A debate has continued in the EU about the relevance of the ICNIRP’s proposed exposure limits and the scope of the Directive. To address this, an EMF good practice
guide was commissioned by the EC and is due for publication soon.
NEWSEMF Directive: Uncertainties Remain
Uncertainties Remain With The EMF Directive
The EMF Directive 2013/35/EU (aka the Physical Agents Directive EMF) covers electromagnetic fields with frequencies between 0 Hz and 300 gigahertz (GHz). It refers only to risks associated with effects recognised by the International Commission on Non-Ionizing Radiation Protection (ICNIRP), i.e., short-term effects in the human body caused by the circulation of induced currents and by energy absorption, as well as by contact currents. Since the proposal for a Directive covering all physical agents was tabled in 1992, an ongoing debate continued in the EU Council of Ministers about the relevance of the ICNIRP’s proposed exposure limits and the scope of the Directive.- What frequency range should be covered? - What ranges of equipment are covered or possibly excluded from the Directive? - Should certain workers or sectors be put outside the scope of the Directive? The trade unions were clear on all these questions: throughout the debate, they have resolutely insisted that all the workers concerned should be covered. It is important to note that when examining the proposal for a Directive, the Council did not set an Exposure Limit Value (maximum value based on computer modelling of internal dose quantities in the body such as electric fields and specific absorption rate (SAR)) for static fields, but only an Action Level (based on external electromagnetic field measurements).The Council originally rejected the call from the European Coordination Committee of the Radiological and Electromedical Industries and some Member States to exclude MRI equipment from the Directive, but eventually acquiesced in 2011 (the current EMF Directive contains derogation for the MRI community).Furthermore, the electrical equipment manufacturing industry wrote to Commission President in 2002 calling for the Commission to base itself on the ICNIRP recommendations rather than the ALARA (“As Low As Reasonably Achievable”) principle under which all exposures must be kept at the lowest level reasonably achievable in light of economic and social factors. Following the adoption of the Directive, the Commission took two initiatives: It mandated CENELEC - the European standardisation body tasked with working out technical standards in electromagnetic field related matters to draw up harmonised standards for assessing, measuring and calculating workers’ exposure to electromagnetic fields in the 0 Hz to 300 GHz range. This mandate was based not on the Directive that was meant to ensure the protection of workers, but on one governing the harmonisation of technical standards for goods (Directive 98/34/CE).So, not only is there no clear legal link between the mandate and the Directive, but also the Directive lays down no technical principles on which for the standards developers to base their work. For example, it does not explain how measurement uncertainties should be factored into the risk assessment procedure. Additionally, the mandate fails to clarify the respective roles of two possible approaches: one based on the worker exposure assessment to be done by the employer, the other on an assessment of emissions by equipment covered by “internal market” Directives, to be done by the manufacturer or his representative. The Commission’s other initiative was to have a good practice guide written by a consultant supported by a tripartite working group of the Advisory Committee on Safety and Health at Work, comprised of government, trade union and employer organisation representatives. The consultants were chosen as Public Health England and EMFcomp Ltd. A practical guide has been produced and will be published by the European Commission in the near future.Dr Richard FindlayEMF Specialist & Director of EMFcomp Limited
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