Surface Engineering Association
SEA
The Surface Engineering Association provides the 'focus' for all aspects of the UK surface engineering industry.
ID: 068589610068-77
Lobbying Activity
Response to Carcinogens 3rd wave of amendments
29 May 2018
The Surface Engineering Association represents the interest of UK companies involved in surface engineering activities and is committed to ensuring the that the impacts of our sector on both the environment and employees is as low as possible.
The proposed strategy is based on an incomplete analysis as both the Commission proposal and Impact Assessment focus exclusively on exposures through air inhalation and ignore exposure through ingestion.
The Commission proposal therefore relies on an excessively low OEL with questionable efficiency and significant difficulties in accurate measuring in a workplace environment.
In plants where workplace air is properly controlled, ingestion (through repeated hand to mouth contacts) is usually the main source of exposure.
Biomonitoring of Cd in urine shows all uptake of cadmium, historic and recent, through both inhalation and ingestion.
The SCOEL 2010 approach controls both inhalation and ingestion. It requires compliance with an OEL of 4 µg/m3 (respirable faction) which monitors inhalation only, in combination with a biomonitoring limit value of 2 µg/g creatine in urine which monitors both exposure routes.
The Binding OEL of 1µg/m3 (inhalable fraction), as well as the transitional OEL of 4 µg/m3, proposed by the Commission would mandate the use of personal respiratory equipment during full shifts, with serious consequences on the working conditions of personnel and the ensuing turnover. In the longer term, this will promote the transfer of industrial activities of several EU plants to America or Asia where regulations provide for an efficient combination of air limit values and biomonitoring.
Therefore, we strongly urge the Commission to recognize the importance of biomonitoring to protect the health of each worker individually by allowing facilities where biomonitoring is undertaken to implement the Binding OEL of 4µg/m3 (respirable fraction), set by SCOEL in 2010 and confirmed by SCOEL in 2017.
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