Rabu, 15 Februari 2012

Report on the Condition of OSH in Indonesia_2011

“The Murder in That Workplace Still Continues to Happen”


This report was compiled by the Local Initiative for OSH Network, based in Bandung, Indonesia. Information contained in this report was collected from media reports, interviews with workers or union representatives, and government reports.

During 2011, there were many incidents of workers being harmed in the workplace in Indonesia. Ironically, worker injuries and illnesses continue to occur, even though the government promotes safety with banner campaigns and National Occupational Safety and Health Month (Bulan K3 Nasional). The workplace injuries and illnesses recorded in the mass media, however, show that the rate of workplace accidents in Indonesia is high. Furthermore, most of the work related accident victims do not get adequate compensation.

Ongoing issues remain with OSH in Indonesia, such as unprotected workers exposed to toxic and hazardous materials in production process, weak law enforcement of existing regulations, and lack of inspection by government officials. These conditions continue almost every year without any significant breakthrough to improve the safety of the workers. Also, every year the number of work-accidents in Indonesia remains very high, with the number of victims of deaths and disabilities in the thousands. This perpetuates the disturbing image that the workplace is the site of slowly-done [CU1] murder against the workers.[CU2]

The Condition in the Field

Workplace death rates are high and are under-reported. An official Indonesian government statement says that more than nine people die each day in workplace accidents. The actual death rate is expected to be far higher because the government social security agency, PT Jamsostek, bases its calculations only on the workplace accidents that happen to PT Jomostek members.[1] Many companies do not register their workers with PT Jamsostek, so the number of deaths reported to the government is low. This was acknowledged by the Department of Labor of Bogor regency: out of the two thousand industrial districts of Bogor, only two companies periodically report their OSH activities to the agency.[2]

The number of accidents reported by the Government is as follows:

Table 1

Work-Accident Cases in Indonesia from the year 2001-2010


Total Number of Workplace Accidents

# Deaths

# Full-Disability

# Partial-Disabilitiy

# Functional-Disabilities[CU3]

# Recuperated


































































1.965 (+)

31 (+)

2.313 (+)

3.662 (+)

78.722 (+)

Source: PT. Jamsostek (Social Security Agency) and the Ministry of Manpower Affairs of Indonesia Republic

On average, there are nearly 100,000 occupational injury cases per year. The data above is taken from 9 million formal workers who are members of the Jamsostek program. This means that there are 90 million Indonesian workers whose health and work-safety are not recorded in the above statistics. The majority of unrecorded workers are from the informal sector, where workers have poorer working relationships than formal workers do, both in terms of wages and working conditions.[3] It is expected that these figures would be much higher if all workers were included in the data.

In some areas in Indonesia, in the first half of the 2011, there was an increased incident rate compared to previous years. For example, in Karawang through May 2011 has occurred as many as 1,355 cases of occupational injuries consisted of the following cases, the production process as many as 883 accident cases, traffic accidents as many as 472 cases, deaths at the workplace as many as four cases and deaths on the highway as many as 12 cases[4]. While the occupational accident rate in East Java in August 2011 was up to 9,846 cases[5].[CU4]

When viewed by business sector, the majority of workplace accidents occur in construction and manufacturing. In 2010, The Ministry of Manpower and Transmigration recorded that workplace accidents were dominated by construction services (31.9%)and the manufacturing industry (31.6%), with lesser percentages from transportation (9.3%), mining (2.6%), forestry (3.6%), and others (20%)[6].

Table 2

The Percentage of Work-Accidents Based on Each Sector

Source: PT. Jamsostek (Social Security Agency) and the Ministry of Manpower Affairs of Indonesia Republic

Worker fatigue, ignorance of safety procedures, and lack of personal protective equipment cause injuries and deaths in the construction sector. The high number of accidents in the construction services sector can be attributed to the long workshifts and strict timelines for construction completion. Workers often extend their shift to 12 or 16 hours per day, sometimes even working 24 hour shifts. This causes fatigue of workers so they can’t function well. In addition, the lack of employee protective equipment and dissemination of the importance of OSH in the workplace still occurs. Many occupational accidents in the construction services sector occur because workers are killed falling from a height; they do not use fall protection equipment or fall barriers are not present. Examples of recent construction accidents are the one dead and two injured workers on the Trans Studio building in Bandung[7], the two workers who fell down from the 9th floor of a building project in Surabaya[8], and another worker who died after falling from the 15th floor of apartment development project in Depok[9].

In the manufacturing industry sector, production machine operators are the most vulnerable victims to workplace accidents. An example is Agus (22 yrs), the production machine operator of PT Bintang Fajar, Jakarta, who died after being crushed by a paper pressing machine[10]. Also, Yayan Rohyana (32 yr) worker at PT PMTI, Bandung regency, died after a dye machine that was being transported upward on the forklift , fell off and crushed him.[11]

Another cause of worker deaths, which was quite common and well-known in the year 2011, was the high number of workers being poisoned by food provided by employers. At PT Newmont Nusa Tenggara (PT NTT), 50 workers became the victims of food poisoning; this also happened at PT Shyang Ju Fung where 500 people were killed . Finally, at PT KMK Global Tangerang, thousands of workers lost their lives . In all cases, the employees were poisoned after consuming food provided by the company.

In the mining sector, many accidents occurred in mines in the informal sector, where landowners send untrained workers into mines to gather precious metals. Many workers were killed by being buried in landslides. . Referring to the records of Bangka Post from January to July 2011 in the province of Bangka, 21 accidents occurred in these mines and 26 people lost theirlives. Notes from Wahana Lingkungan Hidup Organization, in the Bangka Province, state that more than 150 people die each year related to the mining of tin ore in Bangka Belitung province[12].

The government has not disclosed the data on the number of victims of occupational diseases, as provided in Law No. 22 of 1993 concerning the Disease Due to Work, which defines the types of injuries and illnesses that need to be reported. However, one thing for sure is that the figure is very high given the low rate of implementation of OSH management systems by the companies in Indonesia as well as the widespread use of hazardous and toxic materials in the production process.

The information above helps confirm the 2008 International Labor Organization (ILO) report, which identified Indonesia as the country with the second largest number of work accidents in the world of the 53 countries surveyed[13].


BOX 1: The Story of a Victim

In October 2010, Samsuri (36 years) should be resting at home, but instead he is working through pain to support to his family- He was diagnosed by a hospital doctor Medirusa Bekasi with the diagnosis of occupational back injury due to his shifting spine.. Already the worker who had worked more than 13 years at PT Rapipack had already undergone dozens of physical therapy and other treatments in an attempt to restore his health.

Samsuri had been working in cardboard box factories since 1997 and served as an operator, with his main task of moving the production of raw materials from storage to the place of production. Every day he had to lift material or sago flour weighing 50 kg and the total daily weighing 2.4 tons.

In December 1999, he had a workplace accident and fell off a 4 meter ladder. As a result, he broke his arm, fractured his right hand in three pieces and experienced hip injuries. For more than three months, he was in outpatient treatment until he was finally declared fully recovered and able to work again.

In 2007, he often felt a sore hip or spine. He thought that the pain was only caused by fatigue. At that time, he was seeing a general practitioner physician. With this pain, the doctor gave medicine and asked for a break. His hip pain was getting worse, he could not even walk, so the general practitioner referred him to a specialist of neurological, orthopedic and rehabilitation medicine in April 2009.

It was discovered that his spine had shifted and the bottom spine collided with the tail bone; the bottom of the spine was worn and tail of the spine was pinched. He had been an outpatient at the Medirusa Hospital, but the physician team recommended surgery to remount the hinges on two vertebrae so that his spine could be restored to its original position. The opinion of the orthopedic and neurological doctors, as well as the rehabilitation medic, was that the 36-year-old man had an occupational injury. Such operations are very costly, however, approximately IDR 380 million (and it is only 50% guaranteed to heal).

The doctors’ recommendation was conveyed to the company, and the result was predictable in that the company objected to paying for such an operation. Social Security could not bear the entire cost due to the maximum limit for handling work-accidents of labor cost is only IDR 12 million. Social Security reprimanded the doctors who dealt with the patient, questioning the length of hospitalization, the course of physiotherapy and the cost of expensive drugs. To address the concerns of Social Security, the doctors and the hospital invited the employee and the Social Security agency and explained how the injury was an occupational disease and how the recommended procedures and medicine were the standard recommended by Jamsostek (Social Security Agency)

What happened to him traumatized his family because the pain did not heal and the company did not take responsibility for his care or surgery. Samsuri said that since he first experienced the pain, his work productivity has decreased, and he can no longer lift and uphold the burden of more than 5 kg.Samsuri must continue to work the best he can to support his family, but he is in constant pain.

In Samsuri’s current workplace, there are 3 people with the same occupational disease diagnosis. Dozens of others have experienced the same symptoms, especially those aged 30 years old with 7 years of experience working in corrugating machine and boiler operation. He stated that the union at his workplace lacks OSH advocacy. The union only advocates issues regarding personal protective equipment (PPE). In the future he plans to pursue his case by presenting it to the realm of law and the courts.

Ripple of Resistance

Based on the monitoring of Local Initiative for OSH Network Indonesia, reviews from the mass media and discussions with some union activists at the regional level, accidents and occupational diseases continued to occur in various regions of Indonesia in the first half of 2011. A variety of threats to health and safety at workplaces continues to occur in Bandung[CU5] [14], Banjarmasin[15], Cilacap [16], Tangerang, Malang[17], and other areas

However, in many areas, workers are beginning to realize the importance of health, safety, and injury compensation for workers. Workers are starting to demand the enforcement of occupational safety and health insurance (Jamostek) -This new emphsis on safety may be attributed to workers’ inceased awareness of basic human rights that should be applied in the workplace, such as breaks, access to food,a nd fair pay.. As shown in Medan[18], Jakarta[19] and West Bandung[20], the workers demand not only the certainty of work but also job security and compensation in case of injury.

Amid the turmoil of low wages, mass layoffs and the increasingly widespread conversion of formal workers to informal workers, the demand for improvements in working conditions and occupational safety and health insurance continue to be a struggle.

The rampant violations of the basic rights of workers' and the de-formalization of the workforce is reflected in the case of PT Daya Mekar Tekstindo in the West Bandung regency of West Java. The mass media reported that the case in PT Daya Mekar Tekstindo, which was associated with Social Security money not being paid (Pikiran Rakyat Daily Newspaper, 01/12/2011). This motivated the workers to take action.

From some of the information collected, it was noted that since its first operation in 1991, PT Daya Mekar Tekstindo treated its workers poorly. In 2003, work accidents befell two of its workers: their fingers were cut off. In 2008, one worker died, but did not get the compensation deserved. In 2010, another two workers died.

The enterprise does not just consist of permanent workers. Substitution of permanent workers to laborers under contract is suspected to occur each and every month. Workers at PT Daya Mekar Tekstindo are not registered to Social Security. Many work accidents suffered by the workers are resolved "amicably”, namely, the compensation amount is far less than the value of losses suffered by the victims. Furthermore, the work accident victims do not get rehabilitation services. In many cases, victims of work accidents are immediately laid off. In the midst of other thorny issues that threaten the survival of the workers, the job becomes their and their families’ subsistence and makes it easy for an injured worker to acquiesce to employer demands. Many workers were laid off due to their activities organizing or protesting action against company policies. Layoffs are the monsters that haunt the workers every second. Therefore, it is not easy for workers to unite.

However, a series of accidents prompted the workers to unite and support each other. In 2003, two workers had amputated fingers, in 2008, one worker died but did not get Jamostek compensation, and in 2010, two workers died without compensation. Initially workers. After so many incidents, the workers became more upset and then more vocal. Two hundred fifty workers protested the lack of actions taken by entrepreneurs on January 12, 2011 at PT Daya Mekar Tekstindo. It was the first action undertaken since the textile mills were established in West Bandung.


Working Conditions in Indonesia

As a follow up to the information above, there are some issues in Indonesia that should be emphasized. First, the threat to the safety and health at work is still very high. The use of hazardous materials (chemical, biological, toxic and harmful substances) is still high in production processes. Also, the use of asbestos is still allowed here, while it has already been prohibited in many countries because it is considered one of the most dangerous carcinogens in the world. Rampant use of toxic and dangerous materials is compounded by poor OSH management systems in each company.

In some places, the victimization of workers occurs repeatedly and even affects the local community. In Malang, East Java, a leak of ammoniac gas on January 19. 2011, at PT Bumi Menara Internusa, caused 51 workers to faint. Similarly, in 2006, another leak at this shrimp processing plant caused 45 workers to faint[21]. The poor OSH systems in industry are not only having a negative impact on workers in the factories, but also on the environment around the factories. Dozens of residents living in the vicinity of PT Semen Andalas Indonesia (PT SAI) were forced to evacuate because they were no longer able to tolerate the coal smoke produced by the cement factories and one of them was admitted to hospital because of shortness of breath that was allegedly caused by inhaling emissions from the plant.[22] These various incidents show how poor the safety and health management systems were in the company.

There are, in fact, some companies trying to apply rules of occupational safety and health systems. However, many people suspect that compliance is supported by pragmatic interests, such as to avoid reprimand from the government or to meet a requirement of the buyers. Some countries involved in free trade require the application of a Quality Management System that includes safety, such as ISO 9001 Series, ISO 14000 Environmental Management System Series, and OHSAS 18001.

Government Programs and OSH

Protection of workers provided by the government is still discriminatory and limited: it is mainly applicable to a fraction of the labor force. Of the 30 million formal workers in Indonesia, just 9 million are registered with the government Social Security injury compensation program, Jamostek. Meanwhile among more than 70 million informal workers, only one percent is protected by the social program.[23]

Membership in Jamsostek is not mandatory, so many workers are left without protection in the event of a workplace injury. There are no negative consequences by the government or the Social Security Agency for companies that do not include workers in this social security program, Jamostek. There is no incentive for companies to enroll their workers, which results in the low membership of only about 30 percent of the total formal workers in Indonesia. In some areas enrollment is drastically low, such as in Lumajang, East Java: of the 600 operating companies, only 150 firms have registered as participants of Social Security[24]. In Cimahi, West Java, only 10 percents of companies enroll their workers in the Social Security program[25]. Even in the construction services sector, which is highly vulnerable to workplace accidents, membership in the program is still very low. According to Social Security data, only 10% of the total Social Security participants come from construction workers on private projects. This is because most construction industry participants in Jamsostek are from government construction of projects, which is required in the bidding process for health insurance[26]. Most private construction workers have no recourse in case of a workplace injury.

Many companies do not register all their workers in Jamostek. A member of Commission IV DPRD Cimahi City, Ike Hikmawati suspected irregularities by the company [CU6] in providing social security coverage to all workers. An example is that some companies did not register all their employees as members of Jamsostek, just some of them. In fact, from a legal perspective, each company is required to register the exact number of its workers it employs[27].

In addition, the OSH surveillance system run by the Government is not optimal. This can be seen from the low number of supervisors in the field of OSH workforce surveillance compared to the number of industries in Indonesia. The 216,547 companies registered by the Ministry of Manpower and Transmigration are supervised by only about 2,384 labor inspectors consisting of 1,460 general supervisors, 361 regulatory specialists and 563 civil servants[28]. Furthermore, they are not evenly distributed in each region. For example, Batam Island, which is an Exclusive Economic Zone, has six superintendents of industrial relations, while there are about 2,500 companies with about 266,000 workers.[29] The city of Malang, has 7 inspectors, including 3 supervisors that oversee 860 industrial companies[30]. In some areas, there is not a single supervisor who is specifically knowledgeable in the field of OSH.

Another problem is the lack of government programs addressing employment issues. Research conducted by Yayasan Wahyu Sosial Foundation found that the budget allocated to the Department of Labor in Semarang is minimal and as much as 70 percent is allocated to facilitate the interests of employers seeking new employees in the form of job fairs. Only 10 percent of the budget is allocated to conduct surveillance of several thousand operational factories and plants[CU7] .

Weak law enforcement is also an issue. Rampant violations of normative rights of workers, especially in OSH affects thousands of workers each year. This is essentially condoned by the government because sanctions are not strictly applied to companies that violate OSH regulations. These omissions provide relief to companies who take refuge behind the excuse of lacking funds or a reduction in production for not applying the rules that protect workers. Lack of legal sanctions against companies that violate the rules of OSH is the product of existing legislation. Indonesia still uses Law No. 1 of 1970 on Occupational Safety and Health. In this Act, the sanction provided for violators is only to impose a fine of IDR 100,000 and/or 6 months of confinement. A more recent piece of legislation raises the fine: Law No. 13, Year 2003, Manpower Chapters 86 and 87, states that violators will get a fine of IDR 500 million-. But presently, companies’ rampant OSH violations never go into the realm of the courts. Ministry of Manpower and Transmigration only give warnings to companies that commit offenses.

The transition to home based workers has led to less safety protection for the workers and more environmental threats to the community. In the past, factories were responsible for all aspects of production of a good. Now the factories outsource the work to home-based workers, who lack Jamostek or any form of worker safety protection. An example would be a garment maker that provides sewing work for workers to complete on piecemeal basis in the home. Also, toy and electronic manufacturers allow community based workers to perform assembly. Production can require use of chemicals or solvents, which can contaminate the household or the village.

the in-formalization of work from formal sector to the informal sector. (changing the employment status of regular workers into temporary workers) and the transfer of jobs to home-based industries. In the pst Such methods of changing work status gets its legitimacy in Law Number 13 Year 2003 on Manpower chartering jobs and employment for a specified time[CU8] . With the enactment of flexible work systems, various losses are experienced by the workers[CU9] , because the loss of the basic rights of workers in the workplace. Meanwhile, the companies can easily avoid their obligations to protect workers from occupational injuries or occupational diseases.[CU10]

A factor leading to diminished safety protection was the weakening of trade unions. As recognized by several trade unions during 2010, the labor movement has continued to decline. The doldrums of the labor movement was shown by the decreased number of worker protests, decreased size of demonstrations and demands of workers still focusing on basic wage issues[31].The weakening of the trade union was also due to the decline of the membership. During 2010, many union members who had been fired were replaced by contract workers. The situation was exacerbated because trade unions did not organize home based community workers: workers based on fixed and formal as well as in internal union system did not participative.

Conclusion…Looking Forward

Trying to look ahead, it should be considered how to build a union that can answer the problems of employment. In addition to maintaining the number of available members, swelling of the informal workforce, it is time to think about organized model.[CU11]

In addition, it should be considered how the major unions’ programs will fight for union members’ rights. In many ways, demanding wage increases will be very useful to improve the workers’ and their families’ opinions of unions. However, a great salary can not compensate for a family member in poor health. Therefore, the union must re-design how to lobby for health programs for workers and their families. The program is not meant as technical health care, but as a citizen's right in the country to get cheap and quality health care.

The country needs to see OSH as a fundamental right of the worker. The government, employers and trade unions all have a responsibility to provide the skills and knowledge to raise awareness about decent working conditions. Currently, a very low number of unions have OSH education programs for their members. Information collected by Local Initiative OSH Network in 2009 showed that commonly unions only included very basic OSH programs, such as fire extinguishing training and how to register in Social Security . Trade unions do not see OSH as a priority: they do not include OSH as an integral part of the basic rights of workers and they do not put the OSH in the framework of the struggle. Issues related to OSH and its characteristic as a basic right should be addressed by employers and the country.

in the eyes of the government and employers, OSH is considered simplistically and this must change. They see it as an added cost to business and something that can be addressed by a quick token gesture like providing gloves or a dust mask. Safety is not considered an important aspect of the company culture, even when zero accident campaigns are espoused that are not actually true. [32]. It would be be better if the companies and the government could embrace safety at a deeper level, beyond awards and banners. The fate of workers who are permanently disable or killed and their families should be considered. Progams that address the root cause of workplace accidents and create a safety culture should be implemented., as well as inclusion of all workers in the Jamostek program. [CU12] Two above things explain why many workers are not registered to follow the Social Security program. And, companies and government become disdainfully proud when they are awarded as zero accident institutions

Is this the end? Need some kind of conclusion.

[1] Media Indonesia – 26 January 2011

[2] LIPS, notes on OSH Network Workshop in Indonesia, July 2009

[3] See Report of AKATIGA research on the informal sector labor relations in 2003.

[4] www.poskota.co.id - 9 June 2011

[5] www.surabayapost.com – 15 September 2011

[6] Suara Merdeka – 13 April 2011

[7] A construction worker at Trans Studio rebuilding projects Bandung Supermal (BSM) was killed, due to falling from height. Meanwhile, two other people seriously injured (Pikiran Rakyat Daily, 12/12/2010).

[8] Two Navvies fell from the 9th floor of a building on the street Kertoarjo 44. A porter was killed while another was seriously wounded. Both the victim fell while pulling plywood from floor to floor 9 (www.surabaya.detik.com - 20 Januari2011)

[9] Two workers were killed in workplace accidents in Depok and Ciracas, East Jakarta. Two workers fell from 15th floor apartment in Depok development projects due to his neck exposed to the grinding ( www.poskota.co.id – 23 Mei 2011)

[10] Tribunnews.com – 11 June 2011

[11] www.pikiran-rakyat.com – 2 August 2011

[12] Bangkapos.com – 19 August 2011

[13] www.indopos.co.id - 03 April 2008

[14] BANDUNG – Eight workers were chemically poisoned at WHAT COMPANY. "I was working in that house. I saw people who were making the emblem suddenly staggered. They opened a chemical substance. They continued to stagger. Vomiting. I was quite far from the substance, but still I felt dizzy. But, I was not that awful. Those six workers were taken to hospital," said Amung when found at the scene (Tribun Jabar Daily, 17 January 2011).

[15] BANJAR MASIN - Five Telkom employees were shocked by electricity and killed. According to one worker who joined the Telkom Project, Husin (41), five employees were climbing the Telkom pole on Friday (21/1/2010) when the pole suddenly touched the electric cable and shocked them (Kompas, 21 January 2011).

[16] CILACAP – An accident happened in Pertamina Refinery Unit (RU) IV Cilacap, Tuesday (13/9) midnight, causing three deaths and four others in a coma. One of the deceased was a foreign citizen (www.detik.com – 14 September 2011)

[17] MALANG - At least 51 workers of PT Bumi Menara Internusa (BMI) Concurrent passed out because of inhaling ammonia gas in the shrimp processing plant in Jalan Pahlawan, Dampit, Malang Regency, Wednesday (19 / 1). All of a sudden, they sensed a foreign smell, like the smell of medicine for straightening curly hair.” Suddenly my throat was dry, sore and nauseated," said Susiana (45), the packing worker, while being treated at the health center Dampit (Surya Daily, 20 January 2011)

[18] MEDAN – After the death of Tri Ardiansyah, a laborer of PT Siantar Top Tbk, his family was not compensated . Because the head of the product development company did not participate in the program, the victim was not a member of Social Security. As a result, the Alliance of Labour Deli Attack (ABDES) criticized and condemned PT Siantar located in Jalan Medan-Tanjungmorawa 12.8 km,for not registering employees in the Social Security program as stipulated in Law No. 3 of 1992 on Social Security (waspada.co.id, 16 January 2011)

[19] JAKARTA – Hundreds of workers at PT Rismar Daewoo Apparel KBN Cakung held a strike. They demanded that the company pay attention to the rules agreed upon regarding the problem of excess hours of work for which had not been paid for 2 years (suspension time), JPK program to be implemented, leave entitlements, THR, better salary and no change in overtime compensation work day policies (Pos Kota Daily, 13 January 2011)

[20] BANDUNG BARAT – A total of 250 workers of PT Dayar Mekar Asih Tekstindo at Giri Road, Village Giriasih, District Batujajar, West Bandung, demonstrated at the front entrance of the company. They demanded payment of Social Security money which since 2003 had not been paid to them. It was said the total bill required for employees amounting to IDR 167 million. The action was triggered after two workers of PT Daya Mekar Tekstindo died in workplace accidents and did not obtain the withdrawal compensation due to them (Pikiran Rakyat Daily, 12 January 2011)

[21] www.surya.co.id – 20 January 2011

[22] www.nasional.inilah.com - 6 August 2011

[23] Republika - 24 December 2010

[25] www.antarajawabarat.com – 21 July 2011

[26] www.solopos.com – 26 May 2011

[27] www.antarajawabarat.com – 21 July 2011

[28] www.poskota.co.id -12 March 2011

[29] Kompas- 9 April 2010

[30] www.mediaindonesia.com – 27 February 2011

[31] This information is obtained from the results of discussions with trade unions in the District of Serang in 9 January 2011.

[32] This information is obtained from union activists in West Bandung regency of West Java in 2009. In the discussion revealed the fact that OSH was no longer a problem, because every year there were competitions of OSH for zero accidents, even though there were accidents.

[CU1]Let’s talk about what you mean to say here to make sure I have it right.

[CU3]These terms should be defined at bottom of table. I am not sure what the difference is..

[CU4]For you to say there is an increased rate of accidents, you will need to show the previous years’ accident rates (or rate) to make the comparison.

[CU5]In footnote, include in what kind of facility they were working, Also in footnote.. factory makes :emblem”. Not sure about this translation . Emblem is a symbol, not usually something made in a factory.

[CU6]What company? Do we know?

[CU7]DO you have a citation for these statistics?

[CU8]Include what this law says that allows them to “in-formalize” workers.

[CU9]But are not recorded or compensated because informal workers…………….. This needs to be explained better. Do informal workers have less rights? And if so, why?

[CU10]Need to explain why this is true.

[CU11]This is not clear, it is confusing. Im not sure what you are tying to say.

[CU12]Not sure what you are trying to say here.

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