Even today, an estimated one million Dutch employees come into contact with harmful, occasionally even carcinogenic, substances (source: TNO Essaybundel Beroepsziekten gevaarlijke stoffen 20180924 - https://bit.ly/31u8O6t). National political bodies, and their executive agencies Inspectorates SZW and L&T and NVWA, want to change that. Through their project ‘Road to Zero’, they ask businesses to reduce exposure to harmful substances. Some substances may seem irreplaceable but, for a number of them, safer or less harmful alternatives are already available.
Occupational illness may sound like it is part of the job – but it should not be. Certainly not in the case of an illness like cancer, caused by exposure to harmful substances at work. Nevertheless, an annual 100,000 people in the EU die from cancer before their time. In the Netherlands, the number is between 2,000 and 4,000 people per year. Comparatively, that is 3 to 7 times more than the number of traffic accidents. Despite these numbers being as high as they are, we must never come to consider carcinogenic substances to be normal. They are not part of the job.
With respect to the classification of chemicals in the Netherlands, there are various terms and gradations that apply to different policy areas:
- Gevaarlijke stoffen (dangerous substances)
- ZZS (very alarming substances)
- pZZS (potentially very alarming substances)
- SVHC substances (substances of very high concern)
- CMR substances (carcinogenic, mutagenic, reprotoxic substances)
4.1 Gevaarlijke stoffen/ZZS/pZZS
Gevaarlijke stoffen (dangerous substances) are substances which, due to their intrinsic properties and the circumstances under which they occur, can cause danger, damage, or severe disruption to human beings, animals, or the environment. Gevaarlijke stoffen are classified into hazard categories by their intrinsic properties or by the circumstances under which they occur. These hazard categories vary by legislation. The GHS aims to harmonise this classification. For most gevaarlijke stoffen, one hazard property is deciding, but combinations can occur. These substances are sub-divided into:
- Harmful to the environment
As previously indicated, all properties are characteristics of a substance that presents a health risk.
4.2 SVHC substances
The designation of a substance as SVHC by the European Chemicals Agency is a first step in the procedure of its so-called authorisation The list of SVHC substances is designated the list of ‘candidates’, as the substances it documents are nominated for their inclusion in REACH Annex XIV (the authorisation list). Authorisation means that the use of a substance is prohibited unless permission (authorisation) has been requested and granted. Reach published the first list of SVHC substances, the so-called candidate list, on 28 October 2008; since then, it has been supplemented with new substances several times. Following the most recent addition on 4 January 2017, the list, available at the ECHA website, now documents 173 SVHC substances.
The fact that a substance meets one or more criteria does not automatically mean that it will be nominated for SVHS status. The SVHC designation also means that authorisation is considered a logical subsequent step, which is not true for all substances. In addition, many such substances are already subject to other production, import, or usage restrictions, which are those in REACH directive annex XVII. Alternatively, a substance may be subject to other legislation, such as in the case of pesticides or cosmetics. REACH uses three so-called priority groups for assessment:
- Substances which are simultaneously persistent, bio-accumulative and toxic (PBT substances), and substances which are simultaneous very persistent and very bio-accumulative (vPvB substances).
- Substances which become widely dispersed when used.
- Substances which are used in large quantities.
The following aspects can lead to a substance’s SVHC classification:
- Substances classified as carcinogenic, mutagenic, or reprotoxic category 1A or 1B under the CLP directive, https://bit.ly/2RZPN97
- Category 1A includes substances known to be carcinogenic in human beings. There is sufficient evidence for a causal relationship between human exposure to such substances and cancer.
- Category 1B includes substances that are equated to being human carcinogenic. There are sufficient indications to decide that there is a strong suspicion that human exposure to such substances can cause cancer. This suspicion is often based on long-term animal studies and/or other applicable information.
- So-called substances of equivalent concern in the POP regulation : https://bit.ly/2UtKuAy
- Priority substances under the Water Framework Directive: https://bit.ly/2Un9zNo
- Substances on the OSPAR priority action list: https://bit.ly/2GXGUXa
4.3 CMR substances
CMR is short for Carcinogenic, Mutagenic, and Reprotoxic (Reproduction Toxic) substances, or: substances that can cause cancer, can damage genetic material, or can harm reproductive ability (reduced fertility or a greater risk of miscarriage or birth defects). CMR substances may be inhaled, enter the body through the skin, or both. CMR substances are the subject of continued study. Twice per year, the Dutch Ministry of Social Affairs and Employment publishes an up-dated list of CMR substances. Currently, the list includes over 400 substances.
Quartz dust, diesel fumes, and chromium-6 can cause lung cancer when inhaled, for example. Chromium-6 can also cause skin cancer, however; the same applies for Polycyclic Aromatic Hydrocarbons (PAHs). PAHs occur as a result of incomplete combustions, and are present in dust from old, tar-based asphalt or roof tar. Aside from being inhaled, PAHs can also enter the body through the skin. Other substances, such as benzene, can cause leukaemia; whereas vinyl chloride increase the risk of liver cancer. Some CMR substances are only harmful once a certain level of exposure has been reached. For example, exposure to quartz dust is not an issue, as long as the benchmark value is not exceeded. Other substances should be avoided outright, as no level of exposure can ever be classified ‘fully safe’.
Inspectorate SZW wants to ensure safe and healthy workplaces; to that end, it wants to minimise exposure to CMR substances through its ‘road to zero’ policy. From this perspective, the preferred option is to have businesses replace all CMR substances with safe alternatives. Indeed, replacement is obligatory as long as it is technically and practically achievable. Financial or economic objections are not taken under consideration; an employee’s health must not depend on an employer’s willingness (or ability) to spend money.
More information is available at:
4.4 Carcinogenic, but not dangerous
Under this apparently self-contradictory title, Vereniging ION issues a number of publications indicating that certain substances, despite having hazard properties, are not in themselves dangerous; rather, the danger comes from the incorrect use of these substances. Examples of these publications are available through the following links:
As previously indicated, substances are generally used in buildings and under controlled substances – which is potentially a safe way of doing things. However, in cases where people fail to observe relevant safety precautions, dangerous situations may develop. The issue is not with the substance, but with the people who have failed to use it correctly. Ignoring safety measures also creates potentially dangerous situations in other areas as well. A fine example is someone’s conscious failure to use a seatbelt: https://bit.ly/381GJWO.
The conclusion is that we should not simply move to prohibit the use of a potentially dangerous substance or situation; rather, we should effect such a change in people’s behaviours as to ensure that the required safety measures are always taken. This applies not only to employees doing their work, but also to businesses (employers) tasking people with particular work activities.