Lower limits for exposure

In January 2018 the European Union adopted a directive (Directive 2017/2398) concerning workplace exposure to substances that have been identified as being either carcinogenic or mutagenic (capable of causing permanent change in an organism’s genes).

The EU sets limits for exposure to harmful chemicals at work using Indicative Occupational Exposure Limit Values (IOELVs) which member states are required to implement with national exposure limits. The EU regularly revises these limits as knowledge of the harm different substances can cause develops.

The latest directive reduces the exposure limits for Hardwood dusts, Chromium (VI) compounds, Hydrazine, Acrylamide, Refractory ceramic fibres, Vinyl chloride monomer, O-toluidine, 1,3 butadine, Bromoethylene (vinyl bromide), Ethylene oxide, 1,2 epoxypropane (propylene oxide) and 2-nitropropane. In addition, while the exposure limit is unchanged, respirable crystalline silica is now to be classified as a carcinogen.

Member states have until 17^th January 2020 to implement the latest changes.

In the UK workplace exposure limits are set for various hazardous substances under the COSHH regulations, these are based on the amount of a hazardous substance present in the air that people breathe, averaged over a specified reference period. Two periods are used a long-term exposure limit (8 hours) and a short-term exposure limit (15 minutes). A list of UK exposure limits is set out in the HSE’s publication EH40/2005.

The HSE proposes to implement the required changes by updating EH40/2005 and has launched a consultation on these proposals. The consultation runs until 7^th June 2019. You can review the proposals and respond to the consultation via the HSE’s website at https://consultations.hse.gov.uk/hse/carcinogens-mutagens-revision-of-limit-values.

For most of these substances it is considered that there should not be significant additional costs to industry in complying with the new limits however there is potential for higher costs to be involved in complying with the lower limits for Hardwood Dust and Chromium (VI) and extended transitional periods are included in the directive for these (January 2023 Hardwood Dust and 2025 Chromium (VI)) to allow time for industry to phase-in improvements in controls and working practices to achieve compliance.

The HSE’s current consultation only relates to regulations that will apply in England, Scotland and Wales and the initial limits to be introduced n January 2020. It is proposed to consult on the substances with extended transition periods nearer the implementation dates. The HSE for Northern Ireland will follow a similar process for implementing the Directive there.

Please speak to your normal PIB Risk management contact or get in touch using [email protected] if you have any questions about managing health risks or would like to arrange a Health and Safety compliance audit.