As a company, how should you deal with CMR substances?

Carcinogenic, mutagenic and reprotoxic (CMR) substances are increasingly in the spotlight. The business community is paying more attention to these substances and they also receive considerable media focus. Do you know what legal requirements you must satisfy with respect to these substances? How do you monitor the risks associated with these substances?

Classifying CMR substances

Substances, such as CMRs, are classified by the manufacturer/importer of the substance, by the government, or by scientific committees. There are different CMR substance lists, of which the following are legally binding in the Netherlands.

  • Annex VI of the CLP Classification, Labelling and Packaging Regulation (EC European Community) 1272/2008
  • Country-specific lists provide insight into which substances are classified as CMRs.

Moreover, there are restrictions on the use of certain CMR substances in production, transport, and use. These substances are also included in an appendix of the REACH regulations (REACH Authorisation List and SVHC list).

Some CMR substances are also included in the Biocides Regulation (EU) 528/2012 and are banned from use in cosmetics products.

This means that it is important for companies to know whether a substance they work with is included on one of these lists. If you enter products in Stoffenmanager® that are included on one of these lists, these substances are automatically marked. In addition, the CMR overview in Stoffenmanager® provides you with a complete overview of all of your CMR substances.

Legal obligations

As a company, you must satisfy your legal obligations with respect to working with CMR substances. These are included in the Working Conditions Act (Arbowet). For example, a duty to replace applies with respect to working with CMR substances. Namely, as a company, you must find a safer alternative to replace a product containing CMR substances. Companies must also ensure that they monitor exposure to CMR substances and that all possible measures are taken (in accordance with the STOP strategy). You must also be able to demonstrate your monitoring of the exposure on the basis of a calculation using measurements or a validated exposure tool (such as Stoffenmanager®). In addition, you must document specific matters with respect to your CMR substances:

  • The number of employees who work with the product
  • Which employees work with this product?
  • How long have these employees worked with this product?
  • The amount of the product that is used
  • The amount of the product that is stored
  • The date on which the data was last updated
  • The start date of the period in which the work was performed
  • The end date of the period in which the work was performed
  • The manner in which exposure could occur
  • The (technical) reasons why it is impossible to use a substitute
  • The measures used to monitor exposure
  • Is the exposure monitored?

You can keep almost all of these elements up to date in Stoffenmanager®. Moreover, the CMR section in Stoffenmanager® ensures that you have a complete overview of all CMR substances that your company works with. In addition, you can enter the above data in Stoffenmanager®. The monitoring of exposure is kept up to date in the overview of the risk assessment and on the dashboard. It is not possible to keep track of individual levels of exposure in Stoffenmanager®.

Monitoring exposure to CMR substances

You are required to monitor exposure to CMR substances in accordance with the STOP strategy. The STOP strategy involves the following:

  • Substitution
  • Technical measures
  • Organisational measures
  • Personal protective equipment (PPE)

Substitution with a safer alternative product is paramount. Companies must demonstrate that they have fully explored this option. Occasionally, a safe alternative is not available or substituting the product is not technically feasible. In this case, a company is required to explore technical measures such as the use of extractors, adapting the installation or adapting the type of operations to be carried out. If this option is not possible, organisational measures must be explored. For example, these measures could involve task rotation and the use of work instruction cards (WICs) so that employees follow procedures. The last step might include the use of personal protective equipment (PPE). You can implement these steps in Stoffenmanager® under the “Control” option. This option displays the different types of measures and you can make your selection. Your selection is then directly included in an Action Plan so that you can immediately implement the improvements!

Practical examples

There are many practical examples of companies that substitute CMR substances or that ensure exposure is as low as possible. You can consult these best practice examples at:

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