EUROPEAN COMMISSION 
Brussels, 14.6.2011 
SEC(2011) 750 final 
  
COMMISSION STAFF WORKING PAPER 
IMPACT ASSESSMENT 
Accompanying document to the 
Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Directive 2004/40/EC on minimum health and safety requirements regarding 
the exposure of workers to the risks arisin g from ph ysical a gents (electroma gnetic fields) 
(eighteenth individual Directive within the meaning of Article 16(1) of Directive 
89/391/EEC) 
{COM(2011) 348 final} 
{SEC(2011) 751 final}  
 
EN 2   EN COMMISSION STAFF WORKING PAPER 
IMPACT ASSESSMENT 
Accompanying document to the 
Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Directive 2004/40/EC on minimum heal th and safety requirements regarding the 
exposure of workers to the risks arising from  physical agents (el ectromagnetic fields) 
(eighteenth individual Directive within the meaning of Articl e 16(1) of Directive 89/391/EEC) 
Including changes after recomm endations of the IA Board 
18 February 2011 
Lead DG: EMPL 
Associated DGs: SG, LS, ENTR, INFSO, RTD, ENER, SANCO, MOVE, TRADE, MARKT, 
ENV 
 
EN 3   EN  
TABLE OF CONTENTS 
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES ...6 
1.1. Background and policy context ....................................................................................6 1.1.1. Policy context .......................................................................................................... .....6 
1.1.2. Scientific and technical context ....................................................................................6 1.1.3. Organisation and timing................................................................................................9  
1.2. Consultation and expertise..........................................................................................10 1.2.1. Social partners' consultation .......................................................................................10 1.2.2. External expertise ...................................................................................................... .13 
2. PROBLEM DEFINITION..........................................................................................15 2.1. What is the problem? ..................................................................................................15 2.2. Who is affected and how?...........................................................................................15 2.3. The underlying drivers of the problem .......................................................................19 2.4. State of implementation of  the legal framework ........................................................19 
2.5. How would the problem evolve , all things being equal?............................................20 
2.6. Right to act and subsidiarity .......................................................................................20 3. OBJECTIVES.............................................................................................................22 3.1. General, specific and operational ob jectives ..............................................................22 
3.2. Consistency of the objectives with othe r EU policies and horizontal objectives .......22 
4. POLICY OPTIONS ....................................................................................................23 4.1. Policy options analysed in detail ................................................................................23 4.1.1. Policy option A:  "Do nothing"...................................................................................23 
4.1.2. Policy option B:  "New Directive with revised exposure limits" ...............................23 
4.1.3. Policy option C1:  "New Directive with revised exposur e limits and partial exemptions" 24 
4.1.4. Policy option C2:  "New Directive with revised exposur e limits and complete exemptions 
for some activities" .....................................................................................................25 
4.1.5. Policy option D1: "Replacement of the Directive by a Recommendation"...............25 
4.1.6. Policy option D2: " Voluntary social partners' agreements"......................................25 
4.1.7. Policy option E:  "no EU legislation".........................................................................25 
4.2. Options discarded from further analysis.....................................................................26 
 
EN 4   EN 5. ANALYSIS OF IMPACTS ........................................................................................27 
5.1. Starting point for the analysis of impacts ...................................................................27 5.1.1. Social impacts.......................................................................................................... ...27 
5.1.2. Economic impacts.......................................................................................................2 8 
5.1.3. Compliance costs ........................................................................................................ 29 
5.1.4. Administrative burden and related costs.....................................................................32 5.2. Assessment of the impacts for each option.................................................................32 5.2.1. Impacts of Option A: "Do nothing"............................................................................32 5.2.2. Impact of policy option B: "New Direc tive with revised exposure limits" ................33 
5.2.3. Impact of policy option C1: "New Directive with revised exposure limits and partial 
exemptions" ................................................................................................................34 
5.2.4. Impact of policy option C2: "N ew Directive with revised ex posure limits and complete 
exemptions for some activities"..................................................................................35 
5.2.5. Impact of policy option D1: "Replacement  of the Directive by a Recommendation"36 
5.2.6. Impact of policy option D2: "Voluntar y social partners' agreements" .......................36 
5.2.7. Impact of policy option E:  "no EU legislation"..........................................................37 
5.2.8. Variability of costs across Member States and options ..............................................37 
6. COMPARING THE OPTIONS..................................................................................39 7. MONITORING AND EVALUATION ......................................................................42 
8. ANNEXES..................................................................................................................43 
Annex 1Second stage of consultation of the social partners on the protection of workers from the 
risks related to exposure to elec tromagnetic fields at work......................................................44 
Annex 2 Current legislative situat ion in the EU Member States as  regards exposure of workers to 
EMF ............................................................................................................................ ..............56 
Annex 3 Details on the new exposure limitation system proposed for option B and option C1 
(except for MRI) ............................................................................................................... ........64 
Annex 4 Case studies to determine compliance costs...............................................................72 
Annex 5 Compliance costs for each option ..............................................................................96 Annex 6 Details on costs related to Administrative Burden...................................................108 
 
EN 5   EN Annex 7 Questions (without additio nal comments and original la yout) of the questionnaire on 
health, socio-economic and environmental impact s in connection with possible amendments to 
Directive 2004/40/EC ........................................................................................................... ..112 
Annex 8 Estimated cost for cases of overexposure.................................................................115 Annex 9 Survey based assessment of the options...................................................................117 Annex 10 Glossary.............................................................................................................. ....121 
 
EN 6   EN 1. PROCEDURAL  ISSUES  AND  CONSULTATION  OF INTERESTED  PARTIES 
1.1. Background and policy context 
1.1.1.  Policy context  
This impact assessment addresses the question of protection of workers exposed to high levels of 
electromagnetic fields (EMF) during their work. This  concern is part of the general EU policy cast 
in the Treaty on the Func tioning of the European union of giving workers the appropriate health and 
safety protection against risks encountered during their professional activities. Consequently this document only deals with the (high) exposure of workers during their work and not with the (much 
lower) exposure encountered by th e general public using cellular phone, living close to high power 
lines or passing through meta l detectors at airports. 
Workers can be exposed to electromagnetic fields in many sectors of activity : industrial  processes 
such as electrolysis, welding, sealing, broadcasting, electricity  generation, etc. or medical 
procedures such as medical Ma gnetic Resonance Imaging (MRI).  The health consequences of 
overexposure can be of different ki nd depending upon the intensity a nd proximity of the sources on 
the one hand but also upon the characteristics of the electromagnetic radiation itself, e.g. its 
frequency or wavelength. The symptoms of acute  effects are well define d. In the high frequency 
range (i.e. broadcasting, radars),  severe burns may occur whilst in  the low frequency range (i.e. 
welding, electricity production and distribution), induced currents can cause effects on the function 
of the central or peripheral ne rvous system and exposed persons  can also experience vertigos, 
nausea, metallic taste feelings, magnetophosphenes (flashes in the eyes). In very rare cases, dramatic indirect safety effects have also to be deplored when strong magnets attract a 
ferromagnetic object and crash it on a person inadvertently staying be tween the magnet and the 
metallic object. 
The issue of protecting workers exposed to EMF wa s already dealt with at EU level in 2004 with 
the adoption of directive 2004/40/EC
1 of the EP and the Council. 
Very rapidly it appeared that the directive, an d in particular the adopted binding exposure limit 
values, would create major implementation probl ems and would even impede some essential 
medical procedures and related research in cutt ing edge medical applications such as MRI.  
The question became critical as the deadline for tran sposition of the directive by the Member States 
was getting closer. The Commission post poned the deadline for transposition2 and decided to 
undertake a full review  of the situation. 
1.1.2.  Scientific and technical context 
In order to clarify the matter, so me physics are required here: inte ractions with matter – from the 
nuclei of atoms to whole galaxies - are governed by different types of so-called fundamental forces 
where under gravity (attraction of masses) and electr omagnetism (for electrica lly charged particles). 
                                                 
1 Directive 2004/40/EC of the European Parliament and of the Council of 29 April 2004 on the minimum health 
and safety requirements regarding the exposure of workers to the risks aris ing from physical agents 
(electromagnetic fields) (18th individual Directive w ithin the meaning of Article 16(1) of Directive 
89/391/EEC). OJ L 184, 24.5.2004, p. 1.  
2 Deadline for transposition was 30/4/2008. This deadline was postponed by 4 years by Directive 2008/43/EC of 
23 April 2008 (OJ L 94, 24.5.2008, P. 8-12) 
 
EN 7   EN The interaction forces of electrically charged partic les with other charged particles in their vicinity 
is materialised by an attracting or repulsive for ce due to their presence (electric field) and an 
additional attractive or repulsive field when th ey are in movement (magnetic field). Each 
electromagnetic force is characterized by its inte nsity and its wavelength and related frequency. 
Both properties have a dir ect influence on the human body. 
In the scientific literature, th e non-ionising and ionizing radiation spectrum is divided as follows: 
(1) from 0 Hertz to 300 billion Hertz (GHz), the scie ntists talk about elec tromagnetic fields and 
radiation (EMF). This is curren tly covered by Directive 2004/40/EC; 
(2) from 300 GHz (1mm wavelength) to 300 Penta Hertz (1 nanometre wavelength), the 
scientists refer to the optical radiation domain: this includes the infrared radiation (heat), the 
visible radiation (light) and the Ultraviolet radiation. The optical domain is covered by 
Directive 2006/25/EC3. 
(3) From there onwards, we are entering the domain of the ionizing radia tion: the frequencies 
are becoming even higher and the characteri sation of each radiation is made by its 
wavelength only for ease of reference4. The radiation becomes sufficiently powerful that it 
can destructively disturb atomic bounds. Protec tion of workers and general public exposed 
to ionizing radiation fall under th e scope of the so-called Eura tom Treaty. Several directives 
have been adopted in this field in line with th e latest scientific evidence. The directives in 
force for the ionising radiation domain are Directive 96/29/Euratom5 (protection of general 
public and workers) and 97/43/Euratom6 (specific to medical exposures). 
                                                 
3 Directive 2006/25/EC of the European Parliament and of the Council of 5 April 2006 on the minimum health 
and safety requirements regarding the exposure of wo rkers to risks arising from physical agents (artificial 
optical radiation) (19th individual Directive within th e meaning of Article 16(1) of Directive 89/391/EEC). OJ 
L 114, 27.4.2006, p. 38.  
4 Frequency (f) and wavelength ( λ) are linked by equation λ.f = c where "c" is the speed of light in free space. 
5 Council Directive 96/29/Euratom of 13 May 1996 laying down basic safety standards for the protection of the 
health of workers and the general public against the dangers arising from ionizing radiation. OJ L 159, 
29.6.1996, p. 1–114.  
6 Council Directive 97/43/Euratom of 30 June 1997 on health protection of individuals against the dangers of 
ionizing radiation in relation to medical exposure, and repealing Directive 84/466/Euratom. OJ L 180, 
9.7.1997, p. 22–27.  
 
EN 8   EN These different types of radiati on are represented in the figure 1 below. For EMF, i.e. for the 
frequency ranges from 0 to 300 GHz, this corresponds on the picture to the areas in dark blue called 
“Low freq .” (Low frequencies) and “ Radio frequencies and higher ”. The picture also shows some of 
the activities/equipments that are causing exposu re to electromagnetic fields. A wide number of 
human activities such as transport, communicati ons, broadcasting, industrial processes, medical 
applications, etc. are using or are affected by EMF. 
Figure 1 
The various domains of el ectromagnetic interactions
  examples of applicationsDC (0 Hz)
  AC (50 Hz)
EAS-RFID <<<<<<<<Medical>>>>>>>>
Welding Heating
Diathermy Baggage
Induction Control 
MRI (RF fields) Lighting
MRI (0 Hz & gradients) Welding controls
UMTS
GSM Research
Radio Radio
Radars Chemistry
Specific areas Low freq. IR Visible UV X-Rays
Domain denomination
Legal coverage
Frequency range 0 - 100 kHz
Coresponding wavelength up to 3 km> 100 kHz - 300 GHzRadio frequencies and higher
Electromagnetic Radiation from 0 Hz to 300 GHz
Directive 2004/40/ECOptical radiation Ionizing radiation
Directive 2006/25/EC Directive 96/29/Euratom  examples of applications
NB: the location of the various applications in the frequency domains is indicative.1 mm - 10E-2 nm λ: 10E-2 nm - 10E-7 nm 3 km - 1 mmSecurity scanners
> 300 GHz - 30 EHz > 30 EHz - > 3 YHz<<<<<<<lasers>>>>>>
Gamma Rays
 
With 3 existing directives EU legislation covers th e whole range of sources of radiation. Protection 
of EU workers will be ensured from 0 Hz to the infinite once directive 2004/40/EC is implemented 
in all Member States. 
The directives have been established on the basis of internationally accepte d principles and values. 
For ionizing radiation, the internationally accep ted recommendations are established by ICRP, the 
International Commission for Radiation Protection7 created in 1928. ICRP de velops, maintains and 
elaborates the International Sy stem of Radiological Protection used worldwide and which has 
served as basis for directives 96/29/Euratom an d 97/43/Euratom referred to in point 3 above. For 
non ionizing radiation (see points 1.and2. above), and in  particular in the ar ea of concern of this 
report, the internationally accepte d recommendations are established by ICNIRP, the International 
Commission for Non Ionizing Radi ation Protection, a daughter orga nization of ICRP. The members 
of the ICNIRP main commission and of the speci alized working groups ar e selected for their 
notoriety in their domain. They are elected for a limited number of years. IC NIRP intends to work 
independently according to strict internal rules an d the validity of their recommendations is checked 
during a consultation process before publication. 8 
The situation in the EU is - not very different from the situation in other countries. This is 
confirmed for ionizing radiation  where sufficient evidence has demonstrated the need to adhere to 
binding limit values commonly accepted worldwide. This is also the case for optical radiation  
although third states often only refer to the in ternational standards which are underlying the 
principles and limits of our directive. 
                                                 
7 More details on www.icrp.org   
8 More details on www.icnirp.org  
 
EN 9   EN For EMF , the situation is less monolithic: outside the EU9, some well developed states (including 
Japan, New Zealand, South Africa, etc.) are maki ng reference to the ICNIRP recommended limit 
values, the so-called “ basic restrictions ” which have also been take n as reference when drafting 
Directive 2004/40/EC. Sometimes they do so onl y for a limited range of the EMF frequency 
domains, neglecting for instance frequencies belo w 3000 Hz. In Australia, whilst using the ICNIRP 
recommendations, some local peculiarities are bei ng developed. In those coun tries, the values of 
ICNIRP are not binding or only partially bind ing probably because of implementation problems 
with the basic restriction levels suggested by ICNIRP. In the USA, values recommended by IEEE10 
apply. They are higher than the ICNIRP values in  the low range of the spectrum – which actually 
avoids some compliance problems - but equivalent in the higher end (radio frequencies). For long 
term effects most countries do not have any restri ctions for workers’ expos ure because of the lack 
of clear evidence for the cu rrent levels of exposure11. 
1.1.3.  Organisation and timing  
In order to allow the Commission to explore new possi bilities in the light of new scientific evidence 
and forthcoming technologies, the EP and the Council adopted a directive12 amending directive 
2004/40/EC and which postponed the transposition deadline by 4 years from April 2008 to April 
2012. 
Since then, the Commission has multiplied contacts and consultations with stakeholders. The two 
phases of the formal consultation of  the Social Partners foreseen by Article 154 of the Treaty were 
also carried out (see re sults in 1.2.1 below).  
An Impact Assessment Steering Group (ISSG) was put in place. This ISSG hold three meetings: 
• the first meeting was held on 23 May 2009 with the purpose to inform th e colleagues of other 
DGs on the problems with current directive 2004/ 40/EC and the consequences in administrative 
and legislative terms; 
• the second meeting took place on 1st September 2009 with the purpose of keeping the colleagues 
up to date on the ongoing and future  initiatives and to invite them to cooperate actively during 
the coming Inter Service Consulta tions linked to the launching of the first and second stages of 
the consultations of the social partners accord ing to Articles 154 (2) and (3) of the TFEU;  
• the third meeting took place on 14 July 2010 to discuss a first draft IA Report. 
Upon completion of a consolidated  draft the document was submitted to the Impact Assessment 
Board which made a number of comments and r ecommendations. Taking these into account the 
following main changes were introduced in the document: 
a) a more comprehensive and c oncrete description of the new exposure limits system which is 
an integral part of Option B and C1 (section 4 and annex 3), 
                                                 
9 Source: World Health Organisation (WHO). 
10 IEEE: Institute of Electrical and Elect ronics Engineers; http://www.ieee.org/ 
11 SCENIHR opinions (2009) 
http://ec.europa.eu/health/archive/ph_risk/c ommittees/04_scenihr/docs/scenihr_o_024.pdf  and 
http://ec.europa.eu/health/archive/ph_risk/c ommittees/04_scenihr/docs/scenihr_o_007.pdf   
12 Directive 2008/46/EC of the Europ ean Parliament and of the Council of 23 April 2008 amending Directive 
2004/40/EC on minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) (18th indivi dual Directive within the meaning of Article 16(1) of 
Directive 89/391/EEC). OJ L 114, 26.4.2008, p. 88–89.  
 
EN 10   EN b) a revision of the section re lating to the analysis of imp acts for each option (section 5), 
c) a refocusing of the problem description and, consequently, an adjust ment of the objectives, 
d) a more transparent presentation of costs, with  examples of variability for typical activities. 
1.2. Consultation and expertise 
1.2.1.  Social partners'  consultation 
For legislative initiatives in the social policy field the Treaty foresees a two stage consultation of the 
Social Partners. The first one (Article 154 (2) of the TFEU) t ook place between 1 July and 10 
September 2009. 
The Commission received 16 replies to this consu ltation (12 from employers' organisations and 4 
from workers' organisations). Most of the cont ributions were from Eur opean Organisations (10 
employers; 3 workers); three replies were rece ived from national orga nisations (2 from UK 
employers' organisations and one from a German trade union).  
The different options where proposed in the form of 5 questions: 
1 "Do you consider the current Di rective 2004/40/EC sufficient for th e health and safety of workers 
exposed to electromagnetic fields during their work?" 
2 "Do you consider that a Comm unity initiative is the best wa y to ensure a high standard of 
protection of workers exposed to electromagnetic fields?" 
3 "Do you think that certain categories of worke rs should be excluded from the scope of any future 
Community initiative because of reported impl ementation problems (e.g. medical procedures 
involving MRI) with some pr ovisions (exposure limit valu es) of Directive 2004/40/EC?" 
4 "Would you find non-binding me asures such as the production of good practices guides, 
launching of regular information campaigns, se tting-up of appropriate training programs, and 
drawing-up of voluntary agreement between the social  partners of EU on sector level – useful, and 
for what purpose?" 
5 “Should a possible future EU in itiative cover the long term effe cts of workers' occupational 
exposure to electromagnetic fields?” 
The outcomes of the first consultati on can be summarized as follows:  
• In general, both trade unions a nd employers agreed that the current directive is not the ideal 
instrument and that there is a basic need for a new Community initiative to protect workers from 
electromagnetic fields. On the employer's side th ere were also some representatives (SMEs and 
national organisations) which indicated their pref erence for non-binding instruments instead of a 
directive.  
• The real problem with directive 2004/40/EC was the series of exposure limit values which was 
seen as too restrictive. To defi ne new exposure limit values seemed to be an acceptable approach 
 
EN 11   EN (except for the healthcare sector), provided th at they are "practic able", "inspectable"13, based on 
solid recent science and expressed in directly measurable units. If  the orientation was to go for a 
revised directive, some attention should be paid to limit the administrative burden. 
• It seemed commonly accepted that the limit values in the current directiv e might be set too low 
and based on too conservative assumptions; but wh ile the employers were in favour of relaxing 
the limits, the workers representa tives required to include the l ong term health effects in the 
future binding instrument.  
• Exempting some categories of workers from the scope of the directive was not welcomed by the 
employers of the industry (except MRI equipmen t manufacturers). Also, allowing derogations to 
exposure limits to specific sectors (healthcar e) posed some probl ems for the industry. 
• Developing non binding instruments was welcomed  by all contributors i ndependent of a new 
directive. 
A second stage of consultation of th e Social Partners according to Article 154 (3) of the TFEU took 
place between 20 May and 5 July 2010. Following the rules for second stage consultations, 9 
concrete areas for pote ntial changes were propo sed. These suggestions corresponded very much 
with the options analysed in this impact assessm ent with the exceptions that a "no change" option 
was not discussed as the social partners had already expressed th eir views on this in the first 
consultation. On the other hand, considering a "c omplete repeal of the directive" option was 
irrelevant in this speci fic context. 27 responses were received:  18 from employers' organizations (10 
EU+2 international+1FR+5 UK), 2 from workers' organizations (1 EU+1 DE), 3 from national 
scientific institutes, 1 from a patients association, 3 experts' personal contributions). All responses 
were very constructive. 
The results can be found in annex 1 and are summari zed as follows for each of the 9 areas proposed 
for change: 
Table 1 
1 Coverage of all sectors of activity 
 All stakeholders confirmed that no category of workers should be excluded from the 
benefits of a legal instrume nt provided that the instru ment gives the appropriate 
flexibility to continue  with activities.  
2 Due flexibility in a controlled working environment 
 To facilitate the continuation and developm ent of activities the Commission proposes to 
introduce more proportionality. Employers are very much in favour of such approach. 
Workers' organizations feel that too much  flexibility may significantly reduce the 
protection of the exposed worker s if not strictly controlled. 
                                                 
13 Practicable" and "inspectable": these words have been used by some stakeholders during the various contacts 
with them. "Practicable" needs to be understood in th e sense that the requirements imposed by the directive 
must be simple to implement, with measurements methods adapted to the level of risk and techniques that can 
be easily explained to the workers. "Inspectable" means that the company safety managers or governmental labour inspectors must be able to verify most situations on the spot by making measurements or by using 
verification methods that give i mmediate and comparable results. 
 
EN 12   EN 3 Precise definitions 
 All social partners agreed that directive 2004/40/EC needed  clarification of definitions. 
One of them is the definition and the understanding of the meaning of “adverse” or “acute” effects. 
4 Exposure limit values 
 a) In line with updated scie ntific recommendations, some re laxation of the “old” limits 
may be envisaged without reducing the protectio n of the workers in real terms. While the 
industry is strongly in favour of such relaxa tion, workers express some concerns, because 
they are afraid that new limits may be chos en to enable continuation of business without 
guarantee for the health of the workers.  
b) Social partners can agree with the “zoning” approach14 proposed by the Commission 
to facilitate the carrying out of the compul sory risk assessment (imposed by framework 
directive 89/391/EEC). 
5 Measurements and calculations 
 The Commission’s proposal  is to introduce more guida nce to facilitate the risk 
assessment process, in particular for SMEs. All social partners agree that this would 
facilitate measurements and calculations. From  employers’ side there is a request to limit 
measurements and calculation to those cases where it is re ally necessary.  
6 Guidance for risk assessments 
 With the same objective, the Commission’s proposal is to introduce more guidance for 
the compulsory risk assessment. The idea is to give orientations to the employers so that 
the means to comply with the requirements are better adapted to  the situation. The 
“zoning” system referred to for ar ea 4 is related to this objective. At the end of the day, 
better guidance should limit the co sts and burden and also ensure  clarification in case of 
a court case. All social partners welcome more and better guidance to perform risk 
assessments in general and for exposure to EMF in particular. 
7 Medical surveillance 
 This issue was raised by the medical profession during the Umea conference. In the low 
frequency range, from 0 to 100 kHz it is very difficult to detect acute effects after the 
exposure itself. This is different for higher frequencies where the acute effects can be 
severe burns. Currently, the requirements of  directive 2004/40/EC say that for any 
overexposure a medical examination must be offered to the worker concerned. Considering that there is sometimes a lack of  symptoms or of detectable adverse effects 
after overexposure, the medical examination may not be justified in all cases. Workers 
and employers representatives are not on the same line on th is issue but the idea of 
                                                 
14 The "zoning" concept is already used by some Member  States (e.g. The Netherlands) and has also been 
developed in the recent CENELEC standard EN50499. The id ea is to create certain zone s (layers) of risk (low, 
medium and high) corresponding to intensities of exposure to EMF and to associate to each zone some specific provisions for the carrying out of the risk assessmen t and for the implementation of preventive protective 
measures. More details about this in section 4 "Policy options", in particular, option B. 
 
EN 13   EN revisiting the conditions for a medical examination is not controversial. 
8 The specific case of medi cal applications using nuclear magnetic resonance 
technology 
 5-8 % of the medical MRI pr ocedures would not be possibl e, even with exposure limits 
aligned with the most recent proposals from  leading agencies. The Commission proposal 
is to give an exemption from binding exposure li mits to the MRI sector  in order to enable 
the use and development of this technique  for the benefit of the patients while 
compensating this by more stringent qualitativ e rules to ensure ad equate protection of 
medical personnel. This causes some proble ms for the employers of the industry who 
consider this as discrimination. The workers or ganisations can agree to this approach but 
under the condition that this is limited in tim e. Innovative design of equipment should in 
future limit the risks of overexposure. 
9 Non binding measures 
 The social partners agreed that accompa nying non binding measures such as raising 
awareness campaigns, multiplying training co urses and producing good practice guides 
at national or sectoral levels would be helpful and necessary. 
- – Final question: willingness of the Social Pa rtners to enter into negotiations on the 
basis of the proposals above under the term s of Article 154(4) and Article 155 of 
the Treaty on the Functi oning of the EU (TFEU). 
 None of the Social Partners reques ted to go for this sectoral approach. 
1.2.2.  External expertise 
Next to the formal consultation of Social Pa rtners the Commission ga thered complementary 
information and expertise by: 
• numerous contacts with representatives  from the industry and their European 
(BUSINESSEUROPE, ORGALIME , CEEMET) and national fe derations EEF (UK), AGORIA 
(BE), with representatives of the SMEs (U EAPME, NORMAPME), with representatives of 
standardisation bodies (CENELEC). This  enumeration is not exhaustive; 
• contacts with the scientific community, in part icular ICNIRP whose recommendations are used 
worldwide and served as a basis for the expos ure limit values in di rective 2004/40/EC; IEEE 
whose recommendations are used in the USA and by NATO15; DG SANCO's committee 
SCENIHR16; 
• for the specific case of MR I, regular contacts in dedi cated working groups, one with 
representatives of ESR17 (MRI practitioners) re presenting also ESMRMB18 (MRI medical 
                                                 
15 NATO: North Atlantic Treaty Organization; http://www.nato.int/ 
16 SCENIHR: Scientific Committee on Emergi ng and Newly Identified health Risks; 
http://ec.europa.eu/health/scientific_committees/emerging/index_en.htm 
17 ESR: European Society of Radiology; http://www.myesr.org 
18 ESMRMB: European Society for Magnetic Resonance and Medical Biology; http://www.esmrmb.org/ 
 
EN 14   EN research) and Alliance for MRI (M RI patients association) and a second one with representatives 
of COCIR19 (MRI equipment manufacturers);  
• regular contacts with the social partners and go vernment representatives, formalised through a 
working party mandated by the Advisory Committ ee for Safety and Health at Work. This 
working party, initially created to supervise the preparation of  a non binding good practice guide 
to directive 2004/40/EC saw its ma ndate expanded to assist the Commission in finding a solution 
for the medical activities and later for the whole range of affected sectors of activity. During the 
meetings of this working party scientists and experts were invited to express their views and to explain the latest technical and scientific deve lopments and new recommendations, in particular 
from ICNIRP and IEEE. WHO and NATO expe rts were also invi ted and consulted. 
In 2007, DG EMPL selected a contractor to ca rry out a comprehensive investigation into 
occupational exposure of workers pe rforming medical MRI. This study
20 which was done in 
cooperation of ESR (selection of and facilitation of access to repr esentative MRI facilities and 
selection of worst case s cenario procedures) took place from July 2007 to April 2008  and enabled to 
identify and quantify the problem areas. 
Between January and September 2009 a study21 (in the following called "preparatory study" or 
"FICETTI study") was carri ed out by a consortium22 to provide the European Commission with 
detailed analysis of the potentia l health, social and economic imp acts of a number of  policy options. 
The study also took into account the input from vari ous stakeholders such as representatives of 
different sectors, universities, research centres, trade unions and military as well as from the discussions of the employers', workers' and gover nmental representatives in  the EMF Working Part 
of the Advisory Committee on Health and Safety at Work. 
In October 2009, the Swedish Presiden cy organised a 3 day conference
23 on occupational exposure 
to EMF. During this conference a new approach for limiting exposure of workers was presented by 
the German Ministry for Employment and Labour (BMAS). 
                                                 
19 COCIR: European Coordination Committee of the Radiological, Electromedical and Healthcare IT Industry; 
http://www.cocir.org/ 
20 Project VT/2007/017: "An Investigation into Occupational Exposure to Electromagnetic Fields for Personnel 
Working With and Around Medical Magnetic Resonance Imaging Equipment"; final report 4 April 2008. 
21 Contract VC/2008/0692 for the "Analysis of health, socio-economic and environmental impacts in connection 
with possible amendments to Directive 2004/40/EC of the European Parliament and of the Council of 29 April 
2004 on the minimum health and safety requirements regarding the exposure of workers to risks arising from physical agents (electromagnetic fiel ds)". Final report: September 2009. 
22 "FICETTI Consortium": Main Contractor: Finnish ins titute of Occupational Hea lth; Subcontractors: The 
Slovenian Institute of Non-Ionizing radiation (INIS) , Central Institute for Labour Protection – National 
Research Institute (CIOP-PIB, Poland), EMFields Ltd (UK), TRaC-KTL (UK), The National Institute of 
Occupational Safety and Prevention (ISPESL, Italy), The University of Modena and Reggio Emilia (Italy), The 
University of Umea (Sweden). 
23 Occupational Exposure to Electromagnetic Fields: Paving the way for a future EU initiative; 6-8 October 2009, 
Umeå University, Sweden. 
 
EN 15   EN 2. PROBLEM  DEFINITION 
2.1. What is the problem? 
As laid out in the introduction, the issue under discussion is the pr otection of workers exposed to 
strong electromagnetic fields. Am ongst devices which are produci ng non-ionizing radiation and are 
most commonly used in the professional side, one can mention, inter alia , induction heating 
installations, electroplaters, welding devices, cr ack detection equipment, plasma etchers, radio 
frequency sputterers and also the equipment used for medical  MRI, diathermia and hyperthermia. 
Amongst particularly affected sect ors are the electrolysis, the i nduction heating, the welding, the 
broadcasting, the electricity production and distribut ion and the telecoms sectors. Such radiation 
appears whenever there are heavy electric currents and/or very st rong magnets at or close to the 
workplace. 
Uncertainty still exists in the international comm unity for some parts of the spectrum regarding 
occupational EMF exposure. Additional research may in the medium term give most precise 
answers. No biological mechanisms could be validated until now. Howe ver, adverse effects on 
health have been demonstrated when exposure exceeds certain levels. Depending where one puts 
the reference levels, adverse eff ects may be disturbing, ir ritating, painful or really harmful for the 
worker. 
2.2. Who is affected and how? 
Many categories of workers may be subject to ex posure to electromagnetic fields, for instance: 
• Those maintaining antennae, for example in broadcasting, navigation and telecommunications; 
• Those working with electricity  generation and distribution; 
• Those working with dielectric and induction heating systems; 
• Those working with resistance welders; 
• Drivers of electric locomotives; 
• Those involved in electro-chemical processing; 
• Those using diathermy, hypothermia and magnetic re sonance equipment, for example in health 
services; 
• Those using tape erasing equipment to erase da ta stored on tapes and other magnetic media; 
• Those using crack detection equipment for the no n-destructive testing of metallic components; 
• Those using plasma etchers in semi-conductor business; 
• Those using RF sputterers24 to apply coatings to components used in a variety of industries; 
                                                 
24 Sputter deposition is a physical vapor deposition  (PVD) method of depositing  thin films  by sputtering , that is 
ejecting, material from a "target" which th en deposits on a substrate (Wikipedia). 
 
EN 16   EN • Those working with Electronic Article Surveillan ce (EAS) equipment used to prevent theft from 
shops, libraries etc. 
The list above is not exhaustive but gives an idea  of the variety of sectors of activities concerned by 
the issue25. It is difficult to estimate the number of work ers in each of the listed categories. Overall, 
according to data from the stakeholders, more  than 1,500,000 workers (self-employed excluded) in 
more than 200,000 workplaces are c oncerned in the EU (table 2). 
Table 2 
Sector Workers Workplaces/assessments 
Electric energy 200,000 3,000 
Health care 211,000 13,000 
Metal industry 1,019,000 162,140 
Telecoms & broadcast 39,500 11,000 
Rail 120,000 500 
Other 50,000 25,000 
Total 1,639,500 214,640 
Source: stakeholders' information  
Workers of both the medical sector  and the industry can be exposed  at much higher levels than 
those defined for the general public. The general public has normally no access to areas where high exposure levels occur. Even the levels produced  by antennas (for GSMs and others) and for which 
the media and some citizens' associations express c oncerns are far below the levels this report is 
referring to.  
Workers can be affected in different ways and the consequences for health can take different forms 
depending namely on the charac teristics of the exposure: 
• Static fields, low frequency fiel ds or high frequency fields, pul sed or sinusoidal (frequency and 
type of wave factors) 
• High or low intensities (power factor) 
• Long or short exposure times (time factor). This f actor will however not be considered here as 
science currently confirms the situation prevalen t in 2004, i.e. that ther e is no evidence yet of 
adverse effects from long term exposure of EMF under the levels considered for short term effects 
When dealing with static fields, the main health  effects derive from the movements of the body in 
the field. The movements of the body in the (strong) static field induce an e ffect materialised by 
                                                
 
25 A more detailed list has been established by the Na tional Radiological Protection Board (UK): NRPB R265 
and NRPB-W24.  
 
EN 17   EN electrical currents in  the body. At certain levels these effect s may become harmful. At very high 
levels there will be an impact on the blood circulat ion. This effect does not seem to be significant 
with the currently used static fields. Other effe cts have been reported when in presence of heavy 
static fields: vertigos, me tallic taste, headaches. 
Another (safety) effect linked to the presence of strong static magnetic fields  is the attraction power 
of any ferromagnetic object inadverten tly introduced in the vicinity of the source. We are referring 
here to static magnetic fields such as those used for MRI which are around 100,000 times stronger 
than the natural earth magnetic field26. As a matter of example, if a person enters the room where 
MRI equipment is operational with a scissor in th e hand, the latter will be attracted away and 
immediately fly like a bullet into the core of the ma gnet. If a patient is present in the machine or a 
worker close to the machine at that moment, the cons equences will be a severe injury or even fatal. 
In the low frequency range above 0 Hz up to 100 kH z the main effect is pe ripheral and/or central 
nerve stimulation (PNS, CNS). Muscles are subject  to unexpected stimulation which can give 
annoying feelings at low levels and unintended movements of the limbs at higher levels. The 
produced effect can be painful. The effect disa ppears when the cause of the effect (the low 
frequency field) disappears. Some undesirable effects on the eyes are also reported in the very low 
frequency range around 20 Hz. They are ca lled magnetophosphenes and can obviously reduce 
worker’s attention. 
In the frequencies higher than 100 kHz, the main eff ect of radiation is burns,  internal or external. 
This effect is much more tangible than the prev ious ones and even short periods of exposure can 
lead to injuries which will require a long recovery period. 
All these effects are reported by scientists and cannot be rejected as they are proven by the 
numerous in vitro, in vivo  and epidemiological studies. A numb er of the most recent ones been 
taken into account by ICNIRP, IEEE and BMAs to  establish their mot recent recommendations. As 
a matter of example, in its late st publication "Guidelines for limiting exposures to time-varying 
electric and magnetic fields (1 Hz to 100kHz)" put on line in November 2010, ICNIRP indicates 53 
references wherefrom some 20 are new studies on effects of EMF on living cells or animals carried 
out over the last 10 years. The other references re late to former guidance but also to publications 
relating to modelling and literature review on the s ubject. In the BMAs approach referred to in 
section 1.2.2., and explained in the "Forschungs bericht 400: Elektromagnetische Felder am 
Arbeitsplatz" – Abschlussbericht (March 2010), 110 references are used and the number of new 
studies is similar. Unfortunately, re ports on real cases are very scarce. 
Table 3 below shows the possible health effects and the associated frequency range(s) that can be 
encountered in a variety of  professional activities. 
Table 3 
Frequency range Related activities Potential Health problems 
0 Hz Magnetic resonance technology 
Lifting cranes Electrochemical processes Safety problems: 
uncontrolled 
attraction of ferromagnetic 
metals 
Health problems:  vertigos, 
                                                 
26 Order of magnitude of the terrestrial magnetic  field strength: 50 microTesla (0.5 Gauss). 
 
EN 18   EN metallic taste feeling, 
headaches 
50 Hz High power lines; Production 
and distribution of electricity; 
Welding 
100 Hz -10,000 kHz Magnetic resonance technology 
(gradient fields) Headaches, 
magnetophosphenes, 
Unwanted effects on the 
peripheral nervous system 
9 kHz - Electric welding 
30 kHz -  Industria l induction heating 
300 kHz -  AM-radio 
Industrial induction heating Effects on the nervous system 
3 MHz -  AM-radio 
Plastic welding Dielectric pressing Induction hardening FM-radio Wood processing 
300 MHz -  TV 
Diathermia GSM Dielectric vulcanizing Burns 
Thermal stress 
3 GHz -  Anti-Theft protection systems 
Radars Satellites  
(communication with) 
30 GHz - Transmission of digital and 
analogue video signals Burns and 
thermal stress 
Source: AGORIA (BE) good practice guide  
 
EN 19   EN 2.3. The underlying drivers of the problem 
As indicated in section 2.2., recent research27 indicates that Directive 20 04/40/EC is stricter than 
necessary in the sense th at there is no room for flexibility or proportionality. Si nce the publ ication 
of the recommendations of the International Commission for Non-Ioni zing Radiation (ICNIRP) 
published in 1998, on which the European directive is based, new scientific data have become 
available on the effects of low- frequency fields. These data suggest that some of the current 
exposure limits could be too low, too conservative and too difficult to use in practice. Raising the 
exposure limit values or – at least – expressing them in more practical terms and enabling higher 
working boundaries (the former " action value " of Directive 2004/40/CE) thanks to recent scientific 
evidence would allow many applications to be us ed without exaggerated compliance costs whilst 
still guaranteeing appropriate protection of worker s exposed to EMF. This may still leave a limited 
number of significant applications  with major compliance problems but – at least – smarter case 
handling would be achieved when confronted to EMF emitting source.  
As pointed out in section 1.1.1 "Pol icy Context", 5-8% of  the medical MRI procedures will not be 
possible without rising the exposure limits above  the levels suggested by the new BMAS or 
ICNIRP values. These procedures would become ille gal. This is undesirable, because the use of 
MRI has many advantages for patien ts: the technique enables diagnosti c of diseases as never before, 
it enables interventional surgery without the use of x-rays and almost every week new applications 
are developed in the benefit of the patients. 
On the other hand, safety and health of me dical personal also need to be ensured. 
2.4. State of implementation of the legal framework 
According to the latest reported information, none of the EU Member States has already completed 
the transposition of directive 2004/40/EC, curren tly due for 30 April 2012. Several countries (FI, 
AT, UK, CZ …) informally indicated their intenti on to introduce some flexibility to ensure proper 
use of MRI techniques although this flexibility is not permitted by directive 2004/40/EC. Other 
countries are currently rely ing on existing non binding ru les (including the ICNIRP 
recommendations) as practical reference. All Memb er States are waiting for clarification and for a 
new initiative from the Commission. 
Information of the existing legal framework in the Member States can be found in Annex 2. The 
overall situation can be captured as follows: 
Table 4 
Countries with specific legislation 
covering exposure of workers to EMF in 
place before Directive 2004/40/EC AT, BG, CZ, DE, EE, FI, LV, LT, LU, NL, PL, 
PT, SE, SK, SP 
Countries without spec ific legislation in 
place BE, CY, DK, FR, GR, HU,  IR, IT, MT, RO, SI, 
UK 
                                                 
27 Forschungsbericht 400: Elektromagnetische Felder am Arbeitsplatz – Abschlussbericht, ISSN 0174-4992, 
März 2010 (BMAS report). ICNIRP Guidelines: Guidelin es for limiting exposure to time-varying electric and 
magnetic fields (1 Hz to 100 kHz): to be published in December 2010. 
 
EN 20   EN Countries having issu ed (additional) non 
binding recommendations AT, IT, PL, UK 
Countries for which the Commission 
already received a notification of new 
national legislation transposing Directive 2004/40/EC AT, EE, LV, LT, IT, CZ, SK (all have delayed 
the entry into force until 30/04/2012) 
The outcome of the review carried ou t by the FICETTI contractor shows: 
• that all Member States rely on ICNIRP guidelines. 
• that Member States do not make differences be tween sectors but betwee n frequency ranges. The 
radiofrequency range is often c onsidered in detail and the lo w frequency range is rather 
neglected. No exemptions are foreseen by sector or size of enterprises with the notable exception 
of MRI. 
• that Member States have paid more attention on the protection of the general public by issuing 
recommendations or binding legislation based on Council Recommendation 1999/519/EEC 
which also relies on the ICNIRP 1998 guidelines. 
These statements are also confirmed by the data sent by Member States a nd third states to the 
database of WHO28. Whilst most states are considering exposure to EMF as a hazard, there is a 
large variety of legal solutions, the large majo rity of them relying on the ICNIRP guidance. 
2.5. How would the problem evolve, all things being equal? 
If everything remains as it is, all 27 Member St ates will have to tran spose the provisions of 
Directive 2004/40/EC by 30 April 2012. This would annihilate the efforts made by the Commission 
to find solutions for the announced implementa tion problems and would not be the outcome 
expected by the governments, the social  partners and most stakeholders.  
2.6. Right to act and subsidiarity  
Social policy belongs to the shared competences between the EU and the Member States for the 
aspects specified in the Treaty. In Article 153 1.a of the TFEU29, improvement of the working 
environment to protect workers' health and safety  is specifically mentioned. 
Subsequent Article 153.2 says: "To this end, the Council and the European Parliament:  
…(b) may adopt, in the fields referred to in paragraph 1(a) to (i), by means of directives, minimum 
requirements for gradual implementation, having regard to the conditions and technical rules 
obtaining in each of the Member  States. Such directives sha ll avoid imposing administrative, 
financial and legal constraints in a way which would hold back the creation and development of 
small and medium-sized undertakings." 
                                                
 
28 http://www.who.int/docstore/peh-emf/EM FStandards/who-0102/Europe/europe5.htm  
29 see the glossary 
 
EN 21   EN In this framework, a number of directives (19)  have been adopted since 1989. The first one was 
Council Directive 89/291/EEC of  12 June 1989 on the introduction of measures to encourage 
improvements in the safety and health of workers at work30. This directive is usually referred to as 
the "Framework directive". 
Amongst the subsequent individual directives deali ng with specific risks, one may find directives on 
the protection of workers exposed to: noise, vibra tion, chemical agents, biol ogical agents, asbestos, 
manual handling of loads, etc. 
On adoption of Directive 2004/40/EC, the Commissi on, Parliament and Council were of the opinion 
that Community action was the best way to protect  workers from risks arising from occupational 
exposure to electromagnetic fields. At the time, the co-legislators justified the action at EU level 
(recital N° 4 of directiv e 2004/40/EC) by the intention "to ensure the health and safety of each 
worker on an individual basis, but also to create a minimum basis of protection for all Community 
workers, in order to avoid possibl e distortions of competition".  
Currently the Commission does not see any new ev idence to go into the opposite of the direction 
chosen by the Parliament and Council in 2004. The need to protect workers remains essential. 
Considering the situation pointed out under point 2.5 and the need for a review recognized by all 
parties, it appears that the Commission must act, using it right of initiative.  
                                                 
30 OJ L 183, 29.6.1989, p. 1. 
 
EN 22   EN 3. OBJECTIVES 
3.1. General, specific and operational objectives 
The general objective remains the protection of workers during their professional activities by 
maintaining and further improving existing levels of protection of both the heal th and the safety of 
the workers. As indicated above there is a comp rehensive corpus of binding instruments on the EU 
level put in place to meet this objective. 
Exposure of workers to electromagnetic fields is  a complex risk. Consequently, as a specific 
objective, there is a need to define  more specific measures to ensu re adequate protection of workers 
exposed and to present the most appropriate so lution to protect them without unduly impeding on 
the use and development of industr ial activities and medical techni ques (as the curr ent instrument 
directive 2004/40/EC does) and without imposi ng disproportionate burde n on enterprises, in 
particular SMEs.  
Consequently because of these somewhat conflicti ng aims the operational objective is to ensure the 
effectiveness of the protection of workers exposed to EMF. The outcome should be clear, coherent 
and easy to understand to help increa se consistency of implementation.  
3.2. Consistency of the objectives with oth er EU policies and horizontal objectives 
These objectives are consistent with the current Europe 2020 Strategy and the Community Strategy 
for Safety and Health at Work 2007 – 2012 fo r improving quality and productivity at work 
(COM(2007)62).  
Taking account of the above, and the latest scientific  evidence on the subj ect reassessing the 
situation is fully justified. DG SANCO is review ing the situation on a regular basis – lastly in 
January 2009 - through SCENIHR (see 1.2.2) and the fact that the inte rnational leading authorities 
in the matter are reviewing their recommendati ons is consistent w ith this approach. 
 
EN 23   EN 4. POLICY  OPTIONS 
4.1. Policy options analysed in detail 
The outcomes of the first consultation document fo r the Social Partners and the supporting work 
carried out by an external contractor have sugges ted to operate around an initial set of 7 broad 
options. This spectrum of options was also supported by st akeholders. Consequently all of them are 
considered in this impact assessment. Neverthe less, during the stakeholder consultation and the 
further work undertaken, the options have been  refined and some elements have changed.  
4.1.1.  Policy option A:  "Do nothing" 
In practical terms this means th at Directive 2004/40/EC has to be  transposed by 30 April 2012 into 
legislation in all the Member States. The existi ng controversial exposure limits become binding 
limits. To achieve compliance employers will be re quired to take actions based on workplace risk 
assessments and in the context of rule s considered to be too conservative. 
Directive 2004/40/EC foresees th at an employer must carry out a (compulsory) risk assessment 
whenever workers are likely to work with or  in the neighbourhood of EMF producing sources. The 
employer is supposed to compare the real level of  exposure at a workplace with a reference level31, 
which is directly measurable with an appropriate device: for the electric field the strength is measured in volt per meter and, for the magnetic fiel d, the field strength is measured in ampere per 
meter (field strength) or in Tesla (magnetic flux density). If the actual exposure is lower than the 
action value* , everything is fine: the protective meas ures in place are appropriate and the 
assessment process can stop here. If  the measured value exceeds the action value , a more complex 
evaluation has to take place to check whether the e ffect induced in the body of the worker does not 
exceed a certain level, the exposure limit value  itself. The main problem with the exposure limit 
values (ELVs) is that they are not expressed in directly measurable entities and therefore require 
some modelling and calculations. If after this comparison exercise , the exposure of the worker is 
likely to exceed the ELV, revised protecti on measures have to be put in place. 
* see the glossary 4.1.2.  Policy option B:  "New Directive with revised exposure limits" 
In this option, the existing exposure limit values  of the 2004/40/EC Dir ective are replaced with 
new, more practicable, exposure limit values base d on latest international recommendations. This 
revision of limit values has become possible as res earch has shown that the safety factors between 
observable physiological reac tions and recommended exposure limits can be reduced. 
The recommendations on which the new requirements could be based are a) the new guidelines for 
static magnetic fields and for the extremel y low frequency (ELF) range published by ICNIRP 
during the last quarter of 2010
32, b) the "IEEE Standard for Safety Levels with Respect to Human 
Exposure to Radio Frequency Electromagneti c Fields, 3 kHz to 300 GHz (C95.1)" and "IEEE 
Standard for Safety Levels with Respect to Human Exposure to Electromagnetic Fields, 0–3 kHz 
(C95.6)" and c) the new BMAS pr oposal referred to in 1.2.2. (las t paragraph) and 2.3. For the 
concrete development of the new system a combin ation of ICNIRP and BMAs will be used. The 
                                                 
31 In Directive 2004/40/EC, this reference level is called the " action value ". 
32 The new recommendations were officially released on www.icnirp.org  on 25 November 2010. 
 
EN 24   EN new reference levels would thereby be set at a higher level than the one defined in Directive 
2004/40/EC (action value)  for the frequency range 0 – 100 kHz. This will facilitate compliance for 
most activities producing or using EMF in that range. The limits will however not be high enough to accommodate all concerns in industry nor those for MRI.  
The choice was made not to take the IEEE system which is only used in the USA and partially in 
Canada. The new system follows mainly the ne w ICNIRP recommendations  recognized worldwide 
and used as the reference of their protection system by more than 40 well developed states 
worldwide. However it is supplemented by elements  of the system proposed by BMAS in order to 
introduce the necessary flex ibility and proportionality in the low frequency range where most of the 
implementation problems are. 
The most significant characteristic s of this new system can be found in annex 3. They concern the 
low frequency range. For the high frequency range th e reference levels and exposure limits remain 
unchanged. 
4.1.3.  Policy option C1:  "New Directive with revised exposure limits and partial exemptions" 
This option is to a large extent identical to option B: New exposure limit values based on the latest 
international recommendations are introduced. However, conditional exemptions will be foreseen for medical MRI; these activitie s will be exempted from the re quirement to comply with the 
exposure limit values of the new Directive, but w ill still remain subject to the other provisions, 
including EMF risk management requirements. Empl oyers shall put in place protective measures to 
prevent direct or indirect health  risks from EMF for workers. Indi rect risks, being e.g. risks from 
ferromagnetic projectiles or interferen ce with implanted medical devices.  
This option implies a differential treatment of the MRI workers. This has advantages in terms of 
facilitating technological progre ss (e.g. medical devices), economi c development and of enabling 
high quality health care (MRI); bu t it has also the disa dvantage to restrict the evaluation of the 
situation to qualitative aspects only.  
When drafting this document, the only sector that  was deemed to be given an exemption was the 
medical MRI sector (operation, cleaning, maintena nce and R&D activities). All other activities, 
including medical diathermia, were expected to fall in zone 2 of the new system (see annex 3). In 
case other (e.g. newly emerging) activ ities would conflict with the re vised limit values it would be 
possible for the Member States to allow for ex emptions from the limit values under strictly 
controlled conditions. Such exemptions woul d need to be notified to the Commission. 
No limitation in time of the exemption is foreseen. For such limitation, provisions to reduce the 
strength of the static magnetic field or to overcome the high intensity of the gradient and stray fields 
need to be introduced. This can only be done by am ending the "medical device s" directive. This is 
not the scope of the Directive. 
In order to ensure the effectiv eness of the protection of worker s in the MRI dom ain, reinforced 
qualitative measures will be addressed in an a nnex of the new directive. The proposed measures 
which were already incl uded in the second stage consultation document adopted by the Commission 
in July 2010 are: 
– reinforced information measures; 
– reinforced training of workers; 
 
EN 25   EN – documented and practicable working procedur es favouring exposure limitation whenever 
possible; 
– strict administrative procedur es for access to MR rooms; 
– consultation of personnel on improvements; 
– monitoring33. 
It is intended to involve employers, manufacturers,  practitioners and health care personnel under the 
auspices of the Advisory Committee for Safety and Health at Work. Th e organisation of these 
consultations would be streamlined in the direct ive itself (scope, implementation, monitoring and 
deadlines). 
4.1.4.  Policy option C2:  "New Directive with revised expos ure limits and complete exemptions 
for some activities" 
New exposure limit values based on the latest inte rnational recommendations are introduced (same 
as option B). Some sectors/activities (medical MRI) will be exempted entirely from all the 
requirements of the EMF Directive on the basis that  their operation is not, and will probably never 
be, compatible with its requirements. 
This option excludes some categories of workers (those working in the medical MRI area) 
completely from the scope and benefits of a direc tive and conflicts with an essential requirement of 
the Framework Directive which is laid down in Article 2.1: "This Directive shall apply to all 
sectors of activity,…." . So far exceptions to that principle ar e very rare and sp ecific (e. g. firemen 
during the combating of a fire). 
4.1.5.  Policy option D1: "Replacement of the Directive by a Recommendation" 
The current EMF Directive is replaced  by non-binding occupational EMF exposure 
recommendations, based on the latest intern ational recommendations. The form of these 
recommendations would be similar to the 1999 Council Recommendation on EMF exposures of the 
general public. 
4.1.6.  Policy option D2: " Voluntary social partners' agreements" 
The EMF Directive is replaced by a set of voluntar y agreements at Europe an or sectoral level 
between social partners according to the provisi ons of Article 154.4 of the TFEU. This possibility 
has not been invoked by any of the social partners  participating in the c onsultations referred to 
under section 1.2.1. 
4.1.7.  Policy option E:  "no EU legislation" 
Directive 2004/40/EC is withdraw n (repealed) while dir ective 89/391/EEC (Framework Directive) 
and existing national regulatory provisions on the subject remain in force. Absence of national 
regulations in some Member States will allow unregulated occupational EMF exposures which may 
cause increased risk, lowering of equality, etc. For this option, it  will be assumed that countries 
                                                 
33 A good example for such an approach can be found in  a document already developed in The Netherlands. Its 
preparation required close cooperatio n between hospitals (employers), practitioners and the medical personnel 
(workers), under supervision of the competent ministries. The booklet "Using MRI safely: Practical Rules for 
Employees" can be downloaded from: http://docs.minszw.nl/pdf/92/2008/92_2008_1_22102.pdf   
 
EN 26   EN which have already (partially) implemented th e EMF Directive would not repeal their EMF 
legislation. 
4.2. Options discarded from further analysis 
Alternative options which have not been analysed in detail are: turning to a more sectoral approach, 
restricting legislation to the pr ovision of safe equipment or an exclusive focus on 'soft' policy 
instruments such as information campaigns and guidance documents. 
A sectoral approach was deemed insufficient as the current legislative corpus at EU level, based on 
Framework directive 89/391/EEC, a ddresses risks by covering all cate gories of workers. There are 
very few exceptions such as mining and drilling activ ities and for which the specific risks have been 
addressed in a specific manner in se parate directives. A cross-sectoral  approach is justified because 
the risks for worker's health are linked to the level of exposure per se – irrespective of where it happens.  
The provision of safe equipment as required in the low Voltage, the Medical Devices, the 
Machinery and the Product directives is an important instrument to ensure safety at the working place. Nevertheless, whilst recognizi ng that these directives are esse ntial tools to protect workers, 
their provisions are not sufficiently comprehensive to ensure th e protection at the workplace. This 
has been often demonstrated in the past: for inst ance Directive 94/9/EC of the European Parliament 
and the Council of 23 March 1994 on the approxima tion of the laws of the Member States 
concerning equipment and protective systems intended for use in potentially explosive 
atmospheres
34 was complemented by Directive 1999/92/EC of the European Parliament and of the 
Council of 16 December 1999 on minimum requirement s for improving the safety and health 
protection of workers potentially at risk from explosive atmospheres (15t h individual Directive 
within the meaning of Article  16(1) of Directive 89/391/EEC)35. In the case of personal protective 
equipment, Council Directive 89/ 656/EEC of 30 November 1989 on th e minimum health and safety 
requirements for the use by workers of personal protective equipment at the workplace (third 
individual directive within the meaning of Article 16 (1) of Directive 89/391/EEC)36 was 
immediately followed by Council Directive 89/686/EEC of 21 December 1989 on the 
approximation of the laws of the Member Stat es relating to personal protective equipment37. 
Information campaigns and guidance tools are seen as important instruments and further efforts of 
this type will happen whatever option will be chos en. In so far it was not looked at separately. 
                                                 
34 OJ L 100 of 19.04.1994, p.1 
35 OJ L 23, 28.1.2000, p. 57–64 
36 OJ L 393, 30.12.1989, p. 18–28 
37 OJ L 399, 30.12.1989, p. 18–38 
 
EN 27   EN 5. ANALYSIS  OF IMPACTS   
5.1. Starting point for the analysis of impacts 
The following sections attempt to identify and an alyse the potential soci al and economic impacts 
and their importance for each option. As regards soci al impacts a special atte ntion is given to the 
impacts on workers' health as they are directly linked to the objectives of the initiative. The 
economic impacts considered in th e analysis are mainly complianc e costs and potential impacts on 
competitiveness.  
Wherever possible an attempt has been made to quantify the impacts of th e various po licy options. 
Where data could not be obtained or is uncertain, the analysis of the policy options is more 
qualitative in line with the principle of a proportionate level of analysis. 
Discussions with experts and stak eholders indicated that environm ental impacts are not likely. Per 
definition exposure to electromagnetic fields is li mited to their immediate surrounding and there is 
no evidence of any long or medium term impacts on the built environment or on the fauna or flora 
eventually surrounding such workplaces. In so far there is no starting point to analyse 
environmental impacts of the options. 
A similar limitation applies for exposure of general public to electromagnetic fields. This matter is 
dealt with by Council Recommendation 99/519/EEC. Members of the public are not supposed to 
have access to areas where worker s are exposed during their work. 
5.1.1.  Social impacts 
Potential negative health effects of  exposure to EMF range from dir ect effects (headache, vertigos, 
unwanted nerve stimulation, burns) to indirect eff ects (loss of attention or injury due to the 
attraction of a metallic object by a strong magnet). Three specific aspects were addr essed for each 
option: 
• Overexposures 
• Worker concern 
• Wider social consequences (availability of MRI, employment, public concern about EMF) 
Overexposures 
Documented overexposures, exceeding the physiologi cal level are rare, but not unknown. The best-
recorded cases have occurred in broadcasting where workers working close to active emitters have 
been subject to severe burns. 
It is estimated (see annex 8) that the immedi ate cost per case of overexposure is around 8 000 
Euros. 
Moreover, while in general the exposure limit values proposed will avoid overexposure, specific 
groups of workers might have a higher sensitivity . Two particularly sensitive groups can be 
identified: pregnant women and wo rkers wearing a medical implant:  
a) Pregnant workers must be considered as “s ensitive workers” for two reasons: one is that 
pregnant women, especially in the final trimes ter, may have an impaired thermoregulatory 
 
EN 28   EN ability, making them potentially more sensit ive to the thermal e ffects of exposure to 
radiofrequencies. The other issu e is the status of the foetus ; there is a question as to 
whether it should be exposed at the occu pational or at genera l-public EMF limits. 
Obviously this has an implication for the e xposure of the mother - and by extension her 
ability to undertake certain work. 
b) There is a definite difference between the options as regards access to the workplace of 
workers with medical implants ( AIMDs )38. The default situation is that in the absence of 
specific information to the contrary, workers with medical implants are not excluded from 
workplaces with high levels of EMF. The cu rrent EMF Directive has a clear requirement 
that specific assessments are done to determ ine the extent to which the access of such 
people should be cont rolled. CENELEC has produced asse ssment standards specifically to 
facilitate this. 
Worker concern 
While keeping in mind that employers should undert ake specific EMF risk a ssessments even in the 
absence of explicit legisl ation employees might not feel as comfortable with these assessments 
carried out for a risk they may even not be aware of if there are no officially approved limit values. 
Which means that workers could re frain from going in certain areas or could refuse to carry out 
certain tasks because they believe  it is not good for their health. 
Avoiding this is one of the main drivers for employers to consider and quantify any EMF risk in the 
workplace in a transparent way.  
Wider social consequences for workers and general public  a) Lack of access of patients to  leading-edge healthcare: This is  a particular issue for medical 
MRI.  
Some options may render some procedures illegal, thereby inducing the effect of shifting from MRI 
procedures to x-Ray based procedures and subseque nt additional health care costs to be borne by 
the collectivity. 
b) Employment: A very strict legal situation might restrict economic activities and by that 
have negative impacts on employment. 
c) Public concern about EMF: In many c ountries, compliance with ICNIRP guidelines 
(possibly with an additional safety factor) is used to ensure that there is no risk to the 
public from the established effect s of EM fields. If there were to be an explicit rejection of 
the validity of the ICNIRP guidelines then it is feared that public confidence in EMF safety 
could be adversely affected. This possible effect has not been observed yet and has not 
been considered essential when comp aring the options in section 5.2 and 6.1. 
5.1.2.  Economic impacts 
Following main effects have been c onsidered for comparing the options: 
• effect on competitiveness of European businesses  
                                                
 
38 all words and acronyms followed by * can be found in the glossary 
 
EN 29   EN • effects on competitiveness of European businesses compared to those outside the EU 
• protection of the employers 
• costs on enterprises (developed in 5.1.3) 
Effects on competitiveness of European businesses  
Options promoting a common EU approach w ill ensure a higher homogeneity of the legal 
instruments relating to workers exposed to EMF. Th is should be beneficial  for the businesses as 
compliance costs would be equal in relative terms. An additional advantage of identical rules in different member states is that mobili ty of skilled workers becomes easier.  
However, too restrictive requirements, in particul ar too conservative expos ure limit values could 
hinder economic activity and in so far reduce competitiveness and growth of Europe.  
Effects on competitiveness of European busin esses compared to those outside the EU 
There is likely to be an impact on some exporti ng sectors, especially fo r options with strict 
requirements MRI equipment producers might lose the competitive edge in MRI equipment production. North America and Japan would probabl y become the most advanced market which 
may promote the development of this equipment abroad instead of Europe.  
In other areas such as induction heating and el ectrolysis, a very strict legal framework may 
encourage companies to build future installations outside Europe but the effect could remain limited 
as the necessity of revised working procedures and design changes for limiting the exposure would 
compare very well towards the creation of complete new installations. 
It is however impossible to asse ss quantitatively which impact it could have for the employment 
numbers as the effects would be subtle and in ma ny cases EMF legislation is only one factor among 
several which are relevant for lo cation decisions. In terms of quali ty of employment, no indication 
of deterioration of employment has been reported yet because of EMF legislation. 
Legal protection of employers 
Many employers favour clear limits that they can show compliance with, ra ther than a general 
safety requirement or a sector-s pecific voluntary agreement as it w ould be the case in options D1, 
D2 and E. Clear limits provided by an extern al (and perceived as independent) authority are 
considered as a convincing way to fulfil employers' responsibilit ies in a transparent manner. 
Examples of court cases exist wher e employers had to bear judicial  costs which exceeded by far the 
costs of an effective risk assessment showing comp liance with the legislative provisions. As these 
events are not so frequent this criterion was not considered essential when comparing the options in 
point 5.2. 
5.1.3.  Compliance costs 
Costs of compliance as calculated below are costs of actions to be under taken by the employer to 
meet the requirements. This is valid for all options . They can be summarized as follows and are in 
line with the general provisions  of the Framework Directive 
Table 5 
 
EN 30   EN Employer's obligations Action 
1. Awareness raising Familiarisation with existing legislation, 
recommendations or sectoral agreement related to occupational exposure to EMF 
2. Determination of exposure and 
assessment of risks  Familiarisation with EMF measurement issues 
Purchase of equipment to measure EMF or hiring external experts to measure EMF 
3. Provisions aimed at avoiding or 
reducing risks  Introduction of protective measures to eliminate 
or reduce workers' EMF exposure (e.g. shielding, warning signs) or changes in work practice 
4. Worker information and training Providing tr aining to concerned workers on safe 
work procedures 
5. Consultation and participation of 
workers  Consultation and participation of workers 
within OSH management process 
The compliance costs have been grouped into 3 subgroups:  
• "generic costs" (common to all sectors or activities) 
• "sectoral costs" (specific implementing cost for each sector or, rather, each activity) 
• cost related to training requirements. 
The cost-estimations are based on visits and case studies conducted in the establishments (mainly 
SMEs) in sectors concerned, with main types of activities involving exposure to EMF: electricity 
generation and transmission, electri c welding, induction heating, surg ical diathermy, RF sealers, 
broadcasting and MRI.  
The advantage of getting cost figures from SME managers is that they are probably based on 
personal "in field" experience. Therefore it can be assumed that the absolute figures for individual 
unit costs are close to reality. The other compone nts of the equation, i.e. the number of workers 
concerned and the number of workplaces to be asse ssed were directly derived from stakeholders' 
assumptions. There are probably underestimated. However, as the number of workers and 
workplaces remain constant across the options, the ove rall figures can be used to ensure a realistic 
ranking of the overall costs for the different options. 
The compliance costs mainly consist of man-hour cost s of the staff or external experts involved in 
the analysis of risk (EMF measurement) and of introducing protective measures (e.g. shielding, 
changes in work procedure). Whilst man-hour costs are variable between Member States, costs for 
material or equipment and "preventive hardware" in  general are assumed to be similar in all EU 
Member States. 
Compliance costs thus st rongly depend on the labour cost in ea ch Member State. According to 
EUROSTAT Labour Survey 2008, average gross hourly  labour costs vary from  2.43 (Bulgaria) to 
37.38 (Belgium) Euros per hour. The average hourly labour cost for across s ectors and professions 
 
EN 31   EN was calculated by EUROSTAT at 16.13 €. In the FIC ETTI report the average la bour cost used in 
the calculations was 18.75 € per hour. Stakeholde rs considered this a reasonable estimate.  
Compliance costs are for most parts one-off cost s, unless the workplace undergoes substantial 
technical or working procedures changes. Still some costs may c ontain a part of recurrence if 
deemed necessary by the Member State or the em ployer himself. For instance, Risk Assessments 
may be made recurrent in some Member States and training may foresee refreshing sessions after a 
number of years of practice. As such requireme nts are different for each MS no attempt was made 
to try to calculate which percentage of cost this would represent. However it was estimated that this 
recurrence effects would not represent more than  a few percents. The co st derived from the 
interviews during the case studies in particular countries were ther efore maintained as a basis for 
the consolidated overall figures. Ot her inputs to the analysis incl ude the numbers of workers and 
assessments that are needed in each sector. Mo re detailed calculations and information on the 
underlying assumptions can be found in annexes 4 and 5. 
Data on costs of compliance with the current directive 2004/40/EC were received from the UK39 
and the Netherlands40. Nevertheless, these data are difficult to compare as different methodologies 
have been applied. They are based on calculations  starting from the existing situation in UK and 
NL. In the UK the accent was put on the risk assessment costs and not on the preventive measures as they were assumed to be in place. In the Netherlands, the appr oach included estimated figures for 
preventive/protective "hardware". Both data enable d to reinforce confidence  in the model and of 
this impact assessment. 
Impacts on SMEs 
The opinions of SMEs and microe nterprises on the EMF Directive and its implications were 
especially solicited in the impact assessment process. Most consulted employers agreed with the principles of the EMF Directive and were willing to perform a simple risk assessment if they knew how to do. SME employers fear th at the costs for risk assessmen ts and measurement surveys as 
requested by Directive 2004/40/EC might be too hi gh. In so far they are opposed to the current 
directive and they welcome a relaxation of limit values accompanied by specific guidance to 
facilitate the risk assessment procedur e and to organize information and training. 
Overall there is a severe information deficit for SMEs, and there is a wish for simplified 
information at the EU level. Sector-specific simp le and short guidance documents (checklist type) 
will thereby be needed for whichever option w ill be chosen. Equipment labelling and better 
manufacturer information, which might facilitate to  identify those situati ons in which no detailed 
assessment will be required, would also be helpful. 
The impact of the relatively hi gh compliance costs for SMEs is well known to the Commission. The 
problem is not specific to the risk of workers to be overexposed to EMF but  is of general nature. 
The compulsory risk assessment imposed by the framework directive 89/391/ EEC for all identified 
hazards (e.g. falling from height, presence of dange rous chemical substances, potentially explosive 
atmospheres, exposure to physical agents such as  EMF, asbestos, etc.) ge nerates compliance costs 
that are relatively higher for SMEs . Moreover, the fact that results  of the risk assessment and the 
prevention measures put in place have to be documented de facto generates an  additional cost. All 
                                                
 
39 Draft UK Cost-benefit analysis: proposal for a physical agents directive on electroma gnetic fields, July 2010, 
HSE UK. 
40 Electromagnetic fields in the working environment, June 2006, Ministry of Social Affairs and Employment, 
the Netherlands. 
 
EN 32   EN these costs may be seen as negative for the SMEs  at first glance but shoul d, at the end, guarantee 
better working conditions and less workers' absenteeism.  
The high level group " High Level Group of Independent Stake holders on Administrative Burdens"  (Stoiber 
group)41 has identified the current obligation for SM Es to document the out comes of their risk 
assessment as one of the legal provisions which may create unnecessary burden on the SMEs. 
Subsequently, the Commission has decided to review the situat ion which concerns all risks 
addressed by EU-OSH legislation. A study will be launched in 2011. Moreover, the European 
Occupational Health and Safety Agen cy in Bilbao is currently deve loping, in close cooperation with 
the Commission and stake holders an on-line tool42 which should facilitate the work (and reduce the 
cost) to the employers, in particular in SMEs. 
5.1.4.  Administrative burden and related costs 
The additional administrative co sts related to the i ssue of exposure of workers to EMF are 
considered as low. They consist of recording43 - and possible notification - of the results of the risks 
assessments for the "EMF risk". The administra tive costs have been estimated with the EU 
"Standard Cost Model" and the "Administrative Burden Calculator". 
5.2. Assessment of the impacts for each option 
5.2.1.  Impacts of Option A: "Do nothing" 
Option A will be the legal framework as from 1/5/ 2012, if no other EU legisl ative act is adopted by 
then. 
As far as health impacts are concerned, worker s exposed to EMF will be very well protected. 
Special groups (pregnant women and workers w ith AIMDs) will also benefit from appropriate 
protection although this option (the Directive) addresses it in very general terms. 
As Directive 2004/40/EC foresees that efficient wo rkers' information and consultation takes place, 
workers' concerns should  also be very limited. 
Nevertheless in terms of wider social consequenc es, there are also negative impacts expected. A UK 
MRI expert recently confirmed44 that at least 3.5% of current MR I procedures would be impossible 
under this option. More importan tly, there might be a slowdow n or even termination of 
development of interventional MRI in Europe. The study commanded by DG EMPL (see 1.2.2 "External expertise" above) confirmed the above c onclusions with 6 to 8 % of the current 8 to 10 
million MRI procedures per year in the EU beco ming impossible. It also predicted an adverse 
impact on the ability of maintenance teams to adequately maintain MRI equipment. 
Moreover, the medical sector (MRI practitioners) and the manufacturers of MRI equipment argue 
that more stringent EMF exposure re strictions could lead to an incr ease of other health risks. Option 
A might induce a transfer from MRI procedures to computerised tomography (CT) X-ray scans. 
The UK's Health Protection Agency estimated the co sts of such a potential shift from MRI to CT. 
                                                
 
41 http://ec.europa.eu/enterprise/policies/better-
regulation/files/hlg_opinion_working_environment_09052009_en.pdf 
42 OIRA: O nline I nteractive R isk A ssessment :http://www.oira.osha.europa.eu/front-page-en 
43 Framework directive 89/391/EEC requires th at the risk assessments be documented. 
44 Presentation "MRI and the Physical Agents Directive"  at the ESOF Conference in Turin on 5/7/2010 by Dr 
Stephen Keevil, King's College London.  
 
EN 33   EN Their calculations indicate that the additiona l collective ionising radiation dose for workers  in 
England and Wales might be 3-5 man-Sievert (man-Sv)  per year. This could be  scaled by a factor of 
around 10 for the whole EU. A financial cost of 50k Euros per man-Sv is often used by the experts 
in ionising radiation optimisati on, giving a total annual  cost of the increas ed collective ionising 
radiation for workers in the EU  of approx. 2.5M Euros per year. 
The "Alliance for MRI" has provided a similar calculation for increased patient exposure  to ionising 
radiation, and the corresponding figure is approxim ately additional 175 M Euros to be borne by the 
EU public community (taxpayers). That means a tr ansfer of MRI procedures to X-Ray procedures 
will have considerable costs. 
Option A impacts also negatively on the economy  by requiring many "long" risk assessments and 
subsequent extensive protective measures which w ould only be necessary fo r a limited number of 
activities (e.g. inducti on heating, electrochemical processes) with other options. This increases the 
overall implementation costs. If option A leads to a situation wher e compliance measures would be 
much stricter than in competing countries, delo calisation of workplaces mi ght be a consequence. 
The one-off costs (see 5.1.3.) under option A have been estimated as follows45: 
Generic costs 111.7 
Sectoral/activity specific costs 548.0 
Training 0.500 
Administrative costs 0.124 
Total (M€) 660.3 
As regards the costs of the possible application of Directive 2004/40/EC (option A), estimates of 
costs at national level were esta blished by Great Britain and the Ne therlands at the time of the 
adoption of the directive. Accord ing to the British estimates whic h have been updated in 2010, first 
year costs are in the range of € 57.9 to €196.5 million. For the original significantly lower figures of 
2003 (€6.0 to €14.3 million), HSE UK states that due to the unavailability of some data, these costs 
did not present a complete picture of implementati on and policy costs, and could be considered the 
minimum costs if the Directive were to be implemented to full (100%) compliance46. The Dutch 
estimates of the costs for the companies were ranging between €10 and €12 million per year during 
the first 2 years and subsequently €6 to €8 million per year47. In both UK and NL, the reason for 
having significant costs after the fi rst year is because national law imposes regular reviews of the 
working conditions and consequent ly of the risk assessments. 
5.2.2.  Impact of policy option B: "New Dir ective with revised exposure limits" 
This option is equivalent to opti on A in terms of the protection of workers. Exposure limits are for 
all workers in line with up-to-date scientific recommendations. 
                                                 
45 All costs have been established by DG EMPL on the basis of FICETTI data and additional information 
received from stakeholders. 
46 Draft UK Cost-benefit analysis: proposal for a physical agents directive on electroma gnetic fields, July 2010, 
HSE UK. 
47 Electromagnetic fields in the working environment, June 2006, Ministry of Social Affairs and Employment, 
the Netherlands 
 
EN 34   EN Moreover this option is also beneficial for the pa rticularly sensitive groups. In option B, workers 
who have declared themselves to be part of one of these groups s hould remain in the areas of rooms 
(or workplaces) where exposure levels do not exceed the levels for general public unless a specific 
evaluation is made on a case by case basis48. 
Option B would improve the effectiveness of the protection of workers in many companies, in 
particular SMEs, as it introduces changes towards more proportionality and flexibility. Experience 
shows that by facilitating implementati on the protection leve ls actually raise. 
Wider social consequences which are expected for option A in the form of MRI procedures which 
cannot take place will be  reduced, but still not co mpletely avoided. A compar ison of the results of 
the Commission study on MRI (see 1.2.2) with th e BMAS values and the recently published 
ICNIRP recommendations shows that overexposure st ill can occur. It was however not possible for 
DG EMPL to get an estimate of the reduction in the percentage of them. 
The economic consequences of option B are less ne gative than of option A. For many applications 
(see lists in annex 3) transition to the new reference levels ( actions values ) will mean that they are 
in an area where it would suffice to conduct very simplified risk assessments. In other areas, well 
guided risk assessments and according preventive measures should do, and the number of areas 
where more cumbersome risk assessments would be  required would be reduced to a minimum (see 
in annex 3," activities likely to be above upper level of zone 2").  For these activities option B will 
still have a negative impact on competitiveness and/or their further development and growth.  
Thanks to the combined effect of less conservativ e reference levels (action values) and of more 
proportionality the complianc e costs are lower than fo r Option A, and amount to: 
Generic costs 111.7 
Sectoral/activity specific costs 414.6 
Training 0.500 
Administrative costs 0.124 
Total (M€) 526.9 
5.2.3.  Impact of policy option C1: "New Directive with revised exposure limits and partial 
exemptions" 
The impacts of Option C1 are identical to those of Option B except for the MRI sector for which 
they are more favourable. Medical MRI would not be subject to binding exposure limits. 
Consequently Option C1 would remove obstacles for the use and development of exempted 
technologies and access of patients to leading-edge healthcare w ould be ensured. Having in mind 
the measures foreseen to compensate the absence of binding exposure limits, the level of protection 
of MRI workers will be maintained at an appropriate level49. The concerns of workers should 
therefore be very limited. 
                                                 
48 CENELEC guidance in preparation. 
49 MRI workers indicated during the consultations of the so cial partners that they are willing to work under the 
conditions foreseen under C1. 
 
EN 35   EN As Option C1 is equal to Option B for the industrial sectors, the competitiveness of industry would 
equally be improved under this option in comparison to option A. 
Costs have been estimated to be:  
Generic costs 111.7 
Sectoral/activity specific costs 385.1 
Training 0.500 
Reinforced qualitative measures for MRI 14.25 
Administrative costs 0.124 
Total (M€) 511.7 
5.2.4.  Impact of policy option C2: "New Directive with revised exposure limits and complete 
exemptions for some activities" 
Having in mind the existing public concern about e xposure to EMF, it is considered that this 
approach would undermine the credibility of th e protection system and send a couterproductive 
message to the international community. This opini on is shared by most stakeholders represented by 
the Social Partners' organisations. This option would be negatively perceived by the MRI workers 
and may at the end have a negative impact on the level of  their protection. 
For all sectors (except MRI) this option would have  the same advantages for the employers as the 
options B and C1, i.e. a certain harmonisation and a more proportionate risk assessment process. 
Effects on employment and competitiveness would ther efore be equivalent to the impacts of Option 
B. 
In option C2 workers involved in the MRI activitie s would be excluded from the scope of directive. 
Unless decided differently by the Member States, this option woul d – de facto – not provide any 
protection for the workers exposed to EMF in MRI activities. This is reflected in the drop for the 
compliance costs50. Administrative costs are considered the same as for Options A, B and C, but 
they should realistically be slig htly lower. Considering the sma ll amounts involved this has only a 
marginal importance: 
Generic costs 111.7 
Sectoral/activity specific costs 385.1 
Training 0.500 
Administrative costs 0.124 
Total (M€) 497.4 
                                                 
50 This is with the assumption that only medical MRI is removed from the scope. 
 
EN 36   EN 5.2.5.  Impact of policy option D1: "Replacement of the Directive by a Recommendation" 
This option has the advantage of giving more flexibility to the Member States. As far as social 
impacts are concerned this option would reduce the effectiveness of the attempt to reach 
harmonisation and in some cases decrease the level of  protection of workers. It may also increase 
workers' concern. 
As regards economic impacts a recommendati on would create or maintain competitiveness 
differentials. For MRI implementation this woul d not create difficultie s but the objective of 
guaranteeing a high level of protect ion across all the EU installations  may not be attained because 
of the lack of generalised reinforced qualitati ve measures. Finally, depending on the situation in 
each Member State, the protection of the employer in  case of a court case would be less favourable.  
Costs have been estimated to be in the order of: 
Generic costs 39.4 
Sectoral/activity specific costs 397.1 
Training 0.500 
Administrative costs 0.124 
Total (M€) 437.1 
The figure reflects the effect of the patchwork situation which ma y occur. The reduction of the 
generic costs reflects the fact that risk aw areness may be lower in some Member States. 
5.2.6.  Impact of policy option D2: "Voluntary social partners' agreements" 
During the second stage of the c onsultation of the social part ners neither trade unions nor 
employers' organisations gave an indication of pref erring such a solution. Both groups see this as an 
issue to be regulated on the European level. Howe ver as a matter of consistency and completeness it 
was decided to examine this option as well.  
The same kind of considerations as in option D1 can be used to express the positive and negative 
impacts of this sectoral approach. Within a Memb er State the level of pr otection of workers would 
not be equivalent in different s ectors and the verification of the e ffectiveness thereof would be more 
difficult for independent expert s and labour inspectorates. 
This would also create confus ion for workers' and provoke public  concern. Moreov er it would be 
more difficult for employers to demonstrate that th ey fulfilled their respons ibilities as regards the 
protection of workers in case of judicial proceedings. 
Costs have been estimated in the order of:  
Generic costs 22.5 
Sectoral/activity specific costs 397.1 
Training 0.500 
Administrative costs 0.124 
 
EN 37   EN Total (M€) 420.2 
This estimate is less reliable th an those for options A, B and C b ecause of the uncertainties on the 
generic costs. It should reflect th e differential approaches for carry ing out a risk assessment in the 
different sectors. 
5.2.7.  Impact of policy option E: "no EU legislation" 
In the first instance, as regards the social impa cts, abstaining from any European level action on 
EMF would reduce significantly the attention paid to the risks of EMF a nd would have negative 
impacts on workers' health and working conditions.  Moreover it may raise pub lic concern as the EU 
would provide guidance for exposure of the public but not anymore for work ers exposed to higher 
risks. Consequently the protection of workers e xposed to EMF would not be guaranteed. Also, the 
EU by repealing an existing directive may send a very negative signal to the international 
community. 
From the strictly legal point of view, even if th e EMF risks were not explicitly addressed by any EU 
Directive, employers should take them into account  in their risk assessments in light of the 
Framework Directive 89/391/EEC. 
As far as competitiveness is concerned, no significant effects are expected. However, the lack of 
guidance and rules for the risk assessment is exp ected to have counterpr oductive effects for the 
carrying out of the various steps of  the risk assessment. In absence of any specific EU legislation 
the employers would need to invest more time a nd effort to identify ri sks and decide on the 
appropriate protective actions. This would have an upward influence on the compliance costs in 
comparison to Options like C1 and C2 where rules are better defined: 
Generic costs 76.3 
Sectoral/activity specific costs 397.1 
Training 0.500 
Administrative costs 0.124 
Total (M€) 474.0 
5.2.8.  Variability of costs across Member States and options 
The relevance of comparing comp liance costs for each option, by si ze of enterprise , by sector and 
by Member State was analysed. Defining the activities  with exposure to EMF which are specific for 
an industrial sector are often not  straightforward. For instance, you may find similar activities (e. g. 
welding, RF sealing, article identification, wi reless communication) ac ross numerous industrial 
domains. On the other hand you may also have se veral and different "EMF producing" workplaces 
in the same factory.  
Apart from the difficulty of defining generic EMF exposure by industrial sector , it is not possible to 
link the absolute cost to the size of the enterprise , because of the variety of existing situations: for 
instance one could find 5 welding devices used in a small company (10 workers) manufacturing 
metallic trailers on demand; one could find 5 similar devices used for machine maintenance purposes in a larger company (e.g. 500 workers) producing shoes. The overall compliance costs will be the same in both cases. Fortunately, in su ch cases, the costs for preventive and protection 
 
EN 38   EN measures will benefit from some costs savings because the risk assessment and design of protection 
measures will be similar for the 5 workplaces. 
For these reasons, establishing a link between sectors and company to  assess the variab ility of costs 
at company level will end up with  a wide bunch of disper sed points on a graph a nd is not deemed to 
be a relevant indicator or a trend. It is however recognized that costs will affect SMEs to a larger 
extent in relative terms. 
As can be seen, from the case studies (annex 4) th e largest part of the compliance costs is due to 
labour costs and therefore directly  proportional to the level of the salaries in the Member States. 
The cases where the part of “hardware” for protectiv e measures is significan t are rather limited (e.g. 
Induction heating). The calculation of  costs for a specific activity in  a Member State can be derived 
from the assumptions used in the case studies, by taking the same fixed amount for the part related 
to the “hardware” and using labour costs calculated proportionally fo r the Member State concerned.  
 
EN 39   EN 6. COMPARING THE OPTIONS  
Whatever the option, benefits canno t be described without difficulty. Benefits on health can only be 
stated by the fact that below the cu rrent or future limits, no adverse effect occurs. This should be in 
favour of options A to C2. 
The comparison of the impacts of each option car ried out under point 5.2 can  be summarized as 
follows.  
Table 6 
 Protection 
against 
overexposure Workers concern 
taken into 
account Wider social 
impacts Economic 
impacts Compliance +
administrative 
costs 
Option A Achieved Achieved 6-8% MRI 
cannot take 
place, estimated 
costs of 172 Mio Euro for the 
general society Negative impact 
on growth of 
medical 
technology and restriction on 
economic 
activities in other areas  660.3 
Option B Achieved Achieved A smaller 
number of MRI 
cannot take placeLess strong 
negative impact 
on growth of medical 
technology. 
Other economic activities are not 
or only very little 
restricted. 526.9 
Option C1 In general 
achieved, case 
specific analysis 
required In general 
achieved, but less 
convincing than 
with options A 
and B No restriction to 
MRI and its 
economic 
development Signal that 
flexible solutions 
can be found 511.7 
Costs for MRI 
reinforced 
measures 
included 
Option C2 In most areas 
achieved, but for some areas 
achievement is 
not ensured Safety standards 
are perceived as not reliable Signal that 
economic interests can 
overrule 
workers’ concerns Unequal 
treatment of sectors may 
create problems. 497.4 
Option D1 Protection of 
Workers 
dependent on MS  Partially, 
depending on the 
effect of the recommendations 
in the MS More uncertainty 
concerning the 
protection of groups at 
particular risks Patchwork of 
solutions which 
is not good for mobility and 
competitiveness 437.1 
Option D2 Protection of 
workers dependent of the 
content of the Partially, 
depending on the effects of the 
content of the More uncertainty 
concerning the protection of 
groups at Patchwork of 
solutions which is not good for 
mobility and 420.2 
 
EN 40   EN agreement(s) agreement(s) par ticular risks. competitiveness 
Option E Not at the level 
of more stringent 
options No Bad signal to 
stakeholders. No 
explicit 
protection for workers anymore 
whilst 
recommendations for general public 
remain Lack of guidance 
may end up in 
higher 
assessment costs 474.0 
Given new scientific evidence which indicates that exposure limits as provided under option B  will 
ensure protection against overexpo sure, option A only adds the disa dvantages of restricting some 
activities and overall less willingness to comply.  
At the other end of the spectr um of possibilities option D1 (R ecommendation), D2 (Voluntary 
agreement) and E  (no EU legislation) can be rejected. St akeholders and expert s expressed strong 
preference for consistent European legislation which gives employers and employees legal and 
physical security. Although EMF on its own is not a major issue, consistent European legislation in 
the field is seen as contributing to the Single Eu ropean Market. Furthermore, abstaining from any 
European level action on EMF would reduce significan tly the attention paid to  the risks of EMF and 
could have negative health impacts.  
The three remaining options are options B (revise d exposure limits), C1 (revised exposure limits 
and conditional exemptions limited to some provisions for medical MRI) and C2 (revised exposure limits and complete exemptions of some activ ities from the scope of the directive).  
Option B
 has the advantage of consistent rules on EMF with exposure limits which are for a 
considerable number of the workpl aces already high enough, so that there is no longer a threat of 
overexposure. Compared to option A the number of situations with poten tial overexposure reduces 
significantly. Option B is in line with recent scien tific evidence. The disadva ntage of this option is 
that there are some activities ( like some MRI treatments) where temporary excessive exposure is 
possible. Completely stopping th ese activities – which are in some cases closely linked to 
technological progress and undertaken to directly contribute to the h ealth and well-being of citizens 
– is problematic. 
Option C1  has the advantage of consis tent rules on EMF in most ar eas like for Option B, while 
accepting derogation from exposure limits for medical MRI and reinforced preventive measures in 
situations where there is a threat of overexposure. As  in the case of option B this must rely on recent 
scientific evidence. It would be more flexible than option B. The disadvantages of option C1 are 
that in case of derogation it requi res a more stringent and more c ontrolled working environment.  
Option C2  also has the advantages of consistent rules on EMF in most areas and allows for flexible 
solutions in situations where there is a threat of over-exposure. The obligations in terms of risk-
assessment are lower for the exempted sector. This also reduces the compliance costs. The disadvantage of this option is that there is no pr otection against this lead ing to lower levels of 
workers protection. Furthermore this option woul d encourage more heter ogeneous protection of 
employees in contradiction with the lette r and spirit of the Framework Directive. 
Conclusion on costs:
 The cost of Option C1 is higher than the costs for less stringent options from 
C2 to E. However for a rather limited increase of  costs Option C1 scores much better than these 
options for other - more qualita tive impacts - and guarantees a high level of protection for the 
 
EN 41   EN workers. The cost of Option C1 is significantl y lower than the cost for option A and almost 
equivalent to Option B whilst offering to the MRI s ector and the industry the flexibility they need.  
Consequently, based on these cons iderations and in line with the survey results hereafter the 
Commission therefore prefers option C1 .  
This conclusion is in line with the results of a su rvey carried out among st akeholders and experts by 
the FICETTI consortium (annex 9). The findings are as follows: 
• Option A is generally considered to have disproportionate economic  costs, especially for SMEs 
• Option B was difficult to assess in the absence of  new exposure guidelines from ICNIRP at the 
time of the survey. Stakeholders believe Option B has rather high economic consequences but it scores well on social and health impacts 
• Option C1 is the only option to score consistently positive in this survey based analysis, despite 
the fact that the new exposure guidelines were not known at the time just like for Option B. The 
additional flexibility and proportionality availabl e under this option led to it being ranked ahead 
of others. 
• Option C2 scores badly on economic and neutrally  on health and social impact grounds, leading 
to an overall negative score. 
• Options D and E score badly on health and social impact gr ounds. Option E especially is 
unpopular with stakeholders. 
The detailed assessment also shows that 'soft elements' like information campaigns targeted at 
specific sectors and practical guid es how to implement legislation on the sectoral level should 
continue to complement the legislative action. 
These conclusions indicate an overall prefer ence of the responding st akeholders for option C1.
51  
                                                 
51 See annex 9 and FICETTI report. 
 
EN 42   EN 7. MONITORING  AND  EVALUATION 
The framework directive 89/391/EEC and the subsequent  19 individual directives  in the sense of its 
Article 16.1 foresee a regular review of the effe ctiveness of their implementation. Since 2007, this 
systematic review has been harmonized and must be  performed every 5 years by all Member States 
for all risks covered by the directives. A report is  then prepared by the Commission which can serve 
as a basis for an evaluation of the situation and for the reporting of implementation difficulties. 
Also, committees bringing together national experts from EU Member States are an important part 
of the process of evaluating and monitoring EU legi slation relating to health and safety at work. 
First there is the tripartite A dvisory Committee for Safety and H ealth at Work set up by a Council 
Decision (2003/C218/01). Each Me mber State has a governmental, an employers' and a workers' 
representative. This is a good place to report on possible problems or unexpected or unwanted 
consequences of an EU-OSH initiative. Part of the remit of the Committee is to assist the European Commission in the preparation, the implementation and the evaluation of  activities in the fields of 
safety and health at work. 
Secondly, there is the Senior Labour Inspectors Committee (SLIC) set up by Commission decision 
(95/319/EC
). It assists the European Commission in monitoring the enforcement of EU legislation 
at the local level. SLIC provi des opinions, either at  the Commission’s re quest or on its own 
initiative on all problems relating to the enfor cement by the Member States of Community law on 
health and safety at work. This committee which meets several times a year enables exchanges of 
views, the sharing of inspection experience and good practices and represents an additional forum 
for firsthand feed-back.  
 
EN 43   EN 8. ANNEXES 
 
EN 44   EN  
Annex 1  
Second stage of consultation of the social partn ers on the protection of  workers from the risks 
related to exposure to electr omagnetic fields at work 
ANSWERS TO THE CONSULTATION 
Synthesis 
The Commission launched the second stage consulta tion of the European social partners, in 
accordance with Article 154(3) of the Treaty on the Functioning of the European Union (TFEU), on 
the content of a new European Un ion initiative to ensu re the protection of workers exposed to 
electromagnetic fields (EMF) during their wor k. The relevant document is C (2010)3250 final, 
published on 20.5.2010. 
The Commission received a total of twenty-seven  answers from associations, organisations and 
institutions. In particular: eight een employers' organisations (10 EU ; 2 international; 1FR; 5 UK), 
two workers' organisations (1EU; 1DE), three nati onal scientific institutions (RO; 2 PL), three 
private experts and one patients' associati on (EU) responded to the Commission's questions. 
Acronym Full Name+main activity Category 
Alliance for MRI Alliance for MRI (radiology) EU; Patients+Practitioners 
ARQIVA Broadcasting and wireless 
communication UK; Employers 
BUSINESSEUROPE Confeder ation of European 
Business EU; Employers 
CBI Business lobbying 
organisation UK; Employers 
CEA National Scientific Institute FR; Employers 
CEEMET Council of European 
Employers of the Metal, 
Engineering and 
Technology-based Industries EU; Employers 
CEEP European centre of 
Employers and Enterprises providing Public Services EU; Employers 
CER Community of European 
Railways and Infrastructure Companies EU; Employers 
COCIR Medical MRI Equipment 
manufacturers EU; Employers 
 
EN 45   EN DGB Deutscher 
Gewerkschaftsbund DE; Workers 
EEF Engineering Employers’ 
Federation UK; Employers 
EMFields Ltd Consultants fo r EMF UK; Private experts 
ENTSO-E Electricity distribution EU; Employers 
ETUC European Trade Union 
Confederation EU; Workers 
EURELECTRIC Electri city production and 
distribution EU; Employers 
EUROCHLOR Chemical processes; 
industrial electrolysis EU; Employers 
Goiceanu (Mr) National Scientific Institute RO; Scientists 
GSMA Mobile telecommunication 
industry International; Employers 
HOSPEEM European Hospital and 
Healthcare Employers' Association EU; Employers 
IEMFA International Electro-
Magnetic Fields Alliance International; Private experts 
Israël (Mr) EMF coordinator for 
Bulgaria BG; Scientists 
NATO North Atlantic Treaty 
Organization (defence) International; Employers 
Polish experts on 
Bioloelectromagnetic Problems Polish Society of Radiation 
Research PL; Scientists 
Polish experts panel National Interdepartmental 
Commission PO; Governmental scientists 
SMMT Society of Motor 
manufacturers and Traders UK; Employers 
UEAPME European Association of 
Craft, Small & Medium-Sized Enterprises EU; Employers 
UK-NHS National Health Service UK; Employers 
 
EN 46   EN The Commission had requested the Social Partners to: 
1. Submit to the Commission an opinion or, where appropriate, a recommendation on the 
content of the envisaged legislative and non-le gislative initiatives pursuant to Article 154 
(3) of the TFEU, giving particular attention to the topics identifie d in section 4 above; 
2. To inform the Commission about alternative solutions in particular for the expression of 
exposure limit values in the range of 0 to 100 kHz and for ways to foster and concretise the 
aspects linked to the implementation of sound and efficient protectio n of workers exposed 
to electromagnetic fields during their work. Alternative solutions for the range from 100 
kHz to 300 GHZ are also welcome; 
3. Where applicable, to indicate their willingness to  enter into negotiations  on the basis of the 
proposals described in this document under the terms of Article 154(4 ) and Article 155 of 
the TFEU. 
Section 4 of the Commission Document, which is re ferred to in point 1, raised the following issues: 
4.1. Coverage of all sectors of activity 4.2. Precise definitions 4.3. Exposure limit values 4.4. Measurements and calculations 4.5. Guidance for risk assessments 4.6. Due flexibility in a cont rolled working environment 
4.7. Medical surveillance 4.8. The specific case of medical applications  and related activities (research, cleaning, 
maintenance) using nuclear magne tic resonance (MR) technology 
4.9. Non-binding measures 
Overall, the social partners welcome the initia tive to propose a new Directive on EMF, since the 
present one, Directive 2000/40, is deemed to be to complex and difficult to apply and would hinder 
some activities and procedures, in particular Ma gnetic Resonance Imaging (MRI). Some employers 
pointed out that even if EMF are an issue that  has to be tackled, they do not constitute major 
concerns, since they assume that no evidence of adverse health effect by their normal usage has been found. Only one employers' organisation, EEF, expressed the view that there would be no 
need for an individual Directive in this field, being the disposit ions of the Framework Directive 
89/391 sufficient to addre ss priorities and risks. 
The responses to the Commission's proposal could be synthesised in this way: 
Point 1 : Submit to the Commission an opinion or, where appropriate, a recommendation 
on the content of the envisaged legislativ e and non-legislative initi atives pursuant to 
Article 154 (3) of the TFEU, gi ving particular attention to the topics identified in section 4 
of the document.  
 
EN 47   EN 4.1. Coverage of all sectors of activity 
Commission's proposal 
The Commission considers it importa nt that EU legislation on o ccupational health and safety 
covers all workers in all sectors of activity in conformity with Article 2 of Framework 
Directive 89/391/EEC. This reflects the wishes of a large majority of  the social partners’ 
organisations who responded to the first phase of the consulta tion and does not depart from 
the provisions of the current directive on the issue. 
There is general consensus on the coverage of a ll sectors of activities by the new proposal. Some 
organisations pointed out that a degree of flexibil ity is however needed in order to enable every 
sector to pursue its activities. NATO underlines that Directive 89/391 does not apply to armed 
forces.  
4.2. Precise definitions 
Commission's proposal 
As the issue has to do with short-term effects,  the Commission is of the opinion that a better 
understanding of the mean ing of adverse health effects c ould reconcile science and industry. 
This should allow a flexible system to be deve loped for defined working conditions in certain 
activities. In order to be credible the system  should reflect the most r ecent scientific progress 
and subsequent recommendations. The definitions  contained in Article 2 of the directive 
should therefore be adapted accordingly. 
There are differing opinions on whether phosphenes,  vertigo and nausea should be considered 
as adverse health effects. They could affect certain aspects of work performance if precision, 
concentration, short-term reaction time or work at height is re quired and would de  facto affect 
the safety of workers but not their health. Th e Commission is of the opinion that the solution 
may be to distinguish between effects which ar e harmful to health and effects which can be 
detrimental to the safety of the worker and ma y even impair the qualit y of work. In practice 
this may lead to a situation where acceptable levels of exposure to EMF depend not only on 
frequency and intensity of the source  but also on the type of work. 
Many organisations welcome the effort towards cl arity and simplification;  definitions should be 
understandable by all. A distinction between adverse health effects and temporarily physical effects 
which are only detrimental to safety and not to health is endorsed by mo st of the employers; a 
ranging of the effects has also been suggeste d. CER affirms that a strong subjective element 
underlies physical effects; therefore it shouldn't be required to take them in to consideration. On the 
contrary, national institutes believ e that also physical e ffects should be taken into account, and that 
the fact that there is no scientific evidence yet on their link to EMF, this should not mean that the 
level of safeguard should be reduc ed. Workers' associations reco mmend giving precise definitions 
of what is considered to be "harmful" and don' t accept a mutually-exclusi ve distinction between 
what is harmful to safety and what is harmful to health. 
4.3. Exposure limit values 
Commission's proposal 
 
EN 48   EN ICNIRP has recently reviewed its recommendations for static fields and is currently reviewing 
its recommendations for the low frequency range which goes from just above 0 Hz to 100 
kHz. A further review of the recommendations fo r higher frequencies is expected in the near 
future. The latter do not seem to be controvers ial because in most situations and under normal 
circumstances they are not exceeded. ICNIRP  recommendations, both the ones published in 
1998 and their new ones as discussed during a c onsultation process, ar e nowadays challenged 
by different agencies: IEEE (USA),  ARPANSA (Australia ) and very recently by a proposal of 
the German Ministry for Employment and So cial Affairs (BMAS). The Commission intends 
to take into account the divers ity of recommendations from th e scientific world and replace 
the current system, which comprises one acti on value and one exposure limit value for each 
frequency, by a ‘multilayer’ system facilitating the verification of compliance and the decision by the employer. This is very much  in line with suggestions already made by 
CENELEC (zoning) and Member States or em ployers’ federations that have already 
undertaken to develop guidance for their workers or members. 
The Commission would however suggest mainta ining the provision of  the directive for 
frequencies above 100 kHz. The ‘zoning’ system for frequencies from 0 to 100 kHz would be 
as follows: 
• Zone 0 (blue zone) where the situation is similar to what is acceptable for the public (no 
action deemed necessary); 
• Zone 1 (green zone) where exposure remain s under the levels pr oposed by ICNIRP in 2009 
for frequencies up to 100 kHz: as there are no h ealth and safety problems, and giving specific 
information to staff should be sufficient except for frequencies equal to or lower than 1 Hz 
where nausea and vertigo may occur. In that pa rticular case, protection measures as for Zone 
2 should apply; 
• Zone 2 (yellow zone) where exposure is be tween the ICNIRP 2009 proposed values and the 
value fixed for Zone 3 (see below): no harmful health problems expected but maybe adverse 
quality problems or potential work ers’ safety problems due to appearance of phosphenes. This 
is the area where required actions and preventi ve measures are in fact situation/activity-
dependent as already indicated under 4.2. A non-e xhaustive list of identified activities could 
be provided in an annex. Measures that should  be considered here include: information, 
specific training and awareness raising, a ppropriate labelling, and limited access;  
• Zone 3 (red zone), where exposure exceeds the current commonly accepted limits proposed 
by ICNIRP and IEEE for frequencies above 10 0 kHz and where the e xposure is above the 
limit line of the BMAS proposal. In this zone, no access should be allowed or even possible. If access is required it must ta ke place under strictly controlle d conditions, never in routine 
work. 
This system would replace the current action valu es and exposure limit values concept in the 
range under 100 kHz and all the limits would be expressed in the same units, for directly 
measurable quantities. 
There is a general agreement on the need of revisi ng the restrictive values of the present Directive 
and on the need for them to be directly and eas ily measurable. The only exception is CER, which 
endorses to keep those of Dir ective 2000/40. Some organisations  contest the us e of ICNIRP 
recommendations, given that they  are undergoing revision and that  the draft vers ion of the new 
 
EN 49   EN guidance has been criticised. More than one employers' organisation s upports a system where 
ICNIRP values are not compulsory, and different ones can also be used. NATO suggests that the 
Directive should not include indication of values, since they are subject to modifications, but only 
some guidance. It is noticed that  EMF devices can emit at different levels, therefore emissions are 
difficult to control (CIOP). BUSINESSEUROPE reco mmends that the limits should not be related 
to the type of work carried out, and point out that a hi gh degree of clarity is needed in this issue 
because in some cases employers can be subject  to penal sanctions if they don't respect the 
requirements. GOICEANU supports lim its that are also based on physic al effects; COCIR adds the 
taking into account of non-thermal and long exposure factors. CIOP deems that there should also be 
a duration limit to exposure. UEAPME questions whether the eventuality of the co-existence of 
multiple EMF sources is considered. 
The zoning system is commonly accepted in prin ciple, but many organisations reserve their 
evaluation until the final levels are set up. The general estimation is that the zoning system is quite complex, many organisations suggest to merge zone  0 and zone 1, some of  them don't agree with 
the limit of 100 kHz. Several respondents remark that  the definition of zone 3 is not very consistent 
because on the one end it says th at "no access should be allowed or even possible", and on the other 
it implies that access can, even though under strictly controlled conditions, occur. NATO proposes a system based of five restrictiv e zones; NHS-UK suggests different limits for the public and for the 
workers; The Polish Society of radiation resear ch advocates internati onally harmonised values. 
4.4. Measurements and calculations 
Commission's proposal  
Management of uncertainties has been reported as being a serious difficulty in implementing 
the exposure limit system set up by the directive even with resort to standards, such as 
EN50499 developed by CENELEC in 2008 on th e basis of the mandate M/351 of 17 May 
2004 given by the Commission to CENELEC in orde r to meet the requirements of Article 
3(3) of the directive currently in force: 
‘3. for the assessment, measurement and/or calculation of workers’ exposure to 
electromagnetic fields, until harmonised European standards from the European Committee 
for Electrotechnical Standardisa tion (CENELEC) cover all relev ant assessment, measurement 
and calculation situations, Member States may em ploy other scientifical ly based standards or 
guidelines’. 
As in any activity where measurements are made, each value is affected by a degree of 
uncertainty. In most cases this uncertainty tends to be limited (a few percent) and can accepted without problem. Unfortunately when measuring electric or magnetic fields the 
‘errors’ can become very high (u p to 100 % of the measured valu e). From a technical point of 
view this may be dealt with when the measur ements concern process controls and triggering 
signals. This may however become an issue from  a legal point of view – at least in some 
Member States – when it comes to comparing a measurement and an exposure limit value, 
especially when the latter is expresse d in non directly measurable quantities. 
Consequently, uncertainty plays an important role in assessing  human exposure to EMF since 
it affects the results of measurements and nu merical calculations. The directive does not 
address this problem in depth and the new proposal  will need to give clear guidance in this 
respect. Moreover, the way to deal with pulsed, non-sinusoidal signals and harmonics should 
also be covered, bearing in mind that in the new system such complex and costly 
 
EN 50   EN measurements and evaluations should be limite d to cases where exposure is likely to exceed 
the upper limit of Zone 2.  
There seems to be an urge for directly measurab le calculations, also feasible by non specialists. 
EURELECTRIC and others support  considering the us e of CENELEC as advisory and not 
compulsory, and that other parameters can be used too. In general, there is  an urge for directly 
measurable values, simple and understandable  by all. EURELECTRIC endorses the use of 
measurable rather than internal quantities. Seve ral employers' organisations advocate the use of a 
practical approach, and many of them suggest that  measurements should only be done when there is 
likelihood of exceeding zone-1 limit, due to the costs that constant measurement would imply, 
especially on small businesses. Also, a science-base d approach is supported,  that only takes into 
account proven risks to health. CIOP requests different parameters for the research sector. 
4.5. Guidance for risk assessments 
Commission's proposal  
According to expert reports, employers do not always realise that there will be situations 
where their staff may be exposed to a high elect ric and/or magnetic field. This is for instance 
the case in establishments using just one we lding device, an induction furnace, an in-house 
electric transformer, a microw ave drying system, etc. Conseque ntly, exposure to EMF is not 
normally considered as a risk and it must be r ecognised that it is probably not seen as one of 
the major sources of illness or accidents in su ch enterprises. Therefor e appropriate guidance 
should be given to raise aw areness and simplify the risk assessment procedure. The 
Commission is aware that some Me mber States and sectoral asso ciations have already put in 
place simple but effective tools to help employers  take account of risks linked to exposure to 
EMF. Moreover, the EN50499 standard referred  to in point 4.4 abov e entails a similar 
approach. These tools and means have the great advantage of simplifying the compulsory risk 
assessment and of limiting the burden when the s ituation does not require extensive efforts. 
This approach leads to a simp le but effective risk assess ment, thereby boosting overall 
implementation. 
The new proposal for a directive will not exempt any employer from carrying out a risk 
assessment and documenting it as already provided for in Directive 89/391/EEC but will introduce to a large extent the desired simplif ication and proportionali ty. Assessment time and 
costs will thus be reduced whenever possible w ithout jeopardising workers’ health and safety. 
Guidance on risk assessment is broadly welcome;  assessment should be a simple and not overly 
burdensome practice. Some organisations propose a proportionality approach; some others add that 
only when zone 1 is likely to be exceeded such  assessment should be made. CEEP supports the 
provision to employers of indi cative exposure measures. UEAPME advocates the creation of safe-
equipment lists. EURELETRIC a dds that it would also suppor t the introduction of lists of 
equipment which is not considered safe. ETUC expr esses its concerns on the creation of the lists; 
asks for repeated exposure to be taken into acco unt; and affirms that they would welcome guidance 
to assessment of sector-specific risks. CIOP under lines that the "CE" labe lling of equipment does 
not duly take into account health risks and that  this should be tackled. BUSINESSEUROP and 
others advocate the use of standards other than  those of CENELEC. UEAP ME suggests carrying 
out awareness-raising activities the use of simplified and proportionate risk-assessment tool for the SMEs.  
 
EN 51   EN 4.6. Due flexibility in a cont rolled working environment 
Commission's proposal  
As can be noted from points 4.2 to 4.4 rela ting to short-term effects, the Commission 
recognises the need for an appr opriate and proportional approach  for all sectors of activity. 
Exposure to electric and/or magnetic fields above  some levels can have effects on the human 
body; however, these effects are not necessarily adverse to health. 
The Commission has taken due note of th e latest conclusions of the SCENIHR 11 relating to 
possible long-term effects. One may concl ude from SCENIHR’s opi nion that there is 
currently no consistent evid ence of long-term adverse eff ects on adult human bodies (with 
very few exceptions for young children) and therefore no possibility to take them into consideration for a quantifiabl e approach in a binding legal instrument. The Commission is 
however of the opinion that a precautionary a pproach should be part of the preventive 
measures developed in the new instrument. In practice this would entail the inclusion of a 
generic principle to avoid pres ence in an exposed zone whenev er a worker’s presence is not 
necessary to carry out an  activity. This is already stated in  the directive under Article 5(2) f): 
‘….. (f) limitation of the duration an d intensity of the exposure; ’. 
Whilst cognitive and/or adverse health effects do appear above certain levels, they can be 
overcome and their nature (nerve stimulation) may be acceptable under certain circumstances  
for instance in a controlled envi ronment. This flexibility to ac cept occasional overriding of the 
upper limit of Zone 2 would obviously have to be  counterbalanced by appropriate training and 
preparation, a thorough risk assessment, adapted exposure level measurements and 
transparent, documented monitoring. A specific a nnex would address this issue in some detail 
for the different areas of the frequency spectrum up to 100 kHz. 
Above that frequency, where the exposure lim it values should remain unchanged, the adverse 
effects consist in inte rnal or external burns from wh ich the human body may not recover 
immediately. This cannot be accepted. However, h eating of tissues does not necessarily occur 
if the exposure time is very short. The importa nce of this parameter is  underestimated in the 
present directive. It is intende d that the proposal should make cl earer the interpretation to be 
given to exposure time and averag ing over it so as to tie in with current publications of 
ICNIRP and IEEE. 
Most of the respondents are in favour  of a certain degree of  flexibility, and belie ve this should apply 
to all sectors; workers in particular deem that it should be strictly controlled that the protection of 
the worker is not hampered. Most of them (the employers) use a scientific-based approach, saying 
that since no scientific evidence exists on adve rse health effects on EMF in the long term, as 
SCENIHR demonstrates, the Direc tive should not cover this issue. NATO, in the same line, 
suggests a " de minimis " approach. Some organisa tions reject the use of a precautionary approach. 
CIOP accepts a certain degree of flexibility provided that minimum health requirements are complied with. The workers' representations an d EMF Alliance don't agree. Some question the 
appropriateness on the use of prec autionary principle. CEA points out that a balance should be 
found between the need of protection for the workers and the burdens on the undertakings, 
especially SMEs. BUSINESSEUROPE underlines that training should not be c onsidered as a basic 
action to counterbalance the use of  flexibility. Many organisations of  different nature advocate the 
taking into account of the exposure time, and also of the case of repeated exposure 
(ETUC).Workers' representatives, as well as scientific institutions, believe that long term effects 
 
EN 52   EN should be taken into account, in particular, EMF Alliance point out that gradual accumulation, 
intrinsic amplification and interaction with other agents are factors that can imply adverse health 
effects of EMF exposure, based on s ound empirical scientific research. 
4.7. Medical surveillance 
Commission's proposal  
Doctors present at the Umea Conference of Oc tober 2009 admitted that they found it difficult 
to identify effects from exposure to EMF, especially with rou tine medical surveillance. They 
also felt there was a need for guidelines on how to handle overexposure as moderate 
overexposure could not be expected to produce any effects once the exposure is over. The 
actual question was: what should be looked fo r after heavy exposure, except for burns? The 
experts were of the opinion that  the exposure limit valu e as suggested in th e directive was not 
a useful indicator for health examinations. 
An open question remains concerning the need fo r special protection of persons at increased 
risk, e.g. pregnant women, persons with implants  and persons with certain neurological or 
cardiac diseases. 
In view of these medical opinions, which seem to  be quite widely hel d, it is suggested that 
Article 8 of the directive be revised. 
In addition, and this was also suggested by the medical  experts present at the Umea 
Conference, there is a need to establish guida nce in this field. The Commission proposes the 
setting-up of an appropriate working part y under the Advisory Committee on Safety and 
Health at Work to develop such guidance. 
Many respondents observe th at there is not enough knowledge at the time of  type of surveillance 
needed and/or possible and on way it  should be carried on. Especially  at frequencies lower than 100 
kHz effects are difficult to diagnose. Most of  the employers' representations believe that 
surveillance should only be compulsory in case of overexposure, also due to the costs they would 
have to incur otherwise. CEEP esteems that ther e is no need for compulsory surveillance at all. 
Workers deem instead that there should be a consta nt monitoring of the workers, that after-accident 
investigation should always be performed, and that the related files should be  archived in order to 
assess long term effects.  
4.8. The specific case of medical applications and related activities (research, cleaning, 
maintenance) using nuclear magn etic resonance (MR) technology 
Commission's proposal  
MR technology is used in medi cal applications such as ma gnetic resonance imaging (MRI) 
and magnetic resonance spectroscopy (MRS). These methods are very powerful and have improved patient care immensely in terms of diagnosis and follow-up of diseases and opened 
new perspectives for interventional medical procedures. Currently, the existing provisions 
would preclude the use of such equipment and methods as they would not comply with the 
limit values of the directive. Therefore the Co mmission has to find a way of providing a high 
level of protection for workers dealing with MR techniques while at the same time permitting the development and full use of MR medical procedures. 
 
EN 53   EN A study ordered by the Commission on the subject of medical MRI 12 showed that compulsory 
compliance with the exposure limit values of th e directive would indeed hamper the further 
use of MRI. However, the study i ndicated that the problem affect s a relatively limited number 
of procedures - less than 10% - and are restricted to the freque ncy range from 0 Hz to 10 kHz 
used in MR medical techniques. For the large ma jority of the procedures - more than 90% - 
compliance with the provisions of  the directive would de facto be assured without any change 
in the current way of working or, in a limited number of cases, by slightly adjusting working practices during the medical procedures. 
By way of example, and bearing in mind the tec hnical specifications of the current machines - 
a large majority of which use a 1.5T or 3.0T (ra rely 7.0 T) static magnetic field – ‘slightly 
adjusting working practices’ to  bring the level of  exposure under the current exposure limit 
values would imply the following recommendations: 
– do not come closer than 0.5m from the entry of the bore when not absolutely necessary to 
assist the patient; – just walk normally in the MRI room (~ 4km/h); – do not stay close to the bore when (image) acquisition is in progress; 
– do not remain in the room when it can be avoided. procedures still represents – per year in  the EU - between 400 000 and 500 000 medical 
procedures that would contravene the directiv e because a presence close to the patient cannot 
be avoided or in cases of emergency, e.g. for the patient. 
Analyses were conducted to compare exposure leve ls for these critical cases with a different 
set of limit values (for instance, IEEE values in the USA) and no ideal solution could be found. Therefore, the Commission envisages th e possibility of exempting the medical MR 
sector and activities related to the use and development of medical MR techniques from 
binding exposure limit values. However, workers’  health and safety w ould continue to be 
protected through reinforced qualitative preven tative and protective measures to be included 
in the proposal for revi sion of the directive: 
– reinforced information measures; – reinforced training of workers; – documented and practicable working proce dures favouring exposure limitation whenever 
possible; – strict administrative procedures for access to MR rooms; – consultation of personnel on improvements; – monitoring. Qualitative elements that reassure the Comm ission when proposing exemption from binding 
exposure limits are that the presence of workers in exposure situations is very limited in their 
normal working time and most of the workers are skilled people who can easily be made 
 
EN 54   EN aware of good practic es. Moreover, most inst ances of exposure woul d not be far above the 
new proposed limits announced under 4.3 above. 
Appropriate and commonly agreed qualitative prevention and protectio n measures should be 
implemented in a harmonised way ideally in all the medical MR faciliti es existing in the EU 
(more than 8 000). European organisations of  MR practitioners and manufacturers have 
already indicated their willingness to give their full support to this approach. Contacts 
between Commission services and stakeholders have been pursued since July 2006. They 
have already led to the successf ul completion of the study referre d to in paragraph 3 of this 
section. In a second phase, which is still in  progress, discussions  have focused on the 
implementation of a common, effective and relia ble system, to be adopted for all EU MR 
facilities with the support of the workers and employers of the sectors concerned. 
Employers' and business associations  directly implicated in the MR  resonance sector, as well as 
Alliance for MRI fully support the exemption of MRI from the expos ure-values requirements. In 
particular, it is noticed that vulne rable patients need assistance and that there is already a strong 
health and safety culture in health-care sector. It  has also been underlined (NHS-UK) that this may 
lead physicians to recur to more dangerous t echniques such as ionising radiations. Some 
organisations simply affirm they don't think to be concerned by this issue. Workers and science-
experts think that exemptions per se  are not a good idea, but accept that some specific rules for 
individual sectors can be set, provided there is  enough protection and health monitoring for workers 
and that this is periodically re viewed (ETUC). NATO disagrees w ith the introduction of whatever 
type of exemption. CIOP suggest that limitation of exposure levels shoul d not be defined; CEA 
requests exemptions also for research activit ies, especially the experimental phases. 
4.9. Non-binding measures 
Commission's proposal  
The Commission agrees with the social partners  that the complexity of the matter and the 
scarce expertise, in particul ar in SMEs, justify supplementi ng the revised di rective with 
nonbinding initiatives. 
For example, the Commission, assisted by the Advisory Committee on Safety and Health at 
Work, has already begun drawing up a guide on prevention and good pr actice which will 
cover the main risk activities and situations. A first draft was prepared in line with the 
provisions of the current directive but it will ha ve to be adapted in order to suit the revised 
directive. 
For difficult situations where workers face very  high exposure levels, pr ecise evaluations will 
be necessary and appropriate standards deve loped by CENELEC will be the best solution. 
However, for lower exposure levels more simple guidance will have to be developed in the language of the ‘end users’. The Commission is of the opinion that an active role by the social 
partners is of crucial importance for effectiv e prevention and that the employers’ and workers’ 
organisations have an essential role to play  in developing and enc ouraging dissemination to 
their members of non-binding but well-adapted t ools. The Commission intends to invite the 
Advisory Committee on Safety and Health at Work to play a more proactive role in this field 
in the future. 
Furthermore, the Commission intends to ask the European Agency for Safety and Health at 
Work to step up information, guidance and aw areness-raising activi ties on the ground with a 
 
EN 55   EN view to enhancing protection against exposure to  EMF in selected sectors. Such activities, 
including a possible European information and awareness campaign, would be undertaken 
with the close involvement of the Me mber States and social partners. 
All the organisations generally welcome the n eed for non binding measures and guidelines. Some 
have expressly agreed on the crea tion of a working party. CER indicat e that they wouldn't want this 
kind of measures to be included in  the text of the Directive. The role of social partners in the 
creation of guiding documents has been underlined. NATO warns about the risk of increasing fear 
by performing awareness raising campaigns. 
Point 2:  To inform the Commission about alternati ve solutions in particular for the 
expression of exposure limit values in the r ange of 0 to 100 kHz and for ways to foster and 
concretise the aspects linked to the implem entation of sound and ef ficient protection of 
workers exposed to electromagnetic fields durin g their work. Alternative solutions for the 
range from 100 kHz to 300 GHZ are also welcome.  
Point 2 received few answers: ETUC suggest the cr eation of an experts committee, the elimination 
of risk exposure and the finding of measures to tackle EMF risks, like good practices. CEEP 
believes that existing measures are enough: CEA insi st on taking long term effects into account; and 
UEAPME only wishes that the limits between the zones are always directly measurable. 
Point 3:  Where applicable, to indicate  their willingness to ente r into negotiations on the 
basis of the proposals described in this doc ument under the terms of  Article 154(4) and 
Article 155 of the TFEU.  
Regarding point 3 there does not seem to be a real  will to enter into negotiations. ETUC only wish 
to participate in the drafting of eventual gu idance; CEEP does not exclude negotiations, EMF 
Alliance say they are open to negotiate; NHS-UK be lieves social partners would lack technical 
knowledge to complete such an exercise. Fi nally, BUSINESSEUROPE don't see the need for 
negotiations since they think the pro posal of the Commission is good enough. 
 
EN 56   EN Annex 2  
Current legislative situation in the EU Member St ates as regards exposure of workers to EMF 
Sources of information 
Official European Commission information 
NATIONAL PROVISIONS COMMUNICATED BY  THE MEMBER STATES CONCERNING: 
Directive 2004/40/EC of the European Parliame nt and of the Council of 29 April 2004 on the 
minimum health and safety requirements regarding the exposure of workers to the risks arising 
from physical agents (electromagne tic fields) (18th individual Di rective within the meaning of 
Article 16(1) of Directive 89/391/EEC) 
The official webpage of the EC reports the following situation: 
For Belgium ,Bulgaria ,Denmark, Germany, Ir eland, Greece, Spain, France, Cyprus, Luxembourg, 
Hungary, Malta, Netherlands, Po land, Portugal, Romania, Sloven ia, Finland, Sweden and United 
Kingdom  
there is no national law specific to the EMF Di rective that has been finalised or published. 
For seven countries: 
Austria, Estonia, Latvia, Lithuania, It aly, Czech Republic and Slovakia 
the European Commission is aware of national legislation. It should be  noted that all these countries 
report that they intend to fully implement th e EMF Directive by 2012 and therefore have not yet 
fully done so. 
Austria 
The Austrian legislation called VORNORM ÖVE/ÖNORM E 8850:2006-02-01 is available in 
German at: 
http://www.beuth.de/langanzeige /OEVE%2FOENORM+E+8850/88537115.html 
for a cost of 103.68 Euros. Discussion with Austrian colleagues indicates that th is is little more than 
a translation of the ICNIRP guidelines and ha s no practical information on implementation. 
Estonia 
The relevant legislation is RT I 2002, 15, 83. We have obtained this standard in the Estonian 
language and it appears to be a translation of the IEEE EMF guide lines (although it has not been 
possible to obtain a translation) and therefore c ontains rather different limits than the EMF 
Directive itself. 
Latvia 
The Latvian legislation is availa ble in English. The rele vant legislation for the EMF directive is: 
 
EN 57   EN Cabinet Regulation No 745, Adopted 5 September 2006: Labour Protection Re quirements for the 
Protection of Workers from th e Risk Arising from the Electromagnetic Field in the Work 
Environment, issued pursuant to Section 25, Paragraph 18 of the Labour Protection Law 
It is very close to the EMF Directive itself and does not contain any practical implementation 
information. Another document, Guide 1.6: “Labour  Protection Requirements for the Protection of 
Workers from the Risk Arising from the Electro magnetic Field in the Work Environment” does 
have practical information. 
Lithuania 
The relevant legislation is: 
Regulations on Protection of Workers from th e Risks Arising From Electromagnetic Fields, 
approved by Order No. A1-119 of the Minister of Social Security and Labour of 25 April 2006 
(Official Gazette, 2006, No. 47-1691) 
Italy 
The Italian legislation is: 
Decreto legislativo 9 aprile 2008, n. 81, "Attuazione dell'articolo  1 della legge 3 agosto 2007, n. 
123, in materia di tutela della salute e della sicurezza nei l uoghi di lavoro" pubblicato nella 
Gazzetta Ufficiale n. 101 del 30 aprile 2008  Supplemento Ordinario n. 108 
This Legislative Decree has 13 sections and 306 ar ticles and 51 technical annexes. It covers many 
workplace risks and makes the general protection principles of the Framework Directive 
(391/89/EEC) binding from January 2009. The EMF pa rt is based on Directive 2004/40/CE and is 
binding from April 2012. There is also a practical Guide to implementation: 
Decreto Legislativo 81/2008, Titolo VIII, Capo I, II,  III e IV sulla prevenzione e protezione dai 
rischi dovuti all’ esposizione ad agenti fisici ne i luoghi di lavoro. Prime indicazioni applicative 
Czech Republic 
The relevant Czech legislation is: 
Nařízení vlády č. 1/2008 Sb., o ochran ě zdraví před neionizujícím zá řením 
Legal act: Na řízení vlády , number: 1/2008 ; Official Jo urnal: Sbirka Zakonu CR , Publication 
date: 09/01/2008 
There is no English translation avai lable. It appears to be very cl ose to a direct implementation of 
the ICNIRP guidelines. 
Slovakia 
The relevant Slovaki an legislation is: 
Nariadenie vlády Slovenskej republiky č. 329/2006 Z. z. o minimálnych zdravotných a 
bezpečnostných požiadavkách na ochranu zamestnancov pred rizikami súvi siacimi s expozíciou 
elektromagnetickému po ľu 
 
EN 58   EN Legal act: nariadenie , number: 329/2006 ; Official Journal: Zbie rka zákonov SR , number: 113 , 
Publication date: 31/05/2006 , Entry into force: 01/06/2006.  
There is no English translation av ailable. It appears to be based on the EMF directive, but with 
considerably more background information. 
The official European Commission information on the implementation status of Directive 
2004/40/EC does not provide all av ailable information. To supplement this, information was 
gathered using questionnaires sent to EU memb er states' regulators in  2007-2008 Directive, and 
then updated. This information is provided in the tables below. 
 
EN 59   EN Current status in each country regarding EMF Directive 2004/40/EC? 
AUSTRIA Transposition process finalized. Entry into force postponed until 30/4/2012 
BELGIUM Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 
BULGARIA Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 
CYPRUS Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 
CZECH REP. Transposition process finalized. Entry into force postponed until 30/4/2012 
DENMARK No additional information. On ice. 
ESTONIA Transposition process finalized. Entry into force postponed until 30/4/2012 
FINLAND The tripartite standing committee ha s drafted a Decree, but  they are waiting 
for additional information as regards medical MRI technology. On ice. 
FRANCE The process of implementation, in pr ogress, has been stopped due to the claim 
of Radiologists. On ice. 
GERMANY Implementation will be executed by means of an Ordinance. A Draft 
Ordinance is prepared by th e Federal Ministry at presen t, so that the Directive 
can be implemented whenever required. 
GREECE No additional information. On ice. 
HUNGARY No additional information. 
IRELAND The first draft of th e transposed Regulations has been prepared. On ice. 
ITALY The frame of a specific regulati on on MR diagnostic equipment, mostly 
addressed to the protection of the patien t, limits of exposure to magnetic static 
field for diagnostic MR workers are defi ned, similar to what established in 
ICNIRP guidelines of 1994. It is also  established that SAR levels on the 
workers must not exceed the value give n for the patient (that may reach 4 
W/kg). 
NB: this is exceeding the lim its of Directive 2004/40/EC 
LATVIA EU directive 2004/40/EC is already transposed in Cabinet Regulation No.745 
“Labour Protection Requirements for the Protection of Workers from the Risk 
Arising from the Electromagnetic Field in the Work Environment” (Adopted 
5, September 2006), will come into force whenever required. 
 
EN 60   EN LITHUANIA Regulations on pr otection of workers from the risks arising from 
electromagnetic fields approved by the orde r of minister of social security and 
labour No. A1-119 of April 25, 2006. The regulations will come into force 
whenever required.  
LUXEMBOURG No additional information. On ice. 
MALTA No additional information. On ice. 
NETHERLANDS Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 
POLAND Regulation of the Minister of Labour and Social Policy, concerning 
permissible occupational EMF (and othe r environmental ambient factors) 
exposure, Journal of Laws  217/2002, item 1833 (in Polish). 
In addition, more than 10 regulations and se veral standards related to OSH practice (e.g. 
related to the Framework Directive provisions) 
PORTUGAL No additional information. On ice. 
ROMANIA No additional information. On ice. 
SLOVAKIA Order on the minimum health and sa fety requirements regarding the exposure 
of workers to the EMF of Slovak Re p. NO. 328/2006 Coll. in force from 
1.6.2006. Delayed.  
SLOVENIA Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 
SPAIN The technical stage of the project has been completed. Legal tasks are being 
managed on the basis of the technical reports issued by the National Institute 
of Safety and Hygiene at Work. On ice. 
SWEDEN On ice. 
UK Working with key stakeholders with  the aim of completing a detailed 
understanding of the impact of the direc tive, which will enable us to develop 
practical solutions and regulations to  implement the directive. On ice 
 
 
EN 61   EN Existing National legislation/ recommendation/standard dealing with the minimum health and 
safety requirements regarding the exposure of workers to the risks arising from 
electromagnetic fields  (independently of Directive 2004/40/EC. 
AUSTRIA Standards. 
BELGIUM No. 
BULGARIA Ordinance No. 7/Government al News No.88/1999 for the minimal 
requirements for healthy and safety work conditions; Bulgarian national 
standard (BNS) 14525-90.  
CYPRUS No. 
CZECH REP. The national Government Orde r No. 480/2000 Coll., available in Czech 
language on the website. 
DENMARK No 
ESTONIA Government decree no 54 (25.01.2 002) “Occupational ex posure limits and 
measurement of physical risk  factors” in Estonian 
https://www.riigiteataja. ee/ert/act.jsp?id=12823094  
FINLAND A decree on high fre quency equipment available in Finnish and Swedish. 
FRANCE No. 
GERMANY The accident prevention regulation BGV B11 "Electromagnetic Fields" with 
the additional BG Regulations BGR B 11 have been released in 2001; BGV 
B11 at http://www.bgfe.de/bilder/pdf/bgv_b11_a03-2002.pdf  and the BGR B11 at 
http://www.bgfe.de/bilder/ pdf/bgr_b11_a06-2006.pdf  . 
GREECE No 
HUNGARY No. 
IRELAND No. 
ITALY The national railway company Trenitalia published two standards (low and 
high frequencies) on EMF measuremen ts on trains, both for workers and 
general public. 
LATVIA Cabinet Regulation No.745 “La bour Protection Requirements for the 
Protection of Workers from the Risk Arising from the Electromagnetic Field in the Work Environment” in English http://www.osha.lv/legislation/index.stm.  
 
EN 62   EN LITHUANIA Lithuanian hygiene norm HN  110:2001 “Industrial frequency (50Hz) 
electromagnetic field in the working place. Permissible values of the parameters and measuring require ments” and labour No. 660/174 of 
December 21, 2001 in Lithuanian. L ithuanian hygiene norm HN 80:2000 
“Electromagnetic field in the work ing places and living environment. 
Permissible values of the parameters and measuring requirements in 10 kHz-
300 GHz zone” approved by the order of mi nister of health and No. 361 of 
June 27, 2000 in Lithuanian. 
LUXEMBOURG ITM-CL 179.4 - pub lic document, only available in French la nguage and the 
"RECOMMANDATION DU CONSEIL du 12 juillet 1999 relative à la 
limitation de l’exposition du public aux champs électromagnétiques (de 0 Hz à 300 GHz)". 
MALTA No 
NETHERLANDS Regulation on elec tromagnetic fields in Arti cle 6.12 of the “Arbobesluit”. 
POLAND Polish Standard PN-T-06580:2002. La bour protection in electromagnetic 
fields and radiation of the frequency range from 0 Hz to 300 GHz. Part 1: 
Terminology. Part 3. Methods of measur ement and evaluation of the field on 
the work stands (in Polish).  
Regulation of the Minister of La bour and Social Policy, concerning 
permissible occupational EMF (and ot her environmental ambient factors) 
exposure, Journal of Laws  217/2002, item 1833 (in Polish). 
Additional regulations related to pregnant workers and to young workers' exposure 
PORTUGAL No 
ROMANIA No 
SLOVAKIA Order of Slovak Rep. NO. 328/2006 Coll. Of Laws on the minimum health 
and safety requirements regarding the exposure of workers to the EMF (in 
force from 1.6.2006) in Slovak http://www.bozpo.sk/pub lic/legis/bozp/06_329.pdf
. 
SLOVENIA No. 
SPAIN Royal Decree 1066/2001, of September 28 (Official Journal of September 29) 
as amended by Royal Decree 424/2005, of April 15 (Official Journal of April 
29) in Spanish http://www.mtas.es/insht/legislation/RD/radiofre.htm  
SWEDEN Current ordinance covers exposure fo r electromagnetic fields in the frequency 
range 3 MHz – 300 GHz and offers prot ection against thermal effects, the 
values given corresponds to the action values in the directive. In the low frequency range SWEA has no ordi nance, only a prudent avoidance 
recommendation aimed towards magnetic  fields at power frequencies. 
 
EN 63   EN UK No specific UK legislati on relating to control of personal exposure to EMFs. 
Control is exercised through the general duties of the Health and Safety at Work etc Act 1974, the Management of  Health and Safety at Work 
Regulations 1999 and by reference to ICNIRP guidelines. http://www.hpa.org.uk/radiation/publica tions/documents_of_nrpb/abstracts/ab
sd15-2htm  
http://www.hpa.org.uk/radiation/understan d/information_sheets/icnirp_exp_g
uidelines.htm  
This is relevant to 50Hz exposures but is also used at higher frequencies, for example for MF 
and HF broadcast sites. Reports for these are published by BBC World Services in the 
European Broadcasting Union Technical Reviews 
http://www.ebu.ch/en/tec hnical/trev/trev_305-emf.pdf  and 
http://www.ebu.ch/en/techni cal/trev/trev_306-emf_hf.pdf  . 
 
EN 64   EN Annex 3  
Details on the new exposure limitation system proposed for option B and option C1 (except 
for MRI) 
Option B and C1 introduce new and more practical  exposure limits but also a more practical 
concept:  
• The system distinguishes between  the lower frequency range (0 to 100.000 Hz or 100 kHz) and 
for the higher frequency range (100 kHz to 300 GHz) because the effects on the human body are 
different. 
• For the lower frequencies, options B and C1 introduce a new system ("zoning" or "layer" 
system) based on the revised recommendations. A firs t, simple, risk evaluation must enable the 
employer to position worker’s exposure in zone 1 (relatively low exposure) or in zone 2 (higher 
exposure). If the result indicates that the exposure  is in zone 2 an a dditional detailed risk 
assessment is needed. The kind and extend of the protective/preventive measures to be put in 
place will be a consequence of the outcome. The low range is actually the range where most of 
the compliance problems exist. Important sector s/activities such as el ectricity production and 
distribution, welding, industrial electrolysis, some i nduction heating systems, and also MRI are 
concerned. 
• In line with the unchanged sc ientific recommendations, the lim it values for higher frequencies 
remain as defined in Dir. 2004/40/EC. 
When a worker is likely to be exposed to EM F under the current direct ive 2004/40/EC regime, an 
employer has to measure the existing electric and/ or magnetic fields at the workplace. If the 
result(s) is (are) under the (frequenc y dependent) level of the so-called action value , no further 
action is required. If th e measurement exceeds the action value , then the employer has to investigate 
and has to ensure by appropriate but rather complicated means that the actual exposure limit value  
has not been exceeded. This is a cumbersome activ ity and requires specific calculation techniques 
based on experimental models. Th ere is no alternativ e and, as an additiona l complication, the 
current exposure limit values are expresse d in non directly measurable variables. 
It is important to note  that in the "old" system adopted under Directive 2004/40/EC  on the basis of 
the 1998 ICNIRP recommendations as well as in  the new system based on ICNIRP 2010 and BMAs 
values the establishment of the exposure limit valu es are derived from the same "risk or hazard 
threshold" value above which all scientists recognize that there are direct effects. However, in order 
to take into account experimental errors, consequences of extrapolation from research on animals, 
differences between human groups (kids, elderly people), a safety factor has been introduced 
between the "risk or hazard threshold" and the actua l exposure limit. This factor is 10 for workers in 
ICNIRP system. BMAs however cons iders that there is sufficient scientific evidence to be less 
conservative and the safety factor is only  10. According to BMAs authors this reduced factor 
reflects the improved knowledge in electrophys iology, biological diversity, modelling and 
measurement in the low frequency range. This appr oach can be considered as safe for workers. 
In the new proposed system, the unique  and directly measurable value ( action value ) will be 
replaced in the low frequency rang e by a set of two values, a lower one  (end of zone 1) and a higher 
one (end of zone 2). No sophisticated evaluation means will be necessary if  an activity located in 
Zone 1 or Zone 2. Only the preventive measures  will be different (more intensive in Zone 2). 
 
EN 65   EN The revised scientific recommendations allow to set the upper level of zone 2 significantly higher 
than the previous action value  for most frequencies so that de facto , many actors who found 
themselves to be exceeding the former action value  and were obliged to go for the extensive 
compliance check will now be in zone 2, i.e. under the upper level referred to above. 
With this new system, it is expected that only a li mited number of activities may need to go for the 
detailed compliance check. From recent informati on received from Dutch experts, only some MRI 
procedures and some induction heat ing installations woul d still be concerned. Some work areas in 
the electrolysis sector may also be affected. 
In order to illustrate the principles la id down above, the figures hereunder show: 
Figure 1: the old and new reference values for exposure to an electric field : 
 
In blue:  the figure shows the current action values  for each frequency for electric fields. For any 
situation where the ac tual exposure level is  higher than this action value , a comprehensive and 
rather complex compliance check has to be carried out. 
In green:  the proposed upper level of "zone 1": this sepa ration is intended to classify some activities 
in the so-called "zone 1". The positive consequences will be that for those activities exposing workers under that level (guidance will be in an annex to the directive), no further action will be 
needed beyond clear signalisation (necessary to a void access to special groups with implants or 
pregnant women for instance) and simple information to workers. 
In red:
 upper level of "zone 2" : if an activity cannot be classifi ed in zone 1, verification (simple 
measurements) will be required to  compare with this upper level.  Preventive measures and more 
extensive training of the workers will be necessa ry. Guidance will be given in the directive. 
In the few cases still exceeding this upper level, th e situation will be simila r to the situation under 
Directive 2004/40/EC. Exposure limits will however be  expressed in more accessible variables (see 
figure 3). The differences between the old action values  and the new values are of a factor of 5 or 
more, while for other frequencies, i.e. very lo w frequencies, the limit values remain untouched. 
 
EN 66   EN Figure 2: the old and new reference value s for the B (magnetic)-field (in µT) : 
 
The same principles as for th e electric fiel ds will apply. 
The current action values  are in blue: in the past, every s ituation above that line required a 
comprehensive verification towards the actual limit values (see Figure 3). With the new system, all measured fields under the red line guarantee complia nce with the exposure limits. Again, one can 
notice significant improvements (relaxation) for some  frequencies. Moreover, for situations for 
which the exposure level is in zone 1, the comp liance will be limited to very simple measures. 
Guidance will be given in the directive. 
 
EN 67   EN Figure 3: new exposure limit values (ELVs): 
 
For the remaining situations, whenever the upper level of zone 2 is exceeded, a more 
comprehensive evaluation will have to be carried out (via modelling etc.). The results, expressed in "in situ" or "in body" induced elect ric fields, will have to be comp ared to the new exposure limit 
values of figure 3. Those ELVs are expressed in different units as th e current ones and must not be 
exceeded. To enable the comparison between th e actually measured level and the limit value 
specific calculations and modelling ar e required based on published models. 
The exposure limit values proposed by BMAS and ICNI RP only differ by the choice of a different 
safety factor. The system would favour the use of  slightly higher BMAS values (ICNIRP values 
times the square root of 3) to be consistent wi th the choice of the upper level 2 (see fig. 1 & 2) 
derived from the BMAS approach. 
 
EN 68   EN Examples of situations likely to be  in Zone 1(from different sources)  
For these cases, either nothing (offices) or a simple signalisation on the equipment or in the 
immediate vicinity should be sufficient. 
Working environments for which it can be assumed a priori that the level 1 will not be exceeded 
are: 
• offices (incl. computer equipment, cable netw orks, radio communication equipment; exc. tape 
erasers) 
• hand-held motor-operate d electric tools  
• transportable motor operated electric tools (inc l. electrically operated garden appliances) 
• household and similar electrical appl iances (incl. mobile equipmen t fitted with heating elements; 
battery chargers; heaters; vacuum cleaners fo r dirt and water; cookers, ovens and cooking 
elements for industrial and commercial use; he ating elements for wate rbeds; microwave ovens 
for industrial and commercial use) 
• electrical installations: 
– low voltage network < 1000 V 
– low voltage components with power less than 200 kVA  
– workplaces at min. 60 cm distance from low voltage components with power not 
exceeding 1000 kVA  
– power transformers connected to low vo ltage networks (<1000 V between phases) 
with power up to 200 kVA  
– workplaces at min. 60 cm from power tr ansformers connected to low voltage 
networks (< 1000 V between phases) with power not higher than 1000 kVA 
• electric motors and electric pumps, subject to 
– the power being lower than 200 kVA  
– the workplace being at least 60 cm dist ance and the power not exceeding 1000 kVA 
• testing instruments (exc. non-de structive magnetic testing)  
• installation and maintenance  
– electrical hand-held tools (exc. welding equipment)  
• detection of articles and people  
– RFID 1 Hz - 100 kHz  
• electricity production and distribution 
 
EN 69   EN – bus bars/conductor rails in substations 
– above ground high voltage cables  
– electricity substations  
– switch gear 
• induction heating  
– automated systems  
• welding  
– automated systems 
– arc welding - cable 
• medical applications  
– shallow hyperthermia  
– pain control, stimulati on of bone growth etc.  
– incubators, lamps for phototherapy, wi reless communication systems etc. 
– deep hyperthermia 
– electrosurgery 
• transport and traction systems  
– rail transport powered by direct current  
– vehicles, ships, aircraft  
– (large) electric motors  
• transport and haulage systems  
– rail transport powered by alte rnating current (50 Hz; HSLs)  
• detection of articles and people 
– EAS 0.01 - 20 kHz (magnetic) 
– EAS 20 - 100 kHz (resonant inductive) 
– metal detectors 
• dielectric heating 
• electricity production and distribution 
 
EN 70   EN • electrochemical processes (except specific places) 
• induction heating  
• research applications  
• Other working environments 
– induction hobs in hotel & cateri ng industry (food preparation) 
– tape erasers 
Example of situations li kely to be in Zone 2  
For these cases, a clear signalisation and clear markings (or fences, guardrails, as appropriate) 
must be foreseen for delimitation. Simple measuremen ts should also be made with a simple but well 
functioning device (measurement uncer tainties do not play a role he re). Specific training should be 
given to workers and foremen. 
– plastic sealers  
– wood gluing equipment  
– power stations 
– air cooled coils in capacitor banks 
– current supply systems (bus bars) 
– electrolysis hall (parts of) 
– larger furnaces 
– arc welding – cable 
– MRI – during scanning 
– use of - ‘open magnetron’ 
– non-destructive magnetic testing  
Examples of situations likely to  exceed the upper level of Zone 2  
For these cases, extensive and precise measurem ents have to be carried out for compliance 
verification with th e exposure limits. Grids, fences or su fficient distance mu st guarantee avoidance 
of overexposure. Specific training shou ld be given for workers and foremen. 
• trouble shooting during inst allation and maintenance 
• proximity of rectifiers in  electrochemical processes 
• induction heating (small melting furnaces) 
• semi-automated spot and induction welding 
 
EN 71   EN • MRI (static and gradient fields) 
 
EN 72   EN Annex 4  
Case studies to determine compliance costs 
Note: these case studies are based on the surveys  made by the FICETTI contractors in 2009. 
Figures have been modified on the basis of bette r information received since from stakeholders 
themselves and experts. Corrections  have been introduced in the costs calculations made by 
FICETTI. 
The aim of the case studies is to look at a comp any in a specific sector and try to quantify the 
impact of each policy option on that company in terms of compliance costs. The assessment of the 
impacts requires an interpretation of exactly what that company would have to do under each 
option. For the purpose of these ca se studies it was assumed by FICETTI that the assessments 
follow the general procedure set in the European  Standard EN50499 on the assessment of workers' 
exposure to electric, magnetic and electromagnetic fields at the workplace. The compliance costs 
include also where necessary the cost of intro ducing the protection contro ls (procedures and/or 
hardware). 
The case studies were conducted in UK, Finland and Poland.  
The case studies have been made for the fo llowing types of workplaces and equipment: 
(1) Electricity generati on and transmission 
(2) Electric welding 
(3) Induction heating 
(4) Surgical diathermy 
(5) RF sealers 
(6) Broadcasting 
(7) MRI 
The case studies were conducted in small and me dium enterprises. The compliance cost per 
establishment obtained in these case studies is used  as the unit cost for the calculation of costs per 
sector in Annex 5. 
 
EN 73   EN 1. Case study: Electricity generation and transmission 
• Present situation 
The electricity generation and transmission i ndustry already effectively works to ICNIRP 
occupational EMF limits for both electric and magnetic field at 50 Hz. 
• Policy options impact 
Policy Option A 
There may be some compliance issues, but th ese are problems that should already be 
addressed under the requirements  of the Framework Directive. 
Policy Option B 
The impact of this policy op tion depends on the new limits. If the existing Action Values 
are changed to be more in line with Exposure Limit Values for electr ic fields, this could 
also reduce impact. As can be seen from figure I in annex 3, it is foreseen to have a slight 
relaxation at 50Hz. 
Policy Option C 
C1 would be acceptable as it is similar to the current situation. C2 would be a problem as 
arbitrary exemptions are not acceptable to workers of this sector. Costs would be 
unchanged. 
Policy Option D 
The costs would be the same as other options, but there is concern about the validity of 
sector-specific negotiated outcomes. 
Policy Option E 
Because the electricity industr y already complies with ICNIRP guidelines, the costs for 
this option would be as A. However, there is concern that de facto national limits might be 
imposed if no pan-European legislative framework is developed. 
It is estimated that for the UK, the effort involved in occupational EMF compliance for the 
electricity generation and transmission industrie s requires approximately  2 persons with an 
average cost of 1250 €. 
Extending this to all EU countries with  an estimated number of 3000 concerned 
workplaces, the approximate costs would be 3.75M Euros. This does not change with 
baseline or with policy option, as  this sector will continue to  comply with ICNIRP values: 
Option Cost per workplace 
(Euros) 
A 1250 
B 1250 
 
EN 74   EN C1 1250 
C2 1250 
D1 1250 
D2 1250 
E 1250 
• Summary 
Electricity generation and transmi ssion is effectively at Option A. There is likely to be very 
little cost difference across the various polic y options, but the indus try as a whole would 
prefer Option C1. Options D and E we re rejected in the consultations. 
 
EN 75   EN 2. Case study: Electric Welding 
The survey was conducted in a medium-sized company in UK with between 100 and 200 
employees. Good health and safety strategy we re in place and implemented, with a health 
and safety officer/small team in place, t hough not full-time – they have other duties. 
• Present situation 
The UK Government in 2000 accepted the use of  ICNIRP EMF guidelines, to replace the 
earlier single-tier NRPB guide lines. NRPB aligned its ow n advice on EMF exposure with 
ICNIRP in 2004. On those bases, the best available scientific advices, and stated 
government policy, are both to use ICNIRP guidelines. 
HSE itself , as part of its response to the FICETTI  questionnaire, stated that the UK position 
was: 
"The HSE believes that this current syst em of regulations based on the Framework 
Directive, referencing the ICNIRP recomme ndations coupled with EMF guidance provide 
a satisfactory, proportionate system for contro lling occupational exposure to EMF risks". 
The authors of this case study visited HSE on 25th March 2009 to elucidate this matter 
further, and were informed that: 
"HSE's approach is to use the I CNIRP basic restrictions not as  an actual restriction, but as 
a starting point for exploring risk in more de tail. The ALARP principle should be followed, 
and erosion of ICNIRP safety factors can be  appropriate, if indica ted by discretion and 
judgement." 
From the interviews carried out by FICETTI, it appears that very fe w employers in the UK 
are aware of the HSE position; the authors of this case study have been very involved in 
occupational EMF assessment in the UK for ma ny years, and have ne ver seen it stated 
explicitly. Indeed, it is the experience of the authors that most companies (and probably 
almost all companies in the SME sector) have li ttle-to-no awareness at all of EMF issues or 
any conception that any of thei r activities might be associated  with any sort of EMF risk. 
In practice, the regulatory situ ation in the UK for SMEs may be close to Policy Option E, 
with any investigation of EMF risk only likel y to be triggered after worker concern has 
been expressed. Several larger enterprises have chosen to be more proactive and have 
voluntarily chosen to ensure that their employees' EMF expos ures are below the ICNIRP 
basic restrictions (equivalent to the Expos ure Limit Values of the EMF Directive).  
Application of EMF Directive implementation framework 
Welding companies have equipment which is  beyond the a priori compliant workplaces 
and equipment listed in Table 1 of the European Standard  EN50499. This means that an 
EMF assessment will be needed. Despite the requirements for equipment labelling contained in the Machinery Directive, littl e or no welding equipm ent currently on the 
market and designed for professional use is supplied with emission /exposure information. 
The CENELEC welding standards require th at a manufacturer shows compliance with 
general public exposure limits, bu t in general this is not equipment used in welding 
companies. 
 
EN 76   EN In the absence of manufacturers' information welding companies will need to make EMF 
exposure assessments. It is a feature of weld ing equipment that the high magnetic fields 
that they generate are localised to the regions close to the cables and welding arc so that there is no real need to cons ider the contributions of other equipment to exposure. This 
makes the assessment comparatively easy. 
Expertise and costs 
Very few welding companies have existing in-house expertise in the assessment of 
workers’ exposure to electromagnetic fields. Th e main factors that would allow them to 
develop this expertise are: 
– Resources (willingness of manageme nt to invest in the issue) 
– Technical knowledge about processes and equipment 
– Existing health and safety infrastructure 
– Familiarity with measurement of other agents, such as noise 
– Willingness to consider a new “problem” 
– Acceptance that an assessment may identif y situations where remedial action is 
needed. 
It is possible that companies c ould invest the time a nd effort to develop this expertise, and 
if they chose to do so then the cost would likely be abou t ten person-days. The average 
wage for the sort of person who might be char ged with this task (from the employer's side) 
is estimated at around 25k Euros per year (techni cian or recent graduate). Allowing 50% 
overhead, and 230 days at work per year, this is equivalent to approximately 1630 Euros. 
In addition to this is the cost of buying (or hiring) measurement equipment. The purchase of a suitable meter would cost approximately 4000 Euros; to hire one for four days might 
cost 500 Euros. 
A measurement programme w ould probably trigger questi ons from employees about 
possible effects on health, and even questions about related i ssues such as mobile phones 
and overhead power lines. An exposure asse ssment programme woul d probably have to 
include the provision of author itative health information to employees. It would be 
necessary to maintain up-to-date knowledge about the current scientific consensus in order to do this. There are very useful websites, su ch as those of the World Health Organisation, 
which are updated regularly and which provide ra pid responses to particular media stories. 
However, it would require some effort to keep up-to-date, and this may prove to be a significant burden for a small-to-medium enterprise, or for a small health and safety team within a bigger organisation. 
The alternative would be to rely on external expe rtise; the cost of a competent consultant is 
likely to be approximately 1500 Euros per day on  site, and the work could be done in one 
day. The in-house actions to perform the measurement woul d include the cost of buying 
and maintaining a magnetic field meter (ca libration costs are likely to be higher than 
purchase cost over time) and th e cost of preparation of staff to conduct measurements. 
• Policy options impact 
 
EN 77   EN Option A . Most welding machines produce exposure s complying with the requirements of 
the EMF Directive, but may need a pplication of e.g. Dimbylow approach52, or possibly 
computational modelling. There is no real ne ed for frequent monitoring unless the job 
changes – certainly not more frequently than  yearly. The cost would be 1500 Euros for an 
external expert, plus perhaps 2 days' in-hous e activity to setup/manage the assessment and 
disseminate the information. The average wa ge for the sort of person who might be 
charged with this task (from the employer's si de) is perhaps 25k Euro s per year (technician 
or recent graduate). Allowing 50% overhead, and 230 days at work per year, this is 
equivalent to approximately 325 Euros. The total compliance cost per establishment is 
therefore at around 1825 Euros . 
It is assumed that a competent assessment w ill show that the welders are compliant with 
the requirements of the EMF Directive, or that simple low-cost measures (such as telling workers to not sit on cables) will be sufficient to demonstrate compliance. 
There is not likely to be any impact on gender equality for welding; the existing hazards 
are such that any concerns about pregna ncy outcome/effects on pregnant women will 
already be addressed by a reasonable employer. 
The Directive requires an assessment of possible impact on AIMD
53 users, and there may 
be a cost associated with this assessment if there are any AIMD users in the workforce. It is very difficult to compare this cost with  the situation with no EMF Directive; it is 
possible that the analysis would be cheaper under Option A than E because of the implementation framework (including CENE LEC standards) that accompanies the 
Directive, and which should allow more focuse d and straightforward determination of any 
measures needed to restrict exposures of AIMD  wearers. However, for the purposes of this 
case study this aspect is not considered further. 
Option B  has the same requirements as option A, but with different limits. The introduced 
guidance might allow in-house asse ssment if Actions Values we re closer to ELVs, but in 
practice it may be cheaper to use an external  expert and the costs will be as option A. 
Considering that 70% of the employers would continue to hire exte rnal expertise (1825€) 
and 30% would take advantage of in house e xpertise (325€), the average sectoral costs 
would be: 1375€ . 
Options C1 and C2  are effectively the same as option B. 
Option D1  is the same as B; the Framework Dir ective already requires a risk assessment 
that includes EMF; and if the exposure guidelines are based on the same limits as B then the costs would be the same: 1375€  
Option D2  Without knowing what these sectoral agreements would say, it's not possible to 
easily cost this option. Assuming th at it will require some assessm ent, it is likely to require 
measurements anyway. So it woul d be equivalent to Option B: 1375€  
Option E This requires EMF to be considered as  part of a general risk assessment under 
the Framework Directive. Without exposure li mits, companies will us e national exposure 
guidelines – in the UK this is the advice of HPA, which is equivalent to ICNIRP 
occupational guidelines but used as a starting point for risk management. In practice there 
                                                
 
52 Explain in footnote 
53 AIMD - Active Implantable Medical Devices 
 
EN 78   EN is no advice on how to do ri sk assessment beyond the use of these guidelines and a welding 
company would need to seek outside help. In this respect it's probably more costly than 
option B if done properly. For the purposes of th is case study it is costed as the same as 
option B. 
Option Cost per establishment 
(Euros) 
A 1825 
B 1375 
C1 1375 
C2 1375 
D1 1375 
D2 1375 
E 1375 
• Summary 
• Electric welding is a technology that falls within Table 2 of EN50499 and normally in 
zone 2 (annex 3). An EMF assessment will be needed. 
• There is little to no manufacturer's information available. 
• The welders can be treated as isolated sources  in most situations – there is no need to 
consider summed exposures. 
• Options A-C provide a specific system (including CENELEC standards) for the 
assessment of exposure of workers with AIMDs that would not be provided by Options 
D and E. 
 
EN 79   EN 3. Case study: Induction heating 
The survey was conducted in a small company in UK with between 10 and 20 employees. 
Basic health and safety strategy was in place and implemented on an ad hoc  basis. No 
OHS officer/team in place. 
• Present situation 
The UK Government in 2000 accep ted the use of ICNIRP EMF guidelines, to replace the 
earlier single-tier NRPB guide lines. NRPB aligned its own advice on EMF exposure with 
ICNIRP in 2004. On those bases, the best available scientific advices, and stated 
government policy, are both to use ICNIRP guidelines. 
In practice, the regulatory si tuation in the UK for SMEs seems close to Policy Option E, 
with any investigation of EMF risk only likel y to be triggered after worker concern has 
been expressed. Several larger enterprises have chosen to be more proactive and have 
voluntarily chosen to ensure that their employees' EMF expos ures are below the ICNIRP 
basic restrictions (equivalent to the Expos ure Limit Values of the EMF Directive).  
Application of EMF Directive implementation framework 
Induction heating companies have equipmen t which may overpose workers working too 
closely to the furnace. This means that an  EMF assessment will be needed. Induction 
heating equipment is usually specialised, and often unique in its configuration. There will 
be little or no emission/exposure informati on supplied by the manufacturer, and induction 
heating companies will need to make EMF exposure assessments.  
Expertise and costs 
Very few induction heating companies have ex isting in-house expertis e in the assessment 
of workers’ exposure to electromagnetic fiel ds. The main contributors that would allow 
them to develop this expertise are: 
• Resource (willingness of management  to invest in the issue) 
• Technical knowledge about processes and equipment 
• Existing health and safety infrastructure 
• Familiarity with measurement of other agents, such as noise 
• Willingness to consider a new “problem” 
• Acceptance that an assessment may identify si tuations where remedial action is needed. 
It is possible that companies c ould invest the time a nd effort to develop this expertise, and 
if they chose to do so then the cost would likely be abou t ten person-days. The average 
wage for the sort of person who might be char ged with this task (from the employer's side) 
is perhaps 25k Euros per year (technician or  recent graduate). A llowing 50% overhead, and 
230 days at work per year, this is equivalent  to approximately 1575 Euros. In addition to 
this is the cost of buying (or hiring) measur ement equipment. To buy a suitable meter 
would be approximately 4000 Euro s; to hire one for four days might cost 500 Euros. 
 
EN 80   EN A measurement programme w ould probably trigger questi ons from employees about 
possible effects on health, and even questions about related i ssues such as mobile phones 
and overhead power lines. An exposure asse ssment programme woul d probably have to 
include the provision of author itative health information to employees. It would be 
necessary to maintain up-to-date knowledge about the current scientific consensus in order to do this. There are very useful websites, su ch as those of the World Health Organisation, 
which are updated regularly and which provide ra pid responses to particular media stories. 
However, it would require some effort to keep up-to-date, and this may prove to be a significant burden for a small-to-medium enterprise, or for a small health and safety team within a bigger organisation. 
The alternative would be to rely on external expe rtise; the cost of a competent consultant is 
likely to be approximately 1500 Euros per day on  site, and the work could be done in one 
day. Balanced against this is  the cost of buying and main taining a magnetic field meter 
(calibration costs are likely to be  higher than purchase cost over time) and the cost of staff 
development.  
• Policy options impact 
Option A Many induction heating machines produce exposures which do not comply with 
the requirements of the EMF Directive and any assessment is likely to lead to measures having to be taken to reduce exposure by changing working practices. The cost of 
assessment would be 1500 Euros for an extern al expert, plus perhaps 2 days' in-house 
activity to setup/manage the assessment and disseminate the information. The average wage for the sort of person who might be char ged with this task (from the employer's side) 
is perhaps 25k Euros per year (technician or  recent graduate). A llowing 50% overhead, and 
230 days at work per year, this is equivalent  to approximately 325 Euros. Total estimate 
(step 1): 1825€ 
There is very little that can be done to moderate exposures from induction heating 
equipment except change in working practi ce, which might include zoning. Practically, 
shielding is not effective fo r most induction heaters, thou gh there my some benefit for 
higher frequency (100 kHz and upwards) machin es that are physically small and are not 
already shielded. 
It is assumed that changes in working practic e would be successful in reducing exposures 
to below the ELVs of the EMF Directive 2004/40/ EC. It is estimated that determination 
and implementation of such measures would requ ire an external consu ltant for one day, at 
a cost of 1500 Euros (to determine and advise  on necessary changes in working practice 
and to define areas to which access might need  to be controlled). There would be an 
additional cost to the enterprise in implemen ting changes to working practices and zoning; 
this is estimated at 115 Euros of employee time (one day) and 75 Euros for signage and minor changes to the workplace; if barriers to control access were needed then the cost of 
these would be approximately 500 Euros. Total es timate (step 2): 2190€ . 
The total compliance cost including the meas urement of EMF by exte rnal expert and the 
following in-house and external expertise invo lved in ensuring the compliance as regards 
the protection controls for Option A would then be 4015 Euros  (1500 + 325 + 1500 + 115 
+ 75 + 500 = 4015 Euros). This is of course  a “worst-case average” estimate; some 
induction heating companies will require no or few measures to moderate exposures; some 
may require significant physical  changes to the workplace. 
 
EN 81   EN The Directive requires an assessment of possi ble impact on AIMD user s, and there may be 
a cost associated with this assessment if ther e are any AIMD users in the workforce. It is 
very difficult to compare this cost with the situation with no EMF Directive; it is possible 
that the analysis would be cheaper under Opti on A than E because of the implementation 
framework (including CENELEC standards) that accompanie s the Directive, and which 
should allow more focused and straightforward determination of any measures needed to 
restrict exposures of AIMD wearers. Howeve r, for the purposes of this case study this 
aspect is not considered further. 
Option B  has the same requirements as option A, but with different limits. It might allow 
in-house assessment if AVs were closer to ELVs , but in practice it will be cheaper to use 
an external expert and the assessment costs will be as Option A. It is likely though that the results of assessment would indicate that  compliance problems would be much less 
widespread with this option because the i nduction heating frequencies that are most 
problematic are those where revised actio n values would allow higher exposures. 
Therefore the cost has been estimated at 2680€ , considering that 50% of the companies 
would hire external expertise (4015€) and the other 50% would decide for internal 
solutions (325+325+690 for implementing measures = 1340€). 
Options C1 and C2  is effectively the same as B for these companies because most 
induction heating companies are unabl e to determine risk themselves: 2680€   
Option D1  is the same as B; the Framework Dir ective already requires a risk assessment 
that includes EMF; and if the exposure guidelines are based on the same limits as B then the costs would be the same. 
Option D2  Without knowing what these sectoral ag reements would say, it is not possible 
to easily cost this option. Assuming that it will require some assessment it is likely to require measurements anyway. So it would be equivalent to Option B. 
Option E  This requires EMF to be considered as  part of a general risk assessment under 
the Framework Directive. Without exposure li mits, companies will us e national exposure 
guidelines – in the UK this is the advice of HPA, which is equivalent to ICNIRP 
occupational guidelines but used as a starting point for risk management. In practice there 
is no advice on how to do risk assessment beyond the use of these guidelines and an 
induction heating company would need to seek outside help. In this respect it's probably 
more costly than option B if done properly. For the purposes of this case study it is costed 
as the same as option B. 
Option Cost per 
establishment 
(Euros) 
A 4015 
B 2680 
C1 2680 
C2 2680 
D1 2680 
 
EN 82   EN D2 2680 
E 2680 
• Summary 
• Induction heating is a technology that falls within Table 2 "Equipment likely to require 
further assessment" of EN50499. Exposure ma y exceed the zone 2 upper level (annex 
3). An EMF assessment will be needed. 
• Exposures are likely to exceed the ELVs, and remedial measures such as guardrails and 
changes to working practices  will probably be needed. 
• Options A-C provide a specific system (including CENELEC standards) for the 
assessment of exposure of workers with AIMDs that would not be provided by Options 
D and E. 
 
EN 83   EN 4. Case study: Surgical diathermy 
The presented case study concerns estimation of  the impact of the defined policy options 
on the use of electrosurgical units in the me dical care enterprises,  based on the current 
situation in Poland. 
There are approx. 2500 electrosurgic al devices used in Polish hospitals (operating theatres, 
surgery rooms) and health centres – in about 1000 establishments in total. The number of devices in one establishment usually ranges be tween 1 and 15. In the la rgest hospitals even 
30-40 units are used. 
The surgeon is the most exposed person from th e health care staff. Th e number of surgeons 
operating these devices in Poland can be estimated at 7500-10000, assuming that one device can be used by 3-4 doctors. 
The total number of workers exposed to elec tromagnetic fields produ ced by electrosurgical 
units can be higher (approx. 15000-20000) when nurses, operating-theatre attendants, 
anaesthesiologists are included. 
Case study was made on the base of 3 vi sits in health care establishments.  
• Present situation 
In Poland the Framework Directive 89/391/EEC is fully implemented. It means that all 
risks in the working environmen t (including those related to el ectromagnetic fields - EMF) 
should be identified and eliminated or appropr iately limited. All requirements concerning 
detailed obligations for employers (systematic risk assessment, prevention of occupational 
risks and provision of information, training and education, medical surveillance) are 
justified by the provisions of general legisl ation called the Labour Code and others law 
regulations. 
Poland has national mandatory legislation concerning occupatio nal exposure to EMF 
(dated 1977 for frequency range 100 kHz – 300 MHz, covering EMF frequency produced 
by electrosurgical devices). Th e current regulation concerning the exposure limitations for 
EMF for the 0 Hz - 300 GHz frequency range wa s worked out in 1999 (recently issued by 
PL Journal of Laws 217/2002, it em 1833). Separate occupationa l safety regulations have 
been also established regarding the obligatio n to carry out periodical testing of EMF 
existing in the working environment. Regu lations are periodically revised and, if 
necessary, updated under the umbrella of the Interdepartmental Commission for Maximum Admissible Concentrations and Intensities for Agents Harmful to Health in the Working 
Environment, which is the scientific adviso ry body established by th e Prime Minister of 
the Polish government. The last draft amendm ents concerned implementation of exposure 
limitation specified in the Dire ctive 2004/40/EC into Polish la w to reach full compliance of 
national regulations with Directive in this scope.  
Special attention was paid to pregnant woman and young workers (b elow 18 years old). 
The thresholds of permissible occupational exposure for them were established as non-
occupational exposure limits only (sim ilarly to general public exposure). 
According to national legislation, workers e xposed to EMF are under medical surveillance 
with special focus on the cardiovascular and neurological func tions. The medical 
 
EN 84   EN examination is repeated periodically for ev ery 4 years. The ultimate decision about scope 
and frequency of surveillance is made by a physician. 
Electrosurgical devices are sour ces of strong electric field and they are taken into account 
during worker’s exposure and risk assessmen t (e.g. currently according to EN 50499). As a 
consequence of the long-standing EMF regulati ons concerning the electrosurgical devices 
in force the following requirements as re gards the working c onditions are met:  
– workplaces are subject to occupational safety and health (OSH) periodical 
inspections (National Labour a nd Sanitary Inspectorate); 
– the equipments that are s ources of occupational expos ure have been identified 
and labelled; 
– health care staff using these devices is informed and trained (on exposure 
levels, procedures for avoiding hazards). 
The above mentioned national requirements concerning workers exposed to EMF produced 
by electrosurgical units were  effectively in place in the visited establishments. 
• Policy options impact 
Policy Option A 
The assessment of surgeons and other health  care staff (assisting physicians and nurses) 
exposure to EMF should be performed based on th e results of measurements of electric and 
magnetic fields strengths. Currently all envi ronmental factors (including EMF) can only be 
measured by testing laboratories accredited by the national accreditation body according to 
the requirements EN ISO/IEC 17025. Apart from  this and in consideration of needed 
knowledge and experience, performing the meas urements by the employer with the use of 
hired equipment is not permitted. 
Because the level of exposure depends on: se lected mode of device operation, type of 
active electrode used and location of cables co nnecting electrodes with the generator, the 
measurements should investigate the conditions  of worst case of e xposure adequate to 
typical working situations (e.g. the use the m onopolar electrode, highe st output power). It 
allows to evaluate the maximum level of  exposure and simplifies the process of 
investigation (decreasing time of measurement session and cost s). Another possibility to 
reduce the number of investigated devices and th e costs of assessment is  created by the fact 
that usually in the electrosurgical units of different types are used  in similar conditions. 
The results of measurements for on e device can be adapted for other. 
The level of EMF exposure of medical staff can be assessed with the use of directly 
measured parameters: electric field strength , magnetic field strength.  EMF exposure at the 
workplace are measured following the national legi slations and standards or in the case of 
lack of such a document, following the intern ationally published standa rds. Polish standard 
PN-T-06580:2002 that determines a protocol  for EMF measurements and workers’ 
exposure assessment is harmonized with na tional mandatory legislation concerning 
occupational exposure to EMF. 
The measurement results are the basis for the risk assessment and for appropriate technical 
and/or organisational measures for exposure mitigation. Of great est importance is to give 
 
EN 85   EN sufficient information concerning possible risks re lated to work in the direct vicinity of 
EMF sources. Information on safe work practices  is given to workers during initial (before 
employment) and periodic repe ated occupational health and safety trainings. It demands 
accessible information (e.g. from papers, guides,  internet) concerning methods of risk 
reduction and the effective use of them by employers. The reduction of the surgeon's 
exposure can be reached without special expe nses by the proper positioning of the cables 
supplying the active electrode (e.g. by avoiding ca bles being in contact with the bodies of 
workers). The exposure of other persons from th e medical staff is relatively weak if they 
do not have direct contact with the cables. Th ese methods can be used without consultant’s 
knowledge and help.  
The costs of measurements are the main costs of health care staff risk assessment arising 
from electromagnetic fields produced by elec trosurgical devices. The average cost of 
measurements for one device in Poland is approx. 80-120 Euro. Assessment of workers’ 
exposure to electromagnetic fi elds, preparing guidelines for safe work, marking the device 
can be done by the establishments themselves on the basis of the measurement results. The 
cost of these activities would likely be about two person-days in case of the use up to 10 
electrosurgical devices and proportionally higher for a greater number of units. The 
average wage for the sort of person who mi ght be charged with this task (from the 
employer's side) is perhaps 25 k Euros (12k Euros in Poland) per year. Allowing 50% 
overhead, and 230 days at work per year, this  is equivalent to approximately 325 (160) 
Euros for two days work. The total maximum cost with the measurements of 10 devices 
would be 1360 Euro (10 measurements@120€+160 for work. It is assumed that this would 
be twice this cost ( 2720€ ) when carried out in the “aver age country where the cost is 
18.75€ per hour. The costs would be similar if ex ternal expert is hired to prepare the 
assessment and guidelines of methods of safe work. 
Preparation of the risks assessment (measum rements), education, training and medical 
surveillance of workers with the reference to EMF do not impose additional costs on the 
establishments because these activities ar e conducted irrespective of the kind of 
environmental agent as a result of the implementation of Framework Directive 
89/391/EEC 
Considering the fact that elec trosurgical devices usually prod uce strong electric fields and 
in accordance with Polish regulations, employme nt of pregnant women for activities in the 
vicinity of this equipment is prohibited. One of the important benefits is that mandatory 
regulations contribute to the well-being of employees who can  feel safer if measures 
limiting their exposure are in place. 
Policy Option B 
The main approach to risk assessment mentioned above will not change. A new limit value 
can force the revision of thresholds of perm issible occupational exposure in the national 
regulations. In consequence, th eoretically it can affect the results of risk assessment, but 
practically significant changes in  this scope are not possible. 
Policy Option C 
The main approach to risk assessment me ntioned above will not change. There is no 
difference regarding the policy option C1 and C2. 
Policy Option D 
 
EN 86   EN The lack of mandatory regula tions can affect the level of  protection against EMF and 
decrease knowledge and awareness of employe rs on occupational risk related to EMF 
exposure. Though requirements of Framework Di rective 89/391/EEC will remain in force, 
it is possible that employers ma y try to avoid exposure assess ment and the use of measures 
to decrease the risk level. There is no diffe rence regarding the policy options D1 and D2. 
Policy Option E 
Poland has national regulations concerning occ upational exposure to EMF. If they remain 
in force, exposure assessment is still realized as for Policy Option A. This situation can create problems in countries in which ther e are no national regula tions. Employers should 
still comply with requirements of Framework Directive 89/391/EEC. 
For the purposes of this case study the costs fo r different policy opti ons would be similar 
(based on the situation in Pola nd, in the case of company with  10 electrosurgical devices): 
Option Cost per 
establishment – 10 
devices on average 
(Euros) 
A 2720 (1360) 
B 2720 (1360) 
C1 2720 (1360) 
C2 2720 (1360) 
D1 2720 (1360) 
D2 2720 (1360) 
E 2720 (1360) 
• Summary 
According to requirements of Framework Dir ective 89/391/EEC irrespective of any Policy 
Option the employers are obliged  to perform risk assessment related to EMF produced by 
different sources (including elec trosurgical devices). Suitable identification of anexisting 
problem is the first step. In case of electro surgical units measurements of EMF at the 
workplace are needed. It will not be possible to avoid costs for the health care companies. 
Available information for employers about meth ods of risk assessment and reduction of the 
workers’ exposure can decrease costs.  
Mandatory regulations can increas e the costs of companies but they give benefits for the 
workers (better feelin g of safety and well-being and in creasing knowledge as a result of 
training). 
 
EN 87   EN 5. Case study: RF sealers 
We assume we have a small company, hiri ng 10 people, and they are doing plastic 
welding, producing tarpaulins and lorry covers . The company has 4 RF sealers with a 
nominal frequency of 27 MHz. The company is located in Sweden. 
• Present situation 
Sweden has since 1987 had legally enforced lim its for RF electromagnetic fields. These are 
somewhat stricter than those of the presen t EU directive from 2004. Sweden has also 
adopted the framework directive 89/391/EEC  and has a demand for systematic work 
environmental risk assessment. So in principl e not very much would change when the new 
directive will come in force. 
• Policy options impact 
Policy Option A 
In principle to make an assessment of the e xposure to radiofrequency fields from the RF 
sealers there is need to call in an expert. It  is not possible for the company to do this by 
themselves since the emissions from the m achines are very much dependent on how the 
installation is built, what plastic material is  being welded, etc. Therefore there is only 
limited use of the manual from th e manufacturer of the machine. 
Both the electric and the magnetic fields have  to be measured. The exposure is also very 
inhomogeneous and it is therefore necessary to do a spatial averaging of the fields over the 
body of the worker. Thre might also be a need  for doing a time average of the measured 
values. In the frequency range the machine is working there is also a demand to survey the 
contact and the induced currents.  Thus, there is a demand to measure 5 parameters: E, H, 
contact and induced current, and frequency. 
When doing exposure assessments for radiofrequen cy fields one has to determine the worst 
case of exposure for a particular working situ ation. It is not always  possible to cover all 
situations during one measurem ent session, but it is necessary to make sure that the 
exposure assessment is done as to take in to account the wors t case scenario.  
It is usually not a question if the actions levels are exceeded or not, but rather how close 
can one come to the machine before they are exceeded. 
To do the survey there is need for expert s with the appropriate instrumentation and 
knowledge on how to use them. The time for each  sealing machine to be under survey can 
be estimated to about 2 hours and about 1 hour for the work  after the measurements in 
form of protocols and information of the outcomes to the employer and the workers.  
For a company with 4 machines this would mean  an expert time of 12 h. Added to this is 
the travel time since it is likely that the few experts that exist on this are not located nearby. The cost for the initial su rvey for this company could thus  be estimated to be in the 
order of 3000 Euro (2 days).  
The survey needs to be repeated on a regular ti me basis, perhaps every second or third year 
since the machines change over time if th e maintenance program is not correct. These 
follow-up surveys should be less expensive sin ce the previous protocol may be of help. 
 
EN 88   EN Policy Option B 
This option would not change from the above since measurements are needed regardless of 
what the limits are since these machines produce intense RF fields, and it is not a question 
if you exceed the limits but rather how close to the machine you can go before exceeding 
the limits. Moreover, ELVs higher frequencies are not affected by the new limits (annex 
3). 
Policy Option C 
The mandatory risk assessment would probably have to be done by external experts so 
there will be no difference towards with opt ions A and B. There is also no difference 
regarding the policy option C1 and C2. 
Policy Option D 
With non binding recommendations it is questiona ble if the company wi ll do an exposure 
assessment. However, a risk assessment carried out on the basis of recommendations or sectoral agreements would probably arrive at  the same costs as for the previous options. 
There is no difference regardi ng the policy option D1 and D2. 
Policy Option E 
The cost of a proper risk assessment under th e framework directive regime would also 
arrive to similar costs in  this particular case.  
With the Framework Directive were fully-i mplemented, all options would require EMF 
assessment and the costs for different policy options would become: 
Option Average cost per 
establishment 
(Euros) 
A 3000 
B 3000 
C1 3000 
C2 3000 
D1 3000 
D2 3000 
E 3000 
• Summary 
For all options measurements are needed sinc e the information from the manufacturer is 
seldom enough for a complete risk assessment. Th ere is a need to measure the electric and 
the magnetic fields as well as induced and contact current. This calls for an expert to do and therefore the costs can be high.  
 
EN 89   EN 6. Case study: Broadcasting 
This case study deals with the occupational exposure to radiofrequency fields from 
broadcasting and telecommuni cation base station antennas during mast work. The 
stakeholder considered in this case study is an owner of the broadcasting towers/mast and 
has employees who are doing mast work (ins tallations, maintenanc e). The case study is 
made in Finland and it considers mainly RF frequencies as lower frequencies are not an issue in the broadcasting towers. 
• Present situation 
Finland has legislation concer ning the maximum allowed exposu re to radiofrequency fields 
(f >100 kHz). Radiation authority of Finland has issued a guideline concerning radiation 
safety of the FM- and TV-station mast work ba sed on this legislation.  The exposure limits 
of the Finnish regulation corre spond with the Directive 2004/ 40/EC in its current form. 
The employers and trade unions have also made  together occupationa l safety guidance for 
mast work which considers also EMF. This gu idance is in line with the Finnish legislation 
and gives more practical instructions. 
The company has the resources and skills  to make the exposure assessments by 
themselves. Workers wear personal EMF mete rs that will sound alar m in case the exposure 
limits are exceeded during the mast work. Mast wo rkers have yearly safety training days in 
which the EMF issues are always included. Training includes the use of measurement 
devices and correct working practices close to the EMF sources. Mast workers are under 
medical surveillance in which a special atte ntion is paid for th e cardio respiratory, 
musculoskeletal, neurological and sense organ functions. The medical examination 
includes the national guidelines given for the medical examinations for working in jobs with high risk of health (item non ionizing radiation, Finnish Inst itute of Occupational 
Health, 2006). The medical exam inations are made every three years for workers under the 
age of 40, every 2 years for workers under 50 and yearly for workers over 50. These medical examinations are mandatory for the license to work on broadcasting masts. Workers with pacemakers are not allowed to work at the broadcasting sites. 
The EMF exposure has been measured in all TV and Radio broadcas ting masts and based 
on these measurements the working practices  have been made. Working practices may 
include safety time limits for staying at certa in locations or the reduction of transmitting 
powers during work tasks. All workers carry pe rsonal alarm devices that sound alarm if the 
exposure limits are exceeded. Workers have be en informed how to act in these cases. 
• Policy options impact 
Policy Option A 
The present situation is already in line w ith the policy option A. However, broadcasting 
sites are very challenging places to ma ke exposure assessments and for example 
measurements of limb induced currents may be  difficult. If the procedures for exposure 
measurements are not clear additional costs may arise or compliance may be difficult to prove. Policy option A would, nevertheless, incu r small costs as the company checks the 
compliance with the provisions. In this case it is estimated to take half days working time to do this task. The average wage for the sort  of person who might be  charged with this 
task (from the employer's side) is perhaps 45k Euros per year (engineer). Allowing 50% 
overhead and 230 working days in a year this is equivalent to approximately 150 € . 
 
EN 90   EN Policy Option B 
At this moment in time it is likely that the ICNIRP will not revise the guidelines for the RF 
frequencies in the near future: 
"... it is the opinion of I CNIRP that the scien tific literature publ ished since the 1998 
guidelines has provided  no evidence of any adverse effects below the basic restrictions and 
does not necessitate an immediate revision of its guidance on limit ing exposure to high 
frequency electromagnetic fields." (Statement on the "Guidelines fo r limiting exposure to 
time-varying electric, magnetic  and electromagnetic fields  (up to 300 GHz). Health 
Physics 97(3):257-259; 2009.) 
Because of no new scientific evidence for higher frequencies, the system proposed for 
options B and C will no modify the ELVs in this range of th e frequency spectrum. ICNIRP 
existing recommendations will be used as for directive 2004/40/EC.  
Policy Option C 
The broadcasting sector will not be concerned by any partial or complete exemption. 
Therefore, both options C1 a nd C2 would not have impact as  the present situation would 
remain. The costs for checking the complian ce would still apply be ing approximately 150 
€, according to the estimate given in policy option A. 
Policy Option D 
In a case of non-binding occupational EMF exposure recommendation (D1) the current 
situation would not change as the recommendations would likely be based on ICNIRP recommendations that are the basis of the current practices. The costs for checking the 
compliance would still apply being approxima tely 150 €, according to the calculations 
given in policy option A. 
In a case of voluntary agreements at European or sectoral level betw een social partners 
(D2) the impacts would likely be minor one s. The sectoral agre ements would likely 
continue to uphold the present situation and the li mits would have a scie ntific basis as this 
is the point telecommunication sector emphasises.  
Policy Option E 
This policy option would not change the curren t practices as the companies would likely 
uphold the current practices that have been proven effective. It may, however, produce 
problems if Member States have different national limits. Pan-European companies having 
expatriates may have difficulties if occupati onal exposure limits change according to the 
country. This may increase costs as more th an one set of personal protective devices are 
required. Furthermore, it will be difficult to e xplain to the workers why the limits differ in 
the same task in different countries. This s ituation is considered to be very unlikely. 
For the purposes of this case study the cost s for different policy options would be: 
Option Cost per 
establishment 
(Euros) 
 
EN 91   EN A 150 
B 150  
C1 150 
C2 150 
D1 150 
D2 150 
E 150 
Occupational health care and mast working licence practices are different in different 
Member States. In Finland the system for th e mast workers periodica l health checks is 
extensive but it is likely that the practices  differ between member states. The economic 
impact of policy options for the costs of medical examinations would therefore differ 
greatly among member states. On e of the problems related to th e comparison of the costs is 
due to the fact that no intern ationally approved method for the health examinations or 
procedures exists. 
• Summary 
Broadcasting and telecommunication sect ors are generally following the ICNIRP 
guidelines throughout the EU and therefore th e impacts of the different policy options 
would be minor for the indivi dual broadcasting/telecommunication companies. As the EU 
council recommendation on the limitation of  exposure of the ge neral public to 
electromagnetic fields (1999/519/EC) is base d on the ICNIRP general public limits many 
EU member states have adopt ed ICNIRP based legislation/ recommendation for the general 
public exposure. It is an a dvantage to the operators to have a common basis for both 
general public and occupational exposure limits . If either one is changed it might reduce 
the credibility of another one.  
 
EN 92   EN 7. Case study: MRI 
This case study is slightly different from the othe rs in that it consider s the totality of MRI 
usage in the EU rather than in an individual workplace. This is because it is very difficult 
to establish financial costs fo r each MRI facility – this wi ll depend on the detailed usage 
modalities.  
• Present situation 
Background 
There are millions of MRI patient examinations  in the EU annually. It is estimated that 
there are approximately 8000 MRI suit es and perhaps 110,000 (wherefrom 3000 
installation/maintenance personne l) potentially-exposed workers54. Few workers will be 
exposed to the RF or switched-gradient fields – this will mostly be a problem for interventional procedures primarily, which ar e likely to be a few percent (6 to 8% as 
indicated in the main document) of the total number of MRI procedures. There may also be 
some RF or gradient field exposure of staff that have to be clos e to the bore during 
scanning, for instance when small children or people under medica tion are being scanned. 
So even outside interventional MRI there may be some RF and switched gradient 
exposure. However, the issue of workers movi ng through static fields will be an issue for 
all MRI systems. 
Application of EMF Directive implementation framework 
MRI suites can present a range  of potential hazards – incl uding the indirect effects of 
magnetic fields (such as projectile risk) and noise. There is therefore already a good risk 
management regime in place in MRI facilities. According to FICETTI any direct risk from 
EMF hazard has not usually been included explicitly in this regime as the practitioners consider that measures taken to minimise poten tial adverse consequences in patients will 
protect workers. The IEC 60601-2-33 standard has been extended to cover occupational 
EMF exposures from MRI, and used in conjun ction with existing s ite guidelines on safe 
working, the MRI community considers that wo rkers are fully-protect ed even though the 
EMF Directive exposure limit values will not always be met. 
• Expertise and costs 
MRI suites usually have access to high-quality advice on risk, and the MRI staffs are well-
educated and aware of the totality of risk in their working environment. Where less EMF-
aware staff has access to MRI facilities (for example cleaners) strict risk-management 
regimes are in place to address the other wo rkplace risks. It is very likely that MRI 
facilities either have access to sufficient EMF expertise to be able to manage the direct 
EMF risk adequately or c ould develop it at low cost. 
• Costed policy options impact 
Option A It has been estimated that perhap s 500,000 MRI procedures would not be 
possible if Option A were fully-implemented. It might of course be possible to make 
                                                
 
54 These figures are based on ESR and COCIR data and differ from the fi gures given by FICETTI. 
 
EN 93   EN technical changes to MRI equipment (for exampl e changing the gradient-field pulse shape) 
to reduce this number. 
There will also be an effect  on the commercial activities of  MRI manufacturers, but like 
the extent and cost of te chnical changes, this is very difficult  to estimate and is likely to be 
a rather small component of the total costs to society. For simila r reasons, and because 
most of them operate within integrated hea lthcare systems, it is difficult to establish an 
exact financial cost to specific MRI facilities. However, there will be a cost to society of 
curtailment of MRI activities and whilst this ma y be primarily a health detriment, it may be 
possible to assign fina ncial costs to it. 
The FICETTI consortium asked the UK's Hea lth Protection Agency to consider the 
potential shift from MRI to  X-ray computed tomography (CT) that Option A might 
engender. Their calculations (det ails in the FICETTI report) indicate that the increased 
collective ionising radiation dose for workers in England and Wales might be 3-5 man Sv 
per year. This could be scaled by a factor of  perhaps 10 for the whole EU. A financial cost 
of 50k Euros per man Sv is often used in ionising radiation optim isation, giving a total 
annual financial cost of perhaps 2.5M Euros55. 
The Alliance for MRI has provided a similar calculation for increased patient exposure to 
ionising radiation, and the co rresponding figure is approximately 175M Euros. They also 
suggest a figure five times larger for lost “ opportunity cost” from an inability to employ 
interventional MRI in the future, but this figure is very speculative indeed. 
The Directive requires an assessment of possibl e impact on AIMD users,  but again this is 
an issue that will already be addressed in  MRI facility risk management systems. 
In its calculations, FICETTI ha s considered the cost s related to the shif ting to X-rays as 
compliance costs although they are of a differen t nature: they apply to the general society 
and not to the employers; moreover, the sectoral  cost for an effective risk assessment has 
been neglected because the MRI community cons iders that this aspects has already been 
covered because they are compliant with the IEC standards referred to above. This is of 
course not acceptable as such for Option A. Therefore, it has been  estimated that under 
option A a comprehensive risk assessment shoul d be carried out including measurements 
etc. As there are a number of similarities wi th the case of induction heating, the sectoral 
cost component has been estimated at €4015 . 
Option B  The impact of this option will be equivalent to option A as far as compliance 
costs are concerned. Whatever th e number of cases of overexposur e, the extent of the risk 
assessment will be the same as for option A: €4015  
Option C1  MRI facilities are already subject to an overall risk-management regime, and 
the practitioners are confident that they would be able to manage EMF risk even where the exposure limit values are exceeded. However, ev en if there are no exposure limit values to 
compare exposure with, a "light" risk assessm ent will remain mandatory. For a 2 days in-
house expertise, the cost has been estimated at €325 . 
                                                
 
55 In contrast with EMF, the effects of exposure to ionising radiation are well known and quantified. There are 
internationally accepted "health costs" for each dose increment to the societ y. This is valid  for workers and 
patients as well. 
 
EN 94   EN Option C2  is complete exemption for the sect or. This might be a low-cost option 
(effectively the same as Option C1): €325 . 
Options D1  Depending on the provisions laid  down in the recommendations the 
obligations may be different in the Member  States. On the othe r hand the Framework 
Directive already requires a risk  assessment that includes EMF. It is difficult to estimate in 
how far this will affect the costs. The lack of precise rules for the carrying out of the 
additional risk assessment may end up in an incr ease of costs. The has been estimated to be 
the hiring of one day external expertise on top of the 2 days internal expertise: 1825€ 
Option D2 The requirements of the employees may influence the content of the sectoral 
agreement in the sense of more verifications. Th is is estimated to be of the same order as 
for option D1: 1825€  
Option E: This requires EMF to be considered as part of a general risk assessment under 
the Framework Directive. There is a concern th at without a pan-EU ag reement in place on 
how to address MRI, there is the potential for health, social and economic inequalities 
between different countries. The result woul d probably end up with a compromise solution, 
different from Member St ate to member State: 1825€ . 
Option Cost per installation 
(Euros) 
A 4015 
B 4015 
C1 325 
C2 325 
D1 1825 
D2 1825 
E 1825 
• Summary 
• MRI facilities already have a ri sk-management framework in place. 
• MRI use would be profoundly affected by Option A, and probably B 
• Option A (and probably B) would le ad to a health detriment for the society as well as a 
financial cost. 
• Additional costs for option C1 
This option foresees reinforced qua litative measures (see 4.1.3). This wi ll mainly consist of specific 
training and refreshing sessions for the personnel wo rking in medical MRI facilities. In this case 
cleaning, maintenance personnel and nurses likely to bring patients into the MRI room must be 
considered. Additional training for maintenance personn el is considered close to 0 as they already 
get extensive training on the subject; specific  training for cleaning personnel (min. 3 per 
 
EN 95   EN installation) would be 0.5 day and for nurses an d dedicated personnel (mi n. 10 per installation) 1 
additional training day per person, during the first year. With a co st estimate of 150 € per day for 
approx. 110.000 persons brings th e additional cost to approx. 14.25 Million Euros (3000 persons 
from maintenance, 24000 for cl eaning, 83000 medical personnel). 
 
EN 96   EN  
Annex 5  
Compliance costs for each option 
Compliance costs are the costs of actions undertaken  by establishments to meet to the requirements 
of the options. They entail three types of cost:  
a) Generic costs b) Sectoral or activity specific costs c) Training costs 
A) Generic compliance costs 
Generic compliance costs are the co sts of actions that employers have to unde rtake in order to 
understand the requirements and comply with them. Th is comprises a series of tasks starting with 
the analysis of the situation, the organisation of th e risk assessment and the setting up of the action 
plan. The tables in Appendix 5a below presents th e generic compliance costs for each policy option. 
For the calculation, a number of assumptions were made: 
Number of concerned organisatio ns: The total number of EU-27 enterprises in the non-financial 
business economy is estimated by Eurostat at around 20,000,000.
56 All of them are concerned by 
the first action (triage). The numbe r of enterprises that need to undertake the following specific 
actions is estimated based on the presence of the relevant equipment for a given policy option. As 
set in Appendix 5b in total 215,140 wo rkplace assessments would take place across se ctors. It is 
estimated that based on these assessments around 60,000 employers after indentifying high 
exposure would need to develop their own action plan which could include several workplaces.  
Tariff: The average EU hourly labour cost used in the study is 18.75 €. For comparison Eurostat's 
Labour Force Survey for the year 2008 indicates the average EU hourly labour cost of 16.13€ for 
Industry, construction a nd services (except activ ities of households as  employers and extra-
territorial organisations and bodies ). Time needed to perform th e actions: Based on the experts 
opinion as set in FICETTI study. 
Appendix 5a - Generic costs summary 
Policy option Costs (Million Euro) 
A 111.7 
B 111.7 
C1 111.7 
C2 111.7 
D1 39.4 
                                                 
56 http://epp.eurostat.ec.europa .eu/cache/ITY_OFFPUB/KS-ET-10- 001/EN/KS-ET-10 -001-EN.PDF 
 
EN 97   EN D2 22.5 
E 76.3 
B) Sectoral or acti vity specific costs 
The costs include the EMF measurement and the intr oduction of protection me asures per sector for 
each policy option. 
The cost per sector is based on the unit cost per establishment (derived from the case studies, Annex 
4) multiplied by the number of workplace sites in the sector requiring an assessment. 
This could be considered a yearly cost, if ther e are no substantial changes in the workplace design, 
equipment used or working procedures. 
The table in Appendix 5b includes: Sectors: Main types of activitie s where workers are exposed to EMF. For the military sector, the 
costs could be estimated only on speculative basi s and are therefore omitted in the calculations. 
Workers exposed and number of workplaces/assessm ents: Number of potenti ally affected workers 
and workplaces in the concerned se ctors in the EU is estimated ba sed on the information obtained 
from the stakeholders from several Member States  (Netherlands, Slovenia, UK, Austria, France, 
Finland, Italy, France, and Sweden).  Source: FICETTI report Appendix 6. 
Cost per establishment: Compliance cost per establishment is estimated based on case studies 
conducted in small and medium size ente rprises in the concerned sectors. 
Appendix 5b - Sectoral or act ivity specific costs summary 
Policy Option Costs (Million Euro) 
A 548.0 
B 414.6 
C1 385.1 
C2 385.1 
D1 397.1 
D2 397.1 
E 397.1 
C) Training costs 
The Framework Directive 89/391/EC sets the obliga tion for employers to provide the training and 
information, so the inclusion of EMF aspects in to the overall existing OSH training may induce on 
average the cost of 300€. It is c onsidered that the costs of providing training and information are the 
same for all the policy options. Training costs as estimated by FICETTI are consolidated on the 
basis of 300.000 establishments deemed to have one  or more EMF sources. However this estimate 
 
EN 98   EN does not take into account the cost of workers’ sa laries during the time they are participating to the 
training. After correction the total figure of 0.1 become € 0.5 million. 
Appendix 5c - Training costs summary 
Policy option Costs (Million euro) 
all 0.500 
Total compliance costs: A+B+C  
Summary of total compliance costs for each option: 
Policy Option  
Compliance cost (Million Euros) 
 
A: no change to 
EC/2004/40 660.2 
B: new ELVs for 
all sectors 526.8 
C1: possibility 
for derogation 
from ELVs 511.6* 
C2: some 
workers out of 
scope 493.3 
D1: non-binding 
recommendations 
only 437.0 
D2: sectoral 
agreements only 420.1 
E: no EU action 473.9 
*including reinforced training for MRI 
 
EN 99   EN Appendix 5b. Sectoral costs  
Sectors Workers 
exposed Number of 
workplaces/ 
assessments Cost 
per establishment 
A EU total Cost per establishment 
B EU total Cost per establishment 
C1 EU total Cost per establishment 
C2 EU total Cost per establishment 
D1 EU total Cost per establishment 
D2 EU total Cost per establishment 
E EU total 
Metal industry 1019000 162140                  
Welding 730000 73000 1825 133225000 1375 100375000 1375 100375000 1375 100375000 1375 100375000 1375 100375000 1375 100375000 
Induction heating 150000 75000 4015 301125000 2680 201000000 2680 201000000 2680 201000000 2680 201000000 2680 201000000 2680 201000000 
Dielectric heating 90000 9000 3000 27000000 3000 27000000 3000 27000000 3000 27000000 3000 27000000 3000 27000000 3000 27000000 
Non-destructive magnetic 
testing 45000 5000 1825 9125000 1825 9125000 1825 9125000 1825 9125000 1825 9125000 1825 9125000 1825 9125000 
Electrolysis 4000 140 4015 562100 1825 255500 1825 255500 1825 255500 1825 255500 1825 255500 1825 255500 
Rail transportation 120000 500 1100 550000 1100 550000 1100 550000 1100 550000 1100 550000 1100 550000 1100 550000 
Telecommunications 
&broadcasting 39500 11000                  
Broadcasting 13500 1500 150 225000 150 225000 150 225000 150 225000 150 225000 150 225000 150 225000 
Radar systems 20000 3500 1100 3850000 1100 3850000 1100 3850000 1100 3850000 1100 3850000 1100 3850000 1100 3850000 
Mobile base stations 6000 6000 1100 6600000 1100 6600000 1100 6600000 1100 6600000 1100 6600000 1100 6600000 1100 6600000 
Electric energy 200000 3000 1250 3750000 1250 3750000 1250 3750000 1250 3750000 1250 3750000 1250 3750000 1250  3750000 
Health care 211000 13000                  
MRI 111000 8000 4015 32120000 4015 32120000 325 2600000 325 2600000 1825 14600000 1825 14600000 1825 14600000 
Surgical and therapeutic 
diathermy 100000 5000 272 1360000 272 1360000 272 1360000 272 1360000 272 1360000 272 1360000 272 1360000 
Research 1000 500 1825 912500 1825 912500 1825 912500 1825 912500 1825 912500 1825 912500 1825 912500 
Other 50000 25000 1100 27500000 1100 27500000 1100 27500000 1100 27500000 1100 27500000 1100 27500000 1100 27500000 
Military 250000 2500                  
Total (Million euro)     A 548.0 B 414.6 C1 385.1 C2 385.1 D1 397.1 D2 397.1 E 397.1 
Figures not estimated in annex 4 are taken from the FICETTI report 
 
EN 100   EN Appendix 5a. Generic costs 
Policy option A 
No Type of 
obligation Description of 
required action Target group Estimated 
number 
of such 
organisati
ons Tariff 
(per 
hour) Time 
(minutes) Price (per 
action)  Total 
number 
of actions Total 
generic 
costs 
(M€) 
1 Triage Understanding 
instruction from 
national authority that 
specific sectors need take no action Organisations that 
implicitly do not need to 
do any assessment at all 
e g  S M E s  w i t h  n o  significant EMF sources 20000000 18,75 10 3,125 1 62.500 
2 Background Understanding general 
Directive requirements 
& implementation 
framework (Guide etc) at a basic level All employers who may 
need to make an 
assessment 300000 18,75 30 9,375 1 2.813 
3 Determine 
what 
assessment 
is needed Assess whether the 
workplace is 
automatically compliant  All employers who may 
need to make an 
assessment 300000 18,75 15 4,6875 1 1.406 
4 Detailed 
background Understanding detailed 
Directive requirements & implementation framework (Guide etc) 
at a basic level Employers with 
workplaces that are not automatically compliant 300000 18,75 480 150 1 45.000 
Total (M€)  111,7 
 
EN 101   EN Policy option B 
No Type of 
obligation Description of 
required action Target group Estimated 
number 
of such 
organisati
ons Tariff 
(per 
hour) Time 
(minutes) Price (per 
action)  Total 
number 
of actions Total 
generic 
costs 
(M€) 
1 Triage Understanding 
instruction from national authority that 
specific sectors need 
take no action Organisations that 
implicitly do not need to do any assessment at all 
eg SMEs with no 
significant EMF sources 20000000 18,75 10 3,125 1 62.500 
2 Background Understanding detailed 
Directive requirements & implementation 
framework (Guide etc) 
at a basic level All employers who may 
need to make an assessment 300000 18,75 30 9,375 1 2.813 
3 Determine 
what assessment 
is needed Assess whether the 
workplace is automatically compliant 
(Table 1 of EN50499 & 
Guide) All employers who may 
need to make an assessment 300000 18,75 15 4,6875 1 1.406 
4 Detailed 
background Understanding general 
Directive requirements & implementation framework (Guide etc) 
at a basic level Employers with 
workplaces that are not automatically compliant 300000 18,75 480 150 1 45.000 
Total (M€)  111.7  
 
EN 102   EN Policy option C1 
No Type of 
obligation Description of 
required action Target group Estimated 
number 
of such 
organisati
ons Tariff 
(per 
hour) Time 
(minutes) Price (per 
action)  Total 
number 
of actions Total 
generic 
costs 
(M€) 
1 Triage Understanding 
instruction from national authority that 
specific sectors need 
take no action Organisations that 
implicitly do not need to do any assessment at all 
eg SMEs with no 
significant EMF sources 20000000 18,75 10 3,125 1 62.500 
2 Background Understanding general 
Directive requirements & implementation 
framework (Guide etc) 
at a basic level All employers who may 
need to make an assessment 300000 18,75 30 9,375 1 2.813 
3 Determine 
what assessment 
is needed Assess whether the 
workplace is automatically compliant  All employers who may 
need to make an assessment 300000 18,75 15 4,6875 1 1.406 
4 Detailed 
background Understanding detailed 
Directive requirements 
& implementation framework (Guide etc) at a basic level Employers with 
workplaces that are not 
automatically compliant 300000 18,75 480 150 1 45.000 
Total (M€)  111.7  
 
EN 103   EN Policy option C2 
No Type of 
obligation Description of 
required action Target group Estimated 
number 
of such 
organisati
ons Tariff 
(per 
hour) Time 
(minutes) Price (per 
action)  Total 
number 
of actions Total 
generic 
costs 
(M€) 
1 Triage Understanding 
instruction from national authority that 
specific sectors need 
take no action Organisations that 
implicitly do not need to do any assessment at all 
eg SMEs with no 
significant EMF sources 20000000 18,75 10 3,125 1 62.500 
2 Background Understanding general 
Directive requirements & implementation 
framework (Guide etc) 
at a basic level All employers who may 
need to make an assessment 300000 18,75 30 9,375 1 2.813 
3 Determine 
what assessment 
is needed Assess whether the 
workplace is automatically compliant  All employers who may 
need to make an assessment 300000 18,75 15 4,6875 1 1.406 
4 Detailed 
background Understanding detailed 
Directive requirements 
& implementation framework (Guide etc) at a basic level Employers with 
workplaces that are not 
automatically compliant 300000 18,75 480 150 1 45.000 
Total (M€)  111.7  
 
EN 104   EN Policy Option D1 
N
o Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisati
ons Tariff 
(per hour) Time 
(minutes) Price (per 
action)  Total 
number of 
actions Total 
generic 
costs (M€) 
1 Background Understanding general 
EMF requirements & implementation 
framework in he 
absence of Diretcive and Guide etc All employers who 
may need to make an assessment 300000 18,75 180 56,25 1 16.875 
2 Understandin
g 
recommendat
ions Establishing 
relationship between 
any recommendation 
that is made and an employer's legal 
responsibility All employers who 
may need to make an 
assessment 300000 18,75 120 18,75 1 11.250 
3 Determine 
what 
assessment is needed Assess whether the 
workplace is 
automatically compliant in the absence of a 
Directive All employers who 
may need to make an 
assessment 300000 18,75 120 37,5 1 11.250 
Total (M€)  39.4 
 
EN 105   EN Policy option D2 
N
o Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisati
ons Tariff 
(per hour) Time 
(minutes) Price (per 
action)  Total 
number of 
actions Total 
generic 
costs (M€) 
1 Background Understanding general 
sector-specific requirements All employers who 
may need to make an assessment 300000 18,75 120 18.75 1 11.250 
2 Determine 
what 
assessment is 
needed Assess whether the 
workplace is 
automatically compliant 
with sector-specific requirements All employers who 
may need to make an 
assessment 300000 18,75 120 37.50 1 11.250 
Total (M€)  22.5 
 
EN 106   EN Policy option E 
No Type of 
obligation Description of 
required action Target group Estimated 
number 
of such 
organisati
ons Tariff Time 
(minutes) Price (per 
action)  Total 
number 
of actions Total 
generic 
costs (M€) 
1 Triage Understanding 
instruction from national authority that 
specific sectors need 
take no action Organisations that 
implicitly do not need to do any assessment at 
all eg SMEs with no 
significant EMF sources 10000000 18.75 10 3.125 1 31.250 
2 Backgroun
d Understanding general 
EMF requirements of 
Framework Directive in 
absence of guidance associated with EMF 
Directive All employers who 
may need to make an 
assessment 300000 18.75 480 300 1 45.000 
Total (M€)  76.3 
 
EN 107   EN Appendix 5c. Training costs (as estimated by FICETTI) 
No Type of 
obligation Description of required 
action Target group Estimated 
number of 
such 
organisatio
ns Tariff (per 
hour) Time 
(minutes) Price (per 
action)  Freq per 
year Total 
number of 
actions Total 
generic 
costs (M€)  
13 Training 
and 
informing Organising training and 
informing Employers with 
workplaces where 
exposures do not met 
requirements of Framework Directive 60000 18,75 60 18,75 0,33 1 0,0003712
5 
14   Preparing training and 
information materials Employers with 
workplaces where 
exposures do not met 
requirements of Framework Directive 60000 18,75 480 150 0,25 1 0,018 
15   Providing training and 
information Employers with 
workplaces where 
exposures do not met 
requirements of Directive 60000 18,75 480 150 1 1 0,072 
Total (M€) 0,09 
 
EN 108   EN Annex 6  
Details on costs related to Administrative Burden 
Policy option A 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,33 1 0,0309375
   Total     millions euro 0,12375
Policy option B 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,33 1 0,0309375
   Total     millions euro 0,12375
 
EN 109   EN Policy option C1 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,33 1 0,0309375
   Total     millions euro 0,12375
Policy option C2 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,33 1 0,0309375
   Total     millions euro  0,12375
 
 
EN 110   EN Policy option D1 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,25 1 0,0234375
   Total     millions euro  0,11625
Policy option D2 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,33 1 0,0928125
 2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,33 1 0,0309375
   Total     millions euro  0,12375
 
 
EN 111   EN Policy option E 
No Type of 
obligation Description of 
required action Target group Estimated 
number of 
such 
organisations Tariff 
(I per 
hour) Time 
(minutes) Price 
(per 
action) Freq 
per 
year Total 
number 
of 
actions Total 
Administrative 
Costs 
1   Recording of 
EMF 
assessment results as 
required by 
national legislation Employers 
who have 
made/had made an 
EMF 
assessment 30000 18,75 30 9,375 0,1 1 0,028125
2   Notification to 
competent 
authorities (according to 
national 
requirements) Employers 
in countries 
where this is required 30000 18,75 10 3,125 0,2 1 0,01875
   Total     millions euro  0,046875
 
EN 112   EN Annex 7  
Questions (without additional  comments and original layout) of the questionnaire on 
health, socio-economic and environmenta l impacts in connection with possible 
amendments to Directive 2004/40/EC 
The questions were repeated for all the selected options.  
1a. Does the option affect the likelihood of su ffering from work-related illness? This may be 
an effect of EMF itself on a worker, it may be st ress due to concerns about EMF (even if these 
may be unfounded) or it may be and effect or stress caused by any measures taken to comply 
with the EMF Directive? 
1b. Does the option affect the job opportunities? 
2a. Does the option affect the health risk of  workers with pacemakers or other implanted 
medical devices (MD)? Please note that the EMF Directive requires that workers with active 
medical implants, and other sensitive workers, are considered explicitly. 
2b. Does the option affect the job opportunities of workers with pacemakers or other 
implanted MD? 
3a. Does the option affect the he alth risk of pregnant women? 
3b. Does the option affect the job opportunities of  pregnant women? Please note that this may 
include either worsened opportunities because EM F exposures are limited, or it may increase 
opportunities because a risk assessment as requi red by the EMF Directive may indicate that 
no particular risk for the pre gnant worker or fetus occurs., 
4a. Does the option affect the hea lth risk of fertile-aged women? 
4b. Does the option affect the job opp ortunities of fertile-aged women? 
5. Does the option increase or decrease the kno wledge of employers an d employees related to 
health risks arising from EMF? 
6. During a risk assessment involving a lot of diff erent health and safety risk factors, does the 
option increase or decrease the attention to exposure to EMF? 
7. Does the option affect the number of EM F exposure assessments in your sector? The 
requirements to undertake EMF exposure assessme nts, and the circumstances in which they 
should or should not be made, ar e described in the Non-bindi ng Guide to the EMF Directive 
which is available in draft form at w ww.indigo-emf.eu (password: ECIndigoLock). 
8. Does the option affect the quality of EMF exposure assessments in your sector? 
9. Does the option increase kno wledge of employers on how to adequately manage 
occupational exposure to EMF? 
 
EN 113   EN 10. How does the option affect preventive technical actions a nd organizational changes which 
will lead to a decrease of the risk level or/and to a decrease in number of workers exposed to 
health risks arising from EMF? 
11a. Does the option increase or  decrease the like lihood of incurring costs? These costs 
include immediate costs such as the costs of  EMF assessments and remedial measures, and 
also deferred costs which might arise from change s in worker job satisfaction or concern that 
a health risk continues to  exist in the workplace 
11b. Does the option affect the costs of risk assessments in a company? Please note that the 
Non-binding Guide to the EM F Directive describes the circumstances in which risk 
assessment might be required and ex plains how this should be done 
11c. Does the option affect the costs of training for workers at risk in a company? Please note 
that the Non-binding Guide to the EMF Dire ctive describes the circumstances in which 
training might be required 
11d. Does the option affect the costs of trai nings for OSH specialists in a company? 
11e. Does the option affect the costs of providing information in a company? Please note that 
the Non-binding Guide to the EMF Directive describes the circumstances, in which the provision of information might be required 
11f. Does the option affect the costs of cha nges in work equipment at workplaces in a 
company? Please note that the Non-binding Gu ide to the EMF Directive describes the 
circumstances, in which changes in  work equipment might be required 
11g. Does the option affect the costs of changes in work organization in a company (including 
costs of ensuring limited access to areas where exposures exceed the exposure limit values)? 
Please note that the Non-binding Guide to the EMF Directive describes the circumstances in 
which changes in work organization might be required 
11h. Does the option affect the costs of medi cal examinations of workers exposed in a 
company? Please note that the Non-binding Gu ide to the EMF Directive describes the 
circumstances in which medical examinations might be required. 
12. Does the option impose additional administrative requirements for companies? 13. Does the option require companies in your s ector to make significant changes in the way 
they conduct their operations? 
14a. Do you foresee considerable difficulties in implementing the option in your sector or in 
your country? 
15. Does the option affect the social safety of employers? 16. Does the option affect the well-being of employees? 17. Does the option affect the level of absenteeism? 
 
EN 114   EN 18. Does the option affect productivity? 
19. Does the option affect the work ability of workers? 20. The costs due to implementing EMF regulations will outweigh benefits? 21. Does the policy option a ffect training activities? 
22. Does the option increase or decrease the inequality between  different sized enterprises 
(large-scale enterprises, SMEs, micro-sized or ganizations) regarding their ability to obtain 
information about health risks arising from EMF? 
23. Does the option increase or decrease the inequality between  different sized enterprises 
(large-scale enterprises, SMEs, micro-sized orga nizations) regarding thei r ability to protect 
their employees against health  risks arising from EMF? 
24. Does the option increase or decrease the comp etitiveness of EU enterprises compared to 
non-EU rivals? 
25. Do you think that the options presented here  guarantee the same leve l of protection of the 
workers among the various sectors (health care , telecommunications, metal industry, rail 
transportation, etc.) or does any of them introduce a level of inequality? 
26. Does the option stimulate or hinder th e needs for research and development? 
27. Does the option facilitate the introduction and disseminati on of new production methods, 
technologies and products? 
28a. Does the option facilitate or restrict the use of technological innov ations in your sector? 
29a. Please rank the different optio ns regarding their suitability  for the health care of the 
employees. Use "7" for the option with the str ongest effect to "1" for the option with the 
lowest effect. 
29b. Please rank the different options regarding th eir ability to make legislation easier to 
apply. 
29c. Please rank the different optio ns regarding their ability to decrease the administrative 
burden to employers. 
29d. Please rank the different options regardi ng their efficiency in implementation and 
enforcement of prevention of health risks from EMF. 
 
EN 115   EN Annex 8  
Estimated cost for cases of overexposure 
According to current direc tive 2004/40/EC, in the case  of overexposure a medical 
examination shall be made available to the worker(s). Accidental overexposure causes costs are generated from the diagnostics, treatment a nd health insurance (wor k inability, long- term 
disability) and from organizati onal managing of the case. If the risk assessment has been 
performed appropriately, the managing of the subj ect is more rapid and the costs are lower. 
The investigation procedure depends on how we ll the exposure situation is known and on the 
symptoms and signs presented from the subject . The usual clinical symptoms of the acute 
overexposure that are investigated  are skin or eye reactions. Sy mptoms to the nervous system, 
both central nervous systems (CNS) and/or peripheral nervous system (PNS) are also 
considered. More advanced methods in diagnos tics might include neurol ogical and laboratory 
studies.  
The estimations of costs are presented in the fo llowing tables. The estimated total cost for any 
case of overexposure without any serious complications w ould be approximately 8 k€ 
(reference Finland). The cost increases consider ably in case of complications. The use of the 
present international safety lim its in the prevention of the overexposure has minimized the 
number of accidental overexposures in the working environment.  
Table 1. Estimated medical examin ation costs in overexposure case. 
Item Details Cost 
Occupational physician Two visits: eval uation of the pres ent situation and 
planning of following steps 200 € 
Consultation of medical 
specialists (neurology, dermatology, ophthalmology) Visits and special examination techniques 1300 € 
Dermatologist One visit 300 € 
Sick leave days Wash out after the incident, 5 days á 300 € (The 
Social Insurance Institution of Finland has estimated the costs of one sick leave day to be 300 € on average) 1500 € 
 TOTAL 3200 € 
MRI examination (brain) If require d according to previous medical 
examinations 1000 € 
Neurophysiologic tests 
 If required according to previous medical 
examinations 1000 € 
 
EN 116   EN  
Table 2. Estimated organisationa l costs in overe xposure case. 
The current information on 
exposure situation Gathering and analysin g existing information 
on the exposure situation. (Engineer 0.5 workdays) 147 € 
Legal requirements Communication w ith the authorities. (Engineer 
0.5 workdays) 147 € 
Office work General office wo rk related to overexposure 
situation (Office staff, 2 work days) 300 € 
Mitigation Technical measures to prevent recurring of the 
event (based on the induction heating case study, 'worst-case scenario') 4015 € 
 TOTAL 4609 € 
The costs per workday for an engineer are based on annual salary  of 45 000 € and 50 % 
overhead. With 230 working days per year this leads to 293 € per working day. The costs per 
workday for office staff are based on annual salary of 23 000 € and 50 % overhead. With 230 
working days per year this leads to 150 € per working day. 
NB: These costs have been estimated for Finlan d, where the salaries ar e at the higher end of 
the spectrum. A quick extrapolat ion shows that in EU, this cost may vary from approx. €2000 
to €4700 depending on the Member St ate (see sections 5.1.3 and 5.1.8). 
 
EN 117   EN Annex 9  
Survey based assessment of the options 
The social impacts do most promin ently concern workers' health and potential losses of jobs. 
The economic impacts are: on the one side the actual costs of implementation and potential 
negative consequences of rest ricting some economic activities (i.e. not realising growth 
potential or technological  progress), and on the other side they  are the benefits of consistent 
rules all over Europe, less legal insecurity for the employers, and lower probability of certain 
accidents or work-related injuries.  
When looking at the potential consequences of the different options, most impacts are 
difficult to quantify in a consistent way. Therefore it was chosen to consolidate the validity of the outcomes of the analysis of  impacts by conductin g an extensive stake holder survey. This 
survey was organized in the framework of  the FICETTI study, taking advantage of the 
presence at the Ljubljana workshop in Febr uary 2009 of a large numb er of stakeholders 
representing a significant num ber of important sectors. 
166 stakeholders' representatives replie d to the questionnaire wherefrom: 
Government/regulator 11 % 
Sectoral organization re presenting employers 15 % 
Trade union organization 7 % Research Centre/university 10 % OSH specialists/consultants 5 % Health care 18 % Large-scale enterprise  (> 250 employees) 24 % 
SME (10 < employees < 250) 3 % 
Micro-sized enterprise (< 10 employees) 0 % Self-employed 0 % Other 6 % 
Expressed by sector, the partition is as follows: 
Rail trans portation 4 % 
Metal industr y 15 % 
Health care secto r 34 % 
Telecommunications or broadcast 8 % 
Electric ener gy production/distribution/transmission 7 % 
Othe r 32 % 
156 (94%) of the respondents were aware of th e requirements set in Di rective 2004/40/EC. In 
so far it can be said that the respondents we re well informed about the ongoing debate.  
There were 30 questions (some with sub questi ons) in the questionnaire (see questions in 
annex 6). The latter addressed health aspects, competiveness, social, administrative aspects in 
 
EN 118   EN a very comprehensive way. The results were duly affected by the appropriate weighting 
factors. 
The conclusions of the survey reflect the opinion s of the participating stakeholders and can be 
summarized as follows: 
• Option A is generally considered  to have disproportionate economic costs, especially for 
SMEs 
• Option B was difficult to assess in the absence of new exposure guidelines from ICNIRP at 
the time of the survey. Stakeholders be lieve Option B has rather high economic 
consequences but it scores well on social and health impacts 
• Option C1 is the only option to score consistently positively in this survey based analysis, 
despite the fact that the new exposure guidelines were not known at the time just like for 
Option B. It seems that the announced flexibility and propor tionality gave the 
breakthrough. 
• Option C2 scores badly on economic and neutra lly on health and social impact grounds, 
leading to an overall negative score. 
• Options D and E score badly on health and so cial impact grounds. Option E especially is 
unpopular with stakeholders. 
 
EN 119   EN Annex 10  
Glossary 
Action values (AVs ): in the current directive 2004/40/ EC, the magnitude of directly 
measurable parameters, provided in terms of electric field strength (E), magnetic field 
strength (H), magnetic flux density (B) and powe r density (S), at which one or more of the 
specified measures in the directive must be  undertaken. Compliance w ith these values will 
ensure compliance with the relevant exposure limit values. 
Electromagnetic fields : static  magnetic and time-varying electric, magnetic and 
electromagnetic fields with  frequencies up to 300 GHz;  
Equipment: any device or hardware concerned by the EMF issue and producing 
electromagnetic fields when operating. 
Exposure level: intensity of the radiation to which a pe rson is exposed. Th e exposure level is 
expressed in Volt per meter (V/m) for the elec tric field strength and in Amperes per meter 
(A/m) for the magnetic field strength. For the ma gnetic field, this valu e is often replaced by 
the magnetic flux density expressed in Tesla (T).  The relation between both is B=µH, where µ 
is the magnetic permeability of the material involved. 
Exposure limits (Els): same as Exposure Limit Values (below)  
Exposure limit values (ELVs): limits on exposure to electromagnetic fields which are based 
directly on established health effects and biol ogical considerations. Compliance with these 
limits will ensure that worker s exposed to electromagnetic fi elds are protected against all 
known adverse health effects. 
Risk assessment: As a component of risk analysis, it involves identification, evaluation, and 
estimation of the levels of risks involved in a situation, their comparison against rules or 
standards, and determination of appropriate preventive a nd/or corrective measures to 
eliminate or reduce the risk. 
Acronyms and abbreviations 
AV(s)  – Action Values  
AIMD  – Active Implantable Medical Devices 
ALARA  – As Low as Reasonably Achievable 
ALARP  – As Low as Reasonably Practicable 
CENELEC  – European Committee for Elec trotechnical Standardisation 
COCIR  - European Coordination Committee of  the Radiological, Electromedical and 
Healthcare IT Industry 
EAS – Electronic Article Surveillance 
ELF(s)  – Extremely Low frequencies 
 
EN 120   EN ELV(s)  – Exposure Limit Values 
EMF – Electrom agnetic F ields 
ESR  – European Society of Radiology 
HF(s)  - High Frequencies 
HPA  – Health Protection Agency (UK) 
HSE – Health and Safety Executive (UK)  
ICNIRP – International Commission on N on-Ionizing Radiation Protection 
IEC – International Electrotechnical Committee 
IEEE - Institute of Electrical and Electronics Engineers 
IF(s)  - Intermediate Frequencies 
LF(s)  – Low Frequencies 
MRI – (medical) Magnetic Resonance Imaging 
NRPB  – National Radiological Protection Body (nowadays HPA ) 
RF – Radiofrequencies 
RFID  – Radiofrequency Identification 
TFEU  – treaty on the Functioning of the European Union