Protection of workers from exposure to carcinogens or mutagens: third proposal

27-06-2018

The impact assessment (IA) accompanying the proposal for a third revision of the carcinogens and mutagens Directive 2004/37/EC clearly defines the problem to be addressed. However, it would have benefited from providing more comprehensive explanations of its evolution without EU action. The objectives appear to be relevant, sufficiently measurable, achievable, though not time-bound. The IA considers a wide range of options, and those retained for further assessment appear to be reasonable, and consistent with the approach followed in two previous amendments of the directive. The analysis of impacts focuses on the economic and social dimension, mainly health, consistently with the manner in which the problem has been defined. Environmental impacts are assessed to be broadly negligible: considering that the IA is dealing with carcinogenic chemical substances, this would have perhaps required further justification. The IA acknowledges a general issue regarding, inter alia, the availability of data on the number of workers exposed, and the scarce and not always sufficiently robust epidemiological evidence. The methodological annex does not provide information regarding how the multi criteria analysis has been performed. Finally, the IA appears to have addressed most of the RSB's recommendations and the legislative proposal appears to be consistent with the analysis carried out in the IA.

The impact assessment (IA) accompanying the proposal for a third revision of the carcinogens and mutagens Directive 2004/37/EC clearly defines the problem to be addressed. However, it would have benefited from providing more comprehensive explanations of its evolution without EU action. The objectives appear to be relevant, sufficiently measurable, achievable, though not time-bound. The IA considers a wide range of options, and those retained for further assessment appear to be reasonable, and consistent with the approach followed in two previous amendments of the directive. The analysis of impacts focuses on the economic and social dimension, mainly health, consistently with the manner in which the problem has been defined. Environmental impacts are assessed to be broadly negligible: considering that the IA is dealing with carcinogenic chemical substances, this would have perhaps required further justification. The IA acknowledges a general issue regarding, inter alia, the availability of data on the number of workers exposed, and the scarce and not always sufficiently robust epidemiological evidence. The methodological annex does not provide information regarding how the multi criteria analysis has been performed. Finally, the IA appears to have addressed most of the RSB's recommendations and the legislative proposal appears to be consistent with the analysis carried out in the IA.