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.
PDF - 97 K
- We are in favour of new values that are less restrictive and easier to assess. All values in the Directive should be directly measurable, reducing the cost and uncertainty involved when assessing the exposure values.
- The zoned approach offers a logical way forward. However at present it is unnecessarily complex. The upper limit of zone 1 below 1Hz should be amended and zones 0 and 1 merged.
- We welcome the recognition that not all physical effects amount to health effects and that the Directive needs to be amended accordingly.
- We agree that there must be relative flexibility to exceed the upper limit in circumstances where it is not practicable to meet it and that in such circumstances this must be counterbalanced by appropriate actions to control the risks. This flexibility should be applied equally to all sectors without exception.
- Risk assessment should be required only where the upper limit of zone 1 is likely to be exceeded. Guidance should be produced to help employers identify which equipment is and is not likely to exceed the limit.
- It should be made explicit that the CENELEC standards and ACSH guidance are produced to provide assistance and are not compulsory tools.
- A database of exposure values, together with sectoral guidance should be produced to help member states with implementation and employers with identifying what action they need take. Ceemet is prepared to provide practical support for this work.
- We welcome the recognition that there is limited knowledge and no consensus about what, if any, medical surveillance is appropriate. We agree that a committee should be appointed to investigate this further.