ETUI-REHS
Att.: Roland Gauthy
Boulevard du Roi Albert II, 5
B1210 Bruxelles27 April 2007

Position of the Danish Confederation of Trade Unions (LO) and Confederation of Professionals in Denmark (FTF) on the 2nd stage of consultation of the social partners on work-related musculoskeletal disorders

This position is related to the Commission request to the social partners of 14 March 2007.

  1. The LO and FTF strongly supports the intention of the Commission to increase its attention towards the MSD issue.
  2. We definitely approve the intention of the Commission to table an individual minimum Directive on MSD.
  3. The MSD directive must be covering all MSD related issues, including the gaps between the existing MSD related directives. By its nature, the MSD directive must be as comprehensive as the work related conditions which are leading to MSD.
  4. The importance of psycho-social risks must be properly reflected in the directive – other wise the directive will not be comprehensive and effective.
  5. Also the knowledge of employers and managers must be reflected, because basic MSD knowledge is a precondition for taking the correct preventive measures.
  6. We are strongly concerned with the concept of simplification, because we fear that this concept leads to a lowering down of the level of protection. The legislation must be fine-meshed enough to safeguard the workers on all work related risk factors leading to MSD.
  7. We are concerned with the idea of defining hazard thresholds in the directive, but may support these, if they are clearly defined as minimum levels (which they should be by nature in a minimum directive).
  8. The LO and FTF supports the opportunity for the social partners to take initiatives which intend to improve the transposition of the MSD directive into national practice. We definitely will support the wording of non-binding good practice guides, which are targeting especially the SME’s.

  1. But LO and FTF strongly believe that the non-regulatory instruments to be developed by the social partners must be kept separately of the process of the wording of the MSD directive. Our position is that first, the wording of the MSD directive most be finalised, in order to avoid any disturbance of the non-regulatory instruments upon the process of wording of the MSD directive.

Yours sincerely

Niels Sørensen
LO / Jan Kahr Frederiksen
FTF

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