Toxicants, Health and Regulation since 1945 by Nathalie Jas Soraya Boudia

Author:Nathalie Jas, Soraya Boudia [Nathalie Jas, Soraya Boudia]
Language: eng
Format: epub
Tags: Nonfiction, Science & Nature, Science, Other Sciences, History
ISBN: 9781317319689
Publisher: Taylor and Francis
Published: 2015-10-06T04:00:00+00:00

How is the French Ministry of Labour going to position itself in relation to the agency’s reports? On those hazardous substances for which a threshold has been determined, it will probably be fairly difficult for the ministry’s labour administration to justify a different threshold. This could trim its room to manoeuvre down to a matter of timing, that is, the date of official application of the texts. In the case of non-threshold hazardous substances, the AFSSET’s opinions will provide another constraint, in addition to all the existing values at international level, and will limit the range of options available to the DGT officials.

This text [proposing an OEL] was then submitted again to the Conseil supérieur de la prévention des risques professionnels, with discussions where normally the debate is really focused on what had been said: ‘We don’t change the level of the exposure limits, we set only the application dates’. This explains that for certain values, you’ve got dates that have been set, like on benzene, there were dates that were applied. Same for refractory ceramic fibres.53

We would be wrong to consider these intervals granted to industry before the application of an OEL as insignificant. On the contrary, they reveal a key issue in the determination of OELs. In the case of RCFs, whereas fears as to their carcinogenic nature appeared during the 1990s, an exposure limit was not adopted until October 2007, with an exemption until 30 June 2009. Yet in a meeting of the CSPRP committee on chemical, biological and physical atmospheric hazards, mention was made of the publication of the decree for 2006 with an exemption until 31 December 2007, the date that the firms in the industry, consulted by the ministry, had reportedly considered to be realistic. On two occasions the representative of the confederation of French industry, the Mouvement des Entreprises de France (MEDEF), had intervened to challenge this decision, by proposing to wait for the results of the AFSSET’s research, and then by asking whether the government administration had carefully assessed the impact on industry.54

The implications of the timing of the entry into application of OELs are crucial when there are stringent constraints weighing on decisions. Because it is increasingly difficult to apply decisions that are not consistent with values decided at international level, and because it is highly likely that a decision close to those values will eventually be ratified, the only option for those actors who want to avoid a new regulation is to try to delay its entry into application. In other words, the timing of the entry into the force of an exposure limit is not just an appendage to this regulation; it is a constituent element. Months, even years, without regulations enable industries to anticipate expected decisions, either by preparing firms for their future application, or by delocalizing to other countries with less stringent regulations. Given the speed at which industrial production processes evolve, and the international competition between firms in these processes, winning time can considerably alter the way in which a new OEL is handled.

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