Joint Positions

Position papers (11)

2015 JOINT POSITIONS

EU employers joint letter on possible consolidation of Information & Consultation Directives

As part of its REFIT programme that aims at cutting back legislation, the Commission wants to consolidate 3 EU Directives on the information and consultation of workers. EU employers ask the Commission not to pursue this initiative, which would have no effect in reducing red tape, and would result in a harmful impact on companies.

2013 JOINT POSITIONS

Ceemet & ORGALIME statement ahead of EU Council

The EU Council is set to pave the way on how to move forward to achieve the 20% of GDP industrial share target, proclaimed by the Commission Communication “A Stronger European Industry for Growth and Economic Recovery”. Ceemet and ORGALIME refer to its joint Manifesto to achieve the objectives.

2013 JOINT POSITIONS

Industry statement on EMF transposition

In connection with the Trialogue process underway, a broad industry alliance wishes to present our view relating to the transposition date of the new ElectroMagnetic Fields (EMF) Directive.

2013 JOINT POSITIONS

Joint industry statement on Electromagnetic fields Directive

This statement on the proposed revision of the Electromagnetic fields (EMF) Directive is presented by the following bodies representing industries that will be impacted by the requirements of the revised EMF Directive: ACEA (automobile manufacturers), BNE (broadcasting), Ceemet (manufacturing), CLEPA (automotive suppliers), ENTSO-E (electricity transmission), EURELECTRIC (electricity), Euro Chlor (chlorine production), EBU (broadcasting), EWA (welding), ORGALIME (mechanical, electrical, electronic and metallic engineering).

2012 JOINT POSITIONS

Ceemet, ECEG and EURATEX joint statement on Green Paper on Restructuring

Employers organisations Ceemet, ECEG and EURATEX welcome the positive overall approach of the Commission to the necessity of restructuring for companies to be able to adapt to continuous change in the economy and society.

2011 JOINT POSITIONS

EU industry joint statement on Electromagnetic fields Directive

After several years of extensive consultation with stakeholders and Member States, while it still includes areas which present problems for different sectors of industry, some good progress had been achieved with the Commission’s proposal of 14 June. This is notably in terms of simplification and additional flexibility, which should be retained.

2011 JOINT POSITIONS

Joint letter to Koos Richelle (DG EMPL) on Electromagnetic fields proposal

Ceemet and Orgalime wrote to DG EMPL Director General Koos Richelle in the context of the possible adoption -in the near future- of the draft proposal for a revised directive on protecting workers' from exposure to electromagnetic fields (EMF).

2007 JOINT POSITIONS

Ceemet & Orgalime position on the Electromagnetic Fields Directive

Ceemet & Orgalime are seeking a complete review of the European Physical Agents Directive on Electromagnetic Fields (EMF), in line with the agenda for better regulation in Europe. both associations are not aware of any evidence base to confirm that exposure to EMF, at the levels likely to be associated with non-specialist working environments, causes harm to people. Therefore additional legislation to control exposure is unnecessary.

2005 JOINT POSITIONS

Ceemet & Orgalime proposed amendments on "Optical Radiations" for the European Parliament

Employers’ organisations in Europe recognize that good health and safety management is an essential feature of profitable and sustainable businesses, but the dossier on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents is at odds with the Commission's better regulation principles. Ceemet and Orgalime believe that this Directive places a disproportionate administrative burden and assessment cost on companies without corresponding health benefits. This negative impact will be felt most keenly in the manufacturing sector and even more disproportionately by small and medium sized enterprises.

2004 JOINT POSITIONS

Ceemet & Orgalime comments & proposed amendments on "Optical Radiations"

Unlike for electromagnetic fields, there is no scientific uncertainty with regard to the risks for the eye or the skin that derive from exposure to optical radiations. Therefore, the risk assessment is carried out without incorporating additional safety margins by measure of precaution, just as for assessing the risk to have one’s hand cut by a knife, given its sharpness and applied pressure. The manufacturer of a machine tool that emits optical radiation already carries out an adequate risk assessment, which takes into consideration the realistic conditions of use and foreseeable misuse of such a machine by the operator, or make use of existing standards. Ceemet & Orgalime believe that the necessary safety and protective devices and training are provided .

2004 JOINT POSITIONS

Ceemet & Orgalime comments & amendments to MEP Perez-Alvarez draft report on the exposure to risks from physical agents

Ceemet & Orgalime would like to share their concerns with the members of the European Parliament and suggest some improvements to the Council common position. These comments take into account the amendments proposed by the Rapporteur, Mr. Perez-Alvarez, in his report of 3 February 2004, which was tabled for the Employment Committee meeting of 17 February 2004.

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