Request to the Committee for Risk Assessment (RAC) to provide an evaluation of occupational exposure limits (OELs) for nickel and its compounds, acrylonitrile and benzene

The Committee for Risk Assessment (RAC) requested ECHA (in their letter Ref. GL/ps ARES env.b.2(2017)1407647 of 8 March 2017) to evaluate the information already available and assess the most recent scientific information, in accordance with Directive 98/24/EC on the protection of the health and safety of workers from the risks related to chemical agents at work (CAD) and/or Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work (CMD), on the chemical compounds: 4,4′- methylenebis[2-chloroaniline] (MOCA), arsenic acid and its inorganic salts, nickel and its compounds, acrylonitrile and benzene.

The purpose of this evaluation and assessment is to support the Commission, by providing scientific advice, in taking action on the Proposal to amend Directive 2004/37/EC (4th amendment). The RAC opinions provided shall include a recommendation to the Advisory Committee on Safety and Health at Work (ACSH) in line with the OSH legislative procedures and, on request of the Commission, the SCOEL-format in drafting their opinions shall be used and would need to be provided to the Commission by 26 March 2018. To this end, detailed timelines will be prepared and agreed with the Committee.

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Baseline report: Legal requirement according to IED

The Baseline Report is a legal requirement of the article 22 of the Industrial Emissions Directive 2010/75 / EU “Site Closure”. An operator has to prepare and submit to the competent authority a baseline report before starting operation of an installation or before a permit for an installation is updated for the first time after 7 January 2013.

The Baseline Report is a key tool and has to be drawn up before starting the operation of the installation. It should contain the information necessary to determine the state of soil and groundwater contamination in order to make a quantified comparison with the state upon definitive cessation of activities. During the closure phase, the operator assesses the state of soil and groundwater pollution. If the installation has caused significant pollution of soil or groundwater by relevant hazardous substances compared to the state established in the baseline report, the shall take the necessary measures to address that pollution so as to return the site to the previous unpolluted state. For that purpose, the technical feasibility of such measures may be taken into account.

Eco-Efficiency Consulting and Technical Ltd. has the experience of preparing a Baseline Report and can guide you at all stages and obligations according to European legislation by:

  1. collecting all the necessary data in order to decide whether a baseline report is required;
  2. determining how a baseline report has to be prepared
  3. defining the main basis for the preparation of the Baseline Report, seeking and correlating the sources of emissions, the routes from which the pollution and the receptors likely to be affected can circulate,
  4. drawing up a soil and groundwater sampling plan in cooperation with accredited laboratories
  5. combining all the above data in order to produce a baseline report