Benzene Convention, 1971 (No. 136) - Greece (RATIFICATION: 1977)

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Application of the Convention in practice. Further to its previous comment, the Committee notes the Government’s indication that the Directorate for Planning and Coordination of Occupational Safety and Health Inspectorate does not collect specific data on the application of the Convention. It takes note of the statistical information provided by the Government on inspection visits carried out between 2010 and 2015 in industries where workers are exposed to benzene, namely crude petroleum and natural gas pumping, manufacture of coke of petroleum refining products and of nuclear fuel and manufacture of chemical substances and products. However, the Committee notes that no information is provided regarding contraventions detected during these visits, nor about the number of occupational diseases caused by exposure to benzene which have been reported. The Committee requests the Government to continue to provide information on the application of the Convention in practice, including statistical data on the number of workers covered by the relevant legislation, inspection visits carried out in industries where workers may be exposed to benzene, the number and nature of the contraventions and the number of cases of occupational disease caused by exposure to benzene.

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The Committee notes the information indicating effect given to Articles 4 and 6(2) of the Convention.

Part IV of the report form. Application in practice. The Committee notes the information regarding branches of economic activities where workers may be exposed to benzene including: crude petroleum and natural gas pumping; manufacture of coke of petroleum refining products and of nuclear fuel; and manufacture of chemical substances and products. It also notes, however, that no information is provided regarding the actual exposure of workers to benzene in these branches, nor about the prevalence of occupational diseases such as cancer which is a possible result of exposure to benzene. The Committee requests the Government to take further measures to ensure that information is collected and made available regarding the exposure of workers to benzene, in particular in the specific branches of economic activity where workers might be exposed to benzene in the country, including on occupational diseases of workers engaged in those branches of economic activity.

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The Committee notes that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

The Committee notes the information contained in the Government’s report and the attached legislation.

Articles 4 and 6(2) of the Convention. National legislation and establishment of limits for occupational exposure. The Committee notes the adoption of Presidential Decree No. 127/2000 and No. 43/2003, both amending Presidential Decree No. 399/1994. It notes that Presidential Decree No. 43/2003 now establishes a concentration limit of benzene in the air of the working environment of 1.00 ppm (parts per million), which is below the concentration level established by the Convention. The Committee would, however, like to draw the Government’s attention to the fact that this limit has been established based on the scientific knowledge available in 1971, at the time when the Convention was adopted. In the meantime, following scientific progress, the concentration limit for occupational exposure recommended by the American Conference of Industrial Hygienists (ACGIH) is now at 0.5 ppm. The Committee therefore invites the Government to consider the possibility to align the limit value currently in force for occupational exposure to benzene to the limit value recommended by the ACGIH. The Committee requests the Government to provide information in its next report on measures taken or envisaged to revise the national occupational exposure limit of benzene in the places of employment.

Article 4. Prohibition of the use of benzene. The Committee notes the Government’s statement that Greece applies the prohibition of using benzene within the framework of the European Union. Recalling that section 4 of European Directive No. 90/394/EEC does not explicitly envisage the prohibition of the use of benzene and of products containing benzene in certain work processes and that Article 4, paragraph 1, of the Convention provides that the use of benzene and of products containing benzene shall be prohibited by national laws or regulations in certain work processes, the Committee reiterates its previous request to the Government to provide information in its next report on measures taken or envisaged to ensure that national laws or regulations prohibit the use of benzene and of products containing benzene, in accordance with the Convention.

Part IV of the report form. The Committee notes the Government’s statement that the previously mentioned research that was carried out with respect to the increased use of unleaded petrol was carried out with sporadic measurements and did not enable for any statistical information to be collected. The Committee requests the Government to provide information in its next report on the practical application of the Convention, including extracts from labour inspection reports, the number of establishments in the country where workers are exposed to benzene or products containing benzene, the number of such workers, disaggregated by gender if possible.

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1. The Committee notes the information contained in the Government’s report and the attached legislation.

2. Articles 4 and 6, paragraph 2, of the Convention. National legislation and establishment of limits for occupational exposure. The Committee notes the adoption of Presidential Decree No. 127/2000 and No. 43/2003, both amending Presidential Decree No. 399/1994. It notes that Presidential Decree No. 43/2003 now establishes a concentration limit of benzene in the air of the working environment of 1.00 ppm (parts per million), which is below the concentration level established by the Convention. The Committee would, however, like to draw the Government’s attention to the fact that this limit has been established based on the scientific knowledge available in 1971, at the time when the Convention was adopted. In the meantime, following scientific progress, the concentration limit for occupational exposure recommended by the American Conference of Industrial Hygienists (ACGIH) is now at 0.5 ppm. The Committee therefore invites the Government to consider the possibility to align the limit value currently in force for occupational exposure to benzene to the limit value recommended by the ACGIH. The Committee requests the Government to provide information in its next report on measures taken or envisaged to revise the national occupational exposure limit of benzene in the places of employment.

3. Article 4. Prohibition of the use of benzene. The Committee notes the Government’s statement that Greece applies the prohibition of using benzene within the framework of the European Union. Recalling that section 4 of European Directive No. 90/394/EEC does not explicitly envisage the prohibition of the use of benzene and of products containing benzene in certain work processes and that Article 4, paragraph 1, of the Convention provides that the use of benzene and of products containing benzene shall be prohibited by national laws or regulations in certain work processes, the Committee reiterates its previous request to the Government to provide information in its next report on measures taken or envisaged to ensure that national laws or regulations prohibit the use of benzene and of products containing benzene, in accordance with the Convention.

4. Part IV of the report form. The Committee notes the Government’s statement that the previously mentioned research that was carried out with respect to the increased use of unleaded petrol was carried out with sporadic measurements and did not enable for any statistical information to be collected. The Committee requests the Government to provide information in its next report on the practical application of the Convention, including extracts from labour inspection reports, the number of establishments in the country where workers are exposed to benzene or products containing benzene, the number of such workers, disaggregated by gender if possible.

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1. Article 4 of the Convention. The Committee notes the publication of Presidential Decree No. 399/94 (FEK/221/A/19.12.1994) respecting the protection of workers against risks arising out of exposure to carcinogenic agents at work, issued under European Council Directive No. 90/394/EEC on the protection of workers from the risks related to exposure to carcinogens at work. It also notes that section 4 of the above European Directive does not explicitly envisage the prohibition of the use of benzene and of products containing benzene. In this respect, the Committee noted in its previous comment that section 3 of Act No. 61 of 1975 prohibits the use of benzene and of products with a benzene content of over 1 per cent as solvents or diluents, except in an enclosed system or where there are equally safe methods of work, in accordance with Article 4, paragraph 2, of the Convention. It recalled that paragraph 1 of this Article provides that the use of benzene and of products containing benzene shall be prohibited in certain work processes to be specified by national laws or regulations. This prohibition could cover the use of benzene in forms other than as solvents or diluents, but in work processes where its use may be considered an unnecessary risk. The Committee had requested the Government to indicate the measures which had been taken or were envisaged to prohibit the use of benzene in certain work processes other than those covered by the minimum requirement set out in Article 4, paragraph 2, of the Convention. The Committee notes that the Government's report does not contain a reply in this respect. It therefore once again requests the Government to provide information on the measures which have been taken or are envisaged to prohibit the use of benzene in cases other than the prohibition set out in section 3 of Act No. 61 of 1975.

2. Part IV of the report form. The Committee notes with interest that the Occupational Safety and Health Centre of the Ministry of Labour and Social Security has commissioned research, including the registration of results, on the exposure to benzene of certain categories of workers in places in which petrol is produced and distributed (refineries and loading and sales points). With regard to the results of this research, the Committee understands that the exposure values are lower than the maximum levels established. The Committee also notes that the research is being undertaken once again in view of the increased use of unleaded petrol. Furthermore, the new research has been extended to other workplaces and workers who are exposed to benzene. The Committee therefore requests the Government to provide detailed information in its next report on the results of the above research and to provide a copy of any statistics which may be established on the basis of the data which are compiled.

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1. Article 4 of the Convention. The Committee notes from the Government's reply to its previous comments that section 3 of Act No. 61 of 1975 prohibits the use of benzene and of products with a benzene content of over 1 per cent as solvents or diluents except when carried out in an enclosed system or where there are other equally safe methods of work, in accordance with Article 4, paragraph 2, of the Convention. The Committee would recall that paragraph 1 of this Article provides that the use of benzene and of products containing benzene shall be prohibited in certain work processes to be specified by national laws or regulations. Such prohibition could cover the use of benzene in forms other than as solvents or diluents, but in work processes where its use may be considered an unnecessary risk. The Government has not supplied any information on measures taken to prohibit the use of benzene in certain work processes other than the minimum requirement set out in Article 4, paragraph 2, of the Convention. The Government is, therefore, requested to indicate in its next report whether any measures have been taken or envisaged to prohibit the use of benzene other than the prohibition set out in section 3 of Act No. 61.

2. Point IV of the report form. In comments it has been making since 1984, the Committee has requested the Government to supply information on the practical application of the Convention. In its latest report, the Government has indicated that sufficient data are not available in this regard. The Committee urges the Government to take the necessary measures both through the inspection services, as required by Article 14(c) of the Convention, and any other competent bodies to obtain information concerning the practical application of the Convention (e.g., the work processes in which benzene is used, the number of persons employed in these work processes, the number and nature of contraventions reported, any sanctions applied, etc.) and to provide this information with its next report, in accordance with point IV of the report form.

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1. Article 4 of the Convention. The Committee refers to its previous comments and understands from the Government's reply that the use of benzene and of products containing benzene (the benzene content of which does not exceed 1 per cent) is only authorised for the activities and under the conditions set out in section 3 of Act No. 61 of 1975, that is as solvents or detergents in accordance with paragraph 2 of the above Article of the Convention.

The Committee would be grateful if the Government would confirm whether this is the case, and keep it informed in its future reports of any provision adopted in order to impose new prohibitions on the use of the substances in question.

2. The Committee once again requests the Government to supply information with its next report on the application of the Convention in practice, in accordance with point IV of the report form on this Convention.

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With reference to its previous comments, the Committee notes with satisfaction the adoption of Ministerial Order No. 130879 of 29 May 1987 which defines the methods for measuring the concentration of benzene in the air of places of employment in conformity with Article 6, paragraph 3, of the Convention.