On June 23, 2022, the US Department of Health and Human Services (“HHS”) Office on Trafficking in Persons (“OTIP”) issued a request for information (“RFI”) on forced labor, a form of human trafficking, in healthcare supply chains.  This RFI is part of OTIP’s ongoing efforts to seek public comments to inform implementation of Executive Order 14001 “A Sustainable Public Health Supply Chain“, the National Strategy for a Resilient Public Health Supply Chain, and other related efforts on forced labor. 

In scoping its review, HHS is seeking comments on:

  • Information on monitoring forced labor in the procurement of healthcare services.
  • Information on monitoring forced labor in the procurement of healthcare products.
  • Information on training and public awareness on forced labor in healthcare supply chains.
  • Information on research and data on forced labor in healthcare supply chains.

Responses should be submitted via email to EndTrafficking@acf.hhs.gov with “RFI: Forced Labor in Healthcare Supply Chains” in the subject. Submissions can include attachments of or links to any supporting documentation (e.g., research, training materials, policies, data).  Responses are due by July 25, 2022. 

Author

Kerry Contini is a partner in the Firm's International Trade Practice Group in Washington, DC. Kerry focuses her practice on export controls, trade sanctions, and antiboycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions, and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.

Author

Ryan Orange is a paralegal in Baker McKenzie's Washington, DC office. He works closely with attorneys on trade sanctions, export controls, customs, and supply chain matters. Ryan has worked on matters for clients across a wide range of industries.