1. Introduction

The ‘Veilig werken met SVHC-/CMR-stoffen’ (Working safely with SVHC/CMR substances) by Vereniging ION was published to promote and support working safely with SVHC/CMR substances, and to illustrate to businesses that careful handling of “dangerous” substances can easily go hand-in-hand with production efficiency.

Vereniging ION feels that the announcement and implementation of restrictions in the use of certain substances should be treated with the utmost of care. Measures that are implemented (too) quickly may have enormous consequences. For example, the Panteia-report commissioned by FME, Koninklijke Metaalunie and Vereniging ION indicates that a prohibition on the use of Chromium-6 would put 300,000 people in Europe out of business. For more on this subject, read the Panteia-report at: https://bit.ly/2GPs84S

Even if it were desirable to do so, it is simply not possible to replace metallic salts or, maybe in the generic sense, a large part of inorganic chemicals with ‘safe alternatives’ from one instance to the next – if only for the fact that no alternatives exist or can be produced using current technology (yet). Moreover, for so-called ‘intermediates’, the search for alternatives is not even necessary, as these substances are used exclusively by professionals in a controlled environment under safe working conditions. Additionally, many substances do not occur in the end product in a non-bound form, or even at all. This means that consumer protection is not a relevant topic. However, we do have to take into account safe working conditions for professionals. In doing so, we look for more than maximising work safety and comfort, but also for the potential consequences of the use of certain substances for the environment.

Moreover, prohibiting the execution of specific activities is not acceptable from a moral perspective; it would mean outsourcing our workplace issues to countries with a (much) lower safety standard. It would be better to processes such substances within the EU, under safe working conditions, based on European norms or directives. This is part of the reason behind the publication of the ‘Veilig werken met SVHC-/CMR-stoffen’ e-book. After all, business owners must have access to the right information and resources needed to create those safe working conditions – and without suffering too many distractions from what a business is meant to be focussing on, being: safe and profitable production, besides.

Picture Introduction
Slide from the PowerPoint presentation ‘Autorisatie van Chroom-6 – Wat hebben we geleerd?’ (Authorisation of Chromium-6 – What we have learned) by Vereniging ION, presented at a workshop during the 2019 Nationale Stoffendag in Ede, the Netherlands.