COMMENTS

CII comments about the CARACAL Paper on the interface of REACH and OSH legislation

The CII considers that the CARACAL Paper does not address all key issues and that a Common Understanding Paper on REACH and OSH is needed. In this document, the CII also calls for Guidance on RMOAs.

Position Paper on the 2nd REACH Review

The CII welcomes the EC’s conclusion that the interface between REACH and OSH calls for systematic solutions

In this paper, the CII reflects on the Commission's preliminary findings on REACH and OSH and shares initial reactions and suggestions on the way forward.

Policy recommendation

Detailed Proposal and Responses to Questions Raised on Workplace Legislation

This document explains the CII proposal in more details, presents the specific strengths of workplace legislation as risk management option and responds to questions raised on the feasibility of the CII’s solution.

Policy recommendation

Enhancing the effectiveness of Occupational Safety and Health (OSH)

The CII presents recommendations on how to improve the effectiveness and workability of the current EU system for setting Occupational Exposure Limits (OELs), as part of the revision of EU Occupational Safety and Health (OSH) legislation.

POLICY RECOMMENDATION

Synergies between REACH and workplace legislation: Improved analysis of alternatives and substitution

The CII, supported by examples of substitution efforts, illustrates that successful substitution starts with stimulating the engagement in and documentation of Analysis of Alternatives efforts. 

Flowchart

How CII Proposals Integrate with the Commission’s SVHC Roadmap

This series of flowcharts presents how the CII proposal articulates with the European Commission’s Roadmap on Substances of Very High Concern (SVHC Roadmap) and the Risk Management Option Analyses (RMOAs) carried out by authorities.

POLICY RECOMMENDATION

CII background paper on workplace exposure limits

The CII discusses the different exposure values applicable at the workplace, their legal background and their relevance in occupational risk management.

COMMENTS

CII position on REACH restrictions that establish workplace exposure limits

In the paper, the CII notes that proposals to establish restrictions that are based on ‘reference exposure levels’ not to be exceeded at the workplace appear to be a circumvention of OSH and the legislative procedure for setting OELs.

DINNER DEBATE

CII presentation 'Strengthening RMOAs to better manage chemical risks while maintaining the competitiveness of the European industry'

During the dinner debate it co-organised with the German Ministry for Economic Affairs and Energy, the CII provided an overview of its recommendations to further strengthen RMOAs so that that they lead to consistent, proportionate and more predictable results.