Manufacturing Standards Group’s Dialogue: Materials To Be Used In Manufacturing
Introduction:
This is an exchange between myself and Cristina Echavarría, Executive Director of the Alliance For Responsible Mining (ARM), on the issue of what materials to be used in manufacturing, and other issues last March.
This is published in the spirit of transparency, as we are about to begin our discussion again. The members of the entire group can be found here: This was posted on our list serve on March 17th, 2009.
Dear Group,
The Steering Committee works to present the best possible starting point for our discussions. Over the past week, we have had some back and forth. I’m putting forth a letter from Cristina Echavarría, Executive Director of the Alliance For Responsible Mining (ARM) and my response to her.
For those who are interested, it will provide a context for our approach to setting standards for the first principal. I also repeat, for those who are new to the group, a long term vision of how our work might be used once we have set standards.
In this letter is also the thinking behind the proposal for the first standard. I will actually put forth that first standard in a separate email, so please hold off on commenting on that first standard at this point. However, you are welcome to provide comments on the other issues covered in this letter.
This material will be published on fairjewelry.org.
Thank you again for your interest and participation in this project. If you want to read previous discussions, you can do so at this link: https://fairjewelry.org/madison-dialogue-manufacturing-committee
There are still a few changes on our member’s list that should be taken care of in the next day or so.
Sincerely,
Marc
See below: First Cristina’s letter and then my response.
All,
Thanks Marc for your warm welcome. I look forward to learning much about the manufacture of jewellery and and its supply chain by participating in this group. Please allow me to set out three issues: a general comment about the scope of this group, comment on the first principle (consultation) and how this process links in with ARM-FLO Standard Zero for Fairtrade-Fairmined Artisanal Gold.
1. Scope of this list serve: I think that this group is
tremendously useful to :
* Determine a clear delimitation of the part of the supply chain
that is included in the proposed principles – this must be
clearly established by the group and communicated E.g. It does
not include ensuring responsible sourcing of metals and stones
(or other materials?), and an explanation of why not.
* Identify the social, economic, environmental and labor issues
that need to be included in the standards for
responsible-fairmade jewellery produced by small and medium
jewellers (is there a way to describe small and medium jewellers?)
* Determine if all of these issues have equal weight (Eg. Which
are the major issues and the secondary or progress issues), and
if there are several levels of progressive compliance. This
crucial groundwork is necessary before any specific requirements
are set.
2. 1a – 1. Consultation: Companies and manufacturing operators will obtain free, prior, participatory and informed consent of affected communities and civil society before starting operations. Existing operations will also engage affected communities.
This principle has been apparently taken from responsible mining principles. FPIC (Free, prior and informed consent) is based on ILO convention 169, and it generally refers to the consent of local communities to a MINING operation. Therefore, do we believe that all small and medium jewellers are to undertake a consultation with the neighbours to procure their consent of having a jewellery operation in the neighbourhood? Or are we thinking of ensuring that jewellery operations are legally registered and compliant with national laws? If we are thinking of the latter, I suggest taking out the consultation principle from the list.
3. How can this process feed into the trading standards that ARM and FLO are developing as part of the FT gold standards? Research is being undertaken at present by FLO and ARM to define the FT gold trading standards. We will submit these standards to consultation soon. Could this manufacturing group act as a specialised consultative group to provide feedback on the standards?
I look forward to your thoughts,
Thanks,
CRISTINA
___________________________________
Dear Cristina,
Thank your for your excellent points. I’ll respond to them one by one.
Determine a clear delimitation of the part of the supply chain that is included in the proposed principles – this must be clearly established by the group and communicated E.g. It does not include ensuring responsible sourcing of metals and stones (or other materials?), and an explanation of why not.
Supply chain issues are beyond the scope of fair made manufacturing. The current supply chain is geared mainly toward the high end market which is not where the majority of the potential manufacturer in the “fair made” space function. It may take years before the supply chain is adequately developed to support fair made manufacturing.
Just the simple task of importing items ethically sourced raw materials is an issue. For example, to import recycled silver to Indonesia, I must pay close to $2000 in duty and shipping costs, regardless of the value of the shipment. My manufacturer had to create an “export free zone” within his factory that traces silver all the way through production. Between administration and government paper work, it took him nearly six months to set up. I suspect that these types of impediments to trade (the importation of a raw material to an “export free” zone!) are not limited only to Indonesia.
To link the sourcing and manufacturing together, at this point, would diminish, from the start, the impact that our work might have. In the short term, on factory tours I’ve taken, I’ve noticed that compounds were being used that were dangerous to the workers, yet this danger was not known. Addressing issues around worker safety would have immediate benefit.
The just the focus on manufacturing issues is a big enough task with plenty challenges separate and distinct from sourcing issues.
In regard to this point: Identify the social, economic, environmental and labor issues that need to be included in the standards for responsible-fairmade jewellery produced by small and medium jewellers (is there a way to describe small and medium jewellers?
Regarding the issue of large versus small, I would like to not address that question until we have to. Let’s focus on standards first and then see how they might apply.
Manufacturers have different skills depending upon a wide range of issues, from traditions within a culture to equipment investment. My view has always been to open up our process to a wide range of manufacturers, reflecting the diversity of manufacturing within the sector. For example, John Hardy’s environmental manager is on our group. Hardy would be considered large scale. If they want to be part of our compliance, why would the efforts of our group not support that.
Dealing with the diversity is why I have supported a web based platform which publishes studies on different fair made manufactures based on radical transparency. The Better Business Bureau uses this approach successfully in the US market, though our fair website would be have a different set of information. But here’s an example of how the BBB rates my company which shows what I mean:
http://www.bbbsw.org/BBBWeb/Forms/Business/CompanyReportPage_Expository.aspx?CompanyID=44712
Radical transparency is a movement that has gained prominence in other sectors and I believe it is a sound footing for our work. If you would like to learn more about radical transparency, here’s an article:
http://www.wired.com/wired/archive/15.04/wired40_ceo.html
Considering your point: Determine if all of these issues have equal weight (Eg. Which are the major issues and the secondary or progress issues), and if there are several levels of progressive compliance. This crucial groundwork is necessary before any specific requirements are set.
The problem I have in creating a hierarchical system is that we are making values based decisions for customers. We should include all the information on a website which would allow a customer to determine what has more weight. Instead of overlaying our values, let us just provide accurate information regarding the critical issues of weight about the factory in the public domain.
For example, in our sector now there has been a vigorous debate over African vs. Canadian diamonds. How one stands is a value based decision. Labor verses environment vs. social issues is also a values based decision. Is labor more important than environment or social issues? It depends who you talk to. I do not see any benefit in creating a hierarchy when radical transparency would provide a model that would make the issue of hierarchy mute.
I say, let us create a structure which would allow for the transparent and accurate flow of information and then see what the market supports.
1a – 1. Consultation: Companies and manufacturing operators will obtain free, prior, participatory and informed consent of affected communities and civil society before starting operations. Existing operations will also engage affected communities.
I agree with your insight that we are simply ensuring that jewelry operations comply with national laws. I think that the issue is really covered in the 7th principle:
7. Legality
Companies and individuals will adhere to existing applicable laws and support the establishment of legal frameworks in sectors where they do not currently exist;
# Companies and individuals will comply with international conventions and national laws with regard to anti-money laundering, bribery and corruption.
I propose moving the 7th principle to the first principal and deleting the current first principle when we put this forth to our larger group.
3. How can this process feed into the trading standards that ARM and FLO are developing as part of the FT gold standards? Research is being undertaken at present by FLO and ARM to define the FT gold trading standards. We will submit these standards to consultation soon. Could this manufacturing group act as a specialized consultative group to provide feedback on the standards?
Certainly I would be pleased to provide feedback, as part of your stockholder’s alliance, to the standards that support ARM. I would also support putting those standards out to our greater group as well.
I believe that given the scope of our group, we have a balanced representation of stakeholder. We have manufacturers from several nations. I am not at all concerned whether we are in alignment with FLO, though FLO is welcome to participate. Any fair trade organization or its members are welcome. Yet the alignment with FLO has never been a goal or objective of the manufacturing group. FLO knows nothing about jewelry manufacturing. Besides, as I’ve put forth, I believe that we can improve their platform.
Furthermore, I believe our process should be open, public and democratic and should not take place with a small group designated as a “technical committee.” The function of our steering committee is to put forth the best ideas for the general group. We can then rely upon the collective wisdom of our list. If you review the dialogue that we had last year, you will see that we had some very vigorous discussions and broad participation. At present, our group is larger, more diversified and stronger now than it was then. I expect that we will continue to have broad participation.
Finally, I will add that many different groups within the jewelry sector are coming up with broad principles and then get stuck when it comes to standards. Of course, ARM is a rare exception. I would like to move forward with our standard setting, even if our movement involves quite a bit of stumbling. I have faith that the vast experience and good intentions of the many members of our group will provide the collective wisdom that we need for success.
This discussion we are having here is important background information. Unless anyone reading this has objections, I would like to post my response to your letter on fairjewelry.org. These issues are of public import, and making them public adds additional credibility to our radically transparent efforts.
Sincerely,
Marc Choyt
From Vivien Johnston
I am of the idea that our standards seek to educate in the fore and share information transparently. I think that materials procurement issues are critical but insisting on transparency may create a barrier to our initial aim which I understand to be improve health and safety and educate of dangers to health of employees and immediate community as necessary.
My own experience of Asian factories is that procurement is erratic and that sub contracting is common place and informal. Insisting on transparent procurement may create a barrier to the aims of improving workers conditions in factories.
