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European Academy of Dermatology and Venereology

EADV

EADV is a non-profit association, founded in 1987, whose mission is to advance excellence in clinical care, research, education and training in the field of dermatology and Venereology and to act as the advocate and educator of patients particularly those with cutaneous or venereal diseases.

Lobbying Activity

Response to Carcinogens 3rd wave of amendments

29 May 2018

The European Academy of Dermatology and Venereology (EADV: non-profit association with the key aims of improving the quality of patient care, providing continuing medical education and advocacy on behalf of the specialty and patients) regrets that the European Commission proposal for the 3rd batch of amendments of 5 April 2018 makes no mention of solar UV radiation as a carcinogen nor any measures to protect workers and other individuals at risk exposed to this well recognized carcinogen. It is our understanding that the central objective of the CMD is to protect workers against the risk of occupational cancer. Solar ultraviolet (UV ABC) radiation is classified by the International Agency for Research on Cancer (IARC) and the WHO as a group 1 carcinogen (e.g. Plutonium, Asbestos) associated with the highest level of causality for cancers in humans, both melanoma and non-melanoma skin cancer (NMSC). There is a growing body of research linking exposure to UV radiation in outdoor workers to the rapidly increasing incidence of NMSC. The risk is double for outdoor workers compared to the general population. According to the European Union’s CAREX database, more than 9 million workers across the EU are regularly exposed to UV radiation (UVR) by more than 75% of their daily working hours. EU-OSHA estimates 14.5 million outdoor workers being regularly exposed to this carcinogen. Recent research findings in EU countries ( GENESIS-UV dosimetric assessment of exposure of outdoor workers) have revealed that dock workers´ yearly exposure corresponds to 222 standard erythematous doses (SED), whilst masons/bricklayers have on average an exposure of 435 SED per year. There is no other occupational carcinogen (IARC group 1) where it is legally accepted for exposed workers to exceed the threshold-levels by 5x times. The European Commission should realize that the incidence for NMSC is by far the highest for any occupational cancer, representing a real epidemic. Only a few European countries recognize NMSC as an occupational disease. Due to the tremendous socio-economic challenge and implications of UV-induced skin cancer at workplaces, the WHO, in cooperation with the ILO, currently focus on this issue in the framework of the UN Global Sustainable Development Goals (SDG). Thus, at present, a methodology is being developed for the assessment of the global disease burden of occupational skin cancer by solar UV, including systematic reviews and meta-analyses. The EADV urges the Commission to consider inclusion of solar UV radiation into the list of carcinogens, and to define limit values accordingly in Annex III of the Directive. It is unacceptable that at least 14.5 million workers in Europe remain unprotected and that solar UV radiation falls outside the scope of the CMD. The EADV also fully supports the following 2 proposals made by the European Trade Union Confederation in its response to the 2nd stage of consultation with the social partners’ revisions of Directive 2004/37/EC, namely i) that “(….) an amendment should be introduced in article 2 of the directive and in the title of annex I. Paragraph 2, a, iii and the title of annex I should add the word “occupational exposure” after “substance, mixture and process”. The new wording would thus be “substance, mixture, process or occupational exposure”. The introduction of the wording “occupational exposure” would strengthen the link between the CMD, and EU activities based on it, and the IARC systematic programme at international level. (…) Such a revision should be introduced with the batch 3 in 2018. The roadmap of the Commission should include a list of “occupational exposures” which are envisaged for annex I and precise deadlines about their inclusion.“ ii) to amend the optical radiation directive by including occupational hazard of solar UV radiation, in order to improve prevention for outdoor workers. Luca Borradori (EADV President) Swen Malte John (EADV Media Cttee)
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