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.
POLICY PAPER
Towards a more effective and consistent RMOA process to support the ambitions of the European Green Deal
The CII encourages an open and inclusive discussion between authorities and stakeholders on how to further improve Risk Management Option Analyses (RMOAs).
INFOGRAPHIC
6 Recommendations for better RMOAs
TECHNICAL PAPER
CII recommendations for a more effective and consistent RMOA process
The present paper analyses the status of what has already been achieved by means of RMOAs and identifies areas where, after several years of positive experiences with RMOAs, there may be opportunities for enhancing their consistency and effectiveness. This would make regulatory measures more efficient and targeted.
FEEDBACK
CII feedback to European Commission Chemical Strategy for Sustainability
The CII encourages an open and inclusive discussion between authorities and stakeholders on how to further improve the selection of Risk Management Options (RMOs)
POLICY RECOMMENDATION
CII background paper on Restrictions
In this paper, the CII recognises that Restrictions can be a useful RMO and could complement OSH in certain cases, provided certain conditions, listed in the paper, are fulfilled.
POLICY STATEMENT
The CII welcomes the Council Conclusions of 10 December 2019 calling for a clarification of the REACH-OSH Interface
The Cross-Industry Initiative for better regulation in chemicals management (CII) welcomes the Council’s Conclusions 'A New EU Strategic Framework on Health and Safety at Work: Improving the implementation of Occupational Safety and Health in the EU' which emphasize the importance of the regulatory framework of Occupational Safety and Health (OSH) and the need to further clarify the interface between OSH and REACH.
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.
