Health & Safety

Position papers (22)


Tech and Industry employer’s views on the Commission’s proposals on Lead and Diisocyanates

MET companies have already made strides to ensure that workers are protected, having gone beyond what has been proposed at a national level, including on lead. However, in this context, industry needs an evolution, not a revolution. When lowering limit values, we should be lowering them step by step, giving companies time to understand and adjust.


Ceemet position paper on Mental Health at the Workplace

Ceemet understands how occupational safety and health (OSH) concerns can be multifactorial, impacted by both work and non-work contributory factors. Workplace mental health, which includes psychosocial risks, is one example of this. It is important to remember that both employers and employees have a shared responsibility under the EU OSH Framework Directive to achieve improvements in OSH conditions. Consequently, efforts to improve OSH standards should not solely rest with the employer, but also with the individual.


Ceemet Position Paper on the OSH Strategic Framework 2021-2027

With this paper Ceemet comments on the European Commission’s Strategic Framework on Health and Safety at work for 2021-2027. While in principle Ceemet agrees with the aim of the new Strategic Framework, there are some issues with which we are concerned, and further issues which we would like to highlight. These issues we look at in the position paper are: ▪ the EU OSH legislative landscape, ▪ the joint responsibility of OSH, ▪ the implementation, enforcement and consistency of legislation, ▪ the role of the EU in OSH policy, ▪ the chemicals policy, ▪ the digitalisation of industry and ▪ the effectiveness of the Strategic Framework.


Ceemet position on REACH-OSH overlap

The European Commission published on 5 March 2018 its conclusions on the 2nd REACH Review. It which prioritised the REACH-OSH interface as one of the four issues requiring the most urgent action. Ceemet welcomes the Commission’s suggestion that the interface between REACH and OSH legislation calls for systemic solutions to address the main overlaps and discrepancies between the two legislative frameworks.


Position on 3rd review of the Carcinogens or Mutagens at Work Directive

Ceemet reacted to the Commission's proposal for a 3rd amendment to Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work (CMD). It aims to add occupational exposure limit values for five substances. Until now, there have been two amendments to this directive, and with more promised, it is crucial to ensure the best outcome in this process for both employers and workers.


Position on the Commission Communication on Occupational Health & Safety

Ceemet particularly welcomes the focus of the Communication on sharing of best practice, simplifying and reducing administrative burden while maintaining workers' protection and the focus on the culture of compliance in companies. However, the Commission missed the opportunity to make improvements to the existing regulatory regime by removing duplication and outdated provisions.


Position on the review of the Directive on Carcinogens or Mutagens at the Workplace

The Commission aims to add or revise occupational exposure limits for a number of substances by amending annexes one and three of the Directive. While Ceemet welcomes the revision of this Directive and see its benefit as a method to protect workers from exposure to carcinogens and mutagens, there are a number of factors with which we take issue in its construction.


Position on Working Time Directive

The Working Time Directive sets out minimum rules for the protection of workers. It is a health and safety measure which has over time done little to either clarify or simplify the law. Employers have found many practical solutions to the problems which the directive has caused, but at a cost to them. Ceemet members do not seek a revision of the Directive, but out of pragmatism, look ahead to future developments and what these might mean for Europe’s manufacturing employers.


Position on Occupational Safety & Health evaluation

Ceemet outlines in this position paper its priority policy recommendations regarding the new EU Strategic Framework on Health and Safety at Work 2014-2020 and the Commission’s ongoing evaluation of all existing EU occupational safety and health (OSH) legislation.


Reply to consultation on Working Time Directive

Ceemet has chosen to not comment in detail on the transposition and implementation of the Directive at Member State level. Instead, Ceemets views concern issues that are related to the EU Directive and not to national transposition and are set out in the response to question five.


Position on Mental Health at the Work Place

Employers in the Metal, Engineering and Technology based industry (MET) sector understand how Occupational Safety and Health (OSH) concerns can be multifactorial, impacted by both work and non-work contributory factors. Workplace mental health which includes psycho-social risks is one example.


Letter to Commissioner Andór on upcoming OSH Communication

Ceemet believes that any Occupational Safety & Health strategy should be postponed until the Commission completes its evaluation and review of the existing OSH legislation.


Advocating a universal approach to chemicals at EU level

It is essential that EU policy makers adopt a universal and holistic approach to the management of chemicals. This means coordinating the interaction between requirements for the environment, health and safety, major hazards, storage, use and transportation.


Reply to consultation on EU Occupational Safety & Health Policy Framework

Ceemet welcomes the opportunity to put forward the Metal, Engineering & Technology-based (MET) industries' views on the 2007-2012 EU OSH strategy and future direction.


Position on Commission proposal to amend the Electromagnetic fields Directive

Ceemet has been following closely the ongoing work concerning a review of the electromagnetic fields (EMF) Directive, in order to make it proportionate and workable. Whereas some progress has been achieved over the last few months, the Metal, Engineering and Technology-based (MET) industry employers consider that there is still room for improvement in the body of the Directive as well as in the exposure limitation system as defined in the annexes.


Views on the Council Presidency compromise proposal on the Electromagnetic fields Directive

While some of the changes in the Presidency Compromise Proposal are welcome, Ceemet believes that it does not solve the remaining issues in the Commission’s proposal (compliance with non-measurable values). It would complicate further the situation for Metal, Engineering and Technology-based (MET) companies by removing the relative flexibility that is provided in the commission’s proposal with the distinction of health and safety effects especially when it applies to low frequency range.


Position on a proposal for a Directive on Electromagnetic fields

Over the past years, Ceemet has been preparing for a review of the Electromagnetic fields (EMF) Directive, in order to make it proportionate and simple. Whereas some progress has been achieved, we are still concerned that the proposed Directive may unintentionally prohibit processes that do not cause adverse physical effects. The Directive has to be workable.


Position for a holistic approach of EU Health and Safety legislation

Ceemet is committed to improving the management of risks to health and safety and so further protecting employees from harm. Not only is it morally the right thing to do, but it also represents good business. Ceemet fully recognise the responsibility of employers to provide safe working conditions and protect their employees from harm. Action taken by employers over the years has greatly reduced accident and ill health rates in manufacturing industry. With its members, Ceemet is committed to promoting further improvement.


Reply to 2nd stage consultation on the Electromagnetic fields Directive

Ceemet welcomes the European Commission’s consultation and its willingness to look again at a wide range of issues in the original directive that created serious problems for industry. These need to be fully addressed to result in proportionate and efficient protection.


Position on the proposal for a Directive amending Council Directive 92/85/eec on the safety and health at work of pregnant workers

Ceemet is committed to the overall goals of the proposal. However, the employers consider that the changes set out in the Commission’s proposal would have an adverse impact on many European companies, without necessarily improving the reconciliation of professional, private and family life for pregnant and breastfeeding women. This is because the Commission’s proposed changes to the duration of maternity leave, when this leave can be taken and the level of maternity pay as well as changes to associated employment rights will result in increased costs and administrative burdens for many European employers.


Reply to 1st phase consultation on review of Electromagnetic fields Directive

The Directive 2004/40/EC on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) was ill conceived and would have had unintended adverse effects on our sector. Therefore Ceemet welcomes the review of the Directive and hope it will address the Metal, Engineering and Technology-based (MET) industries' concerns.


Position regarding possible options for a forthcoming Commission initiative on musculoskeletal disorders

Simplification of EU legislation as part of the “better regulation” agenda is a necessity. However, merging two directives into one does not necessarily imply real simplification or improvement of legislation. In Ceemet's view, simplification should lead to coherent and accurate legislation which is easier to understand and to implement.

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