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Late last month, CEEMET (Council of European Employers of the Metal, Engineering and Technology-Based Industries) issued a position paper advocating the simplification of the existing EU regulatory system for health and safety risks from exposure to chemical substances. The industry association believes that this simplification would bring greater understanding, more consistency and predictability for employers and SMEs that operate in a very complex regulatory environment.
CEEMET wants the existing EU framework for chemicals to be streamlined and consolidated. It believes the current framework is inconsistent, overlapping, confusing and uncoordinated. A universal and holistic approach to chemicals management should be adopted, CEEMET says.
CEEMET’s position paper has a number of examples that illustrate the complexity of EU chemicals regulations, such as:
- The overlap between the following EU regulations:
- CAD (Chemical Agents at Work Directive)
- CMD (Carcinogens or Mutagens at Work Directive)
- REACH
- CLP
- Seveso
- Occupational safety and health (OSH) regulations, such as CAD and CMD, are mainly process-driven whereas product regulations, such as CLP and REACH, are substance-driven. CLP and REACH apply to chemicals that are manufactured, imported, placed on the market or used in the EU. In contrast, OSH directives address substances present at the workplace including process-derived substances (e.g. fumes and dust).
- While REACH and CLP address health and environment risks, OSH directives address only health risks at the workplace. Adding to the complexity, Seveso introduces additional safety and environmental requirements so that operators handling dangerous substances above certain thresholds must regularly inform the public likely to be affected by an accident.
- While occupational exposure limits (OELs) under OSH regulations are set at EU level for around 120 substances, DNELs (derived no-effects levels) are provided for any registered substance under REACH. Additionally, REACH provides for an obligation to list the relevant applicable EU or national OELs.
- OSH directives apply without distinction to employers who use chemicals in the workplace. CAD and CMD require employers to determine whether any hazardous substances are present at the workplace. If such substances are present, employers must assess health and safety risks to workers. This risk assessment is based on the chemical’s properties, information provided by suppliers, type of exposure, etc. In contrast, under REACH, information on the substance’s properties is communicated in the supply chain with the SDS and/or a CSR. As a result, this serves as a basis for classification under CLP. Under REACH, the main roles are attributed to producers, manufacturers or importers of chemicals. However, downstream users have a secondary key role by communicating relevant information both to their suppliers and customers. These risk management divergences should be rationalized to simplify compliance requirements, CEEMET says.
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