Limit values for lead and its inorganic compounds and diisocyanates

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the proposal revising the CMRD and the lowering of the occupational exposure limit (OEL) and biological limit value (BLV) for lead and its compounds. Since 2021, Germany enforces a 15 µgPb/dL BLV. Conversely, 11 Member States still implement the maximum 70 µgPb/dL authorised by the current version of the CMRD.

Following the public consultation announced by the European Commission on the revision of Council Directive 98/24/EC and European Parliament and Council Directive 2004/37/EC concerning OEL and BLV for lead and its inorganic compounds and diisocyanates we enclose the position of KGHM Polska Miedź S.A. on this matter and the comments of our company with respect to the Impact Assessment document.

Comments of Association of Chemical Industry of the Czech Republic on the proposal to amend the Directive 2004/37/EC of the EP and of the Council on the protection of workers from risks related to exposure to carcinogens, mutagens or reprotoxic substances at working environment.

AUSTIN DETONATOR (AUSTIN) based in Vsetín, Czech Republic is part of the AUSTIN POWDER HOLDINGS COMPANY, Cleveland, Ohio, USA. AUSTIN is traditional manufacturer of initiation systems for industrial blasting operations with around 1 000 employees. Our company is an important technological and research base for production and further development of initiation systems.

3F, the United Federation of Workers in Denmark, finds it important to establish EU occupational limit values for lead and diisocyanates that in fact respect the right of workers to have a high level of protection of their health and safety at work. Regarding lead, the values must protect both men and women, including women in the childbearing age.

The French Building Federation is attentive to the work currently being carried out by the European Union on safety and health at work, whether on the subject of lead, on the draft revision of Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work or on diisocyanates and on the draft revision of Directive 98/24/EC on the protection of the health and…

Filed in French · English published by the European Commission

In relation to the ongoing European Commission consultation on the Health & safety at work protecting workers from exposure to chemicals (lead and di-isocyanates), on behalf of the associated stakeholders we would like to draw attention to the key issues for the chemical industry in Poland. PIPC's position attached

The German Social Security Agency (DSV) agrees with the European Commission that safety and health at work needs to be continuously improved. The European Commission’s initiative to protect workers from exposure to lead and diisocyanates is an important and further step.

Filed in German · English published by the European Commission

Revision of Council Directive 98/24/EC and European Parliament and Council Directive 2004/37/EC concerning OEL and BLV for lead and its inorganic compounds and diisocyanates The EU Commission has put forward proposals for new limit values for lead and its inorganic compounds and for diisocyanates.

ISOPA and ALIPA welcome the European Commissions proposal to amend the Chemical Agents Directive (CAD) 98/24/EC to establish binding EU Occupational Exposure Limit (OEL) for diisocyanates. Today, EU Member States have different OEL levels for individual diisocyanates across the Union and some even have no limit value at all.

Confartigianato Imprese considers it essential to ensure adequate levels of safety and health in the workplace. For this reason, all the European Commission’s actions to update the EU legislation currently in force are supported.

Filed in Italian · English published by the European Commission

As regards diisocyanates, in the BTP sector, it is mainly met with the 4,4-diphenylmethane diisocyanate (MDI), which is a component of polyurethane foams (PU) used in the projection insulation works. There are no binding OELs for diisocyanates in France. The MDI has a non-regulatory indicative OEL set by circular at 0,01 ppm or 0.1 mg/m³.

Filed in French · English published by the European Commission

For more than 90 years, Boliden has been exploring for, extracting and processing metals and precious metals based on experience, innovation and modern technology. We are a part of the non-ferrous metals industry and our main products are zinc, copper, lead, nickel, gold and silver.

Baterpol S.A. purchases and reprocesses battery scrap while being a major producer of refined lead and lead alloys in Poland. The company’s technological solutions close the battery recycling cycle and allow the economic use of more than 95 % by weight of battery scrap.

Filed in Polish · English published by the European Commission

IOSH welcomes this inquiry that looks to assess the work-related health risks of occupational workplace exposure to chemicals, from lead and its compounds and di-isocyanate exposure. To complete our response an additional evidence-based document has been provided highlighting the existing gaps and challenges. This response focuses on the recommendations on improvements to the Chemical Agents Directive (CAD).

EUROBAT is the leading association for European automotive and industrial battery manufacturers, ‎covering all battery technologies, and has more than 50 members. The members and staff work ‎with all policymakers, industry stakeholders, NGOs and media to highlight the important role ‎batteries play for decarbonised mobility and energy systems as well as all other numerous ‎applications.‎ EUROBAT welcomes the call…

Introduction The revision, or setting of, Occupational Exposure Limits (OELs) and Biological Limit Values (BLVs) for substances must be done based on sound scientific evidence and via social partner consultation. A careful impact assessment must be made on forthcoming proposals for substances based on the costs and administrative burdens that follow.

IGMNIR, Poland_Position Paper Protecting workers from exposure to chemicals (lead) Economic Chamber of Non-Ferrous Metals and Recycling („IGMNiR”) associates the largest companies in Poland that produce primary lead, secondary lead and the largest producers of lead batteries.

TCO welcomes this initiative and supports the proposal to revise the limit values of the Chemical Agents Directive for these hazardous substances, i.e. to update limit values for lead and to introduce limit values for diisocyanates. However, the updated limit values must not increase the limit values in the Directive.

Filed in Swedish · English published by the European Commission

Aurubis is a leading worldwide provider of non-ferrous metals with smelters in Germany, Bulgaria and Belgium. We process complex metal concentrates and diverse recycling raw materials, being one of the global leaders for copper recycling. We do support the update of the existing EU binding occupational exposure limits for lead.

Taking into account the currently binding standards for lead in Polish legislation: a) Occupational Exposure Limit (OEL) – 0,05 mg/m3 b) Biological Limit Value (BLV) in employees’ blood - 50 µg/dL and the monitoring of workplace and employees’ blood biological measurements, which has been carried out for many years we would like to take the opportunity to present our company’s stance in the public consultation on…

KGHM Polska Miedź S.A. (KGHM) is one of the world’s leading companies in the mining and production of copper and silver. The company also produces other accompanying metals, which results from the properties of the exploited polymetallic deposit. The lead production process is an extremely important element/stage in the copper production process at KGHM.

Filed in Polish · English published by the European Commission

Lubin, 21 March 2022 ZPPM / 13S / III/ 2022 European Commission Directorate-General for Employment, Social Affairs and Inclusion DG EMPL – Unit.2 – Health and Safety at Work, EU-OSHA 1049 Bruxelles/Brussel Belgium Proposal for a directive – Call for evidence: Ref.

Lubin, 21 March 2022 ZPPM / 13S / III/ 2022 European Commission Directorate-General for Employment, Social Affairs and Inclusion DG EMPL – Unit.2 – Health and Safety at Work, EU-OSHA 1049 Bruxelles/Brussel Belgium Proposal for a directive – Call for evidence: Ref.

Lead and lead compounds are important substances for battery production and recycling, manufacture of lead oxides, glass and ceramics. These substances are hazardous for both human health and the environment. They are currently classified under the CLP regulation with a harmonised classification as substances toxic for reproduction in humans (Reproduction category 1A) and are covered under the CAD with outdated…

Austin Detonator s.r.o. (AD) is part of Austin Powder Corporation, Cleveland, Ohio, USA. We are the largest European manufacturer of electric, non-electric and electronic detonators for use in mines in the extraction of minerals, in the construction of transport infrastructure, including tunnels, and in the extraction of oil and natural gas. We actively export to 40 countries, of which 23 are outside the EU.

The DGUV [German Statutory Accident Insurance] is the umbrella association for professional associations in this branch and governmental accident insurers. It looks after the joint interests of its members and promotes the work they do for the benefit of insured persons and enterprises.

Filed in German · English published by the European Commission

According to research, the lowest dose of lead (current hygienic and biological limits) shows toxic effects and an increased risk of cardiovascular disease. There are also clear reproductive disorders for those in contact with lead in working life, as well as an increased risk of cancer. Diisocyanates can be released from many materials. Exposure can lead to allergies, asthma and possibly cancer.

Filed in Swedish · English published by the European Commission

HBM4EU is a joint effort of 28 countries, the European Environment Agency and the European Commission, co-funded under Horizon 2020. The initiative is coordinating and advancing human biomonitoring (HBM) in Europe. HBM4EU is generating evidence of the actual exposure of citizens to chemicals and the possible health effects in order to support policy making.

Lead substances in explosives/detonators – comments We support the comments submitted by International Lead Association and we would like to add following: • Lead compounds are used for the production of detonators and explosives since 1900s.

With reference to the ongoing consultation on the protection of workers against exposure to chemicals, the Polish Chamber of Chemical Industry would like to draw attention to issues concerning lead on behalf of the Member States. Please find attached the position of the PIPC.

Filed in Polish · English published by the European Commission

Lubin, 18 March 2022 ZPPM/12S/III/2020 European Commission Directorate-General for Employment, Social Affairs and Inclusion DG DG EMPL — Unit C.2 — Health and Safety at Work, EU-OSHA 1049 Brussels/Brussel Belgium Proposal for a Directive — Call for comments on impact assessment: Ref.

Filed in Polish · English published by the European Commission

Lubin, 18 March 2022 ZPPM/12S/III/2020 European Commission Directorate-General for Employment, Social Affairs and Inclusion DG DG EMPL — Unit C.2 — Health and Safety at Work, EU-OSHA 1049 Brussels/Brussel Belgium Proposal for a Directive — Call for comments on impact assessment: Ref.

Filed in Polish · English published by the European Commission

The German association for the apparal and textile industry (t+m) welcomes the opportunity to provide feedback to the European Commission on the review of the Chemical Agents Directive (98/24/EC) (our opinion refers to diisocycate). As a downstream user industry, we have not closely followed the OEL process for diisocyanates so far, as the affectedness was not clear enough for our SME companies.

ISOPA/ALIPA and its downstream users’ associations welcome the opportunity to provide feedback to the European Commission on the review of the Chemical Agents Directive (98/24/EC) which intends to set Binding Occupational Exposure Limit Values (BOEL) for diisocyanates and lead. We will not comment on the OEL setting intentions regarding lead.

The substances concerned cause serious illnesses, I think in particular of lead, which directly affects the development of the foetus and its future development, with a risk of increased mortality and proven malformations.

Filed in French · English published by the European Commission

According to research, the lowest dose of lead (current hygienic and biological limits) shows toxic effects and an increased risk of cardiovascular disease. There are also clear reproductive disorders for those in contact with lead in working life, as well as an increased risk of cancer. Diisocyanates can be released from many materials. Exposure can lead to allergies, asthma and possibly cancer.

Filed in Swedish · English published by the European Commission

PENOX is a German company, specialized in the production of lead oxides, with operation in Germany, Spain, Mexico and South Korea. PENOX is a SME with 170 employees in total and 110 in Europe, producing close to 100.000 t of lead oxide per year and therefore one of the key actors in this sector worldwide.

As association, Verband der Mineralfarbenindustrie e. V. represents the German manufacturers of lead-containing ceramic colours and frits, amongst others. Our members are predominantly medium-sized companies and employ many long-serving employees. We can understand the appropriateness to lower the established biological limit of 700 µg lead/L blood, which has been in place for 20 years.

Comments of RUAG Ammotec GmbH for the Public Consultation for OEL Lead RUAG Ammotec GmbH: With its Business Units of Hunting & Sport, Military & Law Enforcement and Industry, RUAG Ammotec is European market leader for small-calibre ammunition, pyrotechnic elements and components.

With the new TRGS 505, Germany has published recently updated substance- and use-specific technical guidelines for companies manufacturing, using or processing lead. The biological limit value of 150 μg lead/L blood specified there is suitable as a key indicator for safe use and can support companies to identify the occupational health and safety measures that are effective for the respective use from the…

Exide Technologies is a producer of lead and lithium based batteries, as well as a recycler of lead based batteries. As such, Exide is an active member to Industry associations that deal with our raw materials (e.g. International Lead Association) and or products and services (EUROBAT). Exide Technologies is committed to ensuring the health and wellbeing of our employees.

WKÖ Draft Input on Roadmaps for revised OELs for lead and diisocyanates We welcome the opportunity to voice our opinion and concerns on the occasion of the call for evidence for an impact assessment on a proposal for a Directive on protecting workers from exposure to chemicals (lead and di-isocyanates).

The International Lead Association (ILA) is the global trade association for the lead industry representing member companies involved in lead mining, smelting and recycling. ILA acts as the secretariat for the Lead REACH Consortium that was established in 2008 to help companies meet their REACH obligations for lead metal, lead chloride, and ten lead compounds covered by the Voluntary Risk Assessment for Lead (VRAL).

We do not agree with this statement, it is an unfounded one: “Member States are allowed to establish themselves own limit values, in compliance with these minimum conditions of protection ''. We do not understand why states should set their own lead exposure limits. Have states found that they have workers who are more resilient to lead? No, in reality we run into some economic interests of some companies.

H.J.Enthoven & Sons is part of Ecobat Resources, the largest lead-acid battery recycling company in the world with facilities in Europe, United States, and Southern Africa. We are leaders in delivering world class HSE performance to protect our valued employees, local communities and the environment.

Bonjour, Je suis qualifié IPRP et je travaille également dans une entreprise de 275 salariés. Nos salariés ne peuvent être confrontés à des matériaux amiantés qu'en de rares occasions. Ils sont souvent en interventions à l'extérieur et très rarement en intérieur. Nous n'avons ni ne pratiquons aucune activité de désamiantage pour laquelle les mesures prises dans notre pays me semblent adaptées.