Together with more than 30 EU industry associations, the Beryllium Science & Technology Association has urged the European Commission to use workplace legislation, instead of REACH authorisation or restriction, to control the risks of hazardous substances used exclusively in the workplace.
The paper calls for the following actions:
– Call on the European Commission to support protective EU-wide OELs as the most adequate and effective RMO where a potential risk has been identified to be limited to the workplace;
– Ensure that no additional regulatory measures (Authorisation, Restriction, Candidate Listing) are applied to substances;
– Strengthening the capacities for setting OELs (increase the budget for and simplify the process of setting OELs);
– Advocate an exemption from authorisation under Article 58(2) of REACH to be applied to cases where the protective EU-wide OEL is put in place.
Furthermore, the paper underlines the following points:
– Authorisation should not be considered as the preferred option when potential risks can be more effectively addressed by workplace-specific legislation;
– Authorisation would not add any layer of protection where safety can already be established by applying OHS legislation and EU-OELs;
– Authorisation is significantly more costly than compliance with protective workplace legislation;
– Authorisation increases the push for substitution of substances. In many cases suitable alternative substances do not exist;
– Substitution of carcinogens, mutagens and respiratory sensitizers is already foreseen, if technically feasible, under existing workplace legislation;
– Overregulation or disproportionate regulatory requirements can be very impactful on the competitiveness of EU businesses;
– Will force businesses out of the EU or relocate outside the EU;
– Concerned substances are indispensable enablers for strategic technologies necessary for major EU policies, including environmental objectives.
To read the full position paper, please click here.