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🔎 Key takeaways
Hazardous chemical agents, 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 preventive measures and means.
Hazardous chemical agents (HCA) 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 conditions of their presence in the workplace or their use.
The effects of human body interaction with HCAs can include:
- acute poisoning, with varying degrees of severity
- chronic poisoning: repeated contact with certain chemical agents, even at low doses, can then harm human health
It is the employer's responsibility to protect their employees. Thus, the Labor Code, in its articles R. 4412-1 to R. 4412-93-4, sets out the provisions applicable to employers concerning the risks of exposure to hazardous chemical agents.
Risk Assessment
Chemical risk assessment must take into account various criteria:
- The hazardous properties of chemical agents present in the workplace;
- Health and safety information provided by the chemical supplier via the Safety Data Sheet (SDS)
- Additional necessary information obtained from the supplier or other readily accessible sources;
- The nature, degree, and duration of exposure;
- The conditions under which activities involving chemical agents take place, including the number and volume of each;
- In the event of simultaneous or successive exposure to several chemical agents, the combined effects of all these agents;
- Occupational exposure limit values and biological limit values
- The effect of preventive measures taken or to be taken on chemical risk;
- The conclusions provided by the occupational physician regarding the monitoring of workers' health status;
- The work carried out and proposals made by occupational risk prevention specialists.
All company activities involving HCAs must be evaluated, including maintenance.
In practice, it is advisable to inventory the products used (via purchasing departments but also on-site) and to retrieve the associated SDSs, ensuring you have the latest version. It is also important to manage the integration of new products to allow for risk assessment updates.
Processes emitting HCAs (welding fumes, wood dust, diesel engine exhaust gases, etc.) must also be considered.
The results of the risk assessment must be communicated to the Social and Economic Committee (CSE) and recorded in the single professional risk assessment document.
Note: The free SEIRICH software, developed by INRS, is a tool to assist with chemical risk assessment.
Preventive Measures and Means
When the results of the risk assessment reveal a risk to workers' health and safety, the employer must then implement several preventive measures and means, based on general safety principles, in order of priority:
- Elimination of the risk where possible
- Substitution of hazardous chemical agents with other non-hazardous or less hazardous chemical agents or processes
- Reduction of risk to a minimum (through the design of work processes, the use of equipment and materials, the application of collective protection measures, and finally the use of personal protective equipment)
- Technical and organizational measures to ensure worker protection (storage, handling, and isolation of incompatible chemical agents)
- Maintenance of personal protective equipment by the employer
- No eating or drinking at the workstation
- Restricted access and risk signage
Inspection of collective protective equipment and installations
The employer must ensure the regular maintenance and inspection of collective protective devices (e.g., fume hoods, ventilation systems, etc.). To this end, a notice must be drawn up, after consulting the CSE, specifying the maintenance conditions and the procedures to be implemented to ensure their monitoring.
Monitoring of worker exposure
The employer must regularly measure workers' exposure to hazardous chemical agents present in the workplace atmosphere.
When occupational exposure limit values (OELVs) have been legally established, the employer must then arrange for technical inspections to be carried out by an accredited body at least once a year (except for a non-CMR classified HCA if the assessment concluded a low risk).
To learn more about OELVs: https://www.tennaxia.com/en/blog/vlep-rappel-evolutions-reglementaires-au-1er-juillet
Measures in case of accident
Alarm systems and other communication systems must be installed to respond in the event of an accident, incident, or emergency.
Furthermore, appropriate first-aid facilities (e.g., eyewash stations, safety showers, etc.) must be made available to personnel, and safety drills organized at regular intervals.
Information and training of personnel
The employer must ensure that workers and the social and economic committee:
- Receive information on hazardous chemical agents present in the workplace
- Have access to SDSs
- Receive training and information on the precautions to be taken to ensure their protection and that of other workers present in the workplace.
Training for workers exposed to CMR agents must cover additional topics.
Finally, the employer must establish a workstation instruction sheet for each workstation or work situation exposing workers to hazardous chemical agents.
Traceability of exposure for carcinogenic, mutagenic, or reprotoxic agents (CMR)
The employer must also establish an updated list of workers likely to be exposed to carcinogenic, mutagenic, or reprotoxic chemical agents (category 1A and 1B or listed by the decree of October 26, 2020). For each worker, this list must indicate the substances to which they are likely to be exposed, as well as, when known, information on the nature, duration, and degree of their exposure. The list must be sent to occupational health and prevention services and made available to the workers concerned.
Health Monitoring
Workers exposed to hazardous chemical agents (ACD) may undergo an additional medical examination prescribed by the occupational physician to verify that they do not have any medical contraindications for these tasks.
The occupational physician must also be informed by the employer of absences due to illness lasting more than ten days among workers exposed to these chemical agents.
Workers exposed to CMR agents must benefit from reinforced individual health monitoring (SIR).