Summary
ISOPA and ALIPA welcome the European Commission’s 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. Therefore, this proposal establishes a level playing field to ensure a high level of protection for workers across the EU so as to further reduce the number of occupational asthma cases.
We support the values and the stepwise approach proposed by the Commission as this reflects a consensus on an EU OEL for diisocyanates reached within its Advisory Committee on Safety and Health at work (ACSH) by its representatives from Member State governments, workers’ organizations such as the European Trade Union Confederation (ETUC) and employers. We are nevertheless seriously concerned about the lack of reference that diisocyanates are to be measured as NCO (paragraphs 12, 13 and Annex I), which we consider to be an error of omission. Regarding the stepwise approach, sufficient time is needed for downstream users to implement mitigation measures in order to reach the challenging target values, a transition for which the Commission foresees additional costs of EUR 13.5 billion.
Importantly, the proposal complements an existing REACH Restriction (Commission Regulation (EU) 2020/1149) on diisocyanates which sets a mandatory training requirement for workers handling these substances. This reflects the Commission’s commitment under the EU strategic framework on health and safety at work for 2021-2027 “to streamline the interface between OSH and REACH regulation to ensure workers’ protection”. The case of diisocyanates illustrates how these two legal frameworks complement each other to provide more effective worker protection. The proposed OEL for diisocyanates, in combination with the mandatory trainings established in the REACH Restriction, will ensure a framework which fully protects workers.
More background information can be found in the PDF version of the position paper here.