Draft proposal for a directive on electro magnetic fields & waves

WEM & Orgalime comments on the basis of the proceedings of the meeting of the Social question working party of 19 may 2003

Between them, ORGALIME and WEM (our sister organisation representing employers’ federations) represent about 200 000 companies employing some 12 million people over 22 European countries, 97% of them are small and medium sized enterprises (SMEs).

On 12 May 2003, we have sent to national representatives in the Social Questions Working Party of the Council our detailed comments on the Amended Commission Proposal for a Directive on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields and waves).

On the basis of the outcome of your meeting on 19 May 2003, WEM and ORGALIME have updated their comments prior to the next meeting of the group on 22 July 2003, under the Italian Presidency of the Council.
If we do welcome the progress made as regards Article 8 on health surveillance, we call the attention of the Council Working Party on the need to reach a workable and balanced solution for all parties, especially as regards Article 3 and 5, which would allow the proposed Directive to move forward with the support of industry

In particular WEM and ORGALIME believe that the overall costs of such a regulatory framework, which we evaluate for the EU 15 between 510 and 1618 million euros one-off costs and between 5,5 up to 15 billions euros running costs over 10 years, would be more proportionate and sustainable for businesses, especially SMEs, if an easier compliance assessment procedure would be provided for businesses using CE marked equipment according to the Low Voltage and RTTE Directives.

References: COM (92) 560 Final / Inter-institutional file 92/0449(COD)