A Critical Appraisal of the Setting and Implementation of Occupational Exposure Limits in the Netherlands

Since 1978 in the Netherlands occupational exposure limits, designated maximum accepted concentrations (MACs), have been established by a three-step procedure. In the first, purely health-based, step the Dutch Expert Committee on Occupational Standards (DECOS), a committee of the Health Council of the Netherlands, establishes a health-based recommended occupational exposure limit (HBR-OEL). In the second, feasibility, step the Subcommittee on MAC values of the Social Economic Council, an advisory body to the government, evaluates the technical and/or socio-economical feasibility of the HBROEL and recommends an operational MAC. In the third, administrative, step the Ministry of Social Affairs and Employment (MSAE) sets the MAC as a legally binding value. Key words of the three-step procedure are openness and transparency. Areas of attention are incompleteness of the toxicological data base, inconsistencies in setting standards and the absence of limit values for composite exposures. One area of concern is the incomplete implementation of MAC values, particularly in small companies. Implementation problems are mainly caused by lack of information and education of both employees and employers on the practical significance of MAC values. Indeed, implementation of MACs should have top priority. On the other hand, setting of standards should be a continuing activity because they are a guidance to employers, they assist workers in negotiations on working conditions and allow the government to impose (mandatory) improvements in the workplace. Indeed HBR-OELs and MACs are necessary for all parties, and more effort is needed to increase the awareness of their practical significance, particularly in small companies.