Should Non-Melanoma Skin Cancer Be Recognised as an Industrial Disease EU-Wide?

Non-melanoma skin cancer (NMSC), or actinic keratosis, is the most common cancer worldwide. The main types are basal cell carcinoma (BCC) and squamous cell carcinoma (SCC), while Merkel cell carcinoma (MCC) is on the rise. NMSC are generally less dangerous than melanoma cancer, as they are less aggressive and less likely to spread to other parts of the body.

In an Industrial Injuries Advisory Council (IIAC) information note, which was discussed in edition 229 of BC Disease News (here), it was confirmed that exposure to ultraviolet (UV) light from the sun is a risk factor of NMSC, though the Council did not recommend that SCC or BCC, caused by occupational exposure to sunlight, should be added to the list of prescribed diseases eligible for disablement benefit, on that occasion.

UV radiation is classified by the World Health Organisation (WHO) as ‘Carcinogenic to humans’ (Group 1 carcinogen).[i]

NMSC is recognized as an occupational disease in several countries, but not in the UK, even though the Institution of Occupational Safety and Health (IOSH) has incentivised solar radiation as a key component of its No Time To Lose (NTTL) campaign objective to prevent occupational cancer – find out more in our Occupational UV Radiation Claims feature, here.

According to Ulrich et al (2016), only France, Germany and Denmark have an established programme on work‐related skin diseases, covering carcinogen-induced skin cancers.[ii]

On 26 April 2019, the Multi-Stakeholder Summit on Occupational Skin Cancer took place.

Subsequently, Summit sponsors (European Academy of Dermatology and Venereology, European Association of Dermato Oncology, International League of Dermatological Societies, Association of European Cancer Leagues, European Dermatology Forum, International Commission on Occupational Health and European Cancer Patient Coalition), in co-operation with patient advocacy groups, workers unions, occupational safety and health professionals, social security representatives, dermatologists and oncologists, called for ‘the implementation of a systematic approach to addressing the Non-Melanoma Skin Cancer Epidemic’.[iii]

For workers in outdoor professions, e.g. in construction and in agriculture, it is estimated that the risk of developing skin cancer increases by more than 100% with 5 or more years of work. We summarised the findings of a recent study on NMSC prevalence here.

The Global Call to Action seeks to have NMSC officially recognised as an occupational disease, EU-wide, within the next legislative period. It also hopes to improve UV exposure level quantification, sun-safe behaviours, skin cancer screenings, treatments and medical reporting of cases.

Smartphone messaging has already been trialled as a sun-safe mechanism in an Institution of Occupational Safety and Health (IOSH) collaborative study (reported in March, here).


[i] ‘Agents Classified by the IARC Monographs, Volumes 1–123’ (25 March 2019 IARC) <> accessed 2 May 2019.

[ii] Ulrich, C. et al. The European Status Quo in legal recognition and patient-care services of occupational skin cancer. Journal of the European Academy of Dermatology and Venereology 30, 46–51 (Accessed 7 June 2018)

[iii] ‘Global Call to Action to End the Non-Melanoma Skin Cancer Epidemic in Outdoor Workers’ (26 April 2019) <> accessed 2 May 2019.