Commenting on the French draft recommendation of 2014

In 2014, France gave the general public, as well as other Member States and the European Commission the opportunity to provide comments on its draft recommendations. The Nickel Institute as well as registrants and downstream users provided comments on the draft recommendations and supported the French analysis that the application of workplace legislation and the setting of binding OELs would be the most proportionate regulatory option. The Nickel REACH Consortia are also in the process of updating the REACH registration dossiers, taking the French analysis of the registration dossiers into account. NiPERA, the Nickel Institute's science division, provided comments on the exposure limit value that France proposed should be used as the DNEL (0.01mg Ni/m³). NiPERA clarified possible misconceptions and provided substantive arguments based on available data to demonstrate that a DNEL of 0.05 mg Ni/m³ is equally health protective. Other industry comments did not engage in the debate as to which value is the scientifically appropriate one. Comments did however indicate difficulties with practically achieving the value proposed by France. Whether (or how quickly) the proposed French value can be achieved may differ among the different uses of nickel compounds.

A summary of the NiPERA comments as well as the full set of the NiPERA comments are available here: