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HCL's Chemical Policy Based on Precautionary Principles
HCL's vision is to avoid the use of substances in its products that could seriously harm the environment or human health and to ensure that the company acts responsibly and with caution.
HCL believes that if reasonable scientific grounds indicate a substance (or group of substances) could pose significant environmental or human health risks, even if the full extent of harm has not yet been definitively established, precautionary measures should be taken to avoid use of the substance(s) in products unless there is convincing evidence that the risks are small and are outweighed by the benefits. HCL considers these to be substances of concern that need to be eliminated in the long term and substituted or gradually phased out in the short term.
HCL is strongly in favour of government legislation such as the Electronic Products Standard law which restricts/bans use of certain identified chemicals in Electronic Products.
HCL identifies these substances with consideration for legal requirements as mandated by the Ministry of Environment and Forest, Government of India, international treaties and conventions, RoHS legislation etc. as applicable to its area of operations and by the following criteria:
- Substances with hazardous properties that are a known threat to human health or the
environment;
- Substances with hazardous properties that show strong indications of significant risks to human health or the environment;
- Substances with hazardous properties that are known to bio persist and bio accumulates in humans or the environment.
To enforce the company's precautionary measures, HCL strives to eliminate such substances of concern in its products by:`
- Maintaining a Banned and Restricted Substance List,
- Choosing designs and materials that avoid the use of substances of concern,
- Committing suppliers not to use these substances contractually, and
- Substitution of viable alternate substances.
To demonstrate our commitment, HCL targeted the following substances for phase out;
- Phthalates - Tentative timeline for its Phase out by HCL is 2012
- Beryllium and its compound- Tentative timeline for its Phase out by HCL is 2012
- Antimony and its Compounds- Tentative timeline for its phase out by HCL is2012.
Acceptable alternatives would be identified for the above that will not compromise product performance and will lower product health and environmental impacts. We will have appropriate management procedures to deliver this policy and review a phase out plan yearly or when required and evaluate available technical, environmental and scalable solutions. HCL is committed to continually improve the environmental quality of our products.
HCL's methodology for Identifying Harmful Chemicals in Future
At HCL, we have a dedicated team that regularly monitors the following indicators for identifying clues/proofs about new Harmful Chemicals in Electronic Industry:
1. National Legislations
2. International Legislations
3. Concerns raised by International Community
4. Environment related Publications
5. Scientific Studies on the effects of Chemicals on Environment/human-health
6. Concerns raised by NGOs
7. Concerns raised by Study-groups
Every quarter, this team classifies the information thus gathered in the following categories:
1. Chemicals which have been empirically proven to be Toxic.
2. Chemicals which are not empirically evident to be Toxic.
Every quarter, the chemicals that figure in the category 1 above are identified as Toxic Chemicals, and are included in the Class A list.
Simultaneously, Changes if any are communicated to all our suppliers as per requirement.
The chemicals that figure in Category 2 are constantly followed for any further clarity on them.
Environment Management System (EMS) at HCL
We at HCL, are committed to continually improve the conservation of natural resources, minimisation of waste & pollutants and comply with applicable legal, regulatory and other requirements relevant to our products, processes and environment. HCL is the first to achieve ISO - 14001 certification for its manufacturing facilities,
HCL follows a management system approach in delivering its policies, management of environmental aspects and reporting on objectives, goals and targets. A multi-disciplinary team drawn from relevant departments engaged in key processes such as product development, procurement, manufacturing, and corporate administration follow established procedures and action plans. The management committee reviews these procedures and plans at regular intervals and shares information with key stakeholders.
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