Problems concerning the integration of "derived-no-effect-levels" (DNEL) into occupational safety and health regulations

Under the rules of chemical safety assessment, derived-no-effect-levels (DNELs) should be established for all registration-subjected substances, which are put on the market in quantities of 10 tonnes and more per year. DNELs represent exposure levels above which humans should not be exposed to. The purpose of DNELs is to serve as a reference value for determining adequate control of exposure for specific scenarios. Since a considerable number of exposure scenarios may comprise occupational inhalation exposure, DNELs may be wrongly understood as a kind of Occupational Exposure Limit, therefore, the issue of their integration into the national legislation on occupational safety and health (OSH) acquires crucial importance. In this paper, procedures for establishing DNELs and occupational exposure limits in the European Union (OEL) and Poland (MAC) are compared. The role of MAC values in Polish occupational safety and health is also discussed. In occupational inhalation exposure, DNELs may serve as a kind of guidelines and tentative criteria for risk characterization/assessment of substances for which sound scientific MAC values have not yet been determined, however, this requires formal introduction of DNELs into Polish OSH legislation.