UV Safety at Work: Understanding European Directive 2006/25/EC

Ultraviolet (UV) radiation is widely used in workplaces across Europe. Applications include UV inspection, fluorescent testing and non-destructive testing, UV disinfection, and the UV curing of inks, coatings, adhesives and resins.

While UV technology can deliver significant operational benefits, artificial UV radiation can also present hazards to workers’ eyes and skin.

Across the European Union, the protection of workers from risks associated with artificial optical radiation is addressed by European Directive 2006/25/EC. The Directive establishes minimum health and safety requirements relating to occupational exposure to artificial optical radiation, including ultraviolet radiation.

For organisations using UV equipment, understanding the potential risks, applicable Exposure Limit Values and employer responsibilities is an important part of protecting workers and supporting regulatory compliance.

However, there is no universal answer to the question: “Is our UV process safe?”

The answer depends on the specific workplace, equipment, process and way in which workers interact with the UV radiation.

What is European Directive 2006/25/EC?

European Directive 2006/25/EC concerns the minimum health and safety requirements regarding the exposure of workers to risks arising from artificial optical radiation (AOR). The Directive specifically addresses risks to workers’ health and safety arising, or likely to arise, from exposure to artificial optical radiation affecting the eyes and skin.

Optical radiation covers electromagnetic radiation between 100 nanometres (nm) and 1 millimetre and includes ultraviolet, visible and infrared radiation. For the purposes of the Directive, ultraviolet radiation covers wavelengths between 100 nm and 400 nm and is divided into:

Band	Wavelength	Typical use
UV-A	315 – 400 nm	UV inspection, UV curing
UV-B	280 – 315 nm	UV curing
UV-C	100 – 280 nm	UV disinfection, UV curing

The potential biological effects of UV radiation vary significantly with wavelength. This is one reason why UV safety cannot be assessed simply by looking at the electrical power of a lamp or the general description of a UV system.

The Directive establishes Exposure Limit Values for workers and requires employers to assess risks and, where necessary, measure and/or calculate levels of exposure so that appropriate protective measures can be identified and implemented.

Directive 2006/25/EC establishes minimum requirements at European level. Individual EU Member States implement the requirements through their own national legislation, which may include more specific or more stringent provisions.

Why is every workplace UV safety scenario different?

The presence of UV equipment does not automatically mean that workers are exposed to hazardous levels of ultraviolet radiation.

Equally, the fact that a UV system is designed for a particular application does not automatically demonstrate that workers are adequately protected in every workplace situation. The actual safety scenario will depend on a range of factors, including:

The spectral output of the UV source
The irradiance or intensity at relevant working positions
The distance between workers and the UV source
The position and orientation of workers
The duration and frequency of exposure
The nature of the task being undertaken
Direct access to the UV source
Reflections from surrounding surfaces
Existing guards, enclosures and shielding
Interlocks and other engineering controls
Maintenance, cleaning and fault-finding activities

A fully enclosed UV curing system, for example, may present a very different exposure scenario from an open UV inspection process.

Similarly, a UV disinfection system installed in an unoccupied enclosure may require a different safety assessment from a system where workers could potentially access the radiation during operation.

The equipment, process and workplace environment must therefore be considered together.

Common workplace applications of UV radiation

Artificial UV radiation is used across a wide range of industries.

UV fluorescent inspection

UV radiation is commonly used for fluorescent inspection, leak detection and non-destructive testing.

The potential for exposure can depend on how close the operator works to the source, the duration of the inspection, the position of the worker and whether direct or reflected UV radiation can reach the eyes or skin. Existing controls, such as shielding and operating procedures, should also be considered.

UV disinfection

UV technology is increasingly used for the disinfection of air, water, surfaces and equipment.

Depending on the wavelength, output and design of the system, UV disinfection equipment can present a significant hazard if workers are able to access the radiation during operation.

Safety arrangements may include enclosure, shielding, access controls, interlocks and clearly defined operating procedures.

However, the effectiveness of these controls should be considered in relation to the actual installation and the way the equipment is used.

UV curing

UV curing is widely used for inks, coatings, adhesives, resins and other manufacturing processes. UV curing systems can range from fully enclosed automated equipment to open or partially enclosed production processes.

Potential exposure scenarios can occur during normal operation but may also arise during:

Maintenance
Cleaning
Adjustment and set-up
Commissioning
Fault finding
Access to equipment when safety controls are bypassed or not functioning correctly

A workplace UV safety assessment should therefore consider the full range of reasonably foreseeable activities.

Other UV applications

UV radiation may also be encountered in laboratories, healthcare, research, specialist manufacturing and other industrial processes.

Regardless of the application, organisations should understand the characteristics of the UV equipment they use and determine whether workers could be exposed.

Understanding UV Exposure Limit Values

Directive 2006/25/EC establishes Exposure Limit Values (ELVs) for occupational exposure to artificial optical radiation. For non-coherent UV radiation, the Annex to the Directive includes limits addressing different UV-related hazards. For the UV spectrum, the relevant assessment may include:

Effective UV exposure between 180 and 400 nm

This assessment is spectrally weighted to account for the fact that different UV wavelengths have different biological effectiveness in causing injury to the eyes and skin.

The applicable daily exposure limit is expressed as an effective radiant exposure over an eight-hour period.

UV-A exposure between 315 and 400 nm

The Directive also contains a separate exposure limit relating to UV-A exposure and the potential for adverse effects to the eye. The applicable limits are not simply “power limits” for UV equipment.

The assessment of exposure can involve:

The wavelength or spectrum of the radiation
Spectral weighting for biological effects
Irradiance at the worker’s position
Exposure duration
The actual task being performed

More than one exposure value and corresponding limit may be relevant for a particular UV source. This is why workplace-specific assessment can be essential where workers are exposed, or could reasonably be exposed, to UV radiation.

What are the employer’s responsibilities?

Directive 2006/25/EC requires employers to assess risks arising from artificial optical radiation.

Where workers are exposed to artificial sources of optical radiation, employers must assess and, if necessary, measure and/or calculate the levels of exposure to which workers are likely to be exposed.

The purpose is to identify and implement the measures necessary to ensure exposure is restricted below the applicable Exposure Limit Values.

The assessment should be proportionate to the nature and level of the risk.

Safety teams and duty holders should therefore understand:

What UV equipment is being used
The characteristics of the UV radiation emitted
Who could be exposed
How and when exposure could occur
Which tasks present the greatest potential for exposure
The existing control measures
Whether those controls are adequate
Whether exposure measurement or calculation is required
The applicable Exposure Limit Values (ELVs)
The requirements of the relevant national legislation implementing the Directive

The European Commission’s non-binding guide to good practice provides further guidance on risk assessment, measurement, manufacturer information, control measures and other aspects of implementing the Directive.

When should UV exposure be measured and assessed?

Not every UV source automatically requires a detailed measurement survey. However, organisations need sufficient information to understand whether workers could be exposed to hazardous levels of UV radiation.

Where personal exposure does occur or could occur, assessment may require measurement and/or calculation to establish the level of exposure under representative workplace conditions.

A UV radiation measurement and assessment survey can help establish:

The spectral characteristics of the UV source
UV irradiance at relevant working positions
Potential exposure of the eyes and skin
The effect of distance and worker positioning
The influence of exposure duration
The effectiveness of existing controls
Whether exposure complies with applicable Exposure Limit Values

Measurements should reflect realistic workplace conditions. For example, a measurement taken directly next to a UV source may not represent the exposure received by an employee carrying out a normal task. Conversely, measurements made only during normal production may fail to identify potential exposure during maintenance, cleaning or fault finding.

Understanding how people actually work around the UV equipment is therefore essential.

Controlling the risks from workplace UV radiation

Where a risk assessment indicates the possibility that Exposure Limit Values may be exceeded, the Directive requires employers to develop and implement an action plan incorporating technical and/or organisational measures to prevent exposure exceeding the limits.

The Directive identifies a range of potential control measures, including:

Selecting equipment that emits less optical radiation where appropriate
Alternative working methods that reduce UV exposure
Engineering controls such as interlocks, shielding and other protective mechanisms
Effective maintenance programmes
Improved workplace and workstation design
Limiting the duration and level of exposure
Appropriate personal protective equipment

Where workplaces could expose workers to levels of artificial optical radiation exceeding the Exposure Limit Values, appropriate warning signs and identification of the relevant areas may also be required, with access restricted where technically possible.

Workers must not be exposed above the applicable Exposure Limit Values.

If an Exposure Limit Value is exceeded, immediate action is required to reduce exposure, identify why the exceedance occurred and adapt the protection and prevention measures to prevent it from happening again.

UV safety training and worker awareness

Understanding the UV hazard should not be limited to safety professionals and duty holders.

Directive 2006/25/EC requires employers to ensure that workers exposed to risks from artificial optical radiation, and/or their representatives, receive the necessary information and training relating to the outcome of the risk assessment.

This includes information about:

The measures implemented to control the risks
Applicable Exposure Limit Values
Potential risks associated with UV exposure
The results of relevant assessments, measurements or calculations
The significance of those results
How to detect and report adverse health effects
The circumstances in which workers may be entitled to health surveillance
Safe working practices and procedures
The proper use of equipment and personal protective equipment

However, from a practical workplace safety perspective, UV hazard awareness should not simply be treated as a requirement for situations where exposure limits are close to being exceeded.

Workers should understand the UV hazards associated with the equipment they use and the control measures in place to protect them.

This is why UV hazard awareness training should be provided regardless of the level of risk, ensuring employees understand the hazards, safe working practices and the importance of controls such as guards, shielding and interlocks.

Why UV risk management knowledge is important for safety teams and duty holders

Safety teams and duty holders are often responsible for making decisions about workplace risk assessments and control measures. However, UV radiation presents technical challenges that may not be familiar to every health and safety professional. Understanding UV safety requires awareness of:

The differences between UV-A, UV-B and UV-C
Spectral output and why wavelength matters
Biological effects and spectral weighting
Exposure Limit Values
Worker exposure scenarios
The role of engineering controls
When measurement and assessment may be necessary

Without this knowledge, it can be difficult to determine whether a generic risk assessment provides sufficient information or whether a more detailed UV exposure assessment is required.

This is where specialist UV risk management knowledge can help organisations make informed and proportionate decisions.

How Arden Ultraviolet can support your organisation

At Arden Ultraviolet, we help organisations understand and manage the risks associated with workplace ultraviolet radiation.

Our services are designed to support organisations using UV technology across a wide range of applications, including UV inspection, disinfection and curing.

Free UV safety webinar

Our free UV safety webinar provides an accessible introduction to the hazards associated with artificial UV radiation in the workplace. The webinar is designed to raise awareness of:

Workplace UV hazards
Potential eye and skin exposure
UV Exposure Limit Values
The importance of workplace-specific risk assessment
The role of effective engineering and administrative controls

It provides an ideal starting point for organisations that want to better understand their UV safety responsibilities and the factors that influence workplace exposure.

UV risk management training

Our UV Risk Management Training is designed for safety professionals, duty holders and others responsible for managing UV risks.

The training helps participants develop a practical understanding of:

Artificial UV radiation and its hazards
The principles of Directive 2006/25/EC
UV Exposure Limit Values
Workplace UV risk assessment
Identifying potential exposure scenarios
The importance of spectral output and irradiance
When measurement and assessment may be required
The principles of effective UV risk control

This training helps safety teams and responsible persons develop the knowledge needed to make more informed decisions about workplace UV safety and regulatory compliance.

UV radiation measurement and assessment surveys

Where personal UV exposure occurs or could reasonably occur, workplace-specific measurement and assessment can provide valuable information. Our UV radiation measurement and assessment surveys consider the real workplace environment, including:

The UV equipment being used
Spectral output
Irradiance
Working positions
Exposure durations
Specific tasks
Existing engineering controls
Potential exposure to the eyes and skin

The results can be used to assess relevant worker exposures and compare them with applicable Exposure Limit Values.

Because every workplace and process is different, our approach focuses on understanding how the UV equipment is actually used and how workers interact with it.

Tailored UV hazard awareness training for employees

Workers are an essential part of any effective UV safety programme. Our tailored UV hazard awareness training can be developed around the specific equipment, processes and workplace conditions within your organisation.

Training can help employees understand:

The UV radiation present in their workplace
Potential risks to the eyes and skin
When exposure could occur
The control measures designed to protect them
Safe working procedures
Why guards, shielding and interlocks must not be bypassed
What to do if controls are damaged or not functioning correctly

Training can be tailored for workplaces using UV inspection, UV disinfection, UV curing and other specialist UV applications.

Take a proactive approach to UV safety and compliance

Artificial UV radiation is an increasingly important technology across many industries. However, effective UV safety requires more than simply identifying that UV equipment is present.

Organisations should understand the specific equipment being used, its spectral and irradiance characteristics, how workers interact with the process, how long potential exposure may last and which controls are in place.

European Directive 2006/25/EC establishes minimum requirements for protecting workers from risks associated with artificial optical radiation, including ultraviolet radiation.

For organisations operating across Europe, understanding the Directive and the relevant national legislation implementing it is an important part of effective UV risk management.

Whether you are looking to raise awareness, improve internal competence, measure potential worker exposure or provide tailored training for employees, Arden Ultraviolet can help you take a more informed and proactive approach to workplace UV safety.

Explore our free UV safety webinar, UV risk management training, UV radiation measurement and assessment surveys, and tailored UV hazard awareness training to support your organisation in protecting workers and managing UV risks effectively.