The battle to keep respirable crystalline silica (RCS) out of the carcinogens and Mutagens Directive (CMD) has been lost and it is due to be debated and added to Annex III of the directive imminently.
There is a second issue with RCS in the CMD, which the Cast Metals Federation and SHIFT only became aware of during a European Foundry Association (CAEF) meeting held in November; that being the exposure level is being reviewed with consideration to creating a binding occupational exposure level (BOEL) of 0.05mg/m3 over an 8 hour period, a figure half the current UK limit. This would apply to all EU countries.
The NePSi signatories have created a position paper aimed aim at keeping the current level, for a number of technical reasons, including the ability to accurately measure to the new level with confidence. At present, it is anyone’s guess which way the decision will go when it is debated at the next EU Commission meeting.
It is highly likely that should the proposed limit be adopted, it will mean greater costs for monitoring and health surveillance; however, there are also implications for the cost of and use of engineering controls which have to be considered long before RPE is considered, especially in the CMD.