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Holding Corporations Responsible for Workplace Deaths

[ 83 ] April 24, 2013 |

We don’t hear too many stories anymore like last week’s fertilizer plant explosion in West, Texas, where the death toll has now risen to 15. This is because we have outsourced our industrial risk to Asia and Latin America.

An 8-story building containing a clothing factory in Dhaka, Bangladesh has collapsed, killing at least 87 people. This is on top of the 112 burned to death 5 months ago in another Bangladesh clothing factory. How many people have to die making our clothes before we pay attention?

If this all sounds like the Triangle Fire in 1911, there’s a reason for that. Clothing corporations, manufacturers, and big box stores actively want the Triangle model to exist. If you are an American or European corporation, you don’t want to employ the people who make your clothes directly. You want to order out for what you need with no responsibility. You want low prices, so you pressure contractors to keep wages and conditions as low as possible. That probably actually goes unsaid but everyone knows what “keep costs low” means. You want to split workers up into a variety of workplaces so that they can be more easily controlled and can’t unionize. Putting them on an upper floor of a building, just like at Triangle, is a perfect way to control that labor with no supervision.

The question we must ask is to what extent the corporations demanding this labor model are responsible for the unsafe working conditions of the employees? We know at least that these workers made clothes for Benetton, Dress Barn, and The Children’s Place. Should these corporations be held accountable when workers die? Wal-Mart denied having any its clothes made in the factory that caught fire, but they were proved liars on the matter. It also seems that Wal-Mart had some contracts in this factory, according to this factory profile sent out by Stephen Greenhouse of the Times on his twitter account.

I argue that we should apply U.S. labor law to all American corporations, no matter where they site their factory. If a worker dies in a factory that makes clothing for your company, the company is responsible. In my mind, this is the only way to fight the outsourcing epidemic that provides a cover for irresponsible corporate policies. The injured workers and the families of the dead deserve financial compensation. The American corporations who buy the clothes produced by this factory should be required to pay American rates of workers compensation. Ultimately, we need international standards for factory safety, guaranteed through an international agency that includes vigorous inspections and real financial punishments. Of course, we are a long ways from any of this. But we have to begin at least talking in these terms, demanding accountability for workplace deaths, whether in the United States or in Bangladesh.

Meanwhile, building on yesterday’s discussion of media coverage of these events, only 2 of 63 cable news segments on the West Fertilizer explosion noted that the plant was in violation of federal standards for holding ammonium nitrate. Bad reporting on workplace conditions helps people see these events as accidents and not as the fault of specific choices corporate leaders make and for which they should be held criminally and civilly responsible.

Moreover, it’s not as if the state plays no role in allowing these violators to operate. Rather, the state actually helps them to do it. For instance, the Dallas Morning News has asked the state of Texas for a list of all factories, facilities, and dealers in the state holding ammonium nitrate (as there was also a massive fertilizer fire in Bryan in 2009 that luckily did not kill anyone because the fire fighters gave up on putting it out and instead put up a perimeter around the blaze). The state chemist’s office, which is at Texas A&M, is resisting this request and the state attorney general will decide if such information should be made public. Given that Rick Perry has said that his state’s lax regulations are fine and that further regulations would have made no difference in West, we can guess what the attorney general’s response will be.

We have a lot of work to do to make our workplaces and communities safe. Simply gathering information and publicizing what we can is the first step, one that faces significant resistance of its own.

Comments (83)

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  1. Another Anonymous says:

    The state chemist’s office, which is at Texas A&M, is resisting this request

    I can see where a terrorist group would be very interested in that list.

  2. [...] Holding Corporations Responsible for Workplace Deaths – Lawyers, Guns & Money : Lawyers, G…. Share this:TwitterFacebookLike this:Like Loading… Contemporary news, opinions and articles [...]

  3. DrDick says:

    I think that this really highlights a central issue regarding these incidents. These are not really “accidents”, but the direct and imminently predictable consequences of deliberate decisions by corporations in order to maximize their profits. It is minimally negligent homicide.

  4. Bitter Scribe says:

    Rick Perry visited Chicago this week, trying to lure businesses away from Illinois to the “friendlier” environment of Texas. Rahm Emanuel made a crack about his ability to remember three things but refrained from mentioning the West disaster. I kind of wish he had. I’m starting to lose all my compunctions about kicking these assholes when they’re down.

    • wengler says:

      How could they possibly lure corporations away when the state of Illinois pays them hundreds of millions of dollars out of their own employees taxes?

      And the big state story here is how evil public union workers are for not wanting their pensions cut to a pittance.

  5. c u n d gulag says:

    If we still give people the death penaly for murder, and the SCOTUS has said that corporations are people, why can’t we give corporations that kill people the death penalty?

    Btw – If you want me to take myself away from my absolutist “NO DEATH PENALTY” position, then make a case for greedy, neglectful, cheating, lying, owners of corporations to get the death penalty, then I might side with you on some other poorer, darker, folks.

  6. Murc says:

    I argue that we should apply U.S. labor law to all American corporations, no matter where they site their factory.

    I’d go further than this, actually. I’d argue we straight-up shouldn’t do business with countries that don’t meet certain minimum standards of political freedom, civil rights and liberties, and other benchmarks.

    The horse has sort of left the barn on that, of course.

  7. Cheap Wino says:

    I argue that we should apply U.S. labor law to all American corporations, no matter where they site their factory.

    Yes! Obama can ram this through congress as soon as he gives a major public speech and combines that with a little back-room cajoling. If it doesn’t happen it must mean he doesn’t want it to happen.

  8. Manta says:

    “If a worker dies in a factory that makes clothing for your company, the company is responsible. In my mind, this is the only way to fight the outsourcing epidemic that provides a cover for irresponsible corporate policies”

    It seems to me it’s not the only way: a more politically realistic way would be protectionism: ditch free market between states and impose stiff tariffs on anything produced abroad.

  9. Sherm says:

    We haven’t simply outsourced our industrial risk, we’ve outsourced the 19th century. These jobs ain’t coming back until the 20th century arrives overseas or the 19th century returns here. Great Post.

  10. Johnny Sack says:

    But but where’s the glib rejoinder that not so subtly implies that low cost clothing is more important than human lives!

    • stickler says:

      I’m sure Yglesias is working on it as we speak. He’s already done the “we actually benefit from mass low-wage immigration” thing a few times.

      • stickler says:

        Holy shit, that was fast:

        http://www.slate.com/blogs/moneybox/2013/04/24/international_factory_safety.html

        Bangladesh may or may not need tougher workplace safety rules, but it’s entirely appropriate for Bangladesh to have different—and, indeed, lower—workplace safety standards than the United States.

        Yeah, crappy worker protection laws are fine! Watch the invisible hand!

        • JKTHs says:

          Unless I’m misreading, basically his argument is we need to keep these jobs dangerous so workers will get paid more? Er…

          • Erik Loomis says:

            Yes. Among many problems with this is that dangerous work does not pay more.

          • Brett says:

            His argument is that all safety standards are a trade-off between what will keep workers safe and what is economically realistic. That’s how we do OSHA standards in this country, for example. Bangladesh is going to figure out its own balance on that, probably reflecting the fact that Bangladeshis are really poor compared to Americans and need/want the jobs (hence why there hasn’t been an exodus of people quitting their textile jobs over there despite industrial accidents).

            Trying to enforce US standards is worse than useless in that situation. Hell, many of these countries already have a bunch of standards that are so far outside the reality of what people are actually willing to accept over there that they just become another source of corruption.

        • Hogeye Grex says:

          The invisible hand is quicker than the eye.

          Just ask the guy with a black eye.

          • shah8 says:

            Would like to see a new post countering that particular post. I had thought that it was clumsy response. I think I see where he’s driving at–Bangladesh needs jobs that are only available if Westerners don’t want them. Missing is the actual talk of why–like how horrifying agricultural work can be, or that it’s better to eat with no hand rather than be dead with two hands, the usual global trade ricardian analysis wonkery.

        • L.M. says:

          For someone with neither academic training in economics nor relevant practical experience, it’s remarkable how strongly Yglesias is committed to sounding like an insufferable know-it-all.

        • JKTHs says:

          Yglesias derives a little too much pleasure from the invisible hand.

  11. Johnny Sack says:

    What clothing companies don’t suck? As I was putting my shirt on this morning (Gap) I noticed it was made in Bangladesh.

    I actually like American Apparel. It’s expensive but they pay a living wage and I know that labor conditions in LA can’t be as bad as over there. But for dress clothes?

    • CaptBackslap says:

      For suits, Hickey-Freeman is an excellent US-made brand. I think it’s pretty safe to assume that high-end imports aren’t being made in lieu of 5th-grade attendance or anything, too.

      For shirts or pants, uhhh…J. Crew talks a lot about responsible sourcing, but I can’t recall any details other than that the Irish linen shirts are actually made in Ireland.

      Ooh, 25% off and free shipping today!

  12. comptr0ller says:

    [thinking aloud]

    Any possibility of leveraging the guest worker program to insource non-agricultural factory jobs to the US?

  13. wengler says:

    It’s interesting you mention the Triangle Shirtwaist factory fire, because after that last fire in Bangladesh I realized something quite hideous. In that factory in Bangladesh the workers were making less money than those women in 1911. Not inflation adjusted. Less.

    This country’s slave worker policies are actually worse than 100 years ago.

  14. Jack Greenall says:

    I love the idea of holding foreign subcontracters and outsourced multinationals to US standards. But, even if it was politically workable, the regulation would be untenable. Who would investigate whether the factories were up to code? And while Walmart etc should (and do) know what’s going on in their subcontractor’s factories, the burden for small businesses to investigate every one of their suppliers or be held accountable for the failings is surely an overburden. So you carve out a small business exemption, and big chains just subcontract procurement to small business middlemen (as big agriculture does to take advantage of subsidies aimed at family farms).

    What if we refused to make trade agreements with countries that have anti-union laws, or fail to protect unions more broadly?
    At the very least, it might help to forstall the race to the bottom. One of the reasons the outsourced labour situation is so intractable is that corporations in third world countries got the jump on union suppression at an earlier stage in the national development. And it helps at home as well by not making union membership an obstacle to locating your factory domestically.

  15. Under the heading of Wholesale Farm Supplies on Manta I found 464 listings. There are a few that should get tossed out from the list, like the cabinetry shop that somehow got included, but you can figure most of them carry NH3.

    Yeah, it will take a court order to get them to turn loose of the list and my suspicion is that this list and their list are not going to be identical sets. How much you wanna bet a big reason for them not wanting to turn it loose is the fact that very few if any have been inspected in the last decade and there are quite a few they don’t even know exist.

    As far as industrial facilities ripe for a terrorist target, pick anything on the left hand side of the road as you come into Corpus Christi. Or any of the multitudes in the Houston area. Or Odessa or Midland. Hey, how about that fuel dump right across the road with tons of gasoline? Yeah, that is right down the road from the Wal-Mart where the fugitive from justice escaped and hid in the woods for a week. Yep, super secure area that is.

    Goodhair and his underlings have no interest in transparency.

    How much more would it cost for a pair of jeans to know they were made by somebody getting a living wage in a safe work environment? How about that box o’ wine? Knowing that they have proper facilities for a toilet and it isn’t a mile walk back to the water jug is worth an extra few dollars to me. I go out of my way to shop locally and think about who gets my dollars. Sometimes I can’t avoid it, but I do try.

  16. oh no. tragic link mistake, please delete that mess.

  17. Ragout says:

    As usual when Loomis starts opining about policy, there’s so much wrong it’s hard to know where to begin. So let me begin with the big picture. The global trade liberalization that Loomis calls an “epidemic” has been a tremendous boon to the global poor. For example, China has seen poverty rates fall from 64% in 1992 to 12% in 2009. Over 600 million Chinese people have been lifted out of poverty. Bangladesh has seen poverty rates fall from 70% to 43% over the same period. (World Bank figures) Poverty, by the way, is defined as living on less than $1.25 a day, so this is a tremendously big deal. It’s much more important than anything usually discussed on this blog. So I think Loomis’ call to disrupt the global trade system, is, at best, foolish.

    Loomis calls for imposing US labor law on Bangladesh. First, labor law seems to have been irrelevant to the accident. Second, US labor law sucks. Presumably Loomis doesn’t want to force Bangladesh to ban secondary picketing, for example. How about the union shop, which is legal in about 1/2 of US states? But the union shop is banned in otherwise labor-friendly countries such as Sweden and France. Should we impose sanctions on them?

    Finally, according to the AP article, the relevant laws are nothing mentioned by Loomis, but are in fact building codes. Again, US building codes aren’t generally so great, so I don’t know why we’d want to impose them on other countries. Also, US building codes are local affairs, not national laws. Building codes in LA, for example, require earthquake safety, but NY building codes don’t, for obvious reasons.

    Loomis apparently thinks building codes should be international, applying equally to the tundra and the desert, huge cities and tiny villages. OK, I know that isn’t what he thinks. I’m perfectly aware that he’s just BSing about matters he knows nothing about (Bangladesh, building codes, labor law). But ultimately, I think this ignorant lecturing to Bangladeshis, who presumably are perfectly capable of writing building codes and labor laws, is just offensive.

    • sibusisodan says:

      Loomis calls for imposing US labor law on Bangladesh.

      Got a cite for that? I mean, the way I read it, he calls for imposing US labor law on US companies in respect of how they do business abroad, such that the US can hold them responsible in some degree for their complicity in unsafe working practices abroad.

      That’s complex, and fraught with difficulty, but not the same as whatever you are disagreeing with. Unless you’re disagreeing that US companies could negotiate with their foreign suppliers for better standards on worker safety if the motivation was there?

      • Ragout says:

        Loomis also says “Ultimately, we need international standards for factory safety, guaranteed through an international agency that includes vigorous inspections and real financial punishments.” So he wants, at the very least, some kind of international OSHA. Since he mentions “labor law” I assume he also wants to extend America’s lousy labor law internationally. Loomis does nothing to acknowledge how “complex and fraught with difficulty” this would be. Or that he realizes that imposing American standards abroad could mean that millions of Bangladeshis don’t get enough to eat.

        And no, I don’t think US companies could have done anything to prevent the disaster no matter how carefully they monitored their foreign suppliers. The garment factories were just renting space in a building that turned out to shoddily constructed. The garment firms didn’t construct the building or own it. Loomis’ “solution” would do nothing at all to address the real problem.

        • sibusisodan says:

          So he wants, at the very least, some kind of international OSHA. Since he mentions “labor law” I assume he also wants to extend America’s lousy labor law internationally.

          Neither of those assumptions are necessarily warranted.

          Creating, agreeing and enforcing international worker-safety standards != imposing US worker-safety standards on foreign countries

          Loomis does nothing to acknowledge how “complex and fraught with difficulty” this would be.

          That’s interesting, because I assumed that this Loomis character kinda understands that this would be difficult to the point of near-impossible. I wonder whose Loomis-assumptions are more accurate, yours or mine?

          And no, I don’t think US companies could have done anything to prevent the disaster no matter how carefully they monitored their foreign suppliers.

          Why? Under what causal mechanism are they powerless?

          • Ragout says:

            You asked why I think US companies were powerless to prevent the accident. I already explained that, but I’ll try again. In the US, factory safety inspections do not look at whether a building is up-to-code. Building code issues are handeled by local building inspectors, since buildings are best inspected while under construction. For example, the Bangladeshi press has suggested that the problem was the steel in the concrete pillars was too thin. Were the factory owners (who didn’t construct the building) and their American customers supposed to X-ray the building’s support columns before rentintg space?

            • sibusisodan says:

              I already explained that, but I’ll try again.

              Well, the part you haven’t explained is how the unwillingness (understandable, since it would be a nightmare – but it’s not an inability, per se) of US companies to ensure that the premises of their overseas contractors are up to spec has anything to do with this particular case.

              I agree, a generic building in a foreign country – you just have to assume that the local building code is doing its job, unless you have reason to believe the contrary.

              But for this particular building, and this particular owner? From Scott’s follow-up post it appears that anyone giving the matter cursory attention would have to ask some more pressing questions. Such as: are those three floors on top a legal construction? Have the govt inspectors said it’s safe to work in there now?

              As to the issue at hand: you seem to be saying that because this disaster (probably) couldn’t have been prevented (I agree), therefore nothing can be done to reduce the chance of future disasters. Which is silly.

    • jasdye says:

      Poverty, by the way, is defined as living on less than $1.25 a day, so this is a tremendously big deal.

      Ooooh. Wow, that’s just tremendously awesome. A lot of people are making at least a buck and a quarter a day.

      Wouln’t wanna disrupt that gravy train.

  18. [...] * Holding Corporations Responsible for Workplace Deaths. And then there’s Matt “Proud Neoliberal” Yglesias. [...]

  19. [...] think Yglesias’s response to Erik, which suggests that trying to apply more stringent labor standards to American corporations abroad [...]

  20. [...] Yglesias had an odd response to my post yesterday calling for American corporations to be held to American labor standards no matter where in the worl…. Yglesias said that less safe conditions in poorer countries was OK and in fact helped the people [...]

  21. [...] over 180 people shows the need for universal labor standards across all countries. He writes in the Lawyers, Guns and Money blog: Ultimately, we need international standards for factory safety, guaranteed through an [...]

  22. [...] West, Texas To Bangladesh Posted at 5:45 on April 25, 2013 by Andrew Sullivan Erik Loomis argues that the reason we [...]

  23. [...] written yesterday, Erik Loomis of Lawyers, Guns & Money argued that U.S. corporations should be required to follow one uniform set of workplace safety rules regardless of where their factories are located: If a worker dies in a factory that makes clothing [...]

  24. [...] of an appalling accident such as this it is no surprise that people are calling for more to be done. Some even suggest that factories in Bangladesh and other developing countries be held to the same standards that [...]

  25. [...] no, if we’re going to outsource our jobs anyway in this capitalist society, we’re going to need to outsource our safety standards (and that would and should include the right and ability for workers to organize for better [...]

  26. [...] Allison and Jamie discuss all the ways the FBI, media, and police misinformed the public recently,Farea al-Muslimi’s amazing drones testimony, the importance of solidarity in union (and non-union) collective actions, the growth of minimum wage jobs, and a Bangladesh garment factory collapsing. [...]

  27. [...] standards were improved either through implementation of the proposal MY was responding to (“apply U.S. labor law to all American corporations, no matter where they site their factory.”), or, presumably, through ending government corruption and enforcement of current [...]

  28. [...] a building collapse. This kind of consideration leads Erik Loomis to the conclusion that we need a unified global standard for safety[.] [...]

  29. [...] the discussion around my piece calling for international safety standards at the workplace with real enforcement teeth that could implicate American corporations subcontracting with unscrupulous e…, a reader suggested I read Augustine Sedgwick’s March 2012 article in International Labor and [...]

  30. [...] Live at 9:30 on workplace safety. In part at least, it will deal with the piece I wrote last week on applying workplace safety law internationally and holding corporations accountable for deaths cause… Among the other panelists is Shikha Dalmia from Reason, so that could get [...]

  31. [...] activists often fold their critique of sweatshops into a broader critique of globalization. Pushing not only for raised safety standards but also for wages that match those in the developed wo… is a tactic that will have the effect of shutting down developing world manufacturing altogether. [...]

  32. [...] building collapse.* This kind of consideration leads Erik Loomis to the conclusion that we need a unified global standard for safety, by which he does not mean that Bangladeshi levels of workplace safety should be implemented in the [...]

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  34. [...] calling for workers globally to have the same safety standards, and yesterday, isn’t a serious proposal. I’d put the “globally unified workplace [...]

  35. [...] calling for workers globally to have the same safety standards, and yesterday, isn’t a serious proposal. I’d put the “globally unified workplace [...]

  36. [...] building collapse is to tie corporate legal status with their subcontractors’ behavior, making them civilly and criminally responsible for the conditions in factories to which they subcont…. Otherwise, Disney can make a big stink of pulling out of Bangladesh to make themselves look good [...]

  37. [...] if the focus of a development strategy is too limited. Perhaps the aim should go as far as applying domestic labour laws on the companies outsourcing the garment trade to Bangladesh. The cost of doubling wages for Bangladeshi garment workers may be as little as 2p a [...]

  38. OpenPolyAG says:

    My comment below is an assignment for a Business Ethics course, part of the requirement for the assignment is to actually post to a blog. Thanks for the opportunity to use yours.

    I am writing in response to your blog ‘Holding Corporations Responsible for Workplace Deaths’ and your comments regarding American companies’ social responsibility to offshore manufacturing.

    You state in your blog that these companies endeavour to operate with “no responsibility” and “irresponsible corporate policies”.

    The clothing companies you refer to are run by executives that are employed to act on the behalf of their shareholders “Only people can have responsibilities” (Friedman, 1970). The executives responsibility as employees is “to conduct the business in accordance with their desires” (Friedman, 1970) the desires of the company, and not for society as a whole. Friedman famously states “the only social responsibility of business is to maximise profit while remaining within the law and engaging in open and free competition without deception or fraud.” (Friedman, 1970)

    I propose that whether these companies outsource their manufacturing or purchase product from offshore suppliers, provided they are acting within the law, that in their pursuit for profit they are in fact attempting to provide the greatest good to the greatest number of people. Maximising profits for their shareholders, fulfilling a need in society by supplying us (the consumer) with a product at a price we deem acceptable, whilst also creating and sustaining jobs in a highly populated, poor and developing economy. (EconomyWatch, 2010)

    You refer negatively to “keeping costs low” however if these companies had to increase the price of their products to fulfil their fiduciary duty to their shareholders, they would then dissatisfy the end user who would end up paying a higher price. This would in turn lead to a drop in demand, which would lead to reduction in supply and potential job cuts both locally and offshore. In a country ranked number 42 of the world’s poorest nations (infoplease.com, 2013) I would suggest the impact of removing these jobs would be socially irresponsible. I believe that you are incorrect in stating that these companies act with “irresponsible corporate policies” and “no responsibility”.

    The responsibility for enforcing legislation and regulation within a workplace surely sits with that particular country’s Government, in this case Bangladesh. Exports of textiles and garments are the principal source of foreign exchange earnings in Bangladesh. (Wikipedia, 2013). History would indicate the industry itself recognises the importance of maintaining a good relationship with their largest trade partner America (Bangladesh.com, 2013) and has previously made changes within the sector to meet foreign standards. For example “In 1993 employers in Bangladesh’ ready-made garment (RMG) industry dismissed 50,000 children (c. 75 percent of child workers in the textile industry) out of fear of economic reprisals of the imminent passage of the Child Labor Deterrence Act banning importation to the United States of products which are manufactured or mined in whole or in part by children” (Wikipedia,2013).

    Your solution of insisting other countries conform to American labour laws seems somewhat dictatorial to me. As you state “We have a lot of work to do to make our workplaces and communities safe” perhaps it would be more appropriate to support the International Labour Organisation who are currently working with the Bangladesh government, trade unions and factory owners to ensure a “high-level political commitment to enforcement of laws and regulations” in the country. (International Labour Organisation, 2013)

    The collapse of the building in Bangladesh is an absolute tragedy. Those employees were failed, but not by a lack of social responsibility from American companies, they were failed by a chain of individuals who it would appear had a direct responsibility to ensure their safety.

    References:

    Bangladesh.Com. (1995-2013). Exports. Retrieved 22 05, 2013, from http://www.bangladesh.com/exports/

    Economy Watch. (2010, 03 10). Bangladesh. Retrieved 22 05, 2013, from
    http://www.economywatch.com/world_economy/bangladesh/

    Friedman, Milton. (1970, 09 13). The social responsibility of business is to increase its profits.
    Retrieved May 22, 2013, from The New York Times Magazine. New York Times Company.

    Information Please.2013.World’s poorest countries. Retrieved 27 05, 2013 from http://www.infoplease.com/ipa/A0908763.html

    International Labour Organisation. (1996-2013). Press Release. Retrieved 22 05, 2013
    http://www.ilo.org/global/about-the-ilo/media-centre/press-releases/WCMS_211999/lang–en/index.htm).

    Wikipedia. (2013, 05 21). Bangladesh Textile Industry. Retrieved 20 05, 2013, from
    http://en.wikipedia.org/wiki/Bangladesh_textile_industry

  39. [...] activists often fold their critique of sweatshops into a broader critique of globalization. Pushing not only for raised safety standards but also for wages that match those in the developed wo… is a tactic that will have the effect of shutting down developing world manufacturing altogether. [...]

  40. [...] a building collapse.* This kind of consideration leads Erik Loomis to the conclusion that we need a unified global standard for safety, by which he does not mean that Bangladeshi levels of workplace safety should be implemented in the [...]

  41. [...] a building collapse.* This kind of consideration leads Erik Loomis to the conclusion that we need a unified global standard for safety, by which he does not mean that Bangladeshi levels of workplace safety should be implemented in the [...]

  42. [...] building collapse.* This kind of consideration leads Erik Loomis to the conclusion that we need a unified global standard for safety, by which he does not mean that Bangladeshi levels of workplace safety should be implemented in the [...]

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