Study of A Proposal (and its alternatives) to Amend the Textile Labelling and Advertising Regulations: Applying the Conference Board’s Optimal Policy Mix Framework

Appendix G: OPM Assessment Rating Details

This appendix presents the result of the criteria-based ratings of the various options generated by stakeholders as part of the OPM process, as well as the importance ratings assigned to each criterion. Twenty-three criterion in 4 categories were considered by stakeholders. Although the Optimal Policy Mix framework forced stakeholders to explicitly assess the effectiveness of the policy options through the use of criteria, it did not require from them a concensus on the ratings. In the summary tables that report on importance (Text Boxes 4, 6, 8 and 10), the importance ratings (L, M, H) refer to criteria.²⁷ In the summary boxes that report on the effectiveness of alternative proposals (Text Boxes 5, 7, 9, 11), the effectiveness ratings (L, M, H) refer to alternative proposals.²⁸

Text Box 4

Identification Criteria (questions that describe how each instrument helps achieve the objective)	Degree of importance of criterion (low, medium, high)
Ability to correctly identify sweatshops: Are companies employing sub-standard labour practices readily identifiable or are there different opinions depending on the stakeholder?	L / H
Quality of the Information: Are the sometimes-complex apparel supply chains accurately reported? Are labour standards readily identifiable? Is there a chance of misinformation?	M / H
Geographic dispersion: Are the sources of sweatshops concentrated (e.g., in particular regions or countries) or dispersed (e.g., can be found anywhere and anyplace)? Are impacts geographically dispersed or concentrated (e.g., is it certain types of apparel from certain regions or all types)?	L
Ability to respond: Once substandard practices have been identified, are companies likely to respond positively to address issues (e.g., new policies, training, improved conditions) or do companies cease to exist (go out of business, bankruptcy, disappear) or do they change locations/names?	M / H

Text Box 5

Identification Criteria (questions that describe how each instrument help achieve the objective)	Mandatory disclosure (ETAG Proposal)	Procurement Initiative (similar to the university and cities initiatives)	Institutional practices codes of conduct	Certification of suppliers (example, ISO or FLA type process)	Bilateral Labour Agreements (in parallel with trade agreements)	Regular reporting (specific companies)
Ability to correctly identify sweatshops: Are companies employing substandard labour practices readily identifiable or are there different opinions depending on the stakeholder?	N/A	L M (Audits and Reports)	L M (Audits and Reports)	L M	L	M
Quality of the Information: Are the sometimes-complex apparel supply chains accurately reported? Are labour standards readily identifiable?	L H (Shady deals, illegal trans-shipments)	M H	M H (Depends on content & audit)	M H (Depends on content & audit)	L	L H (Quality And Frequency)
Geographic dispersion: Are the sources of sweatshops concentrated (e.g., in particular regions or countries) or dispersed (e.g., can be found anywhere and anyplace)? Are impacts geographically dispersed or concentrated (e.g., is it certain types of apparel from certain regions or all types)?	H	L	L	L	L	L
Ability to respond: Once substandard practices have been identified, are companies likely to respond positively to address issues (e.g., new policies, training, improved conditions) or do companies cease to exist (go out of business, bankruptcy, disappear) or do they change locations/names?	L M	H	L M	M H	L (Remedies / enforcement)	M - H

 

Text Box 6

Technical Criteria (questions that describe how each instrument help achieve the objective)	Degree of importance of criterion (low, medium, high)
Level of change, innovation and turnover: Does the apparel industry undergo high levels of change in production/manufacturing sources (e.g., new suppliers are introduced every day)?	M-H
Structure of the industry: Are practices homogeneous throughout the industry or are practices of small firms different from those of large firms?	H
Existence of appropriate information: How long are supply chains in this industry? How many suppliers are there? Is there an easy way to verify and share information about labour practices used by those suppliers (e.g., relatively homogenous information sources) or is a wide variety of means being used (e.g., hearsay, media reports, list of suppliers)?	H
Availability of alternative suppliers: Are new, more acceptable suppliers readily available (e.g., purchasers can cut and run) or is it economically feasible and/or are existing suppliers willing and able to change (purchasers will work with them)?	M-H
Government administrative capacity: Does government possess the administrative capacity to accurately capture information about suppliers and manufacturers, or must it rely on the word of others, or implement more complex approaches (such as voluntary measures, MOU s, legal agreements, fiscal instruments)? Are shipments accurately reported?	L-H
Impact mitigation: Does the approach contribute to impact prevention, better labour standards, or impact reduction?	H

 

Text Box 7

Technical Criteria (questions that describe how each instrument help achieve the objective)	Mandatory disclosure (ETAG Proposal)	Procurement Initiative (similar to the universities and cities initiatives)	Institutional practices codes of conduct	Certification of suppliers (example, ISO or FLA type process)	Bilateral Labour Agreements (in parallel with trade agreements)	Regular reporting (specific companies)
Level of change, innovation and turnover: Does the apparel industry undergo high levels of change in production / manufacturing sources (e.g., new suppliers are introduced every day)?	M	M	M	L	L	L M
Structure of the industry: Are practices homogeneous throughout the industry or are practices of small firms different from those of large firms?	H	M H	M H	H	M H	H
Existence of appropriate information: How long are supply chains in this industry? How many suppliers are there? Is there an easy way to verify and share information about labour practices used by those suppliers (e.g., relatively homogenous information sources) or are a wide variety of means being used (e.g., hearsay, media reports, list of suppliers)?	L H	M H	L H	M H	L H	M H Depends on third-party credibility
Availability of alternative suppliers: Are new, more acceptable suppliers readily available (e.g., purchasers can cut and run) or is it economically feasible and/or are existing suppliers willing and able to change (purchasers will work with them)?	N/A	L H	L H	L H	L	L M
Government administrative capacity: Does government possess the administrative capacity to accurately capture information about suppliers and manufacturers, or must it rely on the word of others, or implement more complex approaches (such as voluntary measures, Memorandums of Understanding (MOUs), legal agreements, fiscal instruments)? Are shipments accurately reported?	M H	M H	M H	M H	M H	M H
Impact mitigation: Does the approach contribute to impact prevention, better labour standards or impact reduction?	H	L	L	L	L	L

 

Text Box 8

Socio-political Criteria (questions that describe how each instrument help achieve the objective)	Status of Criterion (degree of importance of criterion,low, medium, high)
Employee dislocations: What are the impacts on local workforce of identification of sweatshops and can they be improved?	L on very serious issues, M & H on less serious issues
Responsibility of government vs self determination for other nations: Is there strong stakeholder or public pressure that the government make decisions about labour practices in other jurisdictions?	L globally M domestically
Public/stakeholder pressure: Is there strong stakeholder or public pressure to resolve this issue in Canada or is a global solution required?	L H it is uneven
Level of political will: Is there a high level of political will to deal with this issue?	M H
Reputation /image : Is there a reputation and/or image benefit to particular manufacturers/ suppliers in undertaking labour standards reviews and reforms?	M H
Drivers / motivators for apparel industry: Are there incentives/reasons for stakeholders to cooperate well or take a leading cooperation/leadership role in dealing with this issue?	H

 

Text Box 9

Socio-political Criteria (questions that describe how each instrument help achieve the objective)	Mandatory disclosure (ETAG Proposal)	Procurement Initiative (similar to the universities' and cities' initiatives)	Institutional practices codes of conduct	Certification of suppliers (example, ISO or FLA type process)	Bilateral Labour Agreements (in parallel with trade agreements)	Regular reporting (specific companies)
Employee dislocations: What are the impacts on the local workforce of identification of sweatshops and can they be improved?	L	L H Depending on reaction	L H Depending on reaction	L H	H if better than NAFTA	L
Responsibility of government vs self determination for other nations: Is there strong stakeholder or public pressure that the government make decisions about labour practices in other jurisdictions?	L	L	L	L	L M	L
Public/stakeholder pressure: Is there strong stakeholder or public pressure to resolve this issue in Canada or is a global solution required?	H	M
Level of political will: Is there a high level of political will to deal with this issue?					L M
Reputation/image : Is there a reputation and/or image benefit to particular manufacturers/suppliers in undertaking labour standards reviews and reforms?	M H	H	H	H	L H	H
Drivers/motivators for apparel industry: Are there incentives/reasons for stakeholders to cooperate well or take a leading co-operation/leadership role in dealing with this issue?	M H Negative implications	M H Positive implications	M	M	L	M

 

Text Box 10

Economic Criteria (questions that describe howeach instrument helps achieve the objective)	Status of Criteria (degree of importance of criteria,low, medium, high)
Level of risk : Does the problem entail a high level of risk to society or local economic well being if not dealt with?	L globally for society and H for local economy
Potential for trade action: Is there likely to be trade retaliation for government or industry action on this issue?	M H
Market structure: Is the apparel market structure competitive? For example, are there many firms? Is there price sensitivity?	H
Benefit and cost of solutions : To what extent does the proposed solution provide a net economic benefit to:
workers?	H
communities?	H
manufacturers?	M H
retailers?	M H
consumers?	M H
governments?	L H
Consumer contact/industry visibility : Are the stakeholders/apparel industry players visible in the public eye?	M
Transparency of compliance: Is compliance by individual stakeholders/resource users easy to determine? For example, are results auditable?	H

 

Text Box 11

Economic Criteria (questions that describe how each instrument help achieve the objective)	Mandatory disclosure (ETAG Proposal)	Procurement Initiative (similar to the university and cities initiatives)	Institutional practices codes of conduct	Certification of suppliers (example, ISO or FLA type process)	Bilateral Labour Agreements (in parallel with trade agreements)	Regular reporting (specific companies)
Level of risk : Does the problem entail a high level of risk to society or local economic well being if not dealt with?	L H	L M	L
Potential for trade action: Is there likely to be trade retaliation for government or industry action on this issue?	N/A or H	N/A or L	N/A or L	N/A or L	L H	N/A
Market structure : Is the apparel market structure competitive? For example, are there many firms? Is there price sensitivity?	M H	L	H	M	L H	L
Benefit and cost of solutions : To what extent does the proposed solution provide a net economic benefit to:
workers?	H (Indirectly)	M	M	H	M	M
communities?	L	M	L	L	M
manufacturers?	L H	M	H	H	L	M
retailers?	L H	M	H	H	L
consumers?	H	M	M	H	M	M
governments?	L	M	L	L	M	M
Consumer contact/industry visibility : Are the stakeholders/apparel industry players visible in the public eye?	L M	M H (Depending on verification)	M H	L H	L M	L M
Transparency of compliance: Is compliance by individual stakeholders/resource users easy to determine? For example, are results auditable?	M	L M	L M	L M	L M	L M

 

---

²⁷ In boxes that summarize the importance of criteria (Boxes 4, 6, 8 and 10), the importance ratings (L, M, H) refers to the importance of each criterion to the achievement of the policy objective. A "L" rating suggests a criterion of lesser importance, whereas a "H" rating reflects a very important criteria. The OPM process did not force stakeholders to agree on a single rating for each criterion (although this happened in many cases). Where stakeholders could not agree, the range of ratings is specified.

²⁸ In boxes that summarize the effectiveness ratings of alternative proposals (Boxes 5, 7, 9 and 11), the importance ratings refer to the effectiveness with which particular alternative proposals contribute to maximizing the policy objective. Stakeholders rated the alternative proposals as highly effective (H), less effective (L) or somewhere in the middle (M). In cases where the proposal did not address the criteria at all, a rating of not applicable (N/A) was given. Where stakeholders could not agree, the range of ratings is specified.