3. Proposal of the Commission
3.1.1 Cadmium and its inorganic compounds under the scope of the CMD: Occupations in which exposures occur include cadmium production and refining, nickel-cadmium battery manufacture, cadmium pigment manufacture and formulation, cadmium alloy production, mechanical plating, zinc and copper smelting, mining of non-ferrous metal ores, brazing with a silver-cadmium-silver alloy solder, polyvinylchloride compounding and recycling of scrap metal and Ni-Cd batteries. The Commission estimates that about 10 000 workers are at risk.
3.1.2 Beryllium and inorganic beryllium compounds under the scope of the CMD: Ten industrial sectors such as foundries, glass and laboratories were identified in which workers are at risk of exposure to beryllium. Copper, aluminium, magnesium and nickel are widely alloyed with beryllium. Approximately 80% of all beryllium is used in copper alloys. Exposure to beryllium causes lung cancer and incurable chronic beryllium disease. The Commission estimates that 54 000 workers are at risk.
3.1.3 Arsenic acid and its salts, as well as inorganic arsenic compounds under the scope of the CMD: Exposure to arsenic compounds occurs, for example, in copper and zinc production, as well as in the glass, electronics and chemical sectors. The Commission estimates that 7 900 – 15 300 workers are at risk.
3.1.4Formaldehyde: Occurs in formaldehyde manufacturing, and in a wide variety of products (adhesives and sealants, coating products, polymers, biocides and laboratory chemicals); exposure may also happen during activities such as building and construction work, and in the manufacturing of leather and fur, pulp, paper and paper products, textile and wood and wood products. Formaldehyde is also used for tissue preservation and as a disinfectant in pathology departments and autopsy rooms. The number Commission estimates that around 1 million workers are at risk.
3.1.5 4,4'-Methylene-bis(2-chloroaniline) ("MOCA"): Exposed workers work in the plastics sector, where MOCA is used for moulding of polyurethane elastomer parts at 89 sites across the EU. The Commission estimates that 350 workers are at risk.
5. Specific comments
5.1 The EESC draws attention to the danger, that ineffective prevention of exposure to carcinogens, mutagens and reprotoxic agents could have negative consequences for businesses, such as higher costs and reduced productivity due to absenteeism, compensation costs to claimants, lost expertise and distorted competition; and for Member States due to increased social security costs and lost tax revenues.
5.2 Member State authorities and employers' and workers' representative bodies within the framework of the tripartite ACSH would very much welcome the legal clarity and increased protection that would result from lower OELs on these substances.
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