On the occasion of the draft of the ZID of ZZBUT provided to us, the Confederation of Employers and Industrialists in Bulgaria expresses its principled disagreement with the proposed changes in§4, item 1 related to the amendment of paragraph 3, which stipulates that the deputy chairman of the working conditions committee and the chairman of the occupational safety and health workers in the working conditions group have the right of access to all workplaces in the enterprise or division / paragraph 3, item 1/, as well as having the right to ask the employer to stop work equipment or to prohibit the use of dangerous chemical substances and mixtures /paragraph 3, item 5/.
Our disagreement with such a proposal is related to the lack of any criteria and competences that the person must have in order to have both full access to each workplace with its respective specifics, as well as to know the technology and the necessary knowledge in chemistry for such solutions. There is also a lack of any sanctions against the person in question in cases where damage is caused to the enterprise for such decisions taken by him.
We also disagree with the proposal in §5 – paragraph 1 of art. 30a, which stipulates that the same persons should temporarily stop work on a separate machine, apparatus, tool, installation, device, arrangement or facility used in work, or to prohibit the use of dangerous chemical substances and mixtures, when they found an immediate danger to health and the lives of workers.
Such proposals, in our opinion, exceed the competence and responsibility of the relevant persons to make such decisions, or at least there is no specific record of such requirements.
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