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The Committee notes the information provided, including reference to legislative developments since the last report. The Committee further notes the comments from the Central Organisation of Finnish Trade Unions (SAK) and the Finnish Construction Trade Union, included in the Government’s report.
Article 1(1) and (3) of the Convention. List of carcinogenic substances and agents. With reference to its previous comments, the Committee notes the information that Finnish legislation on the prevention of work-related cancer risks covers only categories 1 and 2 of the EU classification of carcinogenic substances and agents, but not those attended by less evidence of the cancer risks they pose to humans; that the scope of Finnish legislation and responsibility to register also covers exposure to agents classified as carcinogenic by the EU, such as environmental tobacco smoke and hardwood dust; that legislation on occupational disease compensation covers for example the risk of lung cancer caused by crystalline silica, although the EU has not classified this as a carcinogenic substance; that Finland complies with EU legislation on the classification of carcinogenic substances and agents; and that it complies with the interpretation of the carcinogenicity of substances and agents by the International Agency for Research on Cancer (IARC). The Committee also notes the comments from SAK that, in their view, ethylene trichloride and formaldehyde should be included in the list of carcinogenic substances, that the Finnish Construction Trade Union considers that creosote and mould should be viewed in the same way as asbestos, and that quartz dust should be included in the list of carcinogenic substances and agents. Noting that the Government does not address the SAK comments in its report, the Committee asks the Government to respond thereto in its next report.
Article 2. Carcinogenic substances and agents replaced by non-carcinogenic or less carcinogenic ones. The Committee notes with interest the information for the developments in the period 2002–07 regarding the decreasing number of persons exposed to the following substances: asbestos (from 1,894 to 1,298); tobacco smoke (from 12,317 to 7,047); carbon tetrachloride (from 287 to 66); 1.4-dioxane (from 177 to 83); amitroles (from 112 to three); dieldrin (from 119 to seven); and lindane (from 131 to nine), that the number of persons exposed to vinyl chloride and ethylene oxide have also decreased, that the exclusion of copper-chrome-arsenic salts used in wood preservatives from the EU market in the autumn of 2007 has reduced the number of workers exposed to chrome and arsenic, but that some enterprises use creosote as a wood preservative causing workers to be exposed to poly aromatic hydrocarbon (PAH) compounds. The Committee also notes that, in the glass industry, arsenic oxides classified as carcinogenic have been replaced with less carcinogenic antimony compounds. The Committee requests the Government to continue reporting on further developments in this respect.
Article 3. Protection of workers and registration of workers exposed to carcinogenic substances and agents. The Committee notes the information provided regarding the register of workers at risk of exposure to carcinogenic substances and processes (ASA register), and that following the required pre-employment medical examinations, including the provision of information on the potential health hazards in the workplace and on risk prevention, workers exposed to carcinogenic substances for at least 20 days are added to this register. As regards environmental tobacco smoke, the registration criterion is a minimum of 40 workdays per year of exposure. However, workers exposed to unusually high doses of carcinogenic factors in a short period of time as a result of an accident, production error, unusual work process, or other corresponding reason, must always be added to the register. The Committee also notes the statement that, while Finland complies with EU legislation on the classification of carcinogenic substances and agents, and with the interpretation of the carcinogenicity of substances and agents by the IARC, a more restrictive list is used for the purposes of this ASA register, and that a registration system based on the Finnish list would require a multifold commitment in comparison to the current situation and cannot be regarded as providing any corresponding advantages to OSH activity. The Committee further notes the statement of the Finnish Institute of Occupational Health that work-related cancers may be prevented through more efficient steering of risk assessment resources and targeted reduction of exposure in connection with high-risk tasks. The Committee notes the absence of information on how the more restrictive list used for the purposes of the ASA register is developed and the criteria used for selecting the substances and agents the exposure to which will trigger registration. The Committee also notes the issue raised by SAK in that the registration system and organization of statutory occupation health-care services for exposed workers in irregular employment is a concern, because, if statutory periodic medical examinations are not performed, workers are ineligible for compensation. The Committee requests the Government to provide further information on how the list of substances relevant for the ASA register is established and to respond to SAK’s concerns in its next report.
Article 6(c). National legislation and labour inspection. The Committee notes that the Ministry of Social Affairs and Health’s occupational safety and health manual for 2010 has been published and that the Department of Occupational Safety and Health is currently preparing a manual for inspectors on the surveillance of chemicals in the workplace. The Committee requests the Government to provide copies of the manual for inspectors once it has been adopted.
Part IV of the report form. Application in practice. The Government notes the brief statistical information provided by the Government concerning the decreasing number of persons added to the ASA register: from 28,028 in 2005 (of which 40 per cent were women) to 23,346 in 2007 (of which 34 per cent were women). The Committee asks the Government to continue to provide relevant statistical information on the application of the Convention in practice.
1. The Committee notes the information contained in the Government’s report and the observations of the Central Organization of Finnish Trade Unions (SAK), which were attached thereto.
2. Article 1, paragraphs 1 and 3, of the Convention. List of carcinogenic substances and agents. The Committee notes with interest that the Government continues to expand the compilation of the index of carcinogens, most recently by Ordinance No. 1014 of 4 December 2003 of the Ministry of Social Affairs and Health, amending Appendix A of Ministry of Labour Decision No. 838 of 1993 on carcinogenic agents at work, adding to the list wood dust of oak or poplar. It also notes that formaldehyde is classified as a carcinogenic substance. With respect to work carried out with asbestos, the Committee refers to its comments under Convention No. 162. With respect to the International Agency for Research on Cancer (IARC) classifications of carcinogenic substances and agents, the Committee notes the Government’s statement that it fully applies the list established by the European Union (European Directive No. 67/548/EEC, Annex I). It provides the explanation that in Finland the determination of carcinogenic substances and agents is linked to the employers’ legal obligation to report for registration all workers exposed to carcinogenic substances and agents. It notes the Government’s statement that due to this it is not practical to register workers exposed to all substances and agents enumerated by the IARC. However, the Committee feels obliged to once again refer to its general comments on the application of Conventions on occupational safety and health that it made in 1997, paragraph 68, that "there is a difference between international standards and regional standards in the approach adopted to occupational safety and health problems and the manner in which they are to be addressed. The incorporation of regional standards into national legislation is not always sufficient to meet the requirements of the international standards of the ILO. States should therefore be reminded that greater attention should be paid to these standards in the revision and formulation of national laws and regulations." The Committee notes the Government’s statement that the Finnish Institute of Occupational Health has applied the IARC list in assessment projects and that it disseminates this list to workplaces, particularly the information that all substances that are possibly, likely and definitely carcinogenic shall be treated as carcinogens in the workplace. Noting that the list of reference for the application of the present Convention is the list established by the IARC, the Committee requests the Government to indicate measures taken to ensure that the list applicable in the country is brought into conformity with the IARC list of carcinogenic substances and agents.
3. Article 2. Carcinogenic substances and agents replaced by non-carcinogenic or less carcinogenic ones. The Committee notes with interest the adoption of the Ordinance of the Council of States on chemical agents in the workplace (Ordinance No. 717 of 2001), replacing the Council of States’ Decision No. 920 of 1992. It notes in particular section 9 ensuring the employers’ obligation either to eliminate or minimize the dangers or risks that chemical substances present for workers and to limit workers’ exposure thereto as far as it is technically possible, in accordance with the Convention. The Committee requests the Government to provide with its next report examples of chemical substances that have been effectively replaced by non-carcinogenic or less carcinogenic ones, as well as details regarding the manner in which this has been done.
4. Article 3. Registration of workers exposed to carcinogenic substances and agents. The Committee notes with interest the adoption of the Act on registers of workers occupationally exposed to carcinogenic substances and processes, Act No. 717 of 17 August 2001, replacing Act No. 1038 of 1993. It notes that employers now also have to provide information with respect to the recorded levels of exposure workers have been subject to (section 2(5)) and that this information shall be kept for a period of 80 years (section 5). With respect to recording information in the ASA register on the exposure of workers employed on short-term contracts - a question raised by SAK both previously and in its observations attached to the Government’s most recent report - the Committee notes that the Government considered that it may be justified to record information on workers in short-term employment, if the period of exposure exceeds 40 days but that it would be problematic to determine such a period of exposure if the worker would be employed under several employment contracts and at different workplaces. The Committee notes SAK’s concerns regarding the application of these rules in practice and that according to a report by the labour market parties, the occupational safety and health protection of workers in atypical employment relationships - such as temporary workers and part-time workers - is insufficient - in particular as regards the exposure to asbestos. The Committee requests the Government to respond in its next report to the concerns raised by SAK and to provide information on measures taken or envisaged to ensure that appropriate information regarding all workers’ exposure to carcinogenic substances and agents is duly recorded.
5. Article 6, paragraph (c). National legislation and labour inspection. The Committee notes with interest the numerous amendments to the current occupational safety and health legislation, particularly the adoption of Occupational Health Care Act No. 1383 of 21 December 2001 and Occupational Safety and Health Act No. 738 of 23 August 2002. It notes in this respect the observations submitted by SAK concerning the Occupational Safety and Health Inspectorate’s chemical expertise and the resources available for monitoring. In this respect, the Committee notes the Government’s statement that it is in the process of adopting new guidelines on how to carry out health inspections. The Committee hopes that the Government will take into account the concerns of SAK when adopting the new guidelines for labour inspections and requests the Government to provide copies of these guidelines once they have been adopted.
The Committee takes note of the comprehensive report provided by the Government as well as the information supplied in reply to its previous comments. It also notes the comments supplied by the Central Organization of Finnish Trade Unions (SAK). The Committee draws the Government’s attention to the following points.
1. Article 1, paragraphs 1 and 3, of the Convention. With reference to its previous comments, the Committee notes the Government’s indication on the number of workers exposed to carcinogens, such as quartz dust, wood dust, diesel engine exhaust and formaldehyde, which, however, although classified as carcinogens by the International Agency for Cancer Research (IARC), do not figure on the list of carcinogens contained in Decision No. 838/1993 on carcinogenic agents at work. The Government explains that the substances compiled in the Finnish list follows in the first line the classification of the European Union, which subordinates the chemical substances and agents into different categories and only the chemical agents found in categories 1 and 2 are classified as carcinogenic. Although the European Union takes the estimates of the IARC into account, the list of carcinogens is structured on the grounds of different criteria, which accordingly causes the abovementioned discrepancies between the list established by the European Union and the list of the IARC. However, the Committee notes with interest that the compilation of an index of carcinogens is continuing and that the list has been supplemented the last time by Decree No. 1232 of 18 December 2000 of the Ministry of Social Affairs and Health amending section 1 and the appendix of the Ministry of Labour Decision No. 838/1993 on carcinogenic agents at work. Moreover, Decision No. 1059 of 24 November 1999 of the Ministry of Social Affairs and Health on a list of dangerous substances contains as well chemicals recently classified as carcinogenic by Finland following the classification of the European Union. The Government further indicates that a working group established under the auspices of the Ministry of Social Affairs and Health has submitted a report proposing to add quartz dust to the list of carcinogens because of its proven characteristic to be conducive to the development of lung cancer, although the number of cases of occupational cancer caused by quartz dust is less than eight cases per year in Finland. With regard to the other above enumerated agents, which were classified as carcinogenic by the IARC, the Committee notes that, pursuant to section 3 of Governmental Decree No. 716 of 3 August 2000 on preventing occupational risk of cancer referring to Decision No. 838/1993 of the Minister of Labour which contains a list of carcinogenic agents at work, hardwood dust, which causes cancer of the nose, and polycyclic aromatic hydrocarbons, found as ingredients in diesel exhaust fumes, are classified as carcinogenic. Furthermore, tobacco smoke is considered as carcinogenic according to section 2 of Government Decision No. 1153 of 8 December 1999 on environmental tobacco smoke and prevention of related risks of cancer. Moreover, Government Decision No. 1154 of 8 December 1999 amending the appendix to Government Decision No. 1672/1992 on health examinations in jobs involving special risk of occupational disease, introduced a new item 14 adding environmental tobacco smoke to the list of chemical agents causing cancer. However, formaldehyde has not yet been classified as carcinogenic pursuant to the classification of the European Union. The Committee, taking due note of this information, requests the Government to specify the legal basis for determining polycyclic aromatic hydrocarbons as carcinogens. It further requests the Government to consider the possibility to base the periodic determination of carcinogenic substances and agents not only on the categorization recognized by the European Union, but also on the indications given by the IACR, in accordance with paragraph 3 of this Article of the Convention.
2. Articles 2 and 3. The Committee notes section 1 of Government Decree No. 610 of 21 June 2000 on prohibitions and restrictions concerning carcinogenic, mutagenic and reproduction-toxic agents, which provides for further restrictions of the use of agents conducive to the development of a cancer, notably their prohibition except for research and analysis purposes. With specific regard to chlorinated solvents, the annex to the Government Decision No. 1209 of 18 December 1997 on prohibitions and restrictions concerning certain chlorinated solvents prescribes restrictions of their use. The Committee further notes section 2 of Government Decision No. 1155 of 8 December 1999, amending section 2 of the Ministry of Social Affairs and Health Decision on estimating risks to pregnancy and development of the foetus providing for the inclusion of particular factors, such as the mutagenic effects of certain substances, into the risk assessment to be carried out before pregnant women workers are exposed to these substances. In the same way, the Ministry of Social Affairs and Health Decision No. 1156 of 8 December 1999 amending the Ministry of Labour Decision on jobs involving risks to young employees prescribes that factors particular harmful to young workers, e.g. mutagenic effects of substances and agents, have to be taken into consideration in the framework of the risk assessment. The Committee notes with interest that section 1 of Decree No. 1028 of 1 December 2000 on concentrations known to be harmful has lowered the existing limits for workers’ exposure to some workplace air carcinogens by referring to the list published as Annexes 1 and 2 of the Safety and Health Notification of the Minister of Social Affairs and Health introducing the human toxicity potential (HTP) values - a calculated index that reflects the potential harm of a unit of chemicals released into the environment used to weight emissions inventories to arrive at a common indicator of harm - for the year 2000. Moreover, section 6 of Government Decree No. 716/2000 on preventing occupational risk of cancer prescribes protective measures to be taken, notably the prohibition to use carcinogenic substances and agents which can be replaced by non- or less carcinogenic ones; the employer’s obligation to use carcinogenic substances, which for technical reasons cannot be replaced, in a closed system and, if that is not feasible, the employer is required to limit workers’ exposure as far as it is technically possible. However, the exposure limits prescribed in Annex A to this Decree must not be exceeded. The Committee further notes the Government’s indication that a Decree issued by the Ministry of Social Affairs and Health has confirmed a list of carcinogenic agents to which workers’ exposure must be recorded pursuant to section 2 of Act No. 1038 of 26 November 1993 requiring the employer to register the workers exposed to carcinogenic substances and methods at their workplace. Noting this information, the Committee requests the Government to specify the abovementioned Decree and to supply a copy for further examination. With regard to work involving workers’ exposure to environmental tobacco smoke, section 2 of Government Decision No. 1153/1999 on environmental tobacco smoke and prevention of the related risk of cancer, effective since 1 July 2000, requires the employer to carry out a risk assessment with a view to the nature, quantity and duration of exposure in order to estimate the risks for workers’ safety and health. On the grounds of the results of this risk assessment, the employer is obliged to take appropriate measures to protect the workers by reducing the degree of exposure, its duration as much as reasonably and technically possible and by introducing protective concepts as the working facilities allow. As to workers with a higher risk factor, notably pregnant women, section 3, subsection 2, of the said Decision prohibits the assignment of pregnant women to work involving exposure to environmental tobacco smoke. In addition, the employer is obliged, upon request, to show to the labour protection authorities the risk assessment carried out, including the data on which the risk assessment is founded, and the measures taken to reduce the workers’ exposure to environmental tobacco smoke. Moreover, the employer must provide information as to the manner in which the implementation of these measures is monitored at the workplace. Moreover, section 10 of Government Decision No. 1153/1999 requires the employer to keep a record of the workers who are exposed for a significant proportion of their working time, that is a minimum period of 40 workdays, in order to determine their annual exposure to environmental tobacco smoke. In this context, the Committee notes the comments provided by the SAK arguing that the legislative process of drafting the Act on the register of workers exposed to carcinogenic substances as well as the preparative work of the legislation concerning the listing of carcinogenic substances and products and workers’ exposure did not lead to an agreed solution with regard to the shortcomings observed in practice, in particular the collection of data on occupational exposure of temporary workers who have uninterrupted short-term employment periods, however, with different employers. In these cases, the employers do not enter in a satisfactory way the exposure data in the register on the exposure of workers occupationally exposed to carcinogens (ASA Register). Therefore the data contained therein are not reliable. This is demonstrated by means of section 11 of Government Decision No. 1153/1999 on environmental tobacco smoke, according to which only exposure data workers exposed for more than 40 days must be entered in the register. Due to a lack of exchange of information between the different employers of these short-term workers, their data are left outside the ASA Register, although they should be included in the ASA Register, because the workers concerned in fact have been exposed for at least 40 workdays to environmental tobacco smoke during a number of different employment periods under short-term contracts. The Committee, taking due note of the information provided by the Government as well as of the position of SAK, requests the Government to consider measures to guarantee that exposure data of all workers irrespective of the nature of their working contract are collected in the ASA Register to ensure a system of records containing reliable data, in accordance with the requirements set forth in Article 3 of the Convention. Moreover, it invites the Government to provide information in relation to the comments supplied by the central organization of SAK. As to the ASA Register itself, the Committee notes the Government’s indication contained in its report, that the impact of the ASA Register, being a statutory register of persons exposed to carcinogenic substances since 1979, was studied by sending questionnaires to working units which entered into the register in 1996. The Committee notes with interest that 73 per cent of the units having sent their replies have introduced changes with a view to either eliminate or to reduce significantly the workers’ exposure to carcinogens. The most common changes were the elimination of work causing exposure, the reduction of the volume of carcinogens used, the replacement of carcinogenic substances by others and the use of personal protective equipment. The Government adds that in a number of cases, the ASA Registration was the primary reason for these positive actions. The Committee notes this information with interest and invites the Government to continue to provide information on the impact of the ASA Register in practice.
3. Article 5. The Committee notes with satisfaction section 16 of the Government Decree No. 716/2000 on preventing occupational risk of cancer, which came into force on 1 September 2000, prescribing the employer’s obligation to arrange appropriate health examinations of workers to monitor their state of health, as provided for under the provisions of the Occupational Health Care Act No. 743/1978. Since section 16 of the above Decree requires appropriate health examinations of workers as necessary to avoid the risk of a cancer according to the Act No. 743/1978 on health examinations, workers, who have been previously exposed to carcinogenic substances, e.g. asbestos, benefit of health examinations even after they have changed their employment. The Government further indicates that, since the scope of application of the Government Decree No. 716/2000 covers all kind of work, workers in temporary employment are also covered. With regard to asbestos and, in response to the comments supplied by the Union of Construction Workers, the Government indicates that a research project on asbestos agreed on by the labour market organizations, the authorities and the insurance system jointly is being launched aiming to obtain new information concerning occupational asbestos diagnostics and possibly of supporting lung cancer screening. As to the participants of this project, the Committee understands that the workers examined are previously diagnosed as mild cases of occupational disease and most of them are not entitled to claim handicap benefits so far. Taking due note of this information, the Committee requests the Government to provide information on the results of this project. It also requests the Government to reveal the possible influence of the results of this study on the worker’s entitlement to benefits as well as on future legislation. Finally, the Committee asks the Government to indicate the definition of the term "mild occupational disease".
4. Article 6(c) in conjunction with Part IV of the report form. The Committee notes the Government’s indications that, between the years 1980 and 1997, the overall cancer morbidity of persons entered into the ASA Register, thus being occupationally exposed, were on the same level as for the population in general. However, exposed workers have been only observed during an average period of 13.2 years, which in general is a too short period to design a comprehensive picture of the incidence of occupational cancer. In the light of the long latency of cancer, the Committee requests the Government to explain why the observance of workers occupationally exposed were limited to the above-indicated period of time, since as the Government said itself, this relatively short period of time of monitoring does not provide reliable results on the origin of occupational cancer. The Committee further notes the Government’s indication that different types of cancer occur according to the substances or agents to which the workers have been exposed. It notes with interest that, since the adoption of the Government Decision No. 920/1992 on the protection of workers from risks related to exposure to chemical agents, the monitoring of risk assessments carried out for workplace chemicals and carcinogenic chemicals has played an increasing role in the inspections of workplaces by the occupational safety and health inspectorates. In this context, the Committee notes with concern that, while a total of 112 cases of cancer of occupational origin were reported in 1999, 109 of them were caused by workers’ exposure to asbestos. However, the number of asbestos deaths reported by the insurance companies in 2000 was declining to 64 cases in relation to 104 cases in 1999.
5. The Committee notes the Government’s indications concerning the CAREX database, which was established with the support from the European Union’s programme named "Europe Against Cancer". The Government explains that this database deals in the first place with those agents classified as carcinogens by the IARC. In this respect, it deals with the number of workers exposed and the exposure data. In that way, CAREX contributes indirectly to the reduction of workers’ exposure by disseminating information to be used in risk evaluation and the measures to be taken in consequence. The Committee noting this information requests the Government to explain more in detail the concept of CAREX and to specify the manner in which the IARC is implied in this programme. Finally, the Committee requests the Government to supply, as an example, a set of data collected since the database CAREX has been set up.
Referring also to its observation under the Convention the Committee notes the indication by the Government in its report that the Institute of Occupational Health measures exposure to carcinogens in the workplace, provides training for occupational health care personnel on carcinogens, and carries on experimental and epidemiological research in work-related cancer in order to intensify risk assessment and preventive work a data system on carcinogenic exposure (CAREX) which is being built. The Committee requests the Government to provide information on the results achieved through this system in particular with a view to reducing to the minimum compatible with safety the number of workers exposed to carcinogenic substances or agents and the duration and degree of such exposure.
In its previous comments the Committee requested the Government to provide information concerning the practical application of the Convention, in particular as concerns the means for ensuring accurate registration of workers exposed to carcinogenic substances. The Committee notes the information provided by the Government in its report. It also notes the comments by the Central Organisation of Finnish Trade Unions (SAK), the Finnish Confederation of Salaried Employees (STTK), the Union of Finnish Metal Workers and the Union of Construction Workers.
Article 1 of the Convention. The Committe notes that by Decision No. 838/93 the list of carcinogenic substances has been complemented. It notes however the indication in the Government's report that this list differs from that established by the International Agency for Cancer Research (IARC) which includes substances such as silica dust, wood dust, diesel exhaust gases and formaldehyde. The Committee requests the Government to indicate whether workers are exposed to these substances and agents, and to provide information on measures envisaged or adopted to take account of the latest information available inter alia from the IARC in the periodic determination to be made under this Article of the Convention.
Articles 2, 3, 5 and Part IV of the report form. The Committee takes note of government Decision No. 1182/92 on the prevention of cancer risk at work and in particular sections 19 to 21 thereof, which provide for the keeping by the employer of a list of carcinogenic agents used or present at the workplace and products containing such agents; of workers exposed and , if available, the degree of exposure; the storage of data and a special register (section 19); identification of exposure in general (section 20); and determination of annual exposure (article 21). The Committee notes that according to SAK the register does not cover all persons exposed to a notifiable degree, due to inadequate risk assessment as well as to insuffficient inspection. The Committee also notes the comments by the Finnish Metal Workers Union that workers under short-term employment and those who have been exposed earlier in some other work remain outside the follow-up. The Committee notes the Government's indication in its report that preventive effects of the register (ASA register) are difficult to measure, that cancer morbidity among those reported in the register have been followed experimentally only once, but that it is intended to repeat the follow-up in 1996-97. The Committee requests the Government to provide information on the outome of the internal follow-up as well as on the comments by SAK and the Metal Workers Union.
The Committeee notes the information provided by the government in its report that according to the register (ASA register) a total of 14,846 workers in 1,693 work departments were exposed to carcinogenic substances in 1993, 5.4 per cent less than in 1992, the most usual substances being chromic (VI) compounds, nickel and its compounds, asbestos, benzene and polycyclic aromatic hydrocarbons. The Committee also notes that in 1990-93 the Institute of Occupational Health carried out a comprehensive study during which about 3,000 new asbstos-related occupational diseases were identified; 80 to 160 cancers from exposure to asbetos were reported in 1992-94. In 1993 from 164 cancers reported as occupational diseases, 162 were caused by asbestos.
The Committee notes the comments by the Union of Construction Workers that despite the fact that the use of asbestos is prohibited the danger remains for workers engaged in demolition work of old constructions containing asbestos. While work with asbestos is subject to licence and supervision by inspection, 10 to 20 per cent of work involving asbestos is executed without due notification, the risk of occupational cancer deriving from asbestos remaining thus alarmingly high. In addition the trade union considers that methods of early diagnosis and follow-up are not always adequate and that the sick person might be left without treatment or compensation when cancer appears. The Committee also notes the comments by STTK that there have been a few cases in which the investigation of causes of a suspected cancer have been inadequate.
The Committee requests the Government to provide information on the measures taken or envisaged to reduce to the minimum compatible with safety the number of workers exposed to carcinogenic substances or agents and the duration and degree of such exposure, and to ensure that all workers exposed to carcinogenic substances or agents are provided with medical examinations during employment and thereafter. It requests the Government to provide information on the comments by the Union of Construction Workers in relation to exposure of workers to asbestos.
The Committee notes the information provided in the Government's latest report and the comment made by the Central Organisation of Finnish Trade Unions (SAK) and the Confederation of Salaried Employees (TVK) transmitted by the Government. According to the SAK, the current grounds for the registration of workers exposed to carcinogenic substances is insufficient and inspections carried out by the labour protection authorities should be intensified. The Committee notes from the Government's report that a register is kept of persons exposed to carcinogenic substances by virtue of sections 10 and 11 of the Council of State Decision 583/85 concerning protection against the risk of cancer at work. Section 10 of Decision 583/85 further provides that the directorate of worker protection is responsible for ensuring that information concerning carcinogenic substances and the workers exposed to these substances is kept in a register. The Committee recalls that Article 3 of the Convention calls for the establishment of an appropriate system of records in respect of carcinogenic substances and, under Article 6(c), appropriate inspection services shall be provided for the purpose of supervising the application of the Convention. It would point out that Paragraph 15(2) of the Occupational Cancer Recommendation suggests that, in establishing a system of records, account should be taken of the assistance which may be provided by international and national organisations, including organisations of employers and workers. The Committee requests the Government to provide information in its next report concerning the practical application of the Convention as requested under point IV of the report form, in particular as concerns the means for ensuring accurate registration of workers exposed to carcinogenic substances.