DOHSBase

Belgian limit values in DOHSBase: the Codex list, the CMR scope and the new BE profile

Geert Wieling with contributions from Saskia Houben 7 min read

DOHSBase now includes the Belgian occupational exposure limits from the Codex on well-being at work. The values are part of the limit-value data and the associated CMR classification has been processed into the CMR data. There is also a separate BE profile, in which Belgium rather than the Netherlands is the starting point.

One distinction up front: the Belgian data is not confined to that BE profile. It has also been added to the other European profiles, so if you work with a Dutch or European profile you will see the Belgian value listed from now on as well.

Summary: The Belgian limit-values list is annex VI.1-1 to book VI of the Codex on well-being at work, and covers more than seven hundred chemical agents with an eight-hour limit value and, where applicable, a short-term value, each in both ppm and mg/m³. The list carries its own “additional classification” column with the notations A (asphyxiant), D (uptake through skin, mucous membranes or eyes), F (fibres), M (irritation or acute poisoning hazard) and VI.2. That last one matters most in practice: VI.2 means the agent falls under title 2 of book VI, the Belgian regime for carcinogenic, mutagenic and reprotoxic agents and agents with endocrine-disrupting properties. Belgium applies that scope on two grounds: VI.2 based on the harmonised classification, and VI.2 (N) based on the notified classification. As a result the Belgian CMR scope is in practice broader than a list that follows only the harmonised CLP classification.

What was added

Three things, which in practice belong together:

  1. The limit values from the Codex list now sit alongside the existing Dutch and European values, so a Belgian value appears on the same substance page as the Dutch one. This applies to all European profiles, not only the Belgian one.
  2. The CMR classification of book VI title 2 has been processed into the CMR data, including the distinction between the harmonised and the notified basis.
  3. A BE profile, in which the Belgian sources are the leading ones instead of the Dutch ones. We switch this profile over on request.

The Belgian list in brief

Formally the list is annex VI.1-1 to book VI, title 1 (chemical agents) of the Codex on well-being at work, published by the FPS Employment, Labour and Social Dialogue. For each agent it gives the EINECS number, the CAS number, the name, the limit value for an eight-hour reference period (time-weighted average) in ppm and mg/m³, the short-term value for a period of normally fifteen minutes in ppm and mg/m³, and the additional classification.

That last column is where the Belgian list carries more information than a bare set of numbers:

Notation Meaning
A Asphyxiant: the gas or vapour is not toxic in itself, but displaces oxygen from the air. Once the oxygen content falls below 17 to 18 vol%, asphyxiation occurs without prior warning.
D A substantial contribution to the total body burden through the skin, mucous membranes or eyes is possible, and/or health effects may follow skin exposure. This can result from direct contact as well as from presence in the air.
F Exposure occurs in the form of fibres, defined as particles longer than 5 µm, thinner than 3 µm, with a length-to-diameter ratio greater than 3. The concentration is then expressed in fibres per volume rather than mg/m³.
M Above the limit value irritation occurs or there is a risk of acute poisoning. The work process must be designed so that the limit value is never exceeded, and the sampling period must be as short as possible.
VI.2 The agent falls under title 2 of book VI: carcinogenic, mutagenic and reprotoxic agents and agents with endocrine-disrupting properties.

The D notation is the Belgian equivalent of what the Netherlands calls the H notation (skin absorption), and the M notation functions in practice as a ceiling-type requirement. Anyone used to the Dutch Annex XIII will recognise the system, but not the notations one for one.

The point that matters in practice: the CMR scope

The most interesting divergence is not in the numbers but in the reach of the CMR regime.

The Belgian list has two variants of the VI.2 entry, and the difference is set out explicitly in the legend:

  • VI.2 means the agent falls under title 2 on the basis of its harmonised classification, that is, the classification in Annex VI of the CLP Regulation.
  • VI.2 (N) means the agent falls under title 2 on the basis of its notified classification, that is, the classification companies have themselves notified to ECHA’s C&L Inventory.

A substantial share of the VI.2 entries in the list are of the (N) type. That is not a detail. It means a substance can fall within the scope of the Belgian CMR regime, with the attendant duties around substitution, exposure registration and closed systems, while that same substance has no harmonised CMR classification and would therefore not appear on a list that follows only the harmonised classification.

On top of that, Belgian title 2 explicitly also covers agents with endocrine-disrupting properties, alongside the carcinogenic, mutagenic and reprotoxic ones.

For anyone working on both sides of the border, that is the practical point of this release: the CMR question “does this substance fall under the strict regime?” can be answered differently in Belgium than in the Netherlands, for exactly the same substance. For the general system, see CMR substances and the hierarchy of limit values.

What the BE profile does

The BE profile sets the order in which sources are offered. That order runs from near to far:

Belgium → Europe → immediate neighbours (the Netherlands, France, Germany) → the rest of Europe → everywhere else.

The neat part is that this order is walked twice, in line with the hierarchy of limit values: once for the legal values and once for the health-based recommended values. Those are two different questions, and they should not be allowed to blur into one another.

For the legal values the chain starts with the Belgian Codex itself. For the health-based values the situation is different: Belgium has no national advisory body that derives health-based limit values, in the way the Netherlands has the Gezondheidsraad. There the chain therefore starts not nationally but at European level, followed by the neighbouring countries, which is where the Dutch Gezondheidsraad and the German DFG MAK values come into play.

That difference is exactly why a country profile is more than a filter. For a Belgian workplace the legal value is a Belgian matter, but the health-based underpinning comes by definition from elsewhere. The profile makes clear which source you are looking at, instead of leaving you to put the Codex table alongside DOHSBase to check whether the Dutch value happens to also be the Belgian one. Often it is not.

Why Belgium

After the Netherlands, Belgium is the largest user group of DOHSBase, and occupational hygiene practice in the Benelux is highly cross-border. Companies with sites on both sides of the border, consultancies working in both countries, and assessments of Belgian workplaces by Dutch hygienists all had to consult the Codex table manually alongside DOHSBase until now.

Getting started

You do not need to request the Belgian data. It is in DOHSBase Online and is visible from the European profiles, including the Dutch one. Nothing is required on your part.

The BE profile is a deliberate choice. If you want Belgium as your starting point, with the source order described above, that is not a setting you switch yourself. Raise a request through support in the portal and we will change your profile over.

If you spot a discrepancy between a value in DOHSBase and the Codex table, or if a substance is missing, we would like to hear about it through that same support channel. Corrections to source data get priority. If you do not have portal access yet, use the contact form.

dataset Belgium limit values CMR Codex release

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