback, further updating if required||June 2019|
|Consideration by CARES Board, formal adoption of the scheme||June 2019|
|Accreditation of the scheme via UKAS||TBC|
|Proposed launch date||July 2019|
Scheme Governance and Structure
Based on BS 8902: 2009 and the successful international Sustainable Constructional Steels (SCS) Scheme, the new scheme is planned to operate in a similar way to the established certification schemes operated by CARES. This includes; a similar governance structure where the ultimate decision-making authority is the CARES Board. Consideration and feedback will be sought from the CARES Policy Advisory and Sustainability Committees as well as broader stakeholders. CARES is accredited by UKAS and it will seek approval from UKAS to certify to the scheme requirements.
The Sustainability Committee should provide important technical advice to CARES to ensure the scheme is suitably challenging for participant companies, provides appropriate focus on UK construction market needs and encourages performance improvement in line with available science and context.
It is planned that the scheme will consist of: a scheme manual; appendices representing the requirements of differing steel production methods and products; a self-assessment and audit workbook; auditing requirement and training for auditors; the transparent publication of summary sustainability performance.
Within the UK market only, the UK Sustainable Steel Scheme supersedes the CARES Sustainable Constructional Steels (SCS) Scheme from 1 year after the official scheme launch date, for any new orders and allows for a transition period of 1 year where both schemes will be acceptable for new orders. Existing orders made under previous schemes can continue to be processed under those certifications until order completion.
The scheme is being developed to comply with the ISEAL Code of Conduct for Standard Setting for Social and Environmental Standards.
Aspects of the scheme that meet that differing expectations of public sector and leading private sector procurement in the UK and that differ from the SCS scheme include:
- Human rights risks, including ensuring suppliers of primary materials are not from countries of very high risk (5 or 5+) as defined by the International Trade Union Congress Global Right's Index.
- Renewable Energy, requires applicant companies to calculate the % renewable energy directly produced or purchased as a proportion of total energy consumption.
- Gender Pay equality, requires applicant companies to report of Gender pay gap following the statutory requirement in the UK
- Lost Time Injuries, with consideration being given to applying a de minimus threshold to encourage the highest levels of health and safety performance
- Skills and Training, with enhanced detail and reporting requirements in relation to apprenticeships and the employment and training of the long-term unemployed, disadvantaged people and young people.
- Local procurement, enhanced detail on procurement from SME’s and Voluntary, Community or Social Enterprises (VCSE)
- Provenance indicator, enhanced detail on the value added to the UK economy based on disclosure of the % of activity of key stages in the constructional steel product value chain in the UK
- Social Value created, employment and social valuation calculations shall be enabled by requiring scheme applicants to hold anonymised employee profile information. This data is then available on request from clients to enable them to calculate the social value from their procurement activities in relation to a specific project or order. Scheme participants will additionally be required to indicate its contribution to the local economy through local employment.
The following documents are available for consultation together with a template to structure your feedback:
- The Scheme Manual (this document describes in detail how the Certification Scheme functions and the operating procedures for the assessment and management of the sustainability aspects and responsible sourcing).
- Appendix 1 of 6 (this Appendix is representative of the set of 6 appendices that particularise and detail the requirements of the Scheme in relation to the specific manufacturing operations and processes or services involved in the provision of steel products and/or associated services.
- Scheme balanced scorecard (this scorecard is intended to be provided to the applicant company after successful certification and will provide performance information in relation to selected scheme indicators
We welcome your feedback on these proposals.
This open consultation period is between: 1 March – 30 April 2019.