REACH should have considerable impact on the existing legislation designed to protect workers exposed to hazardous substances in the various sectors concerned, namely by:

• providing missing information on their properties;

• making chemical safety data publicly available on a right-to-know basis;

• enforcing the efficient distribution of information to downstream users and their personnel in a bid to counteract the risks of occupational diseases.

Indeed, one out of every three occupational diseases recognised annually in Europe can be ascribed to exposure to hazardous chemicals.

With a view to genuinely improving the health protection of workers exposed to chemical products, the ETUC demands that particular attention should be paid to ensuring that the obligations laid down in the REACH system are consistent with those of the occupational safety and health directives.

The REACH system is not only a way of improving workers’ health and safety, but also a real opportunity for the chemical industry to make headway on innovation. The REACH system will foster innovation in the industry by encouraging it to develop new chemicals that are less harmful to workers, consumers and the environment.

ETUC wishes to make a constructive contribution to the debate on the REACH proposal by recommending the following improvements to the draft reform:

A general principle of Duty of care defining the responsibility of the manufactures and importers should be reintroduced into the REACH system for all chemicals produced or imported. The chemical safety report must be required to ensure that substances subject to registration and preparations are managed safely during manufacture, import and uses down the supply chain.

For substances produced in the 1-10 ton range per year more basic information should be required such as acute toxicity and biodegradability tests to improve their classification and the risk assessment situation compared to current legislation.

The aim of the authorisation procedure should be to promote the effective substitution of the most hazardous chemicals as European legislation on carcinogens provides. The authorisation procedures should also be extended to other substances of very high concern that show serious or irreversible effects.

Both the costs and the benefits should be considered in all three dimensions- the social, the environment and the economic - in order to assess the effectiveness of the new system and the impact on employment and health. There is clearly a need to better understand the likely effects (positive and negative) REACH might have on employment in the different sectors concerned throughout its implementation period.

Apart from being of considerable importance to the chemical industry and its workers, the REACH proposal is in fact a major issue for European society as a whole, especially when seen as a step towards developing a Europe that seeks to create a labour market that excels both in quantitative and qualitative terms. By combining efforts aimed at developing the internal market and improving compliance with workers’ rights and protection, REACH is an opportunity to grab in order to develop a more socially responsible Europe.