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Chemical risk prevention concerns all companies. Indeed, chemicals are ubiquitous in the workplace and in all business sectors.
Even in small quantities, these products often present significant risks, ranging from simple personal injury (burns, allergies, irritation) to fire or explosion in the most serious cases. in the most serious cases.
To prevent these risks and protect workers, the French Labor Code sets out specific rules to be complied with by employers. These rules apply in particular to hazardous chemical agents. We take stock in this article!
Note: we will not deal here with the rules applicable to CMR agents, which have already been discussed in this article. this article. Feel free to (re)read it!
Assessing chemical risk
As a reminder, hazardous chemical agents (HCAs ) include :
- substances and mixtures meeting the classification criteria of Annex I of the CLP Regulation;
- chemical agents that do not meet these classification criteria but are considered hazardous because of their properties ;
- chemical agents for which an occupational occupational exposure limit value (VLEP).
As with all occupational hazards, the employer must assess the risk for all activities likely to present a risk of exposure to hazardous chemical agents, including servicing and maintenance activities.
All the elements to be taken into account in this risk assessment are listed in article R4412-6 of the French Labor Code. These include
- hazardous properties of chemical agents ;
- health and safety information provided by the product supplier(safety data sheets);
- the nature, degree and duration of exposure;
- in the event of simultaneous exposure to several ACDs, the combined effects of these agents ;
- occupational exposure limit values (OELVs).
Good to know: the safety data sheet (SDS) must be provided to the must be supplied to the employer by the person to whom the order is placed (producer, supplier, reseller) when the product is first delivered.
Each work situation involving exposure to hazardous chemical agents must be carefully analyzed to determine how the products are used and in what volumes.
The results of the risk assessment must be communicated to the Social and Economic Committee (CSE). They must also be recorded in the document unique d'évaluation des risques professionnels (DUER).
Please note: risk assessments must be renewed regularly, particularly when any significant changes are made to conditions that could affect the health or safety of workers. that could affect the health or safety of workers.
Implement appropriate preventive measures
Once a risk assessment has been carried out, it is up to the employer to define the necessary preventive measures.
These measures must aim, as a priority, to eliminate the chemical risk. Failing that, they should aim to reduce the risk to a minimum , in particular by substituting one product for another. If such substitution is not possible, action should be taken on the design of the work process, the use of equipment and materials, and the application of collective protection measures.
Please note: it is the employer's responsibility to draw up, after consultation with the CSE, a notice setting out the conditions for maintenance of collective protection installations and equipment, as well as the procedures for monitoring them.
Finally, and only if exposure cannot be reduced by other means, personal protective equipment (PPE) must be provided for exposed workers. PPE, like collective protective equipment, must be regularly checked and maintained.
Take note!
When the risk assessment reveals only a low risk (for example, in the case of low quantities of hazardous chemical agents), preventive measures may be reduced, and some will not be applicable (verification of installations, exposure control, emergency measures, medical follow-up, workstation instructions).
Other technical and organizational measures apply to the storage, handling and isolation of incompatible hazardous chemical agents. If these measures are not feasible, sources of ignition must be avoided. In addition, the existence of unfavorable conditions and adverse effects on the health and safety of workers must be mitigated.
Finally, access to premises where hazardous chemical agents are used must be restricted to authorized personnel , and these premises must be signposted. Hazardous chemicals must also be labeled in accordance with current regulations (CLP labeling).
Monitoring worker exposure
For workers exposed to hazardous chemical agents, the French Labor Code requires employers to regularly measure their exposure.
When chemical agents are subject to VLEP (see article R4412-149 of the French Labor Code), the employer must have a technical inspection carried out at least once a year by a COFRAC-accredited organization.
Please note: this control must also be carried out in the event of any change likely to have a negative impact on worker exposure.
If an indicative VLEP is exceeded
The employer must carry out a risk assessment to define appropriate measures.
If a restrictive VLEP is exceeded
The employer must immediately take appropriate protective and preventive measures.
Measurement results and technical inspection reports must be forwarded to the works doctor and the Works Council. They must also be made available to the labor inspector, the medical inspector and the agents of the prevention services of the Social Security organizations.
Take emergency measures in the event of an accident or incident
In order to be able to react rapidly in the event of an incident or accident involving chemicals, emergency measures must be drawn up in writing for each workplace where a chemical risk has been identified during the risk assessment.
In particular, they must specify :
- what to do in the event of an accident ;
- alarm and warning systems to be used to trigger rescue and evacuation operations;
- who to contact (workplace first-aid workers, external emergency services, etc.);
- rules for evacuating personnel in the event of an accident;
- first-aid and personal protective equipment to be used.
The employer must also ensure that emergency measures relating to hazardous chemical agents are available, in particular to the competent internal or external response services in the event of an incident or accident.
All high-risk workplaces must be equipped with first-aid and first-response equipment appropriate to the nature of the risk, and safety drills must be organized at regular intervals.
Examples: safety showers, eyewash fountains, fire extinguishers, fire hose reels, etc.
Access to the affected area must be restricted to workers who are essential for carrying out repairs or other work. They must be provided with appropriate PPE, and their exposure must be limited to what is strictly necessary.
Informing and training workers
All employees and the Works Council must receive information on hazardous chemical agents , and have easy access to safety data sheets. They must also be trained in the precautions to be taken in the event of an incident or accident.
Employers are required to draw up a workstation manual for each position where workers are exposed to hazardous chemical agents. These instructions must be updated as soon as necessary. In particular, it includes a reminder of :
- applicable hygiene rules ;
- instructions on the use of collective and individual protective equipment.
Medical monitoring of exposed workers
All employees exposed to chemical agents must undergo individual health monitoring. This includes an information and prevention visit (VIP) within three months of starting work.
Workers assigned to work involving exposure to hazardous chemical agents may also undergo an additional medical examination to verify that they are not medically contraindicated to perform such work.
In addition, any worker exposed to hazardous chemical agents who claims to be "inconvenienced" by the work he or she is performing must undergo a complementary examination. This examination can be carried out at the worker's request.
Please note: if a worker exposed to hazardous chemical agents is absent due to illness for more than 10 days, you must inform the occupational physician.
It should also be remembered that hazardous chemical agents constitute an occupational risk factor in terms of arduous work.
Some useful definitions of chemical risk...
Source: French Labour Code / INRS
Legislative and regulatory sources
French Labour Code, article L4412-1 (consideration of polyexposure situations), articles R4412-1 to R4412-57 (provisions applicable to hazardous chemical agents), Regulation (EC) No 1907/2006 [known as REACH] and Regulation (EC) No 1272/2008 [known as CLP].
General note:
The specific provisions concerning CMR agents (Carcinogenic, Mutagenic, toxic for Reproduction) are not explained in this article. A special article on this subject will be published on our EHS Regulatory blog.
Photo credit: 351305184 @marchsirawit