Substitution
The first step in taking measures against exposure to hazardous substances is always substitution, i.e. replacing a hazardous substance with a non-hazardous or less hazardous substance. Substitution of a hazardous substance directly ensures that no one in the company is exposed to the substance in question. For that reason, it is the first step in the STOP strategy.
There are several websites with suggestions for substitutes, such as marketplace.chemsec.org or SUBSPORTplus. Branche organisations also sometimes offer an overview of alternative substances. Look at the website of the branche organization or contact your branch organization.
Substitution hazardous substances
For substitution of hazardous substances, go through the following steps:
- Identify hazardous substances
- Find safer alternatives and compare them
- Run tests with the alternative
- Implement and adjust as needed
- Introduce a system to track the use of chemicals
Check carefully whether the replacement substance is indeed less harmful. Substitution should always be considered as a first measure. Also pay attention to innovations that come on the market.
CMR substances
Substitution is always the best possible measure and that is why it is at the top of the STOP strategy (the STOP strategy is the concrete elaboration of the occupational hygiene strategy for substances). Only when substitution is not reasonably possible, because there is no better alternative, or because the implementation involves disproportionately large adjustments or costs, should technical measures be considered (the second step in the STOP strategy).
For CMR substances, these rules are even stricter: if a better alternative is available, the substance must be replaced. The ‘reasonable principle’ does not apply in this case. CMR substances are carcinogenic (carcinogenic), mutagenic (substances that can damage the genes) and toxic to reproduction (substances that can be harmful to reproduction or offspring).
A list with CMR substances available by the Dutch Ministry of Socials affairs and Employment can be found here.