Interested parties are invited to submit general comments on the GoodWeave Generic Standard for the Rug Industry draft version 2.4.2 using the web form below. Specific comments on sections of the standard should be entered on the appropriate page at http://www.goodweave.net/comments.
The second consultation period takes place from June 30 – August 10, 2010. Comments are considered for the development of the final version of the GoodWeave Generic Standard for the Rug Industry. Go to http://www.goodweave.net/standard-development to learn more and to participate in the public consultation.
The new GoodWeave Standard represents a tremendous and welcome evolution for RugMark/GoodWeave in addressing very comprehensively the social and environmental impacts of handmade carpet production – while still in keeping with the original mandate to end exploitative child labor. I found little to comment on in the Draft 2.4.2 document and applaud this far-reaching undertaking. Just a few questions/comments are noted below:
• Under Principle 3 (Freedom of association/collective bargaining): I wondered if consideration was given to explicit language prohibiting intimidation or coercion of workers attempting to organize. While this might be implicit in the core and progressive requirements, given the prevalence of such tactics, such explicit language may be important.
• Under Principle 4 (No discrimination is practiced): What is the reason that the progress requirement that “Employers have a written policy about their recruitment practices, employment terms, …made available to all workers” is not a core requirement? It would seem to me that policies are a necessary first step, whereas processes and implementation might take time to evolve.
• Under Principle 5 (Workplace conditions): Risk assessments based on MSDS is a good requirement. I confess to not knowing much about the toxicity of raw materials, but it would seem appropriate to have a progress goal that addresses explicitly the goal of reducing exposure to harmful materials by aiming to reduce both the volume and toxicity of inputs in the production process. This is addressed a bit later in the environmental section, but I see it equally as an occupational safety and health issue.
Also, I thought the chart in Appendix 3 relating GoodWeave to other standards was interesting. Since other standards were benchmarked to GoodWeave, I couldn’t discern if those groups covered any areas that might be relevant to GoodWeave (and therefore missing). Admittedly, that seems unlikely!
Thanks for providing me with an opportunity to comment.
GoodWeave Generic Standard for the Rug Industry, Draft Version 2.4.2- Comments:
Page 1- “Objectives”
- Bullet 2 “…to promote the application of other fundamental human rights in the workplace identified as root causes of child labour.” Could be re-phrased to avoid confusion, as it currently can be read as though rights are root cause of child labour.
- Bullet 3 might be clarified, with language such as ‘To promote positive change in the community as a result of the programme…”
- Bullet 5 should identify the scope as being the rug industry: “…monitoring and verification of working conditions and environmental impact in the rug industry.”
Page 8- “Section 2 Standard Requirements”
5a. would be clearer if used safe and healthy workplace instead of repeating the category of working conditions.
5a-c take on a different presentation that doesn’t include the goal-oriented presentation of principles 1-4, 5d, 6 and 7. Could be clearer with a. safe and healthy workplaces, b. living wage, c. no abusive working hours.
Page 9- “Core Requirements”
Statement in paragraph 2 – “Companies applying this Standard are expected to comply with national requirements.” – should be clarified, such as, “Companies applying this Standard shall comply with national laws.”
Principle 1- No Child Labour
Page 10
- Conditions for children working with parents should include parameters on time.
- Given that GoodWeave is industry-specific, it seems reasonable to assess the different types of work involved and to identify either the types of work that are hazardous to children and young workers or the types of work that are acceptable for non-adults.
- Standard should reference the GoodWeave Protocol for Dealing With Child Labour” to clarify the requirements on companies when they discover child labour.
- Identification of risks involved should be added to the “Core Requirement” of a list of tasks carried out by young workers.
- “Progress Requirements” protection from hazards for children of workers and legal compliance seem to be more appropriately minimum entry, “core requirements”.
- “Producer will co-operate with local community initiatives in order to create the social norms…” might be a more reasonable expectation as “cooperate with local community initiatives to contribute to the establishment of…” A “Core Requirement” here might be communication to the community of the producer’s participation in GoodWeave. Progress requirement of “employer works with local…” might be tracked better if phrased as contributions in-kind and or financial.
- Homework “progress requirements” might include: separation of working space and living space as well as records of participants & their ages, hours and types of work carried out.
Principle 2- No forced or bonded labour
- Workers should be free to leave employment after a “reasonable” notice period; a “agreed” notice period opens up the possibility for coercion.
- Workers should be free to leave work after a “standard work day”, not “agreed time of close of work”, which opens up the possibility for coercion and confusion concerning overtime.
- “Confidential grievance procedure” is a reasonable “core requirement”, and the related “progress requirement” would be that all workers are aware of the system.
- Is “payment in kind or paying workers in tokens for shops on site” a practice that cannot be improved to the practice of cash or check only payment method? If very common, a “core requirement” should be added that prices at stores that redeem tokens are no more than local prices, and cash/check payment added as a “progress requirement”.
Principle 3- Freedom of Association and Collective Bargaining
- Unions’ access to workplaces to conduct their representational activities should be a “core requirement”; the “progress requirement” may be the negotiation of a collective bargaining agreement.
- The prohibition of discrimination for trade union activity should include prohibition of a worker’s trade union affiliation in decisions related to hiring, remuneration, promotion, access to training, redundancy and retirement.
- “The employer shall, where freedom of association is restricted by law, facilitate parallel means…” creates confusion on roles of employers and workers. Only workers can exercise the right to organize in order to negotiate collectively with their employer. Employers’ responsibility is to respect workers’ exercise of these rights. A “core requirement” in this case may be that an “explanation of the relevant law is made available to workers.”
Principle 4- No Discrimination
Policy and processes should be “core requirements”, while “affirmative action” programs may be more appropriate as a “progress requirement”.
Principle 5- Decent working conditions are respected
5a. Workplace conditions
- Using “occupational safety and health” or “safe and healthy workplaces” would clarify this principle.
- “All workers have access to potable water and clean toilet facilities…” should replace “There is…” water and toilets.
- Management member appointed responsible for health and safety should be a “core requirement”. “Progress requirement” for workplaces with reasonable workforce (over 10) may be the establishment of a worker-manager committee that oversees occupational safety and health.
- To be effective, personal protective equipment require training. Training should be a “core requirement” and include comprehensive methods for preventing and mitigating workplace hazards.
5b. Wages
- Deductions for disciplinary practices should be prohibited unless both conditions exist: the law permits them and a collective bargaining agreement is in force.
- Overtime premium “core requirement” can be that workers are aware of the premium rate for overtime hours.
- Loan “core requirement” can be that workers understand the terms of the loan agreement.
5c. Working hours
First clarification, bullet 2, should include that overtime is voluntary; while stated in the following clarification box, this first statement on overtime needs to be clear.
5d. No harsh or inhumane treatment
Establishing a policy should be a “core requirement” and maintenance of related records the “progress requirement”. It would be useful to indicate that the disciplinary system should be progressive, not punitive.
Section 3- Implementation
The verification system is unclear. Who makes the certification decision? Who are the “evaluators” who conduct the audits? Who qualifies the auditors? What are the audit procedures, and who establishes them and monitors their effectiveness? What is the system to oversee the auditing process & auditors?
Page 28-
Inspection of factories paragraph indicates that a “synopsis of the findings…will be given…”. The closing meeting between the auditor and the producer is referred to on page 29 and should be noted here.
“GoodWeave Protocol for Dealing With Child Labor” should be referenced; current text is vague in its description of the process for remediating child labour.
I see a distinct difference between the “standard” as defined within this document and what GoodWeave is or will be able to “certify”. The credibility of the GoodWeave certification will depend upon the development of clear and guidelines. The present GW standard and certification are generally seen as being one and the same. I’m not so sure this will be the case with the new standard.
The development of the guidelines will dictate how relevant and effective the standard will be in the field.
I know that a number of experts have commented on the specifics of the right to organize, health and safety, etc. so I will limit my comments to a couple areas of general concern…
This Standard covers all workers and workplaces in which rugs are produced. – This statement seems inconsistent the preceding statements. The standard actually covers all workers and workplaces under the purview of the licensee…it might make sense to simply remove this portion of the paragraph.
The application seems inequitable – if I understand it correctly, existing licensees have 12 months to meet the core requirements. Any new applicant must meet the core requirements prior to becoming a licensee. This will create unwelcome barriers to entry.
This section should be tightened as parts seem too vague and open to interpretation – e.g. where existing licensees experience difficulties addressing the Standard in all subcontract levels, they may apply for an extension if they can demonstrate good intent and difficulties. Extension requests will be decided on a case by case basis taking into account all considerations including the impact of the non-compliance on the GoodWeave Standard’s credibility.
The progress requirements could appear to be meaningless if there are no specific performance requirements (two years, three years, whatever..)
I’ve only made a couple of comments regarding principle 1:
The second core requirement lacks specificity: what type of systems? Mandatory that the facility participate in and/or support all GoodWeave community based monitoring programs?
Producers have systems in place to ensure that no children are employed or work illegally. This includes participating and/or supporting community-based monitoring programmes that are initiated or supported by GoodWeave.
Should the footnote about acceptable family labor be included in the body of the principal?
Children below the age of 15 are not employed or allowed to work (where the national legal limit or the end of compulsory school age is above 15, the higher age limit will be followed). Note: This progress requirement must be achieved within one year. Within one year of what date/event?
There is a register of all workers under the age of 15 indicating their age and their work. Their conditions of work shall be compliant with ILO conventions for work given to children below the age of 15. This statement could seem somewhat inconsistent with others in the principle.
What type of remediation processes…? Schools, vocational training, counseling, etc.