COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Council Directive 98/24/EC and Directive 2004/37/EC of the European Parliament and of the Council as regards the limit values for lead and its inorganic compounds and diisocyanates
Date: 2023-02-13
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: chemical compound, health risk, lead, occupational safety, reproductive health, respiratory disease, safety standard, toxic substance

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.2.2023  SWD(2023) 34 final  COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Council Directive 98/24/EC and Directive 2004/37/EC of the European Parliament and of the Council as regards the limit values for lead and its inorganic compounds and diisocyanates   {COM(2023) 71 final} - {SEC(2023) 67 final} - {SWD(2023) 35 final} - {SWD(2023) 36 final}  
 
 
Subsidiarity Grid 

1.  Can the Union act? What is the legal basis and competence of the Unions’ intended action? 

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative? 

Article  153  of  the  Treaty  on  the  Functioning  of  the  European  Union  (TFEU),  which  empowers  the 
European  Union  to  support  and  complement  the  activities  of  the  Member  States  as  regards 
improvements, in particular of the working environment to protect workers' health and safety and to 
adopt, by means of directives, minimum requirements for gradual implementation, having regard to 
the conditions and technical rules obtaining in each of the Member States. 

Article 154  of the  TFEU, which requests the  Commission to initiate a two-stage  consultation of the 
social partners at the EU level prior to submitting proposals in the social policy field. 

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in 
nature? 

In  the  case  of  social  policy,  the  Union’s  competence  is  shared.  Article  153(1)(a)  of  the  TFEU  states 
that  the  Union  shall  support  and  complement  the  activities  of  the  Member  States  in  the  field  of 
“improvement in particular of the working environment to protect workers’ health and safety”. 

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in 
Article  3  TFEU1.  It  is  the  specific  legal  basis  which  determines  whether  the  proposal  falls  under  the 
subsidiarity  control  mechanism.  Article  4  TFEU2  sets  out  the  areas  where  competence  is  shared 
between the Union and the Member States. Article 6 TFEU3 sets out the areas for which the Unions 
has competence only to support the actions of the Member States. 

2.  Subsidiarity Principle: Why should the EU act? 

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 24: 

-  Has there been a wide consultation before proposing the act? 
- 

Is  there  a  detailed  statement  with  qualitative  and,  where  possible,  quantitative  indicators 
allowing an appraisal of whether the action can best be achieved at Union level? 

As requested by the TFEU Article 154, a formal two-stage consultation of the social partners at EU 
level is required prior to submitting proposals in the social policy field. Such a two-stage consultation 
was  performed  in  2021.  The  Commission  has  also  consulted  the  tripartite  Advisory  Committee  on 
Safety  and  Health  (ACSH)  and  its  Working  Party  on  Chemicals  (WPC),  both  composed  of 
representatives  from Member  States,  representing national governments, workers’ and employers’ 
organisations. The ACSH has adopted an opinion on 24 November 2021. In addition to that, a call for 
evidence was published on the Europa website for feedback in February 2022.  

The  explanatory  memorandum  and  the  impact  assessment  contain  a  section  on  the  principle  of 
subsidiarity. More information is available in question 2.2 below. 

2.2 Does  the  explanatory  memorandum  (and  any 

impact  assessment)  accompanying  the 
Commission’s  proposal  contain  an  adequate  justification  regarding  the  conformity  with  the 

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN  
2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN  
3 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML  
4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN  

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principle of subsidiarity? 

Both  the  explanatory  memorandum  and  the  impact  assessment  accompanying  the  Commission’s 
proposal contain an adequate justification regarding the conformity with the principle of subsidiarity. 

As risks to workers’ health and safety are broadly similar across the European Union, there is a clear 
role for the EU in supporting Member States to address such risks.  

Data  gathered  in  the  preparatory  work  indicate  that  there  are  differences  in  the  Member  States 
regarding the setting of limit values both for lead and for diisocyanates, subjecting workers in the EU 
to different levels of protection.  

Significant divergences between national limit values distort competition in the internal market. The 
costs of complying with lower national levels are generally higher and entail, therefore, a competitive 
advantage for enterprises operating in markets with no or less stringent national limit values.  

For lead, companies based in Bulgaria, Czechia, Denmark, Latvia and Poland need to comply with an 
Occupational  Exposure  Limit  (OEL)  EL  3  times  lower  than  the  maximum OEL set  at  EU  level  (0.050 
g/m3 vs 0.150 g/m3). 15 Member States have a Biological Limit Value (BLV) lower than the current EU 
BLV. Some Member States have a lower limit for women, this is age dependent or stated as women 
of childbearing age and typically ranges between 20-40 µg/100ml blood. The (OEL ranges from 0.050 
mg/m3 to 0.15 mg/m3 (the current OEL under the Carcinogens, Mutagens and Reprotoxic Substances 
Directive5 [CMRD]).  

For diisocyanates, as there is no EU limit value, differences are even larger. Three EU Member States 
have  a general OEL and 18 have different OELs for some, but  not all, diisocyanates. As regards the 
Short  Term  Exposure  Level  (STEL),  17  Member  States  have  a  STEL,  of  which  only  5  have  a  general 
level;  the  others  are  for  specific  diisocyanates  substances.  This  makes  presenting  a  general  range 
challenging.  However,  where  they  exist,  OELs  range  from  3  µg  NCO/m3  to  500  µg  NCO/m3  with  a 
median value of 17.4 µg NCO/m3. For the STEL, the range is from 10 to 82 µg NCO/m3.  

Updating  the  CMRD  for  lead  and  the  Chemical  Agents  Directive6  (CAD)  for  diisocyanates  is  an 
effective  way  to  ensure  that  preventive  measures  would  be  updated  accordingly  in  all  Member 
States, providing a uniform level of minimum requirements designed to guarantee a better standard 
of  health  and  safety  and  thus  minimising  the  disparities  in  health  and  safety  protection  levels  of 
workers between Member States. 

Moreover,  a  revision  of  those  directives  can  only  be  done  by  action  at  EU  level.  Such  revision  is 
necessary  in  view  of  the  development  of  scientific  knowledge  in  this  area.  The  fact  that  15  EU 
Member  States  have  already  reduced  their  exposure  limit  values  for  lead  and  that  18  have 
introduced limit values for diisocyanates demonstrates this need. The need for revision has also been 
recognised by the tripartite ACSH. 

The revision of the limit values under the CMRD and the CAD at the EU level will lead to a greater 
harmonisation of limit  values  across the  EU. Companies willing to operate  in different  EU Member 
States can further benefit from a streamlining of the applicable limit values, potentially providing for 
savings as common solutions can be  adopted across facilities, as opposed to having to design site-
specific solutions to meet different requirements.  

Furthermore,  the  revision  of  limit  values  is  very  complex  and  requires  a  high  level  of  scientific 
expertise. An important advantage of the revision of the limit values at EU level is that it eliminates 
the need for Member States to conduct their own scientific analysis, with likely substantial savings on 

6 Directive 98/24/EC 

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administrative  costs.  These  resources  saved  could  instead  be  dedicated  to  further  improving 
occupational safety and health (OSH) policies in each Member State.  

2.3 Based  on  the  answers  to  the  questions  below,  can  the  objectives  of  the  proposed  action  be 

achieved sufficiently by the Member States acting alone (necessity for EU action)? 

Risks to workers’ health and safety are broadly similar across the European Union. National actions 
alone  lead  to  insufficient  and  divergent  levels  of  protection  of  workers’  health,  as  well  as  to  an 
uneven playing field for businesses. 

(a)  Are  there  significant/appreciable  transnational/cross-border  aspects  to  the  problems  being 

tackled? Have these been quantified? 

As explained in point 2.2, risks to workers’ health and safety are broadly similar across the European 
Union. However, data gathered in the preparatory work indicates differences in the Member States 
regarding the OEL and BLV for lead and the OEL and STEL for diisocyanates. 

It is estimated that currently between 50 000 and 150 000 workers are exposed to lead. Determining 
a  precise  number  for  lead  is  difficult  because  workers  in  sectors  such  as  demolition,  waste 
management, and those using articles of lead metal may only occasionally be exposed to lead, but 
sometimes at relatively high levels. Approximately 4.2 million workers are exposed to diisocyanates. 

Moreover,  diisocyanates  are  found  in  insulation  materials  in  construction,  and  this  sector  is 
characterised by a considerable level of cross-border work. 

Therefore,  such  differences  in  limit  values  result  in  high  disparities  in  the  levels  of  protection  of 
workers’ health in the different Members States. 

(b)  Would national action or the absence of the EU level action conflict with core objectives of 

the Treaty7 or significantly damage the interests of other Member States? 

National  actions  alone  lead  to  high  disparities  between  the  existing  national  limit  values,  with  the 
consequences in point 2.3 (a) above. EU level action would  not conflict with core objectives of the 
Treaty  or  significantly  damage  the  interests  of  other  Member  States.  On  the  contrary,  it  would 
enable among others to: 

- 
- 
- 
- 

ensure a similar and fair minimum level of protection across the European Union; 
contribute to a level playing field; 
improve clarity and enforcement of the CMRD and the CAD; 
assume burdens at EU level related to revision of the limit values by eliminating the need for 
Member States to individually conduct their own scientific analyses. 

(c)  To  what  extent  do  Member  States  have  the  ability  or  possibility  to  enact  appropriate 

measures? 

The  CMRD  aims  to  protect  workers  from  the  health  and  safety  risks  related  to  exposure  to 
carcinogens, mutagens or substances toxic to reproduction at work. The CAD aims to protect workers 
from risks to their safety and health arising, or likely to arise, from the effects of chemical agents that 
are present at the workplace.  

A  consistent  level  of  protection  from  the  risks  related  to  carcinogens,  mutagens  and  reprotoxic 
substances, and to chemical agents respectively is provided for by a framework of general principles 
to  enable  Member  States  to  ensure  the  consistent  application  of  the  minimum  requirements.  The 

7 https://europa.eu/european-union/about-eu/eu-in-brief_en  

3 

 
 
 
                                                           
minimum requirements  provided for in the  Directives  aim  to protect  workers at  Union level. More 
stringent binding limit values or other protective measures can be set by Member States.  

(d)  How  does  the  problem  and  its  causes  (e.g.,  negative  externalities,  spill-over  effects)  vary 

across the national, regional and local levels of the EU? 

Risks to workers’ health and safety are broadly similar across the European Union.  

However,  in  the  absence  of  EU  action,  the  level  of  workers’  protection  from  exposure  to  lead  can 
diverge  from  a  Member  State  to  another  depending  among  others  on  whether  national  OELs  and 
BLVs  have  already  been  revised  following  scientific  development.  For  instance,  15  Member  States 
have a BLV lower than the EU level (Bulgaria, Croatia, Czechia, Denmark, Finland, France, Germany, 
Hungary,  Italy,  Latvia,  the  Netherlands,  Poland,  Slovakia,  Slovenia  and  Sweden).  Some  Member 
States also have lower, age-dependant limits for women.  

As for diisocyanates, despite the lack of EU limit values, three EU Member States have a general OEL   
and 18 have different OELs and STELS for some, but not all, different diisocyanates. 17 have a STEL.  

(e)  Is the problem widespread across the EU or limited to a few Member States? 

Although the current levels of protection diverge considerably, the problem is widespread across the 
European Union as risks to workers’ health and safety are broadly similar. 

A  wide variety of  sectors  working with  lead  are  particularly  represented  in  France,  Germany,  Italy, 
Poland  and  Spain,  in  which  the  existing  limit  value  is  higher  than  the  Commission  proposal. 
Therefore, these Member States are expected to be more affected by a lowering of the limit values, 
although all will be impacted.  2.4 million companies across most Member States are concerned by 
the proposal on diisocyanates. 

(f)  Are Member States overstretched in achieving the objectives of the planned measure? 

The  process  of  establishing  limit  values  is  very  complex  and  requires  a  high  level  of  scientific 
expertise. This could partly explain why some Member States have not yet lowered their OELs and 
BLVs  for  lead  (from  the  values  set  at  EU  level  in  1982)  or  have  not  introduced  limit  values  for 
diisocyanates. An important advantage of setting limit values at EU level is that it eliminates the need 
for  Member  States  to  conduct  their  own  scientific  analyses,  with  likely  substantial  savings  on 
administrative costs. Given the limited resources for OSH at national level, this could release funds to 
be redirected into other OSH priorities. 

(g)  How  do  the  views/preferred  courses  of  action  of  national,  regional  and  local  authorities 

differ across the EU? 

Acknowledging  the  development  of  the  scientific  knowledge,  15  EU  Member  States  have  already 
reduced their BLV for lead, 21 have introduced an OEL for diisocyanates and 17 a STEL. 

The  tripartite ACSH  (composed of  representatives of  National Authorities, Employers  and Workers´ 
organisations  in  each  Member  State),  in  November  2021,  reached  a  consensus  on  the  need  to 
substantially  revise  downwards  the  existing  binding  OEL  and  BLV  for  lead  and  to  introduce  an  OEL 
and  STEL  for  diisocyanates  to  better  protect  workers’  health  and  safety  and  thus  reduce  the 
probability for occupational diseases to happen.8 

8 DOC.008 21. ACSH Opinion on an EU Binding Occupational Exposure Limit Value for Asbestos under the 
Asbestos at Work Directive 2009/148/EC. Adopted on 24/11/2021 

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2.4 Based  on  the  answer  to  the  questions  below,  can  the  objectives  of  the  proposed  action  be 
better achieved at Union level by reason of scale or effects of that action (EU added value)? 

Acting  at  the  EU  level  would  enable  among  others  to  ensure  a  fair  similar  minimum  level  of 
protection  across  the  European  Union,  contribute  to  a  level  playing  field  and  improve  clarity  and 
enforcement. Revising  the limit values  at the EU level would also enable  to eliminate the need for 
Member  States  to  conduct  their  own  scientific  analyses  with  likely  substantial  savings  on 
administrative costs.  

(a)  Are there clear benefits from EU level action?  

Amending Directive 98/24/EC and 2004/37/EC presents an EU added value in several aspects:  

Ensuring a similar and fair minimum level of protection across the European Union; 

- 
-  Contributing to a level playing field; 
-  Assuming burdens at EU level related to revision of limit values.  

More information can be found in point 3.2 of the Impact Assessment. 

(b)  Are there economies of scale? Can the objectives be met more efficiently at EU level (larger 

benefits per unit cost)? Will the functioning of the internal market be improved? 

The  process  of  establishing  limit  values  is  very  complex  and  requires  a  high  level  of  scientific 
expertise.  An  important  advantage  of  setting  OELs  at  EU  level  is  that  it  eliminates  the  need  for 
Member  States  to  conduct  their  own  scientific  analyses.  These  economies  of  scale  should  lead  to 
likely  substantial  savings  on  administrative  costs.  Given  the  limited  resources  for  OSH  at  national 
level, this could release funds to be redirected into other OSH priorities. 

(c)  What  are  the  benefits  in  replacing  different  national  policies  and  rules  with  a  more 

homogenous policy approach? 

Directives 98/24/EC and 2004/37/EC do not aim to replace national policies and rules but rather to 
set minimum requirements in order to protect workers at  EU level. More stringent binding OELs or 
other protective measures can be set by Member States.  

However, the minimum requirements provided for in the Directives aim, among others, to ensure a 
similar minimum level of protection across the European Union while contributing to a level playing 
field and a better functioning of the internal market. 

(d)  Do  the  benefits  of  EU-level  action outweigh  the  loss of  competence  of  the  Member  States 
and  the  local and  regional  authorities  (beyond  the  costs  and  benefits of  acting  at  national, 
regional and local levels)? 

The fight against occupational diseases remains a high priority in the area of OSH at EU-level.  

The  Commission  announced  in  the  European  Pillar  of  Social  Rights  Action  Plan  the  intention  to 
ensure a healthy, safe and well adapted work environment, which was confirmed with the adoption 
of the OSH Strategic Framework for 2021-2027. Also, the 2020 Chemicals Strategy for Sustainability 
recognises  the  need  to  strengthen  the  protection  of  workers  and  identifies  lead  and  diisocyanates 
among the priority chemicals to act upon.  

Therefore,  acting  at  the  EU  level  will  enable  to  support  all  the  Member  States  in  addressing 
occupational diseases arising from exposure to chemicals at work. In addition to that, Member States 
can continue to set additional or more stringent binding OELs, or other protective measures. 

5 

 
 
(e)  Will there be improved legal clarity for those having to implement the legislation? 

The revision of the limit values under the CMRD and the CAD at the EU level will lead to a greater 
harmonisation of limit values  across Europe, with expected improvements in the  level playing field 
for enterprises, particularly those operating in different Member States.  

The revision of the CAD to remove the reference to lead, and the simultaneous revision of the CMRD 
to update the OEL and BLV for lead will substantially improve legal clarity, as provisions on lead will 
only  be  included  in  one  legal  instrument,  therefore  eliminating  the  risk  of  contradictions  and 
discrepancies between the two, and clearly outlining employers’ responsibilities and the protective 
measures to follow.  

3.  Proportionality: How the EU should act 

3.1  Does  the  explanatory  memorandum  (and  any  impact  assessment)  accompanying  the 
Commission’s proposal contain an adequate justification regarding the proportionality of the 
proposal  and  a  statement  allowing  appraisal  of  the  compliance  of  the  proposal  with  the 
principle of proportionality? 

Both  the  explanatory  memorandum  and  the  impact  assessment  accompanying  the  Commission’s 
proposal contain such a justification.  

This  proposal  makes  a  step  forward  to  achieve  the  objectives  set  to  improve  living  and  working 
conditions of workers.  

With  regard  to  the  revision  of  the  limit  values  proposed,  socio-economic  and  technical  feasibility 
factors  have  been  taken 
intensive  discussions  with  all  stakeholders 
(representatives  of  workers’  organisations,  representatives  of  employers’  organisations,  and 
representatives of governments). 

into  account  after 

The costs of the proposed option for lead would amount to EUR 30 000 per company over 40 years, 
which represents less than 1% of companies’ turnover. For diisocyanates, a company would have to 
spend  EUR 6 000  over  40  years,  which  would  not  represent  a  significant  share  of  their  turnover 
either.  Besides,  the  values  are  endorsed  by employers,  meaning  that  despite  the  costs,  businesses 
consider it a proportionate option.  

In  accordance  with  Article  153(4)  of  the  TFEU,  the  provisions  in  this  proposal  do  not  prevent  any 
Member State from maintaining or introducing more stringent protective measures compatible with 
the Treaties, in the form for example of lower limit values. Article 153(3) of the TFEU gives Member 
States  the  possibility  to  entrust  management  and  labour,  at  their  joint  request,  with  the 
implementation  of  directives  adopted  pursuant  to  Article  153(2)  of  the  TFEU,  thus  respecting  well 
established national arrangements for regulation in this area.  

It follows that in line with the principle of proportionality, as set out in Article 5(4) of the TFEU, this 
proposal  does  not  go  beyond  what  is  necessary  in  order  to  achieve  its  objectives,  namely,  the 
improvement of the health and safety of workers pursuant to Article 153 TFEU. 

3.2 Based  on  the  answers  to  the  questions  below  and  information  available  from  any  impact 
assessment,  the  explanatory  memorandum  or  other  sources,  is  the  proposed  action  an 
appropriate way to achieve the intended objectives? 

6 

 
 
 
The European Pillar of Social Rights9, jointly proclaimed by the European Parliament, the Council and 
the  Commission  at  the  Social  Summit  for  Fair  Jobs  and  Growth  on  17  November  2017,  enshrines 
workers'  right  to  healthy,  safe,  and  well-adapted  work  environment,  including  protection  from 
harmful substances, which covers lead and diisocyanates. 

Therefore, it is appropriate to act at the EU level in order to ensure to the workers the right to a high 
level of protection of their health and safety at work, and to support and complement the activities 
of the Member States in this regard, pursuant to Article 153 of the TFEU. 

It is all the more appropriate as the CMRD and CAD are already in force, and this proposal is limited 
to revising the limit values of two of the substances covered by those directives on the basis of the 
latest scientific and technical data available. 

(a)  Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on 

their own, and where the Union can do better? 

This initiative  aims at ensuring  a balanced approach, i.e.,  to prevent companies from facing severe 
economic  disadvantages  while  providing  an  adequate  protection  to  workers  at  EU  level.  It  is 
considered  balanced  and  justified  in  light  of  the  accrued  and  longer-term  benefits  in  terms  of 
reducing  health  risks  arising  from  workers'  exposure  to  asbestos  and  saving  lives,  without  putting 
disproportionate  burdens  on  economic  operations  in  the  concerned  sectors,  including  on  micro, 
small and medium-sized enterprises. 

(b)  Is  the  form  of  Union  action  (choice  of  instrument)  justified,  as  simple  as  possible,  and 
coherent with the satisfactory achievement of, and ensuring compliance with the objectives 
pursued  (e.g.  choice  between  regulation,  (framework)  directive,  recommendation,  or 
alternative regulatory methods such as co-legislation, etc.)? 

Article 153(2)(b) of the TFEU allows minimum requirements in the field of workers’ health and safety 
protection to be adopted ‘by means of directives’. In addition, Directives 98/24/EC and 2004/37/EC 
are already in force, and this proposal is limited to revising the limit values of lead and diisocyanates 
on the basis of the scientific data available. 

(c)  Does the Union action leave as much scope for national decision as possible while achieving 
satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum 
standards or use a less stringent policy instrument of approach?) 

Article 153(2)(b) of the TFEU only allows minimum requirements in the field of workers’ health and 
safety protection to be adopted ‘by means of directives’. These minimum requirements are proposed 
by  the  European  Commission  after  consultation  of  representatives  of  workers’  organisations, 
representatives of employers’ organisations, and representatives of governments. The provisions in 
this  initiative  do  not  prevent  any  Member  State  from  maintaining  or  introducing  more  stringent 
protective measures compatible with the Treaties. 

(d)  Does  the 

initiative  create  financial  or  administrative  cost  for  the  Union,  national 
governments,  regional or local authorities, economic operators or citizens? Are these costs 
commensurate with the objective to be achieved? 

Actions to adjust working practices (risk management measures, health surveillance, monitoring and 

9 Available at: https://ec.europa.eu/commission/priorities/deeper-and-fairer-economic-and-monetary-union/european-
pillar-social-rights_en 

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training) to comply with the new values will result in increased costs for companies. The estimated 
cost of the preferred options is overall bearable for businesses. For lead, the costs would amount to 
EUR 30 000 per company over 40 years (less than 1% of their turnover). For diisocyanates, a company 
would have to spend EUR 6 000 over 40 years, which would not represent a significant share of their 
turnover either. Since these are sectors with a high degree of competition, impacts on consumers are 
expected to be limited. 

Additional administrative and enforcement costs that might be incurred by enforcing authorities are 
not expected to be significant. The reduction of ill-health cases will contribute to mitigating financial 
losses as burdens to social security and health care systems are reduced. The estimated savings for 
public  authorities  for  lead  are  around  EUR  100 million  over  40 years, which outweighs  the  one-off 
costs  (EUR  500  000).  For  diisocyanates,  public  administrations  in  the  EU  will  have  to  incur  one-off 
costs of around EUR 970 000, also expected to be balanced by the benefits (EUR 1 750 000).   

In addition to that, this initiative should result in benefits in terms of avoided cases of occupational 
diseases and related monetised health benefits including intangible costs such as the reduced quality 
of life, the suffering of the workers and their families, etc.  

(e)  While  respecting  the  Union  law,  have  special  circumstances  applying  in  individual  Member 

States been taken into account? 

As  mentioned  above,  the  European  Commission  consulted  the  tripartite  ACSH,  composed  of  three 
full  members  per  Member  State,  representing  national  governments,  trade  unions  and  employers’ 
organisations.  This broad representation enables to take into account special circumstances applying 
in individual Member States. 

8