2013 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.

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Ceemet key messages

  • The essential EU legislative structure established by early Health and Safety directives was holistic, well considered and remains largely fit for purpose;
  • A holistic approach is essential in any health and safety framework to ensure that significant risks are identified, assessed and prioritised effectively;
  • This holistic approach is being undermined by non evidence based hazard-specific Directives such as the Artificial Optical Radiation Directive and the Electromagnetic Fields Directive (due to come into force in July 2016) which impose unnecessary costs and bureaucracy on industry and where the requirements are not proportional to the risk;
  • Attention should now focus upon ensuring that the original H&S Directives are fully effective and have been fully implemented across all Member States. The Commission need to look in detail at the practical implementation and enforcement in Member States of existing Directives before considering new Directives; Ceemet members are ready to lend their active support to this approach;
  • New hazard-specific precautionary Directives should not be introduced, unless they are both risk and evidence based;
  • It must take into account the current economic and financial context. The use of resources needs to be optimised and OSH priorities should be focused on aligning with or assisting rather than hampering economic recovery for business and SME’s;
  • There should be a competitiveness check of all existing and proposed OSH Directives which informs any OSH policy framework or strategy development;
  • The outcomes of the report due to be published by the Commission in 2015 on the current evaluation of OSH Directives being carried out by Member States (completion 2013), should be used to determine the Commissions OSH framework or strategy from 2015 onwards and should concentrate on simplification, consolidation and revocation of Directives;
  • There are, inconsistencies, overlaps, and synergies which can be identified across and between the Directives. Risk Assessment and Health Surveillance requirements should only be contained in the Framework Directive;
  • Any future EU Commission Strategy should only look at significant risks (not one size fits all);
  • Any future OSH framework or strategy should update out dated Directives, e.g. the Display Screen Equipment Directive (90/270/EEC). Advances in computer technology now mean that the use of computers is now ubiquitous in both the workplace and society as a whole.

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