Electronics Industry

Midstream Recommendations from UN SAICM Meeting in Vienna

International Workshop on Hazardous Substances

Within the Life Cycle of Electronic and Electrical Products

March 30, 2011

 

Aware that the manufacture of electrical and electronic products has increased dramatically over the past several decades and that there are now billions of electronic and electrical products produced and consumed throughout the world; [1]

 

Recognizing that the manufacture of electrical and electronic products relies on and uses thousands of chemicals and other materials, many of which are hazardous;

Aware that hazardous substances contained in consumer electrical and electronic products can include phthalates, metals such as chromium, lead, and mercury, and persistent organic pollutants such as certain flame retardants, as well as other carcinogens, mutagens, reproductive and developmental toxins and endocrine disrupting compounds;[2]

 

Recalling the need for transparency with respect to information on hazardous substances throughout the entire life cycle, and in particular those contained in electrical and electronic equipment and products as well as in the workplace and communities around extraction, production and disposal sites; [3][4]

 

Aware that the manufacture of electronic products can pose severe negative impacts on health of workers and communities as well as the environment where these products are made and disposed of1;

 

Recalling the need to protect workers and community health all throughout the life-cycle of electrical and electronic products from extraction through materials processing to component manufacture to assembly to recycling and disposal34;

 

Aware that there is a lack of capacity to properly address and to provide adequate protection from the hazards of electronics production in an environmentally sound manner in many countries leading to the exposure to hazardous substances causing harm to human health and the environment; [5]

 

Recognizing the pressing need for the continued development of clean technology7;

 

Recalling that it is important to consider product stewardship and extended producer responsibility aspects in the life-cycle management of electronic and electrical products7;

Recognizing important provisions with regards to workers in the Universal Declaration of Human Rights[6]and International Labor Organization Convention 98 - Adopted by the International Labour Conference at its Eighty-sixth Session, Geneva, 18 June 1998 (Annex revised 15 June 2010);

Recognizing UNEP guidelines for the development of domestic legislation on liability, response action and compensation for damage caused by activities dangerous to the environment, including any adverse or negative effect or impact on human health;[7]

 

Recognizing the work of the International Conference on Chemicals Management at its Second Meeting and subsequent SAICM Regional Meetings held in 2009 – 2010; 

www.saicm.org

The Participants of the International Workshop on Hazardous Substances Within the Life Cycle of Electronic and Electrical Products hereby recommends to the SAICM Open-ended Working Group and the International Conference on Chemicals Management at its third meeting (ICCM3) that:

Environmentally sound manufacturing and capacity building

1)    Governments, intergovernmental organizations, and non-governmental organizations including the private sector and others should encourage and promote sustainable production and pollution prevention by using cleaner production techniques, waste minimization, and safer substitutes whenever available;

SAICM Global Plan of Action Item 43, 118

 

2)    The producers and manufacturers should prioritize reduction of exposure to chemicals, primarily by elimination or substitution of the most hazardous substances and production processes, especially those processes involving worker and community exposure to substances of concern. In the present context, substances of concern include those that are persistent, bioaccumulative and toxic and/or those that are carcinogens, mutagens, reproductive or developmental toxins, neurotoxins, neurodevelopmental toxins, respiratory toxins, immuno toxins, organ system toxins,and/or endocrine disrupting compounds. ; 

SAICM Global Plan of Action 190

 

3)    Specific protection and prevention measures[8]:

1. The employer should ensure that the risk from a hazardous chemical agent to the safety and health of workers at work is eliminated or reduced to a minimum.

2. In applying paragraph 1, substitution should by preference be undertaken, whereby the employer should avoid the use of a hazardous chemical agent by replacing it with a chemical agent or process which, under its condition of use, is not hazardous or less hazardous to workers' safety and health, as the case may be.

3. Where the nature of the activity does not permit risk to be eliminated by substitution, the employer should ensure that the risk is reduced to a minimum by application of protection and prevention measures. These will include, in order of priority:

(a) design of appropriate work processes and engineering controls and use of adequate equipment and materials, so as to avoid or minimise the release of hazardous chemical agents which may present a risk to workers' safety and health at the place of work;

(b) application of collective protection measures at the source of the risk, such as adequate ventilation and appropriate organizational measures;

(c) where exposure cannot be prevented by other means, application of individual protection measures including personal protective equipment.

 

4)    The producers and manufacturers and chemical suppliers should conduct ongoing assessments of chemicals and materials used in products to implement green design and select safer substitutes.

·       A safer substitute is an alternative that reduces the potential for harm to human health or the environment

Stockholm Convention Alternatives Guidance

·       When reducing the use of substances of concern, select substitutes that are inherently safer than the substances they replace. Substitutes include safer chemicals, materials and products as well as eliminating the need for the chemical in the first place.

Stockholm Convention Alternatives Guidance

·       Create a list of preferred substitutes -- those that are inherently safer than chemicals of concern -- for electronic and electrical products.

Electronics case study; UNEP Chemicals in Products Project

·       Chemical substitutes should not have hazardous properties such as very persistent and very bioaccumulative (vPvB), persistent, bioaccumulative and toxic (PBT), carcinogen, mutagen, reproductive or developmental toxicant, neurotoxicant, or endocrine disruptor

Stockholm Convention Alternatives Guidance

 

5)    Producers and manufacturers should inventory all materials and chemical substances used throughout the life cycle (including conflict minerals and rare earth minerals), disclose  these substances and share this information publicly and throughout the supply chain;

Electronics case study; UNEP Chemicals in Products Project

 

6)    Producers and manufacturers should phase out the use of substances of concern in their production when there are safer alternatives available;

 

7)    Producers, and manufacturers and chemical suppliers  should provide funding for robust, independent and transparent research to develop safer substitutes and safer production processes;

SAICM Global Plan of Action Item 84, 118, 162

 

8)    Environmentally unsound technologies and products that are prohibited or cause severe environmental degradation or are found to be harmful to human health should not be transferred to other countries[9];

Rio Principle 14

 

9)    If companies transfer technologies and products to subcontractors they should be environmentally sound and the companies should ensure that the subcontractors have the capacity to protect workers and the surrounding communities before making the transfer.

 

10)Environmentally sound technologies and their technical transfer should be promoted by relevant intergovernmental, governmental, academic and non-governmental organizations and the private sector. The Cleaner Production Centres should play a guiding role in this process.

 

11)Pollution prevention should be adopted in policies, management practices, programmes, and activities of governments as well as producers and manufacturers, taking into consideration the whole life cycle of the chemicals used in the production of electronic equipment;

SAICM Global Plan of Action Item 45

Information

 

12)Information on health and safety  for  humans and the environment for  the substances used in manufacturing of electronic and electrical products and present in products should not be considered confidential;

Stockholm Convention; Article 9 paragraph 5

 

13)Producers and manufacturers should provide ongoing understandable and free health and safety information to workers which is sufficient to protect safety and health; governments have the role to enforce provision of health and safety information to workers.

SAICM Global Plan of Action Item 140, 147

 

14)Producers and manufacturers should provide to consumers easily understandable information on substances of concern in EEE as well as information about their sound disposal.

 

15)Producers and manufacturers should cooperate with government, non-governmental organizations, trade unions, health care providers, and others to provide ongoing training to workers, community representatives and first responders to provide early warning systems about the inherent hazards of the materials being used, detailed information about best practices for protection from and reduction of exposure to those hazards, how to recognize early signs of adverse health impacts,  and prevention of exposure to all hazards

SAICM Global Plan of Action Item 89, 255

 

16)Governments, intergovernmental organizations, and non-governmental organizations including the producers and manufacturers and others should promote full transparency with respect to information on hazardous substances found throughout the lifecycle of electronic and electrical products, including those used in production, those contained in electrical and electronic equipment, those found in the workplace and communities, as well as those found around recycling,  waste and disposal sites, including smelters[10][11];

 

17)  Governments should formulate, promote, and implement policies requiring the public disclosure of the identity of chemicals and materials used in production and manufacturing of electronic and electrical products, those released during production, as well as those that end up in products;this disclosure should include health and safety information about the hazard traits and exposure traits of such chemicals and materials10.

Electronics case study; UNEP Chemicals in Products Project

 

18) Governments, intergovernmental organizations, and non-governmental organizations including the producers and manufacturers and others should formulate, promote, and implement legislative as well as voluntary initiatives to adopt and implement Pollutant Release and Transfer Registries (PRTR).  Governments that have not yet ratified the Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters are encouraged to do so.

SAICM Global Plan of Action Item 124, 125

 

Exposure and monitoring

 

19)Governments should formulate, promote, and implement health-based exposure limits for workers. These exposure limits are to be based on thorough and adequate hazard testing of all chemicals and mixtures used and produced throughout the life cycle. Producers, manufacturers and suppliers of chemicals are responsible for performing these tests. Exposure limit values should be protective of the most vulnerable populations, and should provide equal protection in the workplace and the community; In cases where data are not yet sufficient to develop a health-based exposure limit value, the precautionary principle should be applied, namely by eliminating exposure to chemicals or reducing it  as low as possible.

SAICM Dubai Declaration “We recognize the need to make special efforts to protect those groups in society that are particularly vulnerable to risks from hazardous chemicals or are highly exposed to them;”

 

20)Producers and manufacturers, with oversight by the government and the full participation of worker and community representatives should ensure (and report the results to appropriate governmental authorities of):

a.      comprehensive, occupationally relevant  health surveillance for all of its workers;  

b.     comprehensive ongoing industrial hygiene and environmental monitoring to measure the release and exposure to all hazardous materials used in manufacturing and production;

c.     access to these data (and adequate funding) to ensure comprehensive and independent epidemiological assessments of worker health;

d.     Action plans to preserve and protect worker health based on these data.

e.     In situations where pollution from electronics production facilities has been found in surrounding communities, the manufacturers and producers should cooperate with health researchers and investigators to assess and control adverse health impacts, especially with respect to vulnerable populations.

SAICM Global Plan of Action Item 66

 

21)Governmentsshould promote the establishment, continuous improvement of and adequate funding of national inspection and enforcement systems for the protection of workers from the adverse effects of chemicals and encourage cooperation between employers and workers (and their representatives) to maximize chemical safety and minimize workplace hazards;

SAICM Global Plan of Action Item 145

 

22) The producers and manufacturers[12], with oversight from government, should provide workers and surrounding communities with all occupational and environmental health monitoring protocols and records including the extent and duration of each person’s exposure, as well as health outcomes data, corporate health records, and other relevant records, while making sure to protect confidentiality  for each individual;

 

23)The producers and manufacturers should ensure protection of individual confidentiality for monitoring and exposure data;

 

Health surveillance and disease prevention

24)The ILO in collaboration with World Health Organization and Governments are invited to   provide financial and technical resources  for a) occupational health training of healthcare providers  b) for better recognition and treatment of diseases associated with the electronics industry and c) tracking of diseases associated with substances used in the electronics industry

 

25)National governments are invited to collaborate with ILO to collect and report worker health information specific to the electronics industry. EEE companies, trade unions and other actors should be encouraged to contribute to this process.

 

26)The ILO in collaboration with World Health Organization are invited to develop coordinated d systems for record keeping, tracking, and reporting for disease relative to occupation in the electronics industry. Countries should be encouraged to ratify the ILO convention 155 regarding  Occupational Safety and Health

 

27)The ILO in collaboration with World Health Organization are invited to intensify coordination with Ministries of Health and Labor in identifying, examining, and reporting patterns of disease associated with work in electronics industries;

ICCM2 II/8: Health aspects of the sound management of chemicals

 

Work environment

 

28)Governments should guarantee that workers have the right to collectively bargain as a fundamental human right, guaranteed by the Universal Declaration of Human rights (adopted in 1948 by the United Nations; the right to bargain collectively is subsumed under the rights to freedom of association and the right to organize into a trade union --see Articles 20 and 23). The right to organize and bargain collectively is explicitly covered under International Labor Organization Convention 98 adopted in 1949. Pursuant to these rights, all workers involved in each stage of the life cycle of electronics production should have the right to:

·       form unions and toorganize for self-protection;

·       to form health and safety committees;

·       to receive training to develop the capacity to monitor and enforce effective  health and safety  protections in the workplace;

·       to refuse unsafe or unhealthy work; and the right to be protected from retaliation for exercising those rights (right-to-act and “whistle-blower” protection)[13];

SAICM Global Plan of Action Item 149

 

29)Governments, producers and manufacturers with the full participation of workers and their representatives should enhance and implement ILO safe work standards and ILO guidelines on occupational safety and health, with special care for vulnerable or precarious workers, including women and migrants;

SAICM Global Plan of Action Item 14

 

30)The producers and manufacturers are encouraged to develop frameworks to promote the active and meaningful participation of all stakeholders in the sound management of chemicals and wastes, including community representatives, non‑governmental organizations, managers, workers, and trade unions;

SAICM Global Plan of Action Item 164

 

31)The producers and manufacturers should promote and implement a work environment which protects of workers and community health all throughout the life-cycle of electrical and electronic products from extraction through materials processing to manufacture to recycling and disposal; all hazard communication and training should be conducted in appropriate languages of the workers1112[14][15].

 

 

32)Governments are encouraged to develop and implement policies promoting the internalization of the costs (and discouraging the externalization of the costs)  to human health, society and the environment  throughout the life cycle of electronic and electrical products, including extraction, materials processing, production, assembly, recycling and disposal;

SAICM Global Plan of Action Item 182

 

33)  Governments are encouraged to develop and implement effective liability and compensation legislation for the victims of toxic exposures in the workplace and the community.  Given that the electronics industry is characterized by multiple chemical exposures to chemicals of concern, many of which are in addition inadequately  tested and regulated, and the frequent changes in process chemicals, it is particularly important to develop compensation systems funded by the employers that are designed to address these inherent challenges to fair compensation by developing mechanisms that assure that workers harmed by such exposure qualify  for adequate and timely compensation, as well as treatment and rehabilitation.http://www.unep.org/dec/PDF/chemicalfinancing/Proceedings_K1060433_final%2011SSGCGMEF.pdfnote finalized in 2011 GMEF/GC = UNEP Governing Council / Global Ministers of Environment Forum

 

 

 

[1]SAICM/ICCM.2/INF/36 Background information in relation to the emerging policy issue of electronic waste

[1]Recommendations on hazardous substances within the lifecycle of electrical and electronic products by participants in the African regional meeting on implementation of the Strategic Approach to International Chemicals Management, Abidjan, Côte d’Ivoire, 25- 29 January 2010

[2]SAICM/ICCM.2/INF/36 Background information in relation to the emerging policy issue of electronic waste

[3]Recommendations on hazardous substances within the lifecycle of electrical and electronic products by participants in the African regional meeting on implementation of the Strategic Approach to International Chemicals Management, Abidjan, Côte d’Ivoire, 25- 29 January 2010

http://www.saicm.org/documents/meeting/afreg/Abidjan%202010/Advance%20report%20of%20the%203rd%20African%20reg%20mtg%20on%20SAICM_April%2025%202010.pdf

[4] Latin America and the Caribbean: Hazardous substances within the life cycle of electrical and electronic products

http://www.saicm.org/documents/meeting/grulac/Jamaica%202010/LAC%20report-%20final%20clean.pdf

[5]Resolution II/4 on emerging policy issues adopted by the International Conference on Chemicals

Management at its second session, held in Geneva, Switzerland, 11 to 15 May 2009

[6] (http://www.un.org/en/documents/udhr/index.shtml

[7]http://www.unep.org/dec/PDF/chemicalfinancing/Proceedings_K1060433_final%2011SSGCGMEF.pdf;note finalized in 2011 GMEF/GC = UNEP Governing Council / Global Ministers of Environment Forum

[8][Source: EU-Directive 98/24/EC on on the protection of the health and safety of workers from the risks related to chemical agents at work]

 

[9]Asia-Pacific Recommendations on hazardous substances within the life cycle of electrical and electronic productshttp://www.saicm.org/documents/meeting/asiapacific/Beijing%202009/Meeting%20docs/FINAL%20REPORT%20-%20Asia-Pacific%20regional%20meeting%20report.pdf

 

[10]Recommendations on hazardous substances within the lifecycle of electrical and electronic products by participants in the African regional meeting on implementation of the Strategic Approach to International Chemicals Management, Abidjan, Côte d’Ivoire, 25- 29 January 2010

http://www.saicm.org/documents/meeting/afreg/Abidjan%202010/Advance%20report%20of%20the%203rd%20African%20reg%20mtg%20on%20SAICM_April%2025%202010.pdf

[11]Latin America and the Caribbean: Hazardous substances within the life cycle of electrical and electronic products http://www.saicm.org/documents/meeting/grulac/Jamaica%202010/LAC%20repor...

[12]In those situations when there are industrial parks and entities with similar management structures, the same provisions should apply to such entities

[13]http://www.ilo.org/declaration/lang--en/index.htm for the full range of ILO protections

[14]Asia-Pacific Recommendations on hazardous substances within the life cycle of electrical and electronic productshttp://www.saicm.org/documents/meeting/asiapacific/Beijing%202009/Meeting%20docs/FINAL%20REPORT%20-%20Asia-Pacific%20regional%20meeting%20report.pdf

[15]Central and Eastern Europe region Recommendations on hazardous substances within the life cycle of electrical and electronic productshttp://www.saicm.org/documents/meeting/cee/Lodz%20Dec%2009/SAICM%20CEE3_final%20report.pdf