Annex 4 analytical methods

model description

general description

acronym
CMD IV Model
name
Fourth revision of the Carcinogens and Mutagens Directive Model
main purpose
The model was developed to assess the costs and benefits related to different policy options for addressing three carcinogenic substances in the frame of the fourth amendment of the Carcinogens and Mutagens Directive 2004/37/EC. These costs and benefits were assessed for a broad range of stakeholders, including employers, workers and public sector.
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Developer and its nature

ownership
EU ownership (European Commission)
ownership additional info
is the model code open-source?
NO

Model structure and approach with any key assumptions, limitations and simplifications

details on model structure and approach

This model, which consists in a benefit model and a cost model, was developed to assess the costs and benefits related to different occupational exposure limit scenarios for three carcinogenic substances.

The benefit model enables to estimate the current and future cases of ill health for both cancer and non-cancer endpoints. The key inputs used are described below. The inputs are those parameters whose variation changes the results and for which the model is run multiple times to derive a benefits curve.

In addition to the inputs, the model is underpinned by a range of default assumptions regarding the onset of the disease and its effects. These assumptions differ by substance but do not change depending on the variations in the input data. Some of these assumptions are a simplification of complex real life scenarios or best estimates (where authoritative evidence could not be identified from readily available literature).

The benefit model provides a good approximation of the order of magnitude of the expected impacts and the core calculations are supported by sensitivity analysis. The outputs of the model include:

  • The number of new cases for each health endpoint assigned to a specific year in the 60 year assessment period;
  • The Present Value (PV) of the direct, indirect, and intangible costs of each case.

The health benefits of implementing new or revised OELs are then calculated in terms of the costs of ill health avoided.

The cost model enables to assess the compliance costs for companies. These costs are estimated on the basis of the inputs described below and are calculated in a worksheet model.

For some sectors, where non-specific data are available, a likelihood model is applied. The likelihood model calculates the costs for a group of similar companies incurred in reducing air exposure to a target OEL based on an assumed sequence of Risk Management Measures implementation which is determined by suitability, effectiveness, and cost. The model is run several times to construct a continuous cost curve.

For other sectors, where the Risk Management Measures to be applied are more well-described, a more simple model is applied, but the same unit costs and life span parameters are used as in the more complex model.

model inputs

The key inputs used for the benefit model are:

  • Rx – Estimate of the risk or fraction of workers affected: this information is based on the Exposure-Risk Relationship (ERR) or Dose-Response Relationship (DRR):
    • ERR: excess risk of developing cancer due to lifetime occupational exposure to a substance (taken here to mean 40 years); and
    • DRR: the proportion of workers that will develop an endpoint when exposed to a certain level.  
  • ExW – Exposed workforce: number of workers exposed at different points in time.
  • Cx: Exposure concentration: 8-hr time-weighted average (TWA) that the workers are exposed to (real concentration, i.e. if personal protection equipment (PPE) is currently worn, the measured concentrations are adjusted to take into account PPE where possible)

The key assumptions are:

  • MinEx – the minimum exposure duration required to develop the endpoint
  • MaxEx – the time needed to reach the maximum risk (I.e. after the MaxEx has been reached, the risk of effects do not increase)
  • ModEx – the modelled exposure duration (the ERRs and DRRs are for a 40 year period)
  • Lat – the latency with which the effect is demonstrated
  • The distribution of cases over the period between MinEx and 60 years
  • Mortality – Mortality rate as a result of the relevant condition
  • Value of a DALY – Monetary value of a case taking into account the direct, indirect, and tangible costs
  • Turnover percentage of staff per year; 
  • Value of a Statistical Life (VSL);
  • Willingness to pay (WTP) to avoid for morbidity;
  • Disability weights;
  • Discount rates. 

The compliance costs are estimated on the basis of:

  • Exposure concentration: 8-hr time-weighted average (TWA) that the workers are exposed to (real concentration, i.e. if personal protection equipment (PPE) is currently worn, the measured concentrations are adjusted to take into account PPE where possible);
  • Risk Management Measures (RMMs) needed for reducing the air exposure levels from the actual levels to the target level;
  • The costs of the RMMs (one-off and recurrent) for each company and/or workstation;
  • The % reduction in exposure of the RMMs;
  • The life span of the RMMs;
  • The number of companies by size (small, medium and large)
  • The number of workstations by size (small, medium and large company)
  • The discount rate
model outputs

The key outputs produced by the benefit model include:

  • The number of new cases for each health endpoint assigned to a specific year in the 60 year assessment period;
  • The Present value of the direct, indirect and intangible costs of each case.

The health benefits of implementing new or revised OELs are then calculated in terms of the costs of ill health avoided.

The key outputs produced by the cost model are the compliance and monitoring costs for companies for each policy option over the next 60 years.

Intended field of application

policy role

The model was developed to support the impact assessment accompanying the legislative proposal aiming to revise the Carcinogens and Mutagens Directive 2004/37/EC.  It enabled to estimate the costs and benefits related to different policy options envisaged in the impact assessment.

policy areas
  • Employment and social affairs 

Model transparency and quality assurance

Are uncertainties accounted for in your simulations?
YES - This cost-benefit analysis posed several challenges, including additional endpoints, number of workers exposed, the future trends, the available epidemiologic evidence, the discount rate. Despite these challenges, some of these parameters have been quantified.
Has the model undergone sensitivity analysis?
YES - Sensitivity analysis has been performed for one substance by taking into consideration lower and higher costs than the main estimate.
Has the model been published in peer review articles?
NO
Has the model formally undergone scientific review by a panel of international experts?
NO
Has model validation been done? Have model predictions been confronted with observed data (ex-post)?
YES - For benzene, a comparison between the estimation of past exposure with actual reported cases was performed. The model results were then discussed against the reported cases.
To what extent do input data come from publicly available sources?
Based on both publicly available and restricted-access sources
Is the full model database as such available to external users?
NO - The databases used have been mentioned in the different reports of the study commissioned by the Commission to support the fourth revision of the Carcinogens and Mutagens Directive 2004/37/EC
Have model results been presented in publicly available reports?
NO
Have output datasets been made publicly available?
NO - The costs and benefits related to the policy options identified by the Commission are available in the impact assessment report accompanying the legislative proposal aiming to amend for the fourth time the Carcinogens and Mutagens Directive 2004/37/EC
Is there any user friendly interface presenting model results that is accessible to the public?
NO
Has the model been documented in a publicly available dedicated report or a manual?
NO

Intellectual property rights

Licence type
Non-Free Software licence

application to the impact assessment

Please note that in the annex 4 of the impact assessment report, the general description of the model (available in MIDAS) has to be complemented with the specific information on how the model has been applied in the impact assessment.

See Better Regulation Toolbox, tool #11 Format of the impact assessment report).