Risk & Policy Analysts Ltd (RPA), together with FoBiG, Milieu, and EPRD, have been contracted by the European Commission (DG Employment, Social Affairs and Inclusion) to support the evaluation of a possible amendment of Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work (hereinafter referred to as the CMD).
The preventive and protective measures established by the CMD include the Occupational Exposure Limit Values (OELVs) set out in Annex 3 of the Directive. OELVs are implemented at the national level by means of Occupational Exposure Limits (OELs) which must be at least as stringent as the OELVs in the CMD. To date, the CMD has established OELVs for three chemical agents (benzene, vinyl chloride monomer and hardwood dusts).
In order to adapt the CMD to changes in scientific knowledge and technical progress, it is the intention of the Commission to submit a proposal to the Council and European Parliament, which, amongst other things, may introduce new or revised OELVs for a number of chemical agents, including (but not limited to) the seven chemical agents within the scope of this study. The objective of the study is to assess the impacts of prospective OELVs for chromium VI compounds, 1,3-butadiene, acrylamide, ethylene oxide, 1,2-epoxypropane, bromoethylene, and a revised OELV for vinyl chloride monomer. A summary of the OELVs that are being considered is provided below.
| Chemical agent |
CAS number |
OELV under consideration (mg/m^3 8 hr TWA, unless stated otherwise) |
| 1,3-Butadiene |
106-99-0 |
2.25 |
| Acrylamide |
79-06-1 |
0.07 |
| Ethylene oxide |
75-21-8 |
1.83 |
| 1,2-Epoxypropane (methyloxirane) |
75-56-9 |
2.41 |
| Bromoethylene |
593-60-2 |
4.37 |
| Vinylchloride monomer |
75-01-4 |
1ppm |
| Cr(VI) compounds Examples include: |
Chromium trioxide |
1333-82-0 |
Four options are being assessed:
Option A: 0.025
Option B: 0.015
Option C: 0.010
Option D: 0.005 |
| Sodium dichromate |
10588-01-9 |
| Potassium dichromate |
7778-50-9 |
| Potassium hydroxyoctaoxodizincatedichromate |
11103-86-9 |
| Strontium chromate |
7789-06-2 |
| Dichromium tris(chromate) |
24613-89-6 |
| Lead Chromate |
7758-97-6 |
| Sodium chromate |
7775-11-3 |
| Chromic acid |
13530-68-2, 7738-94-5 |
| Ammonium dichromate |
7789-09-5 |
| Lead chromate molybdate sulphate red (C.I. Pigment Red 104) |
12656-85-8 |
| Lead sulfochromate yellow (C.I. Pigment Yellow 34) |
1344-37-2 |
| Pentazinc chromate octahydroxide |
49663-84-5 |
| Potassium chromate |
7789-00-6 |
| Ammonium chromate |
7788-98-9 |
| Barium chromate |
10294-40-3 |
| Chromium (VI) chloride |
14986-48-2 |
| Chromyl chloride |
14977-61-8 |
| Zinc chromate |
13530-65-9 |
| Basic lead chromate orange |
1344-38-3 |
| Bis(triphenylsilyl) chromate |
1624-02-8 |
| Cadmium chromate |
14312-00-6 |
| Copper chromate |
13548-42-0 |
| Diiron tris(chromate) |
10294-52-7 |
| Lithium dichromate |
13843-81-7 |
| Lithium chromate |
14307-35-8 |
| Magnesium Chromate |
13423-61-5 |
| Pyridinium chlorochromate |
26299-14-9 |
| Pyridinium dichromate |
20039-37-6 |
| Silver chromate |
7784-01-2 |
| Zinc dichromate |
14018-95-2 |
Corrigendum/clarification 12th May 2016: All limits being considered are expressed as 8 hour TWA.
The objective of the study is to collect data and information feeding into the assessment of the impacts of the OELVs set out above and, in particular, the evaluation of potential impacts on competitiveness and SMEs. This survey is aimed at companies that may experience impacts if the OELVs under consideration were to be adopted, i.e. primarily producers and users of the relevant chemical agents.
Responses to this questionnaire will be handled in the strictest confidence and will only be used for the purposes of this study. In preparing our reports for the Commission (which, subsequently, may be published), care will be taken to ensure that specific responses cannot be linked to individual companies. If you have specific concerns about how your views will be treated, you can contact us and we will be happy to discuss your concerns.
The original deadline for survey completion (18
th May) has now been extended to the
31st May 2016 to allow all relevant companies to participate in the consultation. If you have any questions about the consultation or study more generally, please contact Daniel Vencovsky (daniel.vencovsky@rpaltd.co.uk or +44 (0)1508 528 465).