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

17-12-2018

This detailed appraisal focuses on the process and evidence base used in the IA for setting the limit values for cadmium and beryllium, notably in light of some knowledge gaps and methodological challenges identified in the IA in relation to the number of workers exposed and the estimation of the burden of disease. The appraisal concludes that the IA has relied on a vast and updated amount of information, including scientific journals, guidelines, manuals, surveys, published by authoritative research centres, publishers and international organisations, making the overall analysis sufficiently convincing and robust. As regards the limitations of the analysis, which are transparently acknowledged, the analysis carried out by the external contractors and endorsed in the IA recognises that the full current and future disease burden deriving from historic exposures to cadmium and beryllium is not captured; consequently, the disease burdens may be underestimated. As regards the estimated number of workers exposed to cadmium, the value of 10 000 workers considered by the external contractors for their modelling (in addition to a higher value of 30 000), and taken over in the IA, is coherently justified in light of the recognised wide divergences among the different estimates. This value appears to be reasonable, based on the availability of data at national and EU level, and the way some of them were gathered. As regards the estimated number of workers exposed to beryllium, the figure of 54 071 workers exposed in the EU 28 (excluding the construction sector) identified by the external contractor and used in the IA appears to be plausible, based on the justifications provided. However, it is acknowledged that higher exposure levels would imply higher costs and benefits at all target OEL values.

This detailed appraisal focuses on the process and evidence base used in the IA for setting the limit values for cadmium and beryllium, notably in light of some knowledge gaps and methodological challenges identified in the IA in relation to the number of workers exposed and the estimation of the burden of disease. The appraisal concludes that the IA has relied on a vast and updated amount of information, including scientific journals, guidelines, manuals, surveys, published by authoritative research centres, publishers and international organisations, making the overall analysis sufficiently convincing and robust. As regards the limitations of the analysis, which are transparently acknowledged, the analysis carried out by the external contractors and endorsed in the IA recognises that the full current and future disease burden deriving from historic exposures to cadmium and beryllium is not captured; consequently, the disease burdens may be underestimated. As regards the estimated number of workers exposed to cadmium, the value of 10 000 workers considered by the external contractors for their modelling (in addition to a higher value of 30 000), and taken over in the IA, is coherently justified in light of the recognised wide divergences among the different estimates. This value appears to be reasonable, based on the availability of data at national and EU level, and the way some of them were gathered. As regards the estimated number of workers exposed to beryllium, the figure of 54 071 workers exposed in the EU 28 (excluding the construction sector) identified by the external contractor and used in the IA appears to be plausible, based on the justifications provided. However, it is acknowledged that higher exposure levels would imply higher costs and benefits at all target OEL values.