CEMFAW; exemptions or derogations?
OK, first up, exemptions and derogations are the same thing. EMF Directive 2013/35/EU just uses the term derogations whilst in the UK, HSE in the CEMFAW regulations have decided to use the term exemptions.
For those familiar with the Directive derogations for MRI or the military will be well known but then the Directive gives scope for member states to do their own thing and grant derogations/exemptions 'in duly justified circumstances'.
In the UK HSE have listed out some activities for exemption including dielectric heating equipment, induction heating equipment & manually operated resistance welding equipment. These are all activities where EMF and resultant exposure to the worker can be high.
So what does it mean?
It means that exposure above the Exposure Limit Values is permissible as long as the employer has jumped through the risk assessment hoops, that means of reducing the exposure have been explored and most importantly that workers are still protected against adverse health effects and safety risks (and remember that includes workers at particular risk).
In practical terms it means that we're in the odd situation of having to do an assessment which in reality will be tough (but not impossible) to do without performing measurements but then having no limit on exposure other than making sure a worker isn't suffering adverse health effects. How some of that would play out in court if something unfortunate did happen would certainly be down to the lawyers. Good luck!
But seriously if you have got any questions on industrial sector EMF assessments just get in touch, it's often not as complicated as it might seem.