In 2020, as the world grappled with the COVID-19 pandemic, critical shipments from a major medical glove maker sat unused at a U.S. port for months. Despite the overwhelming demand for personal protective equipment (PPE), federal law blocked these gloves from entering the U.S. market due to evidence of forced labor in their production. Reports from the media and federal sources (PDF) revealed harsh and exploitative conditions faced by migrant workers where the gloves were made. This incident was part of a broader pattern, with several shipments of disposable gloves being held at U.S. ports under a Withhold Release Order (WRO) over concerns related to forced labor.
Forced labor is the practice of compelling a person to provide labor or services through force, fraud or coercion. The International Labor Organization estimates that 27.6 million people worldwide are subjected to forced labor across various industries. The WROs against gloves show that the healthcare sector is not exempt from this abuse. Further examples of forced labor contaminating healthcare supply chains include reports of coercion of persecuted groups to produce medical devices, PPE, and raw materials for other healthcare products. Recently, the U.S. Department of Labor added aluminum and polyvinyl chloride from China to its 2024 List of Goods Produced by Child Labor or Forced Labor (PDF)—both of which are common materials in medical equipment.
In the wake of the WROs against gloves, the U.S. Government committed to tackling forced labor in its National Strategy for a Resilient Public Health Supply Chain. (PDF) Related commitments are outlined in the National Action Plan to Combat Human Trafficking (PDF) and the National Action Plan for Responsible Business Conduct.
To implement these commitments, the Administration for Children and Families Office on Trafficking in Persons, within the U.S. Department of Health and Human Services, established a public-private working group in 2023. The Joint Forced Labor Working Group is co-chaired by a major healthcare provider and includes representatives from federal agencies, industries involved in healthcare procurement, anti-trafficking professionals, and individuals with lived experience of forced labor.
In October 2024, the Working Group released guidance for the health care and public health sectors regarding forced labor risks in supply chains. This marked the first set of recommendations (PDF) jointly endorsed by both public and private sectors, specifically designed to help healthcare organizations mitigate forced labor risks associated with purchased goods and services. Key recommendations include:
- Develop and adopt policies, codes of conduct, and contract language on forced labor to integrate into a broader program of environmental, social, and governance due diligence.
- Set metrics for measuring compliance and regularly review policies to incorporate evolving best practices and lessons learned.
- Assess forced labor risk by product or service, geography, and size of the contract.
- In high-risk supply chains, map components of production and labor by verifying data with suppliers rather than relying solely on tech platforms.
Tools for implementing these recommendations, including online, on-demand training, are available on the Working Group’s website.