Ceemet expresses its strong support for the UNICE position paper of 4 March 2004 on the Commission’s Communication on the review of the Working Time Directive. Ceemet argues that a range of national and European legislation already protects the health of safety of workers to a high degree and that any new legislation should not introduce new rigidities or administrative burdens, especially for SMEs. Also, the current text of the Directive is already quite detailed and sometimes unduly and unnecessarily confusing, thus leading to some legal uncertainty .
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On the four specific points in the Commission’s Communication on which views are being sought, Ceemet highlights and endorses some major comments in UNICE’s response, adding its own ideas:
- Reference periods: Ceemet is convinced that the reference period for averaging the maximum weekly working time (Art. 6) over 12 months should be the general rule.
- Use of opt-out: the retention of the individual "opt-out" provision is essential to ensure the flexibility that companies need for the management of working time.
- Definition of 'Working Time': the creation of a new category of "time at the disposal of the employer" is not necessarily the only or the best approach to adopt.
- Conciliation of work and family life: Ceemet is convinced that it should not be addressed by this Directive but be left to the discretion of national social partners and / or company level discussions.