On February 13, 2012, the Fair Labor Association, conducted an independent investigation of Apple's Foxconn factories. View their findings here. The "Appendix 1.1 SCI Findings Guanlan" were used for the FLA Compliance section of this application. Sustainable Compliance Assessments were conducted at the IDPBG Business Group of the Guanlan Factory (assembly of the iPhone and the iPod) from February 14 to February 17, 2012, at the IDSBG Business Unit of the Longhua factory (assembly of the iPad and the Mac) from March 5 to March 8, 2012, and at the SHZBG Business Unit of the Chengdu factory (manufacture of components and assembly of the iPad) from March 6 to March 9, 2012.
The FLA assessors gathered raw information and entered it into their SCI reporting tool, housed on the FLA IT platform. Aggregate score of performance by employment function and by management function are included in the "FLA Compliance" section of MIC. To obtain an "Average Score" for each device, the percentage compliance values across all functions were added, and then divided by their total number of functions. View more detailed information regarding the FLA report methodology.
Information regarding the components of the device, as well as its CO2 emissions, was obtained directly from Apple's website. View more details regarding this information.
The creators of MIC did not create any new data content nor are they in any way directly affiliated with the FLA or Apple. With the exception of links to other sources altogether, included within the "Additional Reports" section, all data is obtained from the sources noted above.
The goal of the MIC (Made in China) iPhone application is to connect those that own electronics more closely with the details of the production of these devices. This iPhone app is meant to provide a glimpse into the human and environmental capital that goes into making your device.
Created by Lauren Glasscock as part of an Independent Study project at Yale University School of Forestry and Environmental Studies.
73,004 workers
An average worker is a 23 year-old male, with a high school level of education, and who has migrated from another province. He earns around $455 dollars per month and works about 56 hours per week.
67% - Male
33% - Female
23.2 years - Average Age
1.86 - Average Years at Factory
3.6% - Young Workers (16 to <18 years)
95.6% - Migrant Workers
28.8% - Living in Dormitories
60.7% - Have High School or Vocational School Level of Education
28.7% - Have Middle School Level of Education
2,872 RMB ($455) - Average Monthly Salary
64.3%* of Workers Felt that this salary is not enough to cover basic needs
56.07 hours/week
45.7% of workers said that they completely disagreed that the Factory's canteen served good food
42.6% of workers said that they believed that the dorm was a little crowded
59% of workers said that after a full day of work they sometimes feel pain in some of their body parts
32% of workers have experienced or witnessed an accident in this factory
43.9% feel that their work is often stressful
1 Salary
2 Bonus and Allowances
3 Quality of Food in the Canteens
Glass 41g
Stainless steel 39g
Battery 25g
Circuit boards 16g
Display 7g
Other 6g
Plastic 3g
Paper (fiberboard, paperboard, paperfoam) 120g
Thermoformed polystyrene 11g
Other plastics 2g
65% - Production
26% - Customer Use
7% - Transport
2% - Recycling
Sustainable Improvement Needed
Factory requires workers –except short term workers and interns – to sign a three year contract that provides for an extended probation period of 6 months. However, in the FLA benchmarks, the probation period limit is 3 months.
No specific policy and/or procedures related to some special categories of workers were available, e.g., short term workers and interns. This issue was resolved in the following week.
FLA Workplace Code (Employment Relationship Benchmark ER.7; and Compensation Benchmark C.3).
Sustainable Improvement Needed
During the review of job descriptions it was observed that there is an age requirement (older than 24 years of age) for the Recruitment Interviewer position.
Several inconsistencies were observed between business group- and factory-level policies and procedures dealing with Recruitment and Hiring that could potentially discriminate against protected classes of workers.
Although there have been many changes implemented recently with respect to technical staff recruitment at the group-level, related procedure has not been reviewed and updated since February 22, 2008. Similarly, the terms of workers' grades have been changed in practice, but the policy has not been updated accordingly.
Assessors observed quality issues with job descriptions in workers' files (e.g., job description of the new Learning and Development supervisor was not available in the files).
FLA Workplace Code (Nondiscrimination Benchmark ND.2; Employment Relationship ER.1)
Immediate Action Required
90% of the workers interviewed mentioned that training and testing for working skills improvement performed after regular working hours is not treated as working hours and not compensated accordingly.
Most of the workers are asked to attend morning meetings, which take place about 10 minutes before the official start time. This is not official policy but common practice in many sections. That meeting time is not treated as time worked and is not being compensated accordingly.
Almost 10% of the workers interviewed did not properly understand the wage structure.
Management to ensure full payment of all hours of work including meetings before and after regular working hours.
China Labor Law, Article 44, and FLA Workplace Code (Employment Relationship Benchmark ER. 28 and Compensation Benchmarks C.5 and C.17; and Hours of Work Benchmark HOW.1)
Sustainable Improvement Needed
Although factory provides pension, medical and work-related injury insurance to all workers, only local workers (approximately 1% of the total workforce) are covered under unemployment and maternity insurance. In practice, however, the Shenzhen Social Security system allows all female workers to register once they become pregnant and to receive maternity benefits without prior registration. http://www.szsi.gov.cn/sbjxxgk/zcfggfxwj/zctw/200810/t20081008_729.htm
During the assessment there were 58 interns in the factory; all of them were being provided with medical and work-related accident insurance, but not covered under unemployment, pension and maternity insurance. There are no clear guidelines about social security benefits for interns and an official statement by the Social Security Bureau indicates that employers do not have to provide social security benefit to interns as they are governed under the Guangdong Internship Regulations. http://www.szsi.gov.cn/bwbd/jjzs/qycbyw/201102/t20110217_3763.htm
There are two types of interns: vocational school and college interns. There is a three-party agreement between the vocational schools, students and Foxconn that governs interns' tenure at Foxconn. The agreement stipulates that the students live in the dormitories. Even if they later decide not to live in the dormitories, dormitory charges are still deducted from their wages. This practice is consistent with the employment agreement that vocational interns sign when they start working at the factory.
China Labor Law, Article 73; and FLA Workplace Code (Compensation Benchmarks C.1 and C.5, Forced Labor
Immediate Action Required
Interns are allowed to work overtime regularly without any restriction, therefore exceeding the 40 hours per week limit.
Factory Management will stop the practice of allowing interns to work overtime hours and will not exceed 40 hours per week.
Guangdong Province Internship Regulation, Article 22.5; FLA Workplace Code (Employment Relationship Benchmarks ER.1 and ER.13)
Sustainable Improvement Needed
Factory's hours of work policy and related procedures set the maximum weekly combined working hours (regular hours plus overtime) at 60 hours per week. This meets Apple and FLA code standards but violates local law which limits regular weekly hours to 40 hours per week and overtime hours to 36 hours per month (an average of nine hours per week).
During the period between February 2011 and January 2012, most of the workers worked overtime beyond the legal limit of 36 hours per month: 20% of the total workforce exceeded this limit in July and August 2011, while for the remainder of the period almost 80% of the total workforce exceeded the legal limit.
Most of the workers worked 60 hours per week (regular hours plus overtime) in recent months, but this was not the case in peak season: For example, 7% of the workforce worked more than 60 and up to 70 hours per week on average during October-December 2011.
7% of the workforce did not receive the required 24 consecutive hours of rest in a seven-day period during the peak season (October-December 2011).
According to the factory's written hours of work procedures, workers are to be provided with a 10-15 minute ergonomic break after every two consecutive hours of work; this procedure is not implemented consistently and many workers do not receive it.
China Labor Law, Articles 38 & 41; and FLA Workplace Code (Hours of Work Benchmarks HOW.1 and HOW.2)
Sustainable Improvement Needed
Despite the presence of a Business Group labor union in the factory (with approximately 70% of the workforce registered as members), 40% of interviewed workers were unaware the union represented them.
Nearly all union committee members are managerial staff (40 of the union committee are either managers or supervisors, and only two representatives are workers, who were nominated by management). The Chairman of local union is the factory's Human Resources Manager and the vice chairman is the Employment Relations supervisor.
Copy of current Collective Bargaining Agreement has not been provided to the workers, per FLA BenchmarkER.16.
FLA Workplace Code (Freedom of Association Benchmarks FOA.2, FOA.10, and FOA.11, Employment Relationship Benchmark ER.16 and ER.26). Trade Union Act (2001); Shenzhen Municipal Implementing Regulations for the Trade Union Law of the People's Republic of China
Sustainable Improvement Needed
Article 113-64 of the work rules in the worker handbook stipulates that workers would be fired in case of any involvement in an illegal strike. Although this provision has not been applied and there have been cases of dismissal owing to this article, it should be removed as it not in compliance with the FLA benchmark.
FLA Workplace Code (Employment Relationship Benchmark ER.26, Freedom of Association Benchmarks FOA.4, FOA.5 and FOA.22)
Immediate Action Required
It was observed that there is a practice of posting all disciplinary actions with names of the workers subjected to these disciplinary actions on the factory's website and notice boards.
Factory management should stop this practice and communicate its discontinuance to the workers
FLA Workplace Code (Harassment or Abuse Benchmark H/A.6)
Sustainable Improvement Needed
Although there are several ways to lodge grievances at this factory, including suggestion boxes (President's Suggestion Box, Communist Party Suggestion Box, General Manager's Suggestion Box, Trade union box, and Business Group Suggestion box), almost 20% of the workers interviewed mentioned that they do not know the factory's grievance and counseling procedures.
There is inconsistency in procedures regulating how to lodge a grievance. For example: the grievance procedures suggest grievances can be anonymous whereas article 140 of the worker handbook stipulates that the Company does not accept anonymous grievances.
Some workers are not comfortable using the grievance system because of fear of retribution and pressure from supervisors to quit if they lodge one or more complaints.
FLA Workplace Code (Employment Relationship Benchmark ER.25)
Sustainable Improvement Needed
There are no written policies or procedures governing retrenchment and resignation.
FLA Workplace Code (Employment Relationship Benchmarks ER.1, ER.19 and ER.32)
Sustainable Improvement Needed
General Health & Safety Policy does not cover protection of special categories of workers such as young (16 to 17 years of age)/elderly workers, pregnant/lactating workers, trainees/apprentices/interns and employees with disabilities.
No procedure for controlling thermal comfort conditions of the workers and protecting them from potential heat-related impact.
No Lock out-Tag Out (LOTO) procedure for protecting workers from hazardous equipment that might accidentally turn on and harm them.
List of machines that need guarding is missing.
No procedure for controlling working conditions and protecting workers from potential risk of falling when they work at heights.
Incomplete Material Safety Data Sheets (MSDS) of chemical substances in use that do not cover all necessary information about these chemicals such as ingredients and the full chemical composition.
No periodic control system for checking both health and safety and social conditions of contractors who work in the factory, such as in construction, maintenance, or waste handling.
Emergency action plans do not cover external parties, such as service providers or visitors.
FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE 11 and HSE.14; Employment
Sustainable Improvement Needed
Although there is an HSE committee in place, this committee is not active. There are no periodic meetings or internal audits conducted by this committee. Currently, the committee only holds meetings for some special cases.
There is no worker participation and integration on ongoing HSE efforts, as there are no elected worker representatives on HSE committee (all current members were selected by management).
Accident records only cover serious accidents (accidents with lost working time) but not all the accidents and near miss cases.
No system for keeping track of sickness and working day lost due to sickness.
Food Safety Law Article: 29; Trade Union Act; FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1 and HSE.3; Employment Relationship Benchmarks ER.25 and ER.31)
Sustainable Improvement Needed
Shower/eye washing station in chemical warehouse area is not in a good condition. Cap of the right eye washing part was missing and open valve is rusted.
Hearing protectors (ear plugs) not being used appropriately by workers, as many workers were not actually using them and others were not using them properly.
Although periodic working environment check results do not indicate any risk of potential dust and chemical exposure in assembly areas, all workers were told to use carbon layered paper masks during working hours.
No protective shoes provided to workers in warehouse areas, forklift and pallet truck traffic areas.
Forklift truck drivers are not using safety belts; also some forklift trucks are operating with worn out tires which affect safe brake distance.
Rear gear sound alarms of forklift trucks are missing or not operational; maximum safe load signs are also missing. No speed limiting systems installed in forklift trucks.
Maximum working pressure limits are not indicated on the manometers of pressure vessels (compressed air and pressurized water).
Color coding of pipes within the factory varies in different areas. While there is no legal requirement to do so, they are not in line with international standards such as British Standard 1701 on color for pipes (e.g., yellow color used for compressed air pipes) and could cause accidents.
Many workers working with chemicals (cleaning solvent and adhesives) use different type of gloves (finger gloves or half gloves); these gloves are providing enough protection against potential risk of skin absorption.
Production Safety Law, Article: 37; Prevention and Treatment of Occupational Diseases Law, Article 23; and FLA Workplace Code (Health, Safety, Environment Benchmarks HSE.1, HSE.6, HSE.7, HSE.8, and HSE.15; Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
No non-smoking warning signs placed near fuel station.
No protective barriers placed around fuel pumps to protect against potential truck or forklift crash.
In some areas, the selection of fire extinguishers is not suitable for the potential fire risks, such as CO2 type fire extinguisher in fuel station, which is not the best option for fuel oil fires considering the re-ignition risk.
No sprinkler protection at the fuel station area, except in the office area.
Emergency assembly areas are not marked and no signs for directing workers to these areas in case of an emergency
Emergency exits do not meet local law requirements in assembly production floors (total width of the emergency exits is 10 meters in these floors, while it should be 15 or 20 meters given the number of workers).
No fire extinguishers on forklift trucks
No fire detectors in wastewater treatment plant and in the following areas: office, control room, laboratory and compressor room.
Some flammable materials stored in logistic warehouse, which is located on the ground floor of dormitory building (C25), are posing a risk of fire; compressor room is located under the office building.
Annual fire drills for production and dormitory buildings were not conducted during all shifts and therefore some workers did not participate.
Fire drills are conducted once a year in production area instead of twice as required by local law.
Code of Design of Manufacturing Equipment Safety and Hygiene Article 6.1.6, Code of Design on Building Fire Protection and Prevention Article 3.7.5, Fire Prevention Regulation for Government Offices, Organizations and Enterprises Article: 40, FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.5, HSE.6, HSE.26, Employment Relationship Benchmarks ER.31)
Sustainable Improvement Needed
Despite the fact that chairs and stools are provided and most of the workers use them (around 95% of the total
workforce), instances of the following issues were observed:
- Chairs are not adjustable (both height and backrest)
- Chairs do not have proper backrest to support the lower back
- No removable armrests on chairs
- No back support provided on stools
- Both chairs and stools made of uncomfortable material (non-breathable/non-slippery material)
In many areas of assembly lines, workers are positioned very close to each other, which reduces their ergonomic comfort as there is not enough space provided for separating their usual and occasional work areas
Illumination levels are inconsistent, not sufficient in some areas, while other areas are over-illuminated.
Although, according to factory's written hours of work procedures, workers are to be provided with 15 minutes of ergonomic breaks after every two consecutive hours of work, this procedure is not always implemented.
Some workers use hand pallet trucks for moving heavy loads for long distances.
Number of toilets in assembly production floors is insufficient and below legal requirement. (There are 1,500 to 2,000 workers in each assembly floor and only 20 to 24 toilets.)
Some workers return to the production area after lunch break and sit at workstations or in hallways, rather than a rest area which is not provided by management
No ergonomic training provided to workers to increase their awareness and knowledge on ergonomic risks in the workplace.
Although there was an ergonomic study conducted and there is a report suggesting some possible improvements, the report does not contain detailed information about necessary improvements on workstations' design and job simplification. Problems observed include workers hunching or leaning in some operations, uncomfortable body postures, usage of pneumatic tools (which are a source of vibration/noise, etc.)
Health Standard for Design of Industrial Enterprises Articles: 6.4.4.1 & 6.4.4.2, FLA Workplace Code (Health, Safety; Environment Benchmarks HSE.1, HSE. 17, and HSE.20)
Immediate Action Required
Two out of three emergency exit doors from the TV room on the 2nd floor of outside male dormitory were locked.
All dormitories should be checked in order to make sure that all emergency exit doors are unlocked
Fire Prevention Law, Article 28; FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.5 and HSE.25)
Immediate Action Required
Food Hygiene Permits of the two food service providers in the factory expired in December 2011.
Food hygiene permits of the two food service providers should be renewed.
Food Safety Law Article: 29, FLA workplace Code (Health, Safety, and Environment Benchmarks HSE.1 and HSE.22)
Sustainable Improvement Needed
There is no active waste management system in the factory for the waste generated in dormitories and cafeterias; all waste goes to municipal landfill without any attempt to separate hazardous and recyclable waste (e.g., batteries, cooking oil,…etc.).
No separation of solid waste at the source; all solid waste goes to the waste collection area in a mixed form.
Prevention and Control of Environmental Pollution by Solid Wastes Article: 58, FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE 11; Employment Relationship Benchmark ER.31)
Immediate Action Required
Direct discharge connection to the factory's main discharge point over a storm water canal at the sludge car washing station
Practice should be halted. Wastewater from sludge car washing section should be directed to waste water treatment plan
Prevention and Control of Environmental Pollution by Solid Wastes Article: 58, FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE 11, and Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
No periodic control system in place to ensure that underground diesel tank is not leaking.
Remains of diesel fuel spill contamination around underground diesel tank probably caused by overflows during filling operations.
Regulation for Safety of Dangerous Chemicals Article: 16, FLA Workplace Code (Health, Safety, and Environment Benchmark HSE.1, Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
Emission permits for Kitchen-Generator-Ovens-Ventilation System (extractors) are missing.
Factory sends sludge of wastewater treatment plant to a landfill via a certified service provider; however, permit for usage of this landfill is missing.
Prevention and Control of Atmospheric Pollution Law, Article 12; FLA Workplace Code (Health, Safety, and Environment Benchmark HSE.1; Employment Relationship, ER.31)
66,680 workers
An average worker is a 23 year-old male, with a high school level of education, and who has migrated from another province. He earns around $426 dollars per month and works about 56 hours per week.
63% - Male
37% - Female
23.1 years - Average Age
1.66 - Average Years at Factory
4.1% - Young Workers (16 to <18 years)
94.8% - Migrant Workers
30.1% - Living in Dormitories
58.2% - Have High School or Vocational School Level of Education
31.2% - Have Middle School Level of Education
2,687 RMB ($426) - Average Monthly Salary
2,200 RMB ($348) - Minimum Wage in Shenzhen
64.3%* of Workers Felt that this salary is not enough to cover basic needs
56.07 hours/week
45.7% of workers said that they completely disagreed that the Factory's canteen served good food
42.6% of workers said that they believed that the dorm was a little crowded
64.9% of workers said that after a full day of work they sometimes feel pain in some of their body parts
35% of workers have experienced or witnessed an accident in this factory
43.9% feel that their work is often stressful
1 Salary
2 Bonus and Allowances
3 Quality of Food in the Canteens
Aluminum 717g
Battery 447g
Display 432g
Hard Drive and Optical Drive 232g
Circuit Boards 195g
Keyboard and Trackpad 145g
Other Metals 140g
Glass 131g
Other 100g
Paper (fiberboard, paperboard, paperfoam) 120g
Thermoformed polystyrene 11g
Other plastics 2g
62% - Production
27% - Customer Use
9% - Transport
2% - Recycling
Sustainable Improvement Needed
Factory requires workers –except short term workers and interns – to sign a three year contract that provides for an extended probation period of 6 months. However, in the FLA benchmarks, the probation period limit is 3 months.
FLA Workplace Code (Employment Relationship Benchmark ER.7; and Compensation Benchmark C.3).
Sustainable Improvement Needed
During the review of job descriptions it was observed that there is an age requirement (older than 24 years of age) for the Recruitment Interviewer position.
Several inconsistencies were observed between business group- and factory-level policies and procedures dealing with Recruitment and Hiring that could potentially discriminate against protected classes of workers.
Although there have been many changes implemented recently with respect to technical staff recruitment at the group-level, related procedure has not been reviewed and updated since February 22, 2008. Similarly, the terms of workers’ grades have been changed in practice, but the policy has not been updated accordingly.
FLA Workplace Code (Nondiscrimination Benchmark ND.2; Employment Relationship ER.1)
Immediate Action Required
5% of the workers interviewed mentioned that training and testing for working skills improvement performed after regular working hours is not treated as working hours and not compensated.
Most of the workers are asked to attend morning meetings, which take place about 10 minutes before the official start time. This is not official policy but common practice in many sections. That meeting time is not treated as time worked and is not being compensated accordingly.
In some instances the factory did not pay unscheduled overtime if it was in fractions of 30 minutes. For example, a worker punching out at 7:53pm would not be paid for 23 minutes, based on how the computer system is set up.
Management to ensure full payment of all hours of work including overtime (and fractions thereof), morning meetings and skills training after regular hours.
China Labor Law, Article 44, and FLA Workplace Code (Employment Relationship Benchmark ER. 28 and Compensation Benchmarks C.5 and C.17; and Hours of Work Benchmark HOW.1)
Sustainable Improvement Needed
Although factory provides pension, medical and work-related injury insurance to all workers, only local workers (approximately 1% of the total workforce) are covered under unemployment and maternity insurance. In practice, however, the Shenzhen Social Security system allows all female workers to register once they become pregnant and to receive maternity benefits without prior registration. http://www.szsi.gov.cn/sbjxxgk/zcfggfxwj/zctw/200810/t20081008_729.htm
During the assessment there were 126 interns in the factory; all of them were being provided with medical and work-related accident insurance, but not covered under unemployment, pension and maternity insurance. There are no clear guidelines about social security benefits for interns and an official statement by the Social Security Bureau indicates that employers do not have to provide social security benefit to interns as they are governed under the Guangdong Internship Regulations. http://www.szsi.gov.cn/bwbd/jjzs/qycbyw/201102/ t20110217_3763.htm
There are two types of interns: vocational school and college interns. There is a three-party agreement between the vocational schools, students and Foxconn that governs interns’ tenure at Foxconn. The agreement stipulates that the students live in the dormitories. Even if they later decide not to live in the dormitories, dormitory charges are still deducted from their wages. This practice is consistent with the employment agreement that vocational interns sign when they start working at the factory.
China Labor Law, Article 73; and FLA Workplace Code (Compensation Benchmarks C.1 and C.5, Forced Labor Benchmark F.5
Immediate Action Required
Interns are allowed to work overtime regularly without any restriction, therefore exceeding the 40 hours per week limit.
Factory Management will stop the practice of allowing interns to work overtime hours and will not exceed 40 hours per week.
Guangdong Province Internship Regulation, Article 22.5; FLA Workplace Code (Employment Relationship Benchmarks ER.1 and ER.13)
Sustainable Improvement Needed
Factory’s hours of work policy and related procedures set the maximum weekly combined working hours (regular hours plus overtime) at 60 hours per week. This meets Apple and FLA code standards but violates local law which limits regular weekly hours to 40 hours per week and overtime hours to 36 hours per month (an average of nine hours per week).
During the period between March 2011 and February 2012, most of the workers (77%) worked overtime beyond the legal limit of 36 hours per month.
Most of the workers worked 60 hours per week (regular hours plus overtime) in recent months in early 2011, but this was not the case during the peak season (November-December 2011 and January 2012).
37% of the workforce did not receive the required 24 consecutive hours of rest in a seven-day period during the peak season (November-December 2011 and January 2012).
According to the factory’s written hours of work procedures, workers are to be provided with a 10-15 minute ergonomic break after every two consecutive hours of work; this procedure is not implemented consistently and many workers do not receive it.
China Labor Law, Articles 38 & 41; and FLA Workplace Code (Hours of Work Benchmarks HOW.1 and HOW.2)
Sustainable Improvement Needed
Nearly all union committee members are managerial staff (30 of the union committee are either managers or supervisors, and only two representatives are workers, who were nominated by management). The Chairman of local union is the factory’s Purchasing Project Manager and the vice chairman is the Human Resources supervisor
Copy of current Collective Bargaining Agreement has not been provided to the workers, per FLA Benchmark ER.16.
FLA Workplace Code (Freedom of Association Benchmarks FOA.2, FOA.10, and FOA.11, Employment Relationship Benchmark ER.16 and ER.26). Trade Union Act (2001); Shenzhen Municipal Implementing Regulations for the Trade Union Law of the People's Republic of China
Sustainable Improvement Needed
Article 113-64 of the work rules in the worker handbook stipulates that workers would be fired in case of any involvement in an illegal strike. Although this provision has not been applied and there have been cases of dismissal owing to this article, it should be removed as it not in compliance with the FLA benchmark.
FLA Workplace Code (Employment Relationship Benchmark ER.26, Freedom of Association Benchmarks FOA.4, FOA.5 and FOA.22); Shenzhen Municipal Implementing Regulations for the Trade Union Law of the People's Republic of China
Immediate Action Required
It was observed that there is a practice of posting all disciplinary actions with names of the workers subjected to these disciplinary actions on the factory's website and notice boards.
Gathered information indicates that workers are using the "self-description form" as a form of self-criticism.
Factory management should stop this practice and communicate its discontinuance to the workers; workers should be trained on proper use of the "self-description form."
FLA Workplace Code (Harassment or Abuse Benchmark H/A.6)
Sustainable Improvement Needed
There is inconsistency in procedures regulating how to lodge a grievance. For example: the grievance procedures suggest grievances can be anonymous whereas Article 140 of the worker handbook stipulates that the Company does not accept anonymous grievances.
No instructions at the suggestions boxes.
Some workers are not comfortable using the grievance system because of fear of retribution and pressure from supervisors to quit if they lodge one or more complaints.
FLA Workplace Code (Employment Relationship Benchmark ER.25)
Sustainable Improvement Needed
There are no written policies or procedures governing retrenchment and resignation.
FLA Workplace Code (Employment Relationship Benchmarks ER.1, ER.19 and ER.32)
Sustainable Improvement Needed
General Health & Safety Policy does not cover protection of special categories of workers such as young (16 to 17 years of age)/elderly workers, pregnant/lactating workers, trainees/apprentices/interns and employees with disabilities.
No procedure for controlling thermal comfort conditions of the workers and protecting them from potential heat-related impact.
No Lock out-Tag Out (LOTO) procedure for protecting workers from hazardous equipment that might accidentally turn on and harm them.
List of machines that need guarding is missing.
No procedure for controlling working conditions and protecting workers from potential risk of falling when they work at heights.
Incomplete Material Safety Data Sheets (MSDS) of chemical substances in use that do not cover all necessary information about these chemicals such as ingredients and the full chemical composition.
No periodic control system for checking both health and safety and social conditions of contractors who work in the factory, such as in construction, maintenance, or waste handling.
Emergency action plans do not cover external parties, such as service providers or visitors.
FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE 11 and HSE.14; Employment
Sustainable Improvement Needed
Although there is an HSE committee in place, this committee is not active. There are no periodic meetings or internal audits conducted by this committee. Currently, the committee only holds meetings for some special cases.
There is no worker participation and integration on ongoing HSE efforts, as there are no elected worker representatives on HSE committee (all current members were selected by management).
Accident records only cover serious accidents (accidents with lost working time) but not all the accidents and near miss cases.
No system for keeping track of sickness and working day lost due to sickness.
Food Safety Law Article: 29; Trade Union Act; FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1 and HSE.3; Employment Relationship Benchmarks ER.25 and ER.31)
Immediate Action Required
No protective barrier for fuel pumps.
Rear gear sound alarm of some forklift trucks was missing or not operational; maximum load sign and speed limitation signage should be installed.
Protective barriers to be placed around fuel pumps for protection against potential truck or forklift crash.
Update the equipment maintenance system, and maintain the forklift truck well.
Production Safety Law, Article: 37; Prevention and Treatment of Occupational Diseases Law, Article 23; and FLA Workplace Code (Health, Safety, Environment Benchmarks HSE.1, HSE.6, HSE.7, HSE.8, and HSE.15; Employment Relationship Benchmark ER.31)
Immediate Action Required
No non-smoking warning signs placed near fuel station.
No protective shoes worn by workers operating forklift truck or working in the pallet moving areas; none of the forklift truck drivers were using their seat belts; tires of some forklift trucks were worn out
Hearing protectors (ear plugs) not used appropriately by workers
EHS-iDSBG-OP-011 PPE Management Procedure (6.7) states that “In principle, no PPE should be replaced or requested during the normal usage life span.”
Thin, simple activated carbon paper masks were selected as PPE to reduce VOC exposure, which is an improper PPE selection that does not provide effective protection;
The half-face activated carbon masks in Chemical Warehouse were not accredited by local authority.
Provide protective shoes to workers operating forklift truck or working in the pallet moving areas. Ensure that all forklift truck drivers use their seat belts while operating the vehicles and maintain tires in good condition.
Hearing protectors (ear plugs) not used appropriately by workers;
Ensure that workers use hearing protectors when required.
Ensure use of proper carbon masks in the Chemical Warehouse.
People’s Republic of China on the Prevention and Treatment of Occupational Diseases, Article 23; Law of the People’s Republic of China on Production Safety, Article: 37, and FLA Workplace Code (Health, Safety, and Environment Benchmark HSE.7; Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
Exit (egress) width not sufficient in many areas and buildings. For example: E3 building(existing width: four exits of 1.8mts wide and one of 1.2mts wide. Total width of 8.4mts, legal standard: 39.15mts); in G02 building (four exits of 1.8mts wide and one of 1.2mts wide. Total width of 8.4mts, legal standard: 17.33m); in G10 building (four exits of 1.8mts wide and one of 1.2mts wide. Total width of 8.4mts, legal standard: 26.37m); and in G11 building (four exits if 1.8mts wide and one of 1.2mts wide. Total width of 8.4mts, legal standard: 39.76m)
The curtain and separating walls for production workplace isolation block egress.
Only one exit is available for 134 workers in 2F of G02 by isolation arising from separating walls.
Emergency assembly areas are not marked and had no signage (production area).
Emergency action plans do not cover visitors, also no information provided to the visitors about what to do in case of an emergency.
Aisles in 2nd floor of G02 were as narrow as 0.40mts.
Only 5% of workers participated in fire drills in on-site dormitories. There were no fire extinguishers in forklift trucks.
Shower/eye washing station in chemical warehouse area was not in a good condition.
Code of Design on Building Fire Protection and Prevention; Fire Control Law of the People’s Republic of China, Article 13, 16; Law of the People’s Republic of China on the Prevention and Treatment of Occupational Diseases, Article 23;FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.5 and HSE.6, Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
Ergonomic principles in workstations were not implemented well. For example, in many areas workers were working in a very stiff position, as their chairs are not adjustable, made with uncomfortable material, and lacked back support (in Circuit Division)
Illumination levels do not seem high enough in some areas while some areas are over-illuminated.
An ergonomic break is supposed to take place for 10-15 minutes every two hours of work, but this rule was not followed.
Visual inspection found some workers were pulling heavily-loaded pallet trucks, which can harm their back. (Workers seen doing this were contractors.)
The number of toilets in the assembly workshop was insufficient. There were 2000 to 3915 employees on many floors, but only 20 to 24 toilets for each gender, less than legal requirements. Based on interview, some assembly lines only allow one 10 min break in each half day, or three times each day, for rest room use. Workers complained that the number of toilets was not enough.
Health Standard for Design of Industrial Enterprises Articles: 6.4.4.1 & 6.4.4.2; FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE.17, HSE.20)
Sustainable Improvement Needed
The MSDS for C-55, Spot-On, YC-336, RP-04, BUEHLER EPO-KWICK Harderner, BUEHLER Release Agent did not provide complete ingredients information.
The ingredient in the MSDS of Primer 94 was not translated into Chinese correctly.
The ingredients in the MSDS of Mr. Muscle Oven, Grill & Stainless Steel Cleaner were not translated from English to Chinese.
One cleaning solvent, CP-02, was used for a couple of months in iDSBG. This chemical was not maintained in iDSBG chemical inventory list. The factory explained that CP-02 was used for other business group products in iDSBG.
The factory did not test the indoor air quality for chemical exposure to substances such as toluene, methyl methacrylate, diethylenetriamine, monothaniarnine, etc over the past year.
The factory did not develop and maintain an effective Restricted Substance List (RSL) to review and phase out toxics in electronic sector.
General Rules for Preparation of Chemical Safety Data Sheet, Article3; Law of the People’s Republic of China on Prevention and Control of Occupational Diseases, Article 21, 24, 25; FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1; Employment Relationship Benchmark ER.31)
Sustainable Improvement Needed
Environmental Impact Assessment (EIA) for buildings G02 not updated to match the workforce and production upscale from 5300 to 7900 workers in the building; similarly, EIA was not updated to match the workforce and production upscale from 3,740 to 48,839 workers in buildings of E3, G10 and G11.
The change of production layouts with cloth curtain and/or separating walls in most floors were not reviewed/approved by local authority.
The factory did not report occupational hazards to the local authority as required by local laws
There was no occupational disease diagnosis or medical surveillance follow up for all the 78 on-job physical checkups in 2011 for which the factory should prove all the medical surveillance to establish relation or do not have the relation to the occupational hazards and/or exposure at their workstations.
The factory did not have the required permit, EIA, and Safety Assessment for the two 30M3 underground diesel tanks.
There is no system in place for controlling possible leakages of underground diesel tanks.
Effect-Assessment Report for Occupational Hazard Control in Construction Project of E3 was not available for SCI review. The factory explained the assessment has been conducted and the report is under preparation.
Prevention and Control of Environmental Pollution by Solid Wastes Article: 58, FLA Workplace Code (Health, Safety, and Environment Benchmarks HSE.1, HSE 11; Employment Relationship Benchmark ER.31)
