Proposal from the Dutch chemical industry to do more than legally required

Proposal from the chemical industry to do more than legally required

The VNCI (Association of the Dutch Chemical Industry) initiated a proposal to improve the occupational hygiene policy in the Netherlands with respect to carcinogen exposure. Their initiative challenges companies to come up with an approach to reduce exposure to an ideal target value, a vale that is lower than the legally required threshold. As such, it advocates health-based approach to carcinogen exposure in the workplace instead of a legal-based approach. Inspiring of this initiative is that the push to limit exposure, even more, has its origins in the chemical sector itself.

Setting and problem description

The current Dutch policy with respect to carcinogens is as follows:

  1. The Dutch Expert Committee on Occupational Safety determines two annual risk values:
    • Maximum value: Exposure above this value is very risky.
    • Ideal target value: Exposure below this value is harmless.
  2. The minister determines a threshold value between the maximal and the ideal target value based on the advice of several expert institutions about the feasibility. This threshold value is equal to or lower than the European limit value

The Dutch Labour Inspectorate checks whether the exposure at companies is below the legally determined threshold value. A side-effect of this approach, however, is that companies are not challenged to reduce exposure even further if the legal threshold value is not exceeded. This makes it highly unlikely that exposure will ever be below the ideal target value.


The VNCI proposes to oblige companies to make a plan of action on how to reduce exposure not to the legally determined threshold value but to below the ideal threshold value. Thus, the VNCI-proposal goes further than current policies and aims to minimise health risks due to carcinogen exposure.


It is inspiring that the chemical sector itself comes up with a proposal that will oblige companies to do more about carcinogen exposure than they are currently expected to do. Currently, the VNCI is discussing this proposal with the Dutch Association for Occupational Hygiene (NVva), the Social and Economic Council of the Netherlands (SER), the Ministry of Social Affairs and Employment (SZW) and the European Chemical Council (CEFIC). If they receive support for their initiative, the International Occupational Hygiene Association (IOHA) and the European Commission will be approached.

Lessons learned

  • Companies and sectors can do more than what is legally required of them!

Further information

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Dirk van Well
The Netherlands