Document VGNegg0pLmE1z0nvKpd8znomw

a. w iY =o 8 kL q ) [| y) -_, y WN RT -- CIE Cat bY y ustainability RI 6 and Health ETBIC NS 4 , ational Safety. rgpecti RL 1) ols 1 (Eee Ve om ZN TE Ege CE LEE EI "4 PINE 2 " MA os. Interface REACH and OSH Binding measures for risks under REACH and OSH REACH authorisation: binding risk management measures as authorisation conditions REACH restrictions: binding conditions for the use of substances OSH Occupational Exposure Limits, Biological Limit Values and notations + OSH Specific Directives (e.g. asbestos) Le Choice between measures under OSH and REACH + No fixed rules in the choice between REACH and OSH In the past, REACH measures were focused rather on placing on the marketof substances (in particular restrictions; Directive 76/769/EC) =With authorisation worker protection measures came more and more in the focus of REACH <REACH restrictions can be proposed by single Member States and can be adopted via comitology =Someofthe latest restrictionscovertraditional worker protection subjects (e.g. harmonised limit values for aprotic solvents; training obligations fordiisocyanates) <OELs for cases where authorisation and restrictions proved to be problematic (e.g. cobalt) + Problem: incoherent solutions, overlaps, inefficiency + Attempt to achieve a better planning through risk management options analysis (RMOA) LE] RMOA + Case-by-case analysis on an informal basis When are regulatory measures for certain substances necessary? >If yes, what is the most appropriate legal framework? > Done by Member States, ECHA, industry, Commission, discussion at RIME+ platform (informal) Possibleresults (i.a.): Verification of hazard properties through harmonised classification and labelling (LH) Identification as substance of very high concern (SVHC) REACH restriction Legislative measures under OSH or other legislation mo "One Substance, One Assessment" in the Chemicals Strategy RMOA stays voluntary instrument Reinforcementof the PACT (public activities coordination tool) instrument >Transparent publication of regulatory planning beyond REACH + Expert group for the implementation of the "Once substance, one assessment" concept > Improvement of co-ordination of regulatory measures in different areas Better exchange and useof data between different regulatory areas + Transferof competences between scientific committees/Agencies and creation ofa separate legal basis for ECHA LI OELs, DNELs and DMELs De facto, DNELS and OELS are all limit values for occupational safety and health, with BOELSs taking into account practical feasibility. <Dmiavneraggienmgelnitmitmevaalsuuerseso.ften lead to confusion concerning the applicable risk In case toxicological reference values will be introduced in CLP, this may help to objectivise and strengthen risk management of hazardous substances. Nevertheless, this may also aggravate potential inconsistencies with OELs. Where OELS are higher, workers' protection measures will have to be strengthened due to the new harmonised DNEL/DMELlimitvalues. There maybe a need to clarify the applicable limit values, as well as practical solutions/derogations, in particular for processes for which respecting DNELS/DMELs will be very difficult in practice. || Reformof Authorisation and Restrictions The authorisation process is = Applies only to manufacturing in the EU -- = Once an authorisation is given, there is , slow and controversial Keep authorisation `with clarifications and simplifications | Clarification of the REACH-OSH Interface =At this point in time only options for the impact assessment, no decisions as yet + Further discussions planned for the expert groups for REACH and OSH legislation * Possible modifications include: Integrated approach for problematic areas in worker protection and co- ordinated packages of measures + Question: should REACH gofurther and open for the possibility to set occupational exposure limits for specific uses? + Remove worker protection measures from REACH and increase use of OSH legislation -- REACH Revision -- State of Play . Inception impact assessment published: httpsijec.europa eulinfollawlbetter: regulation/have-your-say/initiatives| Lam evision-of-EU-legislation-on- registration-evaluation-authorisation-and-restriction-of-chericals- =Commenting period closed on 1 June 2021: 325 contributions received + 12 ongoing studies + Several workshops, including 9 and 12 November 2021 workshops on reform of aMuatrhcohri2s0a2t2iownoarnkdshroesptroinctgieonnesr;i3cMaaprpcrhoa2c0h22toworirskksmhaonpaogneemsesnenttial uses; 21 + Joint Caracal/ACSH-WPC meeting 5April 2022 + Open public consultation 20 Januar-y 15 April 2022 Impact assessment tobefinalised in September 2022 + Revision proposal by end 2022 LE Collaboration between different policy areas Close cooperation & collaboration of DG EMPL and REACH DGs (GROW/ENV) Early involvement of OSH stakeholders when discuss matters related to health and safety at work, for example: + Presentation/exchanges on REACH and CLP revisions at the tripartite Working Party Chemicalsof the Advisory Committee on Safety and Health at Work (ACSH); AACSH bureau, ACSH interest groups; Chemical Safety and Health Issues Working Party (CHEMEX)of the Senior Labour Inspectors Committee (SLIC) + Public consultations + Participation at relevant workshops. | oo = 1 . 2y 34 8 = 3 * IL v rig k )/ ) ` prnl oYA RY NT 1 Rr J "for Y i Va Ra als Strategy Sustainability =m |