‘Meeting the Challenge’ on Protecting Workers:

The brands shall ensure that their own and all workplaces throughout the supply chain are safe for all workers, regardless of gender or age. Risks from hazardous substances to the safety and health of workers, who are routinely exposed to low levels of multiple chemicals on the job, must be eliminated or reduced to a minimum, including risk to the pregnant worker and her fetus.

This responsibility includes the prevention of harmful toxic discharges into communities surrounding manufacturing facilities and throughout the product lifecycle, beginning with mining communities, continuing with workers in chemical manufacturing and communities, and ending with workers involved in informal and formal e-waste recycling.

  • Map processes: The brands must map each manufacturing process used to make its products. Each supplier must document which processes are used, at which locations, to manufacture materials, components and subassemblies, and in final assembly.
  • Identify potential for harm: The brands must assess the potential for harm connected with each of the processes identified above. The assessment process shall be conducted by industrial hygienists knowledgeable about the relevant toxic materials and an occupational medicine specialist.
  • Identify the chemicals generally used (and generated) in each process: The brands must take responsibility for the safe use of chemicals used for each process, including the best methods for safe management of each chemical during transport, storage and manufacturing, and as waste.
  • Inventory of the actual chemicals used (and generated): The identity and volume of all chemicals used in each process shall be disclosed on a quarterly basis, as well as how each chemical is managed as waste. Brands and suppliers share this responsibility. Periodic testing shall be done to identify all of the materials in the waste stream, including those generated during production.
  • Determine hazard potential: The brands and suppliers shall (based on the advice of qualified experts) evaluate each material used and generated to determine which have the potential to cause harm when released into the workplace air, external air, wastewater, waterways or onto land.
  • Develop and implement comprehensive workplace hazard monitoring protocols and methods that take into account privacy and are gender- and culture-sensitive: The brands must develop and implement, jointly with affected and interested workers and their organisations, comprehensive hazard monitoring to assure a safe and healthy workplace throughout the product lifecycle. This includes:
    • Participatory training of all workers and managers potentially exposed to Materials of Concern;
    • Capacity building for all workers and managers potentially exposed to Materials of Concern;
    • Comprehensive ongoing industrial hygiene and environmental monitoring to measure the release of and exposure to all Materials of Concern used and/or generated in manufacturing/production;
    • Ongoing independent comprehensive health surveillance by qualified experts that is occupationally-relevant, for all workers, to identify and prevent diseases. Results shall be disclosed to workers in a detailed, timely manner;
    • Recognition of workers’ rights to negotiate regarding hazardous working conditions and to refuse hazardous work without fear of retaliation.

Comprehensive monitoring, including industrial hygiene monitoring to measure exposures and health surveillance to identify and prevent disease, must be extended to all workers in the supply chain, including workers involved in extraction of raw materials, processing of raw materials, manufacture and assembly of components and products, as well as workers involved in re-use and recycling, especially workers in the informal sector.

  • Conduct monitoring, measuring and documenting exposures: The brands shall create, oversee and manage procedures for all suppliers to use in monitoring and measuring releases of hazardous chemicals to the workplace, to the external air, wastewater, waterways and to land (see Appendix A). Properly calibrated or otherwise verifiable equipment shall be used and maintained for required monitoring and measurement. Measurements of worker exposure shall evaluate ongoing exposures, as well as short-term spikes in exposures. Monitoring shall be conducted by a certified industrial hygienist, or equivalent.