Protection of workers from exposure to carcinogens or mutagens

18-07-2016

Overall, the Commission appears to have provided sound reasoning and justification for the initiative. The methodology used to compare the scope of impacts is well-developed, but the proposed range of options limits the scope of the analysis. As Option 3 is barely considered, and Option 4 does not seem to be consistent with the objectives, the added value of these options is not evident. Moreover, both the IA and the Explanatory Memorandum of the proposal are not explicit about the preferred option. More information on the consultation with SCOEL and ACSH would have been welcomed in order to understand the way in which the OELs were set. Finally, it is not entirely clear why the Commission has come forward with this proposal before the ex-post evaluation of the OSH Framework undertaken within the remit of REFIT has been completed. Indeed, including the results of the ex-post evaluation in the IA might have strengthened the Commission’s evidence base as well as further clarified the monitoring and evaluation arrangements and the interaction between the various pieces of legislation under the OSH Framework.      

Overall, the Commission appears to have provided sound reasoning and justification for the initiative. The methodology used to compare the scope of impacts is well-developed, but the proposed range of options limits the scope of the analysis. As Option 3 is barely considered, and Option 4 does not seem to be consistent with the objectives, the added value of these options is not evident. Moreover, both the IA and the Explanatory Memorandum of the proposal are not explicit about the preferred option. More information on the consultation with SCOEL and ACSH would have been welcomed in order to understand the way in which the OELs were set. Finally, it is not entirely clear why the Commission has come forward with this proposal before the ex-post evaluation of the OSH Framework undertaken within the remit of REFIT has been completed. Indeed, including the results of the ex-post evaluation in the IA might have strengthened the Commission’s evidence base as well as further clarified the monitoring and evaluation arrangements and the interaction between the various pieces of legislation under the OSH Framework.