Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
NGO · United Kingdom
Declared costs: €100K+ a year · in the register since 2013
Trade union · Belgium
Declared costs: €900K+ a year · in the register since 2009
Limit values for lead and its inorganic compounds and diisocyanates · Asbestos screening, registering and monitoring · Protection of workers from asbestos
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Institution of Occupational Safety and Health · filed 21 Mar 2022 · source
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).
European Trade Union Confederation (ETUC) · filed 21 Mar 2022 · source
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as substances toxic for reproduction in humans (Reproduction category 1A) and are covered under the CAD with outdated…
European Trade Union Confederation (ETUC) · filed 24 Jan 2023 · source
Asbestos screening prior to the start of work should be mandatory. Not only employers but also main contractors, contracting authorities, and owners should be obliged to carry out an asbestos diagnosis before commissioning any work. Only qualified and certified operators should be commissioned with the search for asbestos prior to the start of work.
European Trade Union Confederation (ETUC) · filed 5 Feb 2023 · source
Asbestos screening prior to the start of work should be mandatory. Not only employers but also main contractors, contracting authorities, and owners should be obliged to carry out an asbestos diagnosis before commissioning any work. Only qualified and certified operators should be commissioned with the search for asbestos prior to the start of work.
Institution of Occupational Safety and Health · filed 8 Feb 2023 · source
The Commissions plans for a legislative proposal on the screening and registration of asbestos in buildings and the incentives for Member States to set up national strategies for asbestos removal in 2023 is a step in the right direction. IOSH is cautious about the setup of a centralised and/or digital registration system under the responsibility of Member States.
European Trade Union Confederation (ETUC) · filed 21 Mar 2022 · source
ETUC fully supports Commission’s intention to improve the Asbestos at Work Directive by reviewing the binding limit value for asbestos. Asbestos is still present in many European buildings and bedrock in mines, and is a significant health and safety threat for millions of European workers.
Institution of Occupational Safety and Health · filed 22 Mar 2022 · source
Recommendations We are conscious that reviewing or developing regulations for managing asbestos in the workplace -while necessary-, will not solely provide the solution to this occupational issue. In addition to asbestos not being in general use in the EU, this needs to be encompassed by a set of measures, including prioritising substitution of carcinogenic substances in the authorisation and restriction processes…
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