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Institution of Occupational Safety and Health

IOSH

IOSH is the Chartered body for health and safety professionals.

Lobbying Activity

Response to The new Action Plan on the implementation of the European Pillar of Social Rights

2 Sept 2025

The Institution of Occupational Safety and Health is listed on the EU Transparency Register (No. 913858710558-02). IOSHs Response Our response to this public consultation will focus on the following principles: Principle 9 Work-life balance Supports flexible working arrangements and leave entitlements to balance work and personal life. Principle 10 Healthy, safe and well-adapted work environment. Workers have the right to a high level of protection of their health and safety at work. Includes protection from occupational risks, adaptation of work to individual needs.
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Response to 2023 Strategic Foresight Report

13 Mar 2023

Emerging health and population trends. Climate-induced health impacts the most obvious association between environmental and social sustainability relates to the potential impacts of climate change on human communities. The emergent occupational health hazards (i.e., extreme heat, reduced air quality, prevalence of vector-borne diseases etc.) are significant for outdoor workers and for those based in regions particularly vulnerable to the effects of climate change. Indeed, there are also other categories of workers, such as those working in hot indoor environments, emergency responders to natural disasters and jobs linked to natural resources who will also have their occupational safety and health at risk. At the same time, as research into the associations between climate change and work matures (see Section 5), a greater cohort of workers will be integrated into this knowledge. Global burden of mental health the impact of mental ill-health, either caused or exacerbated by work, is a global concern. The inclusion of numerous mental health targets within the United Nations Sustainable Development Goals (SDGs) reflects its contribution to sustainable development (for examples, SDG 3). Given the annual economic losses attributable to mental health disorders, estimations of which have been recorded at 4.7 trillion USD (Patel et al., 2018), the contribution that decent work can make to reducing the global burden is hugely significant. Indeed, since key determinants of occupational mental illness include excessive workloads, long or unsociable hours, unsafe or poor working conditions, job insecurity and so on, the onus on employers is clear. Ageing and diversifying workforces workers globally are remaining in employment for longer, resulting both in a greater need for strategies to protect, manage, and develop this cohort of older workers (CIPD, 2022), and to account for the emergence of notable intergenerational discrepancies in attitudes towards work. Equally, the steady diversification of workforces (i.e., along cultural, linguistic, gender, socio-economic lines, etc.) emphasises the need for tailored management of workers based on individual safety and health profiles and outcomes. Uneven progress in the pursuit of sustainable work for all the interdependent relationship between social, economic, and environmental sustainability is felt most keenly in areas where all three dimensions present significant challenges. In other words, environmental unsustainability compounds its social and economic counterparts and vice versa. In an occupational context, while workers are united by the universal desire for wellbeing, a tiered global workforce persists in which the outcomes of work are vastly different for different workers. Ultimately, the challenges trade-offs involved in achieving sustainable development at state and international level are repeated at the level of the individual and the enterprise. Socially conscious policymaking In the pursuit of ambitious environmental goals, socially conscious policymaking will be required to ensure that the social impacts of the green transition are also accounted for. In the occupational context, this will does not only include mitigating for direct safety and health implications, but also the longer-term effects on a global workforce that has to adapt to significant changes; for example, life-long learning opportunities, worker reskilling, and so on will be invaluable, and will be supported by flexible, transferrable, and inclusive principles and practice of safe, healthy, decent and sustainable work.
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Response to A comprehensive approach to mental health

9 Feb 2023

Consultative initiatives like this one help to visualise the bigger picture and interplays on how poor employee mental health and wellbeing have a critical cost to the business (in the form of absence from work, presenteeism, team cost, staff turnover and other organisational costs), as well as impacts on the employee and costs to local communities and wider society. Legislators have an important role in planning, promoting, and implementing approaches and support offerings within the workplace that can drive positive mental health outcomes. They are instrumental in changing approaches and actions on worker mental health and psychosocial health treating risks of a psychosocial nature with the same level of concern as physical health risks and occupational safety risks. We are conscious that occupational safety and health regulatory frameworks need to better promote, prevent and mitigate occupational psychosocial hazards and risks and mental health issues. European, national, local, and regional policy strategies need to consider the following recommendations: Promotion of wellbeing at work as a contributor to higher participation in the labour market, longer healthy working lives, and the sustainability of social security systems, as well as reduced expenditure on public health services and sickness benefit costs (e.g. costs associated to anxiety and depression). Raising awareness on the fact that investments in mental health and wellbeing at work, in particular social investments, have positive effects on efficiency and productivity at company level, and on individuals and society. Developing a cross-sectoral assessment of impacts on mental health and wellbeing at work to strengthen knowledge-based policy- and decision-making. Including a mental health and wellbeing at work perspective in their reflections in the policy fields within the remit of local and regional strategies and plans. Through enhanced enforcement strategies by regulators: o recognising and promoting that health within occupational health and Safety management systems covers both physical and mental health, o regarding the assessment of risk which includes the identification, prevention and mitigation of occupational psychosocial risks, and o for the protection and promotion of occupational health. As the recent World Health Organizations World Mental Health report highlighted workplaces are pivotal to contribute to the prevention of mental health conditions. Employers and governments have a responsibility to create more work opportunities for people with mental health conditions, and to promote and protect all peoples mental health at work. For governments, that means implementing supportive legislation and regulations in human rights, labour and occupational health. For employers, WHO guidelines emphasize the importance of organizational interventions, manager mental health training and interventions for workers. Employers have a legal and moral duty to achieve this aim, by playing a more proactive and visible role towards prioritising and committing to mental health and wellbeing in the workplace through leadership commitment and the development and delivery of policy, strategies and systematic programmes tailored to the needs of the business and the workforce. At this tipping point, for policymakers, employers and organisations to be able to navigate into this new world of work a drastic change in policies and strategies for proactively managing peoples physical and mental health will be required. This new mindset will require mental and physical ill health to be on an equal footing and placing a stronger emphasis on the prevention and management of mental and work-related psychosocial risks in a manner consistent with other occupational safety and health risks. IOSH advocates for a prevention first approach and support the adoption of a preventative and protective strategic approach to mental health and wellbeing at work.
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Response to Asbestos screening, registering and monitoring

8 Feb 2023

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. Recent national experiences can support this statement. In Spain, recent legislation obliged local governments to do a census of asbestos in buildings by April 2023, but the law is open to interpretation on whether private buildings should be included as part of this exercise. Similarly in the UK, an all-party parliamentary select committee recommended a 40-year timetable to remove asbestos in buildings and to create a central register of asbestos, but the government to-date has not agreed to the implementation but do review the relevant legislation as part of the post implementation review process. The announced legislative initiative on mandatory screening and registration of asbestos in buildings is welcomed, together with the revision of the EU Construction and Demolition Waste Management Protocol and the Guidelines for the waste audits before demolition and renovation works of buildings but should also be extended to other types of infrastructures. We promote a mandatory framework that facilitates the screening, registering and removal of asbestos before any renovation works can start. This needs to be accompanied by funding and capacity building efforts to address the financial and administrative burden that this measure can have at the workplace level and in particular for SMEs, as a failure to implement this correctly can lead to negative health and safety impacts. The collated data must also be made accessible for companies and workers who perform the work on the field. In view of the current Commission viewpoint of not considering a legislative framework for national asbestos removal plans, a barrier can arise affecting the capacity for employers (including mico-SMEs) to take all necessary steps to identify presumed asbestos-containing materials and to the management ACMs within the building. Without the foundations of an up-to-date Directive that amends the 2009/148/EC on the protection of workers from the risks related to exposure to asbestos at work, EU National regulatory asbestos strategies continue to be fragmented, ranging from nascent responses from countries such as The Netherlands and Italy, or through more structured responses, such as the case of Poland, where 17.3 percent of inventoried asbestos material has been removed as part of an asbestos removal programme that started back in 2003. In Italy as in other regions of the EU, their national removal programme faces territorial barriers (due to a decentralised system), issues due to the complex Italian legislative framework, lack of economic resources and more practical issues such as where to dispose the asbestos after a removal procedure. The benefits of more stringent requirements for transparency and disclosure when screening and registering the presence of ACMs in buildings when economic transactions are made (e.g., before sale or rent) and/or at other pivotal moments in the life-cycle of a building are worth exploring. A legislative proposal on mandatory screening and registration of asbestos in buildings through asbestos disclosure practices connected with sales, rentals and other economic transactions is seen as a positive step. The introduction of legal disclosure of ACMs to inform construction parties and end users of asbestos and asbestos-containing materials can ensure a more preventative approach, as seen in countries such as France, where an asbestos assessment is required . IOSH believes this requirement can be appropriate and will contribute towards a heightened level of transparency and disclosure.
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Response to Sustainable corporate governance

23 May 2022

Tackling corporate human rights issues across the entire value chain through a risk-based approach. The approach included in the directive proposal relies on the term ‘established business relationships’, this is a complex matter as the effective identification of supply chain connections is considered a systemic issue, in particular for those businesses with strong links to less visible or informal relationships. This can be the case for many large companies and SMEs that operate in hazardous industries or high-risk activities, or for large, companies operating in high-impact sectors, that need to improve on their ability to control their entire value chains across the world, including "indirect" third party suppliers. As abuse and misuse of subcontracting practices is ubiquitous in supply chains, a foreseeable challenge will be how to apply these responsible business conduct principles to all workers in all tiers of the chain, as yet many workplaces are known to hide the names of brands they supply for. A major setback on Director’s duties The directive was also hoped to align a part of directors’ variable remuneration with corporate sustainability goals, which would set appropriate incentives for businesses to transition towards sustainability. The articles relating to directors’ duties should be reinforced. Compared to the Commission’s initial impact assessment, the coverage of director’s duties in this proposal is extremely limited. Ownership of sustainable corporate governance issues should start from the top with the board and/or senior leadership, which must put in place the appropriate structures, control systems and processes. One aspect that IOSH regrets from the existing proposal is the ruling out from directors’ obligations and accountability to shareholders (e.g., requirements for linking the board of directors’ remunerations to achieving environmental or social-related targets), while placing the focus on corporate due diligence issues instead. From our perspective, due diligence mechanisms should be regularly evaluated on the same basis that board’s involvement and oversight. With this in mind, ownership of sustainable corporate governance issues should start from the top, with the board and/or senior leadership, which must put in place the appropriate structures, control systems, and processes. Climate change due diligence Climate-related issues can threaten business operations, supply chains, workers, communities and wider society, strengthening the duty for companies to tackle climate-related risks in their value chains will be a pivotal element in achieving socially and environmentally responsible business. As the environment changes and degrades, and despite efforts to ensure environmental sustainability, this will inevitably have consequences and might generate obligations for businesses. Practical reach It is clear that the potential for this proposed Directive to succeed relies with the scope of the EU's due diligence law. In practical terms the primary goal of making businesses accountable for human rights and environmental violations throughout their value chain will only cover to the so-called major corporate players (an estimated 1% of EU companies - 13,000 EU companies according to Euractiv), leaving apart the vast majority of SMEs (smaller companies from high-risk sectors are covered too, but only if they have over 250 employees and or turnover of more than €40 million) from the due diligence duty. This structure falls short from the initial ambition that looks at including a bigger share of businesses operating in the EU, regardless of sector or size. The Institution of Occupational Safety and Health welcomes the current proposal on mandatory corporate due diligence. However, this legislative development has to put the social elements of human rights in ESG due diligence (modern slavery, CSR, OSH, decent working conditions, supply chain sustainability) at the very top front.
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Response to Protection of workers from risks related to exposure to asbestos at work

22 Mar 2022

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, and revising worker protection legislation, setting binding occupational exposure limits and ensuring enforcement and availability of public health and occupational health capacity related to specific exposure to asbestos. IOSH promotes urgent action on tackling the huge global toll from work-related exposure to asbestos, and recognises action taken by the European Parliament recommendations European strategy for the removal of all asbestos in line with Parliament’s resolution with recommendations to the Commission on protecting workers from asbestos, that called on the Commission increase public policy efforts towards the removal of all asbestos and to revise Directive 2009/148/EC with regard to minimum requirements for certified training of workers exposed to asbestos. Based on recent/new scientific evidence, this should include an update on the occupational exposure limit value for asbestos, which should be set at 0.001 fibres/cm3 (1 000 fibres/m3). This is well-supported by the recommendation from the International Commission on Occupational Health (ICOH) , which also advocates for reducing the current limit value. Due to the large numbers of buildings that contain asbestos, awareness on management is essential and when planning and organising for the removal of asbestos it is essential that all OSH hazards and risks are identified and controls in place as necessary to prevent exposure to workers and other who could be exposed during its removal, transportation and disposal. We therefore also agree on the specific proposal for a EU framework directive for national asbestos removal strategies that needs to include updating Directive 2010/31/EU for the mandatory screening of buildings and subsequent removal of asbestos and other dangerous substances before renovation works can start. The timing for these actions to take place, and the competency of those persons is a necessity and a real game-changer for the prevention and management of asbestos. The following set of recommendations on strategies and priorities seek at encourage good practice and provision of solutions to address the previously exposed issues: • IOSH is supportive of the possibility of introducing public national registers and systematic screening of asbestos in buildings. This will require some consistency as only some EU Member States have developed registers of buildings containing asbestos. This process will require harmonisation, clear processes to remedy concerns around data capture, use and dissemination. • Those workers who have already fallen ill from asbestos must have access to early diagnosis, treatment, rehabilitation and sustainable return to work, and compensation. This will require capacity building by encourage investment by Member States to improve early diagnosis, treatment, social and medical rehabilitation of asbestos-related diseases. • Recognition and compensation procedures for asbestos victims must be improved and access to the necessary information must be facilitated to enable affected workers to obtain legal, financial, and personal assistance. • We see the European Commission playing a key role globally in reinvigorating the mandate of The International Labour Organization/World Health Organization Joint Program for the Elimination of Asbestos-Related Diseases. • IOSH has also called for improved training for employees in how to deal with asbestos, clearer guidance around working with asbestos and more awareness raising about the dangers of exposure.
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Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

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 challenges. This response focuses on the recommendations on improvements to the Chemical Agents Directive (CAD). Recommendations This response highlights a number of recommendations for better protecting workers from exposure to chemicals (lead and di-isocyanates), considering that legislative developments in the form of OEL’s will not be enough to reduce workers’ exposure to hazardous chemicals. • Enforcement and implementation at the workplaces, in particular in micro-SME companies, constantly has to be improved. This needs to be well-supported by other initiatives that seek to improve the way SMEs assess and control risks from hazardous substances, for the previously indicated sectors and activities. This should be extended to also comply with the requirements of the Carcinogens or Mutagens at work Directive CMD such as assessing and reducing occupational exposure and providing information, training, and health surveillance to workers. • Something that IOSH and other organisations such as EU-OSHA have supported to help filling the existing gap is the promotion of a harmonised EU led competence approach to support risk assessment practices and risk management authorities with current and future challenges related to chemical safety. Tools such as the Stoffenmanager for smart chemicals management are a representative example of best practices in translating technical issues into practical standards. • From a technical perspective, experts working on the field still struggle with occupational health and safety issues arising from the interrelationship between European occupational safety and health requirements and those coming from other legislative developments such as REACH and CLP. We believe there is still a need for better alignment to bring much needed consistency, understanding and comparability between Member States practices and perspectives. At the same time wider expertise needs to be taken into consideration in key decision-making initiatives from not only toxicologists, but also epidemiologists, occupational health and experts, and experts in public and occupational health. • More evidence-based research is needed to understand the health effects of exposure to toxic chemicals to women and to analyse the global burden of disease related to women and chemicals. As such, this evidence should be used in the identification of OELs and limit values. A stronger collaboration between the Commission key regulating bodies and the ILO, the WHO and the International Commission on Occupational Health should be stimulated (ICOH) is also suggested. • Raising-awareness initiatives that inform each worker who could be exposed to dangerous substances about the hazards related to the chemicals, and other on-site employers whose workers could be exposed, about chemical hazards and appropriate protective measures. We believe the European Agency for Health and Safety at Work 2018-19 campaign that aimed to raise awareness of dangerous substances in the workplace, the risks associated with them and how to prevent harm to workers was an excellent example of translating a technical issue into a wider audience. The campaign clearly tackled a structural issue, the low levels of literacy from workers and employers on this matter. We recommend building on this awareness initiatives to not only increase awareness of relevant EU legislation and but to provide businesses and workers with practical guidance on how to ensure compliance, prevention, and an effective management.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

IOSH welcomes the opportunity to comment on the ‘Impact Assessment’ as part of the ongoing process for a CSRD. Based on the recommendations to move forward incorporated in the Impact Assessment document for the Revision of the Non-Financial Reporting Directive we would like to reconfirm IOSH’s position, rationale and arguments: • Our recommended preference is for a mandatory, horizontal, cross-thematic due diligence legislation that provides robust foundations and mechanisms for compliance monitoring and capacity-building for enforcement purposes, by expanding the capacity of large companies and SMEs companies that operate in most risky sectors to report and disclose on social, employee and environmental matters and human rights matters. This blueprint could enable coverage across human rights, and social issues, including occupational safety and health, modern slavery and decent work aspects, along with sectoral guidance to address challenging issues such as trade and investment practices. It will also help to address the increasing pressure to act on sustainability, converting it into a necessity rather than an option of a voluntary nature. • Any EU-wide legislative system in the form of a level playing field mechanism would therefore need to be more inclusive and articulated through proportionality principles to reach the diverse spectrum of business’ complexities (e.g the different consumption, sourcing and production strategies, supply chain and human capital management, and so on). It should also entail awareness, educational and training strategies and tools to improve the compliance of Micro and Small Enterprises (MSEs). When it comes to the practicalities of SMEs operating systems, special attention needs to be paid to those operating in hazardous industries or high-risk activities where we expect the requirement to allow simplified reporting standards for SMEs on listed and non-listed markets to be adequately supported. • IOSH would like to see the following additional information specifically required from reporting organisations: a) Corporate occupational safety and health management performance reports; b) Corporate occupational safety and health management in supply chains reports; c) Corporate action to tackle modern slavery and human trafficking reports. IOSH would like to see the following additional categories related to governance and management: a) Leading indicators related to occupational safety and health training for decision-makers and corporate access to, and use of, occupational safety and health assistance; b) Leading and lagging indicators related to corporate occupational safety and health management system performance; c) Leading and lagging indicators related to the corporate protection, development and management of human capital. • IOSH would support a finalised version of a legislative initiative that proactively stimulates business working together towards comprehensive corporate reporting and disclosure on a broader spectrum of work-related human rights. To this respect, the existing proposal falls short. As part of the recovery from the current Covid-19 pandemic and in order to support the revitalising and building back better and healthier momentum, it is important that corporate reporting and disclosure practices become more effective, including on supply chain management, human capital, occupational safety and health and human rights due diligence. • We would thus like to highlight the fact the current form of the document fails to provide more clarity on how to achieve policy and business coherence in connection to reporting on Sustainable Development Goals (SDGs) – If this is not resolved at this design and consultation phase, it can result in a lost opportunity to leverage the SDGs-related aim for a world of work where businesses frame their sustainability policies towards decent work principles, and one which demonstrates a business’s value-creation and contribution.
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Response to EU Strategic Framework on Health and Safety at Work [2021-2027]

26 Nov 2020

The Institution of Occupational Safety and Health (IOSH), the Chartered body for occupational safety and health professionals and international NGO, has members living and working in most European Member States, and is pleased to have the opportunity to comment on the development of the Roadmap to the EU Strategic Framework on Health and Safety at Work [2021-2027]. IOSH believes that a wide-ranging European strategy on health and safety at work is required to address the humanitarian and socioeconomic consequences of COVID-19 (and the need to revitalise and build back better and healthier), while also urgently tackling the major global challenges of health inequality; climate change; demographic shifts; and new work models and technologies. We advocate that this should include: 1. Psychosocial risk and wellbeing 2. Musculoskeletal disorders 3. Occupational cancers 4. Work-related injury / illness and vulnerable groups 5. OSH capacity and return to work 6. Sustainability and human capital And, in addition, IOSH believes that the new strategy should also support public- and corporate-policy related to the following topics: 7. OSH and new forms of employment / technology 8. Trade, investment and development 9. Collaboration with key stakeholders 10. The new social license to operate IOSH is pleased to detail these recommendations and provide links to relevant materials in our supporting paper attached. For more information, visit www.iosh.com or contact us at: consultation@iosh.com or publicaffairs@iosh.com.
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