At WD, we recognize the need to preserve and protect the earth’s vital natural resources. We believe that part of being a good corporate citizen and a good neighbor is maintaining or improving the cleanliness of the air, water and land of the locations in which we operate. As a result, our facilities throughout the world comply with applicable environmental laws and regulations, and each has developed and implemented a comprehensive set of practices designed to ensure continued compliance. In addition, we continually review our operations and processes to identify opportunities which allow us to reduce or recycle byproducts generated by our activities. We are also concerned about protecting the natural resources of the communities in which our products are sold and used. We review the content of the products we manufacture and have established programs to eliminate or phase out the use of certain materials restricted by international legislation. We have also begun offering for sale a line of products specifically designed to reduce the environmental impact resulting from their use.
All of our manufacturing facilities in Asia have environmental management systems in place which are ISO 14001 certified. Each facility has a comprehensive policy and set of supporting procedures addressing environmental permits, pollution prevention, hazardous substances, wastewater and solid wastes, airborne emissions and product content. Our policies express a commitment to continued improvement, and to this end, we review the status of our environmental management systems at least annually.
All of our manufacturing facilities have environmental specialists onsite, and we provide training programs on environmental practices for employees whose job duties impact our environmental management systems. In addition, all of our facilities provide clear written direction to all employees and workers in languages appropriate to each site regarding requirements and responsibilities for environmental practices in accordance with company policy.
Compliance with RoHS and WEEE Directives
WD products manufactured and sold worldwide after August 1, 2005, meet or exceed Restriction of Hazardous Substances (RoHS) compliance requirements as mandated by the European Union for electrical and electronic products. The RoHS Directive 2002/95/EC of the European Parliament, which was effective in the EU beginning July 1, 2006, aims to protect human health and the environment by restricting the use of certain hazardous substances in new equipment, and consists of restrictions on lead, mercury, cadmium, and other substances. The Waste Electrical and Electronic Equipment (WEEE) directive was developed to minimize the disposal of electrical and electronic equipment into landfills. WD hard drive products and packaging include the WEEE symbol in support of this directive.
WD has conducted and continues to conduct very extensive tests regarding use of environmental compliant material on all our components. WD requires all component suppliers meet WD’s environmental Specification, titled “WD’s Environmental Guidelines for Materials, Components and Products.” This 20-page Specification sets forth the maximum threshold limits for restricted, prohibited and managed substances and requires suppliers to adhere to all applicable laws. In addition, the Specification states that all WD suppliers and sub-suppliers will be expected to complete environmental declaration forms for all new materials and components based on a combination of knowledge of their incoming raw materials, process review and their own analytical testing and certification data. Suppliers are required to maintain documented records, made available to Western Digital, indicating which measures are used to ensure compliance to the Specification. We review all suppliers’ Declarations of compliance with WD’s environmental Specification during the launch of every new hard drive program and also track this together with a 3rd party Analytical lab data by component in our Environmental Compliance database. In addition, we maintain strict requirements with respect to Supplier Process/Material Change requests. Suppliers are also required to keep records of their in process tests to ensure compliance to the approved Process Management Plan and
approved materials. These are regularly audited by WD.
Greenhouse Gas Emissions
Global climate change, caused by increasing concentrations of atmospheric carbon dioxide, is one of the most significant concerns facing our world today. As a corporate citizen, WD is particularly sensitive to the effects of global climate change. The need to understand the science of climate change and to formulate appropriate policy to address scientific findings is intensifying with each passing day. To view WD’s Greenhouse Gas report, click here.
Q&A for Environmental and Hazardous Materials
QDoes Western Digital have management representatives responsible for assuring compliance with respect to environmental laws, regulations and codes? AYes. Western Digital has management representatives at all critical sites whose core responsibility is monitoring, communicating and training employees in all aspects of environmental compliance as related to the specific facility.
QDo Western Digital’s facilities receive periodic audits of environmental practices in order to assess conformance with regulatory and other requirements? AYes. Western Digital conducts both internal and external audits to evaluate its compliance with applicable environmental laws and regulations.
QWhat types of policies, rules or procedures does Western Digital maintain relative to environmental programs? AWestern Digital maintains environmental polices, rules and/or procedures which address environmental permits, pollution prevention, hazardous substances, liquid waste, solid waste, air emission controls and product content. The substance of these programs is delivered to our employee population utilizing various formats including in-person training, web-based training, face-to-face communications, postings and bulletins. All programs are communicated in
various languages appropriate to the employee population of each of our facilities to insure that all employees have a clear understanding of the programs.
QDoes Western Digital place contractual requirements on its suppliers to be in compliance with environmental laws, regulations and codes of conduct? AYes. Whenever possible, Western Digital executes contracts with its suppliers which require, among other things, that the suppliers comply with all relevant and applicable environmental laws and regulations.
QIs Western Digital required to maintain certain environmental permits in the operations of its facilities? AYes. Western Digital is required to maintain certain environmental permits as related to the operations of its facilities. Based on the geography and the operations, permits may be required for chemical handling and storage, waste treatment, wastewater discharge, air emissions and storage tanks.
QDoes Western Digital make available Material Data Safety Sheets (MSDS) to workers that handle chemicals? AYes. Western Digital makes MSDS sheets available to employees onsite at all of its facilities. In addition, Western Digital contracts for OnCall MSDS information domestically.
QDoes Western Digital use hazardous materials in its manufacturing process? AYes. Western Digital utilizes a variety of hazardous materials in its manufacturing operations. Classifications of hazardous materials include flammables, combustibles, corrosives and toxic gases.
QHow does Western Digital store chemicals at its facilities? AWestern Digital stores all hazardous materials in compliance with applicable laws and regulations. Storage areas are secured and covered containing various types of containers including bottles, cylinders, drums and other approved vessels with the appropriate type of labeling and containment as required or recommended by codes, regulations and other authorities.
QDoes Western Digital generate wastes that are classified as hazardous wastes? AYes. Western Digital generates various types and quantities of hazardous wastes. All wastes are disposed of in compliance with applicable law, and we regularly audit our hazardous waste haulers and their facilities.
QDoes Western Digital have a program or procedures for management of hazardous waste? AYes. Western Digital has a variety of programs and procedures for the management of its hazardous waste. These include monitoring, characterization, treatment, conversion and disposition. All wastes are disposed of in compliance with applicable law, and we regularly audit our hazardous waste haulers and their facilities.
QDoes Western Digital have a site specific management system registered to ISO 14001, OSHAS 18001, or other recognized health and safety or environmental management standards? AYes. Western Digital factories in Malaysia and Thailand maintain management systems which have earned the ISO 14001 and OSHAS 18001 designation.
QDoes Western Digital have programs or procedures to reduce or eliminate pollution and waste in its operations? AWestern Digital is always looking for ways to eliminate or reduce pollution or waste generated by our operations. Among the programs we consider are solvent re-use or elimination, process waste and emission minimization, packaging reduction, recycling or elimination as well as reductions in greenhouse gas (GHG) emissions.
QDoes Western Digital have programs or procedures to reduce the use of energy, water and other natural resources in its operations? AWestern Digital is always looking for ways to reduce energy and other natural resource consumption in our operations. Among the programs we consider are evaluating product or process design modifications, improvement in energy efficiency of process, and the evaluation of construction, maintenance and land use programs.
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