The electronics industry has made significant improvements in tracking, reducing, and ultimately eliminating many potentially harmful chemicals from its products. With considerable success addressing product-related chemicals, the industry has expanded its attention to process chemicals, the chemicals used in manufacturing processes in the supply chain. Safe process chemical management in the supply chain requires adequately protecting workers and the environment through proper care in shipping, use, storage and disposal of chemicals.
RBA Code of Conduct
Protecting workers and communities from exposure to hazardous chemicals has been a core component of the RBA Code of Conduct and Validated Assessment Program since its inception. The RBA Code of Conduct requires:
“Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper design, engineering and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment. Protective programs shall include educational materials about the risks associated with these hazards.” (Section B.4.)
“Chemicals and other materials posing a hazard to humans or the environment are to be identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.” (Section C.3.)
Additionally, the RBA introduced a new chemical policy in 2021, including an Industry Focus Process Chemical List (IFPCL), which outlines greater industry scrutiny and the need for the most protective levels of control to be utilized for the most hazardous chemicals.
The policy is effective January 1, 2022 and will be operationalized through the VAP and/or Specialty VAP (SVAP) on Chemical Management to prioritize more advanced, permanent and protective levels of control as defined by the Hierarchy of Controls, focusing on isolating or eliminating hazards, for chemicals on the IFPCL list. The full policy is available to RBA members here.
Chemical Management Workgroup
To further address the ongoing challenge of reducing risks and protecting workers in the electronics supply chain, the RBA has made chemical management a priority issue. Members collaborate on solutions through the Chemical Management Workgroup and encourage adoption of proven quality management systems. The Workgroup also strives to improve visibility and communication within supply chains and among stakeholders to bring attention to each chemical’s potential hazards and requirements for safe use, handling and disposal.The Chemical Management Workgroup has helped the RBA to:
- Increase member awareness and involvement in the safe use of chemicals
- Develop training and capability-building activities to reduce worker exposure, like online training courses on effective chemical management, and fact sheets for workers and managers on product and workstation cleaning, plating and etching, bonding and gluing, painting, chemical transportation, storage, labeling, and personal protective equipment
- Define adequate and effective practices for conducting chemical risk assessments, tracking and reporting process chemicals, and communicating with workers.
- Explore how to phase out hazardous chemicals and pursue safer alternatives, where feasible
The RBA joined the Clean Electronics Production Network (CEPN), facilitated by Green America. This multi-stakeholder effort includes participants from the academic, government, NGO and business communities. As partners, the CEPN and RBA are working to develop and scale effective monitoring and control systems to prevent worker exposure to harmful chemicals by empowering and engaging workers, tracking and measuring worker exposure, finding safer substitutions and enabling faster, easier process chemicals reporting. Several RBA member companies are also participating directly in the CEPN.
All of our chemical management work has benefited from significant feedback from well-respected NGOs and is being conducted in collaboration with civil society organizations. We recognize there is still much work to do around the safe use of chemicals and reducing worker exposure. The RBA and its members are committed to staying the course, working with partners and making meaningful progress on this important issue.