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Time for a New Approach to Work Hours

The social compliance industry as we know it today is still a relatively young one, but it has come a long way since its inception roughly two decades ago.

Social responsibility certification programs have had a significant positive impact at the factory level, resulting in far greater awareness of the importance of responsible practices and safeguards for production workers. Yet throughout this period, the social compliance certification model itself has remained largely unchanged, with most approaches building on the core International Labour Organization (ILO) conventions as the issues to be covered, while focusing on local laws to determine the specific requirements to establish compliance under those issues.

As a long-time practitioner in this field, when I reflect back on the progress that this model has helped drive, it’s becoming increasingly clear that while this approach did make great initial strides, it has simply not moved things past a certain point because it fails to recognize some critical ground realities.

Chief among them is the fact that prevailing certification models require compliance with—among other things—limits set by local laws on the number of hours that workers can work, yet in so many of the key sourcing destinations within the apparel supply chain, exceeding those hours is a routine industry practice.

While certainly well-intentioned, the original compliance certification model, insistent as it is on factories meeting those limits embodied in local laws, can therefore result in a misalignment of incentives, with factories striving to “pass” audits by doctoring their records to show the kinds of numbers they think the auditors want to see. Especially when it comes to working hours.

This fear on the part of these factories—that telling the truth would actually harm their chances of certification—has made social auditing a real cat-and-mouse game, with the resulting set of multiple books being a standing joke in the industry.

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It is a bad enough problem in itself, but it gets compounded because of the multiplier effect that the lack of knowing actual hours worked has on being able to assess social compliance in a factory. Given that workers are typically paid based on the number of hours they work, not being sure of actual hours worked makes it impossible to be sure about compensation.

All in all, this lack of transparency inherently hampers the ultimate aim of social compliance certification organizations like the Worldwide Responsible Accredited Production (WRAP), which is to engage with factories to help drive real and lasting improvements in working conditions. But getting factories to focus on improving working conditions (rather than simply passing audits) is just not possible without first acknowledging the problem and establishing its true extent, and that, in turn, isn’t possible when the audit model isn’t set up to reward honesty.

So, after spending a long time looking for a more refined approach to this issue of working hours, WRAP has concluded that we need a new model, one with transparency at its very core.

As part of a revision to our 12 Production Principles, we recently announced that, effective Jan. 1, 2016, our certification criteria has been changed to allow factories that meet certain conditions to qualify, even if they are not yet in full compliance with limits on working hours set in local laws.

Those conditions include being fully transparent with WRAP about working hours, ensuring those hours are all being worked voluntarily in conditions that protect worker safety and health, compensating all employees fully for those hours, and showing progress, from one audit to the next, toward meeting the working hour requirements in local law.

Our plan is to engage with factories where working hours are found to be in excess of the country’s legal limit to develop a mutually-agreeable plan of actionable, verifiable steps the company can take to gradually come into compliance with its country’s laws.

This action plan will be included in the company’s WRAP file and progress against the plan will be assessed and documented, with facilities needing to demonstrate adequate progress toward compliance at each successive audit in order to remain in the Certification Program.

The goal here is to facilitate actual progress by identifying root causes of excessive working hours and addressing them, instead of merely masking the problem with double books. By not requiring immediate, full compliance with local laws on working hours as a condition of certification, we will foster an environment of trust and transparency, which, over time, will enable real and lasting progress.

The old social compliance certification model—after helping drive significant positive change—stalled because it did not take existing ground realities about working hours into account. It’s time for it to evolve into a model better suited to enabling the kind of improvements it was always intended for, and that is the new trail we are blazing at WRAP.


Avedis Seferian joined WRAP in 2004 and was named president & CEO in 2012. He has extensive knowledge of social responsibility issues within the highly complex worldwide supply chains of the apparel, textile and footwear sectors.