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

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18 April 2011
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).

Despite some improvements compared to the original 2004 EMF Directive, both organisations would like to highlight our serious concerns about the current draft proposal which in our view:

  • Will lead once again to the same difficulties in application which led the Commission to revise the existing proposal. There are indeed still a number of technical issues which need to be dealt with. In particular, the values in the annexes and the scientific basis for adopting them need to be reviewed. Without this, we will face the same issues as forced regulators to review the directive.
  • Will lead to significant, disproportionate and unnecessary burdens for employers: the nature of the measures which it is proposed to impose on employers and the coherence of the set of obligations in the different zones of exposure need to be adapted to reflect proportionality of prevention measures to real risk.