Exposure limit value for hardwood dust
The European Organization of the Sawmill Industry (EOS) expresses its deepest concerns related to the agreement on the Carcinogens and Mutagens at Work Directive by Maltese presidency and the European Parliament on the hardwood wood dust threshold limit.
While supporting the reduction of the existing exposure limit value at 3mg/m3 restrictedly for hardwood dust (currently at 5 mg/m3), the further lowering of the threshold at 2mg/m3 in 5 years’ time is not supported by any impact assessment and it lacks technical feasibility.
Moreover, any threshold limit would differently apply in Member States because the testing methods are not harmonised. Today different testing methods lead to lack of comparability, which undermine efforts aimed at increasing workers’ protection at the European level. Prior to any consideration on the most appropriate threshold limit, a common methodology should therefore be established. Presently, some European Member States are actually refusing the harmonization of testing methods, provoking great discrepancies in the internal market and without giving any realistic guarantee of safer and healthier working place.
It should be acknowledged that even the most high-quality ventilation systems used in the sawmill plants are sold on the market only with the information related to the quantity of wood dust absorbed/ captured by the machine. Hence, no guarantee is given about the exposure threshold that can be achieved. The European Sawmill Industry is always committed in finding the best and most advanced technologies, but only realistic and feasible exposure limit value should be proposed and adopted homogeneously by Member States.
It is reasonable to believe that no hardwood sawmill plants will be able to achieve any threshold below 3mg/m3. Furthermore, the exposure threshold shall not be applied in the fresh sawn timber cutting phase as it is technically impossible to do a reliable dust sampling in this phase (particle size, high moisture condition). Finally, unlike other substances, wood cannot be substituted in order to better comply with the European legislation or to reduce compliance costs.
Without doubt the European Sawmill Industry, as the European woodworking and the furniture sector, is very committed in providing workers with the best and safest working conditions. The exposure limit value of 3 mg/m3 restrictedly for hardwood dust - as proposed by the European Commission – was already identified in the impact assessment as the “clearly preferred value” that combines clear benefits both for workers’ health and companies’ technical and economic possibilities.
Together with the woodworking and furniture sector, EOS agrees with the necessity to better reflect on the status of technology available and call for the need of harmonised measurements. In this sense, we support the request for a Wood Dust Conference – aimed at analysing these existing issues – that will soon be submitted to the European Commission by Social Partners in the field.
EOS regrets that this agreement was reached without considering the specific issues that have been continuously raised by European Sawmill, Woodworking and Furniture Industry on the technical aspects related to our processing structure.
Together with the woodworking and furniture sector, EOS agrees with the necessity to better reflect on the status of technology available and call for the need of harmonised measurements. In this sense, we support the request for a Wood Dust Conference – aimed at analysing these existing issues – that will soon be submitted to the European Commission by Social Partners in the field