Controlling exposure to CMR substances - carcinogenic, mutagenic and reprotoxic substances - remains a difficult subject for many companies. What obligations apply? How should a company deal with CMR substances in the workplace? In practice, there is often uncertainty about the best obligations for working with CMR substances, especially when the expected exposure is below the limit value. In this blog you can read how you deal with these kinds of issues within your company.
Assessment of CMR substances
As for all hazardous substances, the exposure level to CMR substances must be determined. Most quantitative assessment models (or estimation models) or suitable measurement methods in air or urine/blood can be used for the exposure assessment. Exposure to lead, on the other hand, should always be determined with measurements in the workplace atmosphere and monitoring of lead concentration in the blood of the (potentially) exposed worker. Measurements are not mandatory for the other CMR substances.
Control of CMR substances
When the exposure assessment of a CMR substance has been carried out and the risk ratio (= exposure concentration / limit value) is above 1, you as a company are obliged to take control measures in accordance with the STOP principle. This by the way applies to all hazardous substances with an RR>1, regardless of CMR classification.
1. What is the STOP principle?
STOP stands for Substitution, Technical Measures, Organizational Measures and Personal Protection. These measures follow a hierarchy of control. In practice, this means that companies - if technically feasible - must first replace (S) the (CMR) substances with less harmful substances, even if replacement is economically or financially less attractive. If substitution is not technically feasible, we descend in hierarchy to limit exposure with technical measures (T) such as installing local exhaust ventilation. Have technical measures already been implemented and is overexposure still taking place? Then switch to organizational measures (O), such as changing work instructions aimed at shortening the exposure time per employee. In some cases, replacement is not possible and technical and organizational measures are not sufficient. In these cases, personal protective equipment (P) can be used to protect employees as much as possible.
NB! There are proven CM (carcinogenic and mutagenic) substances without a so-called threshold value. This means that there is always a health risk even when exposure is below the limit value. So regardless of the degree and duration of exposure. Control measures must always be taken for these substances in accordance with the STOP principle in order to reduce exposure as much as possible.
An obligation to replace applies to all proven CM substances (designated H340 and H350) - regardless of exposure level. This means that companies must always first look for an alternative substance to replace the CM substance. There are several initiatives/websites that can help you research alternatives suitable for your company:
Additional registration obligations
There is also an additional registration obligation for proven CM substances. The following information must be recorded for these CM substances:
- Consumption on an annual basis (minimum – maximum)
- Frequency of use on an annual basis
- Type of work/activities
- Necessity of use
- Possibilities for replacement and possibly an explanation why the substance cannot be replaced with a healthier alternative (see above)
- Use of PPE
Although this obligation does not apply to suspected CM substances (designated with H341 and H351), we do recommend doing so. Substances that are not yet classified as 'proven' carcinogens/mutagens may become so in the future.
2. ''My employee is pregnant – what now?''
Your employee is pregnant and may be exposed to reprotoxic (R) substances: substances that have a negative effect on the fertility of the employee or the development of the unborn child (teratogenic). At this moment there are less strict rules for working with reprotoxic substances in the workplace than for CM substances. However, R substances are also subject to an assessment obligation and control according to STOP at RR>1. In addition, all R substances are subject to a registration obligation, whereby only the consumption on an annual basis must be recorded. There is growing attention for R substances. A new directive (2022/431) states that stricter registration and effort obligations will be introduced that are comparable to the current obligations regarding CM substances. It is also expected that for R substances without a safe limit value, it will become mandatory to apply control measures to reduce exposure as much as possible, again comparable to CM substances without a safe limit value. It is not yet known when this guideline will be enforced in practice, but this is expected to take shape in 2024.
CMR Substances & Chemrade
A good CMR policy starts with an up-to-date register of hazardous substances. You also keep track of whether your substances and products are CMR-classified. Chemrade's full-managed Substance Database can take care of this for you. All substances on the most recent CMR list are registered and maintained in the Substance Database. Subscribing to substances from the Substance Database means that your overview of CMR substances is always up to date. In addition, Chemrade offers the option of establishing additional registration obligations for CMR substances. Using the reporting function, you can easily and simply create a printout of your CMR household, assessment & control, in a way that satisfies the inspection.
Would you like to know what else Chemrade can do for your CMR registry?