COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT
Date: 2011-06-14
Institutions: European Commission
Subjects: Cenelec, electromagnetic interference, occupational health, waveband

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 arising from physical agents (electromagnetic fields) 
(eighteenth individual Directive within the meaning of Article 16(1) of Directive 
89/391/EEC) 

{COM(2011) 348 final} 
{SEC(2011) 751 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 arising from physical agents (electromagnetic fields) 
(eighteenth individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC) 

Including changes after recommendations of the IA Board 

18 February 2011 

Lead DG: EMPL 

Associated DGs: SG, LS, ENTR, INFSO, RTD, ENER, SANCO, MOVE, TRADE, MARKT, 
ENV 

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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. 

2.4. 

2.5. 

2.6. 

3. 

3.1. 

3.2. 

4. 

The underlying drivers of the problem .......................................................................19 

State of implementation of the legal framework ........................................................19 

How would the problem evolve, all things being equal?............................................20 

Right to act and subsidiarity .......................................................................................20 

OBJECTIVES.............................................................................................................22 

General, specific and operational objectives ..............................................................22 

Consistency of the objectives with other EU policies and horizontal objectives .......22 

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 exposure limits and partial exemptions" 24 

4.1.4.  Policy option C2: "New Directive with revised exposure 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 

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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.......................................................................................................28 

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 Directive 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: "New Directive with revised exposure 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: "Voluntary 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. 

7. 

8. 

COMPARING THE OPTIONS..................................................................................39 

MONITORING AND EVALUATION ......................................................................42 

ANNEXES..................................................................................................................43 

Annex 1Second stage of consultation of the social partners on the protection of workers from the 
risks related to exposure to electromagnetic fields at work ......................................................44 

Annex 2 Current legislative situation 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 

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Annex 7 Questions (without additional comments and original layout) of the questionnaire on 
health, socio-economic and environmental impacts 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 

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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 Functioning 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 the general public using cellular phone, living close to high power 
lines or passing through metal 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  Magnetic  Resonance  Imaging  (MRI).  The  health  consequences  of 
overexposure can be of different kind depending upon the intensity and 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  defined.  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  nervous  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  between  the  magnet  and  the 
metallic object. 

The issue of protecting workers exposed to EMF was already dealt with at EU level in 2004 with 
the adoption of directive 2004/40/EC1 of the EP and the Council. 

Very  rapidly  it  appeared  that  the  directive,  and  in  particular  the  adopted  binding  exposure  limit 
values,  would  create  major  implementation  problems  and  would  even  impede  some  essential 
medical procedures and related research in cutting edge medical applications such as MRI.  

The question became critical as the deadline for transposition of the directive by the Member States 
was  getting  closer.  The  Commission  postponed  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, some physics are required here: interactions 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 electromagnetism (for electrically charged particles). 

1 

2 

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  arising  from  physical  agents 
(electromagnetic  fields)  (18th  individual  Directive  within  the  meaning  of  Article  16(1)  of  Directive 
89/391/EEC). OJ L 184, 24.5.2004, p. 1. 
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) 

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The interaction forces of electrically charged particles with other charged particles in their vicinity 
is  materialised  by  an  attracting  or  repulsive  force  due  to  their  presence  (electric  field)  and  an 
additional  attractive  or  repulsive  field  when  they  are  in  movement  (magnetic  field).  Each 
electromagnetic  force  is  characterized  by  its  intensity  and  its  wavelength  and  related  frequency. 
Both properties have a direct influence on the human body. 

In the scientific literature, the non-ionising and ionizing radiation spectrum is divided as follows: 

(1) 

(2) 

(3) 

from 0 Hertz to 300 billion Hertz (GHz), the scientists talk about electromagnetic fields and 
radiation (EMF). This is currently covered by Directive 2004/40/EC; 

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. 

From there onwards, we are entering the domain of the ionizing radiation: the frequencies 
are  becoming  even  higher  and  the  characterisation  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. Protection of workers and general public exposed 
to ionizing radiation fall under the scope of the so-called Euratom Treaty. Several directives 
have been adopted in this field in line with the 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). 

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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  workers  to  risks  arising  from  physical  agents  (artificial 
optical radiation) (19th individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC). OJ 
L 114, 27.4.2006, p. 38. 
Frequency (f) and wavelength (λ) are linked by equation λ.f = c where "c" is the speed of light in free space. 
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. 
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. 

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These  different  types  of  radiation  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  exposure  to  electromagnetic  fields.  A  wide  number  of 
human  activities  such  as  transport,  communications,  broadcasting,  industrial  processes,  medical 
applications, etc. are using or are affected by EMF. 

Figure 1 

The various domains of electromagnetic interactions

<<<<<<<lasers>>>>>>

ns
ns DC (0 Hz)

  AC (50 Hz)

plicatio
plicatio
ples of ap
ples of ap
  exam
  exam

Welding

Induction

EAS-RFID

Diathermy

Heating

Security scanners

MRI (0 Hz & gradients)

MRI (RF fields)

Lighting

<<<<<<<<Medical>>>>>>>>

Baggage
Control 

Welding controls

Radio Radio

UMTS

GSM

Radars

Research

Chemistry

Low freq.

Specific areas
Domain denomination
Legal coverage
Frequency range
0 - 100 kHz
Coresponding wavelength up to 3 km

Electromagnetic Radiation from 0 Hz to 300 GHz
Directive 2004/40/EC

> 100 kHz - 300 GHz
3 km - 1 mm

Optical radiation
Directive 2006/25/EC
> 300 GHz - 30 EHz
1 mm - 10E-2 nm

Ionizing radiation
Directive 96/29/Euratom
> 30 EHz - > 3 YHz
λ: 10E-2 nm - 10E-7 nm

Radio frequencies and higher

IR

Visible

UV

X-Rays

Gamma Rays

NB: the location of the various applications in the frequency domains is indicative.

With 3 existing directives EU legislation covers the 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 accepted principles and values. 
For ionizing radiation, the internationally accepted recommendations are established by ICRP, the 
International Commission for Radiation Protection7 created in 1928. ICRP develops, maintains and 
elaborates  the  International  System  of  Radiological  Protection  used  worldwide  and  which  has 
served as basis for  directives 96/29/Euratom and 97/43/Euratom referred to in point  3 above. For 
non  ionizing  radiation  (see  points  1.and2.  above),  and  in  particular  in  the  area  of  concern  of  this 
report, the internationally accepted recommendations are established by ICNIRP, the International 
Commission for Non Ionizing Radiation Protection, a daughter organization of ICRP. The members 
of  the  ICNIRP  main  commission  and  of  the  specialized  working  groups  are  selected  for  their 
notoriety in their domain. They are elected for a limited number of years. ICNIRP intends to work 
independently according to strict internal rules and 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  international  standards  which  are  underlying  the 
principles and limits of our directive. 

7 
8 

More details on www.icrp.org  
More details on www.icnirp.org 

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For EMF, the situation is less monolithic: outside the EU9, some well developed states (including 
Japan,  New  Zealand,  South  Africa,  etc.)  are  making  reference  to  the  ICNIRP  recommended  limit 
values,  the  so-called  “basic  restrictions”  which  have  also  been  taken  as  reference  when  drafting 
Directive  2004/40/EC.  Sometimes  they  do  so  only  for  a  limited  range  of  the  EMF  frequency 
domains, neglecting for instance frequencies below 3000 Hz. In Australia, whilst using the ICNIRP 
recommendations,  some  local  peculiarities  are  being  developed.  In  those  countries,  the  values  of 
ICNIRP  are  not  binding  or  only  partially  binding  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  (radiofrequencies).  For  long 
term effects most countries do not have any restrictions for workers’ exposure because of the lack 
of clear evidence for the current levels of exposure11. 

1.1.3.  Organisation and timing  

In order to allow the Commission to explore new possibilities 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 results 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 the 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 Consultations linked to the launching of the first and second stages of 
the consultations of the social partners according 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  recommendations.  Taking  these  into  account  the 
following main changes were introduced in the document: 

a) 

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12 

a more comprehensive and concrete description of the new exposure limits system which is 
an integral part of Option B and C1 (section 4 and annex 3), 

Source: World Health Organisation (WHO). 
IEEE: Institute of Electrical and Electronics Engineers; http://www.ieee.org/ 
SCENIHR opinions (2009) 
http://ec.europa.eu/health/archive/ph_risk/committees/04_scenihr/docs/scenihr_o_024.pdf and 
http://ec.europa.eu/health/archive/ph_risk/committees/04_scenihr/docs/scenihr_o_007.pdf  
Directive  2008/46/EC  of  the  European  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 individual Directive within the meaning of Article 16(1) of 
Directive 89/391/EEC). OJ L 114, 26.4.2008, p. 88–89. 

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b) 

c) 

d) 

a revision of the section relating to the analysis of impacts for each option (section 5), 

a refocusing of the problem description and, consequently, an adjustment of the objectives, 

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)  took  place  between  1  July  and  10 
September 2009. 

The Commission received 16 replies to this consultation (12 from employers' organisations and 4 
from  workers'  organisations).  Most  of  the  contributions  were  from  European  Organisations  (10 
employers;  3  workers);  three  replies  were  received  from  national  organisations  (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 Directive 2004/40/EC sufficient for the health and safety of workers 
exposed to electromagnetic fields during their work?" 

2  "Do  you  consider  that  a  Community  initiative  is  the  best  way  to  ensure  a  high  standard  of 
protection of workers exposed to electromagnetic fields?" 

3 "Do you think that certain categories of workers should be excluded from the scope of any future 
Community  initiative  because  of  reported  implementation  problems  (e.g.  medical  procedures 
involving MRI) with some provisions (exposure limit values) of Directive 2004/40/EC?" 

4  "Would  you  find  non-binding  measures  such  as  the  production  of  good  practices  guides, 
launching  of  regular  information  campaigns,  setting-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  initiative  cover  the  long  term  effects  of  workers'  occupational 
exposure to electromagnetic fields?” 

The outcomes of the first consultation can be summarized as follows:  

•  In  general,  both  trade  unions  and  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 there were also some representatives (SMEs and 
national organisations) which indicated their preference 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 define new exposure limit values seemed to be an acceptable approach 

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(except for the healthcare sector), provided that they are "practicable", "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 directive might be set too low 
and based on too conservative assumptions; but while the employers were in favour of relaxing 
the  limits,  the  workers  representatives  required  to  include  the  long  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 equipment manufacturers). Also, allowing derogations to 
exposure limits to specific sectors (healthcare) posed some problems for the industry. 

•  Developing  non  binding  instruments  was  welcomed  by  all  contributors  independent  of  a  new 

directive. 

A second stage of consultation of the 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  potential  changes  were  proposed.  These  suggestions  corresponded  very  much 
with the options analysed in this impact assessment with the exceptions that a "no change" option 
was  not  discussed  as  the  social  partners  had  already  expressed  their  views  on  this  in  the  first 
consultation.  On  the  other  hand,  considering  a  "complete  repeal  of  the  directive"  option  was 
irrelevant in this specific 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 summarized as follows for each of the 9 areas proposed 
for change: 

1  Coverage of all sectors of activity 

Table 1 

  All  stakeholders  confirmed  that  no  category  of  workers  should  be  excluded  from  the 
benefits  of  a  legal  instrument  provided  that  the  instrument  gives  the  appropriate 
flexibility to continue with activities.  

2  Due flexibility in a controlled working environment 

To facilitate the continuation and development 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 workers if not strictly controlled. 

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Practicable" and "inspectable": these words have been used by some stakeholders during the various contacts 
with  them.  "Practicable"  needs  to be understood  in  the  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 immediate and comparable results. 

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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 scientific recommendations, some relaxation of the “old” limits 
may be envisaged without reducing the protection of the workers in real terms. While the 
industry is strongly in favour of such relaxation, workers express some concerns, because 
they are afraid that new limits may be chosen 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 compulsory risk assessment (imposed by framework 
directive 89/391/EEC). 

5  Measurements and calculations 

The  Commission’s  proposal  is  to  introduce  more  guidance  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 really 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 area 4 is related to this objective. At the end of the day, 
better guidance should limit the costs 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  this  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 idea is to create certain zones (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  assessment  and  for  the  implementation  of  preventive  protective 
measures. More details about this in section 4 "Policy options", in particular, option B. 

EN 

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revisiting the conditions for a medical examination is not controversial. 

8  The  specific  case  of  medical  applications  using  nuclear  magnetic  resonance 

technology 

5-8 % of the medical MRI procedures would not be possible, even with exposure limits 
aligned with the most recent proposals from leading agencies. The Commission proposal 
is to give an exemption from binding exposure limits 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  qualitative  rules  to  ensure  adequate  protection  of 
medical  personnel.  This  causes  some  problems  for  the  employers  of  the  industry  who 
consider this as discrimination. The workers organisations can agree to this approach but 
under the condition that this is limited in time. Innovative design of equipment should in 
future limit the risks of overexposure. 

9  Non binding measures 

The  social  partners  agreed  that  accompanying  non  binding  measures  such  as  raising 
awareness  campaigns,  multiplying  training  courses  and producing  good practice guides 
at national or sectoral levels would be helpful and necessary. 

- 

–  Final question: willingness of the Social Partners to enter into negotiations on the 
basis of the proposals above under the terms of Article 154(4) and Article 155 of 
the Treaty on the Functioning of the EU (TFEU). 

  None of the Social Partners requested to go for this sectoral approach. 

1.2.2.  External expertise 

Next  to  the  formal  consultation  of  Social  Partners  the  Commission  gathered  complementary 
information and expertise by: 

•  numerous 

contacts  with 

their  European 
(BUSINESSEUROPE,  ORGALIME,  CEEMET) and national federations EEF (UK), AGORIA 
(BE),  with  representatives  of  the  SMEs  (UEAPME,  NORMAPME),  with  representatives  of 
standardisation bodies (CENELEC). This enumeration is not exhaustive; 

representatives 

industry 

from 

and 

the 

•  contacts with the scientific community, in particular ICNIRP whose recommendations are used 
worldwide  and  served  as  a  basis  for  the  exposure  limit  values  in  directive  2004/40/EC;  IEEE 
whose  recommendations  are  used  in  the  USA  and  by  NATO15;  DG  SANCO's  committee 
SCENIHR16; 

•  for  the  specific  case  of  MRI,  regular  contacts  in  dedicated  working  groups,  one  with 
representatives  of  ESR17  (MRI  practitioners)  representing  also  ESMRMB18  (MRI  medical 

15 
16 

17 
18 

EN 

Scientific  Committee 

NATO: North Atlantic Treaty Organization; http://www.nato.int/ 
SCENIHR: 
http://ec.europa.eu/health/scientific_committees/emerging/index_en.htm 
ESR: European Society of Radiology; http://www.myesr.org 
ESMRMB: European Society for Magnetic Resonance and Medical Biology; http://www.esmrmb.org/ 

and  Newly 

Emerging 

Identified 

on 

health  Risks; 

13 

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research) and Alliance for MRI (MRI patients association) and a second one with representatives 
of COCIR19 (MRI equipment manufacturers);  

•  regular  contacts  with  the  social  partners  and  government  representatives,  formalised  through  a 
working  party  mandated  by  the  Advisory  Committee  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 mandate 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 developments and new recommendations, in particular 
from ICNIRP and IEEE. WHO and NATO experts were also invited and consulted. 

In  2007,  DG  EMPL  selected  a  contractor  to  carry  out  a  comprehensive  investigation  into 
occupational  exposure  of  workers  performing  medical  MRI.  This  study20  which  was  done  in 
cooperation  of  ESR  (selection  of  and  facilitation  of  access  to  representative  MRI  facilities  and 
selection of worst case scenario 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  carried  out  by  a  consortium22  to  provide  the  European  Commission  with 
detailed analysis of the potential health, social and economic impacts of a number of policy options. 
The  study  also  took  into  account  the  input  from  various  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 governmental representatives in the EMF Working Part 
of the Advisory Committee on Health and Safety at Work. 

In October 2009, the Swedish Presidency organised a 3 day conference23 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 

20 

21 

22 

23 

COCIR:  European  Coordination  Committee  of  the  Radiological,  Electromedical  and  Healthcare  IT  Industry; 
http://www.cocir.org/ 
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. 
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 fields)". Final report: September 2009. 
"FICETTI  Consortium":  Main  Contractor:  Finnish  institute  of  Occupational  Health;  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). 
Occupational Exposure to Electromagnetic Fields: Paving the way for a future EU initiative; 6-8 October 2009, 
Umeå University, Sweden. 

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2. 

PROBLEM DEFINITION 

2.1.  What is the problem? 

As laid out in the introduction, the issue under discussion is the protection of workers exposed to 
strong electromagnetic fields. Amongst devices which are producing non-ionizing radiation and are 
most  commonly  used  in  the  professional  side,  one  can  mention,  inter  alia,  induction  heating 
installations,  electroplaters,  welding  devices,  crack  detection  equipment,  plasma  etchers,  radio 
frequency sputterers and also the  equipment  used for medical MRI, diathermia and hyperthermia. 
Amongst  particularly  affected  sectors  are  the  electrolysis,  the  induction  heating,  the  welding,  the 
broadcasting,  the  electricity  production  and  distribution  and  the  telecoms  sectors.  Such  radiation 
appears  whenever  there  are  heavy  electric  currents  and/or  very  strong  magnets  at  or  close  to  the 
workplace. 

Uncertainty  still  exists  in  the  international  community  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.  However,  adverse  effects  on 
health  have  been  demonstrated  when  exposure  exceeds  certain  levels.  Depending  where  one  puts 
the reference levels, adverse effects may be disturbing, irritating, painful or really harmful for the 
worker. 

2.2.  Who is affected and how? 

Many categories of workers may be subject to exposure 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 resonance equipment, for example in health 

services; 

•  Those using tape erasing equipment to erase data stored on tapes and other magnetic media; 

•  Those using crack detection equipment for the non-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 then deposits on a substrate (Wikipedia). 

EN 

15 

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•  Those working with Electronic Article Surveillance (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 workers 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 concerned in the EU (table 2). 

Table 2 

Sector 

Workers

Workplaces/assessments 

Electric energy 

Health care 

200,000

211,000

Metal industry 

1,019,000

Telecoms & broadcast 

39,500

Rail 

Other 

Total 

120,000

50,000

1,639,500

Source: stakeholders' information 

3,000 

13,000 

162,140 

11,000 

500 

25,000 

214,640 

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  concerns  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 characteristics of the exposure: 

•  Static fields, low frequency fields or high frequency fields, pulsed or sinusoidal (frequency and 

type of wave factors) 

•  High or low intensities (power factor) 

•  Long or short exposure times (time factor). This factor will however not be considered here as 
science  currently  confirms  the  situation  prevalent  in  2004,  i.e.  that  there  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  effect  materialised  by 

25 

A  more detailed  list  has been  established by  the  National  Radiological Protection  Board  (UK): NRPB  R265 
and NRPB-W24.  

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electrical  currents  in  the  body.  At  certain  levels  these  effects  may  become  harmful.  At  very  high 
levels there will be an impact on the blood circulation. This effect does not seem to be significant 
with  the  currently  used  static  fields.  Other  effects  have  been  reported  when  in  presence  of  heavy 
static fields: vertigos, metallic taste, headaches. 

Another (safety) effect linked to the presence of strong static magnetic fields is the attraction power 
of any ferromagnetic object inadvertently 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  the  hand,  the  latter  will  be  attracted  away  and 
immediately fly like a bullet into the core of the magnet. If a patient is present in the machine or a 
worker close to the machine at that moment, the consequences will be a severe injury or even fatal. 

In the low frequency range above 0 Hz up to 100 kHz the main effect is peripheral 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  disappears  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  called  magnetophosphenes  and  can  obviously  reduce 
worker’s attention. 

In the frequencies higher than 100 kHz, the main effect of radiation is burns, internal or external. 
This  effect  is  much  more  tangible  than  the  previous 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  number  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  latest  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 relate to former guidance but also to publications 
relating  to  modelling  and  literature  review  on  the  subject.  In  the  BMAs  approach  referred  to  in 
section  1.2.2.,  and  explained  in  the  "Forschungsbericht  400:  Elektromagnetische  Felder  am 
Arbeitsplatz"  –  Abschlussbericht  (March  2010),  110  references  are  used  and  the  number  of  new 
studies is similar. Unfortunately, reports 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 

Safety problems: uncontrolled 
attraction of ferromagnetic 
metals 

Electrochemical processes 

Health problems: vertigos, 

26 

Order of magnitude of the terrestrial magnetic field strength: 50 microTesla (0.5 Gauss). 

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17 

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50 Hz 

High  power  lines;  Production 
and distribution of electricity; 

Welding 

100 Hz -10,000 kHz 

Magnetic resonance technology 
(gradient fields) 

metallic taste feeling, 
headaches 

Headaches, 
magnetophosphenes, 

Unwanted effects on the 
peripheral nervous system 

Effects on the nervous system 

Burns 

Electric welding 

Industrial induction heating 

AM-radio 

Industrial induction heating 

AM-radio 

Plastic welding 

Dielectric pressing 

Induction hardening 

FM-radio 

Wood processing 

Thermal stress 

TV 

Diathermia 

GSM 

Dielectric vulcanizing 

9 kHz - 

30 kHz -  

300 kHz -  

3 MHz -  

300 MHz -  

3 GHz -  

Anti-Theft protection systems 

Radars 

Satellites  
(communication with) 

Burns and 

thermal stress 

30 GHz - 

Transmission  of  digital  and 
analogue video signals 

Source: AGORIA (BE) good practice guide 

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2.3. 

The underlying drivers of the problem 

As  indicated  in  section  2.2.,  recent  research27  indicates  that  Directive  2004/40/EC  is  stricter  than 
necessary in the sense that there is no room for flexibility or proportionality. Since the publication 
of  the  recommendations  of  the  International  Commission  for  Non-Ionizing  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  used  without  exaggerated  compliance  costs  whilst 
still guaranteeing appropriate protection of workers 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 "Policy 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  illegal.  This  is  undesirable,  because  the  use  of 
MRI has many advantages for patients: the technique enables diagnostic 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 medical 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,  currently  due  for  30  April  2012.  Several  countries  (FI, 
AT, UK, CZ …) informally indicated their intention 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  relying  on  existing  non  binding  rules  (including 
the  ICNIRP 
recommendations) as practical reference. All Member 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 
legislation 
covering exposure of workers to EMF in 
place before Directive 2004/40/EC 

specific 

AT, BG, CZ, DE, EE, FI, LV, LT, LU, NL, PL, 
PT, SE, SK, SP 

Countries without specific 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: Guidelines for limiting exposure to time-varying electric and 
magnetic fields (1 Hz to 100 kHz): to be published in December 2010. 

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Countries having issued (additional) non 
binding recommendations 

AT, IT, PL, UK 

Countries  for  which  the  Commission 
already  received  a  notification  of  new 
national 
transposing 
Directive 2004/40/EC 

legislation 

AT, EE, LV, LT, IT, CZ, SK (all have delayed 
the entry into force until 30/04/2012) 

The outcome of the review carried out by the FICETTI contractor shows: 

•  that all Member States rely on ICNIRP guidelines. 

•  that Member States do not make differences between sectors but between frequency ranges. The 
radiofrequency  range  is  often  considered  in  detail  and  the  low  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  and  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 majority 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  States  will  have  to  transpose  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  implementation  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  shall  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 
29 

http://www.who.int/docstore/peh-emf/EMFStandards/who-0102/Europe/europe5.htm 
see the glossary 

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20 

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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 dealing with specific risks, one may find directives on 
the protection of workers exposed to: noise, vibration, chemical agents, biological agents, asbestos, 
manual handling of loads, etc. 

On adoption of Directive 2004/40/EC, the Commission, 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  directive  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 possible distortions of competition".  

Currently the Commission does not see any new evidence 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. 

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21 

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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 health and the safety of 
the workers. As indicated above there is a comprehensive 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 ensure adequate protection of workers 
exposed and to present the most appropriate solution to protect them without unduly impeding on 
the use and development of industrial activities and medical techniques (as the current instrument 
directive  2004/40/EC  does)  and  without  imposing  disproportionate  burden  on  enterprises,  in 
particular SMEs.  

Consequently because of these somewhat conflicting 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 increase consistency of implementation.  

3.2. 

Consistency of the objectives with other 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  for  improving  quality  and  productivity  at  work 
(COM(2007)62).  

Taking  account  of  the  above,  and  the  latest  scientific  evidence  on  the  subject  reassessing  the 
situation  is  fully  justified.  DG  SANCO  is  reviewing  the  situation  on  a  regular  basis  –  lastly  in 
January 2009 - through SCENIHR (see 1.2.2) and the fact that the international leading authorities 
in the matter are reviewing their recommendations is consistent with this approach. 

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4. 

POLICY OPTIONS 

4.1. 

Policy options analysed in detail 

The  outcomes  of  the  first  consultation  document  for  the  Social  Partners  and  the  supporting  work 
carried  out  by  an  external  contractor  have  suggested  to  operate  around  an  initial  set  of  7  broad 
options. This spectrum of options was also supported by stakeholders. Consequently all of them are 
considered  in  this  impact  assessment.  Nevertheless,  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 that Directive 2004/40/EC has to be transposed by 30 April 2012 into 
legislation  in  all  the  Member  States.  The  existing  controversial  exposure  limits  become  binding 
limits. To achieve compliance employers will be required to take actions based on workplace risk 
assessments and in the context of rules considered to be too conservative. 

Directive  2004/40/EC  foresees  that  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 field, 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  measures  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 effect 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 protection 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  Directive  are  replaced  with 
new,  more  practicable,  exposure  limit  values  based  on  latest  international  recommendations.  This 
revision of limit values has become possible as research has shown that the safety factors between 
observable physiological reactions 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  extremely  low  frequency  (ELF)  range  published  by  ICNIRP 
during the last quarter of 201032, b) the "IEEE Standard for Safety Levels with Respect to Human 
Exposure  to  Radio  Frequency  Electromagnetic  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  proposal  referred  to  in  1.2.2.  (last  paragraph)  and  2.3.  For  the 
concrete  development  of  the  new  system  a  combination  of  ICNIRP  and  BMAs  will  be  used.  The 

31 
32 

In Directive 2004/40/EC, this reference level is called the "action value". 
The new recommendations were officially released on www.icnirp.org on 25 November 2010. 

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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 new 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 flexibility and proportionality in the low frequency range where most of the 
implementation problems are. 

The most significant characteristics of this new system can be found in annex 3. They concern the 
low frequency range. For the high frequency range the 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  activities  will  be  exempted  from  the  requirement  to  comply  with  the 
exposure  limit  values  of  the  new  Directive,  but  will  still  remain  subject  to  the  other  provisions, 
including EMF risk management requirements. Employers shall put in place protective measures to 
prevent direct  or  indirect health  risks  from  EMF  for  workers.  Indirect risks,  being e.g. risks from 
ferromagnetic projectiles or interference with implanted medical devices.  

This  option  implies  a  differential  treatment  of  the  MRI  workers.  This  has  advantages  in  terms  of 
facilitating  technological  progress  (e.g.  medical  devices),  economic  development  and  of  enabling 
high  quality  health  care  (MRI);  but  it  has  also  the  disadvantage  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,  maintenance  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) activities would conflict with the revised limit values it would be 
possible  for  the  Member  States  to  allow  for  exemptions  from  the  limit  values  under  strictly 
controlled conditions. Such exemptions would 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 amending the "medical devices" directive. This is 
not the scope of the Directive. 

In  order  to  ensure  the  effectiveness  of  the  protection  of  workers  in  the  MRI  domain,  reinforced 
qualitative  measures  will  be  addressed  in  an  annex  of  the  new  directive.  The  proposed  measures 
which were already included in the second stage consultation document adopted by the Commission 
in July 2010 are: 

–  reinforced information measures; 

–  reinforced training of workers; 

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–  documented  and  practicable  working  procedures  favouring  exposure  limitation  whenever 

possible; 

–  strict administrative procedures 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.  The  organisation  of  these 
consultations  would  be  streamlined  in  the  directive  itself  (scope,  implementation,  monitoring  and 
deadlines). 

4.1.4.  Policy  option  C2:  "New  Directive  with  revised  exposure  limits  and  complete  exemptions 

for some activities" 

New exposure limit values based on the latest international 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 directive 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 are very rare and specific (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 
replaced  by  non-binding  occupational  EMF  exposure 
recommendations,  based  on  the  latest  international  recommendations.  The  form  of  these 
recommendations would be similar to the 1999 Council Recommendation on EMF exposures of the 
general public. 

is 

4.1.6.  Policy option D2: "Voluntary social partners' agreements" 

The  EMF  Directive  is  replaced  by  a  set  of  voluntary  agreements  at  European  or  sectoral  level 
between social partners according to the provisions of Article 154.4 of the TFEU. This possibility 
has  not  been  invoked  by  any  of  the  social  partners  participating  in  the  consultations  referred  to 
under section 1.2.1. 

4.1.7.  Policy option E: "no EU legislation" 

Directive 2004/40/EC is withdrawn (repealed) while directive 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 cooperation 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  

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25 

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which  have  already  (partially)  implemented  the  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  provision  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, addresses risks by covering all categories of workers. There are 
very few exceptions such as mining and drilling activities and for which the specific risks have been 
addressed in a specific manner in separate 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 recognizing that these directives are essential tools to protect workers, 
their provisions are not sufficiently comprehensive to ensure the protection at the workplace. This 
has been often demonstrated in the past: for instance Directive 94/9/EC of the European Parliament 
and  the  Council  of  23  March  1994  on  the  approximation  of  the  laws  of  the  Member  States 
concerning  equipment  and  protective  systems  intended  for  use  in  potentially  explosive 
atmospheres34 was complemented by Directive 1999/92/EC of the European Parliament and of the 
Council  of  16  December  1999  on  minimum  requirements  for  improving  the  safety  and  health 
protection  of  workers  potentially  at  risk  from  explosive  atmospheres  (15th  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 the 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 States 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 chosen. In so far it was not looked at separately. 

34 
35 
36 
37 

OJ L 100 of 19.04.1994, p.1 
OJ L 23, 28.1.2000, p. 57–64 
OJ L 393, 30.12.1989, p. 18–28 
OJ L 399, 30.12.1989, p. 18–38 

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5. 

ANALYSIS OF IMPACTS  

5.1. 

Starting point for the analysis of impacts 

The  following  sections  attempt  to  identify  and  analyse  the  potential  social  and  economic  impacts 
and their importance for each option. As regards social impacts a special attention is given to the 
impacts  on  workers'  health  as  they  are  directly  linked  to  the  objectives  of  the  initiative.  The 
economic impacts considered in the analysis are mainly compliance costs and potential impacts on 
competitiveness.  

Wherever possible an attempt has been made to quantify the impacts of the various policy 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 stakeholders indicated that environmental impacts are not likely. Per 
definition exposure to electromagnetic fields is limited 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 workers are exposed during their work. 

5.1.1. 

Social impacts 

Potential negative health effects of exposure to EMF range from direct effects (headache, vertigos, 
unwanted  nerve  stimulation,  burns)  to  indirect  effects  (loss  of  attention  or  injury  due  to  the 
attraction of a metallic object by a strong magnet). Three specific aspects were addressed for each 
option: 

•  Overexposures 

•  Worker concern 

•  Wider social consequences (availability of MRI, employment, public concern about EMF) 

Overexposures 

Documented overexposures, exceeding the physiological 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  immediate  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 workers wearing a medical implant:  

a) 

Pregnant  workers  must  be  considered  as  “sensitive  workers”  for  two  reasons:  one  is  that 
pregnant women, especially in the final trimester, may have an impaired thermoregulatory 

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ability,  making  them  potentially  more  sensitive  to  the  thermal  effects  of  exposure  to 
radiofrequencies.  The  other  issue  is  the  status  of  the  foetus;  there  is  a  question  as  to 
whether  it  should  be  exposed  at  the  occupational  or  at  general-public  EMF  limits. 
Obviously  this  has  an  implication  for  the  exposure  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 current EMF Directive has a clear requirement 
that  specific  assessments  are  done  to  determine  the  extent  to  which  the  access  of  such 
people should be controlled. CENELEC has produced assessment standards specifically to 
facilitate this. 

Worker concern 

While keeping in mind that employers should undertake specific EMF risk assessments even in the 
absence  of  explicit  legislation  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  refrain  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  subsequent additional  health care costs to be borne by 
the collectivity. 

b) 

c) 

Employment:  A  very  strict  legal  situation  might  restrict  economic  activities  and  by  that 
have negative impacts on employment. 

Public  concern  about  EMF:  In  many  countries,  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 effects 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 comparing the options in section 5.2 and 6.1. 

5.1.2.  Economic impacts 

Following main effects have been considered for comparing the options: 

•  effect on competitiveness of European businesses  

38 

all words and acronyms followed by * can be found in the glossary 

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28 

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•  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  will  ensure  a  higher  homogeneity  of  the  legal 
instruments  relating  to  workers  exposed  to  EMF.  This  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 mobility of skilled workers becomes easier.  

However,  too  restrictive  requirements,  in  particular  too  conservative  exposure  limit  values  could 
hinder economic activity and in so far reduce competitiveness and growth of Europe.  

Effects on competitiveness of European businesses compared to those outside the EU 

There  is  likely  to  be  an  impact  on  some  exporting  sectors,  especially  for  options  with  strict 
requirements  MRI  equipment  producers  might  lose  the  competitive  edge  in  MRI  equipment 
production.  North  America  and  Japan  would  probably  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  electrolysis,  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  assess  quantitatively  which  impact  it  could  have  for  the  employment 
numbers as the effects would be subtle and in many cases EMF legislation is only one factor among 
several which are relevant for location decisions. In terms of quality 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,  rather  than  a  general 
safety requirement or a sector-specific voluntary agreement as it would be the case in options D1, 
D2  and  E.  Clear  limits  provided  by  an  external  (and  perceived  as  independent)  authority  are 
considered  as  a  convincing  way  to  fulfil  employers'  responsibilities  in  a  transparent  manner. 
Examples of court cases exist where employers had to bear judicial costs which exceeded by far the 
costs of an effective risk assessment showing compliance 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 undertaken 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 

EN 

Table 5 

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Employer's obligations 

Action 

1. 

Awareness raising 

Familiarisation  with 
legislation, 
recommendations  or  sectoral  agreement  related 
to occupational exposure to EMF 

existing 

2. 

3. 

4. 

5. 

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 

Provisions  aimed  at  avoiding  or 
reducing risks  

Introduction of protective measures to eliminate 
or 
(e.g. 
reduce  workers'  EMF  exposure 
shielding,  warning  signs)  or  changes  in  work 
practice 

Worker information and training  Providing training to concerned workers on safe 

work procedures 

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,  electric  welding,  induction  heating,  surgical  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  components  of  the  equation,  i.e.  the  number  of  workers 
concerned  and  the  number  of  workplaces  to  be  assessed  were  directly  derived  from  stakeholders' 
assumptions.  There  are  probably  underestimated.  However,  as  the  number  of  workers  and 
workplaces remain constant across the options, the overall 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 costs 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  strongly  depend  on  the  labour  cost  in  each  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 sectors and professions 

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was calculated by EUROSTAT at 16.13 €. In the FICETTI report the average labour cost used in 
the calculations was 18.75 € per hour. Stakeholders considered this a reasonable estimate.  

Compliance  costs  are  for  most  parts  one-off  costs,  unless  the  workplace  undergoes  substantial 
technical  or  working  procedures  changes.  Still  some  costs  may  contain  a  part  of  recurrence  if 
deemed  necessary  by  the  Member  State  or  the  employer  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 requirements 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  cost  derived  from  the 
interviews  during  the  case  studies in  particular  countries  were  therefore  maintained  as  a  basis  for 
the  consolidated  overall  figures.  Other  inputs  to  the  analysis  include  the  numbers  of  workers  and 
assessments  that  are  needed  in  each  sector.  More  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 approach included estimated figures for 
preventive/protective  "hardware".  Both  data  enabled  to  reinforce  confidence  in  the  model  and  of 
this impact assessment. 

Impacts on SMEs 

The  opinions  of  SMEs  and  microenterprises  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  that  the  costs  for  risk  assessments  and  measurement  surveys  as 
requested  by  Directive  2004/40/EC  might  be  too  high.  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 procedure 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 simple and short guidance documents (checklist type) 
will  thereby  be  needed  for  whichever  option  will  be  chosen.  Equipment  labelling  and  better 
manufacturer  information,  which  might  facilitate  to  identify  those  situations  in  which  no  detailed 
assessment will be required, would also be helpful. 

The impact of the relatively high 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 dangerous chemical substances, potentially explosive 
atmospheres, exposure to physical agents such as EMF, asbestos, etc.) generates 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 

40 

Draft UK Cost-benefit analysis: proposal for a physical agents directive on electromagnetic fields, July 2010, 
HSE UK. 
Electromagnetic  fields  in  the  working  environment,  June  2006,  Ministry  of  Social  Affairs  and  Employment, 
the Netherlands. 

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these costs may be seen as negative for the SMEs at first glance but should, at the end, guarantee 
better working conditions and less workers' absenteeism.  

The  high  level  group  "High  Level  Group  of  Independent  Stakeholders  on  Administrative  Burdens"  (Stoiber 
group)41  has  identified  the  current  obligation  for  SMEs  to  document  the  outcomes  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  situation  which  concerns  all  risks 
addressed  by  EU-OSH  legislation.  A  study  will  be  launched  in  2011.  Moreover,  the  European 
Occupational Health and Safety Agency in Bilbao is currently developing, in close cooperation with 
the Commission and stakeholders 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  costs  related  to  the  issue  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  administrative  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 legislative act is adopted by 
then. 

As  far  as  health  impacts  are  concerned,  workers  exposed  to  EMF  will  be  very  well  protected. 
Special  groups  (pregnant  women  and  workers  with  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 workers' information and consultation takes place, 
workers' concerns should also be very limited. 

Nevertheless in terms of wider social consequences, there are also negative impacts expected. A UK 
MRI expert recently confirmed44 that at least 3.5% of current MRI procedures would be impossible 
under  this  option.  More  importantly,  there  might  be  a  slowdown  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 conclusions with 6 to 8 % of the current 8 to 10 
million  MRI  procedures  per  year  in  the  EU  becoming  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 restrictions could lead to an increase 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 costs of such a potential shift from MRI to CT. 

41 

42 
43 
44 

http://ec.europa.eu/enterprise/policies/better-
regulation/files/hlg_opinion_working_environment_09052009_en.pdf 
OIRA: Online Interactive Risk Assessment :http://www.oira.osha.europa.eu/front-page-en 
Framework directive 89/391/EEC requires that the risk assessments be documented. 
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.  

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Their  calculations  indicate  that  the  additional  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  optimisation,  giving  a  total  annual  cost  of  the  increased  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 approximately additional 175 M Euros to be borne by the 
EU public community (taxpayers). That means a transfer 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 would only be necessary for a limited number of 
activities (e.g. induction heating, electrochemical processes) with other options. This increases the 
overall implementation costs. If option A leads to a situation where compliance measures would be 
much  stricter  than  in  competing  countries,  delocalisation  of  workplaces  might  be  a  consequence. 
The one-off costs (see 5.1.3.) under option A have been estimated as follows45: 

Generic costs 

Sectoral/activity specific costs 

Training 

Administrative costs 

Total (M€) 

111.7 

548.0 

0.500 

0.124 

660.3 

As  regards  the  costs  of  the  possible  application  of  Directive  2004/40/EC  (option  A),  estimates  of 
costs  at  national  level  were  established  by  Great  Britain  and  the  Netherlands  at  the  time  of  the 
adoption of the directive. According to the British estimates which 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 implementation 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 first year is because national law imposes regular reviews of the 
working conditions and consequently of the risk assessments. 

5.2.2. 

Impact of policy option B: "New Directive with revised exposure limits" 

This option is equivalent to option A in terms of the protection of workers. Exposure limits are for 
all workers in line with up-to-date scientific recommendations. 

45 

46 

47 

All  costs  have  been  established  by  DG  EMPL  on  the  basis  of  FICETTI  data  and  additional  information 
received from stakeholders. 
Draft UK Cost-benefit analysis: proposal for a physical agents directive on electromagnetic fields, July 2010, 
HSE UK. 
Electromagnetic  fields  in  the  working  environment,  June  2006,  Ministry  of  Social  Affairs  and  Employment, 
the Netherlands 

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Moreover  this  option  is  also  beneficial  for  the  particularly  sensitive  groups.  In  option  B,  workers 
who have declared themselves to be part of one of these groups should 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 implementation the protection levels 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 completely avoided. A comparison of the results of 
the  Commission  study  on  MRI  (see  1.2.2)  with  the  BMAS  values  and  the  recently  published 
ICNIRP recommendations shows that overexposure still 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 negative 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  conservative  reference  levels  (action  values)  and  of  more 
proportionality the compliance costs are lower than for Option A, and amount to: 

Generic costs 

Sectoral/activity specific costs 

Training 

Administrative costs 

Total (M€) 

111.7 

414.6 

0.500 

0.124 

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  would 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 
49 

CENELEC guidance in preparation. 
MRI workers indicated during the consultations of the social partners that they are willing to work under the 
conditions foreseen under C1. 

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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 

Sectoral/activity specific costs 

Training 

Reinforced qualitative measures for MRI 

Administrative costs 

Total (M€) 

111.7 

385.1 

0.500 

14.25 

0.124 

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  exposure  to  EMF,  it  is  considered  that  this 
approach  would  undermine  the  credibility  of  the  protection  system  and  send  a  couterproductive 
message to the international community. This opinion 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 therefore be equivalent to the impacts of Option 
B. 

In option C2 workers involved in the MRI activities would be excluded from the scope of directive. 
Unless  decided  differently  by  the Member  States,  this  option  would  –  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 slightly lower. Considering the small amounts involved this has only a 
marginal importance: 

Generic costs 

Sectoral/activity specific costs 

Training 

Administrative costs 

Total (M€) 

111.7 

385.1 

0.500 

0.124 

497.4 

50 

This is with the assumption that only medical MRI is removed from the scope. 

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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  recommendation  would  create  or  maintain  competitiveness 
differentials.  For  MRI  implementation  this  would  not  create  difficulties  but  the  objective  of 
guaranteeing a high level of protection across all the EU installations may not be attained because 
of  the  lack  of  generalised  reinforced  qualitative  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 

Sectoral/activity specific costs 

Training 

Administrative costs 

Total (M€) 

39.4 

397.1 

0.500 

0.124 

437.1 

The  figure  reflects  the  effect  of  the  patchwork  situation  which  may  occur.  The  reduction  of  the 
generic costs reflects the fact that risk awareness 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  consultation  of  the  social  partners  neither  trade  unions  nor 
employers' organisations gave an indication of preferring such a solution. Both groups see this as an 
issue to be regulated on the European level. However 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 Member State the level of protection of workers would 
not be equivalent in different sectors and the verification of the effectiveness thereof would be more 
difficult for independent experts and labour inspectorates. 

This would also create confusion for workers' and provoke public concern. Moreover it would be 
more difficult for employers to demonstrate that they fulfilled their responsibilities as regards the 
protection of workers in case of judicial proceedings. 

Costs have been estimated in the order of:  

Generic costs 

Sectoral/activity specific costs 

Training 

Administrative costs 

22.5 

397.1 

0.500 

0.124 

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Total (M€) 

420.2 

This estimate is less reliable than those for options A, B and C because of the uncertainties on the 
generic costs. It should reflect the differential approaches for carrying 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  impacts,  abstaining  from  any  European  level  action  on 
EMF  would  reduce  significantly  the  attention  paid  to  the  risks  of  EMF  and  would  have  negative 
impacts on workers' health and working conditions. Moreover it may raise public concern as the EU 
would provide guidance for exposure of the public but not anymore for workers exposed to higher 
risks. Consequently the protection of workers exposed 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 the 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  expected  to  have  counterproductive  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  and  effort  to  identify  risks  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 

Sectoral/activity specific costs 

Training 

Administrative costs 

Total (M€) 

76.3 

397.1 

0.500 

0.124 

474.0 

5.2.8.  Variability of costs across Member States and options 

The relevance of comparing compliance costs for each option, by size 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,  wireless  communication)  across  numerous  industrial 
domains. On the other hand you may also have several 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  such  cases,  the  costs  for  preventive  and  protection 

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37 

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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 variability of costs 
at company level will end up with a wide bunch of dispersed points on a graph and 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) the 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 protective measures is significant 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 for the Member State concerned.  

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6. 

COMPARING THE OPTIONS 

Whatever the option, benefits cannot be described without difficulty. Benefits on health can only be 
stated by the fact that below the current 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  carried  out  under  point  5.2  can  be  summarized  as 
follows.  

Table 6 

Protection 
against 
overexposure 

Workers  concern 
taken 
into 
account 

Wider 
impacts 

social 

Economic 
impacts 

Option A 

Achieved 

Achieved 

Option B 

Achieved 

Achieved 

+

Compliance 
administrative 
costs 

660.3 

526.9 

511.7 
Costs for MRI 
reinforced 
measures 
included 

497.4 

6-8% 
MRI 
take 
cannot 
place,  estimated 
costs  of  172  Mio 
Euro 
the 
for 
general society 

smaller 
A 
number  of  MRI 
cannot take place

No  restriction  to 
MRI 
its 
and 
economic 
development 

Negative  impact 
on  growth  of 
medical 
technology  and 
restriction 
on 
economic 
activities in other 
areas  

strong 
Less 
negative 
impact 
on  growth  of 
medical 
technology. 
Other  economic 
activities  are  not 
or only very little 
restricted. 

Signal 
that 
flexible solutions 
can be found 

that 

can 

Unequal 
treatment 
of 
may 
sectors 
create problems. 

Signal 
economic 
interests 
overrule 
workers’ 
concerns 

general 
In 
achieved, 
case 
specific  analysis 
required 

In  most  areas 
achieved,  but  for 
areas 
some 
achievement 
is 
not ensured 

In 
general 
achieved, but less 
convincing 
than 
with  options  A 
and B 

Safety  standards 
are  perceived  as 
not reliable 

Option C1 

Option C2 

Option D1 

Option D2 

Protection 
Workers 
dependent 
MS  

of 

on 

Partially, 
depending  on  the 
effect 
the 
recommendations 
in the MS 

of 

More  uncertainty 
the 
concerning 
of 
protection 
at 
groups 
particular risks 

Patchwork 
of 
solutions  which 
is  not  good  for 
and 
mobility 
competitiveness 

of 

Protection 
workers 
dependent  of  the 
the 
content  of 

Partially, 
depending  on  the 
the 
effects  of 
the 
content  of 

More  uncertainty 
the 
concerning 
of 
protection 
at 
groups 

Patchwork 
of 
solutions  which 
is  not  good  for 
and 
mobility 

437.1 

420.2 

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39 

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agreement(s) 

agreement(s) 

particular risks. 

competitiveness 

Option E 

Not  at  the  level 
of more stringent 
options 

No 

474.0 

Lack of guidance 
may  end  up  in 
higher 
assessment costs 

Bad 
to 
signal 
stakeholders.  No 
explicit 
protection 
for 
workers  anymore 
whilst 
recommendations 
for general public 
remain 

Given new scientific evidence which indicates that exposure limits as provided under option B will 
ensure  protection  against  overexposure,  option  A  only  adds  the  disadvantages  of  restricting  some 
activities and overall less willingness to comply.  

At  the  other  end  of  the  spectrum  of  possibilities  option  D1  (Recommendation),  D2  (Voluntary 
agreement)  and  E  (no  EU  legislation)  can  be  rejected.  Stakeholders  and  experts  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 European Market. Furthermore, abstaining from any 
European level action on EMF would reduce significantly the attention paid to the risks of EMF and 
could have negative health impacts.  

The  three  remaining  options  are  options  B  (revised  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 activities 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 workplaces already high enough, so that there is no longer a threat of 
overexposure. Compared to option A the number of situations with potential overexposure reduces 
significantly. Option B is in line with recent scientific evidence. The disadvantage of this option is 
that  there  are  some  activities  (like  some  MRI  treatments)  where  temporary  excessive  exposure  is 
possible.  Completely  stopping  these  activities  –  which  are  in  some  cases  closely  linked  to 
technological progress and undertaken to directly contribute to the health and well-being of citizens 
– is problematic. 

Option  C1  has  the  advantage  of  consistent  rules  on  EMF  in  most  areas  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 requires a more stringent and more controlled 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  protection  against  this  leading  to  lower  levels  of 
workers  protection.  Furthermore  this  option  would  encourage  more  heterogeneous  protection  of 
employees in contradiction with the letter 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  qualitative  impacts  -  and  guarantees  a  high  level  of  protection  for  the 

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40 

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workers.  The  cost  of  Option  C1  is  significantly  lower  than  the  cost  for  option  A  and  almost 
equivalent to Option B whilst offering to the MRI sector and the industry the flexibility they need.  

Consequently,  based  on  these  considerations  and  in  line  with  the  survey  results  hereafter  the 
Commission therefore prefers option C1.  

This conclusion is in line with the results of a survey carried out among stakeholders 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 available 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  grounds.  Option  E  especially  is 

unpopular with stakeholders. 

The  detailed  assessment  also  shows  that  'soft  elements'  like  information  campaigns  targeted  at 
specific  sectors  and  practical  guides  how  to  implement  legislation  on  the  sectoral  level  should 
continue to complement the legislative action. 

These conclusions indicate an overall preference of the responding stakeholders for option C1.51  

51 

See annex 9 and FICETTI report. 

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41 

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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 effectiveness 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 legislation relating to health and safety at work. 

First there is the tripartite Advisory Committee for Safety and Health at Work set up by a Council 
Decision  (2003/C218/01).  Each  Member  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  provides  opinions,  either  at  the  Commission’s  request  or  on  its  own 
initiative on all problems relating to the enforcement 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.  

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8. 

ANNEXES 

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43 

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Annex 1 
Second stage of consultation of the social partners on the protection of workers from the risks 
related to exposure to electromagnetic fields at work 

ANSWERS TO THE CONSULTATION 

Synthesis 

The  Commission  launched  the  second  stage  consultation  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  Union  initiative  to  ensure  the  protection  of  workers  exposed  to 
electromagnetic  fields  (EMF)  during  their  work.  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: eighteen employers' organisations (10 EU; 2 international; 1FR; 5 UK), 
two  workers'  organisations  (1EU;  1DE),  three  national  scientific  institutions  (RO;  2  PL),  three 
private experts and one patients' association (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 

Confederation  of  European 
Business 

EU; Employers 

CBI 

CEA 

CEEMET 

CEEP 

CER 

COCIR 

Business 
organisation 

lobbying 

UK; Employers 

National Scientific Institute 

FR; Employers 

European 
Council 
of 
the  Metal, 
Employers  of 
and 
Engineering 
Technology-based Industries 

centre 

European 
of 
Employers  and  Enterprises 
providing Public Services 

Community  of  European 
Railways  and  Infrastructure 
Companies 

EU; Employers 

EU; Employers 

EU; Employers 

Medical  MRI  Equipment 
manufacturers 

EU; Employers 

EN 

44 

   EN 

 
 
DGB 

EEF 

Deutscher 
Gewerkschaftsbund 

DE; Workers 

Engineering 
Federation 

Employers’ 

UK; Employers 

EMFields Ltd 

Consultants for EMF 

UK; Private experts 

ENTSO-E 

ETUC 

EURELECTRIC 

EUROCHLOR 

Electricity distribution 

EU; Employers 

European 
Confederation 

Trade  Union 

EU; Workers 

Electricity  production  and 
distribution 

EU; Employers 

Chemical 
industrial electrolysis 

processes; 

EU; Employers 

Goiceanu (Mr) 

National Scientific Institute 

RO; Scientists 

GSMA 

HOSPEEM 

IEMFA 

Israël (Mr) 

NATO 

Polish 
experts 
Bioloelectromagnetic 
Problems 

Polish experts panel 

SMMT 

UEAPME 

Mobile 
industry 

telecommunication 

International; Employers 

European  Hospital 
Healthcare 
Association 

and 
Employers' 

International 
Magnetic Fields Alliance 

Electro-

EU; Employers 

International; Private experts 

EMF 
Bulgaria 

coordinator 

for 

BG; Scientists 

North 
Organization (defence) 

Atlantic 

Treaty 

International; Employers 

on 

Polish  Society  of  Radiation 
Research 

PL; Scientists 

National 
Commission 

Interdepartmental 

PO; Governmental scientists 

Society 
manufacturers and Traders 

of 

Motor 

European  Association 
of 
Craft,  Small  &  Medium-
Sized Enterprises 

UK; Employers 

EU; Employers 

UK-NHS 

National Health Service 

UK; Employers 

EN 

45 

   EN 

 
The Commission had requested the Social Partners to: 

1. 

2. 

3. 

Submit  to  the  Commission  an  opinion  or,  where  appropriate,  a  recommendation  on  the 
content of the envisaged legislative and non-legislative initiatives pursuant to Article 154 
(3) of the TFEU, giving particular attention to the topics identified in section 4 above; 

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 protection of workers exposed 
to  electromagnetic  fields  during  their  work.  Alternative  solutions  for  the  range  from  100 
kHz to 300 GHZ are also welcome; 

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 referred 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 controlled working environment 

4.7. Medical surveillance 

4.8.  The  specific  case  of  medical  applications  and  related  activities  (research,  cleaning, 
maintenance) using nuclear magnetic resonance (MR) technology 

4.9. Non-binding measures 

Overall,  the  social  partners  welcome  the  initiative  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 Magnetic 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  dispositions  of  the  Framework  Directive 
89/391 sufficient to address 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  legislative  and  non-legislative  initiatives  pursuant  to 
Article 154 (3) of the TFEU, giving particular attention to the topics identified in section 4 
of the document. 

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46 

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4.1. Coverage of all sectors of activity 

Commission's proposal 

The Commission considers it important that EU legislation on occupational 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 consultation and does not depart from 
the provisions of the current directive on the issue. 

There is general consensus on the coverage of all sectors of activities by the new proposal. Some 
organisations  pointed  out  that  a  degree  of  flexibility  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 meaning of adverse health effects could reconcile science and industry. 
This should allow a flexible system to be developed for defined working conditions in certain 
activities. In order to be credible the system should reflect the most recent 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 required and would de facto affect 
the safety of workers but not their health. The Commission is of the opinion that the solution 
may be to distinguish between effects which are harmful to health and effects which can be 
detrimental to the safety of the worker and may even impair the quality 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  clarity  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  most  of  the  employers;  a 
ranging  of  the  effects  has  also  been  suggested.  CER  affirms  that  a  strong  subjective  element 
underlies physical effects; therefore it shouldn't be required to take them into consideration. On the 
contrary, national institutes believe that also physical effects 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 reduced. Workers' associations recommend giving precise definitions 
of  what  is  considered  to  be  "harmful"  and  don't  accept  a  mutually-exclusive  distinction  between 
what is harmful to safety and what is harmful to health. 

4.3. Exposure limit values 

Commission's proposal 

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47 

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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 for higher frequencies is expected in the near 
future. The latter do not seem to be controversial 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 consultation process, are nowadays challenged 
by different agencies: IEEE (USA), ARPANSA (Australia) and very recently by a proposal of 

the German Ministry for Employment and Social Affairs (BMAS). The Commission intends 
to take into account the diversity  of recommendations  from  the scientific world and  replace 
the current system, which comprises one action 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  employers’  federations  that  have  already 
undertaken to develop guidance for their workers or members. 

The  Commission  would  however  suggest  maintaining  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 remains under the levels proposed by ICNIRP in 2009 
for frequencies up to 100 kHz: as there are no health 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 particular case, protection measures as for Zone 
2 should apply; 

• Zone 2 (yellow zone) where exposure is between 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 workers’ safety problems due to appearance of phosphenes. This 
is  the  area  where  required  actions  and  preventive  measures  are  in  fact  situation/activity-
dependent as already indicated under 4.2. A non-exhaustive list of identified activities could 
be  provided  in  an  annex.  Measures  that  should  be  considered  here  include:  information, 
specific training and awareness raising, appropriate labelling, and limited access;  

• Zone 3 (red zone), where exposure exceeds the current commonly accepted limits proposed 
by  ICNIRP  and  IEEE  for  frequencies  above  100  kHz  and  where  the  exposure  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  take  place  under  strictly  controlled  conditions,  never  in  routine 
work. 

This system would replace the current action values 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 revising the restrictive values of the present Directive 
and on the need for them to be directly and easily measurable. The only exception is CER, which 
endorses  to  keep  those  of  Directive  2000/40.  Some  organisations  contest  the  use  of  ICNIRP 
recommendations,  given  that  they  are  undergoing  revision  and  that  the  draft  version  of  the  new 

EN 

48 

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guidance  has  been  criticised.  More  than  one  employers'  organisation  supports  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 recommends that the limits should not be related 
to the type of work carried out,  and point out that a high 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 limits that are also based on physical 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  principle,  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 that "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 restrictive zones; NHS-UK suggests different limits for the public and for the 
workers; The Polish Society of radiation research advocates internationally 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  the  basis  of  the  mandate  M/351  of  17  May 
2004  given  by  the  Commission  to  CENELEC  in  order  to  meet  the  requirements  of  Article 
3(3) of the directive currently in force: 

for 

the  assessment,  measurement  and/or  calculation  of  workers’  exposure 

‘3. 
to 
electromagnetic fields, until harmonised European standards from the European Committee 
for Electrotechnical Standardisation (CENELEC) cover all relevant assessment, measurement 
and calculation situations, Member States may employ other scientifically 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 (up to 100 % of the measured value). From a technical point of 
view this may be dealt with when the measurements 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 expressed 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  numerical  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 

49 

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measurements and evaluations should be limited to cases where exposure is likely to exceed 
the upper limit of Zone 2.  

There  seems  to  be  an  urge  for  directly  measurable  calculations,  also  feasible  by  non  specialists. 
EURELECTRIC  and  others  support  considering  the  use  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.  Several  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-based  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 electric and/or magnetic field. This is for instance 
the  case  in  establishments  using  just  one  welding  device,  an  induction  furnace,  an  in-house 
electric transformer, a microwave drying system, etc. Consequently, exposure to EMF is not 
normally considered as a risk and it must be recognised that it is probably not seen as one of 
the major sources of illness or accidents in such enterprises. Therefore appropriate guidance 
should  be  given  to  raise  awareness  and  simplify  the  risk  assessment  procedure.  The 
Commission is aware that some Member States and sectoral associations 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  above  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 situation does not require extensive efforts. 

This  approach  leads  to  a  simple  but  effective  risk  assessment,  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 simplification and proportionality. Assessment time and 
costs will thus be reduced whenever possible without 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 indicative exposure measures. UEAPME advocates the creation of safe-
equipment  lists.  EURELETRIC  adds  that  it  would  also  support  the  introduction  of  lists  of 
equipment which is not considered safe. ETUC expresses its concerns on the creation of the lists; 
asks for repeated exposure to be taken into account; and affirms that they would welcome guidance 
to assessment of sector-specific risks. CIOP underlines that the "CE" labelling 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.  UEAPME  suggests  carrying 
out awareness-raising activities the use of simplified and proportionate risk-assessment tool for the 
SMEs. 

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50 

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4.6. Due flexibility in a controlled working environment 

Commission's proposal 

As  can  be  noted  from  points  4.2  to  4.4  relating  to  short-term  effects,  the  Commission 
recognises  the  need  for  an  appropriate  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 the latest conclusions  of  the SCENIHR11 relating to 
possible  long-term  effects.  One  may  conclude  from  SCENIHR’s  opinion  that  there  is 
currently  no  consistent  evidence  of  long-term  adverse  effects  on  adult  human  bodies  (with 
very  few  exceptions  for  young  children)  and  therefore  no  possibility  to  take  them  into 
consideration  for  a  quantifiable  approach  in  a  binding  legal  instrument.  The  Commission  is 
however  of  the  opinion  that  a  precautionary  approach  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 presence in an exposed zone whenever 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 and 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 environment. This flexibility to accept 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 annex 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 limit values should remain unchanged, the adverse 
effects  consist  in  internal  or  external  burns  from  which  the  human  body  may  not  recover 
immediately. This cannot be accepted. However, heating of tissues does not necessarily occur 
if the exposure time is very short. The importance of this parameter is underestimated in the 
present directive. It is intended that the proposal should make clearer the interpretation to be 
given  to  exposure  time  and  averaging  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 believe 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  adverse  health  effects  on  EMF  in  the  long  term,  as 
SCENIHR  demonstrates,  the  Directive  should  not  cover  this  issue.  NATO,  in  the  same  line, 
suggests a "de minimis" approach. Some organisations 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  and  EMF  Alliance  don't  agree.  Some  question  the 
appropriateness  on  the  use  of  precautionary  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 considered 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 

51 

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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 sound empirical scientific research. 

4.7. Medical surveillance 

Commission's proposal 

Doctors present at the Umea Conference of October 2009 admitted that they found it difficult 
to identify effects from exposure to EMF, especially with routine 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 for after heavy exposure, except for burns? The 
experts were of the opinion that the exposure limit value as suggested in the directive was not 
a useful indicator for health examinations. 

An open question remains concerning the need for 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  held,  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 guidance in this field. The Commission proposes the 
setting-up  of  an  appropriate  working  party  under  the  Advisory  Committee  on  Safety  and 
Health at Work to develop such guidance. 

Many  respondents  observe that 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  there  is  no  need  for  compulsory  surveillance  at  all. 
Workers deem instead that there should be a constant 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 magnetic resonance (MR) technology 

Commission's proposal 

MR  technology  is  used  in  medical  applications  such  as  magnetic  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 Commission 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. 

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A study ordered by the Commission on the subject of medical MRI12 showed that compulsory 
compliance with the exposure limit values of the directive would indeed hamper the further 
use of MRI. However, the study indicated that the problem affects a relatively limited number 
of procedures - less than 10% - and are restricted to the frequency range from 0 Hz to 10 kHz 
used in MR medical techniques. For the large majority 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 technical specifications of the current machines - 
a  large  majority  of  which  use  a  1.5T  or  3.0T  (rarely  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 directive 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 levels 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  the  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  would  continue  to  be 
protected through reinforced qualitative preventative and protective measures to be included 
in the proposal for revision of the directive: 

– reinforced information measures; 

– reinforced training of workers; 

– documented and practicable working procedures favouring exposure limitation whenever 

possible; 

– strict administrative procedures for access to MR rooms; 

– consultation of personnel on improvements; 

– monitoring. 

Qualitative elements that reassure the Commission 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 

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53 

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aware  of  good  practices.  Moreover,  most  instances  of  exposure  would  not  be  far  above  the 
new proposed limits announced under 4.3 above. 

Appropriate and commonly agreed qualitative prevention and protection measures should be 
implemented in a harmonised way ideally in all the medical MR facilities 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 successful completion of the study referred 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  reliable  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  exposure-values  requirements.  In 
particular,  it  is  noticed  that  vulnerable  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  techniques  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 reviewed (ETUC). NATO disagrees with the introduction of whatever 
type  of  exemption.  CIOP  suggest  that  limitation  of  exposure  levels  should  not  be  defined;  CEA 
requests exemptions also for research activities, 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  particular  in  SMEs,  justify  supplementing  the  revised  directive  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  practice  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 have to be adapted in order to  suit the  revised 
directive. 

For difficult situations where workers face very high exposure levels, precise evaluations will 
be  necessary  and  appropriate  standards  developed  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 effective prevention and that the employers’ and workers’ 
organisations have an essential role to play in developing and encouraging dissemination to 
their members of non-binding but well-adapted tools. 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 awareness-raising activities on the ground with a 

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54 

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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 Member States and social partners. 

All the organisations generally welcome the need for non binding measures and guidelines. Some 
have expressly agreed on the creation of a working party. CER indicate 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  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  protection  of 
workers exposed to electromagnetic fields during their work. Alternative solutions for the 
range from 100 kHz to 300 GHZ are also welcome. 

Point 2 received few answers: ETUC suggest the creation 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 insist 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 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. 

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  guidance;  CEEP  does  not  exclude  negotiations,  EMF 
Alliance  say  they  are  open  to  negotiate;  NHS-UK  believes  social  partners  would  lack  technical 
knowledge  to  complete  such  an  exercise.  Finally,  BUSINESSEUROPE  don't  see  the  need  for 
negotiations since they think the proposal of the Commission is good enough. 

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55 

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Annex 2 
Current legislative situation in the EU Member States 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  Parliament  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  (electromagnetic  fields)  (18th  individual  Directive  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, Ireland, Greece, Spain, France, Cyprus, Luxembourg, 
Hungary, Malta, Netherlands, Poland, Portugal, Romania, Slovenia, Finland, Sweden and United 
Kingdom  

there is no national law specific to the EMF Directive that has been finalised or published. 

For seven countries: 

Austria, Estonia, Latvia, Lithuania, Italy, 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  the  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 this is little more than 
a translation of the ICNIRP guidelines and has 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 guidelines (although it has not been 
possible  to  obtain  a  translation)  and  therefore  contains  rather  different  limits  than  the  EMF 
Directive itself. 

Latvia 

The Latvian legislation is available in English. The relevant legislation for the EMF directive is: 

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56 

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Cabinet  Regulation  No  745,  Adopted  5  September 2006:  Labour  Protection  Requirements  for  the 
Protection  of  Workers  from  the  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  Electromagnetic  Field  in  the  Work  Environment”  does 
have practical information. 

Lithuania 

The relevant legislation is: 

Regulations  on  Protection  of  Workers  from  the  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  luoghi  di  lavoro"  pubblicato  nella 
Gazzetta Ufficiale n. 101 del 30 aprile 2008  Supplemento Ordinario n. 108 

This Legislative Decree has 13 sections and 306 articles 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 part 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 nei luoghi di lavoro. Prime indicazioni applicative 

Czech Republic 

The relevant Czech legislation is: 

Nařízení vlády č. 1/2008 Sb., o ochraně zdraví před neionizujícím zářením 

Legal  act:  Nařízení  vlády  ,  number:  1/2008  ;  Official  Journal:  Sbirka  Zakonu  CR  ,  Publication 
date: 09/01/2008 

There is no English translation available. It appears to be very close to a direct implementation of 
the ICNIRP guidelines. 

Slovakia 

The relevant Slovakian legislation is: 

Nariadenie  vlády  Slovenskej  republiky  č.  329/2006  Z.  z.  o  minimálnych  zdravotných  a 
bezpečnostných  požiadavkách  na  ochranu  zamestnancov  pred  rizikami  súvisiacimi  s  expozíciou 
elektromagnetickému poľu 

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57 

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Legal act: nariadenie , number: 329/2006 ; Official Journal: Zbierka zákonov SR , number: 113 , 
Publication date: 31/05/2006 , Entry into force: 01/06/2006. 

There  is  no  English  translation  available.  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  available  information.  To  supplement  this,  information  was 
gathered  using  questionnaires  sent  to  EU  member  states'  regulators  in  2007-2008  Directive,  and 
then updated. This information is provided in the tables below. 

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58 

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Current status in each country regarding EMF Directive 2004/40/EC? 

AUSTRIA 

Transposition process finalized. Entry into force postponed until 30/4/2012 

BELGIUM 

BULGARIA 

CYPRUS 

Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 

Drafting regulations for the transposition of the EC Directive to the national 
legislation. On ice. 

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 

FRANCE 

GERMANY 

The  tripartite  standing  committee  has  drafted  a  Decree,  but  they  are  waiting 
for additional information as regards medical MRI technology. On ice. 

The process of implementation, in progress, has been stopped due to the claim 
of Radiologists. On ice. 

Implementation  will  be  executed  by  means  of  an  Ordinance.  A  Draft 
Ordinance is prepared by the Federal Ministry at present, so that the Directive 
can be implemented whenever required. 

GREECE 

No additional information. On ice. 

HUNGARY 

No additional information. 

IRELAND 

The first draft of the transposed Regulations has been prepared. On ice. 

ITALY 

The  frame  of  a  specific  regulation  on  MR  diagnostic  equipment,  mostly 
addressed to the protection of the patient, limits of exposure to magnetic static 
field  for  diagnostic  MR  workers  are  defined,  similar  to  what  established  in 
ICNIRP  guidelines  of  1994.  It  is  also  established  that  SAR  levels  on  the 
workers  must  not  exceed  the  value  given  for  the  patient  (that  may  reach  4 
W/kg). 

NB: this is exceeding the limits 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. 

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59 

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LITHUANIA 

Regulations  on  protection  of  workers  from 
the  risks  arising  from 
electromagnetic fields approved by the order 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  other  environmental  ambient  factors) 
exposure, Journal of Laws 217/2002, item 1833 (in Polish). 

In  addition,  more  than  10  regulations  and  several  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 safety requirements regarding the exposure 
of  workers  to  the  EMF  of  Slovak  Rep.  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 directive, which will enable us to develop 
practical solutions and regulations to implement the directive. On ice 

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60 

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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 

the  minimal 
Ordinance  No.  7/Governmental  News  No.88/1999 
requirements  for  healthy  and  safety  work  conditions;  Bulgarian  national 
standard (BNS) 14525-90.  

for 

CYPRUS 

No. 

CZECH REP. 

The  national  Government  Order  No.  480/2000  Coll.,  available  in  Czech 
language on the website. 

DENMARK 

No 

ESTONIA 

Government  decree  no  54  (25.01.2002)  “Occupational  exposure  limits  and 
measurement 
Estonian 
https://www.riigiteataja.ee/ert/act.jsp?id=12823094 

physical 

factors” 

risk 

of 

in 

FINLAND 

A decree on high frequency equipment available in Finnish and Swedish. 

FRANCE 

No. 

GERMANY 

GREECE 

HUNGARY 

IRELAND 

ITALY 

LATVIA 

The  accident  prevention  regulation  BGV  B11  "Electromagnetic  Fields"  with 
the  additional  BG  Regulations  BGR  B11  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 . 

No 

No. 

No. 

The  national  railway  company  Trenitalia  published  two  standards  (low  and 
high  frequencies)  on  EMF  measurements  on  trains,  both  for  workers  and 
general public. 

the 
Cabinet  Regulation  No.745  “Labour  Protection  Requirements  for 
Protection of Workers from the Risk Arising from the Electromagnetic Field 
in 
English 
http://www.osha.lv/legislation/index.stm.  

Environment” 

Work 

the 

in 

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61 

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LITHUANIA 

Lithuanian  hygiene  norm  HN  110:2001  “Industrial  frequency  (50Hz) 
electromagnetic  field  in  the  working  place.  Permissible  values  of  the 
parameters  and  measuring  requirements”  and  labour  No.  660/174  of 
December  21,  2001  in  Lithuanian.  Lithuanian  hygiene  norm  HN  80:2000 
“Electromagnetic  field  in  the  working  places  and  living  environment. 
Permissible values of the parameters and measuring requirements in 10 kHz-
300  GHz  zone”  approved  by  the  order  of  minister  of  health  and  No.  361  of 
June 27, 2000 in Lithuanian. 

LUXEMBOURG 

ITM-CL 179.4 - public document, only available in French language 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 electromagnetic fields in Article 6.12 of the “Arbobesluit”. 

POLAND 

Polish  Standard  PN-T-06580:2002.  Labour  protection  in  electromagnetic 
fields  and  radiation  of  the  frequency  range  from  0  Hz  to  300  GHz.  Part  1: 
Terminology. Part 3. Methods of measurement and evaluation of the field on 
the work stands (in Polish).  

Regulation  of  the  Minister  of  Labour  and  Social  Policy,  concerning 
permissible  occupational  EMF  (and  other  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 

ROMANIA 

SLOVAKIA 

No 

No 

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 
Slovak 
1.6.2006) 
http://www.bozpo.sk/public/legis/bozp/06_329.pdf. 

from 

in 

SLOVENIA 

No. 

SPAIN 

SWEDEN 

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  

Current ordinance covers exposure for electromagnetic fields in the frequency 
range  3  MHz  –  300  GHz  and  offers  protection  against  thermal  effects,  the 
values  given  corresponds  to  the  action  values  in  the  directive.  In  the  low 
frequency  range  SWEA  has  no  ordinance,  only  a  prudent  avoidance 
recommendation aimed towards magnetic fields at power frequencies. 

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UK 

No specific UK legislation 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 
guidelines. 
http://www.hpa.org.uk/radiation/publications/documents_of_nrpb/abstracts/ab
sd15-2htm 

reference 

ICNIRP 

1999 

and 

by 

to 

http://www.hpa.org.uk/radiation/understand/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 
Reviews 
European 
http://www.ebu.ch/en/technical/trev/trev_305-emf.pdf 
and 
http://www.ebu.ch/en/technical/trev/trev_306-emf_hf.pdf . 

Broadcasting 

Technical 

Union 

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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 first, 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  additional  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  sectors/activities  such  as  electricity  production  and 
distribution, welding, industrial electrolysis, some induction heating systems, and also MRI are 
concerned. 

•  In  line  with  the  unchanged  scientific  recommendations,  the  limit  values  for  higher  frequencies 

remain as defined in Dir. 2004/40/EC. 

When a worker is likely to be exposed to EMF under the current directive 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  (frequency  dependent)  level  of  the  so-called  action  value,  no  further 
action is required. If the 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 activity and requires specific calculation techniques 
based  on  experimental  models.  There  is  no  alternative  and,  as  an  additional  complication,  the 
current exposure limit values are expressed 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  values  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 actual exposure limit. This factor is 10 for workers in 
ICNIRP  system.  BMAs  however  considers  that  there  is  sufficient  scientific  evidence  to  be  less 
  10 .  According  to  BMAs  authors  this  reduced  factor 
conservative  and  the  safety  factor  is  only 
reflects  the  improved  knowledge  in  electrophysiology,  biological  diversity,  modelling  and 
measurement in the low frequency range. This approach 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 range 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). 

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64 

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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 limited number of activities may need to go for the 
detailed compliance check. From recent information received from Dutch experts, only some MRI 
procedures and some induction heating installations would still be concerned. Some work areas in 
the electrolysis sector may also be affected. 

In order to illustrate the principles laid 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  actual  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 separation 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  avoid  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  classified  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 necessary. Guidance will be given in the directive. 

In the few cases still exceeding this upper level, the situation will be similar 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 low frequencies, the limit values remain untouched. 

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65 

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Figure 2: the old and new reference values for the B (magnetic)-field (in µT): 

The same principles as for the electric fields will apply. 

The  current  action  values  are  in  blue:  in  the  past,  every  situation  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 compliance 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  compliance  will  be  limited  to  very  simple  measures. 
Guidance will be given in the directive. 

EN 

66 

   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 electric fields, will have to be compared to the new exposure limit 
values of figure 3. Those ELVs are expressed in different units as the current ones and must not be 
exceeded.  To  enable  the  comparison  between  the  actually  measured  level  and  the  limit  value 
specific calculations and modelling are required based on published models. 

The exposure limit values proposed by BMAS and ICNIRP 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  with  the  choice  of  the  upper  level  2  (see  fig.  1  &  2) 
derived from the BMAS approach. 

EN 

67 

   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  networks,  radio  communication  equipment;  exc.  tape 

erasers) 

•  hand-held motor-operated electric tools  

•  transportable motor operated electric tools (incl. electrically operated garden appliances) 

•  household and similar electrical appliances (incl. mobile equipment fitted with heating elements; 
battery  chargers;  heaters;  vacuum  cleaners  for  dirt  and  water;  cookers,  ovens  and  cooking 
elements  for  industrial  and  commercial  use;  heating  elements  for  waterbeds;  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  voltage  networks  (<1000  V  between  phases) 
with power up to 200 kVA  

workplaces  at  min.  60  cm  from  power  transformers  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 distance and the power not exceeding 1000 kVA 

•  testing instruments (exc. non-destructive 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 

68 

   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, stimulation of bone growth etc.  

incubators, lamps for phototherapy, wireless 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 alternating 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 

69 

   EN 

 
•  electrochemical processes (except specific places) 

•  induction heating  

•  research applications  

•  Other working environments 

– 

– 

induction hobs in hotel & catering industry (food preparation) 

tape erasers 

Example of situations likely 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 measurements should also be made with a simple but well 
functioning device (measurement uncertainties do not play a role here). 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  measurements  have  to  be  carried  out  for  compliance 
verification with the exposure limits. Grids, fences or sufficient distance must guarantee avoidance 
of overexposure. Specific training should be given for workers and foremen. 

•  trouble shooting during installation and maintenance 

•  proximity of rectifiers in electrochemical processes 

•  induction heating (small melting furnaces) 

•  semi-automated spot and induction welding 

EN 

70 

   EN 

 
•  MRI (static and gradient fields) 

EN 

71 

   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  better  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  company  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  case  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  introducing  the  protection  controls  (procedures  and/or 
hardware). 

The case studies were conducted in UK, Finland and Poland.  

The case studies have been made for the following types of workplaces and equipment: 

(1) 

Electricity generation 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  medium  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 

72 

   EN 

 
1. Case study: Electricity generation and transmission 

•  Present situation 

The electricity generation and transmission industry 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  these  are  problems  that  should  already  be 
addressed under the requirements of the Framework Directive. 

Policy Option B 

The impact of this policy option depends on the new limits. If the existing Action Values 
are changed to be more in line with Exposure  Limit Values for electric 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  industry  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 industries 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 

B 

1250 

1250 

EN 

73 

   EN 

 
C1 

C2 

D1 

D2 

E 

1250 

1250 

1250 

1250 

1250 

•  Summary 

Electricity generation and transmission is effectively at Option A. There is likely to be very 
little cost difference across the various policy options, but the industry as a whole would 
prefer Option C1. Options D and E were rejected in the consultations. 

EN 

74 

   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 were in place and implemented, with a health 
and safety officer/small team in place, though 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 guidelines. 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. 

HSE itself, as part of its response to the FICETTI questionnaire, stated that the UK position 
was: 

"The  HSE  believes  that  this  current  system  of  regulations  based  on  the  Framework 
Directive, referencing the ICNIRP recommendations coupled with EMF guidance provide 
a satisfactory, proportionate system for controlling 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 ICNIRP basic restrictions not as an actual restriction, but as 
a starting point for exploring risk in more detail. The ALARP principle should be followed, 
and  erosion  of  ICNIRP  safety  factors  can  be  appropriate,  if  indicated  by  discretion  and 
judgement." 

From the interviews carried out by FICETTI, it appears that very few 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  many  years,  and  have  never  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 little-to-no awareness at all of EMF issues or 
any conception that any of their activities might be associated with any sort of EMF risk. 

In practice, the regulatory situation in the UK for SMEs may be close to Policy Option E, 
with  any  investigation  of  EMF  risk  only  likely  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 exposures are below the ICNIRP 
basic restrictions (equivalent to the Exposure 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,  little  or  no  welding  equipment  currently  on  the 
market and designed for professional use is supplied with emission/exposure information. 

The  CENELEC  welding  standards  require  that  a  manufacturer  shows  compliance  with 
general  public  exposure  limits,  but  in  general  this  is  not  equipment  used  in  welding 
companies. 

EN 

75 

   EN 

 
In the absence of manufacturers' information welding companies will need to make EMF 
exposure  assessments.  It  is  a  feature  of  welding  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  consider  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.  The  main  factors  that  would  allow  them  to 
develop this expertise are: 

– 

– 

– 

– 

Resources (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 situations where remedial action is 
needed. 

It is possible that companies could invest the time and effort to develop this expertise, and 
if  they  chose  to  do  so  then  the  cost  would  likely  be  about  ten  person-days.  The  average 
wage for the sort of person who might be charged with this task (from the employer's side) 
is estimated at around 25k Euros per year (technician 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  would  probably  trigger  questions  from  employees  about 
possible effects on health, and even questions about related issues such as mobile phones 
and  overhead  power  lines.  An  exposure  assessment  programme  would  probably  have  to 
include  the  provision  of  authoritative  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, such as those of the World Health Organisation, 
which are updated regularly and which provide rapid 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 expertise; 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  would  include  the  cost  of  buying 
and  maintaining  a  magnetic  field  meter  (calibration  costs  are  likely  to  be  higher  than 
purchase cost over time) and the cost of preparation of staff to conduct measurements. 

•  Policy options impact 

EN 

76 

   EN 

 
Option A. Most welding machines produce exposures complying with the requirements of 
the  EMF  Directive,  but  may  need  application  of  e.g.  Dimbylow  approach52,  or  possibly 
computational  modelling.  There  is  no  real  need  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-house activity to setup/manage the assessment and 
disseminate  the  information.  The  average  wage  for  the  sort  of  person  who  might  be 
charged with this task (from the employer's side) is perhaps 25k Euros 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 will 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  pregnancy  outcome/effects  on  pregnant  women  will 
already be addressed by a reasonable employer. 

The Directive requires an assessment of possible impact on AIMD53 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  CENELEC  standards)  that  accompanies  the 
Directive, and which should allow more focused 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 assessment if Actions Values were 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 external expertise (1825€) 
and  30%  would  take  advantage  of  in  house  expertise  (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 Directive 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 that it will require some assessment, it is likely to require 
measurements anyway. So it would 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 limits, companies will use 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 
53 

Explain in footnote 
AIMD - Active Implantable Medical Devices 

EN 

77 

   EN 

 
 
 
                                                 
is no advice on how to do risk 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 this case study it is costed as the same as 
option B. 

Option 

Cost per establishment 
(Euros) 

A 

B 

C1 

C2 

D1 

D2 

E 

1825 

1375 

1375 

1375 

1375 

1375 

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 

78 

   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 accepted the use of ICNIRP EMF guidelines, to replace the 
earlier single-tier NRPB guidelines. 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 situation in the UK for SMEs seems close to Policy Option E, 
with  any  investigation  of  EMF  risk  only  likely  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 exposures are below the ICNIRP 
basic restrictions (equivalent to the Exposure Limit Values of the EMF Directive).  

Application of EMF Directive implementation framework 

Induction  heating  companies  have  equipment  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 information supplied by the manufacturer, and induction 
heating companies will need to make EMF exposure assessments.  

Expertise and costs 

Very few induction heating companies have existing in-house expertise in the assessment 
of  workers’  exposure  to  electromagnetic  fields.  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 situations where remedial action is needed. 

It is possible that companies could invest the time and effort to develop this expertise, and 
if  they  chose  to  do  so  then  the  cost  would  likely  be  about  ten  person-days.  The  average 
wage for the sort of person who might be charged with this task (from the employer's side) 
is perhaps 25k Euros per year (technician or recent graduate). Allowing 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)  measurement  equipment.  To  buy  a  suitable  meter 
would be approximately 4000 Euros; to hire one for four days might cost 500 Euros. 

EN 

79 

   EN 

 
A  measurement  programme  would  probably  trigger  questions  from  employees  about 
possible effects on health, and even questions about related issues such as mobile phones 
and  overhead  power  lines.  An  exposure  assessment  programme  would  probably  have  to 
include  the  provision  of  authoritative  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, such as those of the World Health Organisation, 
which are updated regularly and which provide rapid 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 expertise; 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  maintaining  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  external  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 charged with this task (from the employer's side) 
is perhaps 25k Euros per year (technician or recent graduate). Allowing 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  practice,  which  might  include  zoning.  Practically, 
shielding  is  not  effective  for  most  induction  heaters,  though  there  my  some  benefit  for 
higher  frequency  (100  kHz  and  upwards)  machines  that  are  physically  small  and  are  not 
already shielded. 

It is assumed that changes in working practice 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 require an external consultant 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 implementing 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 estimate (step 2): 2190€

. 

The total compliance cost including the measurement of EMF by external expert and the 
following in-house and external expertise involved 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 

80 

   EN 

 
The Directive requires an assessment of possible impact on AIMD 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  CENELEC  standards)  that  accompanies  the  Directive,  and  which 
should allow more focused 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. 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  induction  heating  frequencies  that  are  most 
problematic  are  those  where  revised  action  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 unable to determine risk themselves: 2680€

Option D1 is the same as B; the Framework Directive 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 agreements 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 limits, companies will use 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 

B 

C1 

C2 

D1 

4015 

2680 

2680 

2680 

2680 

EN 

81 

   EN 

 
  
D2 

E 

2680 

2680 

•  Summary 

•  Induction heating is a technology that falls within Table 2 "Equipment likely to require 
further assessment" of EN50499. Exposure may 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 

82 

   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  medical  care  enterprises,  based  on  the  current 
situation in Poland. 

There are approx. 2500 electrosurgical 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 between 1 and 15. In the largest hospitals even 
30-40 units are used. 

The surgeon is the most exposed person from the health care staff. The 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 electromagnetic fields produced 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 visits 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 environment (including those related to electromagnetic fields - EMF) 
should be identified and eliminated or appropriately 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  legislation  called  the  Labour  Code  and  others  law 
regulations. 

Poland  has  national  mandatory  legislation  concerning  occupational  exposure  to  EMF 
(dated 1977 for frequency range 100 kHz – 300 MHz, covering EMF frequency produced 
by electrosurgical devices). The current regulation concerning the exposure limitations for 
EMF for the 0 Hz - 300 GHz frequency range was worked out in 1999 (recently issued by 
PL Journal of Laws 217/2002, item 1833). Separate  occupational safety regulations have 
been  also  established  regarding  the  obligation  to  carry  out  periodical  testing  of  EMF 
existing  in  the  working  environment.  Regulations  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  advisory  body  established  by  the  Prime  Minister  of 
the Polish government. The last draft amendments concerned implementation of exposure 
limitation specified in the Directive 2004/40/EC into Polish law to reach full compliance of 
national regulations with Directive in this scope.  

Special  attention  was  paid  to  pregnant  woman  and  young  workers  (below  18  years  old). 
The  thresholds  of  permissible  occupational  exposure  for  them  were  established  as  non-
occupational exposure limits only (similarly to general public exposure). 

According to national legislation, workers exposed to EMF are under medical surveillance 
with  special  focus  on  the  cardiovascular  and  neurological  functions.  The  medical 

EN 

83 

   EN 

 
examination is repeated periodically for every 4 years. The ultimate decision about scope 
and frequency of surveillance is made by a physician. 

Electrosurgical devices are sources of strong electric field and they are taken into account 
during worker’s exposure and risk assessment (e.g. currently according to EN 50499). As a 
consequence of the long-standing EMF regulations concerning the electrosurgical devices 
in force the following requirements as regards the working conditions are met:  

– 

– 

– 

workplaces  are  subject  to  occupational  safety  and  health  (OSH)  periodical 
inspections (National Labour and Sanitary Inspectorate); 

the equipments that are sources of occupational exposure 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 the results of measurements of electric and 
magnetic fields strengths. Currently all environmental 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 measurements by the employer with the use of 
hired equipment is not permitted. 

Because  the  level  of  exposure  depends  on:  selected  mode  of  device  operation,  type  of 
active electrode used and location of cables connecting electrodes with the generator, the 
measurements  should  investigate  the  conditions  of  worst  case  of  exposure  adequate  to 
typical working situations (e.g. the use the monopolar electrode, highest output power). It 
allows  to  evaluate  the  maximum  level  of  exposure  and  simplifies  the  process  of 
investigation  (decreasing  time  of  measurement  session  and  costs).  Another  possibility  to 
reduce the number of investigated devices and the 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 one 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 legislations and standards or in the case of 
lack of such a document, following the internationally published standards. Polish standard 
PN-T-06580:2002  that  determines  a  protocol  for  EMF  measurements  and  workers’ 
exposure  assessment  is  harmonized  with  national  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 greatest importance is to give 

EN 

84 

   EN 

 
sufficient  information  concerning  possible  risks  related  to  work  in  the  direct  vicinity  of 
EMF sources. Information on safe work practices is given to workers during initial (before 
employment)  and  periodic  repeated  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 expenses by the proper positioning of the cables 
supplying the active electrode (e.g. by avoiding cables being in contact with the bodies of 
workers). The exposure of other persons from the medical staff is relatively weak if they 
do not have direct contact with the cables. These 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  electrosurgical  devices.  The  average  cost  of 
measurements  for  one  device  in  Poland  is  approx.  80-120  Euro.  Assessment  of  workers’ 
exposure to electromagnetic fields, 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  might  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  “average  country  where  the  cost  is 
18.75€  per  hour.  The  costs  would  be  similar  if  external  expert  is  hired  to  prepare  the 
assessment and guidelines of methods of safe work. 

Preparation  of  the  risks  assessment  (measumrements),  education,  training  and  medical 
surveillance of workers with the reference to EMF do not impose additional costs on the 
establishments  because  these  activities  are  conducted  irrespective  of  the  kind  of 
environmental  agent  as  a  result  of  the  implementation  of  Framework  Directive 
89/391/EEC 

Considering the fact that electrosurgical devices usually produce strong electric fields and 
in accordance with Polish regulations, employment 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  permissible  occupational  exposure  in  the  national 
regulations.  In  consequence,  theoretically  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  mentioned  above  will  not  change.  There  is  no 
difference regarding the policy option C1 and C2. 

Policy Option D 

EN 

85 

   EN 

 
The  lack  of  mandatory  regulations  can  affect  the  level  of  protection  against  EMF  and 
decrease  knowledge  and  awareness  of  employers  on  occupational  risk  related  to  EMF 
exposure. Though requirements of Framework Directive 89/391/EEC will remain in force, 
it is possible that employers may try to avoid exposure assessment and the use of measures 
to decrease the risk level. There is no difference regarding the policy options D1 and D2. 

Policy Option E 

Poland has national regulations concerning occupational 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 there are no national regulations. Employers should 
still comply with requirements of Framework Directive 89/391/EEC. 

For the purposes of this case study the costs for different policy options would be similar 
(based on the situation in Poland, in the case of company with 10 electrosurgical devices): 

Option 

Cost per 
establishment – 10 
devices on average 
(Euros) 

A 

B 

C1 

C2 

D1 

D2 

E 

2720 (1360) 

2720 (1360) 

2720 (1360) 

2720 (1360) 

2720 (1360) 

2720 (1360) 

2720 (1360) 

•  Summary 

According to requirements of Framework Directive 89/391/EEC irrespective of any Policy 
Option the employers are obliged to perform risk assessment related to EMF produced by 
different  sources  (including  electrosurgical  devices).  Suitable  identification  of  anexisting 
problem  is  the  first  step.  In  case  of  electrosurgical  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 methods of risk assessment and reduction of the 
workers’ exposure can decrease costs.  

Mandatory regulations can increase the costs of companies but they give benefits for the 
workers  (better  feeling  of  safety  and  well-being  and  increasing  knowledge  as  a  result  of 
training). 

EN 

86 

   EN 

 
5. Case study: RF sealers 

We  assume  we  have  a  small  company,  hiring  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 limits for RF electromagnetic fields. These are 
somewhat  stricter  than  those  of  the  present  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 principle 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 exposure 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  machines  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 the 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 radiofrequency fields one has to determine the worst 
case  of  exposure  for  a  particular  working  situation.  It  is  not  always  possible  to  cover  all 
situations  during  one  measurement  session,  but  it  is  necessary  to  make  sure  that  the 
exposure assessment is done as to take into account the worst 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  experts  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 survey 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 time basis, perhaps every second or third year 
since  the  machines  change  over  time  if  the  maintenance  program  is  not  correct.  These 
follow-up surveys should be less expensive since the previous protocol may be of help. 

EN 

87 

   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  options  A  and  B.  There  is  also  no  difference 
regarding the policy option C1 and C2. 

Policy Option D 

With non binding recommendations it is questionable if the company will 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 regarding the policy option D1 and D2. 

Policy Option E 

The  cost  of  a  proper  risk  assessment  under  the  framework  directive  regime  would  also 
arrive to similar costs in this particular case.  

With  the  Framework  Directive  were  fully-implemented,  all  options  would  require  EMF 
assessment and the costs for different policy options would become: 

Option 

Average cost per 
establishment 
(Euros) 

A 

B 

C1 

C2 

D1 

D2 

E 

3000 

3000 

3000 

3000 

3000 

3000 

3000 

•  Summary 

For  all  options  measurements  are  needed  since  the  information  from  the  manufacturer  is 
seldom enough for a complete risk assessment. There 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 

88 

   EN 

 
6. Case study: Broadcasting 

This  case  study  deals  with  the  occupational  exposure  to  radiofrequency  fields  from 
broadcasting  and  telecommunication  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  (installations,  maintenance).  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 concerning the maximum allowed exposure 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 based on this legislation. The exposure limits 
of  the  Finnish  regulation  correspond  with  the  Directive  2004/40/EC  in  its  current  form. 
The employers and trade unions have also made together occupational safety guidance for 
mast work which considers also EMF. This guidance 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 meters that will sound alarm in case the exposure 
limits are exceeded during the mast work. Mast workers 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  attention  is  paid  for  the  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  Institute  of  Occupational 
Health, 2006). The medical examinations 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 broadcasting masts and based 
on  these  measurements  the  working  practices  have  been  made.  Working  practices  may 
include  safety  time  limits  for  staying  at  certain  locations  or  the  reduction  of  transmitting 
powers during work tasks. All workers carry personal alarm devices that sound alarm if the 
exposure limits are exceeded. Workers have been informed how to act in these cases. 

•  Policy options impact 

Policy Option A 

The  present  situation  is  already  in  line  with  the  policy  option  A.  However,  broadcasting 
sites  are  very  challenging  places  to  make  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, incur 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 

89 

   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  ICNIRP  that  the  scientific  literature  published  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  limiting  exposure  to  high 
frequency electromagnetic  fields." (Statement on the "Guidelines for 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 the 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 and C2 would not have impact as the present situation would 
remain. The costs for checking the compliance would still apply being 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  approximately  150  €,  according  to  the  calculations 
given in policy option A. 

In  a  case  of  voluntary  agreements  at  European  or  sectoral  level  between  social  partners 
(D2)  the  impacts  would  likely  be  minor  ones.  The  sectoral  agreements  would  likely 
continue to uphold the present situation and the limits would have a scientific basis as this 
is the point telecommunication sector emphasises.  

Policy Option E 

This policy option would not change the current 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  occupational  exposure  limits  change  according  to  the 
country.  This  may  increase  costs  as  more  than  one  set  of  personal  protective  devices  are 
required. Furthermore, it will be difficult to explain to the workers why the limits differ in 
the same task in different countries. This situation is considered to be very unlikely. 

For the purposes of this case study the costs for different policy options would be: 

Option 

Cost per 
establishment 
(Euros) 

EN 

90 

   EN 

 
A 

B 

C1 

C2 

D1 

D2 

E 

150 

150  

150 

150 

150 

150 

150 

Occupational  health  care  and  mast  working  licence  practices  are  different  in  different 
Member  States.  In  Finland  the  system  for  the  mast  workers  periodical  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. One of the problems related to the comparison of the costs is 
due  to  the  fact  that  no  internationally  approved  method  for  the  health  examinations  or 
procedures exists. 

•  Summary 

Broadcasting  and  telecommunication  sectors  are  generally  following  the  ICNIRP 
guidelines  throughout  the  EU  and  therefore  the  impacts  of  the  different  policy  options 
would be minor for the individual broadcasting/telecommunication companies. As the EU 
council  recommendation  on  the  limitation  of  exposure  of  the  general  public  to 
electromagnetic fields (1999/519/EC) is based on the ICNIRP general public limits many 
EU member states have adopted ICNIRP based legislation/recommendation for the general 
public  exposure.  It  is  an  advantage  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 

91 

   EN 

 
7. Case study: MRI 

This case study is slightly different from the others in that it considers 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 for each MRI facility – this will 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  suites  and  perhaps  110,000  (wherefrom  3000 
installation/maintenance  personnel)  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  are  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  close  to  the  bore  during 
scanning, for instance when small children or people under medication are being scanned. 
So  even  outside  interventional  MRI  there  may  be  some  RF  and  switched  gradient 
exposure. However, the issue of workers moving 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  –  including  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 potential 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  conjunction  with  existing  site  guidelines  on  safe 
working, the MRI community considers that workers  are fully-protected 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  workplace  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 could develop it at low cost. 

•  Costed policy options impact 

Option  A  It  has  been  estimated  that  perhaps  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 figures given by FICETTI. 

EN 

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technical changes to MRI equipment (for example 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 technical changes, this is very difficult to estimate and is likely to be 
a  rather  small  component  of  the  total  costs  to  society.  For  similar  reasons,  and  because 
most  of  them  operate  within  integrated  healthcare  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 may be primarily a health detriment, it may be 
possible to assign financial costs to it. 

The  FICETTI  consortium  asked  the  UK's  Health  Protection  Agency  to  consider  the 
potential  shift  from  MRI  to  X-ray  computed  tomography  (CT)  that  Option  A  might 
engender.  Their  calculations  (details  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  optimisation,  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 corresponding 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 possible 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  has  considered  the  costs  related  to  the  shifting  to  X-rays  as 
compliance costs although they are of a different 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  considers  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 should be carried out including measurements 
etc. As  there  are a  number  of similarities with 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 the number of cases of overexposure, 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, even if there are no exposure limit values to 
compare exposure with, a "light" risk assessment 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  society.  This  is  valid  for  workers  and 
patients as well. 

EN 

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Option  C2  is  complete  exemption  for  the  sector.  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  other  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 increase 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. This 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 that without a pan-EU agreement in place on 
how  to  address  MRI,  there  is  the  potential  for  health,  social  and  economic  inequalities 
between different countries. The result would probably end up with a compromise solution, 
different from Member State to member State: 1825€

. 

Option 

Cost per installation 
(Euros) 

A 

B 

C1 

C2 

D1 

D2 

E 

4015 

4015 

325 

325 

1825 

1825 

1825 

•  Summary 

•  MRI facilities already have a risk-management framework in place. 

•  MRI use would be profoundly affected by Option A, and probably B 

•  Option A (and probably B) would lead to a health detriment for the society as well as a 

financial cost. 

•  Additional costs for option C1 

This option foresees reinforced qualitative measures (see 4.1.3). This will mainly consist of specific 
training  and  refreshing  sessions  for  the  personnel  working  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 personnel is considered close to 0 as they already 
get  extensive  training  on  the  subject;  specific  training  for  cleaning  personnel  (min.  3  per 

EN 

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installation) would  be 0.5 day and for nurses and dedicated personnel (min. 10 per installation) 1 
additional training day per person, during the first year. With a cost estimate of 150 € per day for 
approx.  110.000  persons  brings  the  additional  cost  to  approx.  14.25  Million  Euros  (3000  persons 
from maintenance, 24000 for cleaning, 83000 medical personnel). 

EN 

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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  costs  of  actions  that  employers  have  to  undertake  in  order  to 
understand the requirements and comply with them. This comprises a series of tasks starting with 
the analysis of the situation, the organisation of the risk assessment and the setting up of the action 
plan. The tables in Appendix 5a below presents the generic compliance costs for each policy option. 
For the calculation, a number of assumptions were made: 

Number  of  concerned  organisations:  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  number  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  workplace  assessments  would  take  place  across  sectors.  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  and  services  (except  activities  of  households  as  employers  and  extra-
territorial  organisations  and  bodies).  Time  needed  to  perform  the  actions:  Based  on  the  experts 
opinion as set in FICETTI study. 

Appendix 5a - Generic costs summary 

Policy option 

Costs (Million Euro) 

A 

B 

C1 

C2 

D1 

111.7 

111.7 

111.7 

111.7 

39.4 

56 

http://epp.eurostat.ec.europa.eu/cache/ITY_OFFPUB/KS-ET-10-001/EN/KS-ET-10-001-EN.PDF 

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D2 

E 

22.5 

76.3 

B) Sectoral or activity specific costs 

The costs include the EMF measurement and the introduction of protection measures 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 there are no substantial changes in the workplace design, 
equipment used or working procedures. 

The table in Appendix 5b includes: 

Sectors:  Main  types  of  activities  where  workers  are  exposed  to  EMF.  For  the  military  sector,  the 
costs could be estimated only on speculative basis and are therefore omitted in the calculations. 

Workers exposed and number of workplaces/assessments: Number of potentially affected workers 
and workplaces in the concerned sectors in the EU is estimated based 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 enterprises in the concerned sectors. 

Appendix 5b - Sectoral or activity specific costs summary 

Policy Option 

Costs (Million Euro) 

A 

B 

C1 

C2 

D1 

D2 

E 

548.0 

414.6 

385.1 

385.1 

397.1 

397.1 

397.1 

C) Training costs 

The Framework Directive 89/391/EC sets the obligation for employers to provide the training and 
information, so the inclusion of EMF aspects into the overall existing OSH training may induce on 
average the cost of 300€. It is considered 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 

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does not take into account the cost of workers’ salaries 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 

B: new ELVs for 
all sectors 

C1: possibility 
for derogation 
from ELVs 

C2: some 
workers out of 
scope 

D1: non-binding 
recommendations 
only 

D2: sectoral 
agreements only 

E: no EU action 

660.2 

526.8 

511.6* 

493.3 

437.0 

420.1 

473.9 

*including reinforced training for MRI 

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Appendix 5b. Sectoral costs  

Sectors 

Workers 
exposed 

Number of 
workplaces/ 
assessments 

Cost 
per 
establis
hment 
A 

EU total 

Cost 
per 
establis
hment 
B 

EU total 

Cost 
per 
establis
hment 
C1 

EU total 

Cost 
per 
establis
hment 
C2 

EU total 

Cost 
per 
establis
hment 
D1 

EU total 

Cost 
per 
establis
hment 
D2 

EU total 

Cost 
per 
establis
hment 
E 

EU total 

Metal industry 

1019000 

162140

Welding 

Induction heating 

Dielectric heating 

Non-destructive magnetic 
testing 

Electrolysis 

730000 

150000 

90000 

45000 

4000 

Rail transportation 

120000 

73000

75000

1825

133225000

1375 100375000

1375 100375000 

1375 100375000

1375 100375000

1375 100375000

1375  100375000 

4015

301125000

2680 201000000

2680 201000000 

2680 201000000

2680 201000000

2680 201000000

2680  201000000 

9000

3000

27000000

3000

27000000

3000

27000000 

3000

27000000

3000

27000000

3000

27000000

3000 

27000000 

5000

1825

9125000

1825

9125000

1825

9125000 

1825

9125000

1825

9125000

1825

9125000

1825 

9125000 

140

500

4015

1100

562100

1825

255500

1825

255500 

1825

255500

1825

255500

1825

255500

1825 

255500 

550000

1100

550000

1100

550000 

1100

550000

1100

550000

1100

550000

1100 

550000 

Telecommunications 
&broadcasting 

Broadcasting 

Radar systems 

Mobile base stations 

39500 

11000

13500 

20000 

6000 

1500

150

225000

150

225000

150

225000 

150

225000

150

225000

150

225000

150 

225000 

3500

1100

3850000

1100

3850000

1100

3850000 

1100

3850000

1100

3850000

1100

3850000

1100 

3850000 

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 

MRI 

Surgical  and  therapeutic 
diathermy 

Research 

Other 

Military 

211000 

13000

111000 

8000

4015

32120000

4015

32120000

100000 

5000

272

1360000

272

1360000

325

272

2600000 

325

2600000

1825

14600000

1825

14600000

1825 

14600000 

1360000 

272

1360000

272

1360000

272

1360000

272 

1360000 

1000 

500

1825

912500

1825

912500

1825

912500 

1825

912500

1825

912500

1825

912500

1825 

912500 

50000 

25000

1100

27500000

1100

27500000

1100

27500000 

1100

27500000

1100

27500000

1100

27500000

1100 

27500000 

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 

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Appendix 5a. Generic costs 

Policy option A 

No 

Type 
obligation 

of 

Description 
required action 

of 

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 

2 

Background 

3 

Determine 
what 
assessment 
is needed 

4 

Detailed 
background 

Understanding 
instruction 
from 
national  authority  that 
specific  sectors  need 
take no action 

that 
Organisations 
implicitly do not need to 
do  any  assessment  at  all 
eg  SMEs  with 
no 
significant EMF sources 

Understanding  general 
Directive  requirements 
& 
implementation 
framework  (Guide  etc) 
at a basic level 

All  employers  who  may 
need 
an 
to  make 
assessment 

the 
Assess  whether 
workplace 
is 
automatically compliant  

All  employers  who  may 
need 
an 
to  make 
assessment 

Understanding  detailed 
Directive  requirements 
& 
implementation 
framework  (Guide  etc) 
at a basic level 

Employers 
with 
workplaces  that  are  not 
automatically compliant 

20000000 

18,75 

10 

3,125 

1 

62.500 

300000 

18,75 

30 

9,375 

1 

2.813 

300000 

18,75 

15 

4,6875 

1 

1.406 

300000 

18,75 

480 

150 

1 

45.000 

Total (M€)  

111,7 

EN 

100 

   EN 

 
Policy option B 

No 

Type 
obligation 

of 

Description 
required action 

of 

Target group 

1 

Triage 

Understanding 
instruction 
from 
national  authority  that 
sectors  need 
specific 
take no action 

Organisations 
that 
implicitly do not need to 
do any assessment at all 
eg  SMEs  with  no 
significant EMF sources 

2 

Background 

3 

Determine 
what 
assessment 
is needed 

4 

Detailed 
background 

Understanding  detailed 
requirements 
Directive 
implementation 
& 
framework  (Guide  etc) 
at a basic level 

the 
Assess  whether 
is 
workplace 
automatically  compliant 
(Table 1 of EN50499 & 
Guide) 

Understanding  general 
requirements 
Directive 
& 
implementation 
framework  (Guide  etc) 
at a basic level 

All employers who may 
an 
to  make 
need 
assessment 

All employers who may 
need 
an 
to  make 
assessment 

Employers 
with 
workplaces  that  are  not 
automatically compliant 

Estimated 
number 
of 
such 
organisati
ons 

Tariff 
(per 
hour) 

Time 
(minutes) 

Price  (per 
action)  

Total 
number 
of actions 

Total 
generic 
costs 
(M€) 

20000000 

18,75 

10 

3,125 

1 

62.500 

300000 

18,75 

30 

9,375 

1 

2.813 

300000 

18,75 

15 

4,6875 

1 

1.406 

300000 

18,75 

480 

150 

1 

45.000 

Total (M€)  

111.7 

EN 

101 

   EN 

 
Policy option C1 

No 

Type 
obligation 

of 

Description 
required action 

of 

Target group 

1 

Triage 

2 

Background 

3 

Determine 
what 
assessment 
is needed 

4 

Detailed 
background 

Understanding 
instruction 
from 
national  authority  that 
sectors  need 
specific 
take no action 

Organisations 
that 
implicitly do not need to 
do any assessment at all 
eg  SMEs  with  no 
significant EMF sources 

Understanding  general 
requirements 
Directive 
implementation 
& 
framework  (Guide  etc) 
at a basic level 

All employers who may 
an 
to  make 
need 
assessment 

Assess  whether 
the 
is 
workplace 
automatically compliant  

All employers who may 
an 
to  make 
need 
assessment 

Understanding  detailed 
requirements 
Directive 
& 
implementation 
framework  (Guide  etc) 
at a basic level 

with 
Employers 
workplaces  that  are  not 
automatically compliant 

Estimated 
number 
of 
such 
organisati
ons 

Tariff 
(per 
hour) 

Time 
(minutes) 

Price  (per 
action)  

Total 
number 
of actions 

Total 
generic 
costs 
(M€) 

20000000 

18,75 

10 

3,125 

1 

62.500 

300000 

18,75 

30 

9,375 

1 

2.813 

300000 

18,75 

15 

4,6875 

1 

1.406 

300000 

18,75 

480 

150 

1 

45.000 

Total (M€)  

111.7 

EN 

102 

   EN 

 
Policy option C2 

No 

Type 
obligation 

of 

Description 
required action 

of 

Target group 

1 

Triage 

2 

Background 

3 

Determine 
what 
assessment 
is needed 

4 

Detailed 
background 

Understanding 
instruction 
from 
national  authority  that 
sectors  need 
specific 
take no action 

Organisations 
that 
implicitly do not need to 
do any assessment at all 
eg  SMEs  with  no 
significant EMF sources 

Understanding  general 
requirements 
Directive 
implementation 
& 
framework  (Guide  etc) 
at a basic level 

All employers who may 
an 
to  make 
need 
assessment 

Assess  whether 
the 
is 
workplace 
automatically compliant  

All employers who may 
an 
to  make 
need 
assessment 

Understanding  detailed 
requirements 
Directive 
& 
implementation 
framework  (Guide  etc) 
at a basic level 

with 
Employers 
workplaces  that  are  not 
automatically compliant 

Estimated 
number 
of 
such 
organisati
ons 

Tariff 
(per 
hour) 

Time 
(minutes) 

Price  (per 
action)  

Total 
number 
of actions 

Total 
generic 
costs 
(M€) 

20000000 

18,75 

10 

3,125 

1 

62.500 

300000 

18,75 

30 

9,375 

1 

2.813 

300000 

18,75 

15 

4,6875 

1 

1.406 

300000 

18,75 

480 

150 

1 

45.000 

Total (M€)  

111.7 

EN 

103 

   EN 

 
Policy Option D1 

N
o 

Type 
obligation 

of 

Description 
required action 

of 

Target group 

Understanding  general 
EMF 
requirements  & 
implementation 
he 
framework 
absence  of  Diretcive 
and Guide etc 

in 

Establishing 
between 
relationship 
any 
recommendation 
that  is  made  and  an 
employer's 
legal 
responsibility 

All  employers  who 
may  need  to  make  an 
assessment 

All  employers  who 
may  need  to  make  an 
assessment 

1 

Background 

Understandin
g 
recommendat
ions 

2 

3 

Estimated 
number of 
such 
organisati
ons 

Tariff 
(per hour) 

Time 
(minutes) 

Price  (per 
action)  

Total 
number of 
actions 

Total 
generic 
costs (M€) 

300000 

18,75 

180 

56,25 

1 

16.875 

300000 

18,75 

120 

18,75 

1 

11.250 

Determine 
what 
assessment  is 
needed 

the 
Assess  whether 
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 

104 

   EN 

 
Policy option D2 

N
o 

Type 
obligation 

of 

Description 
required action 

of 

Target group 

1 

Background 

Understanding  general 
sector-specific 
requirements 

All  employers  who 
may  need  to  make  an 
assessment 

2 

Determine 
what 
assessment  is 
needed 

the 
Assess  whether 
workplace 
is 
automatically  compliant 
with 
sector-specific 
requirements 

All  employers  who 
may  need  to  make  an 
assessment 

Estimated 
number of 
such 
organisati
ons 

Tariff 
(per hour) 

Time 
(minutes) 

Price  (per 
action)  

Total 
number of 
actions 

Total 
generic 
costs (M€) 

300000 

18,75 

120 

18.75 

1 

11.250 

300000 

18,75 

120 

37.50 

1 

11.250 

Total (M€)  

22.5 

EN 

105 

   EN 

 
Policy option E 

No 

Type 
of 
obligation 

Description 
required action 

of 

Target group 

1 

Triage 

2 

Backgroun
d 

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 

Understanding  general 
EMF  requirements  of 
Framework  Directive  in 
absence  of  guidance 
associated  with  EMF 
Directive 

All 
employers  who 
may  need  to  make  an 
assessment 

Estimated 
number 
of 
such 
organisati
ons 

Tariff 

Time 

(minutes) 

Price  (per 
action)  

Total 
number 
of actions 

Total 
generic 
costs (M€) 

10000000 

18.75 

10 

3.125 

1 

31.250 

300000 

18.75 

480 

300 

1 

45.000 

Total (M€)  

76.3 

EN 

106 

   EN 

 
Appendix 5c. Training costs (as estimated by FICETTI) 

No 

Type 
obligation 

of 

Description  of  required 
action 

Target group 

13 

Training 
and 
informing 

Organising  training  and 
informing 

14 

15 

Preparing  training  and 
information materials 

Providing  training  and 
information 

with 
Employers 
workplaces 
where 
exposures  do  not  met 
of 
requirements 
Framework Directive 

with 
Employers 
workplaces 
where 
exposures  do  not  met 
requirements 
of 
Framework Directive 

Employers 
with 
where 
workplaces 
exposures  do  not  met 
requirements 
of 
Directive 

Estimated 
number  of 
such 
organisatio
ns 

Tariff  (per 
hour) 

Time 
(minutes) 

Price  (per 
action)  

Freq 
year 

per 

Total 
number  of 
actions 

Total 
generic 
costs (M€)  

60000 

18,75 

60 

18,75 

0,33 

1 

0,0003712
5 

60000 

18,75 

480 

150 

0,25 

1 

0,018 

60000 

18,75 

480 

150 

1 

1 

0,072 

Total (M€) 

0,09 

EN 

107 

   EN 

 
  
  
Annex 6 
Details on costs related to Administrative Burden 

Policy option A 

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Policy option B 

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,33 

1 

0,0309375

millions euro 

0,12375

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,33 

1 

0,0309375

millions euro 

0,12375

EN 

108 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Policy option C1 

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Policy option C2 

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,33 

1 

0,0309375

millions euro 

0,12375

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,33 

1 

0,0309375

millions euro 

0,12375

EN 

109 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Policy option D1 

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Policy option D2 

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,25 

1 

0,0234375

millions euro 

0,11625

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

 2 

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,33 

1 

0,0928125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,33 

1 

0,0309375

millions euro 

0,12375

EN 

110 

   EN 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Policy option E 

Type 
of 
obligation 

Description  of 
required action  Target group 

No 

Estimated 
number 
such 
organisations 

of 

Tariff 
(I  per 
hour) 

Time 
(minutes) 

Price 
(per 
action) 

Freq 
per 
year 

Total 
number 
of 
actions 

Total 
Administrative 
Costs 

Recording  of 
EMF 
assessment 
results 
required 
national 
legislation 

as 
by 

Notification  to 
competent 
authorities 
(according 
national 
requirements) 

to 

1    

2    

Employers 
who 
made/had 
made 
EMF 
assessment 

have 

an 

30000 18,75

30

9,375

0,1 

1 

0,028125

Employers 
in  countries 
where  this  is 
required 

Total 

30000 18,75

10

3,125

0,2 

1 

0,01875

millions euro 

0,046875

EN 

111 

   EN 

 
 
 
 
 
 
 
 
Annex 7 
Questions (without additional comments and original layout) of the questionnaire on 
health, socio-economic and environmental 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 suffering from work-related illness? This may be 
an effect of EMF itself on a worker, it may be stress 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 health 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 EMF exposures are limited, or it may increase 
opportunities because a risk assessment as required by the EMF Directive may indicate that 
no particular risk for the pregnant worker or fetus occurs., 

4a. Does the option affect the health risk of fertile-aged women? 

4b. Does the option affect the job opportunities of fertile-aged women? 

5. Does the option increase or decrease the knowledge of employers and employees related to 
health risks arising from EMF? 

6. During a risk assessment involving a lot of different 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  EMF  exposure  assessments  in  your  sector?  The 
requirements to undertake  EMF exposure assessments, and the circumstances in which they 
should or should not be made, are described in the Non-binding Guide to the EMF Directive 
which is available in draft form at www.indigo-emf.eu (password: ECIndigoLock). 

8. Does the option affect the quality of EMF exposure assessments in your sector? 

9.  Does  the  option  increase  knowledge  of  employers  on  how  to  adequately  manage 
occupational exposure to EMF? 

EN 

112 

   EN 

 
10. How does the option affect preventive technical actions and 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  likelihood  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 changes 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  EMF  Directive  describes  the  circumstances  in  which  risk 
assessment might be required and explains 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  Directive  describes  the  circumstances  in  which 
training might be required 

11d. Does the option affect the costs of trainings 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  changes  in  work  equipment  at  workplaces  in  a 
company?  Please  note  that  the  Non-binding  Guide  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  medical  examinations  of  workers  exposed  in  a 
company?  Please  note  that  the  Non-binding  Guide  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 sector 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 

113 

   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 affect training activities? 

22.  Does  the  option  increase  or  decrease  the  inequality  between  different  sized  enterprises 
(large-scale  enterprises,  SMEs,  micro-sized  organizations)  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  organizations)  regarding  their  ability  to  protect 
their employees against health risks arising from EMF? 

24. Does the option increase or decrease the competitiveness of EU enterprises compared to 
non-EU rivals? 

25. Do you think that the options presented here guarantee the same level 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 the needs for research and development? 

27. Does the option facilitate the introduction and dissemination of new production methods, 
technologies and products? 

28a. Does the option facilitate or restrict the use of technological innovations in your sector? 

29a.  Please  rank  the  different  options  regarding  their  suitability  for  the  health  care  of  the 
employees.  Use  "7"  for  the  option  with  the  strongest  effect  to  "1"  for  the  option  with  the 
lowest effect. 

29b.  Please  rank  the  different  options  regarding  their  ability  to  make  legislation  easier  to 
apply. 

29c.  Please  rank  the  different  options  regarding  their  ability  to  decrease  the  administrative 
burden to employers. 

29d.  Please  rank  the  different  options  regarding  their  efficiency  in  implementation  and 
enforcement of prevention of health risks from EMF. 

EN 

114 

   EN 

 
Annex 8 
Estimated cost for cases of overexposure 

According  to  current  directive  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 and health insurance (work inability, long- term 
disability)  and  from  organizational  managing  of  the  case.  If  the  risk  assessment  has  been 
performed appropriately, the managing of the subject is more rapid and the costs are lower. 

The investigation procedure depends on how well 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. Symptoms to the nervous system, 
both  central  nervous  systems  (CNS)  and/or  peripheral  nervous  system  (PNS)  are  also 
considered. More advanced methods in diagnostics might include neurological and laboratory 
studies.  

The estimations of costs are presented in the following tables. The estimated total cost for any 
case  of  overexposure  without  any  serious  complications  would  be  approximately  8  k€ 
(reference Finland). The cost increases considerably in case of complications. The use of the 
present  international  safety  limits  in  the  prevention  of  the  overexposure  has  minimized  the 
number of accidental overexposures in the working environment.  

Table 1. Estimated medical examination costs in overexposure case. 

Item 

Details 

Occupational physician 

Two  visits:  evaluation  of  the  present  situation  and 
planning of following steps 

Cost 

200 € 

of  medical 
(neurology, 

Consultation 
specialists 
dermatology, 
ophthalmology) 

Visits and special examination techniques 

1300 € 

Dermatologist 

One visit 

Sick leave days 

Wash  out  after  the  incident,  5  days  á  300  €  (The 
Social 
Institution  of  Finland  has 
estimated the costs of one sick leave day to be 300 
€ on average) 

Insurance 

300 € 

1500 € 

MRI examination (brain) 

Neurophysiologic tests 

required  according 

If 
examinations 

required  according 

If 
examinations 

TOTAL 

3200 € 

to  previous  medical 

1000 € 

to  previous  medical 

1000 € 

EN 

115 

   EN 

 
 
 
Table 2. Estimated organisational costs in overexposure case. 

The  current  information  on 
exposure situation 

Gathering  and  analysing  existing  information 
the  exposure  situation.  (Engineer  0.5 
on 
workdays) 

Legal requirements 

Communication with the authorities. (Engineer 
0.5 workdays) 

Office work 

Mitigation 

General  office  work  related  to  overexposure 
situation (Office staff, 2 work days) 

Technical measures to prevent recurring of the 
event  (based  on  the  induction  heating  case 
study, 'worst-case scenario') 

147 € 

147 € 

300 € 

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 Finland, where the salaries are at the higher end of 
the spectrum. A quick extrapolation shows that in EU, this cost may vary from approx. €2000 
to €4700 depending on the Member State (see sections 5.1.3 and 5.1.8). 

EN 

116 

   EN 

 
 
 
Annex 9  
Survey based assessment of the options 

The social impacts do most prominently 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  restricting  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 conducting an extensive stakeholder survey. This 
survey  was  organized  in  the  framework  of  the  FICETTI  study,  taking  advantage  of  the 
presence  at  the  Ljubljana  workshop  in  February  2009  of  a  large  number  of  stakeholders 
representing a significant number of important sectors. 

166 stakeholders' representatives replied to the questionnaire wherefrom: 

Government/regulator 

Sectoral organization representing employers 

Trade union organization 

Research Centre/university 

OSH specialists/consultants 

Health care 

Large-scale enterprise (> 250 employees) 

SME (10 < employees < 250) 

Micro-sized enterprise (< 10 employees) 

Self-employed 

Other 

Expressed by sector, the partition is as follows: 

Rail transportation

Metal industry 

Health care sector

Telecommunications or broadcast

Electric energy production/distribution/transmission

Other 

11 % 

15 % 

7 % 

10 % 

5 % 

18 % 

24 % 

3 % 

0 % 

0 % 

6 % 

4 % 

15 % 

34 % 

8 % 

7 % 

32 % 

156 (94%) of the respondents were aware of the requirements set in Directive 2004/40/EC. In 
so far it can be said that the respondents were well informed about the ongoing debate.  

There  were  30  questions  (some  with  sub  questions)  in  the  questionnaire  (see  questions  in 
annex 6). The latter addressed health aspects, competiveness, social, administrative aspects in 

EN 

117 

   EN 

 
a  very  comprehensive  way.  The  results  were  duly  affected  by  the  appropriate  weighting 
factors. 

The conclusions of the survey reflect the opinions 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  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 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  proportionality  gave  the 
breakthrough. 

•  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 grounds. Option E especially is 

unpopular with stakeholders. 

EN 

118 

   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 power density (S), at which one or more of the 
specified  measures  in  the  directive  must  be  undertaken.  Compliance  with  these  values  will 
ensure compliance with the relevant exposure limit values. 

Electromagnetic 
electromagnetic fields with frequencies up to 300 GHz; 

fields:  static  magnetic  and 

time-varying  electric,  magnetic  and 

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 person is exposed. The exposure level is 
expressed  in  Volt  per  meter  (V/m)  for  the  electric  field  strength  and  in  Amperes  per  meter 
(A/m) for the magnetic field strength. For the magnetic field, this value 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  biological  considerations.  Compliance  with  these 
limits  will  ensure  that  workers  exposed  to  electromagnetic  fields  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  and/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 Electrotechnical Standardisation 

COCIR  -  European  Coordination  Committee  of  the  Radiological,  Electromedical  and 
Healthcare IT Industry 

EAS – Electronic Article Surveillance 

ELF(s) – Extremely Low frequencies 

EN 

119 

   EN 

 
ELV(s) – Exposure Limit Values 

EMF – Electromagnetic Fields 

ESR – European Society of Radiology 

HF(s) - High Frequencies 

HPA – Health Protection Agency (UK) 

HSE – Health and Safety Executive (UK) 

ICNIRP – International Commission on Non-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 

EN 

120 

   EN