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In 2016 the Directive 2013/35/EU regarding the protection of health and safety of workers exposed to electromagnetic fields was transposed in Italy. Since then, the authors of this paper have been faced with several issues related to the implementation of the provisions of the Directive, which pose some interpretative and operative concerns. A primary critical feature of the Directive is that, in some circumstances, conditions of "overexposure", i.e., of exceeding the exposure limits, are allowed. In the case of transient effects, the "flexibility" concerning the compliance with exposure limits is based on the approach introduced by ICNIRP in its guidelines on static magnetic fields and on time-varying electric and magnetic fields. On the contrary, the possibility of exceeding the exposure limits for health effects, formally recognized in the article of the Directive dealing with derogations, is not included in the ICNIRP guidelines. This paper analyzes the main concerns in interpreting and managing some provisions of the Directive with particular reference to the issue of how the employer can manage the situations of overexposure.

Issues in the Implementation of Directive 2013/35/EU Regarding the Protection of Workers against Electromagnetic Fields