Annex XV restriction report for cobalt carbonate; cobalt di(acetate); cobalt dichloride; cobalt dinitrate; cobalt sulphate

Comment on

WVMetalle would like to comment on the ECHA restriction proposal on the manufacture, placing on the market and use of the five cobalt salts with a special emphasis on the concept of a Reference Exposure Value (REV) and the missing in depth reflection of a much more tar-geted approach to guarantee adequate control by implementing a Binding Occupational Limit Value (BOELV) under the umbrella of the Carcinogens and Mutagens Directive (CMD).

WVMetalle supports the activities to update the directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work and play an active role in this context by Dr. Wieske being a member of the DG Employment Working Party Chemicals (WPC) advising the tripartite Advisory Committee on Health & Safety at Work (ACSH). It is worth to mention that the WPC early in 2019 strongly recommended DG EMPL to give a priority mandate to RAC to evaluate Cobalt and its inorganic compounds to-wards a BOELV amending the CMD as all members of the tripartite WPC are convinced that a BOELV would be the most targeted and effective risk management option for the protection of workers for all uses of all Cobalt compounds.

For further information please see the attached document.




Dr. Martin
Leiter Arbeits- & Gesundheitsschutz 30 726207 106