CMD Amendment 3

CMD Amendment 3

A consortium comprising RPA Risk & Policy Analysts (United Kingdom), FoBiG Forschungs- und Beratungsinstitut Gefahrstoffe (Germany), COWI (Denmark), and EPRD Office for Economic Policy and Regional Development (Poland) has been contracted by the European Commission (DG Employment, Social Affairs and Inclusion) to carry out a study to support a possible amendment of Directive 2004/37/EC on the protection of workers from exposure to carcinogens or mutagens at work.

The objectives of the study are:

1. to assess the impacts of establishing Occupational Exposure Limits (OELs) under the CMD and, where relevant, other potential measures for the following chemical agents:

    • cadmium and its inorganic compounds*1;
    • beryllium and its inorganic compounds* (also includes consideration of a Short-term Exposure Limit STEL);
    • inorganic arsenic compounds including arsenic acid and its salts*;
    • formaldehyde (also includes consideration of a Short-term Exposure Limit STEL); and
    • 4,4'-Methylene-bis(2-chloroaniline) (MOCA) (includes consideration of a skin notation).

*As far as under the scope of the CMD

For each agent, a range of potential limit values is being assessed reaching from the lowest to the highest values resulting from SCOEL recommendations, RAC opinions and OELs established in EU Member States.

2. to describe and assess the OEL-deriving systems in EU Member States and selected competitor countries.

3. to describe the impacts of the OEL of 5 µg/m3 for ‘chromium (VI) compounds in welding or plasma cutting processes or similar work processes that generate fume’ which will enter into force five years after the transposition date of the compromise recently reached by Council and the European Parliament on the Commission proposal COM(2016)248 final.

Please see “Supporting Documentation” for the European Commission’s  letter of support for this study.

The purpose of stakeholder consultation for this study is to collect data and information that will underpin the assessment. This data will be collected through questionnaires developed for specific stakeholder groups.  The questionnaires can be completed either online (links are provided in the bullet points below) or by downloading the word version (available at the bottom right-hand side of this webpage) and sending it back to Daniel Vencovsky (

If relevant to your organisation, please complete one or more of the following questionnaires:

  • Questionnaire 1 for companies whose workers are exposed to cadmium and its inorganic compounds, beryllium and its inorganic compounds, inorganic arsenic compounds, formaldehyde, and 4,4'-Methylene-bis(2-chloroaniline) (MOCA): en, de, fr, es, it, pl
  • Questionnaire 2 for companies whose workers are exposed to Cr(VI) compounds from welding, plasma cutting, and similar processes that generate fumes: en, de, fr, es, it, pl
  • Questionnaire 3 for Occupational Health & Safety consultants/experts: en, de, fr, es, it, pl
  • Questionnaire 4 for Member State authorities that are responsible for setting and/or enforcing national OELs and/or would be able to provide any information, views, and data on the likely impacts of new OELs, STELs and skin notations under the CMD: en

The deadline for completion of all questionnaires  is 3 November 2017If you are interested in completing this questionnaire but need more time, please contact the study team prior to the deadlines given above to agree an individual deadline.

If you have any questions about this study, please contact Daniel Vencovsky ( or +44 (0)1508 528 465).

Confidentiality statement:  Responses to Questionnaires 1-3 will be handled in the strictest confidence and will only be used for the purposes of this study.  In preparing our reports for the Commission (which, subsequently, may be published), care will be taken to ensure that specific responses cannot be linked to individual companies.

Consultation with other stakeholder categories:  Other stakeholder categories (trade unions, manufacturers of Risk Management Measures, etc.) are being approached by email.  If you have not received an email and would like to contribute your views, please contact the study team.

1 In collaboration with the International Cadmium Association (ICdA), RPA will survey ICdA members by means of a dedicated questionnaire. If your company is a member of ICdA or regularly takes part in ICdA’s Health and Safety (H&S) activities and related exposure reporting surveys (OCdBIO and OCdAIR), there is no need for you to complete this questionnaire; a dedicated questionnaire will be sent to you by ICdA in the near future.

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Supporting Documentation