3.3 Protecting workers – Do the brands track and report the volumes of all used chemical materials, the number of workers exposed and the volumes of discharge of each of these materials?

Original question as formulated in the survey: Have EICC member companies identified the volume of all the chemicals used and generated in each process throughout your supply chain, how many workers are exposed to these materials, and the volumes of the discharge of each of these materials?

EICC self-score: chemical-yellow-web

EICC justifies this score by referring to VAP Protocol C3.1, adding that suppliers are required to do this for hazardous chemicals, but not for all chemicals.

VAP Protocol C3.1 reads as follows: ‘Hazardous substances including wastes are properly categorized, labelled, handled, stored, transported and disposed using government-approved and/or licensed vendors as per local laws. Minimum requirements are listed including requirements for site observation (Hazardous substances are categorized, handled, stored and transported within the facility. To control access or potential employee exposure methods such as segregation, secondary contained, ventilation, fire protection, appropriate storage cabinets, hazard signage and information (labels and MSDS), limited access, … have been implemented throughout the site).’

GoodElectronics and ICRT score: chemical-red-web

GoodElectronics and ICRT object to the overly positive assessment EICC is giving here. C3.1 does not require measurement of the volume of any chemicals used. C3.1 does not require measurement and reporting on numbers of workers exposed. C3.1 does not require measurement of the volume of materials discharged. And again, C3.1 does not provide any definition of adequacy, accuracy or verifiability. EICC auditors have therefore no way of evaluating compliance by suppliers. Moreover, none of these registrations seem to be public or reportable.

Further reading

‘Meeting the Challenge’ on Protecting workers