3.6 Protecting workers – Are suppliers required to implement medical surveillance policies and practices to prevent occupational diseases?

Original question as formulated in the survey: Do EICC member companies require their suppliers to develop and implement comprehensive medical surveillance policies and practices for all workers to help prevent occupational diseases (and that protect the privacy of the workers as more fully detailed in Section 3 of ‘Meeting the Challenge’?)

EICC self-score: chemical-yellow-web

EICC justifies this score by referring to VAP Protocol B3 and B4.

GoodElectronics and ICRT score: chemical-red-web

GoodElectronics and ICRT, however, remark that the VAP Protocol does not seem to provide any guidance on how to evaluate the ‘procedures and systems to prevent, manage, report and track’ occupational illnesses. Nor is there any guidance on minimum and/or optimum methods for identifying occupational illnesses, such as what constitutes comprehensive or adequate medical monitoring. Likewise, GoodElectronics and ICRT could find no guidance on how long medical monitoring records need to be kept or on what constitutes an adequate ‘medical surveillance system’ or on how to define ‘abnormal medical surveillance’.

GoodElectronics and ICRT did note that VAP 3.2 requires that injury and illness records must be kept for three (3) years. However, this is also inadequate and different from medical monitoring records retention. Industrial hygiene and air monitoring are not mentioned in this section.  None of this is defined, documented, tracked, or monitored; therefore, it cannot be properly audited.

Further reading

‘Meeting the Challenge’ on Protecting workers