Improving Occupational and Environmental Health in the Global Electronics Industry 

(Press release from NGO coalition)

Policy Date: 10/30/2012 - http://www.apha.org/advocacy/policy/policysearch/default.htm?id=1438
Policy Number: 20124

Abstract 

The manufacture and use of electrical and electronic products has increased dramatically over the past several decades and includes rapid growth in contract manufacturing, which takes place through a complicated chain of subcontractors, often located in Asia. The rapid growth of the industry has been accompanied by increased use of toxic chemical substances and a variety of adverse health outcomes have been observed, including in Asian manufacturing facilities located in China, Korea, and Malaysia. Compounding issues include weak occupational exposure limits (if any); lack of uniform protective exposure standards for workers, including the presence of child laborers; lack of information about the hazardous substances used in and released from electrical and electronic products; use of tactics by special interests to delay protective action; lack of advisory panels on occupational health policies that provide diverse perspectives with clear conflict of interest policies; and often the complete absence of tracking and reporting of patterns of disease associated with the electronics sector. Recommendations include development of precautionary, health-based exposure limits; age limits for employment and specific work activities based on hazards; provision of information; implementation of green design and substitution; promoting the formation of expert advisory panels whose members represent a diversity of policy perspectives; and tracking and reporting of diseases associated with the electronics sector in electronics-producing countries. 

Problem Statement 

The manufacture and use of electrical and electronic products has increased dramatically over the past several decades, and contract manufacturing for the global supply chain takes place through a complicated web of subcontractors, often located in Asia.[1–8] The global consumption of electronic chemicals and materials, particularly in developing countries, is projected to increase between 5% and 12.6% annually from 2010 to 2015, and a significant proportion of chemicals used in the production of integrated circuits and printed circuit boards currently originate from Asia.[9,10] The manufacture of electrical and electronic products relies on and uses more than a thousand chemicals and other materials, many of which are known to be hazardous and lack comprehensive toxicological health and safety information due to weak regulatory policies.[11,12] These substances include solvents, metals, persistent organic pollutants, such as certain flame retardants, and known carcinogens, mutagens, reproductive and developmental toxicants, and endocrine-disrupting compounds.[4,13] 

A variety of adverse health outcomes are associated with chemicals used in the electronics sector, and these outcomes—including cancer, lung disease, reproductive disorders, congenital anomalies in offspring, and musculoskeletal problems arising from repetitive motion—have been identified in manufacturing facilities located in China, Korea, Malaysia, and elsewhere.[14–22] Female workers in the semiconductor and electronics industry may also be at increased risk for spontaneous abortion and subfertility.[23–25] Some evidence even suggests that environmental exposure to chemicals while working in the electronics industry may lead to intergenerational adverse health outcomes.[26] However, progress toward reducing the risks experienced by women and children may have been slowed either by industry efforts to block publication of reports that identify causal links between exposures and outcomes or by industry-sponsored research that questions such causal links.[27–30] This suggests that women in their reproductive years, lactating women, and children may be particularly vulnerable populations in this context. Children have also been found to be working in these same hazardous work environments.[31–33] According to International Labour Organization (ILO) Convention 138, the minimum age for youth to be employed is 15 years,[34] and ILO Convention 182 was adopted to protect youth from the worst forms of child labor, including working in and around hazardous conditions and exposures.[35] 

Communities located in electronics manufacturing areas can also be adversely affected due to pollution from the manufacturing facilities. For example, there are 29 Superfund sites in Silicon Valley, the most concentrated number of Superfund sites in the United States. Most of these sites were contaminated by high-tech firms in the manufacturing of computer chips and other components.[36] However, the extent of community exposures requires further evaluation. It is understood that while the electronics industry provides valuable jobs, attention is nonetheless needed to identify greener and safer alternatives and controls. In 2009, more than 100 governments agreed under the Strategic Approach to International Chemicals Management (SAICM) that hazardous substances within the life cycle of electrical and electronic products are an emerging global policy issue requiring action.[37]

The occupational health and safety problems in the modern-day electronics sector are compounded by several factors. First, many occupational exposure limits (if they exist at all) are substantially less protective than community exposure limits. Moreover, they fail to account for the risks of long-term serious or irreversible damage among men, women, and children, such as cancers, adverse reproductive and developmental health, and other illnesses.[38,39] Second, a uniform set of protective standards for workers in the electronics sector does not exist, despite documented evidence of adverse health effects by the World Health Organization (WHO), the International Labour Organization, various government agencies, and individual scientists.[40] 

Third, the lack of information about the hazardous substances used in and released from electrical and electronic products, including during their extraction, production, and disposal, prevents workers and communities from knowing to what they are being exposed.[4,41] Fourth, special interests, in particular those with an economic stake in the electronic industry, exploit the nature of science, specifically scientific uncertainty, to delay protective legal and/or regulatory action. Under the guise of a call for “sound science,” these interests sponsor and promote changes in policy that weaken and continue to threaten public health protections.[42–44] Fifth, vested corporate economic interests may influence government decision making on issues related to environmental and occupational health protections if procedures are not in place to manage conflicts of interest and include a diversity of perspectives.[45] As a result, public health protections can be seriously undermined.

Proposed Recommendations Statement 

Key strategies to strengthen occupational and environmental health in the global electronics industry include right-to-know laws, an emphasis on substitution of safer substances and processes, and occupational health surveillance. These strategies must be undertaken by electronics manufacturers (e.g., Acer, Advanced Micro Devices, Apple, Dell, AU Optronics, Hewlett Packard, Hon Hai [Foxconn], HTC, Intel, Lenovo, LG, Samsung, Taiwan Semiconductor Manufacturing Company, Young Fast Optoelectronics) and overseen by relevant government agencies in the affected countries, as well as the industry’s trade associations (e.g., Consumer Electronics Association, IPC-Association Connecting Electronics Industries, SEMI, Semiconductor Industry Association, Telecommunications Industry Association).

Right-to-know is a key chemical safety principle.[46] Workers have a need and right to know about the identities and hazards of chemicals they are exposed to when working.[47] Community residents have a right to know about chemicals they may be exposed to from manufacturing facilities, water, food, products, and wastes.[48] There is broad recognition in the public health community that the effectiveness of environmental and occupational safety protections depends on open access to information and opportunities for meaningful participation of community residents and workers in decision making.[49]

The most effective point at which to address the use of hazardous chemicals in manufacturing electronic products is in the design and material selection phases. This prevention through design approach includes identifying hazardous chemicals in processes and products, implementing programs to identify alternatives, and selecting safer chemical and nonchemical alternatives.[50,51] Resistance to these measures is usually stated in terms of cost, but if the true cost is calculated, failure to address these issues results in a detrimental status quo or regrettable substitution with substances that turn out to be toxic. An example of how this approach works in practice is in the state of Massachusetts, where, in collaboration with the Toxics Use Reduction Institute, companies have reduced toxic chemical use by 40%, chemical by-products by 71%, and onsite releases of toxic chemicals by 91%.[52] 

In September 2012, more than 120 governments, UN agencies, and representatives of the private sector and public interest nongovernmental organizations (NGOs) ratified a pair of consensus decisions on hazardous chemicals in the life cycle of electrical and electronic products at the Third International Conference on Chemicals Management convened by the United Nations Environment Programme and the World Health Organization.[53] Delegates agreed to develop a set of best practice resources on electronics, including tools that reduce and eliminate the use of hazardous chemicals and practices for tracking and disclosing the presence of hazardous chemicals in electronics manufacturing and other parts of the life cycle. Delegates also added measures to address hazardous chemicals in the electronics life cycle to the Global Plan of Action of the Strategic Approach to International Chemicals Management. Measures for action on electronics manufacturing include compiling lists of chemicals of concern, implementing green design, and developing policy instruments that support hazardous chemical reduction, elimination, and substitution.

Finally, health surveillance is recommended by WHO and ILO as a key part of public health prevention. Effective surveillance related to the work environment includes data collection on injuries, illnesses, hazards, and exposures, followed by analysis and dissemination within a comprehensive occupational health program.[54,55] Moreover, workers must be given access to exposure monitoring protocols and results and to medical records prepared and/or maintained by the manufacturers or their contractors. Such rights are consistent with those assured by government agency legislation such as the US Occupational Safety and Health Administration’s Employee Access to Medical and Exposure Records (29 CFR 1910.1020) and the United Kingdom’s Access to Medical Reports Act of 1988. 

Opposing Arguments/Evidence 

Electronics industry executives assert that clean rooms for chip manufacturing are thousands of times more sanitary than any hospital operating room.[56] US companies that operate contract supply chains declare that suppliers provide safe working conditions and use environmentally responsible manufacturing processes.[1] Contract electronics manufacturers in other countries insist that companies provide a “positive working environment.”[57] Companies assert that worker safety is assured and that rigorous management systems are in place to ensure that workers are not exposed to carcinogens, radiation, or other harmful substances.[58] The evidence cited above contradicts this viewpoint.

Action Steps

Therefore, APHA recommends the following:

• The National Institute for Occupational Safety and Health (NIOSH) and other research organizations should direct attention and resources toward studies that will provide more quantitative data to improve knowledge and understanding about the true scope of this problem, as well as primary, secondary, and tertiary prevention strategies for individual workers, family members, and the community at large. 

• NIOSH and other research organizations should conduct further research into the health risks for women and children working in the electronics industry.

• The public health community should promote and disseminate independent research on the risks associated with the electronics industry.

• Manufacturers of electronics should provide workers and surrounding communities with information on their use and release of chemicals and other potential sources of exposures, consistent with the fundamental public health principle of right-to-know. 

• Manufacturers of electronics should provide workers with access to exposure monitoring protocols and results, as well as medical records prepared and/or maintained by the manufacturers or their contractors.

• Manufacturers of electronics and local governments should adhere to ILO Conventions 138 and 182 on the minimum age and appropriate working conditions for youth employment.

• Government agencies in electronics-producing countries should promote the formation of expert advisory panels whose members represent a diversity of policy perspectives (i.e., industry, health care professionals, trade unions, workers, health-affected groups, public interest NGOs, and other relevant stakeholders), and there should be procedures for members to disclose and avoid potential financial conflicts of interest and recuse themselves if conflicts of interest exist.

• WHO should collaborate with relevant government agencies from electronics-producing countries to formulate, promote, and implement precautionary, health-based exposure limits for chemicals used in the manufacture of electronic products that are protective of the most vulnerable exposed populations, including children and pregnant and lactating women.

• Health professionals, regulators, and manufacturers should include women in their reproductive years, lactating women, and children in the category of vulnerable populations in terms of exposure to hazardous or harmful materials used in the electronics industry.

• Manufacturers of electronics should reduce the use of toxic substances by implementing designs to eliminate or substitute the most hazardous compounds and production processes with safer chemical and nonchemical alternatives that reduce the potential for harm to human health and the environment. 

• Manufacturers of electronics should ensure that subcontractors have the capacity to protect workers and the surrounding communities before transferring technologies and manufacturing processes to them and continue to monitor subcontractors during manufacturing to ensure protection of worker and community health.

• WHO and ILO should intensify coordination with ministries of health and labor in electronics-producing countries, as well as worker representatives, to conduct health surveillance among workers employed in and residents living near electronics-producing facilities.

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