SHARPS Views of Samsung’s Arguments Concerning
Worker Safety
Jeong-ok Kong, MD, MS
Supporters of Health and Rights of People in the Semiconductor Industry (SHARPs)
January 2012
This note responds to various points raised by Mr. Brendon Gore, European PR Director for
Samsung, in response to the recent nomination of Samsung for a Public Eye Award.
Mr. Gore notes that, “The most unfair and troubling aspect of the nomination is the
insinuation that Samsung has willfully subjected employees to unsafe working conditions.
This is a patently false claim…” Gore continues by stating that, “Samsung takes the
wellbeing of our employees very seriously and we maintain a world-class environment, safety
and health infrastructure as well as rigorous standards in our facilities around the world.”
Unfortunately, the actual data and experience reveal a different reality.
We believe it is extremely important to address Samsung’s improper interpretation of three
scientific studies mentioned by Gore. The annex contains summaries of the studies and their
scientific flaws.
A few points in response to Mr. Gore:
Gore states that, “…two separate studies by the Korea Occupational Safety and Health
Agency and a private consulting team recommended by the Korean Labor Ministry found no
correlation between the workplace environment and employee illnesses.”
This is actually not true. Consider the following:

The Korea Occupational Safety and Health Administration (KOSHA) found that
female workers who produce semiconductors got Non-Hodgkin’s lymphoma about 5
times more than general population. The study included Samsung workers since they
are the largest semiconductor manufacturer in Korea.

KOSHA found elevated risk of leukemia in female workers but could not conclude
firmly because the statistical power was not enough.

KOSHA did not take “healthy worker effect” into account; a fundamental element of
sound epidemiology research.

The “private consulting team” consisted of researchers from Seoul National
University (SNU). The report was never released but in 2010 it was obtained from an
anonymous source. This indicates lack of transparency on the part of the company.

The SNU report indicated that a large number of chemical substances were used in
Samsung manufacturing with poor control over exposure. The SNU report
documented cases of high toxic chemical exposure conditions.
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Gore mentions the study by ENVIRON stating that, “The study was designed according to
scientific standards and was reviewed by an independent, external Scientific Advisory Panel.
The study concluded that Samsung’s current manufacturing operations are well within
accepted standards related to chemical and physical agent exposures, and that the scientific
evidence does not support a link between workplace exposure and the diagnosed cancers in
the cases reviewed.”
This is more difficult to answer since the company refuses to release the study for scientific
examination. However, a few points can be made:

ENVIRON is a consulting firm hired by polluting industries to avoid or lessen
damages in regulatory procedures or lawsuits. A few examples of their work include:
defending Philip Morris in their efforts to de-link second hand smoke and cancer;
defending toxic Chinese drywall concluding no harm to human health; and defending
use of lead in products for lead smelters.

The ENVIRON study was commissioned after Samsung lost a lawsuit judgment
which recognized that leukemia in two female workers in the case was caused by their
occupation at Samsung.

Instead of releasing the study publically, Samsung held an invited-only press
conference. At the press conference, no handout materials were given of the
presentation, and no photos, no cameras and no recording of any kind was allowed.
Only Samsung’s press release material was given out – the same content which has
been repeated in many papers. ENVIRON spent half of their presentation promoting
themselves and then stated their conclusion.

ENVIRON made their “no problems” conclusion by “reconstructing” exposures in six
workers. Ironically and sadly, one of them, Ms. Park Ji-yeon, died of leukemia at age
23 after working in semi-conductor manufacturing at Samsung.

ENVIRON appears to have used the KOSHA study as its basis despite its serious
scientific limitations.
Samsung has a long history of disregarding worker safety and health in spite of serious health
injuries in its manufacturing workforce. This attitude has not changed since SHARPs raised
the issue. Samsung routinely ignores the voices of victims, of social leaders in Korea,1 of
global occupational health professionals and public interest NGOs.2 Some might expect that
1
In December 2010, 591 social leaders including medical and legal professionals, religious leaders, and social
movement leaders made a “Proclamation urging the Samsung Electronics to Take the Responsibility of
Laborers’ Occupational Disease”. You can see the full text at http://www.peoplepower21.org/40805.
2
Since March 2010, Asian Network for the Rights of Occupational Accident Victims, International Campaign
for Responsible Technology, Korean Metal Workers' Union and SHARPs began online petition, "Calling on
Samsung to Accept Responsibility for Occupational Deaths and to Provide Safe and Decent Working
Conditions". Over 9,000 people in Korea and over 1,600 globally signed the petition. ([Korea]
http://it.nodong.net/petition/list.php, [International]
http://www.petitiononline.com/petitions/s4m5ung/signatures)
In April 2010, 62 public interest NGOs and labor unions in the world announced the statement “Enough is
Enough – Groups call for global actions on Workers’ Memorial Day April 28" for supporting the victims of
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Samsung’s Public Eye Award nomination would give Samsung an opportunity to take some
tangible actions to improve the situation, but it is very disappointing to see the same
irresponsible attitude continue.
Annex 1. Summaries of three studies
The Epidemiologic Study by the Korean Occupational Safety and
Health Administration (KOSHA)
A. Background of the Study
Since November 2007, SHARPs strongly demanded that the government must investigate the
working environment of semiconductor industry including Samsung in a transparent and
thorough manner. A lot of protests and visits to the Ministry of Labor resulted in the decision
of the Occupational Safety and Health Research Institute(OSHRI) in the Korean
Occupational Safety and Health Agency(KOSHA) to do an epidemiologic study of
hematopoietic cancer (so-called 'blood cancers' such as leukemia or lymphoma) in the
semiconductor industry in February 2008.
B. Main Results of the Study
Although there were several serious limitations3 in the data, analytical method, and process
of study, there were several meaningful findings. The standardized prevalence rate (SPR)4 of
Non-Hodgkin’s lymphoma of female workers in fabrication (manufacturing) process of the
semiconductor industry was 5.16, which means female workers who produce semiconductors
got Non-Hodgkin’s lymphoma about 5 times more than general population with the same
gender and age. The standardized mortality rate (SMR) and SPR of leukemia in female
semiconductor workers were 1.48 and 1.31 respectively. Although the ‘statistical
significance’ of the slight increase in SMR or SPR of leukemia could not be found in the
study, the result should be interpreted seriously with consideration of ‘Healthy worker effect’,
which was strongly suspected based on the result of the same study.5
Samsung. (http://stopsamsung.wordpress.com/2010/04/17/enough-is-enough-groups-call-for-global-actions-onworkers%e2%80%99-memorial-day-april-28/)
In October 2010, 538 occupational health professionals and practitioners from Asia, Africa, Europe, and
North America signed to "International Petition to support Samsung workers & families", demanding to
Samsung to guarantee “the right-to-know” and "right-to-act" of the workers and civil society on the occupationl
health hazards. They emphasized that Samsung and the Korean government should disclose all the occupational
health studies undertaken for public review. (http://www.gopetition.com/petition/40246.html)
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The limitations of epidemiologic study by OSHRI are; No consideration of ‘Healthy worker effect’, too short
study period, misclassification of ‘case’ and ‘control’, dilution of the ‘real’ risk by mixing the higher risk groups
with lower risk groups, no investigation on the exposure to hazards, dependency on the employers’ resources
without substantial inspection nor participation of victims’ group, and no disclosure of the full text of final
report.
4
The standardized prevalence rate (SPR) and standardized mortality rate (SMR) of hematopoietic cancers in
semiconductor workers were calculated based on the comparison with prevalence and mortality of general
population.
5
The study showed that mortality from all causes of death in semiconductor workers was very lower than that
of general population, 0.53 in male workers and 0.66 in female workers.
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C. Misinterpretation and Distortion of the Results
Samsung argued in its email to the Public Eye Award that “two separate studies by the Korea
Occupational Safety and Health Agency and a private consulting team recommended by the
Korean Labor Ministry found no correlation between the workplace environment and
employee illnesses.”
But this argument is not correct. KOSHA’s finding was “Risk of leukemia was not
statistically significantly elevated in semiconductor workers” as the agency announced in its
press release in December 2008. Actually, the study found elevated risk of leukemia in female
workers but could not conclude firmly because the statistical power was not enough. The
study did not investigate the exposure status of workers in different production processes in
different factories, but just calculated SPR and SMR. That is why KOSHA concluded that
further study with more data of health effects and exposure to hazardous material was needed
to get a clearer conclusion. Therefore, it is impossible for Samsung to say that “no correlation
between the workplace environment and employee illnesses” unless no one in the company
could understand basic epidemiology or the company was trying to distort the scientific
results.
The Exposure Assessment Study by Seoul National University
(SNU)
Samsung mentioned “a private consulting team recommended by the Korean Labor Ministry”
in its email. As we know, there is only one study other than studies by KOSHA or ENVIRON,
the study for consulting on the risk management of three semiconductor companies including
Samsung.
Background of the Study
After finishing the epidemiologic study, KOSHA did not disclose the full text of the final
report to the public. SHARPs and many supporting groups criticized KOSHA and its relevant
ministry, the Ministry of Labor, for their ignoring their obligation to provide information to
the public obligation as governmental bodies. In the middle of 2009, the Ministry of Labor
recommended Samsung and two other major semiconductor companies to get voluntary
consultation by a team of professionals from Seoul National University (SNU). The study
was very important for the victims and their families who needed any information on the
workplace because there would be assessment of exposure which could not have been done in
KOSHA’s study. But the process and the results were not disclosed to anyone. In 2010,
several public interest NGOs got a part of SNU’s report, the exposure assessment of Samsung
semiconductor factories, from an anonymous source. They disclosed the report in public in
September 2010.
Main Results of the Study
The report showed the management of chemicals in Samsung Giheung semiconductor plant
had many problems.
1) Lack of data on substances and date of introduction of chemicals in use
- The Giheung plant (5th line) uses 99 types of chemical products and Samsung Electronics
has never identified these substances. The dates of introduction to the plant for up to 60
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percent of the products are unknown or unreported.
- Seoul National University studied the substances of 99 types of chemicals, 83 types of
which turned out to be single chemical materials. The substances of 10 single chemical
materials were not identified, as the company did not divulge the information due to its trade
secrecy.
- Such an act runs counter to the Samsung’s statement that, “all the chemical materials used
in making chips are identified and known to employees, and the related information was
submitted for an epidemiological survey.”
This discrepancy in reporting demonstrates the insufficient chemical control of the company.
2) The risks of the chemical exposure at Samsung Electronics semiconductor plants
- From February to July 2009, the gas detector was set off 46 times. The causes of the alarms
(46 times in total) were;
* 25 cases (54%): The effect of remaining gases while conducting the Preventive
Maintenance (PM) task even though the standard operating procedure (SOP) was
followed
* 11 cases (24%): A malfunction of the gas detector
* 3 cases: SOP was not followed during the PM task
* 33 cases: The gas leakage occurred when every manufacturing process was running
normal
* 4 cases: Causes unidentified
It was confirmed that even when the SOP was followed, the chemical exposure occurred
while conducting the PM task and normal manufacturing processes.
- Some of the cases indicate that high concentrations of gas, which was 32% of IDLH (HBr,
July 20th, 2009), leaked for an hour and 35 minutes (5,729 seconds). This shows that even
after the gas detector went off and when it exceeded the permitted exposure limit, the leakage
was not automatically shut off but went on more than an hour. The case directly challenges
Samsung’s argument that “when there is a gas leak, the safety device operates automatically.”
- As for the chemical supply system for 99 chemicals in use, it turned out that ‘32 types are
centrally provided through pipe line’, and ‘65 types in bottles and 2 types in drums are
replaced and replenished directly by employees’. These findings confirm that Samsung
Electronics lied by insisting that “gases and organic solvents are replenished through the
central supply system and emptied automatically after the process is finished.”
3) The risks of the organic chemical exposure
- It was confirmed that not only gas but also organic solvents are used in making chips.
- According to the article “The Establishment of the Monitoring System on the Workplace
Environment in the Chip-making, written by Gwansik Lee (Chief Coordinator of the Safety
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Department at the Giheung plant) and published in <Green Samsung> as of summer 2007,
“There is no extra detector system set up for organic solvents…in order to protect the health
of employees from their chronic exposure to odors of organic solvents in low concentration
and to identify and repair the problem of a leakage, the monitoring system on the workplace
environment was established in the plant on June 2007.” In addition, “60% of gases and
chemicals used in making chips are hazardous. In the case of chemical odors occurring these
can spread within 60 seconds due to the cooling water circulation system. Particularly, when
odors contain toxins these can have serious health impacts on employees.” This indicates that
internally Samsung Electronics already recognized the seriousness of the problem of odors:
that is, the organic solvents exposure.
4) The insufficiency of the chemical exposure control
- The Advisory Report shows that the Giheung plant (5th line) controls the exposure levels,
through the working environment measurement, for only 24 types out of the 83 single
chemical materials (28.9%).
- Even though there are the exposure measurement methods in place and standards set for the
five chemicals in use (BF3, Catechol, NH4OH, PGME, Sih4), they were left out from the list
of exposure control for the reason that they are not legally-bounding chemicals.
- In addition, it was pointed that Samsung reveals errors of their working environment
measurement, regarding the number of samples to take, the duration of samples, the period(s)
during the work day and in the year when the samples should be collected, and variation in
workers.
Samsung Electronics should no longer avoid their responsibility for causing leukemia, and
the Korean government and National Assembly should supplement policies and the
control/management system to protect the health and lives of workers in the semiconductor
industry.
By reviewing the Advisory Report on the chemical use and exposure control of the Samsung
Semiconductor plants, we found that
► the risk assessment and management of chemicals are insufficient
► the exposure control system covers only some of the chemicals that the company uses
► there exist the risks of the chemical exposure at the semiconductor plants
► there were cases of the highly toxic chemical exposure.
These findings run counter to Samsung Electronics' current stance and reveal that the
company has serious problems in their chemical exposure control. Therefore, Samsung
Electronics should no longer avoid their responsibility for causing leukemia among their
employees, and the Korean government and National Assembly should supplement policies
and the control/management system to protect the health and lives of workers in the
semiconductor industry.
In this regard, it is required that
► the cases of employees contracting leukemia at Samsung Electronics should be recognized
as occupational diseases
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► the ailing workers and the families of the deceased should be given appropriate
compensations, and a better workplace environment should be provided
► the government should make it obligatory to disclose information on hazardous chemicals
► the National Assembly should supplement the Industrial Accident Compensation
Insurance Act (i.e. easing the eligibility criteria for making claims relating to operational
disease compensation)
► The Occupational Safety and Health Act should be amended to broaden the coverage of
the chemical management and to strengthen exposure controls.
To download this report, please visit The Committee for Fair Labor Society, PSPD
at http://blog.peoplepower21.org/labor
Misinterpretation and Distortion of the Results
As you can see from above, the result of SNU’s study did not support Samsung’s argument,
“a private consulting team recommended by the Korean Labor Ministry found no correlation
between the workplace environment and employee illnesses.” Rather, it shows that there are
so many flaws in chemical management in Samsung even under the “world-class”
environment as the company argues.
The Environ Study
Background of the Study
Korea has a social insurance system of workers compensation managed by the Korea
Workers’ Compensation and Welfare Service (KCOMWEL), which is a government body,
affiliated the Ministry of Labor. But KCOMWEL has been refusing to compensate Samsung
cancer victims. In January 2010, six leukemia and lymphoma cancer victims in Samsung
semiconductor factories filed a lawsuit against KCOMWEL. Samsung Electronics intervened
in the lawsuit with many lawyers from a giant law firm to prevent workers from getting
compensation from the government. In the end of June 2011, the Court decided to recognize
work-relatedness of illnesses in two female workers who developed leukemia in the Samsung
Giheung factory saying, “it can still be inferred that her exposure to various toxic chemicals
during her work in the Giheung plant Line number 3 induced or at least accelerated the
development of her disease; thus, a proximate causal relation seems considerable.” Samsung
hired Environ to contradict these findings and in July 2011 held an invited-only press
conference at its Giheung factory. Because Samsung has refused to make the Environ report
public, the description below is only based on the record of the press conference. Note that
ENVIRON is a consulting firm hired by polluting industries to avoid or lessen damages in
regulatory procedures or lawsuits. A few examples of their work include: defending Philip
Morris in their efforts to de-link second hand smoke and cancer; defending toxic Chinese
drywall concluding no harm to human health; and defending use of lead in products for lead
smelters.
Main Results of the Study
At the ENVIRON press conference on July 14, 10 am there were more than 100 media
people in a huge conference room. The MC, Kim Joon-sik, the Communications Team (PR)
leader of Samsung, gave an introduction with the background and goal of the event. He said
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the intention was to reveal the facts accurately, and that the results of the study were global
top level, and that Samsung could guarantee the study’s objectivity and transparency. He said,
“We tried to check by all scientific methods on the debate re: Samsung Semiconductors’
working environment,” and added “We make today’s event to keep our promise to reveal the
results transparently.”
In fact the session was to be from 10 a.m. to 11 a.m., with 40 minutes for presentation and 20
minutes for Q&A. Of the 40 minutes, however, 15-20 minutes were spent to show a PR video
of ENVIRON, basically showing how great, big and excellent ENVIRON is, and what it has
achieved. The CEO of ENVIRON, Mr. Stephen T. Washburn, introduced the results of the
study, gave an overview and summarized the findings. According to him, the general
conclusions were basically these two:
1) Occupational exposure in manufacturing areas, in the current working environment. By
their evaluation, these were significantly below the norm levels developed by some
agencies.
2) According to studies done in the past, they reconstructed the working environment and
the exposure levels of workers under past working conditions, based on the evidence of six
workers with cancer, to determine their level of occupational exposure to carcinogens – i.e.,
to assess the likelihood that workplace exposure of previous times did increase the risk of
cancer in those six specific workers. By the evaluation of ENVIRON, the scientific data did
not support a link between workplace exposure and the diagnosed cancers.
Those six workers are the victims who had joined in the lawsuit against Samsung. One had
dropped out, which was Park Ji-yeon, after Samsung had offered them some payment. Ms.
Park died of leukemia at age 23 after working in semi-conductor manufacturing at Samsung.
At the press conference, no handout materials were given of the presentation, and no photos,
no cameras and no recording of any kind was allowed. At the end, only Samsung’s press
release material was given out – the same content which has been repeated in many papers
and internet articles now, saying that the scientific evidence proved no relationship between
the cancers and the Samsung workplace. Even the photos in the media articles, are all only
what Samsung had provided. The presentation was also written in English, and all was
spoken in English; although there was Korean translation, it was still fast, and the whole
press conference did not show that Samsung was sincerely trying to share the information so
that it could be well understood.
It is difficult to comment further on the study since the company refuses to release it.
Misinterpretation and Distortion of the Results
As noted, the study has not been released. However, it appeared to “reconstruct” worker
exposure using the KOSHA study – despite the limitations mentioned above making it
inappropriate for use.
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