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Recommendations by an EU-wide cross-industry initiative for better regulation in chemicals management

Better regulation in chemicals management requires identification, implementation and enforcement of the most effective risk management option, tailored to tackle a specific risk. Please find the document below in English, German, French and Italian. 

FEEDBACK

CII comments on the 'Paper to inform joint CARACAL and ACSH/WPC discussions on the interface between REACH and OSH' (CA/05/22)

The CII welcomes the organisation of the 1st Joint Meeting of CARACAL and the ACSH/WPC, as well as the related background paper which proved to be a useful basis for constructive exchanges at the meeting. We appreciate the opportunity to comment on the background paper. We have firstly addressed the questions asked in the background paper and then added some further reflections on the topic. We encourage continuing the discussions in further joint meetings of CARACAL and ACSH/WPC.

FEEDBACK

CII contribution to the European Commission’s public consultation on the targeted revision of the REACH Regulation

The Cross-Industry Initiative for Better Regulation in Chemicals Management (CII) welcomes the opportunity to reply to the European Commission’s public consultation on the targeted revision of the REACH Regulation. In its replies and comments, the CII has focused on the much-needed clarification of the REACH-OSH interface.

EVENT

A successful first session of the CII REACH-OSH Forum

We are really pleased that about 50 experts from all over Europe joined us for the first CII REACH-OSH Forum on 1 April 2022. The aim of this Forum is to provide an informal platform for the European Commission, Member States’ experts, trade union and industry representatives and other relevant stakeholders to exchange views and discuss solutions to clarify the REACH-OSH interface. Please find below the summary overview of this event.

FEEDBACK

CII comments on the CARACAL paper on the Reform of the REACH Authorisation and Restriction Processes

The Cross-Industry Initiative for Better Regulation in Chemicals Management (CII) welcomes the opportunity to provide its views on the reform of the REACH Authorisation and Restriction, as presented by the European Commission to CARACAL on 27 January 2022 (CA/03/2022). In this context, we support the Commission’s intention to clarify the interface between REACH and other pieces of EU legislation, most notably the Occupational Safety and Health (OSH) framework.

FEEDBACK

CII feedback to the commission inception impact assessments ahead of the revision of the CLP regulation

The CII welcomes the Commission Inception Impact Assessments for the revision of the CLP Regulation. In this context, the CII does not recommend the introduction of the possibility to set harmonised limit values by CLP. The CII urges the Commission and Member States to assess whether such limit values set under the CLP would in any way pre-empt the necessary considerations in risk management. This is essential to enable tailored and efficient protection of workers from chemical risks, while maintaining workplaces and the competitiveness of European industries.

POSITION PAPER

Joint SMEUnited and CII views on DGs ENV-GROW paper on REACH Restriction and OSH OELVs

SMEUnited and the CII welcome the Commission’s initiative to clarify the REACH-OSH interface and consider that transparent procedures and criteria should be used when selecting the most appropriate regulatory options. We welcome the DGs ENV-GROW’s thought-starter to promote a decision tree that would clarify the interface and optimise worker protection.

STATEMENT

CII recommendations regarding the EU Strategic Framework on Health and Safety at Work (2021-2027)

The CII fully supports a strong EU framework for Occupational Health and Safety (OSH) that strives for a consistent improvement of the health and safety of workers across Europe. To ensure an ever-stronger OSH framework and its implementation in the EU, the CII recommends clarifying of the interface between REACH and OSH legislations, as well as improving the predictability and consistency of RMOAs.

POSITION PAPER

CII response to ECHA RAC/SEAC opinion on an Annex XV restriction dossier for N,N Dimethylformamide (DMF)

The CII considers the restriction proposal applied to DMF is not the appropriate policy instrument to manage risks posed by exposure to chemicals in the work environment. In this context, the CII considers that the REACH-OSH interface should be clarified with priority.

CONTRIBUTION

CII contribution to the consultation regarding the 4th revision of the Carcinogens and Mutagens Directive 2004/37/EC

The CII welcomes the Commission’s proposal for a revision of the Carcinogens and Mutagens Directive (CMD) and would like to express its support to the further setting of occupational exposure limit values (OELVs) for substances presenting a risk in the workplace specifically.