The Cross-Industry Initiative (CII) stands for using the most effective tool to manage risks caused by chemicals.
Better regulation in chemicals management requires identification, implementation and enforcement of the most effective risk management option, tailored to tackle a specific risk.
When authorities identify a risk, but find that it is limited to the workplace, the CII believes that workplace-specific legislation offers the most targeted, effective and proportionate regulatory risk management approach.
We warn against unintended consequences of duplicating legislation
Adding Candidate Listing and REACH Authorisation will not improve workers’ protection; it may instead have a negative impact on, or even prevent, the achievement of key environmental and other policy objectives.
Our concrete proposals to achieve better regulation when managing chemicals in the workplace
- Recognising workplace legislation including EU-wide Occupational Exposure Limits (OELs) as the most effective risk management option for substances where there is a need to address a risk limited to the workplace;
- Reviewing how to strengthen EU capacities for the swifter setting and/or review of EU-wide OELs;
- Proceeding to set EU-wide OELs for substances, where a risk is identified at the workplace; and
- Ensuring that in the described cases no additional and unnecessary regulatory measures (e.g. Candidate Listing, Authorisation) are applied, i.e.:
- when the identified risk for all uses of a substance can be more effectively addressed by
workplace legislation, the substance should not be included in the Candidate List; and - when the identified risk for some uses of a substance can be more effectively addressed by
workplace legislation, those uses should be exempted from REACH Authorisation pursuant to Article 58(2) of the REACH Regulation.
- when the identified risk for all uses of a substance can be more effectively addressed by