AEIP responds to the European Commission Call for Evidence on the revision of Directive 2004/37/EC on carcinogens, mutagens and reprotoxic substances at work

The European Association of Paritarian Institutions (AEIP) has submitted its response to the European Commission’s Call for Evidence on the revision of Directive 2004/37/EC. AEIP welcomes the initiative and stresses that stronger protection against occupational cancers is essential for workers across the European Union, particularly in sectors with frequent exposure such as construction.

Representing paritarian social protection institutions across 13 countries, AEIP works closely with organisations managing paid holiday schemes, training funds and health and safety initiatives. Given its close link to construction, AEIP highlights that the revised Directive must combine ambitious worker protection with support measures that allow small and medium sized enterprises to implement new requirements effectively.

AEIP supports the proposed inclusion of welding fumes, polycyclic aromatic hydrocarbons and cobalt compounds due to their clear relevance for construction activities. Welding fumes are a common hazard on worksites where ventilation is often limited and exposures are difficult to control. PAHs affect workers involved in roofing, paving and renovation, and exposure levels vary widely depending on the season and materials used. Cobalt may be present in cement, pigments, tools and battery powered equipment, creating diffuse but persistent risks. AEIP notes that harmonised EU limits will help ensure equal protection across Member States.

To ensure practical implementation, AEIP calls for sector specific guidance that reflects the realities of outdoor and temporary worksites. This includes mobile fume extraction for welding, safe handling of heated bitumen and clear recommendations on dust suppression and personal protective equipment. Paritarian training funds should play a central role in raising awareness and providing tailored training for both workers and site managers.

AEIP also underlines the importance of monitoring and enforcement. Pooled exposure monitoring schemes can help SMEs comply with requirements, while strengthening labour inspectorates will support consistent enforcement. Financial support tools, including grants and incentives, will be essential to help companies invest in engineering controls, monitoring devices and safer substitutes.

AEIP looks forward to continuing its engagement with the Commission, Member States and social partners to ensure that the revised Directive improves worker protection while supporting the resilience and sustainability of SMEs in the construction sector.

You can see the position paper here.