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«Social Europe This publication is supported by the European Union Programme for Employment and So- cial Solidarity - PROGRESS (2007-2013). This ...»

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chemical risk

to workers’ health

and safety through


Social Europe

This publication is supported by the European Union Programme for Employment and So-

cial Solidarity - PROGRESS (2007-2013).

This programme is implemented by the European Commission. It was established to finan-

cially support the implementation of the objectives of the European Union in the employ-

ment, social affairs and equal opportunities area, and thereby contribute to the achieve- ment of the Europe 2020 Strategy goals in these fields.

The seven-year Programme targets all stakeholders who can help shape the development of appropriate and effective employment and social legislation and policies, across the EU-27, EFTA-EEA and EU candidate and pre-candidate countries.

For more information see: http://ec.europa.eu/progress Minimising chemical risk to workers’ health and safety through substitution PART I Practical Guidance


Study Report on identifying a viable risk management measure European Commission Directorate-General for Employment, Social Affairs and Inclusion Unit Health, Safety & Hygiene at Work Manuscript completed in July 2012 This study was financed by and prepared for the use of the European Commission, Directorate-General for Employment, Social Affairs and Inclusion. It does not necessarily represent the Commission’s official position.


Y. Gilbert, P. Pessala, J. Aho, R. Lehti, I. Vehviläinen, and M. Hjelt (Gaia Consulting Oy) E. Priha, T. Santonen, M. Koponen, B. Bäck, E.-R. Hyytinen and A. Kangas (Finnish Institute for Occupational Health) Europe Direct is a service to help you find answers to your questions about the European Union

Freephone number (*):

00 800 6 7 8 9 10 11 (*) Certain mobile telephone operators do not allow access to 00 800 numbers or these calls may be billed.

More information on the European Union is available on the Internet (http://europa.eu).

Cataloguing data as well as an


can be found at the end of this publication.

Luxembourg: Publications Office of the European Union, 2012 ISBN 978-92-79-25969-2 doi:10.2767/77360 © European Union, 2012 Reproduction is authorised provided the source is acknowledged.

Foreword The implementation of effective chemical substitution policies and management practices at the workplace can deliver significant benefits in terms of protecting the health and safety of workers. To make this happen in practice requires a raised awareness and involvement of all stakeholders to develop an understanding of how successful substitution could look like in practice.

The effective practical implementation of the substitution principle can bring substantial benefits to EU employers and workers not only in terms of health and safety impact via improved risk management at the level of individual companies, or at sectoral level, but also in terms of wider socioeconomic considerations.

Whilst it may be possible to agree that chemical substitution is important for improving working conditions, there is no clear objective information on how effectively it is used in practice. Substitution is associated with a number of issues that are not always easy to evaluate in order to facilitate the decision making process. It requires judgment to take account of workers health and safety protection, process performance, the ease and cost of introducing substitutes, environmental considerations and other factors in making a substitution choice.

DG Employment, Social Affairs and Inclusion recognises the multi-attribute challenges that substitution presents to individual employers. Several approaches to substitution exist ranging from ad-hoc approaches to methods that are defined, structured and documented. Less sophisticated substitution approaches may be more suitable for smaller companies compared to larger better resourced organisations that have a high level of technical expertise.

DG Employment, Social Affairs and Inclusion funded this study to analyse and evaluate the practical implementation of the principle of substitution of hazardous chemicals at the workplace with a view to further enhance the protection of workers health and safety while taking into account the abovementioned factors.

DG Employment, Social Affairs and Inclusion hopes that this study and the associated guidance document will contribute to the development of a decision making framework which will consider all the relevant aspects of implementing the principle of substitution at the workplace.

3 Content PART I - Practical Guidance

1. Introduction

2. Change for health and safety in four steps

3. Change for health and safety in seven steps

Appendix 1 Hazards signs and CLP pictograms

Appendix 2 Tools and further reading

Appendix 3 Risk matrix

Appendix 4 Tables for the 4 step substitution process

Appendix 5 Case studies

Appendix 6 Comparison tools for the 7 step process

Appendix 7 Substitution flow chart

PART II - Study Report on identifying a viable risk management measure

Key findings

Principales conclusions

Wichtigste Erkenntnisse

Executive summary

1. Introduction

1.1 Chemicals are a vital part of today’s society

1.2 Legislation sets the basic requirements for chemical risk management

1.3 Substitution as a preferred risk reduction measure

1.4 Data interpretation and requirements for tools

1.5 Report structure

1.6 Steering group

1.7 Disclaimer and acknowledgements

2. Study focus, definitions, aim and objectives

2.1 Focus of the work

2.2 Definition of substitution

2.3 Aim and objective

3. Study framework and methodologies

3.1 Research boundaries

3.2 The analytical framework

3.3 Overview of methodologies used


3.4 Data collation

3.4.1 Data collation overview

3.4.2 Literature review

3.4.3 Data

3.5 Analysis and evaluation

3.5.1 Overview

3.5.2 Assessment of drivers, barriers and motivators

3.5.3 Assessment of existing approaches and development of requirements for a common approach

3.5.4 Interactive methods: Cross-disciplinary evaluation and workshop

3.6 Developing a common approach

3.6.1 Development work

3.6.2 Validation

3.7 Reporting

4. Policy, legislation and information sources

4.1 Introduction

4.1.1 Relevant policy and legislative areas

4.2 Supranational organisations

4.2.1 United Nations – promoter of chemical safety

4.2.2 OECD – information provider

4.2.3 OSPAR – international agreements for industry specific requirements on substitution

4.3 European Union – legislator, policy setter and information provider

4.3.1 Overview and the main actors

4.3.2 Occupational safety and health (OSH) legislation

4.3.3 Control of Major Accident Hazard

4.3.4 Overarching chemical legislation - REACH

4.3.5 Environment

4.3.6 Transport of dangerous goods

4.3.7 Combined effects

4.4 National approaches in the case study countries

4.4.1 Finland

4.4.2 France

4.4.3 Germany

5 4.4.4 Netherlands

4.4.5 The United Kingdom

4.4.6 Some additional notes from Denmark

4.4.7 Evaluation of existing guidance to substitution in the case study countries

5. Substitution drivers, barriers and motivators

5.1 Overview

5.2 External influences

5.2.1 Types of influences

5.2.2 The legal framework influencing substitution decisions

5.2.3 Stakeholders: Supply chain influences

5.2.4 Market forces: Raw materials and energy use

5.2.5 Legal framework and standards and quality control

5.2.6 Stakeholders: Public opinion and company image

5.2.7 Summary of external forces

5.3 Internal factors influencing the use of substitution

5.3.1 Types of influences

5.3.2 The R&D process

5.3.3 Technical and practical considerations

5.3.4 Management approaches

5.3.5 Financial considerations

5.3.6 Summarising internal factors

5.4 Conflicting influences

6. Substitution in practice

6.1 Actors and the value chain

6.1.1 Taking the value chain approach

6.1.2 The role of authorities

6.1.3 The role of companies

6.1.4 The role of other organisations

6.2 Chemical manufacturing

6.2.1 Overview

6.2.2 Current practices

6.2.3 Requirements

6.3 Chemical blenders and service companies

6 6.3.1 Overview

6.3.2 Current practices

6.3.3 Requirements

6.4 Process industry

6.4.1 Overview

6.4.2 Current practices

6.4.3 Requirements

6.5 Chemical users

6.5.1 Overview

6.5.2 Current practices

6.5.3 Requirements

6.6 Summary of current practices and existing challenges in the supply chain

7. Tools and databases supporting practical substitution

7.1 Overview

7.2 Databases with substance information only

7.3 Existing tools for chemical risk assessment

7.4 Existing databases and tools for finding and comparing alternatives

7.5 Existing cost benefit approaches and tools

7.6 Analysis of existing tools and databases

8. The feasibility of a common approach

8.1 Substitution as a risk management measure

8.2 The relative complexity of substitution

8.3 Requirements for the common approach

8.4 Risk assessment tools

8.5 Identification of alternatives

8.6 Feasibility and overall costs and benefits

8.7 Common guidance to a common approach

9. The proposed common approach

10. The proposed Draft Guidance document

11. Validation of the proposed process

11.1 Validation process

11.2 Workshop

11.3 Hearing at the Working party "Chemicals at the workplace”


11.4 Validation survey

11.5 Piloting

12. Summary of results for set objectives

13. Conclusions and recommendations

Terminology and abbreviations


Annex 1 Participants

Annex 2 Survey summary

Annex 3 Construction survey summary

Annex 4 Summary of the validation survey


Practical Guidance

1. Introduction

The objective for this guidance The objective for preparing this guidance was to provide workplaces across the EU with a common approach to chemical substitution. The guidance has been prepared for use in EU workplaces with particular emphasis on the needs on SME’s. The main target audience is companies with limited or some knowledge or experience of chemical risk management.

Innovation and product development aiming for safer products and processes are a vital part in the drive for safer chemical use in workplaces. This guidance does not in detail address the innovation or R&D processes required for more challenging substitutions, such as substitution of reagents in chemical reactions or of complex process industry use of chemicals.

 At the individual company level you can also further develop the process presented to meet your specific needs or circumstances.

 Industry associations or national authorities can also adapt the model to better reflect specific needs of employment sectors or national approaches in Member States.

The developed approach presents a systematic yet flexible, risk based process for identifying chemicals that could or should be substituted and evaluating alternatives against risk, technical requirements and practical and cost considerations.

Substitution of very hazardous chemicals is part of the regulatory framework in the EU, through the Chemical Agents Directive, the Carcinogens and Mutagens Directive as well as within environmental legislation and the REACH Directive. Substitution may also be an element in each company's day-to-day product stewardship, product development and innovation activities. Both processes may lead to substitution but are quite distinct in nature. This guidance approaches substitution as an element of risk management, as part of the company’s day-to-day business.

The main focus is on occupational health and safety, but the importance of including environmental aspects is also highlighted.

This guidance does not attempt to produce new science or reveal major new ways of thinking about substitution – it aims to translate scientific considerations of hazard, risk and risk reduction through substitution into something more easily accessible for the target audience. The vast majority of companies within the EU do not have the expert knowledge or resources to undertake state of the art evaluations. It is acknowledged that this guidance simplifies scientific knowledge. Wherever there are simplifications, we hope the scientific community and experts in occupational hygiene, safety and chemical risk will accept this simplification as a necessity in the effort to reach a larger potential audience and make substitution a more widely used risk reduction measure.

“....Seeking perfection [in methodology] will only ensure that the prevention of work-related disorders will not be achieved for the majority of the world’s work force...” David M. Zalk; Deborah Imel Nelson: History and Evolution of Control Banding: A Review. Journal of occupational hygiene, 2008

10Substitution as a risk management measure

Substitution – what is it?

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