Industry Exposure Trends Voluntary Blood Lead Reduction Programmes The European Battery Industry Prague, 19 June 2013 Michel Baumgartner, EU Affairs Manager

European Battery Industry EUROBAT Battery Manufacturers provide over 25,000 direct jobs to Europe 10,000 staff directly involved in Lead-based battery manufacturing

Membership Battery Manufacturers

Contents 1° Why a Blood Lead Programme? a. Rationale b. DNEL / OELs c. Results of previous EUROBAT Blood Lead Programme 2° (New) Provisions of EUROBAT Blood Lead Programme a. Objectives b. Guidelines c. Specific Provisions - Examples d. Enforcement & Reporting

1.a. Why a Blood Lead Programme : The Rationale A duty for continuous improvement Technical progress in industry is faster than legislation Transparent dialogue with regulators – Evidence that industry can be a credible partner and deliver results on its own  EUROBAT Blood Lead Programme in place since Objective was to reduce blood lead levels for all employees to 50µg/dl blood and to 30 µg/dl for female employees in childbearing capacity.  Objectives revised in Target lowered to 40µg/dl for all employees (unchanged for female employees in chilbearing capacity) by 12/2007.

1.b OELs / DNEL “The Commission services are of the view that OELs and DNELs (for both the same duration and the same route of exposure) may co-exist, and in some circumstances may apply simultaneously to some work activities. In certain cases, where the guidance allows the registrant to use OEL instead of deriving DNEL, the problem of two different values would not arise. In other cases, it is the Commission's view that, in principle, the lowest level should be complied with by the employer. The binding OEL needs to be always complied with by the relevant employer. In cases when the DNEL is lower than the OEL, the compliance with DNEL is based on the premise that the registrant could not use OEL instead of deriving DNEL for the same exposure route and duration, as he has obtained new scientific information which indicated that the OEL does not provide the appropriate level of protection.” European Commission General Report on REACH, page 7 5 February 2013

1.c Results EUROBAT Blood Lead Programmes 2001 and 2006 Limited improvement since 2008, under national OELs but some still above DNEL (<40µg/dl for males and <10µg/dl for females).

1.d Results REACH Lead Consortium Survey – Battery Manufacturing Limited improvement since 2008, under national OELs but some still above DNEL (<40µg/dl for males and <10µg/dl for females).

2° (New) Provisions of EUROBAT Blood Lead Programme 2.a: Objective All employees below 30µg/dl blood at the end of Taking into account 10µg/dl limit for female employees in chilbearing capacity. 2.b: Guidelines  Definitions / specifications: monitoring frequency, removal & return levels…  Catalogue of best practices to achieve objectives: Technical Controls Personal and general hygiene Training and counselling

2.c. Specific Provisions - Examples Monitoring Frequency: All employees under medical surveillance to be tested at least every 6 months. Employees with PbB under 15µg/dl or working in e.g administration can be tested once per year. Removal limit: 30µg/dl as from Return level: 25µg/dl. Female employees in childbearing capacity with PbB over 10µg/dl to be employed in areas of non- significant exposure (where no Pb processing takes place). Reporting: once per year to EUROBAT for annual battery industry blood Lead data (improved questionnaire per plant) Plant design / Locker Rooms:

2.d. Enforcement and Reporting Adherence compulsory for EUROBAT members Different steps in enforcement – up to possible exclusion Support procedure for members not reaching objectives Inclusion of facilities in all EMEA but flexibility for MEA region Open to non-members Improved reporting format for verifying compliance with the programme

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