OpenLobby.EU
Explore

Protection of workers health from risks related to exposure to lead and di-isocyanates

Employment and social affairs

The aim of this initiative is to improve workers’ health and safety by revising the Directive on the protection of workers from the risks related to exposure to chemical agents (98/24/EC). This revision will establish or revise the binding occupational and / or biological exposure limit values for lead and certain other substances.

Links

Public consultation

ID: 12745

Lobbying Activity

26 responses

Consultation response

EUROPEAN TRADE UNION CONFEDERATION, 21 Mar 2022

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…

Swedish Enterprise Urges Gradual Phase-In for Lead Safety Rules

Confederation of Swedish Enterprise, 17 Apr 2023

The organization requests a step-by-step reduction of lead exposure limits over eight years. They support the diisocyanate proposal but advocate for higher lead limit values.
Longer transition periods would reduce immediate compliance costs and prevent the relocation of production.
Industrial workers will face higher health risks due to delayed enforcement of stricter lead limits.

Consultation response

Wirtschaftskammer Österreich, 16 Mar 2022

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…

Danish union 3F urges stricter EU chemical exposure limits

Fagligt Fælles Forbund, 26 Apr 2023

3F demands occupational limit values that ensure a high level of protection. They advocate for standards aligned with scientific recommendations to minimize health risks.
Stricter standards would reduce occupational diseases and lower health risks for union members.

Consultation response

Aurubis AG, 21 Mar 2022

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…

Consultation response

Council of European Employers of the Metal, Engineering and Technology-based Industries, 21 Mar 2022

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…

Confartigianato Imprese urges phased introduction of chemical exposure limits

Confartigianato Imprese, 16 Mar 2023

The association requests that lead exposure limits be phased in over time. They advocate for practical monitoring and clearer training rules for chemical use.
A gradual transition reduces immediate compliance costs and technical burdens for small businesses.
Workers face prolonged exposure to toxic substances during the proposed extended transition period.

EUROBAT Urges Higher Lead Limits and a Five-Year Transition

Association of European Automotive and Industrial Battery Manufacturers, 26 Apr 2023

The association requests raising the occupational exposure limit to 50 µg/m³. They also propose a transitional period until 2030 for biological limits.
This would prevent factory closures and significantly reduce compliance costs for the battery industry.
Workers face prolonged exposure to higher lead levels due to the requested implementation delays.

Consultation response

Association of European Automotive and Industrial Battery Manufacturers, 21 Mar 2022

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…

Consultation response

International Lead Association, 16 Mar 2022

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…

Czech Chamber of Commerce urges five-year delay for lead limits

Hospodářská komora České republiky, 26 Apr 2023

The organization requests a five-year extension for implementation and specific transitional periods for long-term employees. They argue immediate compliance is technically impossible for workers with historical lead accumulation.
Affected industries would avoid mass layoffs and gain time for costly technological investments.
Workers in the metal and recycling sectors remain exposed to higher lead levels longer.

French Building Federation warns against drastic lead exposure limits

Fédération Française du Bâtiment, 26 Apr 2023

The federation demands common measurement methods and warns lead limits are technically impossible. They also argue that proposed standards could unfairly bar women from specialized building trades.
This allows builders to continue using traditional materials where no technical alternatives exist.
Female craftspeople lose career opportunities due to strict exposure limits for women of childbearing age.

KGHM warns strict lead limits threaten industry survival

KGHM Polska Miedź Spółka Akcyjna, 26 Apr 2023

The company requests longer transition periods of up to ten years for primary lead producers. They propose reaching 35 µg/dL within five years and 20 µg/dL within a decade.
Extended deadlines would prevent high investment costs and the cessation of local production.
Reduced domestic lead supply would harm European raw material security and battery manufacturers.

Consultation response

Confederation of the German Textile and Fashion Industry, 21 Mar 2022

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…

Consultation response

Deutsche Gesetzliche Unfallversicherung e.V., 21 Mar 2022

Die „Deutsche Gesetzliche Unfallversicherung“ (DGUV) ist der Spitzenverband der gewerblichen Berufsgenossenschaften und der Unfallversicherungsträger der öffentlichen Hand. Er nimmt die gemeinsamen Interessen seiner Mitglieder wahr und fördert deren Aufgaben zum Wohl der Versicherten und der…

Consultation response

Polska Izba Przemysłu Chemicznego, 25 Apr 2023

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…

Consultation response

European Diisocyanate and Polyol Producers Association, 21 Mar 2023

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…

Consultation response

European Domestic Glass, 21 Mar 2022

Please find enclosed the comments by EU Domestic Glass Association and also EU Special Glass Association.

Consultation response

Polska Izba Przemysłu Chemicznego, 21 Mar 2022

W nawiązaniu do trwających konsultacji dot. ochrony pracowników przed narażaniem na działanie chemikaliów Polska Izba Przemysłu Chemicznego w imieniu podmiotów członkowskich chciałaby zwrócić uwagę na kwestie dotyczące ołowiu. W załączeniu znajduje się stanowisko PIPC.

Consultation response

European Diisocyanate and Polyol Producers Association, 21 Mar 2022

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…

Consultation response

Institution of Occupational Safety and Health, 21 Mar 2022

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…

Consultation response

Związek Pracodawców Polska Miedź (The Polish Copper Employers' Association), 21 Mar 2022

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. Ares(2022)1281076 -…

Consultation response

Verband der Mineralfarbenindustrie e. V., 18 Mar 2022

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…

Consultation response

Fachvereinigung Kaltwalzwerke e.V., 18 Mar 2022

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…

Consultation response

Exide Technologies GmbH, 18 Mar 2022

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…

Consultation response

Asociatia Principia, 13 Mar 2022

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…