COMMENTS AND RESPONSE TO COMMENTS ON ANNEX XV SVHC: PROPOSAL AND JUSTIFICATION

Substance name:	2-Methoxyethanol	
CAS number:	109-86-4	
EC number:	203-713-7	

Reason of the submission of the Annex XV: CMR

Disclaimer: The European Chemicals Agency is not responsible for the content of this document. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. The comments were received during the public consultation of the Annex XV dossier. The table does not contain any confidential information.

General comments
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
15	2010-10-14	International NGO,
Health and Environment Alliance,
Belgium	We support the inclusion of  2-Methoxyethanol on the candidate list on the basis of the information in the Annex XV dossier	Thank you for the support.	
14	2010-10-14

	Industry or trade association,
SYCABEL,
France	SYCABEL is the French Trade Association of electric and communication wires and cables manufacturers. There are united today the main players of the Cable Manufacturers Industry, i.e. about 30 companies realizing 90 % of the € 3 billion Industry turnover, among which are several European or world leaders.

In the industry of electric cables, 2-methoxyethanol is not a substance used as raw material. This molecule comes from the hydrolysis of an organic additive, the VTMOEO (vinyltris (2-methoxyethoxy) silane CAS : 1067-53-4) and is already present  at low concentration in the initial state (<0.5% - see MSDS). During the production of elastomeric materials used for cable, the alcohol content can reach a maximum value of 2% in the compounds for insulation and sheathing of cables. The different suppliers of this silane have been aware of this difficulty for 2-3 years and offer substitute products to VTMOEO. Today, many trials performed by the whole industry show that, with these alternative raw materials, it has not been possible to reach the same level of quality and safety for the cables produced. We have not been able to comply anylonger with the more stringent cables specifications using alternative to VTMOEO.  The whole cable industry is very concerned about the introduction of the 2-methoxyethanol in the Candidate List of Substances of Very High Concern for Authorisation because the suppliers of Vinyltris (2-methoxyethoxy) silane might then withdraw this substance from production and from marketing in Europe. The permanent withdrawal of Vinyltris (2-methoxyethoxy) silane from the European market by all suppliers would stop the manufacture of some ranges of cables without the downstream users being able to find solutions of substitution for their applications.  The Cable Industry wishes to underline that in Europe it would also be very penalized by the withdrawal of this product compared to its non European competitors. Nevertheless, aware of inherent risks in the use of this product, the cable industry does everything to limit exposure to 2-methoxyethanol of its employees below the professional exposure limit value (<16 mg / m3).  The French industry of cable manufacturing, represented by the Trade Association of electric and communication wires and cables manufacturers (SYCABEL), requests to postpone the introduction of 2-methoxyethanol in the Candidate List of Substances of Very High Concern for Authorisation . 	From the short description given for the production of elastomeric materials it seems that EGME is not used as such but formed during processes which are themselves in the scope of authorisations for EGME.  If EGME is identified as candidate substance, the main obligations might arise from the use of articles containing EGME. For example, if EGME remains in the cables in concentrations of up to 2% information obligations from Articles 7 and 33 might arise. From the data provided it does not seem difficult for the concerned industry to fulfil such information obligations.	
13	2010-10-14	National Authority,
RIVM,
Netherlands	NL supports the proposal to include 2-methoxyethanol in the candidate list of substances of very high concern. 	Thank you for the support.	
12	2010-10-14	International NGO,
WWF European Policy Office,
Belgium	WWF and CHEM Trust support the inclusion of 2-methoxyethanol in the candidate list due to its reprotoxic properties.	Thank you for the support.	
11	2010-10-13	National Authority,
Climate and pollution agency,
Norway	The Norwegian CA supports that 2-methoxyethanol (CAS number 109-86-4) should be identified as a substance of very high concern and should be included in the Candidate List. 	Thank you for the support.	
10	2010-10-13	International NGO,
International chemical secretariat,
Sweden	Full support regarding its identification as a SVHC. 	Thank you for the support.	
9	2010-10-13	MS CA, Germany	Comment by the German CA  Title of the Annex XV dossier The title of the dossier is misleading. With this dossier a reprotoxic substance is identified as being a “substance of very high concern” and not as a CMR substance as the current title implies. To avoid misunderstandings and confusion with CLH dossiers, the title of the report should read according to what is intended with the dossier namely being a “PROPOSAL FOR THE IDENTIFICATION OF A SUBSTANCE AS SUBSTANCE OF VERY HIGH CONCERN (SVHC)”. The title of the report should be changed accordingly. 

Note, currently the abbreviation “SVHC” is used in the header of the report but never explained in the report.  

Initial statement in bullet on page 5: Should be changed to include the following text added in bold italics: The substance is proposed to be identified as a substance of very high concern (SVHC) due to meeting the criteria of Article 57 (c) ….”  

Page 36 ECETOC, 2005 - reference missing in the reference list Page 37 WHO, 2008 - reference missing in the reference list  	For the Annex XV Dossier the updated format provided by ECHA was used. We agree with the proposed changes on the title of the report. However changes would need to be done in the format, therefore this request is forwarded to ECHA.

“SVHC” is included now in the list of abbreviations in the support document.

This statement is part of the format, the request is therefore forwarded to ECHA.

Thank you for the notice.	
8	2010-10-12	European Institution, Council of Europe, Directorate for the Quality of Medicines and HealthCare, France	Article 56(3) of the Regulation (EC) No 1907/2006 corr applies.  2-Methoxyethanol should remain on the market as a reagent for the convention on the elaboration of the European Pharmacopoeia (European Treaty Series 50) and the protocol to the elaboration of the European Pharmacopoeia, which are necessary for the implementation of the Directive 2001/82/EC on the community code relating to veterinary medicinal products and Directive 2001/83/EC on the community code relating to medicinal products for human use. 
	Information on uses, exposure and release will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.	
6	2010-10-11

	Company,
Germany	Please see attachment.	For response please see attachment.
RCOM_INEOS_other_final_AT_for_ECHA.doc
	
5	2010-10-08

	Company,
INEOS nv,
Belgium	Please see attachment	For response please see attachment
RCOM_INEOS_other_final_AT_for_ECHA.doc

3	2010-10-06	National Authority,
Allgemeine Unfallversicherungsanstalt,
Austria	We support placing of EGME on the candidate list and as soon as possible in Annex XIV.	Thank you for the support.	
2	2010-10-06	MS CA, Sweden	Sweden supports the proposal to identify 2-Methoxyethanol as a substance of very high concern.	Thank you for the support.	
1	2010-09-03	Trade union,
European Trade Union Organisation,
Belgium	ETUC supports the inclusion of 2-methoxyethanol in teh Candidate List.	Thank you for the support.	

Specific comments on the justification
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
13	2010-10-14	National Authority,
RIVM,
Netherlands	In part 1 (Justification) information is provided on the substance (composition of the substance, classification and labelling, manufacture and use). However, an overall justification is not included, which would make part 1 more evident.	In the dossier the structure of the format is followed. From our point of view the sections “Proposal for identification” on p5 and chapter 6 of part I do give an overall justification.	
10	2010-10-13	International NGO,
International chemical secretariat,
Sweden	The classification is clearly justified due to its CMR properties and its wide dispersive use. 	Thank you for the support.	
9	2010-10-13	MS CA, Germany	Comment by the German CA "Identity of the substance and physical and chemical properties" + "Classification and Labelling"  Identity of the substance and physical and chemical properties Page 6, table 4: The physical and chemical properties concerning flammability, explosive and oxidising properties are relevant for classification and should be mentioned additionally as follows:  Flash point:  39 oC (close cup); CHEMSAFE, 1996  

Flammability:  Flammability upon ignition (solids, gases): Testing is technically not possible, substance is a liquid. Flammability in contact with water: The classification procedure needs not to be applied because the organic substance does not contain metals or metalloids. 

Pyrophoric properties: The classification procedure needs not be applied because the known experience in handling shows that the organic substance does not ignite spontaneously in contact with air at room temperature for prolonged periods of time (days).; BAM II.2 (2010) Explosion limits in air: Lower: 2.5 vol%, Upper: 20 vol%; CHEMSAFE, 1996  

Explosive properties:  The classification procedure needs not to be applied because there are no chemical groups present in the molecule which are associated with explosive properties, but 2-Methoxyethanol forms explosive peroxides by auto-oxidation on contact with air. Due to this fact classifying with R19/EUH019 is proposed.; BAM II.2 (2010) and P. G. Urben (Ed.): Bretherick’s Handbook of Reactive Chemical Hazards, 7 th ed., Elsevier 2007  

Auto-ignition temperature:  285 oC (DIN 51794); CHEMSAFE, 1996 

Oxidising properties:  The classification procedure needs not to be applied because the organic substance contains oxygen, which is chemically bonded only to carbon.; BAM II.2 (2010) 

Page 48-52 (REFERENCES); Please insert the following reference: BAM, Expert judgement by BAM Federal Institute for Materials Research and Testing, Division II.2 in 2010. Urben, P G. (Ed.): Bretherick’s Handbook of Reactive Chemical Hazards,   7 th ed., Elsevier 2007.  

Classification and labeling Page 7, 8 2-Methoxyethanol is proposed to classify additionally with R19/EUH019  	Thank you for this information. The data given on additional physico-chemical properties have been included in Table 4, page 6 of the support document. 
Information on additional classification and labelling requirements beyond the agreed harmonized classification has not been included as  it is not within the scope of this dossier.	
8	2010-10-12	European Institution, Council of Europe, Directorate for the Quality of Medicines and HealthCare, France	The quality of medicines including their containers and raw materials may be compromised, if 2-methoxyethanol is withdrawn from the market.
	The comment is very general and it is not clear to which possible specific uses of EGME it is referred to. Medicinal products are exempted from Authorisation according to Art 2 (5). In general authorisations are granted if it can be shown that the risks are adequately controlled and may be granted if it can be shown that the socio-economic benefits outweigh the risks.	
7	2010-10-13	National Authority,
Health & Safety Authority,
Ireland	2-methoxyethanol is classified as toxic for reproduction category 1B according to Regulation (EC) 1272/2008. Therefore, the Irish CA agrees that the substance meets the criteria as toxic for reproduction in accordance with Article 57 (c) of REACH.	Thank you for the support.	
6	2010-10-11	Company,
Germany	CRITICAL END POINT (pages 35-37): We agree that developmental toxicity is the most critical end point.  We do not believe that the Annex XV dossier accurately reflects the findings of ECETOC.  We prefer therefore to follow the opinion of the authors of the key study that the NOAEC is 10ppm (32mg/m3). Haematotoxicity:  The interpretation presented in the Annex XV dossier does not take into account evidence of confounding through dermal exposure when using the data to derive a NOAEC.  Data presented in an earlier publication by the same author indicates that an exposure in the range 4-4.3ppm does not cause blood parameters to change outside of normal values.  We believe that this would be a more justifiable starting point for DNEL derivation that is consistent with the IOEL derived by SCOEL of 1ppm. DNEL DERIVATION (pages 39-41): According to appendix R.8-13 of the REACH guidance, a registrant is allowed to use an IOEL as a DNEL for the same exposure route and duration provided that there is no information obtained in preparing the registration that does not support the use of the IOEL for this purpose.  All conditions are met in this case for using the IOEL as the DNEL.  We support this approach and the DNEL of 1ppm (3.2mg/m3) in the registration dossier submitted by the lead company. RISK CHARACTERISATION (pages 42-46): There are no known uses of 2-methoxyethanol in consumer products and we do not support the use of 2-methoxyethanol in any other inappropriate end-use application where strict exposure control can not be assured. The risk characterisations presented in the dossier are therefore of academic interest only as they do not represent any current known current conditions of use.  For detailed comments, please see attachment 	For response please see attachment above:
RCOM_INEOS_other_final_AT_for_ECHA.doc	
5	2010-10-08	Company,
INEOS nv,
Belgium	CRITICAL END POINT (pages 35-37): We agree that developmental toxicity is the most critical end point.  We do not believe that the Annex XV dossier accurately reflects the findings of ECETOC.  We prefer therefore to follow the opinion of the authors of the key study that the NOAEC is 10ppm (32mg/m3). Haematotoxicity:  The interpretation presented in the Annex XV dossier does not take into account evidence of confounding through dermal exposure when using the data to derive a NOAEC.  Data presented in an earlier publication by the same author indicates that an exposure in the range 4-4.3ppm does not cause blood parameters to change outside of normal values.  We believe that this would be a more justifiable starting point for DNEL derivation that is consistent with the IOEL derived by SCOEL of 1ppm. DNEL DERIVATION (pages 39-41): According to appendix R.8-13 of the REACH guidance, a registrant is allowed to use an IOEL as a DNEL for the same exposure route and duration provided that there is no information obtained in preparing the registration that does not support the use of the IOEL for this purpose.  All conditions are met in this case for using the IOEL as the DNEL.  We support this approach and the DNEL of 1ppm (3.2mg/m3) in the registration dossier submitted by the lead company. RISK CHARACTERISATION (pages 42-46): There are no known uses of 2-methoxyethanol in consumer products and we do not support the use of 2-methoxyethanol in any other inappropriate end-use application where strict exposure control can not be assured. The risk characterisations presented in the dossier are therefore of academic interest only as they do not represent any current known current conditions of use.  For detailed comments, please see attachment 	For response please see attachment above:
RCOM_INEOS_other_final_AT_for_ECHA.doc	
1	2010-09-03	Trade union,
European Trade Union Organisation,
Belgium	That substance is also included in the Trade Union Priority List for REACH authorisation (version 2.0, June 2010) see http://www.etuc.org/a/7479 	Thank you for this information.	

INFORMATION ON USE, EXPOSURE, ALTERNATIVE AND RISKS ON ANNEX XV SVHC

Substance name:	2-Methoxyethanol	
CAS number:	109-86-4	
EC number:	203-713-7	

Reason of the submission of the Annex XV: CMR

Disclaimer: The European Chemicals Agency is not responsible for the content of this document. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. The comments were received during the public consultation of the Annex XV dossier. The table does not contain any confidential information.

Specific comments on use, exposure, alternatives and risks
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
16	2010-10-28	MSCA, France
	See attachment.
	Thank you for this additional information. It will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.

The need for grouping of potential substitutes of EGEE and EGME like other glycol ethers, which may also be identified as SVHC according their CMR classification is acknowledged. It should be noted that the Belgium CA is currently working on an RMO analysis, possibly followed by an Annex XV Dossier for the acetate salt EGEEA – CAS 111-15-9. 
	
13	2010-10-14	National Authority,
RIVM,
Netherlands	The proposal contains calculations showing that the 0.5% limit as used for classification of mixtures and for authorisation (article 56.6b) is not protective for workers and consumers in case the reported long-term inhalation DNEL (0.04 mg/m3 for general population 0.16 mg/m3 for worker) is used as reference value. However, when the IOELV of 3.11 mg/m3 as derived by the SCOEL is used as reference value, the 0.5% limit would result in a safe situation (NL calculations). The reason for this difference is that the inhalation DNEL figure is lower than the IOELV (due to a different derivation method). According to the REACH guidance, Appendix R8-13, an IOELV may also be used, instead of developing a DNEL.	IOELs do not apply to  the general population. Therefore, DNELs for the general population were  derived (see also REACH guidance R.8).

For the DNEL derivation the lowest point of departure was chosen, which was derived from the developmental study (Hanley et al., 1984). Whereas the IOEL is based on haematological effects seen at higher doses. 	
10	2010-10-13	International NGO,
International chemical secretariat,
Sweden	Its wide dispersive use should be considered and render the substance priority in further prioritizations.  Uses: perfume, painting plasters, cleaning compounds, liquid soaps, cosmetics, varnishes, enamels, nail polishes, wood stains, resins, dyes; in dyeing leather, Automotive windshield washer fluid, Floor polish, Household hard surface cleaners (aerosol+liquids), Paint and varnish removers Pharmaceutical preparations nail polish remover, hydraulic fluids, jet fuel additive (pesticide+ anti freeze), Whiteboard cleaning liquids; Hydraulic Brake Fluids, Cellulose Acetate Solvents, Nitrocellulose Solvents, Wood Stain Solvents. Source: HSDB; Scorecard; Canada Chemicals; US EPA	Information on uses, exposure and release will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.	
9	2010-10-13	MS CA, Germany	Comment by the German CA "Information on uses" + "Exposure information" + "Information on risks related to alternatives"  
Information on uses: Page 13 & 18: In the footnote to Tab. 7 (Page 13), a total amount of the substance below 100 kg is states for Sweden. In contrast to that, Tab. 10 (page 18) gives the information, that the exposure in the context of soil in Sweden is indicated to be very probable. It should be evaluated whether these information are in conflict to each other    

Exposure information: Dermal exposure as well as risk resulting from it is not mentioned in the report. On the other hand, in the case of the very similar substance 2 ethoxyethanol dermal exposure has been identified as one relevant route of exposure which leads to the suggestion that dermal exposure might be associated to risks for the methyl ether too.  
Page 23: Firstly, we are not sure whether the values listed in Tab 14 are really meant to represent the LOD. Compared to exposure measurements given from France or other countries (e.g. a median value of 0.15 mg/m3) a LOD (or more precisely a LOQ) of 4.2 mg/m3 seems quite high and exceed the German OEL of 3.8 mg/m3.  

Information on risks related to alternatives: Page 34 ff: A broad description of the toxicology of the substance is given here. This description should either be transferred to Part 1 or into an annex to the report as it has been done in the case of the ethyl ether. On the other hand, the substance has to be identified based on its reproductive toxicity according to art. 57c. A description of toxicological properties other than those might be dispensable. 
 
Page 47: We strictly support the calculation of DNEL-values for Workers (as well as consumers) (page 39). Nevertheless we miss a comparison of these DNEL values with exposure data in order to clearly identify whether or not workers are under risk. 	The SPIN Exposure Toolbox uses confidential information to estimate a probable exposure of the environmental compartment. The confidential uses indicate a very probable exposure of soil, even if the volume is below 100 kg.

We agree. But the dermal exposure was not covered, because the inhalation exposure already resulted in a risk.

The values listed in Table 19 refer to the LOQ and not by mistake to the LOD. 

The intention was to give a very short overview of the toxicological profile of the substance. We put it under the chapter risk characterization in order to facilitate the reading for the reprotoxic endpoints.

A comparison of exposure data with the IOELV and the DNEL values for workers was performed in chapter:
“Comparing monitoring data with tolerable threshold concentration
Very few monitoring data from Austrian workplaces have obtained exceedance of Austrian limit values, the IOELV and the herein derived DNELs. Results from exposure measurements from the COLCHIC database from INRS conducted between 2000 and 2006 indicate EGME median/mean concentrations of 0.15 / 0.29 mg/m3 (AFSSET report, 2008). The EGME concentration of 0.29 mg/m3 is lower than the IOELV, but higher than the DNELlong-term inhalation of 0.16 mg/m3 derived herein for the worker population. Some measurements have been conducted (2000 – 2006) in the chemical industry, rubber and plastic sector, and the building of transport materials. The mean EGME concentrations are in the range of 0.1 and 0.5 mg/m3. Again the mean values of 0.5 mg/m3 is lower than the IOELV, but higher than the herein derived DNELlong-term inhalation for workers.”	
8	2010-10-12	European Institution, Council of Europe, Directorate for the Quality of Medicines and HealthCare, France	2-Methoxyethanol (or ethylene glycol monomethyl ether) is reagent 1036300 currently used in
a) Preparation of Nihydrin and stannous chloride reagent R1 (1058302) 
b) Monograph 1198 (diethylene glycol monoethyl ether) for preparation of reference solution for GC test (no substitution possible)  
c) Monograph 0080 Emetidine Hydrochloride heptahydrate for determination of related substances by TLC for the preparation of the mobile phase
d) Monograph 0081 Emetidine hydrochloride pentahydrate e) Monograph 1999 Nifuroxazide – Solvent for specific absorption test 
e) Monograph 0736 Prednisolone pivalate used for RP-HPLC related substances tests for the preparation of the mobile phase	Information on uses, exposure and release will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.	
6	2010-10-11	Company,
Germany	VOLUMES (pages 10-12): The estimate of imported/manufactured volume described in the Annex XV dossier is excessive.  We do not expect the notified volume to reach even the lowest estimate suggested in the dossier. More accurate figures on volumes will be available for ECHA after  the first registration deadline (November 30th, 2010) when all actual manufacturers/importers have registered their respective volumes. (Substances classified as toxic to reproduction and manufactured in the European Community or imported, have to be registered in quantities reaching one tonne or more per year per manufacturer already before the first registration deadline). 
USES (pages 12-17): The information on uses presented in the Annex XV dossier is rather historic and does not reflect current applications that are restricted to industrial use only under strictly controlled conditions.   INFORMATION ON ALTERNATIVES (pages 28-30):  Where substitution is technically or economically feasible, this has already been carried out. For detailed comments, please see attachment. 	The substance clearly fulfils the criteria as an SVHC, the information provided does not relate to the inherent properties of the substance and thus does not affect the identification as SVHC substance. 

Companies (including the commenting one) were contacted in due time during the elaboration of the dossier for current data on volumes, uses and alternatives. Only very general information was provided. Therefore estimates on volumes and accessible information on uses and alternatives were used and the preregistration data have been considered as rough estimates.

Additional Information on uses, exposure and alternatives will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.	
5	2010-10-08	Company,
INEOS nv,
Belgium	VOLUMES (pages 10-12): The estimate of imported/manufactured volume described in the Annex XV dossier is excessive.  We do not expect the notified volume to reach even the lowest estimate suggested in the dossier. More accurate figures on volumes will be available for ECHA after  the first registration deadline (November 30th, 2010) when all actual manufacturers/importers have registered their respective volumes. (Substances classified as toxic to reproduction and manufactured in the European Community or imported, have to be registered in quantities reaching one tonne or more per year per manufacturer already before the first registration deadline). USES (pages 12-17): The information on uses presented in the Annex XV dossier is rather historic and does not reflect current applications that are restricted to industrial use only under strictly controlled conditions.   INFORMATION ON ALTERNATIVES (pages 28-30):  Where substitution is technically or economically feasible, this has already been carried out.  For detailed comments, please see attachment. 	The company was contacted in due time during the elaboration of the dossier for current data on volumes, uses and alternatives. Unfortunately only very general information was provided. Therefore estimates on volumes and accessible information on uses and alternatives had to be used in the dossier.	
4	2010-10-08	Company,
Germany	p. 9 General remarks: 
The following laboratory uses should be exempted from the authorisation because there is very low exposure to consumers and the environment. The analytical standards are manufactured by industrial personnel, which are well trained. Therefore, the handling steps at professional users are reduced. The disposal of the substance is controlled also.   

Detailed information:
The substance is used in a preparation or solution as an analytical standard for test and measuring instruments by industrial and professional users. The use of the substance might be e.g. for calibration purposes or as reactive compound in a test kit. These applications are laboratory uses and therefore, the risk for the environment and consumers is very low. It is a routine application in environmental laboratories. Usually the volumes and the concentration of the substance are low.

Additionally, the substance is described in standard references like e.g. Reag. Ph. Eur and ACS and is used for amino acid analysis. Applications described in these references should also be exempted from authorisation. 	Information on uses, exposure and release will be forwarded for discussion on prioritisation and exemption of uses for the preparation of the entry in Annex XIV.
	
3	2010-10-06	National Authority,
Allgemeine Unfallversicherungsanstalt,
Austria	P42 There is a recommendation by SCOEL clearly above the calculated DNEL and still the following exposure scenarios show that this OEL might be exceeded. Thus workers are still exposed on a high level of exposure to EGME.  Furthermore EGME is used as a solvent for paints; i.e. uses are spraying, brushing, … and these uses lead to a wide and dispersive use. 	We agree.	
1	2010-09-03	Trade union,
European Trade Union Organisation,
Belgium	It is a causal agent for recognized occupational diseases in the EU see: 1) Commission Recommendation 2003/670/EC of 19 September 2003 concerning the European schedule of occupational diseases: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32003H0670:EN:HTML   

The substances listed in Annex I are causative agents for diseases which have been scientifically recognised as being occupational in origin, which are liable for compensation and which must be the subject of preventive measures in all MS.     2) "Information notices on occupational diseases: a guide to diagnosis"  http://www.beroepsziekten.nl/sites/default/files/documents/Information-Notices-2009.pdf   This document contains additional information on entries listed on Annex I of the European Schedule of Occupational diseases.   	Thank you for this additional information.