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Chemical Roulette

Published: 18th Nov 2013 in OSA Magazine

Chemical safety management issues in contract manufacturing

Many large global brands exclusively operate on a contract manufacturing basis. In contract manufacturing, one company – a well-known global brand, for example – hires another company to produce products, parts or other materials on behalf of their client.

As a result, the contracting company, or brand, does not own or maintain manufacturing facilities, purchase raw materials, or directly hire labour. Over the last decade, the manufacturing base has expanded greatly in the Asia Pacific region due to this type of contract manufacturing.

The clothes you are currently wearing may have the name of a global brand printed on them, but they are actually being manufactured by a company you have probably never heard of before. 

Making it even more complicated is that the second company is probably buying parts or raw materials from another manufacturer. The supply chain, in most cases, is long and complex and the health and safety issues along this chain are similarly complex and varied.

Contract manufacturers often seek what is known as the ‘iron triangle’ of the lowest price/the highest quality/the fastest delivery. This results in expansion into countries with a potentially poor record of health and safety regulation, poor enforcement, or rampant corruption.

This model often obscures the perception of certain consumers of the potential human costs associated with production of their favourite products as consumers put their trust in the brand name company rather than the actual manufacturer. Consumers in the United States or Europe who don’t understand this model may not be able to visualise the potential risks faced by the workers who are actually tasked with assembling, sewing, or otherwise producing the products we are so accustomed to purchasing. 

Contracting companies often do conduct assessments or audits of their supplier factories. These assessments may indicate serious issues related to chemical safety, including the lack of appropriate hazard communications, no consideration for the hierarchy of controls, and the extensive misunderstanding of the principles and limitations of personal protective equipment (PPE), especially respiratory protection. 

Lack of HAZCOM programmes

Hazard Communication, or HAZCOM, is a foundation of workplace protection regulations in many countries. In the absence of appropriate HAZCOM programmes, sound management of chemicals will likely not occur, resulting in potential worker risks.

HAZCOM standards are designed as a way to modify the behaviour of both employees and employers by providing information about chemical hazards in a structured way. Given proper information and warnings regarding chemical hazards, workers are more likely to make appropriate decisions.

Generally, HAZCOM programmes include three main components:
• Labels
• Safety Data Sheets
• Employee training

Although certainly not limited to contract manufacturers, our experience has indicated severe and overly common issues with all three components within the contract manufacturing supply chain.

Review of Safety Data Sheets (SDS) during Environmental, Health and Safety (EHS) audits and other assessments indicate a disturbing lack of completeness, accuracy, and consistency with international standards. Similarly, chemical package and secondary container labels are lacking in detail regarding the contents and associated hazards of the chemicals therein. 

From the very beginning, the workers are at a disadvantage and are not provided the tools required to make decisions and perform their work in a way that is protective of their health.

Effective training – if any training is provided at all – is also elusive. Although workers may have actually physically attended a training course, when asked about the properties and hazards of a particular chemical solution, employees are often unable to provide a clear answer.

So, what should these suppliers and factories do to improve HAZCOM? Many countries, including most notably China in the Asia region, have completed or are in the process of completing phase one of the Globally Harmonized System of Classification and Labeling of Chemicals, or GHS, through the passage of regulation. 

This internationally agreed upon system of classification and labelling of hazardous chemicals was designed to replace the various labelling systems found throughout the regions of the world with a single and consistent system. The principles of GHS, including easy to understand pictograms and other labelling components, can easily be implemented at the factory level.

Most important is providing effective training for employees who will potentially be exposed to hazardous chemicals. The decisions they make will have a direct impact on their exposure. As noted above, training is a common weakness in contract manufacturers, as turnover in factories in some Asian regions can be extremely high and the number of workers in a single factory –some factories in China have hundreds of thousands of workers – can be overwhelming to the staff in charge of training. 

It is important to have an open and clear communication system regarding the management of chemicals in the workplace.

Information should be accessible to workers/management and be easy to understand. The keys to effective communication are:
• Information must be easily accessed
• Information must be easy to understand
• Information must be consistent
• Information must be regularly refreshed

Application of hierarchy of controls

Professionals in occupational hygiene and safety should understand the application of the hierarchy of controls. This hierarchy is widely accepted and represents standard practise in all industries. For any hazard that requires control, management should start at the top of the hierarchy and only move to the next level if the current level is not feasible or possible.

Each step down the ladder represents a loss of effectiveness and reliability due to an increase in potential for failure. Each step down therefore represents a higher potential risk.

The hierarchy of hazard controls are, in order of decreasing effectiveness:
1. Elimination – Physically removing the hazard
2. Substitution – Replacement with something that reduces or does not produce hazard
3. Engineering – Isolate workers from hazard or removal/reduction of hazard by engineered control, e.g. exhaust ventilation
4. Administration – Change way people work, e.g. training, warning labels
5. Personal protective equipment (PPE) – Equipment worn by a person to reduce hazard

Unfortunately, experience in contract manufacturer factories indicates a poor understanding of this hierarchy. Most manufacturers do not systematically move through the various levels.

Failure to follow this well accepted standard puts workers at risk.

Improper PPE used as primary control

As noted above, other controls are often eschewed in favour of jumping straight to the use of PPE. There are many reasons why PPE is considered the least desirable method of control, which include the following:
• The hazard is not eliminated or changed
• If the equipment is inadequate or fails, the worker is not protected
• No personal protective equipment is fool-proof; for example, respirators leak
• Personal protective equipment is often uncomfortable and can place an additional physical burden on a worker
• PPE places the burden of control directly on the worker, which requires a modification of behaviour. Behaviour modification is resource intensive (e.g. training and enforcement) and often unsuccessful, especially in an unstable, high turnover workforce

Despite the issues, in the view of some manufacturers, buying and handing out PPE – sometimes only to be used in the presence of auditors and assessors – is cheaper than investing in engineering systems, and easier than researching and investing in new products or processes that may remove or reduce the exposure risk. 

This is compounded by the lack of occupational health surveillance systems in most of the factories. Without a surveillance system of some kind, most workers disappear from the factory for various reasons, and responsibility for any chronic issues due to chemical exposures are unrealised. 

The wearing of surgical-type face masks is extremely common in Asia. So much so that in some places such as Japan, several articles have been written about the cultural significance. Unfortunately, it is also common to see these face masks being utilised in factory settings as a primary control of dust and chemical exposures. 

Most occupational health and safety professionals understand that face masks are not designed to protect the wearer and should not be considered respirators – they were originally designed to catch the bacteria and other droplets shed from the wearer’s mouth and nose. Though not specifically studied in the manufacturing setting, the level of protection of face masks has been studied, and as expected, the masks generally provide little or no protection to the wearer. 

Similarly, the use of insufficient or inappropriate gloves is quite common. Examples include the use of cotton gloves for work with chemicals, or thin latex gloves, which are commonly used for medical examinations, may be used against chemicals that will quickly permeate the glove material.

It is unclear how this mis-use became so prevalent, but we suspect that the gaps in knowledge regarding the principles of respiratory protection such as protection factors, or proper fit testing, and the principle of glove selection such as permeation rate, or degradation rate, were filled by applying a more simple equation: Use chemicals = need mask and gloves. 

Personnel without proper occupational hygiene and safety training both internally and externally, or government regulators or auditors hired by contracting brands, may not have the specific knowledge to determine the proper application of PPE. In these cases, it’s much easier to make a gross oversimplification of the issue and apply the equation above. 

Additionally, there are often gaps in the procurement of PPE as factory purchasing staff who may be responsible for purchasing PPE often have little knowledge on proper selection and principles of PPE use. This issue can often be perpetuated by PPE sales representatives who lack specific knowledge of the facility’s processes and chemical use, or proper PPE selection itself, causing them to provide misleading information and/or products. 

Selection of PPE is always specific and not general. In order to properly select PPE you must know the type of hazard, e.g. the chemical, and the level and duration of exposure.

PPE selection guidance published or endorsed by internationally recognised occupational health and safety agencies such as the National Institute for Occupational Health and Safety (NIOSH) in the United States, the Health and Safety Executive (HSE) in the UK, and the Occupational Health & Safety Council in Hong Kong may also be used as counsel for selecting appropriate PPE.

The future

Although the manufacturing base has shifted into the Asia region, there has not, to date, been a comparable growth of occupational hygienists and safety professionals in this region. Others have estimated a potential gap of more than 30,000 of these professionals based on the growth of the workforce, mostly in highly populated Asian countries like India and China. 

According to the International Labor Organization (ILO), 2.02 million people die each year from work-related diseases. This means that every 15 seconds, a worker dies from a work related accident or disease. 

A recent study, ‘Economic Burden of Occupational Injury and Illness in the United States’, estimated the economic costs of occupational injuries and illnesses to be roughly $250 billion a year in the USA. It is expected that similar or greater human life and financial impacts would be experienced in Asia. One estimate for China indicates that occupational illnesses and injuries are costing as much as 6% of GDP (Gross Domestic Product). It’s expected that these impacts would be overlooked in some less developed Asian countries.

The importance of bringing professional and institutional knowledge to these areas cannot be stressed enough. At each level of the contract manufacturing chain, there must be responsibility and accountability for the health and safety of every worker. This can only be accomplished by implementing appropriate HAZCOM programmess, proper application of the hierarchy of controls, and the proper selection and use of PPE when PPE is found to be necessary. 

Published: 18th Nov 2013 in OSA Magazine


Michael S Andrew

Michael S Andrew, MS, CIH, CSP, LEED AP 

Michael Andrew currently serves as the Technical Officer of Sumerra, an environmental health and safety (EHS) and corporate social responsibility (CSR) consulting company. Mr Andrew has extensive professional experience in occupational and environmental health and safety (OEHS). He has conducted hundreds of evaluations throughout Asia and worldwide to evaluate physical, biological and chemical hazards in both occupational and community environments.

Projects of interest include investigation of mass fainting episodes in apparel factories in Cambodia, providing EHS audits of contract manufacturers in China, and the evaluation of ozone exposure in a denim product factory in Vietnam. In addition to his work in OEHS, he has experience in conducting social, security, and sustainability assessments.

Mr Andrew has a Master of Science degree from the Environmental Engineering department of the Georgia Institute of Technology (Georgia Tech) and is both a Certified Industrial Hygienist (CIH) and a Certified Safety Professional (CSP).

His specialties include creation of health and safety plans, conducting environmental health and safety audits, designing and implementing exposure assessments, statistical interpretation of analytical data, HVAC and local exhaust system evaluations, assessment of indoor environmental quality issues, forensic assessments of contamination/damage, community and occupational noise, and assessments for regulatory compliance. Mr Andrew regularly provides training on occupational and environmental health and safety issues such as risk assessment and prioritisation, root cause analysis, proper chemical management and handling, personal protective equipment, conducting exposure assessments, and forensic assessments of contamination/damage. He has provided services and consulting in a diverse set of environments including ambient surroundings (outdoors), manufacturing facilities, healthcare establishments, office and institutional buildings, residential settings, construction sites, and schools and universities. 

Sumerra was created to meet the needs of Brands, Factories and Licensees who are striving to improve working conditions and reduce risks throughout the world. The foundation of Sumerra is the belief that every worker in every factory should be allowed to work in safe conditions and that the surrounding environment and communities should be kept clean and healthy. 

It is Sumerra’s goal to promote management that assures the fair treatment of workers, worker health and safety, and environmental stewardship through education, accountability and collaboration. We are defined by our commitment to knowledge, client relationships and sustainable performance improvement. Sumerra is currently working with some of the world’s most well known apparel brands to assure compliance with health and safety standards throughout the supply chain.Sumerra manages audits and assessments at contract manufacturers, creates assessment tools and provides training to factories and brands in support of these goals.

The author would also like to recognise the contributions of Joesph Dakin, Sumerra’s Asia Operations Director. Mr Dakin is an environmental health and safety consultant with extensive experience with contract manufacturers in the Asia region.

Michael S Andrew



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