Protection of workers from exposure to carcinogens or mutagens: second proposal (CMD 2)

13-07-2017

The IA defines the problem clearly, and its evolution without EU action is comprehensively outlined. The objectives appear to be relevant, sufficiently measurable, achievable, and consistent with the manner in which the problem has been defined, as well as with other EU policies; however, they are not time-bound. The methodology used to compare the scope of impacts is well-developed, even though it is not always clear how the reported figures were obtained. However, the proposed range of options limits the scope of the analysis, and some of those retained for consideration are not entirely convincing. Environmental impacts are claimed not to be significant, without any explanation being provided. There is also a general issue regarding the availability of timely and reliable data, as well as the scarcity of available epidemiologic evidence. The Commission has consulted a broad range of stakeholders, and the replies received were highly representative of all national-level social partner organisations of employers and trade unions. Finally, the IA seems to have addressed the RSB's recommendations.

The IA defines the problem clearly, and its evolution without EU action is comprehensively outlined. The objectives appear to be relevant, sufficiently measurable, achievable, and consistent with the manner in which the problem has been defined, as well as with other EU policies; however, they are not time-bound. The methodology used to compare the scope of impacts is well-developed, even though it is not always clear how the reported figures were obtained. However, the proposed range of options limits the scope of the analysis, and some of those retained for consideration are not entirely convincing. Environmental impacts are claimed not to be significant, without any explanation being provided. There is also a general issue regarding the availability of timely and reliable data, as well as the scarcity of available epidemiologic evidence. The Commission has consulted a broad range of stakeholders, and the replies received were highly representative of all national-level social partner organisations of employers and trade unions. Finally, the IA seems to have addressed the RSB's recommendations.