‘Meeting the Challenge’ on Transparency

To protect workers and community residents from harmful chemical exposure, both workers and communities must know what chemicals are being used and stored on the production site, what is being transported to and from the facility, what is being discharged and released both inside and outside the factory and what hazards these substances pose to people (including reproductive hazards) and the environment.

Workers must know what substances they are handling in their daily work. This transparency requires companies to provide full materials disclosure to workers, community residents and their representative organisations.

Brands must disclose their complete supply chain, as well as disclosing all of the materials used by all of their suppliers. Where adequate hazard data are unavailable for any chemical, this also needs to be disclosed.

Transparency and disclosure require action. Companies must:

  1. Provide health and safety information: Workers and community residents must receive full, up-to-date, understandable and free-of-charge health and safety information about chemical hazards. These published and peer-reviewed studies should make clear who has to do what to ensure a safe working environment when hazardous chemicals are being used. In addition, fully referenced scientific/technical data upon which this information is based must be provided upon request. It is the brands’ responsibility to ensure that contract manufacturers, ODMs, component manufacturers and others in their supply chains provide this information to workers, communities and the general public.
  2. Share hazard information without restriction: Information on the health, safety and environmental effects of substances used in production and present in electronics and electrical products must be shared without restrictions with workers, communities and their representative organisations. Even when specific material formulas are confidential, the hazard information shall not be considered as such.
  3. Provide all Safety Data Sheets (SDS): Globally Harmonised System (GHS)-compliant safety data sheets must be freely and easily available to workers, communities and their representative organisations, for all materials stored, used and discharged from the workplace. For substances whose environmental or human health effects are inadequately or incompletely characterised, the principles outlined at the end of Section 2 apply.
  4. Cooperate with education and training initiatives: Companies should cooperate with governments, non-governmental organisations, trade unions, health-care providers and other third party experts to provide ongoing education and training for workers, community representatives and emergency medical responders. Brands must ensure training and education throughout their supply chains. Education and training must cover:
    • monitoring and early warning systems for dangerous chemicals used or created during production;
    • detailed information about hazardous substances in production, and best practices for protection from and reduction of exposure to those hazards;
    • how to recognise early signs of adverse health impacts;
    • implementation of good industrial hygiene practices to prevent and/or minimise exposures or the risks that these exposures create. Implementation entails controlling hazards at or as close as possible to the potential source, along the exposure path if control at the source is not possible, and with personal protective equipment only as a last resort when engineering controls at or close to the source do not provide sufficient protection.
  5. Maintain and disclose chemical inventory: Companies shall maintain an inventory of all materials and chemical substances used and generated throughout the production process following the Globally Harmonised System (GHS). Companies will disclose this information to workers, communities and their representative organisations at least annually (updated) and make this information publicly available. Brands will include contract language with their suppliers requiring disclosure of all materials used in production processes, not just those substances that appear in the final products. In addition, brands shall implement an effective system to accept and manage all chemical disclosure information in real time in order to track chemical use and management by suppliers.