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 .

• Both associations underline that ICNIRP’s expertise is “brought to bear on addressing the important issues of possible adverse effects on human health of exposure to non-ionising radiation”, and not to supplement policy makers in their responsibility for establishing rules appropriate to each industrial and economical context. Such elements would have been provided by a detailed impact assessment for this new Directive and would have shed light on the policy choices to be proposed by the European Commission and discussed by the Council and the Parliament.
• In the absence of an appropriate impact assessment, Ceemet and Orgalime call on Member State representatives to take due consideration of the practical occupational conditions as well as already existing product related health and safety legislation and corresponding standards.