The European Commission published on 5 March 2018 its conclusions on the 2nd REACH Review. It which prioritised the REACH-OSH interface as one of the four issues requiring the most urgent action. Ceemet welcomes the Commission’s suggestion that the interface between REACH and OSH legislation calls for systemic solutions to address the main overlaps and discrepancies between the two legislative frameworks.

Ceemet set out its position on the need for a Universal Approach to Chemicals in its position paper dealing with environmental, product and worker protection, however for the purposes of this paper, we limit ourselves to the interplay between REACH and OSH.

Employers are committed to ensuring that worker health and safety is not harmed by exposure to hazardous chemical substances present at the workplace.

However, the safety and health risks from exposure to these substances are addressed by at least two different and overlapping sets of legislation. On the one hand, occupational health and safety (OSH) legislation: CAD (Chemical Agents at Work Directive – 98/24/EC) and CMD (Carcinogens or Mutagens at Work Directive – 2004/37/EC).

On the other hand, environmental legislation such as REACH (EC Regulation 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals).