Prevention of Risks Associated with Hazardous Chemical Agents

Hazardous chemicals, which are present in all sectors of activity, pose immediate or delayed risks to workers’ health. It is the employer’s responsibility to identify them, assess the risks, and implement all necessary preventive measures and resources.

Hazardous chemical agents (HCAs) are defined as chemical agents that may pose a risk to workers’ health and safety due to their physicochemical, chemical, or toxicological properties, as well as the circumstances of their presence in the workplace or their use.

The effects of the human body's interaction with ACDs may include the following:

• acute poisoning, with effects ranging from mild to severe
• Chronic poisoning: Repeated exposure to certain chemicals, even in small doses, can harm human health

It is the employer’s responsibility to protect its employees. Accordingly, the Labor Code sets forth, in Articles R. 4412-1 through R. 4412-93-4, the provisions applicable to employers regarding the risks of exposure to hazardous chemicals.

Risk assessment

Chemical risk assessments must take various criteria into account:

1. The hazardous properties of chemicals found in the workplace;
2. Health and safety information provided by the chemical supplier through the safety data sheet (SDS)
3. Any additional information he needs, obtained from the supplier or other readily available sources;
4. The nature, degree, and duration of exposure;
5. The conditions under which activities involving chemical agents take place, including the number and volume of each such agent;
6. In the event of simultaneous or successive exposure to multiple chemical agents, the combined effects of all such agents;
7. Occupational Exposure Limits and Biological Limit Values
8. The effect of preventive measures that have been or will be taken on chemical risk;
9. The findings provided by the occupational physician regarding the monitoring of workers' health;
10. The work carried out and proposals made by occupational risk prevention specialists.

All company activities involving ACDs must be evaluated, including maintenance. 

In practice, it is advisable to conduct an inventory of the products in use (through the purchasing department as well as on-site) and to obtain the associated MSDSs, ensuring that you have the latest version. It is also important to oversee the introduction of a new product so that the risk assessment can be updated. 

We must also take into account processes that emit ACDs (welding fumes, wood dust, diesel engine exhaust, etc.).

The results of the risk assessment must be communicated to the Social and Economic Committee (CSE) and recorded in the single occupational risk assessment document.

Note: The free SEIRICH software, developed by INRS, is a tool to assist in chemical risk assessment.

Preventive Measures and Resources

When the results of the risk assessment reveal a risk to workers’ health and safety, the employer must implement various preventive measures and controls, based on general safety principles, in order of priority:

• Eliminate risk whenever possible
• Substitution of hazardous chemicals with other chemicals or processes that are non-hazardous or less hazardous
• Minimizing risk (through the design of work processes, the use of equipment and materials, the implementation of collective protective measures, and, finally, the use of personal protective equipment)
• Technical and organizational measures to ensure the protection of workers (storage, handling, and segregation of incompatible chemicals)
• Employer Maintenance of Personal Protective Equipment
• No Eating or Drinking at the Station
• Restricted Access and Hazard Signs

Inspections of Collective Protection Systems and Equipment

The employer must ensure the regular maintenance and inspection of collective protection equipment (e.g., fume hoods, exhaust systems, etc.). To this end, after consulting with the Social and Economic Committee (CSE), a procedure must be established setting forth the maintenance requirements and the procedures to be followed to ensure their monitoring.

Monitoring Workers' Exposure

The employer must regularly measure workers' exposure to hazardous chemical agents present in the workplace air.

When occupational exposure limit values (OELs) have been established by regulation, the employer must have technical inspections conducted by an accredited organization at least once a year (except for an ACD not classified as CMR if the assessment concluded that the risk is low).

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Steps to Take in the Event of an Accident

Alarm systems and other communication systems must be installed to enable a response in the event of an accident, incident, or emergency.

In addition, appropriate first-aid facilities (e.g., eye wash stations, safety showers, etc.) must be made available to staff, and safety drills must be conducted at regular intervals.

Staff Information and Training

The employer must ensure that employees and the social and economic committee:

• Receive information about hazardous chemicals in the workplace
• Have access to the SDSs
• Receive training and information on the precautions to take to ensure their own safety and that of other workers at the workplace.

Training for workers exposed to CMR agents must cover additional topics.

Finally, the employer must prepare a job description for each position or work situation that exposes workers to hazardous chemicals.

Exposure tracking for carcinogens, mutagens, or substances toxic to reproduction (CMR)

The employer must also maintain an up-to-date list of workers who may be exposed to chemical agents that are carcinogenic, mutagenic, or toxic to reproduction (Categories 1A and 1B or listed in the decree of October 26, 2020). This list specifies, for each worker, the substances to which they may be exposed, as well as—where known—information on the nature, duration, and degree of their exposure. The list must be submitted to the occupational health and safety services and made available to the affected workers.

Health Monitoring

Workers exposed to ACDs may be required to undergo an additional medical examination ordered by the occupational physician to verify that they have no medical contraindications for such work.

The employer must also notify the occupational physician of any absences due to illness lasting more than ten days among workers exposed to these chemical agents.

Workers exposed to CMR agents must receive enhanced individual health monitoring (SIR).

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