Replacement of hazardous chemical agents in companies is a priority action
Francisco Alberto Vicente de la Peña, of the National Centre for New Technologies, under the National Institute for Health and Safety at Work (INSST), states, in a recently published good practice guide, that the replacement of hazardous chemical agents in companies with other less or non-hazardous ones should be considered a priority action, as established by current legislation based on the principles of preventive action. The aim is to eliminate or reduce the risks to which people are exposed in the workplace.
The technical note on prevention drafted by Francisco Alberto Vicente de la Peña replaces NTP 712, describing the German GHS column model for the replacement of hazardous chemical agents, with the aim of adapting it to the Regulation on classification, labelling and packaging of substances and mixtures (CLP) and the latest version of the Model Columns of the German Institute for Health and Safety at Work of the German Social Accident Insurance (IFA). This tool describes a simple methodology, intended for small companies, to compare the hazards of two or more substances in order to select the less hazardous substance. In the introduction to the guide, De la Peña stresses that the replacement of hazardous chemical agents with less hazardous or non-hazardous ones should be considered a priority action, although he also acknowledges that the process of replacing a chemical agent is a complex one. “In terms of the scope of regulation on the bringing to market of chemical substances, Regulation (EC) No. 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and the CLP Regulation, and, for example, REACH, through the authorisation and restriction processes, already limit marketing or requests more requirements so that the most dangerous substances are handled safely and control measures are more effective.” Steps to follow The European Chemicals Agency (ECHA) provides information and tools on the steps to be taken into account it comes to replacing chemical agents. Specifically, the following steps are set out: identification, search and analysis of alternatives, testing and implementation, and feedback. The first step in successful replacement is to identify the hazardous substances in use and prioritise those that could be candidates to replace it. Once this is done, alternatives should be sought. “It is recommended to explore a wide range of options, including substances, techniques and product designs. For an alternative to be viable, there must be sufficient information on its properties. The ECHA itself offers resources and tools to facilitate this search, including the Classification and Labelling Inventory of Substances database. When identifying possible alternatives, compare and select those that best fit the process and whose final outcome is as expected. "At this stage, risks and hazards, functionality, economic viability and other potential impacts should be assessed in order to avoid undesirable outcomes or merely replacing one risk for another.” After a general analysis, the key criteria for decision making will be further explored. “If an alternative chemical is chosen, it is essential to carry out an assessment of the potential risks associated with it and to consult toxicological and exposure information databases. It is also necessary to assess performance, looking at the product life cycle and other aspects such as greenhouse gas emissions. Once the most suitable alternative has been chosen, pilot tests should be carried out to verify and adjust the changes in the process required to definitively implement the replacement. “If the results are satisfactory, industrial scale-up will follow.” Finally, once the replacement has been completed, it is necessary to “announce this change to customers and suppliers, in case it has implications for their processes or products”.