Sound and Sustainable

Management of Chemicals
A Training Manual for Workers and Trade Unions

Sustainlabour
Cover page: © P. Van Peenen / UNEP / Still Pictures
Chemical weapons dump, Canada. Hazardous chemicals can persist in the environment for decades, accumulating in the food chain, and can be transported far from the
original source. They form major health risks for workers, damage the nervous and immune systems, cause cancers and reproductive disorders, and interfere with child
development. To save lives and protect the environment by eliminating the most toxic chemicals will cost billions of dollars.

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 SOUND AND SUSTAINABLE
MANAGEMENT OF CHEMICALS

A training manual for workers and trade

unions
Copyright ©2008, United Nations Environment Programme

Disclaimers:
The content and views expressed in this publication do not necessarily reflect the
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UNEP/Sustainlabour Training Manual on Sound and Sustainable
Management of Chemicals, 2008

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2
 Training Manual Prepared by

the the
International Labour United Nations
Foundation for Sustainable Environment
Development Programme
(Sustainlabour) (UNEP)

Sustainlabour

As part of their joint project on

“Strengthening trade union participation to

international environmental processes”

Funded by the Government of Spain

3
 ACKNOWLEDGEMENTS
The preparation of the Training Manual on “Sound and Sustainable Management
of Chemicals” has involved many individuals and organizations. UNEP and
Sustainlabour wish to express their gratitude to authors, contributors and
reviewers that have made this possible.

UNEP and Sustainlabour wish to acknowledge, in particular, the contributions

from the International Labour Organization (ILO), the World Health Organization
(WHO), and the International Trade Union Confederation (ITUC) and its affiliates.

Our particular thanks are extended to the Government of Spain for its support to
workers and trade unions, and UNEP.

PRODUCTION TEAM
Lead Author:

• Judith Carreras Garcia, Programme Coordinator, Sustainlabour Foundation

Contributors:

• Clifton Curtis, Director, Global Toxics Programme of WWF, World Wide Fund
for Nature
• Nilton Freitas, Advisor of Social and Public Policies, Sindicato dos Químicos do
ABC
• Laura Martín Murillo, Director, Sustainlabour Foundation
• Yahya Msangi, Former Head of Department of Occupational Health and Safety
at Tanzania Plantation Agriculture Workers Union
• Joaquín Nieto Sáinz, President, Sustainlabour Foundation
• Peter Orris, Professor and Director, Occupational Health Service Institute,
School of Public Health, University of Illinois at Chicago
• Dolores Romano, Coordinator of the Chemical Risk Area, ISTAS-CCOO, Union
Institute of Work, Environment and Health of the Spanish Trade Union
Confederation CCOO
• Anabella Rosemberg, Consultant, Sustainlabour Foundation
• Tatiana Santos, Technical expert in the Chemical Risk Area, ISTAS-CCOO,
Union Institute of Work, Environment and Health of the Spanish Trade Union
Confederation CCOO
• Joel Tickner, Director and Assistant Professor of Community Health and
Sustainability, Lowell’s Centre for Sustainable Production at Massachusetts
University

4
UNEP Review / Editon Team:

• Olivier Deleuze, Chief, Major Groups and Stakeholders Branch, Division of

Regional Cooperation (DRC), UNEP
• Hilary French, Special Advisor, Major Groups and Stakeholders Branch,
Division of Regional Cooperation, United Nations Environment Programme and
Senior Advisor for Programs, Worldwatch Institute
• Kaj Madsen, Senior Programme Officer, Chemicals Branch, Division of
Technology, Industry and Economics (DTIE), UNEP
• Fatou Ndoye, Programme Officer, Major Groups and Stakeholders Branch,
Division of Regional Cooperation (DRC), UNEP
• Hortense Palmier, Project Officer, Major Groups and Stakeholders Branch,
Division of Regional Cooperation (DRC), UNEP

5
6
 TABLE OF CONTENTS

ACKNOWLEDGEMENTS ..................................................................................... 4
PRODUCTION TEAM ......................................................................................... 4
TABLE OF CONTENTS ....................................................................................... 7
BACKGROUND ................................................................................................ 8
INTRODUCTION ............................................................................................ 11

MODULE 1: INTRODUCTION TO CHEMICALS MANAGEMENT ...................................... 17

UNIT 1: WHAT DO WE KNOW ABOUT CHEMICALS? ................................................................... 18
UNIT 2: PAINFUL, DEADLY ENCOUNTERS WITH POISONS ............................................................ 34
UNIT 3: PREVENTION, THE BEST ANTIDOTE TO CHEMICAL EXPOSURE ............................................... 42
UNIT 4: GREEENING OUR CHEMICAL WORLD .......................................................................... 46

MODULE 2: SAFE USE OF CHEMICALS IN THE WORKPLACE ...................................... 55

UNIT 1: PREVENTION IS THE CORNERSTONE: ENHANCING A SAFETY AND PREVENTION CULTURE ................. 56
UNIT 2: BEING A WORKPLACE DETECTIVE: IDENTIFICATION OF EXPOSURE RISKS AND CHEMICALS .............. 65
UNIT 3: IS YOUR JOB PUTTING YOU AT RISK? QUALITATIVE RISK ASSESSMENT ................................... 71
UNIT 4: GET PRIORITIES RIGHT! PLAN OF INTERVENTION ........................................................... 74
UNIT 5: SAFE CHEMICALS – SAFE PRODUCTS GUIDELINES TO ENFORCE THE “SUBSTITUTION PRINCIPLE” ...... 83
UNIT 6: KEEP AN EYE ON WHAT IS HAPPENING! HEALTH AND ENVIRONMENTAL SURVEILLANCE AND FOLLOW-
UP......................................................................................................................... 89
UNIT 7: WATCH OUT! RISK NEVER SLEEPS: EMERGENCY AND FIRST-AID PROCEDURES ........................... 90
ANNEX 1: CLASSIFICATION AND LABELLING: GLOBAL HARMONISED SYSTEM (GHS), EU RISK- AND
SAFETY-PHRASES ....................................................................................................... 95
ANNEX 2: CARDS ..................................................................................................... 106
ANNEX 3: QUESTIONNAIRES ......................................................................................... 109
ANNEX 4: EXAMPLE OF A BASIC CARD TO SUMMARIZE INFORMATION ABOUT THE WORKING CENTRE ........... 114

MODULE 3: CHEMICALS REGULATION .............................................................. 117

UNIT 1: INTERNATIONAL GOVERNANCE OF CHEMICAL SUBSTANCES .............................................. 118
UNIT 2: NEGOTIATION AT THE NATIONAL LEVEL: OUR NEIGHBOURS ADOPTED IT, WHY CAN’T WE? ............ 135
UNIT 3: NEGOTIATION IN THE WORKPLACE: NOT WORTH DYING FOR A JOB...................................... 141

7
 BACKGROUND
The Training Manual on Sound and Sustainable Management of Chemicals is
developed under the framework of the project “Strengthening trade union
participation in international environmental processes”, jointly implemented by
the United Nations Environment Programme (UNEP), the International Labour
Foundation for Sustainable Development (Sustainlabour), in collaboration with the
International Trade Union Confederation (ITUC), and its affiliates, the
International Labour Organization (ILO), the World Health Organization (WHO)
and the Government of Spain.

The overall objective of the project is to improve engagement of workers and

trade unions in the development and implementation of environmental policy, as
recommended by the Trade Union Assembly on Labour and the Environment at its
first meeting in January 2006. The main purpose of the training component of the
project is to address a clear gap and lack of knowledge of the environmental
issues at stake regionally and globally in the trade union movement. The training
component of the project focuses on two topics:

a. Climate Change, its consequences on employment and trade union

action, and the need for alternative methods of production and just
transition;

b. Sound and Sustainable Management of Chemicals and how to

integrate just employment into environmental policy design.

Manual objective

The purpose of this Manual is to enhance understanding of sound and sustainable

management of chemicals and of related risks in the workplace. Particular
attention is given to the “environmental” rights of workers exposed to chemicals
and hazardous substances.

Trade unions are uniquely placed to sensitize workers about the impact of
industrial chemicals on occupational and environmental health, to promote and
demand that both public and private sectors develop programmes on chemical
safety, as well as to train workers to contribute and verify that these measures
are adequately implemented.

In this regard, access to information and training are necessary to improve

working conditions. The purpose of this Manual is to provide workers and trade
unions with general information and guidance on how to ensure sound and
sustainable management of chemicals.

Manual format and content

The Manual is designed in modular format and may be used integrally or partially
in modules, depending on the purpose and duration of the training. Modules can
be studied not necessarily in a chronological order. The expected length of the
training period is five days, however the Manual is designed in such a way that
trainers may add or leave out sections for a specific training session to shorten or
lengthen the suggested training.

The content is designed to be applicable at different spatial levels – from the

national, sub-regional, regional, and global level. It contains several case studies
from the workplace to illustrate the theoretical aspects of the Manual.

8
The Manual targets mainly workers and trade unions, both from developing
countries and countries with economies in transition from Africa, Asia and the
Pacific, Latin America and the Caribbean, and Eastern Europe. The Manual targets
experienced or inexperienced workers and trade unions in chemicals management
issues. It attempts to combine different types and levels of information to suit the
needs and interests of all; though, it targets mainly an inexperienced audience.

The Manual is elaborated for women and men, workers, who are in industry,
agriculture, government and other public or private sectors, to enable them
carefully consider the potential adverse effects of hazardous chemicals on health
and the environment, and ultimately on employment, and take appropriate
actions at the local, national or international levels for their environmentally
sound management.

The first module focuses on the concept of sound and sustainable management of
chemicals. It is a general introduction to key concepts of chemistry such as
toxicity, human and environmental effects, occupational exposure, dose-effect
relationship; concepts normally used and associated to the workplace. The
concepts of substitution and green chemistry are also presented as options to
move towards sound and sustainable management of chemicals.

The second module lays out practical advice, as it provides guidelines and
concrete examples to facilitate a structured intervention in the workplace. That is
to say, what should be done and how it could be done.

The last module explores the regulation mechanisms of chemicals from

international to workplace level. The module briefly introduces the main
mechanisms in place, and particularly underlines the importance of stakeholders’
participation, namely workers and trade unions.

Course evaluation

At the end of the training, an evaluation is requested from the trainees. The
evaluation allows trainees to highlight points that will assist trainers to improve
their delivery of the course, and to facilitate the review and revision of the Manual
over time.

9
NOTES:

10
 INTRODUCTION
Sound and sustainable management of chemicals: the basics

Chemicals have become an indispensable part of our life, sustaining many of our
activities, preventing and controlling diseases, and increasing agriculture
productivity.

Synthetic chemicals used in farms help feed us. Chemicals provide synthetic
fibbers for clothing and molecules to manufacture medicines. They provide the
basic materials to the manufacturing of cars, phones and computers, as well as
many building materials, rugs and other furnishings.

The benefits are immense. However, one cannot ignore that chemicals may also
damage human health and poison the environment.

The nature, variety and quantity of chemicals used in countries vary widely
according to factors such as the country’s economy, and the structure of its
industrial and agricultural sectors. More than 43 millions of chemical substances
are used on a global scale.1 Production of chemical substances worldwide is set to
rise from one million tonnes in 1930 to 400 million tonnes nowadays.2 Chemicals
have contributed to the improvement of living conditions, and there is no denying
that they yield benefits without which modern society could not do (e.g. in the
production of food and pharmaceuticals).

The global chemical industry also contributes to economic prosperity in terms of

trade and jobs. Its annual sales are estimated at more than US$1,600 billion. The
industry employs over 10 million people worldwide.3

However, chemicals can also cause irreversible damage to human health and the
environment since many have potentially toxic effects. Exposure risk arises
during production, storage, handling, transport, use and disposal of chemicals, as
well as from accidental leakage or illegal dumping. Thus, the whole life cycle of a
chemical substance needs to be considered when assessing its dangers and
benefits.

In particular, both the manufacture and use of chemicals takes a heavy toll on
workers. Millions of them are exposed to chemicals (occupational exposure) on
a daily basis, not only in the chemical industry but in sectors where they are
used, including agriculture, the building and construction sector, the woodworking
industry, automobile, textile and electronics manufacturing.4

Chemical hazards are currently a major cause of occupational mortality in the

1 CAS Database Registry: http://www.cas.org/expertise/cascontent/registry/regsys.html (last

accessed 14 April 2008)
2 Copenhagen Chemicals Charter, Chemicals Under The Spotlight, International conference, 27-28
October 2000, Copenhagen
http://www.eeb.org/publication/2000/CCC_from_BEUC_corrected_EL_clean.pdf (last accessed 14
April 2008)
3 International Council of Chemical Associations (ICCA) www.icca-chem.org (last accessed 19
December 2007)
4 Including the disassembly of mobile telephones, computers and other electronic equipment, which
are often sent from industrialized to developing countries for this purpose. Shipbreaking is another
example of the transfer of disassembly to developing countries (e.g. India), with potentially lethal
consequences for the health of those engaged in this type of work.
www.ilo.org/public/english/protection/safework/wdcongrs /intrep.pdf (last accessed 19 December
2007)

11
world.
According to the International Labour Organization (ILO), hazardous substances
kill about 438,000 workers annually, and 10% of all skin cancers are estimated to
be attributable to workplace exposure to hazardous substances.5 Additionaly, the
World Health Organization indicates that approximately 125 million workers
worldwide are exposed to asbestos in the workplace, which results in at least
90,000 deaths every year; the figure is rising annually.6

The ILO further estimates that there are around 270 milion occupational accidents
and 160 million work-related diseases each year among a global workforce of 2.8
billion people. 7 However, no data are available so far on the percentage of
occupational diseases related to chemicals exposure at global level.

The worker handling chemicals is not the only one at risk. Individuals may also be
exposed to chemical risks at home. The environment as well is affected, as
chemicals may pollute the air we breathe, the water we drink, and the food we
eat. They may have reached forests and lakes, destroying wildlife and altering the
ecosystems.

As a result of economic activity, many chemicals are released into the

environment. They are not only generated by the chemical industry
(quantitatively, power generation, and metals and mining industries are larger
sources of pollution), but also by other sectors, for example agriculture, car
manufacturing, construction, energy production, extraction of fossil resources and
minerals, metallurgy, pharmaceuticals, textile or transport, among others.

The environment has been at the receiving end of a wide range of hazardous
substances, which has caused unprecedented environmental degradation. The
challenge has now to be addressed as it is a struggle for the future of the planet,
an issue of survival for other species and quality of life for humans.

One of the root causes of environmental degradation by chemical substances is

the lack of knowledge about the inherent hazardous properties of most chemicals
found on the market and their sound and safe use. It is an appalling fact that
over 99 per cent of the total volume of marketed substances has never
undergone in-depth assessment of their risks to human health and the
environment.8 The direct consequence of this lack of data is that many hazardous
chemicals are not classified as such, and are therefore sold without appropriate
labels or safety data sheets. Thus, many chemicals are used in the workplace
while their potential effects on the health of workers exposed to them and on the
environment are barely known, or known too late.

Chemical risks at work derive both from the intrinsic hazardous properties of
chemicals and from workers’ levels of exposure to these substances, reflecting
the way in which they are used in the workplace. When it comes to safe use of
chemicals at work, the situation varies according to countries, sectors of activity
and company size.

5 International Labour Organization. ILO (2005). “Facts on Safety at Work”

http://www.ilo.org/wcmsp5/groups/public/---dgreports/---
dcomm/documents/publication/wcms_067574.pdf, (last accessed 14 April 2008)
6 “Asbestos Exposure Responsible for 90,000 Deaths Annually”. Asbestos News
http://www.asbestosnews.com/news/asbesos-deaths-annually.html, (last accessed 14 April 2008)
7 International Labour Organization. ILO. 2005. “Facts on Safety at Work”
http://www.ilo.org/wcmsp5/groups/public/---dgreports/---
dcomm/documents/publication/wcms_067574.pdf
8 European Commission (February 2001). “Strategy for a future Chemicals Policy”. White Paper.
COM(2001) final.

12
In industrialized countries, while important improvements still have to be made in
large companies, the main areas for improvement lie in small and medium-sized
enterprises (SMEs), where existing legislation or good practices aimed at
protecting workers’ health and the environment from chemical risks are scarcely
enforced.

In general, the situation in developing countries is particularly alarming. Often

chemicals are used at industrial and agricultural sites with highly toxic active
ingredients, which, although they may have been banned in industrialized
countries, are still marketed in the developing world. Protective equipment is
often not available, and information and training are mostly lacking. Due to less
stringent regulations and, as a consequence, deliberate corporate strategies to
relocate production to countries with lower standards, workers in these countries
are increasingly becoming victims of social, environmental, and health and safety
dumping.

The growth of chemical industries, both in developing and developed countries, is

set to go on increasing this XXIst century. Reorganization of the conventional
chemical industry (the most polluting of all industries) to green or sustainable
chemistry seems a necessity not only in order to decrease the toxic pressure on
humans and other living beings (adverse effects on health and reproduction), but
also to maintain the benefits the chemical industry provides to society through a
variety of services and the millions of jobs it sustains.

The environmentally sound management of toxic chemicals requires proper

management of chemicals from manufacture to disposal (often referred to as
cradle-to-grave or life-cycle management). This means developing a chemistry as
little harmful as possible, based on the application of a series of principles that
help reduce or eliminate the generation of hazardous substances in the design,
manufacturing and use of chemicals:9 for example, using renewable raw materials,
manufacturing non-toxic and biodegradable products, and avoiding waste.

Clean production and green/sustainable chemistry need to be factored in the

discussion as they pave the way to sustainability. These are new concepts that
have to gain importance in research, negotiation, and the production process if
sustainable development is to be attained.

Basic elements for sound and sustainable management of chemicals are:10

(a) adequate legislation;
(b) information gathering and dissemination;
(c) capacity for risk assessment and interpretation;
(d) design of a risk management policy;
(e) capacity for implementation and enforcement;

9 Anastas, P. T.; Warner, J. C. Green Chemistry (1998): Theory and Practice, Oxford University Press:
New York, p.30.
10 Based on Agenda 21: Chapter 19 - Environmentally Sound Management of Toxic Chemicals,
Including Prevention of Illegal International Traffic in Toxic and dangerous products

13
 (f) capacity for rehabilitation of contaminated sites and healing of poisoned
persons;
(g) effective education programmes; and
(h) capacity to respond to emergencies.

Occupational health and environment are two sides of the same coin, since the
measures we adopt to protect workers health will protect the environment and
vice versa. The basic principle of prevention consists in substitution or reduction
to the minimum of the hazardous chemical agents in the workplace. Prevention
and management of hazards, and consequently chemical safety, are essential to
contain and reduce related health and environmental risks.

This publication aims at explaining and assessing the risks of the current model
for the chemical industry, and the need to move towards a new, environmentally-
sound chemistry. With this view, urgent measures have to be taken, particularly
in the workplace, to minimize the significant adverse effects that some chemicals
have on human health and the environment.

14
NOTES:

15
16
 MODULE 1:
INTRODUCTION TO CHEMICALS
MANAGEMENT
Most frequently used chemicals: are some
chemicals better or safer than others?

Spraying mosquito breeding grounds to control malaria, Cameroon

© Mark Edwards / UNEP / Still Pictures

Module aims:

The module aims at:

Providing basic information on hazardous chemicals, their toxicity, including

properties and characteristics, and their effects on human and environmental
health, particularly for workers;
Introducing the concepts and principles of green chemistry;

Learning outcomes:

At the end of the session, the trainee will be familiar with:

the terminology related to sound and sustainable management of chemicals;
the types of effects on human health and the environment, including routes of
entry of chemicals into the body; and
the concept of green chemistry.

17
 Unit 1: WHAT DO WE KNOW ABOUT CHEMICALS?

This unit will mainly address the following questions:

1. What are hazardous substances?

2. What do we know about them?
3. Do we have enough knowledge of their effects?

GETTING TO KNOW BASIC CHEMISTRY11

Chemicals substances are everywhere. All matter (i.e. liquids, solids and gases)
is made of elements. An element is the simplest form of matter that exists. At
present, there are 106 different elements - including oxygen, nitrogen, carbon -
and many other substances composed of atoms.

A single chemical element, standing alone, is a pure substance. When there is a

combination of two or more elements, it is called a compound (for example,
water (H2O)).

At another level, a mixture is the name used to refer to a substance that

contains more than one chemical element or compound, the separate
constituencies of which, still retain their own properties. There are two different
types of mixtures:
• Homogenous mixtures, known as solutions, which involve two or more
substances (the solutes) dissolving into another substance (the solvent)
(for example, salt or sugar dissolving in water, or gold into mercury); and
• Heterogeneous mixtures, known as suspensions, which are mixtures
with definite, circumscribed composition (for example, granite, although a
salad is probably the most typical example of this kind of mixture).

NAME, SURNAME AND “NICKNAME” OF CHEMICALS: HOW DO WE REFER TO

THEM?

There are different ways to refer to and name a chemical. It can appear as the
chemical formula, or it can be brought up by a common name that normally
refers to the elements that make up the chemical compound (for example,
hydrogen sulphide contains elements of hydrogen and sulphur).

It can also be called by its trade name. Producers and manufacturers often
choose to give “trade” or commercial names to chemical compounds or mixtures
to make them easier to remember.

11 Chapter based on IPCS (International programme on chemical safety): Users’ manual for the IPCS
health and safety guides (1996), http://www.inchem.org/documents/hsg/hsg/hsgguide.htm (last
accessed 14 April 2008)

18
There are different international identifications methods:
• The CAS registry number: each chemical is given a unique number by
the Chemical Abstract Service (CAS), a division of the American Chemical
Society. As of April 2008, there were 34,793,507 organic and inorganic
substances, and 59,792,349 sequences in the CAS registry.12
• The RTECS number: is allocated by the Registry of Toxic Effects of
Chemical Substances. It is a database of toxicity information on the health
effects of the chemicals compiled from the open scientific literature.
However, not all toxicity information is free or available.
• Another classification or numbering system involves the use of UN
numbers or UN IDs that are used in the framework of international
transport. They are four-digit numbers that identify dangerous goods,
hazardous substances and articles (such as explosives, gases, flammable
liquids, toxic substances, etc.).13

There are other nomenclature and referencing systems for classifying chemicals,
including the IUPAC which has developed the International Chemical Identifier
(InChI), and the EC-No and EC#, the latter ones being allocated by the
Commission of the European Communities for commercially available chemical
substances within the European Union mainly.

WHAT DO CHEMICALS LOOK LIKE?

PHYSICAL FORMS OR “STATES”

Chemicals are present in different physical forms, with the main ones being:
• Solid. This form is the least likely to cause chemical poisoning. However,
certain chemical solids can cause poisoning if they get onto your skin, or
into food;
• Dust. Dust is made of tiny particles of solids. Exposure can be either from
materials that normally exist in dust form (for example, bags of cement),
or from work processes that create dust (for example, handling glass
fibres that produce toxic dust);
• Liquid. Many hazardous substances, such as acids and solvents, are
liquids when they are at normal temperature;
• Vapour. This is the gas phase of a material that is found as a liquid under
normal conditions. Tiny droplets of liquid which are suspended in the air
are called mists; and
• Gases. Some chemical substances exist as a gas when they are at a
normal temperature. However, some chemicals in liquid or solid form
become gases when they are heated.

12 CAS Database Registry: http://www.cas.org/cgi-bin/cas/regreport.pl (last accessed 14 April 2008)

13 United Nations Economic Commission for Europe (UNECE)
http://www.unece.org/trans/danger/publi/unrec/12_e.html (last accessed 14 April 2008)

19
Other physical forms are aerosols, fumes, smokes, and fogs.

Chemicals can change forms or “states” depending on temperature and pressure.

For instance, water is liquid between 0-100 degrees Celsius (°C). Above 100°C it
is in a gaseous state (steam) and below 0°C it is ice, a solid state.

As a general rule, when the temperature of a solid is increased, it turns into a

liquid (i.e. it melts). If the liquid is further heated, it boils and evaporates,
generating smoke or fumes and turning into vapour or gas. If the surrounding
pressure upon gases is increased without changes in temperature, they move
from a gaseous state to a liquid one.

Substances can change from one physical form to another, depending upon
temperature and pressure. It is crucial to be aware of the possible movement of
chemicals between physical forms due to surrounding and external changes, since
some physical forms have a much greater negative impact than others. A
substance, which might not represent a risk14 in a solid state, for example, can
become hazardous to a worker in a liquid or gaseous form.

PHYSICAL PROCESSES
They refer to the properties that chemicals have and which allows them to change
from one form to another without involving a change in chemical composition.
This happens through the following processes:
• The boiling point, which is the temperature at which a substance
changes from liquid to gaseous state;
• The melting point, which is the temperature at which a substance
changes from a solid to a liquid state;
• The flash point (open or closed cup), which describes the temperature at
which a substance gives off enough vapour to form a mixture with air that
can be ignited –causing it to burn- by a spark or flame;
• The auto-ignition temperature, which is the lowest temperature at
which a substance burns without a spark or flame. To contrast these two
types of properties, the flash point for gasoline (petrol) is <-40°C (-45°F),
whereas for diesel it is at >62°C (143°F); their respective auto-ignition
temperatures are at 246°C (475°F) and 210°C (410°F).

The key physical properties are:

• Solubility in water designates the amount (by weight) of the substance
that can dissolve in one litre of water to form a solution (homogenous
mixture). This property is particularly relevant to possible water pollution
and the potential impacts on aquatic organisms. In other words, high
solubility compounds are normally a greater threat to aquatic organisms
than low solubility compounds because they dissipate more quickly.
• Insolubility often refers to poorly soluble compounds, rather than to non-
soluble compounds. In a stricter sense, there are very few cases where
absolutely no material dissolves.

Other properties to mention are vapour pressure, relative vapour density,

flammability, octanol/water partition coefficient, among others.

14 It is important to distinguish risk from hazard. For a detailed explanation, see “Unit 3: Prevention,
the best antidote to chemical exposure / Assessing hazards, risks and safety: safer handling, what
else?”

20
PHYSICAL HAZARDS
The physico-chemical hazards encountered in the workplace level generally arise
from explosive, flammable, extremely flammable, highly flammable or
oxidizing 15 substances. Often, of course, such substances will also present
health hazards due to their toxicity.

Box 1.1. What are hazardous chemical substances?

A hazardous chemical substance is one that represents a risk for the safety and security
of workers and the environment, due to:
its physicochemical, chemical and toxicological properties;
the form in which it is used (dust, aerosol, liquid…); and
the form in which it is found in the workplace. For example, using water at room
temperature might not be a risk, whereas if it is heated up to a 100°C, contact
with that liquid or vapour could be very dangerous.

Source: IPCS (International programme on chemical safety) (1996). “Users’ manual for the IPCS
health and safety guides” http://www.inchem.org/documents/hsg/hsg/hsgguide.htm (last accessed
14 April 2008)

WHY ARE CHEMICALS TOXIC? HOW TOXIC CAN A SUBSTANCE BE?

WHAT IS TOXICOLOGY?
There is an array of toxic substances, whether manufactured (synthetic)
chemicals like medicines, pesticides and solvents used in the industry, or
substances occurring naturally in the environment.

They have the potential to cause harmful effects on human beings and the
environment, referred to as toxic or adverse effects. Examples of toxic effects
range from headaches, nauseas, vomiting, or irritations, to cancer, alterations of
the reproductive system, or death.

Nature is also capable of producing toxic substances which can also have adverse
effects on human health and the environment: certain types of naturally
occurring gases, or via fungi, viruses, bacteria, plants and animals like certain
species of snakes, fishes or insects, among others. However, the far-reaching
scope of injury caused by naturally produced elements does not come anywhere
close to the devastating effects that some synthetic chemicals can have on
human health and the environment.

15 Strong oxidizing agents are often very reactive chemicals, and, in contact with combustible
material such as paper, sawdust, fabrics or powdered metals, may form unstable mixtures, which
constitute a risk of fire or explosion. A variety of substances can act as oxidizing agents. Oxygen on its
own is a reasonably strong oxidizing agent, but other materials, such as fluorine, metal nitrates,
potassium permanganate, hydrogen peroxide, sodium hypochlorite (bleach), or sodium dichromate
are very effective.

21
 Box 1.2. Types of toxic vectors

There are three types of toxic vectors: chemical, biological, and physical.

• Chemical vectors include inorganic substances such as lead, hydrofluoric acid,

and chlorine gas; organic compounds such as methyl alcohol; most medications;
and poisons from living organisms;
• Biological vectors include those bacteria and viruses that are able to induce
disease in living organisms; and
• Physical vectors include elements that seldom come to mind as being "toxic":
direct blows, concussions, sound and vibration, heat and cold, non-ionizing
electromagnetic radiation such as infrared or visible light, and ionizing radiation
such as X-rays.

This Manual will focus on chemical toxicity.

Source: Health and Protection Agency. Glossary. “Toxic Agent”

http://www.hpa.org.uk/webw/HPAweb&Page&HPAwebAutoListName/Page/1153846673536?p=11538
46673536 (last accessed 14 April 2008)

• Toxicology is the science of adverse effects of chemical substances on

living organisms. Even substances that are essential to our bodies, such as
iron, can be toxic at high doses. Without enough iron, we would develop
anaemia, but too much iron causes liver abnormalities.16
•
Ecotoxicology is part of toxicology, and was defined by Truhaut in 1969,
as "the branch of toxicology concerned with the study of toxic effects,
caused by natural or synthetic pollutants, to the constituents of
ecosystems, animal (including human), vegetable and microbial, in an
integral context”. Throughout the Manual, the term toxicology refers also
to ecotoxicology.17

EXPOSURE TO CHEMICALS
For a chemical to exert an effect, there has first to be exposure. If there is no
contact between a living organism and a chemical, no matter how toxic the
chemical, the organism cannot possibly be harmed.

Occupational exposure is a concern of highest priority to workers as they may

face significant exposure to chemicals in their daily jobs. Workers are at the
frontline of occupational exposure during the different phases of production,
storage, handling, transport, use and disposal of chemicals.

In addition, exposure may also occur in different and multiple ways (air, soil,
water for drinking or irrigation in agriculture, etc.) through contaminated
environments. Contamination can arise when waste are released into the
environment, for example after industrial accidents or during industrial and
agricultural processes. It is thus becoming increasingly obvious that human
health, environmental contamination and chemical exposure are closely
linked.

16 International Occupational Safety and Health Information Centre (CIS), Chemical Safety Training
Modules, What is toxicology?, ILO,
http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/toxic.htm (last accessed
14 April 2008)
17 Truhaut, R, (1977), "Eco-Toxicology - Objectives, Principles and Perspectives", Ecotoxicology and
Environmental Safety, vol. 1, no. 2, pp. 151-173.

22
Although some chemicals are less harmful than others, their combined effects
should be taken into account to assess the level of exposure and the potential
consequences on human health and living organisms. The dose or
concentration is another aspect to consider. For instance, a highly toxic
substance can be extremely harmful even if only very small amounts are present
in the body. Conversely, a substance of low toxicity will normally not produce any
toxic effect unless the amount present in the body is significant.

There is a progression in severity of effects as the dose increases: it is the dose-

effect relationship.

In addition to a chemical’s dose, its toxicity also depends on how long exposure
lasts, also known as the duration of exposure. Single exposure is referred to as
acute exposure, while repeated exposure over a longer time is called chronic
exposure.

Toxicological studies aim at assessing the adverse effects related to the different
doses. To this end, they seek to establish the relationship between a determined
dose and its effects on a variety of living organisms. The next section will
introduce the major toxic effects that chemicals have on human health and the
environment

Box 1.3. Exposure to chemicals: dose-effect relationship

EXPOSURE
TOXICITY Type of exposure
Type of (how?)
substance, Characteristics EFFECTS
Duration
and its of the of the
(how long?)
chemical biological body substance
Dose
and (how much?)
physical Multiple exposure
properties (how often?)

Source: Sustainlabour, 2008

The exposure pathway 18 is an important notion that refers to the route a

substance takes from its source (where the substance is first released) to its end
point (where the substance ends: in the environment, on/inside the body), and
how people come into contact with (or get exposed to) it.
An exposure pathway is defined by five elements:
• A source of contamination (such as factories which were closed down);
• An environmental medium and transport mechanism (such as movement
through groundwater);
• A point of exposure (such as a private well);
• A route of exposure (eating, drinking, breathing, or touching); and
• A receptor population (people potentially or actually exposed).

18 Agency for Toxic Substances and Disease Registry (ATSDR): Definition of exposure pathway,
http://www.atsdr.cdc.gov/glossary.html#G-D- (last accessed 14 April 2008)

23
When all five elements are present, the exposure pathway is termed “completed
exposure pathway”.

WHAT ARE THE TOXIC EFFECTS OF CHEMICALS ON HUMAN HEALTH AND THE
ENVIRONMENT?
Hazardous chemicals are found in the tissues of nearly every person on Earth.
Exposure to chemicals has resulted in several cancers and in a range of
reproductive problems, including birth defects, development disorders and other
diseases. The increasing number of cases and the constant exposure of
individuals to a cocktail of chemicals have raised concern, particularly among
workers.

The terminology referring to the toxic effects of chemicals is complex and

deserves particular attention. The terms “acute” and “chronic”, previously used to
refer to duration of exposure, can also describe how long it takes for the effect
of exposure to a certain chemical to appear, which is also very important data.

Box 1.4. Classification of toxic effects of chemicals: definitions

Acute effect – The term acute means “of rapid onset and short duration” and, with
reference to chemicals, usually means a short exposure with an immediate effect (24
hours or less). While an acute exposure can result in an acute effect, it can also result in
a chronic disease, e.g. permanent brain damage can result from acute exposure to
trialkyl tin compounds or from severe carbon monoxide poisoning;
Chronic effect – The term chronic means “of slow onset and long duration” and usually
refers to repeated exposure with a long delay between the first exposure and the
appearance of adverse health effects;
Acute and chronic effects – A substance may have both an acute and a chronic effect.
For example, a single exposure to high levels of carbon disulfide can result in
unconsciousness (acute effect), but repeated daily exposure for years at much lower
concentrations may result in damage to the central and peripheral nervous system, as
well as to the heart (chronic effects). Another example, percloroethylene, known as the
“universal solvent” for dry cleaning and other uses, can result in acute effects such as
irritation and chronic ones such as cancer;
Reversible (temporary) effect – An effect that disappears if exposure to that chemical
ceases. Contact dermatitis, headaches and nausea from exposure to solvents are
examples of reversible effects;
Irreversible (permanent) effect – An effect that will have a lasting, damaging effect
on the body, even if exposure to the chemical causing that effect ceases. Cancer caused
by exposure to a chemical is an example of an irreversible effect;
Local effect – The harmful effect of a chemical at the point of contact or entry to the
body, e.g. burns to the skin; and
Systemic effect – Occurs after the chemical has been absorbed and distributed from the
entry point to other parts of the body.

It can be caused by a number of chemicals, including lead, beryllium, benzene, cadmium

and mercury compounds.

Source: IPCS (International programme on chemical safety) (1996). “Users’ manual for the IPCS
health and safety guides” http://www.inchem.org/documents/hsg/hsg/hsgguide.htm (last accessed
14 April 2008)

24
Below are listed some of the most toxic effects chemicals can have on humans, as
well as on biological organisms.
• Concentrated solutions of strong acids (sulphuric acid for example), or
alkalis (such as caustic soda), can cause chemical burns to the skin. A
chemical that destroys or damages (burns) living tissue on contact is
corrosive. A splash of a corrosive liquid in the eye, for example, can
result in permanent damage to eyesight.
• When a chemical produces local annoyance, pain or inflammation of the
skin, eyes, nose or lung tissue, it is called an irritant. For instance, a
common substance like hypochlorite, also known as bleach, has a
corrosive and irritant effect when applied to the skin.
• A chemical causing difficulties to breathe by interfering with oxygenation
of body tissues, is an asphyxiant. There are two types of asphyxiation:
simple asphyxiation, whereby oxygen in the air is replaced by a gas to a
level at which it cannot sustain life (lack of oxygen); and chemical
asphyxiation, whereby a direct chemical action interferes with the body's
ability to transport and use oxygen. Examples of chemical asphyxiants
include carbon monoxide and cyanides.

There are a number of reactions and effects caused by exposure to chemicals,

which are highly damaging and irreversible. When these effects occur, the
organism is so severely affected, that it is not possible to restore it into the
original health state in which it was before exposure, thus resulting in a
permanent change to the organism.

For example, chlorpyrifos, which is an insecticide on the market today, is used to

kill insect pests by disrupting their nervous system; it is said to have an
advantage over other products in that it is effective against a wide range of plant-
eating insect pests. However, it has proved to cause immune system
abnormalities to individuals, as well as to animals other than the targeted insect
pests. Such a chemical can have a sensitizing or immunotoxical effect causing
allergic reactions. A person who reacts to a chemical will experience a heightened
reaction to it, even at a very low dose, whereas the chemical will not be harmful
for the majority of individuals at the same dose. Any subsequent exposure to that
substance – whether through skin contact or inhalation - represents a risk to the
health of a person who has been sensitized to it.

Chemicals can also have a carcinogenic effect, meaning they cause cancer.
Cancer is characterized by the manner in which abnormal cells in the body
multiply and spread out of control. The key feature of cancer is the malignant or
deadly way in which its cells crowd out sound/normal cells and interfere with the
normal functioning of the body. For example, benzene, which is still used as a
petrol additive or as an intermediate compound to manufacture other chemicals,
has been classified by the International Agency for Research and Cancer (IARC)
as carcinogen. For the record, one of benzene’s early uses in the 19th and early-
20th centuries was as an after-shave lotion because of its pleasant smell.

25
 Box 1.5. Occupational cancer: the forgotten epidemic!

Little is heard about occupational cancer. At least one in every 10 cancers –and probably
many more- are the result of preventable and predictable workplace exposure.

More people face risks of cancer in the workplace nowadays than at any other time in
history. Regrettably, however, most of them are just not aware of it.

A cautious estimate by ILO puts the human toll from occupational cancer at over 600,000
deaths a year – one death every 52 seconds.

Source: International Metalworkers´ Federation (2007) Occupational Cancer/Zero cancer – A Union

Guide to prevention, http://www.hazards.org/cancer/ (last accessed 19 December 2007)

Additional effects of chemicals include a mutagen effect, which causes

permanent damages to the DNA (deoxyribonucleic acid) in a cell. DNA is a
molecule that carries the genetic information controlling the growth and
functioning of cells. DNA damage in the human egg or sperm may lead to reduced
fertility, spontaneous abortion (miscarriage), birth defects and genetic diseases.
As many mutations cause cancer, mutagens are typically also carcinogens.

Because some chemicals can adversely affect the reproductive capacity of women
and men, and the un-born generations, they are said toxic to reproduction.
They affect all phases of the reproductive cycle, as adverse effects on the
developing organism can result from exposure before conception (either parent),
during pregnancy, or between birth and the time of sexual maturation. Toluene
belongs to that category; though, this product is largely used, especially as a
common solvent to dissolve paints, paint thinners, chemical reactants, rubber,
printing ink, adhesives and glues, lacquers, leather tanners, and disinfectants.

Endocrine disrupters are chemicals that alter functions of the hormonal system,
consequently causing adverse health effects in women and men, and their
descendents. The possible health effects include breast and prostate cancer,
reduction of sperm quality, and modified hormone levels. The children of exposed
women can suffer from precocious puberty, vaginal cancer, deformation of
reproductive organs, among other serious problems.

There is growing scientific consensus that numerous industrial and agricultural

chemicals have the ability to interfere with endocrine systems and hormonal
activities of all animals including fish. One of the best-known effects is the
feminizing of male fish. Some examples of substances known or suspected to be
endocrine disrupting chemicals (EDCs) are pesticides as atrazine, 2,4-D, DDE,
DDT, diazinon, diuron, endosulfan, fenthrothion, glyphosate, lindane, or industrial
chemicals or breakdown products such as bisphenol A, dioxins, nonylphenol, PCBs,
some phthalates.19

19 Briefing note on Fish and Endocrine Disrupters, WWF, (1998)

http://www.ngo.grida.no/wwfneap/Publication/briefings/Fish.pdf (last accessed 19 December 2007)

26
These effects may appear at extremelly low doses, generally below legally
established limits of exposure. Another example involves bisphenol A, which is
used to make plastic bottles and many other plastic products. Apart from its
impact on workers, it has also proven to cause sex reversals in animals like the
broad-snouted caiman - an alligator native to South America - and has also
caused reproductive malformations in quail and chicken embryos. This substance
is both toxic to reproduction and an endocrine disrupter.

Some chemicals can have adverse effects on the structure and function of, both
the central nervous systems (brain and spinal cord) and peripheral nervous
system, causing muscular weakness, a loss of sensation and motor control,
tremors, cognitive alterations, and a dysfunction of the autonomic nervous
system. These types of chemical are known as neurotoxics.

TPB is an acronym which refers to substances that are:

• “T”oxic for mammals and aquatic organisms;
• “P”ersistent, given that they remain in the environment for long periods
of time, degrading very slowly; and
• “B”io-accumulative as they tend to accumulate in the body tissues of
living organisms. For example, pesticides like aldrin, dieldrin and mirex.

COCKTAIL OF CHEMICALS: MULTIPLE EXPOSURE AND COMBUNED EFFECTS

Workers seldom use a single chemical in their daily jobs. Most times, they
manipulate or are surrounded by two ore more chemicals, to which they might be
exposed via dermal contact (through the skin), inhalation (through the
respiratory tract, including the lungs) or ingestion (through the mouth).
In the same way, in their normal environment individuals are seldom exposed to
a single substance. When two or more chemicals are in presence, they may
interact with each other, which can alter the resulting toxicity. However, the
resulting effect of chemical interactions can take different forms. Basically, the
four types of combined effects chemicals that can have are:
• Independent: when the chemicals taken individually produce different
effects or have different modes of action, and do not interfere with each
other;
• Additive: when the combined effect is equal to the sum of the effects of
each agent taken alone. For instance, organophosphate pesticides, such as
dialiphos, naled and parathion are usually additive. Numerically it could be
represented as 1+1=2;
• Synergistic: when the toxic effect resulting from the interaction is greater
than the sum of individual effects. An example of increased risk is
asbestos fibres combined with cigarette smoking: the risk of developing
lung cancer after exposure to asbestos fibres is forty times greater for a
smoker than for a non smoker. Numerically it could be represented as
1+1=4; and
• Antagonistic: when the respective effects of two or more substances
neutralize one another (e.g. the way an antidote reacts to a poison).
However, this type of interaction does not happen very frequently. For
example, if dimercaprol binds with various elements such as arsenic,
mercury and lead, the toxic effect will be less than what could be expected
for dimercaprol alone. Numerically it could be represented as 3-2=1.

There is not much information available that can help predict the likely effects of

27
the potential interactions between hazardous chemicals. To be safe, or at least
safer, chemical cocktails should be avoided or reduced to the lowest possible
level.

Avoid mixing several chemicals. The combination may result in

very dangerous effects.

DIFFERING REACTIONS: HYPER-SUSCEPTIBLE GROUPS

Each individual responds in a specific way to a chemical. Exposure to the same
dose over a similar time period will thus induce different responses among
different people. This principle also applies to all life on Earth.

In the workplace, workers exposed to similar concentrations of the same chemical,

at the same worksite, will not necessarily exhibit the same symptoms. There may
be various reasons to that, including:
• Gender: women, because of a greater relative proportion of body fat, may
be more susceptible than men to harmful effects of solvents which
accumulate in fat tissues, for instance;
• Age: children and the elderly are generally more susceptible to chemical
hazards;
• Race: certain races may be genetically more vulnerable to certain chemical
exposures;
• Lifestyle factors and nutritional situations may also have a considerable
effect on the action of some compounds; and/or
• Individual variations: different individuals with similar characteristics such
as gender, age, etc. may have different sensitivities.

Box 1.6. What is the “healthy worker effect”?

Occupational groups very often have lower total mortality than the general population as
the latter includes people unable to work due to illness or disability. In other words, any
group of workers is likely to be healthier than the population as a whole, a phenomenon
known as the “healthy worker effect”.

Source: ILO (1998). Encyclopaedia of occupational health and safety

http://www.lhc.org.uk/members/pubs/books/chem/chedeaaa.htm (last accessed 19 December
2007)

HOW IS CHEMICAL TOXICITY DETERMINED?

There are two main sources of information on health effects resulting from
exposure to chemicals. The more frequently used source consists of toxicity
studies on laboratory animals. The second source consists of studies on human
populations.

Laboratory animals are those that undergo tests to measure the toxicity of a
chemical before people and animals are widely exposed to it. Different animal
studies can be undertaken. Acute toxicity test (short-term) gives, for example,
the LD50 (lethal dose) and LC50 (lethal concentration) indices of toxicity,
which are two widely used indicators for toxicity.

28
LD50 (lethal dose) refers to the amount of the substance that kills 50% of the test
population of experimental animals when administered as a single dose. The LD50
is usually expressed as the mass of substance administered per unit of mass of
the subject, such as grams of substance per kilogram of body mass. LC50 (lethal
concentration), used for inhalation experiments, is the concentration of the
chemical in air that kills 50% of the test animals in a given time (usually four
hours).

In general, the smaller the value, the more toxic the chemical. The opposite
is also true: the larger the value, the lower the toxicity. It is also important to
know that the actual LC50 value may be different for a given chemical
depending on the route of exposure (dermal, oral, or respiratory).

For example, if the LC50 value for a dermal route of exposure rates a chemical as
extremely toxic, then the skin should be protected when handling it, using
clothing, gloves, etc. made of an appropriate chemical-resistant material.
Alternatively, if the LC50 value for a respiratory route of exposure that indicates
the chemical is relatively harmless, then respiratory protective equipment may
not be necessary (as long as the oxygen concentration in the air is in the normal
range - around 18%).

To compare the toxic potency or intensity of different chemicals, researchers

must measure a common parameter. One way is to carry out lethality tests (the
LD50 tests) by measuring how much of a chemical is required to cause death.
They are very crude indices of toxicity, which give a very rough or gross figure,
and are undertaken in order to compare the lethal toxicity of different chemicals.
These tests do not give adequate data on carcinogenicity, teratogenicity or
reprotoxicity.

Many national and international bodies are now trying to modify or replace the
LD50 and LC50 tests by simpler methods, such as the fixed-dose procedure, as
fewer animals are involved. This requires only a small number of animals, and
analysts can evaluate a chemical’s toxicity without animals dying as the ultimate
result.

Civil society groups have campaigned against LD50 testing on animals, in

particular to protest against the use of these substances, which result in the
slow and painful death of animals. Several countries, like the UK, have taken
steps to ban the oral toxicity LD50 testing, and the Organization for Economic
Cooperation and Development (OECD) abolished the requirement for the oral
test in 2001.

The lowest dose that causes a toxic effect (TDLO), or the Lethal Dose Low
(LDLo) are other sources of toxicity information. There are other animal studies
undertaken on mutagenicity, reproductive tests, to name but a few examples.

Conclusions related to chemicals toxicity are not all based on laboratory tests.
Human evidence is also a very important source of information, especially in the
case of hazards and effects in the workplace (occupational health), where most
information come from reviewing specific cases and situations.
Epidemiological studies are another important source of information, basing
investigations on the health of a group of people to establish whether they are
affected by the chemical to which they are exposed at work or via the

29
environment.

Although epidemiological investigations provide the most reliable proof of the

adverse effect of a given chemical, it also has obvious disadvantages. Few
chemicals have been submitted to epidemiological investigations because these
analyses are very expensive compared to other tests. In addition, validation of
the results requires a large number of exposed workers, and above all, it does not
really act as a prevention measure: many people would have already been
exposed and suffered illness or death before the investigations could happen.

Another important concept is threshold dose or threshold concentration,

which refers to the minimum dose required to produce detectable responses in a
given group of population, for example workers. The no-observed-effect-level
(NOEL) refers to the greatest dose of a chemical, which causes no detectable
health effect. And the lowest-observed-effect-level (LOEL) refers to the
lowest dose of a substance which causes a detectable health effect.

IS THERE A TOLERABLE TOXICITY LIMIT?

The question of trying to establish a threshold based on the toxicity of the
substance is used as the basis to estimate other indicators, as for example, the
tolerable daily intake (TDI), which is the daily intake of a chemical
contaminant over a lifetime without appreciable health risk.

However, it is impossible to examine every situation that might lead to toxic

effects, and therefore potential effects may be missed. Whether there is a
threshold dose, below which there is no toxic effect or an acceptable exposure
dose, is very controversial because of the nature of the indicators.

To be able to handle and benefit from the properties of a chemical safely, i.e. in a
way and at doses which ensure that overall exposure of people and/or other
organisms is kept below defined and tolerable limits, it is fundamental to know
how poisonous or toxic it is.

However, the notion of “tolerable” limit is not a fixed standard. The perception of
what is “tolerable” is clearly influenced by economic, environmental, social and
political factors. In particular, it is closely linked to the probability of occurrence
of several factors - including suffering, injuries or disease - and social acceptance
of associated risks in comparison to expected benefits arising from the direct use
of a chemical or as part of a productive process.

It is important to be familiar with the systems of classification of toxicology, as

they are the basis for determining occupational limit values. However, the limit
values might vary from one country to another.20 In deciding what constitutes a
tolerable exposure, it seems necessary to establish principles or guidelines for
action. For example, it may be prudent and necessary to demand the elimination
of certain substances from the workplace if they can significantly damage human
health or the environment.

! The “black-list” of substances for which elimination is a priority for trade

unions includes carcinogenics, mutagens, reprotoxic agents, endocrine
disrupters, sensitizers, neurotoxics, and toxic, persistent and bio-

20 BGIA GESTIS International limit values for chemical agents, (2008)

http://www.hvbg.de/e/bia/gestis/limit_values/index.html (last accessed 14 April 2007)

30
 accumulative substances (TPB). For these chemicals, trade unions advocate
No tolerance! Exposure should be zero.

Box 1.7. The case of aldrin

This was a pesticide largely used in the 1950s, to kill soil insects such as termites and
grasshoppers in order to protect crops such as corn and potatoes. However, it has proven
to be a persistent organic pollutant (POP) with carcinogenic and mutagenic effects. As
early as the 1970s, it was severely restricted and banned in several countries, and in
2004 the parties to the global Stockholm Convention on Persistent Organic Pollutants
agreed to eliminate its production, use and release.

Source: IPCS International Programme on Chemical Safety, Health and Safety (1989). “Aldrin and
Dieldrin Health and Safety Guide”. Guide No. 21,
http://www.inchem.org/documents/hsg/hsg/hsg021.htm (last accessed 17 December 2007) and
Stockholm Convention on Persistent Organic Pollutants http://www.pops.int/

Safe use of chemicals in the workplace implies:

• Availability of information:
It is important that toxicological information through testing methods be
made available, as the toxicity and effects on human health and the
environment of many substances that are already commercialized are still
unknown. It is important to remember that absence of evidence of risk is
not the same thing as evidence of absence of risk. With precaution as a
guiding principle, it is logical to demand “zero tolerance” for substances whose
effects are not yet known. This is valid for new substances as well as existing
ones which are already on the market.

• Promoting a culture of prevention:

Understanding toxicological information is very important for workers’ safety
as users. It is important to be familiar with the systems of classification of
toxicology, as they constitute the basis for determining occupational limit
values, and therefore building a precautionary approach to the use of
chemicals in the workplace.
However, in addition to a lack of toxicological information for many
substances, the toxicological results sometimes lead to different
interpretations from one legal source to another. For example, formaldehyde,
which is used as solvent and adhesive, is classified by the International
Agency for Research on Cancer (IARC) in Group 1, which means “the agent
(mixture), is carcinogenic to humans”, while the European Union considers it
to be part of Category 3 in its classification, which includes substances with
possible carcinogenic effects to humans, but for which insufficient information
is available to make a satisfactory assessment.
Therefore, prevention must always be the leading strategy. In decisions
relating to chemical safety, the toxicity of a substance is less important than
the risk associated with its use. It is fundamental to adopt prevention and
control policies of hazards in the workplace. As part of that effort, the
promotion of a safety culture should take into account the common belief that
all accidents can be prevented.

In the next chapter titled Safe Use of Chemicals in the Workplace, elimination
is the main objective. Yet, whenever possible - which is often the case -
prevention measures need to be implemented. Prevention measures should

31
 focus first on the cause of emission:
1. Priority 1 - Eliminate risks: ensure less risky situations, through
changes in the productive process or substitution of dangerous
substances;
2. Priority 2 - Reduce and control risks by adopting measures at the
source of the exposure such as isolation, aspiration, ventilation
systems, and other actions; and
3. Priority 3 – Workers’ protection, in case the risks are not fully
eliminated, or properly reduced and controlled (as per priorities 1 and
2): the worker will be provided with individual protective equipment.

It is worth noting that some cases may require a combination of the three
prevention measures above-mentioned.
When all these prevention measures cannot be taken, and the risk is not fully
eliminated or at a minimally acceptable degree, technical evaluations in the
form of tests to workers and the workplace environment are undertaken to
compare the actual exposure in the workplace with threshold limit values
(TLV).
Where TLV are exceeded, corrective measures should be demanded. TLV are
thus good tools for practical action. However, exposure below the TLV does
not fully guarantee safety, and prevention measures still need to be
implemented. The preferred strategy should be first and foremost that of
anticipating and preventing the release rather than relying on an after-the-
fact approach based on remediation and treatment.

• Calling for a proper regulation of chemicals:

Often decisions are made by national authorities based only on scientific data
or on the interests of specific economic groups. Stakeholders are not involved,
while some of them, like workers and trade unions, are at the frontline of
chemical exposure, and should thus have a real say on regulation of chemicals.
Given the severe risks associated with chemical contamination, channels need
to be created to guarantee the participation of workers and trade unions, in
decision making processes, as a democratic principle. It is essential that
workers and trade unions, as well as stakeholders in general, develop and
strengthen capacity to influence debates on critical chemicals-related issues,
including on the definition of what constitutes an injury or an adverse effect,
of what is socially and environmentally acceptable or not.

More information about the chemical regulatory frameworks is provided in the

third module of this Manual.

32
Box 1.8. Asbestos: the world’s biggest industrial killer ever!

Workers and trade unions, have been long struggling to raise awareness on the risks and
effects posed by the use of asbestos. Used massively as a natural mineral fibre in
construction to insulate materials, in protective carpets and clothes due to its heat,
electrical and chemical resistance. Asbestos has caused hundreds of thousands of deaths
and illnesses, mainly among workers who handle it.

In June 2005, Global Unions launched its campaign for a “world ban of asbestos” at the
ILO conference. However, despite the evidence, the vast amount of information available
concerning deaths due to asbestos (at least 100,000 people in the world every year- one
person every five minutes), and the resulting costs to society, it is still being used in
some countries.

In recognition of these effects, asbestos bans are spreading, despite the offensive by the
asbestos industry.

Source: Based on Hazards Magazine. Section Asbestos http://www.hazards.org/asbestos/

33
 Unit 2: PAINFUL, DEADLY ENCOUNTERS WITH POISONS

This unit will address the following questions:

1. What are the effects of hazardous chemicals on human health? How does
the body process them?
2. What are the effects of hazardous chemicals on the environment? How
does the environment process them?

WORKERS AND HAZARDOUS SUBSTANCES: A PERILOUS RELATIONSHIP!

ROUTES OF EXPOSURE
Chemicals can enter the human body and other living organisms through a
number of different pathways, known as “routes of exposure”; each pathway
may react differently to the toxicity of a chemical. The type of route of exposure
is thus critically important in determining how harmful a chemical can be.

The four major routes of exposure are: penetration through the skin or dermal
absorption, through the respiratory tract and especially the lungs or by
inhalation, through the digestive tract or by ingestion, and through the eyes.

The most common forms of occupational exposure are the inhalation of gases,
vapours or airborne particles resulting in penetration through the lungs, and
dermal contact, especially with liquids, which can be easily absorbed through the
skin. The ingestion of poisons is common where general hygiene conditions are
poor.

• Inhalation: respiratory tract, lungs

The lung is a common route of exposure. Unlike the skin, lung tissue is not a
very protective barrier against chemical exposure. In industry, inhalation is
the most significant route of exposure.
The substances irritate the mucous membrane of the upper respiratory tract
and respiratory passages within the lungs. Thus, the occurrence of
irritation may indicate the presence of toxic chemicals. However,
certain gases or vapours do not induce any irritation and, when unnoticed,
penetrate deeply into the body through the lungs where they may cause
injuries, or even reach the bloodstream.
The entry of dust particles into the body depends on their size and solubility.
The bigger they are, the more difficult it is for them to penetrate.

! Exercise extreme caution with chemicals in the form of vapour,

fumes, dust or gas, as they can easily enter the body through
breathing.

34
• Dermal absorption: skin contact
Chemicals that pass through the skin are nearly always in a liquid form.
Dusts, gases or vapours do not generally pass through the skin unless they
are first dissolved in moisture at the surface of the skin. Chemicals that can
dissolve easily in fats (lipids) are much more likely to penetrate the skin than
chemicals that are soluble in water.
However, gaseous and solid chemicals can also pass through the skin: for
example, highly toxic gases such as sarin and parathion, penetrate the skin
without causing overt damage. If the skin is damaged by cuts or abrasions, or
diseased, chemicals (including in a solid form) may penetrate easily and even
more quickly into the body.

• Ingestion: digestive tract, mouth

Ingestion is another way in which chemical substances can enter the body.
Eating at the workstation, where food and drink may be contaminated by
vapours in the air, or smoking with contaminated hands, should be strictly
prohibited. Besides, chemical substances can be ingested when inhaling
particles through the throat, since they can be swallowed and pass both into
the digestive system and the lungs.

! Watch out while eating and drinking at your workstation! You

may be introducing hazardous chemicals into your digestive
system, because the substance may be coating the food or
eating utensils.

• Absorption through the eyes

Any chemical, in the form of a liquid, dust, vapour, gas, aerosol or mist can
enter the eyes. It is common to incur eye splashes or eye contamination due
to exposure to chemicals in the workplace. Small amounts of chemicals can
enter the eye by dissolving in the liquid surrounding the eye. The eyes are
richly supplied with blood vessels, into which many chemicals can pass after
penetrating the outer tissues. The eye may be damaged in the process,
depending on whether the chemical is corrosive or not.

The different mucous membranes in the body – in the mouth, gastrointestinal

tract, nose, vagina, etc. – can also be easy ways for the chemicals to enter the
body.

HOW ARE CHEMICALS PROCESSED WITHIN THE BODY?

When a chemical enters the human body or any living organism, it goes through
different processes. It is transported into different parts of the body where it
can be metabolized (transformed), accumulated (stored) and/or excreted
(expelled).
• Metabolizing is the process by which the body renders an alien chemical
more easily extractable and/or less toxic. For most chemicals, the liver is
the main site of transformation, but other organs such as the kidneys are
also capable of metabolizing chemicals, sometimes into a resulting product
that is also toxic.
• Excretion is the process by which unwanted chemicals are removed from

35
 the body, for example, by exiting through urine. However, these
substances may cause damage to internal organs prior to excretion.

Chemicals that undergo a slow metabolism or excretion are often stored in

various tissues inside the body. Sustained exposure may increase the amount of
chemical present in tissues. Chemicals that are stored in this way are said to
accumulate.

ADVERSE EFFECTS OF CHEMICALS ON HUMANS

The toxic effect of hazardous substances is not the same in all organs.

“A local effect refers to an adverse health effect that takes place at the point or
area of contact. The site may be skin, mucous membranes, the respiratory tract,
gastrointestinal system, eyes, etc.

Systemic effect refers to an adverse health effect that takes place at a location
distant from the body’s initial point of contact and presupposes absorption has
taken place. Substances with systemic effects often have “target organs” in which
they accumulate and exert their toxic effect.”21

The central nervous system is the target organ of toxicity most frequently
involved in systemic effects. The blood circulation system, liver, kidneys, lungs
and skin follow in frequency of systemic effects. Muscle and bones are target
organs for a few substances, causing for example degenerative osteoarthritis,
osteoporosis.
• Skin is the largest organ in the human body. It provides a protective
cover to the body but can fail to do so if the toxic load is overwhelming. A
number of substances can penetrate healthy intact skins and pass into the
blood stream. Phenol is a substance that can ultimately result in death
after exposure and penetration through the skin. The vast majority of
work-related skin diseases are contact eczemas, irritation and
inflammation. This condition can be either a non-allergic or allergic
reaction to chemical substances. Examples of common contact sensitizers
are several colorants and dyes, metals such as nickel and its salts,
chromium and cobalt salts, organomercuric compounds, the monomers of
a number of acrylates and methacrylates, rubber additives and pesticides.
In practice chemical skin injury is also influenced by environmental factors
such as humidity and heat;
• Lungs are the major routes through which toxic substances found in the
workplace enter the body. It is also the first organ to be affected by dusts,
metal fumes, solvent vapours and corrosive gases. Allergic reactions may
be caused by substances such as cotton dust, TDI (toluene disocyanate,
used in the manufacture of polyurethane plastics), and MIC
(methylisocyanate, used in the production of carbaryl insecticide).
Exposure to silica (quartz) or asbestos dust cause pneumoconiosis or lung
cancer. 22 Other substances, such as formaldehyde, sulphur dioxide,
nitrogen oxides and acid mists may cause irritation and reduce the
breathing capacity;

21 Chem Safe: Local vs Systemic Health Effects

http://learn.caim.yale.edu/chemsafe/references/localvs.html
22 Respiratory diseases from exposure to asbestos include asbestosis, lung cancer and mesothelioma.

36
 • The nervous system is sensitive to the hazardous effects of organic
solvents. Some metals can affect the nervous system, especially heavy
metals such as lead, mercury and manganese. Organophosphate
insecticides such as malathion and parathion interfere severely with the
transmission of information in the nervous system, leading to muscular
weakness, paralysis or sometimes death. Because it is the nervous
system, almost any of the many functions it controls can be inhibited by
neurotoxicants - speech, sight, memory, muscle strength and coordination
for example;
• The circulatory system is a target for solvents. Blood cells are mainly
produced in the bone marrow. For example, when benzene affects the
bone marrow, the first signs are mutations in the blood cells called
lymphocytes. Lead and its compounds are other classic examples of
chemicals toxic to the blood system. Chronic lead poisoning may result in
reduced ability of the blood to distribute oxygen through the body, a
condition known as anaemia;
• The liver is the largest of all internal organs and has several important
functions. It is the body’s “purification plant” which breaks down
substances unwanted in the blood. As the liver shows a considerable
reserve capacity, symptoms of liver disorder appear only in serious
diseases. Solvents such as carbon tetrachloride, chloroform and vinyl
chloride, as well as alcohol, are hazardous to the liver;
• The kidneys are part of the body’s urinary system. Their main function is
to excrete the waste products transported by the blood from various
organs and ensuring that body fluids contain an adequate blend of various
vital salts. They also maintain the acidity of the blood at a constant level.
Solvents may irritate and impair kidneys’ function. Carbon tetrachloride is
the most hazardous to the kidneys. Turpentine in large quantities can also
prove harmful: “painter's kidney” is a well-known condition related to
occupational exposure. Lead and cadmium are also common kidney-
damaging substances; and
• The immune system is a highly sophisticated defense system that
protects the body from invading organisms, tumour cells and external
agents. Immunotoxicants can have three different effects on the immune
system: they can suppress the immune system; make it hypersensitive,
which causes allergies; or they can cause the immune system to attack its
host, which is known as autoimmunity.

As indicated in the previous section, exposure to hazardous substances can also

affect the male and female reproductive systems as well as have a genetic
impact, raising the possibility of transmission to descendents.

ENVIRONMENT AND HAZARDOUS SUBSTANCES: MORE THAN JUST A DIFFICULT

RELATIONSHIP

ORIGIN OF CHEMICAL POLLUTION OF THE ENVIRONMENT23

Hazardous manufactured chemicals are released from the workplace into the
environment in the form of liquids, dust, fumes or gas. They can be planned (part
of the production process) or unplanned releases (industrial accidents and
leakages).

23 Ramon Mestres (2006). Hacia una producción química sostenible. University of Valencia

37
 The planned release of chemical substances into the environment can be in the
form of:
• Waste: the leftovers of dangerous products, their containers and any
material contaminated used in the productive process (cloths, gloves,
sawdust, etc.) that are either placed in dumps, treated in specialized
plants or burned in incinerators. Waste can be also in the form of:
Emissions released into the environment through chimneys,
systems of extraction or ventilation and windows; and
Spillage through drainages and pipes.
• Manufactured goods: During their intended use, manufactured goods
may release chemicals into the environment. At the same time, many
chemical substances free themselves to the environment as finished
products while used by the consumers. These include products like paint,
plastics, cosmetics, electrical appliances and electronics, as well as
exhaust fumes from motor vehicles.

These chemicals, once released, will eventually interact with air, soil and water.

As a result of economic activity, many chemicals are released into the

environment. They are not only generated by the chemical industry, but also by
other sectors which contribute significantly, for example agriculture, car
manufacturing, construction, energy production, extraction of fossil resources and
minerals, metallurgy, pharmaceuticals, textile or transport, among others.

Box 1.9. Origin of chemical contamination

ENVIRONMENT: Media (air, soil, water) and Living Organisms (animals, plants)

Energy and Chemical Activities that use

Transport industry Metallurgy /
synthetic products Industrial metals

Exploration, Metals and

Production and Renewable Resources Mining
Refining

Beneath the Earth’s surface

Mineral Resources
Fossil Resources
(coal, gas, oil)

Source: Ramon Mestres (2006). Hacia una producción química sostenible. University of Valencia

38
ADVERSE EFFECTS ON THE ENVIRONMENT
Some chemical pollutants affect the air, surface water, groundwater, soil or
sediments, more than others. Different species will react to the same chemical in
different ways and to a different degree. However, aquatic life has been proven to
be the most vulnerable medium, where most effects first appear. However, what
is highly toxic to aquatic life may not be toxic to birds. Similarly, some substances
have a greater impact on other living organisms than on humans.

Rather than focusing on defining and analysing the specific characteristics of air,
soil and water contamination, the list below presents briefly different types of
exposure of human beings and other living organisms to polluted environments:
• By breathing polluted air. The World Health Organization estimates that
4.6 million people die each year from causes directly attributable to air
pollution. Many of these deaths are attributable to indoor air pollution.24 In
addition, polluted air makes the process of photosynthesis from plants
more difficult;

Box 1.10. A tragic story: the 1984 Bhopal Disaster

On the night of 2 December 1984, over 35 tons of toxic gases leaked from a pesticide
plant in Bhopal owned by the US-based multinational Union Carbide Corporation (UCC)'s
Indian affiliate Union Carbide India Limited (UCIL).

In the next 2-3 days more than 7,000 people died and many more were injured. Over the
last 21 years, at least 15,000 more people have died from illnesses related to gas
exposure. Today more than 100,000 people continue to suffer chronic and debilitating
illnesses for which treatment is largely ineffective.

Source: Amnesty International USA. “DOW Chemical Company (DOW), Union Carbide Corporation and
the Bhopal Communities in India” http://www.amnestyusa.org/Business-and-Human-Rights/Dow-
Chemical/page.do?id=1101668&n1=3&n2=26&n3=1241 (last accessed 14 April 2008)

• By eating plants grown on contaminated soils. These chemicals can cause

changes in the composition of the soil (i.e. alkalinity or acidity of soil pH),
which affects living organisms and possibly the whole ecosystem; and
• By drinking and using contaminated water from lakes, rivers, oceans, and
groundwater.

24 WHO Member State (2002). Estimated deaths & DALYs attributable to selected environmental risk
factors http://www.who.int/entity/quantifying_ehimpacts/countryprofilesebd.xls (last accessed 19
December 2007)

39
 Box 1.11. A tragic story in Africa, today

More than 50,000 tonnes of obsolete pesticides have been stockpiled in Africa
contaminating tens of thousands of tonnes of soil. While more than 11 million cases of
pesticide poisoning occur annually in Africa, few African countries have specialized centres
to deal with it. However, the new multi-stakeholder Africa Stockpiles Programme
(www.africastockpiles.org) is taking action to clean up obsolete pesticides across Africa
and to help prevent reaccumulations.

In addition, the extension of agriculture and corporate marketing have contributed to

increased use of agricultural chemicals. In many places, small farmers have abandoned
traditional and more environmentally-friendly practices under pressure to engage in the
market, to produce improved crops and to increase yields.

In Africa, despite the poor levels of comparable data over the last five decades, trends
indicate an increase in the concentration of nitrates and phosphates at river mouths.

Source: Monosson, Emily. UNEP (2007) “Chemicals use in Africa: opportunities and risks”.
Encyclopaedia of Earth
http://www.eoearth.org/article/Chemical_use_in_Africa:_opportunities_and_risks (last accessed 19
December 2007)

Animals and plants are exposed to chemicals through their functions in the food
chain. Each successive step up the food chain causes a stepwise concentration of
pollutants, for example in the case of heavy metals (e.g. mercury) or persistent
organic pollutants (e.g. DDT, aldrin). This mechanism is known as
biomagnification or bioaccumulation. For example, a substance found at a
certain concentration in plankton will be at a higher concentration in small fish
that eat the plankton, higher still in big fish that eat small fish, and higher still in
bears or seals that eat big fish.

Box 1.12. Ecosystems

An ecosystem is a natural unit consisting of all plants, animals and microorganisms

functioning in a defined area, together with all the non-living physical features of the
environment.

Sometimes when chemical accidents occur, major attention is focused on the largest
animals, yet all species, as well as humans, have a key role to play in the
functioning of the ecosystem.

Source: World Institute For Conservation & Environment (Wice). “Nature Worldwide: Ecosystems,
The Ecosystem concept” http://www.ecosystems.ws/the_concept.htm

GLOBAL ENVIRONMENTAL IMPACTS OF CHEMICALS

The following pollution mechanisms and situations are among the most far
reaching. They are both interlinked with one another and unleashed to other
mechanisms.

Chemicals released as smoke and dust from factory chimneys will eventually fall
to the earth’s surface as dust or in the rain. For example, the effects of sulphur
and nitrogen oxides released in industrial areas have contributed to acid rain.
These substances are emitted into the atmosphere, where they undergo chemical
transformations, and are absorbed by water droplets in clouds. The droplets then

40
fall on earth as rain, snow, mist, dry dust, hail, or sleet, even far from the
countries where they were emitted. This phenomenon is called acid rain because
it increases the acidity of the soil, and thus affects the chemical balance of lakes
and streams, with a significant impact on the entire ecosystem.

The Earth’s atmosphere has different layers. One of them is the ozone layer,
which contains relatively high concentrations of ozone (O3), a molecule that is
continuously produced and destroyed through natural processes. The ozone layer
plays an extremely important role in absorbing the biologically harmful part of the
ultraviolet rays that come from the sun. However, the release of
chlorofluorocarbons (CFCs) which were widely used as refrigerants, propellants,
plastic from blowers and cleaning agents for electronic circuitry has caused a big
reduction in the ozone concentration, known as ozone depletion. Awareness of
the problem was reflected in the signature/ratification of the Montreal Protocol in
1987; the measures taken under this agreement have enabled significant
improvements in the situation, but there is a still a long way to go.

Climate change, also called global warming in mainstream media, receives a lot
of attention and news, as one of the major challenges humanity will have to face
during this century, with impacts set to be critical: a rise in sea level, increased
desertification, and melting of glaciers, among others. Initially, climate change is
a natural cyclical phenomenon; yet it has been seriously and adversely altered by
human activities, most specifically these involving anthropogenic emissions (i.e.
caused by human activities) of the so-called greenhouse gases (GHG). The use
of fossil fuels for transport and power generation (vital to both the economy and
households) are the main contributors to GHG emissions. Other factors, including
land use, deforestation, or the above-mentioned ozone depletion also contribute
to climate change.

As this brief review shows, the environment is on the receiving end of a wide
range of hazardous substances. Therefore the promotion of different and
sustainable chemistry is needed, as it is a struggle for the future of the planet,
the quality of life for humankind and the survival of other species.

PROCESSING OF CHEMICALS IN THE ENVIRONMENT

There are numerous differing views regarding the capacity ecosystems have to
confront and react towards hazardous chemical substances. Therefore, the
question is, how are they processed in the environment? Depending on a number
of complex factors, four strategies in particular can help answer that question.

The environment has a given capacity to biodegrade toxic substances, enabling

them to be broken down and to decompose. However, some substances are
resistant to decomposition processes. Specific ecosystems can adapt or
deteriorate which, after several changes, might lead to varying levels of loss of
diversity, including loss of variety and complexity. Extinction of a species or
group of species could be the last and most catastrophic step that would
contribute to reduced biodiversity. A species is declared “extinct” when the last
individual that belongs to it dies, although the capacity to breed and recover may
have been lost long before that point.

41
 Unit 3: PREVENTION, THE BEST ANTIDOTE TO CHEMICAL
EXPOSURE

This unit will address the following questions:

1. How do we assess hazards and risks?

2. How do we ensure safe handling?

There are no safe chemicals!

ASSESSING HAZARDS, RISKS AND SAFETY: SAFER HANDLING, WHAT ELSE?

A historical review of chemicals would highlight a set of positive applications and

benefits such as medicine, solutions for plague control, detergents, cosmetics,
food additives and preservatives, as well as processes in the textile and electronic
industries or in the construction sector for example. These benefits arose from
the development of chemistry as a scientific discipline, and from the production of
chemicals and synthetic materials on an industrial scale.

However, according to ILO, the recent average number of deaths attributable to

occupational exposure to hazardous substances is estimated at approximately
440,000 a year (or 20 per cent of all work-related fatalities). 25 Additionally,
hazardous substances may also have harmful impacts on the environment, as
indicated in the previous unit.

Environmentally sound management of toxic chemicals encompasses safe

manufacture, storage, transport, use and disposal of hazardous chemicals. In
other words, it is necessary to develop a proper form of management for
chemicals that takes into account the whole life cycle, from manufacture to
disposal - a cradle-to-grave management. But, how to achieve this?

In assessing hazards and risks, key questions to address would be:

• Can all these negative effects on workers, communities and the
environment be avoided?
• Has enough been done yet?
• What should be the role of prevention?

Whenever individuals or the environment become exposed to hazardous

substances, remediation/decontamination measures should be deployed in order
to minimize the toxic effects.

However, prevention should be the first step to avoid contamination and exposure
of individuals and the environment to toxic products, or, at least, to keep it under

25 Ivan D. Ivanov, Igor Fedotov and Monica Wehrle-Mac Devette (2007). “Occupational,
environmental and public health”. Labour and the Environment: A natural Synergy. UNEP

42
maximum “tolerable” levels. Additionally, for most chemicals, there often is no
“proof” or “near proof” of adverse effect; yet in the meantime, an even greater
number of workers might be exposed. This is why prevention is so crucial to
chemical risk management.

It is always better to anticipate, rather than to rely on an

after-the-fact approach.

DEFINITIONS
A definition of key concepts and terms is necessary:

Hazard: It is the source of danger. It can be defined as the set of inherent

properties of a chemical, mixture of chemicals or processes that has the potential
to adversely affect the environment or the organisms it contains, during
production, usage or disposal.

Risk: It is important to distinguish risk from hazard. Hazard refers to the intrinsic
properties of a chemical, whereas risk refers to the chance or probability that the
chemical will cause an adverse health or environmental effect.

If there is a high risk that a certain chemical will cause cancer to exposed
workers, then it is very likely that some of those workers will develop cancer. If
the risk is low, then it is less likely that the workers will develop cancer. However,
even if the risk of some health effect is low, the chemical in question is still a
hazard.

Depending on the circumstances, a “low risk” may be acceptable to the people

exposed. Determining the “acceptable risk” is part of the process for setting
safety standards. “Setting safety standards” is not a scientific but a political issue.
Therefore, it is important that workers have a say in their definition.

Risk assessment involves identifying the origin of the hazard (the chemical
of concern, for instance, and its adverse effects, target populations and conditions
of exposure), characterizing the risk, assessing exposure (by modelling,
measuring or monitoring), and estimating the risk. Thus, it consists of
identification and quantification of the risk resulting from a specific use or
occurrence of a chemical, and takes into account the potential harmful effects on
individuals of using the chemical in the manner and amount proposed, as well as
all possible routes of exposure.

Risk management covers the whole range of actions taken to prevent, minimize
or otherwise control specific risks posed by a certain chemical or situation. This
also refers to the search for substitutes for problematic chemicals, or for new
and different processes to avoid the use of chemicals.

In this regard, the notion of safety is even more difficult to define than risk or
hazard. The safety of a chemical, in the context of human health, is the extent to
which a chemical may be used in the amount necessary for the intended purpose,
with a minimum risk of adverse health effects. It can also be defined as a
"socially acceptable" level of risk. But it is usually unclear which part of society is
judging the risk. Workers that are exposed to the risk are likely to be more
concerned about the safety of a chemical than others are. Therefore, it is very

43
important to question statements such as "this chemical is safe" or "there is a
high level of safety when using this chemical". Safety is a subjective concept,
which needs to be properly defined in practice.

The next module will focus on safety in the workplace.

PRECAUTIONARY PRINCIPLE

As part of the prevention culture, the precautionary principle is a key driving

notion.

“It is a truth very certain that when it is not in our power to determine
what is true, we ought to follow what is most probable.”
René Descartes (1596-1650)

The precautionary principle is a moral and political principle which states that if
an action or policy might cause severe or irreversible harm to the public, in the
absence of a scientific consensus that harm would not ensue, the burden of proof
falls on those who would advocate taking the action.26

This is the reason why many workers and trade unions demand that the principle
of “not assessed, not used” be enforced. Precaution is about taking protective
decisions based on the best available evidence.

Box 1.13. Nanotechnology, nanomaterials and precaution

Nanotechnology is a rapidly emerging technology that is expected to result in major

changes across many industry sectors. This may bring many advances to society and
benefits for the environment, but also poses new challenges, especially to health and
safety.

To date discussions on the potential benefits of nanotechnology have mostly taken place
separately from discussions on the potential risks of nanomaterials to human health and
the environment. In the context of prevention, it is important that the precautionary
principle be taken into account in assessing the development of these emerging
approaches and processes.

Source: Sustainlabour, 2008

ALTERNATIVES: SUBSTITUTION PRINCIPLE

Substitution is one of the most important preventive techniques, given that it

seeks to eliminate a certain risk at its source, through the implementation of
significant changes in the productive process.

These changes can be grouped in three levels:

Substitution of an auxiliary substance or primary resource for an another
without affecting the productive process,

26 Raffensberger C, Tickner J (eds.) (1999). Protecting Public Health and the Environment:
Implementing the Precautionary Principle. Island Press, Washington, DC

44
Substitution of equipment and procedures without affecting the production
process, and/or
Substitution of an auxiliary substance or primary resource in an
equipment, with changes in the production process.

45
 Unit 4: GREEENING OUR CHEMICAL WORLD

The unit will address the following questions:

1. Is it possible to develop a different chemistry?

2. What is “green” chemistry?

It is often argued that the consequences of hazardous chemicals on public health

and the environment should be understood as a necessary part of the
development of so-called modern societies, which bear “socially accepted” side
effects.

Yet, is the current mainstream chemistry known thus far the only possible way
forward? Is there no possibility to move towards more sustainable, clean
production models? Rather than the existence of chemistry itself, as it has been
largely practiced over the past decades, the question relates to the types of
chemicals, their roles, as well as the principles and criteria that should provide
the basis for deciding which chemicals should be produced and to what ends.

Chemistry is the basis of life: we breathe O2 (oxygen), we drink H2O (water), we

expel CO2 (carbon dioxide), and when we die we become CH4 (methane) or if
cremated turn into PCDD and PCDF (dioxins and furans). The development of
chemistry should thus be compatible with the development of life and the
protection of the environment.

WHAT ARE THE LIMITS OF THE CURRENT CHEMISTRY?

Two problems can be identified in today’s chemistry, among others:

occupational exposure and human health risks, and environmental
pollution. The relationship between social, occupational and environmental risks
is increasingly recognized and integrated in the decisions regarding the
production and use of chemicals.

At the same time, other significant circumstances affect even the viability of the
chemical industry in a relatively near future. The dependency of current
chemistry on fossil fuels requires close attention: an overwhelming volume of
products and synthetic materials are made from organic compounds based on
fossil materials, primarily petroleum. Therefore, the variation of prices and
production of petroleum is set to affect the chemical industry. It is therefore
legitimate to wonder whether we are moving from a peak oil scenario to a peak
chemicals scenario.27

It is important and necessary to identify alternative sources of organic renewable

materials to ensure that the chemical industry remains the supplier of products
and materials for the human wellbeing.

27 Based on Mestres (2006), Hacia una producción química sostenible. University of Valencia.

46
The production and use of chemicals have not only expanded quantitatively, but
also geographically. Africa, but also Latin America and Asia are becoming
dumping grounds for chemical wastes, while chemical industries are also
relocating increasingly into these countries, where there is less fiscal and
regulatory oversight and pressure.

It is expected that there will be a significant shift in the production of chemicals

from OECD countries to non-OECD countries. It is estimated that the developing
world will increase its share from 23 per cent of global demand for chemicals and
21 of production in 1995 to 33 and 31 per cent, respectively, by 2020.28

It is essential to strengthen chemicals regulations nationally and internationally.

It is also necessary to promote development and to base production on cleaner
and safer technologies. The strengthening of chemicals regulation and the
promotion of cleaner and safer technologies will be the best preventive measure
to anticipate and avoid occupational and environmental exposure to hazardous
substances as well as possible accidents.

GREEN CHEMISTRY IS THE KEY! CAN THE DOOR BE UNLOCKED?

Taking into account that all toxic chemicals are dangerous, and that there is no
possibility to eliminate risk completely, but at least to reduce it as much as is
feasible, it seems logical to develop a chemistry which is as little harmful as
possible. Substitution of products and processes is a very valuable and necessary
component in daily practices and production, and should be promoted.

However, adopting a chemical-by-chemical/individual substance substitution

approach is too slow, due to the large number of chemicals already on the market.
It needs to be accompanied by the promotion of a new conception of chemistry, a
sustainable chemistry or green chemistry.

Box 1.14. Green Chemistry research

Based on 12 principles, the Green Chemistry approach was developed by Doctors Paul
Anastas and John Warner:

1. Prevention: It is better to prevent waste than to treat or clean up waste after it

has been created;
2. Atom Economy: Synthetic methods should be designed to maximize the
incorporation of all materials used in the process into the final product;
3. Less Hazardous Chemical Syntheses: Wherever practicable, synthetic methods
should be designed to use and generate substances that possess little or no
toxicity to human health and the environment;
4. Designing Safer Chemicals: Chemical products should be designed to effect
their desired function while minimizing their toxicity;
5. Safer Solvents and Auxiliaries: The use of auxiliary substances (e.g., solvents,
separation agents, etc.) should be avoided wherever possible and innocuous when
used;

6. Design for Energy Efficiency: Energy requirements of chemical processes

should be recognized for their environmental and economic impacts and should be
minimized. If possible, synthetic methods should be conducted at ambient
temperature and pressure;
7. Use of Renewable Feedstocks: A raw material or feedstock should be

28 Monosson, E. (2007). “Chemicals use in Africa”. Encyclopaedia of Earth

http://www.eoearth.org/article/Chemical_use_in_Africa (last accessed 19 December 2007)

47
 renewable rather than depleting whenever technically and economically
practicable;
8. Reduced Derivatives: Unnecessary derivatization (use of blocking groups,
protection/deprotection, temporary modification of physical/chemical processes)
should be minimized or avoided if possible, because such steps require additional
reagents and can generate waste;
9. Catalysis: Catalytic reagents (as selective as possible) are superior to
stoichiometric reagents;
10. Design for Degradation: Chemical products should be designed so that at the
end of their useful lives they break down into innocuous degradation products and
do not persist in the environment;
11. Real-time analysis for Pollution Prevention: Analytical methodologies need to
be further developed to enable real-time, in-process monitoring and control prior
to the formation of hazardous substances; and
12. Inherently Safer Chemistry for Accident Prevention: Substances and the
form of a substance used in a chemical process should be chosen to minimize the
potential for chemical accidents, including releases, explosions, and fires.

Source: Anastas, P. T.; Warner, J. C. (1998) Green Chemistry: Theory and Practice, Oxford
University Press: New York, p.30.

Green chemistry is based on the application of a series of principles by which the

use or generation of hazardous substances is reduced or eliminated in the design,
manufacture and application of chemical products, 29 by using renewable raw
materials, manufacturing products that are non-toxic and biodegradable, and
avoiding waste. Moving forward to a different chemistry based on imitation of
nature, or biomimesis, must be part of that “green” future.

The proposal of a sustainable chemistry goes hand-in-hand with the need to

develop sustainable products, based on clean production.

Imagine, then, a chemical that:

• Does not accumulate in the environment or in our bodies,
• Does not present toxicity - neither to human beings nor to the
environment,
• Is based on renewable resources,
• Minimizes the use of energy and resources,
• Whose products can be reused, recycled or composted at the end of their
lives, and
• That produces necessary and useful products and safe jobs.

29 Anastas, P. T. Warner, J. C. (1998). Green Chemistry: Theory and Practice, p.30. Oxford University
Press, New York

48
 Box 1.15. Clean Production

Cleaner Production is the continuous application of an integrated preventive

environmental strategy to processes, products, and services with a view to increasing
overall efficiency, and reducing risks to humans and the environment. Cleaner Production
can be applied to the processes used in any industry, to products themselves and to
various services provided in society (UNEP, 2001).

• For production processes, Cleaner Production results from one or a combination of

raw materials, water and energy; eliminating toxic and dangerous raw materials; and
reducing the quantity and toxicity of all emissions and wastes at source during the
production process;
• For products, Cleaner Production aims to reduce the environmental, health and
safety impacts of products over their entire life cycles, from raw materials extraction,
through manufacturing and use, to the “ultimate” disposal of the product; and
• For services, Cleaner Production implies incorporating environmental concerns into
designing and delivering services.

Source: UNEP. Production and Consumption Branch. “Cleaner production: key elements”
http://www.uneptie.org/pc/cp/understanding_cp/home.htm#definition (last accessed 19 December
2007

Is that a fantasy? Or can it be the reality of our future. Apart from formulating
objective and general strategies, it seems necessary to answer the fundamental
question of whether it is technically feasible to develop and implement green
chemistry and to establish clean production systems.

Numerous chemical products are already being developed by major companies

according to these principles. As they also represent significant new economic
opportunities, consumers and clients should urge companies to adopt widely
green chemistry. Yet, it is important to guarantee that the products of green
chemistry do not have adverse effects on workers’ health.

It is true that many technical questions remain unsolved. Nonetheless, it is

difficult to find answers when the resources allocated to research and
development as well as impact assessment are not sufficient.

The political will to invest in innovation and research, to adopt regulatory

frameworks that prioritize clean production and green chemistry incentives, and
to promote capacity development for appropriate action are some of the doors
that need to be unlocked.

Trade unions and workers, the first victims of hazardous chemicals, can and need
to push these doors, while looking for alliances with the scientific and research
community, and the private sector to obtain collectively a stronger impact.

Green chemistry is the key to the door to a sustainable path forward.

49
Where to get more information?

Sources of information to identify substances (last accessed 14 April 2008):

International Chemical Safety Cards
http://www.ilo.org/public/english/protection/safework/cis/products/icsc/ or
http://www.unece.org/trans/danger/publi/unrec/12_e.html: for essential information about
chemicals’ physical properties, as well as health and safety information on the use of
chemicals at the "shop floor" level by workers and employers in factories, agriculture,
construction and other work places
TOXNET http://toxnet.nlm.nih.gov
Hazardous Substance Database (HSDB) http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB
Pesticide Action Network Database http://www.pesticideinfo.org
ChemIDplus http://chem2.sis.nlm.nih.gov/chemidplus/chemidlite.jsp
European Chemicals Bureau http://ecb.jrc.it/existing-chemicals/
RISCTOX database: Contains information in Spanish on the health and environmental risks of
over 30 000 chemicals - http://www.istas.net/ecoinformas

50
Module 1 references

Official websites:
International Labour Organization. “Safe work”
http://www.ilo.org/public/english/protection/safework/intro/

Documents:
ILO. International Labour Office. “Programme on Safety and Health and Work and
Environment. International Chemical Control Toolkit”
http://www.ilo.org/public/english/protection/safework/ctrl_banding/toolkit/main_guide.pdf
ILO. “International Occupational Safety and Health Centre of Information: Basics of chemical
safety” http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/toc.htm
ILO. International Occupational Safety and Health Centre of Information. “Chemical safety
training modules”
http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/index.htm
ILO. “Chemicals in the workplace. Your health and safety at work.”
http://www.itcilo.it/actrav/actrav-english/telearn/osh/kemi/chemicaa.htm
IPCS (International programme on chemical safety) (2004). “Guidelines on the prevention of
toxic exposure, Education and public awareness activities”
IPCS (International programme on chemical safety). “Users’ manual for the IPCS health and
safety guides http://www.inchem.org/documents/hsg/hsg/hsgguide.htm
IPCS (International Programme on Chemical Safety). “Safety and Health in the Use of
Agrochemicals” http://www.itcilo.it/actrav/actrav-english/telearn/osh/kemi/pest/pesti2.htm
IPCS (International programme on chemical safety) (2000). “Hazardous Chemicals in Human
and Environmental Health”
IPCS (International programme on chemical safety). “General Scientific Principles of Chemical
Safety”, Training Module, no.4
“Occupational Cancer/Zero cancer: A Union Guide to prevention”
http://www.hazards.org/cancer/
WHO-UNEP (2006). “Sound Management of Pesticides and diagnosis treatment of pesticide
poisoning”

51
NOTES:

52
53
54
 MODULE 2:
SAFE USE OF CHEMICALS IN THE WORKPLACE
Safer management of chemicals at work: will it
require major changes?

Capping an oil well, Kuwait

© S. Compoint / UNEP / Still Pictures

Module objectives:

The module aims at:

Providing guidelines on how to identify problems and situations of chemical risk

in the workplace;
Advising on prioritizing problems to be addressed through preventive action;
Advising on the preventive measures to be put in place, and the notion of
“substitution principle”;
Identifying steps to ensure workers’ participation.

Learning outcomes:

At the end of the session, the trainee will be familiar with:

Sources of information about chemicals used at work;
The different states in which hazardous substances can be found throughout the
production process (as primary resources, auxiliary products, sub products, or
final products), including in the case of non-intentional releases;
Interpreting the information on labels and Safety Data Sheets;
Identifying potential risks related to chemical substances in the workplace;
evaluating better their consequences for human health and the environment;
Steps to elaborate more consistent, complete and effective plans of intervention;
The notion of “substitution principle”.

55
 Unit 1: PREVENTION IS THE CORNERSTONE: ENHANCING A
SAFETY AND PREVENTION CULTURE

This unit will mainly address the following questions:

1. How to design a framework for intervention in the workplace?

2. Where to get useful information on chemicals to this end?
3. What are management’s and the manufacturer/supplier’s responsibilities
regarding workers’ right-to-know?

The groups most exposed to chemical contamination are, logically, the people
who are closer to the source. The first examples that come to mind are industry
and agriculture workers. However, workers in the service sector such as
hairdressers are significantly exposed as well. Thus, it is not a coincidence if the
harmful health effects of many chemical products have been first discovered
among workers.

To prevent chemical risks, it is necessary to:

• identify the substances present in the workplace;
• be aware of their risks for health and the environment;
• understand both employers’ and employees’ perception of risk;
• identify alternatives that bear lesser risk; and
• evaluate the advantages and inconveniences that these alternatives may
present from a legal, environmental, occupational and economic
perspective, before implementing them.

All workplaces should implement effective safety procedures against chemical

hazards, agreed jointly between employers and workers. In some countries, these
agreements will be negotiated as collective bargaining agreements or health
and safety agreements between management and workers. Sometimes
these agreements are additional to the minimum obligations imposed on
employers by workplace health and safety laws. However, agreements that are
not part of a collective bargaining agreement experience implementation
problems, as they lack legal power.

56
 Box 2.1. Collective agreements and collective bargaining

Collective agreements means all agreements in writing regarding working conditions

and terms of employment concluded between an employer, a group of employers or one
or more employers’ organizations, on the one hand, and one or more representative
workers’ organizations, or, in the absence of such organizations, the representatives of
the workers duly elected and authorized by them in accordance with national laws and
regulations, on the other.

Source: ILO Collective Agreements Recommendation (R91) - 1951

Collective bargaining serves a dual purpose. It provides a means of determining the

wages and conditions of work applying to the group of workers covered by the ensuing
agreement through free and voluntary negotiations between the two independent parties
concerned. It also enables employers and workers to define by agreement the rules
governing their relationship.

Collective bargaining takes place between an employer, a group of employers or one or

more employers’ organizations on the one hand and one or more workers’ organizations
on the other. It may take place at many different levels, with one level sometimes
complementing the other: a unit within an enterprise, enterprise level, sectoral, regional
and national level.

Source: www.ilo.org/public/spanish/dialogue/themes/cb.htm

Occupational health and environmental protections are two sides of the

same coin. This section presents a number of steps to follow to prevent
occupational and environmental risks in the workplace, related to the exposure to
chemical products and substances. The final objective is to provide advice to
workers’ representatives, business and industry, as well as other social actors
involved in preventing adverse health and safety effects in the workplace.

The main objectives are the:

• Identification of chemical risk situations and problems in the workplace;
• Evaluation of the problems, in terms of priority and importance, to
determine the type of preventive action;
• Promotion of concrete prevention practices;
• Enhancement of workers’ participation.

57
 Box 2.2. Procedure for intervention on chemical risk in the workplace

[Procedure]

1 PREPARE INTERVENTION

2 IDENTIFICATION OF EXPOSURE RISK AND CHEMICALS

Risk situations
Dangerous substances
Characteristics of exposure

3 RISK ASSESSMENT

4 PLAN OF INTERVENTION
5
Risk elimination
Technical evaluation
Risk control

5 + PROTECTION AND EMERGENCY ACTION

6 FOLLOW-UP: Evaluation, efficiency and revision

Source: Based on ISTAS. “Chemical risk prevention in the workplace. Guide for intervention”
http://www.istas.net/web/abreenlace.asp?idenlace=1367

PREPARING A FRAMEWORK FOR “INTERVENTION”

SITUATION ANALYSIS
Experience has shown that the level of awareness and degree of perception of the
people involved are key to the success of any intervention in the workplace.

Those in charge of drafting the plan of intervention must be aware of this before
starting any preventive measures against chemical risk, and, if necessary, they
must create the conditions that will enhance the overall awareness and degree of
perception of these risks in the workplace.

58
In this case, they should first identify and take into account workers’ and,
importantly, management’s perceptions and attitudes about chemical risk in the
workplace. If it appears that there is little concern in the workplace about
chemical risk, the first actions should focus on information and sensitization
through:
• Providing proof of chemical risk in the workplace;
• Raising awareness on the effects of these chemical products on health and
the environment; and
• Identifying options to avoid and reduce risk through responsible attitudes
(good practices, use of alternative substances, among others).

EVALUATION OR RAPID ASSESSMENT OF THE WORKFORCE AND MANAGEMENT’S

PERCEPTIONS OF RISK
As indicated previously, the level of awareness and the degree of perception
towards chemical hazards is critical to the success of any chemical risk
elimination or risk reduction intervention.

AWARENESS RAISING AND SENSITIZATION

Workers and employers’ sensitization to risks caused by chemical products is key
for effectively preventing these risks. For the person in charge of designing the
plan of intervention, it is very important to raise awareness. This training should
enhance the knowledge and skills required for the sound and sustainable
management of chemicals, both in the workplace and in the living environment.

WHERE TO GET INFORMATION?

One of the biggest challenges for workers’ and trade union health and safety
representatives is to obtain adequate information about chemicals used at work.
There are different sources of information, which they should all explore, as a
single source will often not tell everything they need to know.

Try to get information from as many of these sources as you can, to

get a full picture of chemicals’ hazards!

The most important sources of information are the labels on containers and the
hazard data sheets. Other relevant sources include:
• Te Union or Health and Safety Representative;
• The manufacturer or supplier of the chemical, through Material Safety
Data Sheets (MSDS), labels and/or direct inquiries;
• The Employer;
• Higher Learning and Research Institutions;
• A registrar of Chemicals (normally in Ministry of Agriculture and Ministry of
Health);
• International Trade Secretariats, e.g. IUF, ICTU;

59
 • International Chemical Secretariats, e.g. ChemSec;
• Intergovernmental Organizations, Agencies and Programmes, e.g. ILO,
UNEP, WHO, IFCS, UNITAR;
• Secretariats of Conventions and Agreements, e.g. Stockholm, Rotterdam,
Basel, Bamako, Cartagena;
• Non–Governmental Organizations, e.g. IPEN, PAN Africa, WWF, PAN AP;
• International Campaigns, e.g. Fair Flowers Fair Plants (FFP) programme;
• Survey of the workplace and interviews/consultations of workers;
• National legislation(s): see “right-to-know”.

The latter two sources are of particular relevance:

• Survey of the workplace and interviews/consultations of workers:
this is an important source of information, which results from a site-visit to
the different workplaces and areas and an exercise of consultation with
workers. This will also provide a reference against which to compare the
information given by the company.
A detailed overview of the places and sites that show a higher level of
absenteeism is usually indicative of higher rates of occupational accidents
and incidents and points out where the major problems may be.
• National legislation(s): Many countries now have some kind of
legislation governing communication of hazard or “right-to-know”.
Under these laws, employers, manufacturers, suppliers and importers of
chemicals must provide clear, detailed information about the particular
chemical substance or product in question: its possible health effects,
including the results of animal tests and surveys of exposed workers, and
means of protecting workers from any harmful effect.
Right to Information and Management’s responsibility: These laws
make it the employer’s legal responsibility to provide workers with as
much information and training as possible on all chemical substances
used. Some unions have negotiated agreements that require the union
be given full information on all chemicals used in the workplace.
Unfortunately, many employers do not have this information and may
not know where to get it. In this case, the health and safety
representative should insist that the employer obtain information from
the manufacturer or the supplier of the chemical and make it available
to the workers.
Right to information and Manufacturer and Supplier’s responsibilities:
If the employer cannot obtain the necessary information, a worker or
the union may write directly to the manufacturer of the chemical to
request the information.

In accordance with the objectives and principles of the ILO

Occupational Health and safety Convention, 1981 (n. 155), and
Recommendation, 1981 (n.164), Employers should make chemical
safety data sheets or similar relevant information of the chemicals
used at work available to workers and their representatives.

60
Manufacturers and suppliers, in particular, are required to provide information
through:

LABELS
The label is the basic tool to keep the user informed on the classification of a
product’s hazard and the most important safety precautions.

Labels must be attached to the container, and correspond to the exact chemical
that can be found in the container.

It is highly recommended that chemicals be kept in their original containers.

However, when a hazardous chemical has been transferred from its original
shipping container, the secondary and all subsequent containers should carry the
appropriate warning labels. Labels should be affixed to all containers from the
production of the chemical to its disposal.

International, regional, and national classification and labelling systems are

already established and tested in practice:
• The United Nations Recommendations on the Transport of Dangerous
Goods is widely recognized and used among the UN member states;
• The classification and labelling system of the European Union which is
used beyond the EU countries; and
• Several functioning national systems, such as those of Canada and USA,
may also be used as models for national systems.

In EU countries the label must clearly show the trade name; the name and the
address, including telephone number, of the manufacturer, the importer or the
distributor; the chemical name of the substance (in the case of a preparation, the
chemical names of the hazardous components); the quantity of the contents of
the package or container. Most important, it contains signs and symbols of
danger, international numbers (CAS or ICSC numbers), risk phrases (R-
phrases) and safety phrases (S-phrases), which are widely used in many
countries from all over the world.

THE GLOBALLY HARMONIZED SYSTEM OF CLASSIFICATION AND LABELLING OF CHEMICALS

(GHS)
It is important to mention the Globally Harmonized System of Classification
and Labelling of Chemicals (GHS), which is an internationally recognized
system set to replace the various classification and labelling standards used in
different countries.

The GHS establishes consistent criteria for classification and labelling of chemicals
on a global scale. It covers all hazardous chemicals, including substances and
mixtures.

Compliance with the GHS is voluntary for each country. However, it is likely that
countries that do not adopt the GHS will be at a disadvantage when doing
business internationally.

There is no definite international implementation schedule for the GHS. The

United Nations are targeting its broad international adoption by 2008. Yet,
different countries will require different periods to update current regulations or
implement new ones.

61
 Box 2.3. Information on GHS labels

The required information in the GHS labels includes:

Symbols (hazard pictograms): Convey health, physical and environmental

hazard information assigned to a GHS hazard class and category. Pictograms
include the harmonized hazard symbols plus other graphic elements, such as
borders, background patterns or colours to convey specific information. The
symbols are similar to current EU symbols, with a few exceptions;

Signal Words: "Danger" or "Warning" used to emphasize hazards and indicate

their relative level of severity, assigned to a GHS hazard class and category.
Some lower level hazard categories do not use signal words. Only one signal word
corresponding to the class of the most severe hazard should be used on a label;
and

Hazard Statements: Standard phrases assigned to a hazard class and category

that describe the nature of the hazard. An appropriate statement for each GHS
hazard should be included on the label for products possessing more than one
hazard.

Additional label elements included in the GHS are:

Precautionary statements: measures to minimize or prevent adverse effects;

Product identifier: name or number used for a hazardous product on a label or
in the SDS; supplier identification: the name, address and telephone number
should be provided on the label; and
Supplemental information.

Source: UNECE. “Globally Harmonized System of Classification and Labelling of Chemicals (GHS)”
http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html (last accessed 14 April 2008)

Box 2.4. An example of label under EU regulation

Product identification –
chemical substance or
Risk T F ABCDE-33 commercial name of mixture
identification

Composition – for mixtures,

relation of hazardous substances
according concentration and
Toxics Highly Flammable Contains… toxicity
Risk
description
(R-Phrases) R 11-23/25: XXX, S.A. Supplier information – name,
Highly flammable Street… address and telephone
Toxic by inhalation and if swallowed

S 7-16-24-45
Preventive Keep container tightly closed
mesures Keep away from sources of ignition -- No smoking
(S-Phrases) Avoid contact with the skin
Avoid contact with eyes

Source: Based on ILO. “Training Modules on Chemical Safety: Identification, classification and labelling of chemicals”
http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/classify.htm (last accessed 2 April 2008)

62
 Every chemical container in the workplace, no matter how small,
should have an appropriate, understandable label.

Where to get more information?

For more information, Globally Harmonized System of Classification and Labelling of

Chemicals (GHS) - GHS Pictograms -
http://www.unece.org/trans/danger/publi/ghs/pictograms.html
Labelling symbols used in the European Union, the European Economic Area and other
countries
http://www.ilo.org/public/english/protection/safework/cis/products/icsc/dtasht/symbols/ind
ex.htm
http://www.ilo.org/public/english/protection/safework/ghs
International Chemical Secretariats, e.g. ChemSec (www.chemsec.org)
Intergovernmental Organizations, Agencies and Programmes e.g. ILO, UNEP, WHO, IFCS
(www.ifcs.ch), UNITAR (http://www.unitar.org), (include relevant websites)
Non–Governmental Organizations e.g. IPEN (www.ipen.org), PAN UK, PAN Africa (www.pan-
africa.sn), PANNA, WWF (http://www.wwf.org.uk/chemical),
(http://www.panda.org/toxics), PAN AP (www.panap.net)

SAFETY DATA SHEETS

Safety data sheet (or SDS) is the name given to the Material Safety Data
Sheet of the Globally Harmonized System of Classification and Labelling of
Chemicals (GHS).

Safety Data Sheets should contain identification information about the substance
(composition, physical, chemical and toxicological hazards), information on
specific protection and prevention measures throughout the whole process
(production, storage, transport, etc.), measures to undertake in case of an
accident (spillage, fire-fighting measures, etc.), as well as contact details of the
supplier.

Chemical safety data sheets should be available within the enterprise for every
chemical substance that has been classified as hazardous. They should also be
available for preparations (products) containing any hazardous substance as a
component.

Chemical safety data sheets are published under several names, such as:
• International chemical safety card (ICSC);
• Chemical safety card;
• Chemical info-sheet;
• Material safety data sheet (MSDS);
• Hazard data sheets (HDSs);
• Chemical safety data sheets (CSDSs);
• Product safety data sheet;
• Health and safety data; and
• Safety data sheet (SDS).

63
Validated data sheets on pure substances are available, for example, from the
International Programme on Chemical Safety (IPCS, www.intox.org) or from
national institutions such as the Canadian Centre for Occupational Safety and
Health (www.ccohs.ca). These can be used by manufacturers as basic sources of
information.

Box 2.5. Safety Data Sheets contents according to the Globally Harmonised
System of classification

The information in the SDS should be presented using the following 16 headings in the
order given below:

1. Identification: identifies the substance or mixture and provides the name of the
supplier, recommended uses and the contact details for the supplier including an
emergency contact;
2. Hazard identification: describes the hazards of the substance or mixture and the
appropriate warning information -signal word, hazard statement(s) and precautionary
statement(s)- associated with these hazards;
3. Composition/information on ingredients: identifies the ingredient(s) in the
product. This includes the impurities and stabilizing additives that are themselves
classified and contribute to the classification of the substance as a whole. This section
may also be used to provide information on complex substances;
4. First-aid measures: This section describes the initial care that can be given by any
untrained individual, without the use of sophisticated equipment and without a wide
selection of medications available. If medical attention is required, the instructions
should state so, as well as the level of urgency. It may be useful to provide information
on the immediate effects, by route of exposure, and indicate the immediate treatment,
followed by possible delayed effects with specific medical surveillance required;
5. Fire-fighting measures: covers the requirements for fighting a fire caused by the
substance or mixture, or arising in its vicinity;
6. Accidental release measures: recommends the appropriate response to spills, leaks,
or releases in order to prevent or minimize the adverse effects on persons, property
and the environment. Distinguish between responses for large and small spills where
the spill volume is a significant factor in the hazard. The procedures for containment
and recovery may indicate that different practices are required;
7. Handling and storage: provides guidance on safe handling practices that minimize
the potential hazards to people, property and the environment from the substance or
mixture. Emphasizes precautions that are appropriate to the intended use and to the
unique properties of the substance or mixture;
8. Exposure controls/personal protection: for the purposes of this document
“exposure control” means the full range of specific protection and prevention measures
to be taken during use in order to minimize worker and environmental exposure;
9. Physical and chemical properties: describes the empirical data of the substance or
mixture (if possible) in this section;
10. Stability and reactivity: describes the reactivity hazards of the substance or mixture
in this section. Provides specific test data for the substance or mixture as a whole,
where available. However, the information may also be based on general data for the
class or family of chemical if such data adequately represent the anticipated hazard of
the substance or mixture;
11. Toxicological information: used primarily by medical professionals, occupational
health and safety professionals and toxicologists, it provides a concise but complete
and comprehensible description of the various toxicological (health) effects. The
available data used to identify those effects should also be provided;
12. Ecological information: provides information to evaluate the environmental impact
of the substance or mixture if it were released into the environment. This information
can assist in handling spills, and evaluating waste treatment practices and should
clearly indicate species, media, units, test duration and test conditions;
13. Disposal considerations: provides information for proper disposal, recycling or
reclamation of the substance or mixture and/or its container, in order to assist in the
determination of safe and environmentally preferred waste management options,
consistent with the requirements of the national competent authority;

64
14. Transport information: provides basic classification information for the
transporting/shipment of a hazardous substance or mixture by road, rail, sea or air.
Where information is not available or relevant, this should be stated;
15. Regulatory information: describes any other regulatory information on the
substance or mixture that is not provided elsewhere in the SDS (e.g. whether the
substance or mixture is subject to the Montreal Protocol, the Stockholm Convention10
or the Rotterdam Convention11); and
16. Other information: provides information relevant to the preparation of the SDS in
this section. This should incorporate other information that does not belong in sections
1 to 15 of the SDS.

Source: UNECE. “Globally Harmonized System of Classification and Labelling of Chemicals (GHS)”
http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html (last accessed 19 December
2007)

What to do?

1. Raise awareness of, and train about, the effects of chemical exposure on
occupational health and the environment;
2. Talk to workers to find out their opinions regarding chemical risk in the workplace
(see as an example the “Questionnaire” in annex 3 A);
3. Get in contact with management to express concerns related to this issue; and
4. Present workers and employers with the need to assess chemical risk at work, in
order to develop measures to minimize, control and reduce these risks.

Unit 2: BEING A WORKPLACE DETECTIVE: IDENTIFICATION

OF EXPOSURE RISKS AND CHEMICALS

This unit will mainly address the following questions:

1. How to identify “hot spots” for chemical risks and problems in the
workplace?
2. How to accurately map out hazardous substances and materials?
3. How to characterize exposure to these hazards?

Text books do not give all the answers about workplace risks: barely one in every
100 chemicals used at work has been systematically tested.

Finding out if there is a potential risk in the workplace requires collective vigilance.
That means each worker should do his/her own “detective” work. Unions have
been instrumental in identifying a number of workplace illnesses, such as cancers.

The best of information is the workforce itself, as workers know their

jobs, their workmates and the real hazards.

65
IDENTIFICATION OF “HOT SPOTS”: WHERE ARE THE PROBLEMS AND RISKS?

Workers’ exposure to chemical risk and toxic products can take place in different
sections and departments on the production line. It can affect a single work post
or a large number of positions.

Environmental risk exposure can originate from generating solid polluted wastes,
spilling or pouring dangerous substances with water through waste pipes,
draining or during accidental discharges or emission of dangerous substances into
the air, whether through windows, systems of ventilation or chimneys.

Identification of risk situations can:

• Be limited to the place of work or can refer to a concrete working area
(department, number of different tasks for the production process, etc.);
and
• Be extended to the whole organization or business to identify all possible
risk situations.

To identify “hot spots”, workers need to look at the company’s operations in a

different way. Rather than focusing on the end-product, they need to look in
details at the storage, handling, and use of chemicals throughout the production
process.

To this end, they can walk through the entire process and develop a flowchart
that represent the complete production process, or the different tasks and
sections that take place at work. This enables the identification of different places
where chemical exposure may occur.

Depending on the type of company (sector, size, number of workers, etc.) there
are several places and tasks that involve chemicals and result in the generation of
chemical waste, dangerous spills, air emissions, etc. In addition, actions and
tasks that are carried out in the workplace frequently require the use of several
different chemical products, each of which can contain several substances,
resulting in “multiple exposure”.

MAPPING OUT THE HAZARDOUS SUBSTANCES AND MATERIALS

It is recommended to draft and update a comprehensive list of all the products

that are used regularly in the workplace. These may be in the form of solid or
liquid waste, gas emissions or poured liquids made up of a mix of products, as
indicated in section one.

This step involves:

• Systematically identifying all chemical substances that are stored and used
in the factory; and
• Creating a structured database than can be used to identify and make
improvements on a continuous basis.

This list can be elaborated using the information provided by workers, as well as
from the labels on the packages and containers and the safety data sheets (SDS).
(Read more in Where to get information?). This should provide information
about their composition, their physico-chemical properties and their toxicity to
human health and the environment.

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In drafting this list, workers and their representatives should be aware that
hazardous substances can be:
• Found in different natural states: solid, liquid or gaseous;
• Involved in the production processes as primary resources, auxiliary
products, intermediate products, sub products and/or non-intentional
releases, or even, the final product; and
• Used or generated regularly or sporadically as a result of cleaning tasks,
maintenance tests, etc.

The inventory should include the following information:

• The products used at different stages of the production process;
• Their compositions, especially the active ingredients they contain;
• The dangers for the environment;
• The potential health risks; and
• Gender specific health risks.

Box 2.6. The “dirty five” group!

The common chemical groups that causes major health risks are:

DUSTS, FUMES AND GASES - Dust may be just a nuisance, but it can present serious
risks. The potential danger depends on the type of material in the dust, and on the
amount and the size of the particles. Asbestos falls into this category.

Exposure to metal fumes can cause damage to the body. “Metal fume fever” is a known
health effect of inhaling metal fumes, especially if they contain zinc. It usually appears on
the day following that of exposure.

Gases do not necessarily have a warning odour at a dangerous concentration level. The
odour may be detected only at very high concentrations in the air. Gases may have an
irritating effect, or they may enter the blood circulation and cause internal damage.
Sulphur oxides, nitrogen oxides, chlorine and ammonia are toxic gases widely used in
industry.

SOLVENTS - Most solvents are liquid organic chemicals. They are used because of their
ability to dissolve other substances, particularly fat and grease, which are insoluble in
water. Many of them evaporate rapidly at ambient temperatures. They are often
flammable.

Many solvents have a narcotic effect and may cause dizziness, headache, reduced
comprehension or tiredness. Some solvents are very hazardous to the liver, kidneys,
bone marrow or nervous system. Benzene, carbon tetrachloride and carbon disulphide
belong to the category of solvents that should be substituted with less dangerous ones.

METALS - Metals can enter the body in the form of dust and fumes (in grinding or
welding) or even through the skin.

Lead is used in various industries: battery, glass and mining sectors, for example.
Mercury is present in many pesticides and pickling baths. Nickel is present mixed with
other metals in various alloys. Chromium compounds are widely used in industry, and
may cause birth defects if mothers are exposed to them during pregnancy.

ACIDS AND BASES - Strong acids and bases are mostly used as water solutions. They
are corrosive to human tissue. Working with acids or bases can give rise to mists that
have the same corrosive properties as the solutions.

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 Serious damage can result when treating metal pieces in an acid bath (with phosphoric
acid for example).

PESTICIDES - Pesticides are intended to destroy or control pests of all kind. They are
used in industry, for example, to impregnate wood, and in agriculture to control insects,
weed, fungi, and rats. There are many different types of pesticide compounds or
mixtures.

Insecticides are divided into the following broad groups, among them organophosphorous
compounds (often acutely poisonous to both insects and humans), organochlorine
compounds and carbamates (insecticides and fungicides).

Source: ILO. “Training Modules on Chemical Safety: Introduction to Safety in the use of chemicals”
http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/introduc.htm
(last accessed 2 April 2008)

IDENTIFICATION OF EXPOSURE CHARACTERISTICS

After identifying where the problems are, what the dangerous substances are,
and what damage they entail, it is necessary to further define the magnitude
and severity of risk in each situation.

Magnitude and Severity of a Risk = Hazard + Exposure

The hazard potential of a substance (toxicological and ecotoxicological hazard)

depends on its physico-chemical properties. To determine the risks associated
with its use, the circumstances and conditions of use that make the risk possible,
i.e., the risk factors, must be known.

Eventually, regardless of the conditions of usage and the prevention measures

taken some chemicals should still be banned. These substances belong to black
list of chemicals, and their elimination is a priority for trade union action.

Box 2.7. Example of trade unions’ Black List of chemicals

Family Associated EU R-Phrases

Carcinogenics R 40, R 45, R 49
Mutagens R 46, R 68
Toxics to reproduction R 60, R 61, R 62, R 63
Endocrine disrupters There are no R-Phrases associated
Sensitizers R 42, R 43, R 42/43
Neurotoxics R 67 and others which do not have R-
Phrases associated
Toxic, persistent and bioaccumulative R 53 and 58 and others which do not have
substances R-Phrases associated

Source: Based on the list elaborated by ISTAS. Union Institute of Work, Environment and Health of
CCOO

This means to lay out the dangerous properties of substances in relation to their
conditions of use or handling, i.e. the risk factors.

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The risk factors, i.e. the conditions of use and handling, include:
• Work organization and rhythm of work. Experience shows that these
are the two conditions that most determine chemical risk, as overexposure
and unnecessary exposure are the cause of many accidents;
• Physical activity accelerates the breathing rhythm and therefore enables
a larger amount of toxics to penetrate into the organism (inhalation is the
major route of entry);
• Working hours: Prolonging the number of working hours increases the
duration of exposure to contaminants;
• Micro-clime: Working conditions such as temperature, humidity and
ventilation can increase exposure. High temperature fosters the
evaporation of volatile substances. High humidity can foster the presence
of hydrosoluble substances in the air;
• Specific individual conditions: Younger or older workers, pregnant or
breastfeeding women, workers with weak or sensitive health, etc are likely
to be more sensitive;
• Lack of information among workers about the products they use or lack
of adequate training about chemical risk; and
• Whether there are or not effective measures to control occupational
and environmental exposure.

The best way to identify each risk situation is to undertake regular visits and
inspections through the different stages and posts of production, as well as to talk
regularly to affected workers.

This information will be summarized in a flow chart indicating the types of risk
and their causes at each stage of the production process, detailing the post and
level in the production process concerned.

What to do?

IDENTIFICATION OF RISK SITUATIONS:

A good way to proceed is to organize the collection of information according to the
following steps. Annex 2 Card 1A and annex 2 card 1B can be of help:
1. Divide the physical space or productive process into smaller units and sections of
analysis. Sort them into a diagram or map (see as an example annex 2 card 1A).
2. Identify the processes and tasks where chemicals are used or simply present.
3. Identify the processes or tasks that generate emissions, spills or waste by-products of
chemical substances.
4. Collect the information on a sheet (see as an example annex 2 card 1B) including
all the products present in the production process, whether they are dangerous or not,
and all the resulting products and wastes.

IDENTIFICATION OF HAZARDOUS SUBSTANCES:

1. Organize information collection keeping in mind the particular problem to solve: to
avoid the possible harm that chemical substances present in the workplace can cause.
2. Remember that chemical substances can be present in the workplace, either because
they are produced or used there, or are waste products that result from non-
intentional releases.
3. To know the existing risks in each situation or task, all products must be listed,
relevant information must be collected and structured, (see as an example annex 2
card 2) and should include:
The name of the product or mix;
The active ingredients that compose it;
Human security and safety risks; and
Environmental risks.

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IDENTIFICATION OF CHARACTERISTICS OF EXPOSURE:
1. Collect and organize information in a way that clearly identifies the production process:
tasks, associated risks, etc. (see as an example annex 2 card 3)
2. Make a brief description of each risk, taking into account the information on the
products and substances, and the information about related reasons and factors of
risk. (see an example annex 2 card 2) (see as an example annex 3 A and
annex 3 B)
3. Try to establish a relationship between risks and their causes.

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 Unit 3: IS YOUR JOB PUTTING YOU AT RISK? QUALITATIVE
RISK ASSESSMENT

This unit will mainly address the following issues:

1. What are the potential risks in the workplace?

2. What is a qualitative risk assessment?

Risk assessment aims at obtaining the necessary information to make an

appropriate decision on whether and how preventive measures should be adopted.

Technical assessments are not always necessary to evaluate, act, eliminate or

control a risk. Actually, on many occasions, the risk is so obvious and its solution
so evident that any prior formal evaluation is simply a waste of time and money.

In this section it is not expected that a technical evaluation of the risks will be
carried out, nor taking samples and developing measurements of the
contaminants or other technical actions. On the contrary, it is proposed that the
importance of the identified risks along with the need to act on them be evaluated
from available documentation and the information collected during the visits and
the talks/interviews undertaken with workers. This method is called qualitative
assessment.

It will be useful to analyse the information collected until then, based on:
• Hazardous properties of substances (toxicity, etc.);
• Exposure characteristics: level, type, duration;
• Conditions of use and factors of risk;
• Record of inconveniences or illnesses related to exposure to chemical
products;
• Existence of wastes, emissions or non control of spillage; and
• Workers’ opinions on the risk.

Among the different qualitative models available to evaluate risk, many Unions
propose to use the Column Model, which is considered as one of the easiest and
the handiest. Based on the R-phrases (see annex 1-B), the Column Model
permits to classify each substance according to different levels of risk. In case of
doubt, the immediate higher level of classification should be systematically
selected.

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Box 2.8. The Column Model
In case of doubt, the immediate higher level of classification should be systematically selected.

Chronic
Acute health
health Fire and
Risks: hazards Environmental Hazards caused by
hazards explosion Exposure potential
level/type (single Hazards procedure
(repeated hazards
affection)
affection)
Gases;
Liquids which evaporate at
R26, R27, R2, R3,R12,
Very high R45, R49 room temperature;
R28, R32 R17
Dust producing solids;
Open processing;
R50, R51, R53, Aerosols.
Possibility of direct skin
R54, R55, R56, R1, R4, R5,
contact;
R23, R24, R57, R58, R59 R6, R7, R8,
R33, R40, Application on large area.
R25, R29, R9, R11, Liquids which evaporate
High R60, R61,
R31, R32, R15, R16, between 30 and 50°C
R68
R42, R43 R18, R19,
R30, R44
R20, R21,
Liquids which evaporate
Medium R22, R34, R63 R52, R53 R10
between 50 and 150°C
R41, R64, Closed processing but
Others (no Hardly exposure possibilities e.g.
R36, R37, R-Phrase flammable when filling sampling or
Liquids which evaporate at
Low R38, R65, associate, substances/ cleaning
more than 150°C
R66, R67 but preparations
hazardous (55-100°C)
Inflammable
or very
Tightly closed equipment;
Harmless substances by hardly
Liquids which evaporate at Closed equipment, with
Negligible experience (e.g. sugar, flammable
more than 200°C exhaust facilities at points of
water, paraffin and similar) substances/
emission.
preparations
(100°C)

Source: Based on the classification provided by Berufsgenossenschaftliches Institut für Arbeitssicherheit (BIA) www.hvbg.de/bia

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What to do?

1. Check the hazard potential of the existing chemical substances (see as an

example annex 2 card 4);
2. Carry out regular inspections with standard checklists for particular chemicals and
chemical processes;
3. Investigate workers’ complaints;
4. Use accident and sickness records;
5. Survey regularly workers’ health;
6. Monitor environmental and biological parameters;
7. Investigate the causes of accidents and their prevention; and
8. Develop a workplace chemical register.

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 Unit 4: GET PRIORITIES RIGHT! PLAN OF INTERVENTION

This unit will mainly address the following questions:

1. What are the principles for operational control of chemical hazards?

2. What control measures should be implemented for safe storage, disposal,
and treatment of chemical waste?
3. What control measures are needed to guarantee safe transport of
chemicals?

CONTROLLING THE HAZARD: PRINCIPLES FOR OPERATIONAL CONTROL

The general objective in the control of hazards relating to chemicals in the

workplace is to eliminate risks or reduce the potential hazard to the lowest possible
level in relation to their contact with workers or the environment, as well as to
minimize the possibility of a fire or an explosion.

1. Ideally, the best means of preventing diseases, injuries, fires and explosions
caused by chemicals would be to rid the working environment of such
chemicals, eliminating risks through application of the precautionary
principle. No severely hazardous chemical should be authorized in the
workplace, regardless of whether or not a substitute exists;
2. When strict prevention is not possible, the risk may be reduced or eliminated
through substitution. However, no substitute is 100% safe.
3. When prevention and substitution are not feasible, risks should be reduced
via control mechanisms that include the following options:
Engineering controls – enclosing, isolation, silencer, etc.;
Management controls – warnings, e.g. do not smoke while spraying;
Personal Protective Equipment (PPE) – e.g. gloves, goggles, coveralls,
apron, masks, etc; and
Personal and environmental hygiene.

SUBSTITUTION OF HAZARDOUS CHEMICALS OR PROCESSES WITH LESS HAZARDOUS ONES

Extremely hazardous chemicals should be removed from the workplace even where
substitutes are not available.

Elimination of hazardous substances can take place in two different ways, through:
• Substitution for other substances that are less hazardous; or
• Modification of the production process.

However, care must be taken to obtain all available information on proposed

alternative chemicals. Indeed, substitutes may turn out to be just as hazardous as
or even more hazardous than the materials they replace. As noted in the graphic,
below, there are a number of direct and indirect benefits associated with actions
that are taken to reduce and eliminate hazardous substances. More can be found
about substitution guidelines in unit 5.

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 Box 2.9. Benefits associated with reducing or eliminating hazardous substances
in the workplace

Direct Benefits Indirect Benefits

• Reduce occupational health
risks;
• Reduce damage (illnesses,
accidents) and absenteeism;
• Reduce environmental risks;
• Improve security;
• Reduce costs related to risks.
• Improve the image of the
enterprise/company;
• Improve labour relations;
• Motivate the creation of some
posts/sections/departments
within the enterprise such as
occupational and health
departments, environmental
department, etc.;
• Improve on productivity and
profitability of the company
through decrease in medical
expenses, absenteeism,
presenteeism, etc.

Presenteeism is defined as lost productivity that occurs when employees come to work but perform
below par due to any kind of illness or emotional problems (anxiety, stress), based on Paul Hemp,
Presenteeism: At Work--But Out of It – Harvard Business Review HBR.

Source: Based on ISTAS. “Chemical risk prevention in the workplace. Guide for intervention”
http://www.istas.net/web/abreenlace.asp?idenlace=1367

ENGINEERING CONTROLS AND VENTILATION

If a chemical hazard cannot be eliminated from the workplace by resorting to
substitution, then the next best solution is to physically enclose or isolate the
hazard to prevent it from coming into contact with either workers or the
environment. This is known as total enclosure or containment of a process.

However, with this option, the source of the hazard should be monitored first; if this
is not possible then the pathway should be monitored, before the worker is.

Box 2.10. Description of total enclosure or containment of a process

(Source) (Pathway) (Target)

Chemical container Worker

Source: Based on input of Yahya Msangi

For example, open tanks from where chemical vapours can escape into the
workplace air can be replaced with closed tanks with inlet and outlet ports for filling
and emptying. Ventilation systems are a means of removing contaminated air
from the workplace. However, attention should be paid to the filters used, as it can
easily happen that chemical vapours are released into the environment, polluting
the water and soil which workers and other come into contact with in many other
ways. Proper calibration of spray equipment is another example of engineering
control.

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MANAGEMENT CONTROLS
Management control measures to control occupational and environmental exposure
should only be considered when there is no possibility to eliminate the risk.
Different management control mechanism can be applied to reduce exposure to
chemicals:
• Restricted entries: Only those directly involved with a chemical process
should be exposed to any chemical hazard. Maintenance workers,
electricians, cleaners or any other workers should do their work when the
chemical hazard is not present.
• Special attention to high-risk groups: The risk to high-risk groups, e.g.
maintenance workers, pregnant and nursing women, spray teams,
young and health sensitive workers, is often ignored or seriously
underestimated when planning chemical control measures. These workers
may be more highly exposed because of the nature of their duties, biological
and physiological factors or state of health.
Specific provisions for the protection of high-risk workers must be included
in any chemical safety procedure.
• Job rotation: In certain circumstances, the reduction in the duration or the
frequency of exposure of workers is achieved by job rotation. However, it
is simply not acceptable to expose more workers less often to significantly
high levels as an alternative to reducing exposure levels.
• Observing re-entry intervals in sprayed places: Management should
make sure it has all information on recommended re-entry intervals for all
chemical and these are displayed at entry points of all sprayed places.
Management must educate workers on the importance of observing re-entry
intervals.

USE OF PERSONAL PROTECTIVE EQUIPMENT AND PERSONAL HYGIENE

Whereas engineering controls place a barrier around a hazardous process or
chemical, personal protective equipment is often used to create a "barrier" around a
worker, thus preventing his/her exposure to chemicals. The use of personal
protective equipment (PPE) should only come as additional protection after the
methods outlined above (substitution and engineering controls) have first been
considered and implemented.

Personal protective equipment is rated as the least effective method of protection

and is often uncomfortable or difficult to work with. Personal protective equipment
against chemicals includes:
• Face shields, goggles and safety glasses;
• Gloves;
• Rubber boots;
• Plastic or rubber overalls and aprons;
• Hard hats;
• Respirators; and
• Dust masks.

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A personal protective equipment programme requires the following steps and
resources:
• the correct equipment - e.g. a respirator designed to protect against dust is
useless if the hazardous chemical is present as a gas; moreover many
solvents can rapidly penetrate natural rubber gloves;
• A thorough training programme for workers who are required to use the
equipment, with follow-up training at regular intervals;
• Tests to ensure that equipment fits correctly; such tests are particularly
important for face masks and respirators;
• A regular equipment maintenance and storage programme. This includes
regular cleaning of equipment, inspection to ensure that it is operating
correctly and regular replacement of items such as gloves or disposable
parts such as respirator filters (which should be replaced at regular time
intervals rather than only when they have become clogged); and
• A personal set of equipment for each worker, and a secure and clean place
in which to store it.

Personal protective equipment should be appropriate to the hazard.

Great care should be taken to fit the equipment to the worker.
Equipment should not be perceived as a nuisance or a trouble to
develop tasks, otherwise it will not be used.

In some situations, the use of personal protective equipment cannot be avoided.

This applies particularly to eye goggles, face shields, boots and hard hats. Because
these items are designed to protect the worker against accidents and unexpected
exposures, they must be worn at all times.

Personal hygiene is very important to protect the body against anything harmful
remaining on it for long periods, especially since it can be absorbed through the
skin. Examples of actions that can be taken are: to keep fingernails clean and short,
not to carry contaminated items such as dirty rags or tools in the pockets of
personal clothing, and to remove and wash separately any contaminated item of
personal protective clothing daily.

At the same time, it is equally important to avoid inhaling or ingesting small, even
minute, quantities of chemicals because of their harmful effects on health. This
concern reinforces the importance of drinking, eating or smoking away from
possible exposure areas.

Box 2.11. Use of PPE

Pesticide spraying

For some jobs, such as pesticide spraying by hand, no other means of protection is
possible. In this case, protective clothing, gloves and respirator masks must be worn.

Wood dust

Wood dust consists of tiny particles of wood produced during processing and handling of
wood, chipboard, hardboard etc. It can be harmful to health and can explode with
disastrous results. Exposure has been associated with the following health problems: skin
disorders; obstruction in the nose; a type of asthma; and a rare type of nasal cancer.

77
 It is a sub product, the result of an industrial process, and cannot be substituted. Thus, the
only way of reducing risk from wood dust is to:
• Provide personal protective equipment, such as eye protection, overalls and gloves.
Make sure it is suitable and kept in good order. Launder overalls and aprons
regularly.
• Make good washing facilities available, with hot and cold water, soap and towels
and encourage a high standard of personal hygiene.
• Provide vacuum cleaning equipment to remove dust from clothing, where this is a
problem. Prevent the use of compressed airlines.

Make sure workers are adequately instructed, trained and supervised. This is essential if
they are to understand the precautions necessary, and their duties and responsibilities in
applying them.

Source: Based on the UK Health and Safety Executive Committee

http://www.hse.gov.uk/woodworking/dust.htm

TECHNICAL EVALUATION: OCCUPATIONAL AND ENVIRONMENTAL SURVEILLANCE

Since elimination of chemical risks is a long-term task, technical evaluations
on the occupational and environmental risks should be undertaken. To develop this
evaluation the assistance of experts (doctors and others) is necessary to carry out
medical examinations on workers (blood tests, urine tests, etc). The same applies
to environmental tests.

There are two types of technical evaluation: environmental monitoring

(ecotoxicological monitoring) to measure the level of contaminants in the
environment (air, water, soil, fauna and flora) and biological monitoring of
individual workers to test for degree of exposure, whether dermal, respiratory, via
ingestion, etc.

The results of these samples should be compared with the threshold limit value
(TLV) and Time Weighted Average (TWA) - average exposure on the basis of a
8h/day, 40h/week work schedule - to see whether or not a worker’s exposure is
under or above what is recommended, and to act accordingly.

As noted in an earlier section, TLVs are good tools for practical action in case the
result exceeds recommended levels. However, while being under the TLV is
important, it is not a full guarantee of safety. Even when the results of
environmental monitoring controls are under 50% of the reference threshold limit
value (called as Level of Action), preventive measures such as the revision of the
proper functioning of the systems implemented, realization of new controls, job
rotation, among others, may still be required to avoid possible contamination.

CONTROL MEASURES FOR THE STORAGE, DISPOSAL, WASTE AND TREATMENT

CONTROL MEASURES FOR THE STORAGE OF HAZARDOUS CHEMICALS

Safety Data Sheets from the manufacturers or suppliers of chemicals should give
specific instructions on the storage of each chemical. These instructions must be
strictly respected, as storage requirements vary according to the nature of the
chemical. Incorrect storage can have disastrous results, e.g. fire, explosion or
release of toxic chemicals.

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Several factors need to be taken into account in reviewing the Safety Data Sheets:
• Certain chemicals require must not be stored together (need for isolation),
given the possibility that vapours or leaks may, if they intermingle, lead to
an explosion.
• The chemicals must be kept away from food, drink and animal feed, and
stored at a temperature below their flash points. The storage temperature
must obviously be below the auto-ignition temperature. Chemicals with flash
points below 34°C are especially dangerous.
• SDSs often specify a "well-ventilated" storeroom for particular chemicals,
and it is essential to comply with this requirement. More specific guidance on
the amount of ventilation required can be obtained from the manufacturers
of the chemicals, and the actual levels of ventilation in the workplace can be
checked by an industrial hygienist or ventilation engineer.
• Chemicals may react with the material from which containers are made. It
is thus important to have information about the type of container used,
which should be specified on the SDS. This is especially important if
chemicals may be transferred from one container to another. There may be
additional requirements, such as pressure relief valves, which are relevant to
the storage of particular chemicals.
• The type of flooring should also be specified, as it must be resistant to,
and not potentially reactive with, the chemical being stored.
• The low walls or embankments (referred to as dykes or bunding) that are
constructed around the storage area should be sufficiently high to contain
any leaks that may occur from storage containers, as well as any water or
foam that may be sprayed in the event of a fire.
• Alarms also are recommended in areas where potentially dangerous
chemicals are stored in order to give early warning of releases of those
chemicals.

DISPOSAL CONTROL MEASURES: WASTE AND TREATMENT OF CHEMICALS

Given that enormous volumes of waste are generated in the production and use of
chemicals, waste disposal is a key issue in health and environmental protection. As
with protection of the workplace, a hierarchy of controls should be applied when
dealing with chemical waste, as follows (see box 2.12. for more details):
• Reduction of waste at the source;
• Segregation of waste;
• Recovery and recycling;
• Waste exchange;
• Incineration;
• Immobilization of intractable wastes;
• Landfill storage;
• Discharge into sewer; and
• Other forms of temporary or final storage.

The volume and toxicity of hazardous waste can be reduced by modifying a process
or by improving process controls.

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 Box 2.12. Different waste treatments

Recycling: The best-known form of recycling is the recovery of useful fractions for reuse.
These processes are usually carried out by specialist recovery operators off-site and
involve recovery of materials such as oils and solvents, as well as other valuable materials,
such as silver in photographic waste.

Waste exchanges: A considerable amount of waste is suitable for exchange. The aim of
the exchange is to put potential users of waste materials in touch with industries that
produce the waste, and vice versa. Waste exchanges reduce the volume of wastes
requiring landfill or incineration.

Incineration: This process involves burning wastes in special high-temperature (1,200°C)

incinerators. Incineration effectively destroys many organic wastes. Additionally, the
energy in solvent and fuel waste can be exploited in the process. However, inorganic
chemicals such as plastics are likely to cause pollution problems when incinerated, as
dangerous dioxins and furans may be formed if some organic materials are incinerated
improperly, e.g., at very low temperatures.

Encapsulation: The waste is sealed within a stable, inert material to prevent contact with
the environment and prevent movement (migration). If the encapsulating jacket were
broken, the waste could leach away. Encapsulation is better suited to those wastes that,
while posing a handling hazard, are relatively inert once buried (e.g. asbestos).

Landfill: Landfills are used for most residual solids or pastes because they are of smaller
volume and less likely to migrate through the soil. A number of solid hazardous wastes
require the higher degree of safety afforded by secure landfill, whereby waste is poured
into small cells lined with an impermeable clay or synthetic material, and subsequently
buried under a layer of soil. However, there are potential problems of infiltration by
rainwater and it is not always easy to ensure permanent maintenance of the cell if the
company relocates its operations or closes its business.

Disposal of less hazardous waste to the sewer: This is generally not recommended.
Improper disposal to the sewer can disrupt the biological treatment of sewage and
represent a hazard at sewer outfalls. In addition, toxic chemicals (e.g. heavy metals) may
accumulate in the sewage sludge and create hazards when they are disposed of.

Storage of intractable wastes: A large volume of hazardous waste is currently stored -

usually in steel drums on industrial sites, awaiting the development of satisfactory disposal
methods - because it is too toxic to be legally disposed into air, water or landfill sites. Most
drums are stored in the open, and many contain corrosive materials. There is an added
risk of hazard from fires, structural damage and vandalism of such toxic waste stores. It is
likely that some of these drums will corrode and leak. In some countries, such stores must
be registered with authorities who, in turn, have a duty to inspect them.

Source: United Nations Environment Programme (UNEP) / International Labour Organization (ILO) /
World Health Organization (WHO). “Users’ Manual for the International Programme On Chemical
Safety (IPCS)”., Health And Safety Guides http://www.inchem.org/documents/hsg/hsg/hsgguide.htm
(last accessed 2 April 2008)

CONTROL MEASURES FOR SPILLAGE

Many spills can be prevented by thorough planning of work, provision of suitable
equipment, regular preventive maintenance and good training of workers. Any
spillage that do happen should be thoroughly investigated and remedial action
taken to prevent their recurrence.

Employers should ensure that they have the necessary plans and equipment to deal
with spillages, that the workforce and their representatives have been consulted
about all such planning, and that the necessary training is carried out regularly.

80
When a spillage occurs, suitable precautions must first be taken to protect workers
from the dangers of the chemical (fumes, burns, etc.) before steps are taken to
deal with the spillage itself.

Some general measures that may apply include the following:

• Use self-contained breathing apparatus and full protective clothing, when
applicable;
• Remove ignition sources;
• Do not smoke;
• Evacuate the area, if necessary at one’s own initiative, as every single
worker has the right to remove himself/herself from imminent danger;
• Collect leaking liquid in sealable containers;
• Prevent liquid from spreading or contaminating other areas, vegetation,
waterways and cargo, with a barrier of the most suitable available material,
e.g. soil or sand;
• In some cases (e.g. hydrazine), a foam can be applied to slow down
vaporization;
• Absorb spills in sand, soil, moist sawdust or other inert material and transfer
them to a suitable container; then remove to a safe place, and dispose of
them in accordance with local regulations;
• Sweep up solid products, and transfer to a suitable container; and
• Depending on the chemical, do not allow run-off into sewers: it may cause
an explosion, kill wildlife or affect water supplies.

CONTROL MEASURES FOR THE TRANSPORT OF CHEMICALS

Transport is necessary for products to reach consumers. The transport and storage
of dangerous chemicals and goods has increased, as commerce has expanded, due
to technical and production advances. The export of used toys, motor vehicles and
electronics equipment can be a route through which hazardous chemicals are
transported from developed to developing countries. These products may contain
highly hazardous chemicals such as lead, cadmium and phthalates.

The hazardous properties of products or chemicals should be clearly stated so that

people at all stages of the transport chain are aware of them. This information
should always track the goods so that people can recognize the risks, avoid
accidental mishandling, and have the right kind of the personal protection at their
disposal in case of leakage.

Dangerous goods can be transported without causing unnecessary

hazards if handled properly and with care.

Empty containers and packages of dangerous goods can present the same hazards
as the chemical substance or product that they contained. It is therefore important
to also treat them as dangerous goods.

Major accidents cause extensive damage, but so can smaller ones. It is forgotten
easily that small amounts of oil, gasoline, battery acids and refrigerator fluids are
released into the environment daily. Even small but frequent wastes from ships,
households, cars or agriculture increase the contamination of the environment.

81
Recommendations and instructions for the handling, storage and transport of
dangerous goods must be clear and unambiguous to avoid harmful or dangerous
circumstances.

Under normal conditions, transport of dangerous goods does not pose a greater
danger than the transport of any other goods, provided the transport chain respects
the existing recommendations and laws, and are aware of the type of hazards that
the cargo bears.

There is always a risk of spillage during the transport of hazardous goods. When
incompatible substances mix with each other there is a possibility of a chemical
reaction, which can produce enough heat to cause fire or explosion and can release
dangerous gases. For example, toxic nitrous oxides are formed when ammonium
nitrate (in fertilizers) decomposes in a fire. Another example involves the toxic
gases that fume off when a spillage of concentrated sulphuric acid is absorbed in
sawdust.

Spillages are possible in the following situations:

• Goods not properly packaged;
• Handling without reference to the contents: loading, unloading, etc. in the
event of missing or incomplete labelling;
• Fire, either when the load or the vehicle is burning;
• Collision or capsize; and
• Defects in tightness or incomplete closing of valves and connections.

The United Nations published a book collecting the work of the Committee of
Experts: UN Recommendations on the Transport of Dangerous Goods30.
This has been largely incorporated into the Globally Harmonised System of
classification and labelling which covers the processes of production, storage and
transport.

What to do?

To plan action taking into account the aforementioned, you can use a guide as a chart like
annex 2 card 5 which will help you to structure the following information and data to:

Identify clearly the risk situation and establish the priority to act on it;
Order priorities from higher to lower level risk;
Establish objectives, such as to eliminate risk, to inform workers, or to establish
control measures;
Get information about the measures and procedures of action that are more
adequate. Consult technical officers and workers;
Analyse information and select the actions; and
Submit the flowchart of actions to the working centre with an estimated budget for
their consideration.

30 http://www.unece.org/trans/danger/publi/unrec/mr_nature_e.html (last accessed 15 April 2008)

82
 Unit 5: SAFE CHEMICALS – SAFE PRODUCTS
GUIDELINES TO ENFORCE THE “SUBSTITUTION PRINCIPLE”

This unit will mainly address the following questions:

1. How can the “substitution principle” successfully be implemented?

2. How to identify safer substitutes for chemicals?
3. How to evaluate the economic, environmental and social viability of
potential substitutes?

One of the most efficient and effective way to reduce chemical hazards is the
application of the “substitution principle”. This can be achieved either by
substituting:
• The substance, for an another without affecting the productive process;
• Equipment and procedures without affecting the productive process; or by
• An auxiliary substance or primary resource that modifies the productive
process.

For any of the three cases of substitution of substances or processes, necessary

steps are as follows:

Box 2.13. Phases to implement the substitution of substances or processes

Informative phase

1 IDENTIFICATION OF THE PROBLEM

.

2 INFORMATION ABOUT PROCESSES AND SUBSTANCES

3 ESTABLISHMENT OF SUBSTITUTION CRITERIA

Executive phase

4 RESEARCH/STUDY OF ALTERNATIVES

5 EVALUATION OF ALTERNATIVES

6 PILOT EXPERIENCE

If it works If it does not work

Follow-up and control phase

7 IMPLEMENTATION OF THE SUBSTITUTION

8 REVISION AND RISK EVALUATION

Source: Based on ISTAS. “Guide for the substitution of dangerous substances in the workplace.
Practical guidelines for intervention” http://www.istas.net/web/abreenlace.asp?idenlace=2428

83
IDENTIFICATION OF THE PROBLEM

The first steps involve identifying the problem. It is important to remember,

though, that identification of the problem is not the only action required in
dealing with the risk to eliminate. It is also crucial to know the circumstances and
factors that help assess how necessary it is to implement substitution. For that
process, it is necessary to determine how substitution would be achieved, and
why it is needed.

INFORMATION ABOUT PROCESSES AND SUBSTANCES

As part of these first steps, in compiling information it will be needed to put

together a “basic card” of the workplace and the activity, to know what hazards and
risks exist in the workplace, and which ones are being targeted for elimination.

It is suggested to compile basic information with regard to the identification of the

substance or product (see box 2.14.), based on a number of questions on the tasks
normally developed in the workplace (see box 2.15.).

Box 2.14. Identification of the substance to substitute

WHO or other HARMFUL

SUBSTANCE CAS No, ICSC No.
CLASSIFICATION* EFFECTS
Possible
carcinogen
(IARC3).
Sensitizer.
Toluene Neurotoxics.
108-88-3
Affects
reproduction.
Persistent
Bioaccumulative
and Toxic (PBT)

* Based on national legislation

Source: Based on ISTAS. “Guide for the substitution of dangerous substances in the workplace.
Practical guidelines for intervention” http://www.istas.net/web/abreenlace.asp?idenlace=2428

Workers also need as well to know the functions of the chemicals, so that they can
answer questions such as “why is it used” and “how is it used in the process”.
Sometimes, chemicals are used but workers might not know why.

In the course of the exercise, workers might find that there is a lot of information
needed that is not available. The labels and the safety data sheet (SDS) should
provide basic information to identify adequately the substances and products used.
Where SDSs are not directly available, in principle the employer has to provide
them to the workers. Alternatively, a search can be conducted for guides and
leaflets on the equipment and products used at work. In pursing the information,
workers may find that the equipment and products are often not used properly.

84
Questions to raise, among others:
• “What tasks do I perform?
• Why do I carry them out in such a way?
• Which risks do they entail?
• Could I do it differently?
• Why do I use this product?
• Which effects it has?
• Could I use another product?
• Could I use different tools?”

In accordance with the objectives and principles of the Occupational

Safety and Health Convention, 1981 (n. 155), and Recommendation,
1981 (n.164), employers should make available to workers and their
representatives chemical safety data sheets or similar relevant
information of the chemicals used at work.

ESTABLISHMENT OF SUBSTITUTION CRITERIA

Substitution criteria are established in two different ways, by identifying:

• Those chemical substances that are priorities for substitution among all the
chemicals that are being used; and
• The alternative substance which would be most appropriate.

It is important to bear in mind a key principle in approaching substitution:

When searching for an alternative, do not think of the process of

substitution as if it were completely free of danger. Instead, it should be
viewed as fulfilling an objective focused on eliminating a risk previously
established. Be careful: make sure that the alternative presented does
not just shift an equivalent or higher risk to another part of the process.
This would only perpetuate the problem, and perhaps even make it
more difficult to remedy.

Taking into account this definition, establishing objective criteria to search for
alternatives is critical. The following table presents actions and strategies that
should be followed as part of the substitution process.

85
 Box 2.15. Criteria for the election of alternative products

Information available The first criteria to decide for one or

another product or substance should be
the information accessible: composition,
intrinsic hazard, use and applications,
safety card, etc.
Essential information on a potential
alternative substance must be at least as
complete, in terms of type and amount, as
information on the substance to be
substituted.
Avoidance of halogenated substances All components that incorporate bromine,
fluorine or chlorine have characteristics
involving high persistence in the
environment, and a high degree of toxicity
in human beings.
Preference of mechanic, physic or The alternatives based on mechanical,
biological options instead of chemical physical or biological options normally
substances present much lower levels of risk than
those related to chemical substances.
Avoidance of most hazardous All chemical substances present intrinsic
substances and products hazards. When selecting substitutes, those
substances that cause major harm for
human health and the environment have
to be always avoided.
The absence of information on potential
harmful effects does not mean the
substance is safe.
Preference for easy and compatible The action of any chemical substance or
products product is based on an “active principle”
which determines its properties: cleans,
disinfects, protects, etc.
Normally this “active principle”
characterizes the substance, or, in limited
situations it characterizes a combination of
different substances. In all cases, it helps
get information that is relevant to
individual, specific substances or products.

Source: Based on ISTAS. “Guide for the substitution of dangerous substances in the workplace.
Practical guidelines for intervention” http://www.istas.net/web/abreenlace.asp?idenlace=2428

RESEARCH/STUDIES AND THE EVALUATION OF ALTERNATIVES

At this stage, an initial, informed and objective evaluation needs to be developed,

which will eventually help take sound decisions in a quick and independent manner.
The elements to take into account in the evaluation are the following:
• Impacts on human and environmental health;
• Technical viability;
• Economic and costs viability;
• Social impacts.

In pursuing that objective, summarizing in a matrix all the information collected on

the alternative substance and the substance to replace can be useful for
comparison purposes. The following table provides a good structure for carrying out
this comparative analysis.

86
Box 2.16. Informative matrix on the effects of selected chemicals

Exposure routes Acute effects Chronic effects Environment

Irritant To be specified To be specified
Carcinogenic Persistent
Reproductive system Bioaccumulative
Nervous system Toxicity
Inhalation
Contact Ingestion Liver/kidneys Water polluter
(respiratory Respiratory
(skin) (digestive tract) Skin Eyes Respiratory system Air polluter
tract) system
Endocrine disrupter Soil polluter
Damages ozone layer
Volatile components
Toxic waste
Substance
CAS N.
*Perchloroethyl Possible carcinogenic Eco-toxic, water
ene Affects nervous system pollutant, volatile
(PER) 127-18-4 √ √ √ √ √ √ and kidneys compound

** Trementine Water pollutant, volatile

essence compound
√ √ √ √ √ √
(turpentine)
8006-64-2
** D-limoneno Water pollutant, volatile
√ √ √ √ √ √
5989-27-5 compound

* Substance to be substituted
** Possible alternatives

Source: Based on ISTAS. “Guide for the substitution of dangerous substances in the workplace. Practical guidelines for intervention”
http://www.istas.net/web/abreenlace.asp?idenlace=2428

87
It is also important to underline some working methodologies such as “Alternatives
Assessment Framework” that is designed to evaluate and identify environmentally
and socially preferable alternatives. “Alternatives” encompass production processes,
chemicals, materials, products, economic systems (such as transportation systems),
and functions, as well as eliminating the need for a current activity or the function
of a product.31

Where to get more information?

Sources of information to identify alternatives:

Toxic Use Reduction Institute – Massachusetts - http://www.p2gems.org/
Pesticide Action Network Database - http://www.pesticideinfo.org
ISTAS alternatives database: Includes over 300 documents in Spanish language on
alternatives to reduce or eliminate chemical risk, classified by substances, uses, processes
and sectors - http://www.istas.net/ecoinformas/web/index.asp?idpagina=576
Campaña de tóxicos de Greenpeace España - http://www.greenpeace.es/toxicos/toxi_0.htm
Solvent Alternatives Guide - http://clean.rti.org/
Alternatives Assessment Framework of the Lowell Centre for Sustainable Production
http://www.chemicalspolicy.org/downloads/FinalAltsAssess06.pdf

PILOT EXPERIENCE

Before introducing an alternative, it is highly advisable to develop a pilot project

that uses this specific substance at some point in the production process for the
purpose of testing it.

At this stage, how the alternative is presented will be extremely important. The
attitude and perception of directly affected workers and other people are key to
obtain as much information and feedback as possible from the pilot experience, and
to ensure that the experience works properly and successfully.

The results of the pilot experience must be properly evaluated and taken into
account in order to assess the viability of the proposed alternative on an industrial
scale.

IMPLEMENTATION OF THE SUBSTITUTION

Once the previous steps have been successfully covered, the alternative of
substitution considered is more likely to be viable.

REVISION AND RISK EVALUATION

The introduction of a safer substance in replacement of another one does not

guarantee the total elimination of risk. For this reason, it is necessary to carry out
regular evaluations that consider the new existing risks, as well as to set-up any
necessary preventive measures to initiate effectively a process of substitution.
Workers have an important role in the promotion of substitutes.

31 Based on Lowell Centre for Sustainable Production (2006). “Alternative Assessment Framework”
http://www.chemicalspolicy.org/downloads/FinalAltsAssess06.pdf (last accessed 14 April 2008)
 Unit 6: KEEP AN EYE ON WHAT IS HAPPENING! HEALTH AND
ENVIRONMENTAL SURVEILLANCE AND FOLLOW-UP

This unit will address the issue of surveillance and follow-up.

SURVEILLANCE AND FOLLOW-UP: EVALUATION, EFFICIENCY AND REVISION

There must be a follow-up of the measures of prevention and control of chemical

risk, included in the national legal framework, to make sure that there is effective
and efficient implementation.

Once chemicals risks have been evaluated and the prevention plan has been
elaborated, a variety of potential exposure parameters must be selected for further
monitoring purposes. This is necessary to determine whether the risk has been
completely eliminated, or because of peculiarities and specificities of the workers
exposed (e.g. pregnant women, the need to use personal protective equipment
(PPE), etc.).

Undertaking health surveillance of various areas of risks which, in principle, have

been controlled and eliminated, is necessary to make sure that the objective of risk
elimination has been achieved. In addition, periodic evaluation of potential health
and environmental impacts must be undertaken, and become necessary as a result
of:
• Modifications of the production mass, materials or process;
• Record of new cases of occupational diseases or impacts on the
environment;
• Accidents or incidents;
• Figures on occupational or environmental health which illustrate risk;
• Changes in the knowledge of risk;
• Legislative changes; or
• New methods or technologies to control risk;
• Staff turnover or new management staff; and
• Change in microclimate or buildings.

What to do?

Identify the situations of risk and where risk is located;

Specify measures to adopt actions proposed and agreed with the working centre;
Indicate starting and closing dates for specific actions;
Undertake a follow-up process; and
Where results are not satisfactory, study measures and actions to improve it. (see
as an example annex 2 card 4)

89
 Unit 7: WATCH OUT! RISK NEVER SLEEPS: EMERGENCY AND
FIRST-AID PROCEDURES

Good safety organization, ventilation and engineering controls, adequate provision

of information on the health hazards of chemicals, and training of workers can help
reduce and control chemical exposure in the workplace.

Nevertheless, as poisonings may still occur, workers must be trained and properly
equipped so that emergency situations can be handled satisfactorily.

Chemicals that are stored together may accidentally mix during an emergency,
forming a new substance with thoroughly different characteristics. The plant
chemist or industrial hygienist should be able to provide workers and trade unions
representatives with advice about the appropriate storage of chemicals, in order to
keep non-compatible chemical substances away from each other.

THE EMERGENCY PLAN

It is essential to have an emergency plan in every workplace. The plan should lay
down the following procedures and information:
• The evacuation of workers, including a system of accounting for them
workers once outside the building;
• Methods of notifying outside assistance such as medical, rescue, fire or
environmental protection specialists, as necessary;
• The role of various plant officials during an emergency;
• The role of selected workers; and
• The location and procedures for the use and maintenance of all emergency
equipment in the plant.

Everyone in the plant should be kept informed of the emergency plan and be able
to understand it in detail. The plan should describe clear and unobstructed
emergency exits, a functioning and frequently tested alarm system, and training
in evacuation for all workers. It should also detail procedures for the immediate
evacuation of disabled workers who may need assistance in reaching emergency
exits.

There should be emergency assembly points outside the plant so that each
worker can be accounted for after evacuation. These predetermined meeting areas
should be safe in case of escalation of the situation.

The emergency plan should outline the structure of the first-aid organization within
the plant, as well as procedures to obtain more specialized medical care when and
as necessary. The role of all plant personnel (including workers, supervisors and
managers) during an emergency situation should be described. The location of all
emergency and first-aid equipment, including emergency showers, eye-wash
stations, first-aid kits and stretchers, should also be mapped out.

The plan should address the organization of the internal capability to fight small
fires within the plant. As with first aid, the role of all plant personnel in a fire
emergency must be described, even if it only details the procedures for rapid
evacuation. The location of all fire-fighting equipment such as sand buckets, hoses
and extinguishers, as well as automatic fire-fighting systems, should be described
with specific guidance as to who should fight a chemical fire, when and how.

90
A chemical leak or spill can have disastrous consequences when the situation is not
tackled rapidly. The emergency plan should specify the staff who will be involved in
controlling the leak or managing the spill. Again, any specific material or
equipment must be described.

Emergency plans should be developed in conjunction with local medical, fire, law
enforcement and civil defence authorities, as well as neighbouring plants, to ensure
better coordination among these actors and a more effective implementation.

1. Every workplace should have an emergency plan.

2. The plan should cover emergency exits and an alarm system for
evacuation.
3. The plan should outline the duties and responsibilities for first aid and
fire fighting within the organization.

91
Module 2 references

Official websites:
UNECE. “Globally Harmonized System of Classification and Labelling of Chemicals (GHS)”
http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html
International Labour Organization. “Safe work”
http://www.ilo.org/public/english/protection/safework/intro/

Documents:
ILO. International Labour Office“Programme on Safety and Health and Work and Environment.
International Chemical Control Toolkit"
http://www.ilo.org/public/english/protection/safework/ctrl_banding/toolkit/main_guide.pdf
ILO. International Occupational Safety and Health Centre of Information. “Basics of chemical
safety” http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/toc.htm
ILO. International Occupational Safety and Health Centre of Information. “Chemical safety
training modules”
http://www.ilo.org/public/english/protection/safework/cis/products/safetytm/index.htm
ILO. “Chemicals in the workplace. Your health and safety at work.”
http://www.itcilo.it/actrav/actrav-english/telearn/osh/kemi/chemicaa.htm
IPCS (International programme on chemical safety). “Users’ manual for the IPCS health and
safety guides” http://www.inchem.org/documents/hsg/hsg/hsgguide.htm
IPCS (International Programme on Chemical Safety). “Safety and Health in the Use of
Agrochemicals” http://www.itcilo.it/actrav/actrav-english/telearn/osh/kemi/pest/pesti2.htm
ISTAS (2004). “La prevención del riesgo químico en el lugar de trabajo. Guía de intervención”
http://www.istas.net/ecoinformas/web/abreenlace.asp?idenlace=1367
ISTAS (2005). “Guía para la sustitución de sustancias peligrosas en la empresa. Manual
práctica para la intervención’
http://www.istas.net/ecoinformas/ficheros/ECOSustanciasDefinitiva.pdf
Lowell Centre for Sustainable Production: Alternatives Assessment Framework, 2006,
http://www.chemicalspolicy.org/downloads/FinalAltsAssess06.pdf
Lowell Centre for Sustainable Production (October 2003). “Integrated Chemicals Policy,
Seeking New Direction in Chemicals Management”
http://chemicalspolicy.org/downloads/ChemPolicyBrochure.pdf
WHO/UNEP (2006). “Sound Management of Pesticides and diagnosis treatment of pesticide
poisoning”

92
NOTES:

93
94
 Annex 1: Classification and labelling:
Global Harmonised System (GHS), EU Risk- and Safety-
Phrases

A. GHS Labelling:

The pictograms that follow are from the first edition (2005) of the GHS.32

EXCLUSIVE SYMBOLS OF THE GHS

32 http://www.unece.org/trans/danger/publi/ghs/pictograms.html (last accessed 24 April 2008)

95
 UN RECOMMENDED SYMBOLS FOR THE TRANSPORT OF DANGEROUS GOODS

SYMBOL/COMPULSARY SYMBOL/COMPULSARY
CASE IN WHICH IS USED
WORD WORD

ALWAYS

SKIN OR EYE IRRITATION

SKIN SENSITIZER OR SKIN OR EYE

IRRITATION

DANGER ATTENTION ALWAYS

96
B. EU Risk-Phrases:

Risk-Phrases
[Changes from the 28th Adaptation to the Technical Progress (ATP 28) of 6 August 2001 are
indicated in blue]

R1 Explosive when dry.

R2 Risk of explosion by shock, friction, fire or other sources of ignition.

R3 Extreme risk of explosion by shock, friction, fire or other sources of

ignition.

R4 Forms very sensitive explosive metallic compounds.

R5 Heating may cause an explosion.

R6 Explosive with or without contact with air.

R7 May cause fire.

R8 Contact with combustible material may cause fire.

R9 Explosive when mixed with combustible material.

R 10 Flammable.

R 11 Highly flammable.

R 12 Extremely flammable.

R 13 Extremely flammable liquefied gas.

The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 14 Reacts violently with water.

R 14/15 Reacts violently with water, liberating extremely flammable gases.

R 15 Contact with water liberates extremely flammable gases.

R 15/29 Contact with water liberates toxic, extremely flammable gas.

R 16 Explosive when mixed with oxidizing substances.

R 17 Spontaneously flammable in air.

R 18 In use, may form flammable/explosive vapour air-mixture.

R 19 May form explosive peroxides.

R 20 Harmful by inhalation.

R 20/21 Harmful by inhalation and in contact with skin.

R 20/21/22 Harmful by inhalation, in contact with skin and if swallowed.

R 20/22 Harmful by inhalation and if swallowed.

R 21 Harmful in contact with skin.

R 21/22 Harmful in contact with skin and if swallowed.

97
R 22 Harmful if swallowed.

R 23 Toxic by inhalation.

R 23/24 Toxic by inhalation and in contact with skin.

R 23/24/25 Toxic by inhalation, in contact with skin and if swallowed.

R 23/25 Toxic by inhalation and if swallowed.

R 24 Toxic in contact with skin.

R 24/25 Toxic in contact with skin and if swallowed.

R 25 Toxic if swallowed.

R 26 Very toxic by inhalation.

R 26/27 Very toxic by inhalation and in contact with skin.

R 26/27/28 Very toxic by inhalation, in contact with skin and if swallowed.

R 26/28 Very toxic by inhalation and if swallowed.

R 27 Very toxic in contact with skin.

R 27/28 Very toxic in contact with skin and if swallowed.

R 28 Very toxic if swallowed.

R 29 Contact with water liberates toxic gas.

R 30 Can become highly flammable in use.

R 31 Contact with acids liberates toxic gas.

R 32 Contact with acids liberates very toxic gas.

R 33 Danger of cumulative effects.

R 34 Causes burns.

R 35 Causes severe burns.

R 36 Irritating to eyes.

R 36/37 Irritating to eyes and respiratory system.

R 36/37/38 Irritating to eyes, respiratory system and skin.

R 36/38 Irritating to eyes and skin.

R 37 Irritating to respiratory system.

R 37/38 Irritating to respiratory system and skin.

R 38 Irritating to skin.

R 39 Danger of very serious irreversible effects.

R 39/23 Toxic: danger of very serious irreversible effects through inhalation.

R 39/23/24 Toxic: danger of very serious irreversible effects through inhalation

and in contact with skin.

98
R 39/23/24/25 Toxic: danger of very serious irreversible effects through inhalation,
in contact with skin and if swallowed.

R 39/23/25 Toxic: danger of very serious irreversible effects through inhalation

and if swallowed.

R 39/24 Toxic: danger of very serious irreversible effects in contact with skin.

R 39/24/25 Toxic: danger of very serious irreversible effects in contact with skin
and if swallowed.

R 39/25 Toxic: danger of very serious irreversible effects if swallowed.

R 39/26 Very toxic: danger of very serious irreversible effects through

inhalation.

R 39/26/27 Very toxic: danger of very serious irreversible effects through

inhalation and in contact with skin.

R 39/26/27/28 Very toxic: danger of very serious irreversible effects through

inhalation, in contact with skin and if swallowed.

R 39/26/28 Very toxic: danger of very serious irreversible effects through

inhalation and if swallowed.

R 39/27 Very toxic: danger of very serious irreversible effects in contact with
skin.

R 39/27/28 Very toxic: danger of very serious irreversible effects in contact with
skin and if swallowed.

R 39/28 Very toxic: danger of very serious irreversible effects if swallowed.

R 40 Limited evidence of a carcinogenic effect.

The phrase has been changed by ATP 28 (6 August 2001). The
corresponding phrase used in earlier cards reads: Possible risk of
irreversible effects.

R 40/20 Harmful: possible risk of irreversible effects through inhalation.

The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 40/20/21 Harmful: possible risk of irreversible effects through inhalation and in

contact with skin.
The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 40/20/21/22 Harmful: possible risk of irreversible effects through inhalation, in

contact with skin and if swallowed.
The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 40/20/22 Harmful: possible risk of irreversible effects through inhalation and if

swallowed.
The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 40/21 Harmful: possible risk of irreversible effects in contact with skin.

The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 40/21/22 Harmful: possible risk of irreversible effects in contact with skin and if
swallowed.
The phrase has been deleted by ATP 28 (6 August 2001), but may

99
 still appear in cards not modified since then.

R 40/22 Harmful: possible risk of irreversible effects if swallowed.

The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 41 Risk of serious damage to eyes.

R 42 May cause sensitization by inhalation.

R 42/43 May cause sensitization by inhalation and skin contact.

R 43 May cause sensitization by skin contact.

R 44 Risk of explosion if heated under confinement.

R 45 May cause cancer.

R 46 May cause heritable genetic damage.

R 47 May cause birth defects.

The phrase has been deleted by ATP 28 (6 August 2001), but may
still appear in cards not modified since then.

R 48 Danger of serious damage to health by prolonged exposure.

R 48/20 Harmful: danger of serious damage to health by prolonged exposure

through inhalation.

R 48/20/21 Harmful: danger of serious damage to health by prolonged exposure

through inhalation and in contact with skin.

R 48/20/21/22 Harmful: danger of serious damage to health by prolonged exposure

through inhalation, in contact with skin and if swallowed.

R 48/20/22 Harmful: danger of serious damage to health by prolonged exposure

through inhalation and if swallowed.

R 48/21 Harmful: danger of serious damage to health by prolonged exposure

in contact with skin.

R 48/21/22 Harmful: danger of serious damage to health by prolonged exposure

in contact with skin and if swallowed.

R 48/22 Harmful: danger of serious damage to health by prolonged exposure

if swallowed.

R 48/23 Toxic: danger of serious damage to health by prolonged exposure

through inhalation.

R 48/23/24 Toxic: danger of serious damage to health by prolonged exposure

through inhalation and in contact with skin.

R 48/23/24/25 Toxic: danger of serious damage to health by prolonged exposure

through inhalation, in contact with skin and if swallowed.

R 48/23/25 Toxic: danger of serious damage to health by prolonged exposure

through inhalation and if swallowed.

R 48/24 Toxic: danger of serious damage to health by prolonged exposure in

contact with skin.

R 48/24/25 Toxic: danger of serious damage to health by prolonged exposure in

contact with skin and if swallowed.

100
R 48/25 Toxic: danger of serious damage to health by prolonged exposure if
swallowed.

R 49 May cause cancer by inhalation.

R 50 Very toxic to aquatic organisms.

R 50/53 Very toxic to aquatic organisms, may cause long-term adverse effects
in the aquatic environment.

R 51 Toxic to aquatic organisms.

R 51/53 Toxic to aquatic organisms, may cause long-term adverse effects in

the aquatic environment.

R 52 Harmful to aquatic organisms.

R 52/53 Harmful to aquatic organisms, may cause long-term adverse effects

in the aquatic environment.

R 53 May cause long-term adverse effects in the aquatic environment.

R 54 Toxic to flora.

R 55 Toxic to fauna.

R 56 Toxic to soil organisms.

R 57 Toxic to bees.

R 58 May cause long-term adverse effects in the environment.

R 59 Dangerous for the ozone layer.

R 60 May impair fertility.

R 61 May cause harm to the unborn child.

R 62 Possible risk of impaired fertility.

R 63 Possible risk of harm to the unborn child.

R 64 May cause harm to breast-fed babies.

R 65 Harmful: may cause lung damage if swallowed.

R 66 Repeated exposure may cause skin dryness or cracking.

R 67 Vapours may cause drowsiness and dizziness.

R 68 Possible risks of irreversible effects.

R 68/20 Harmful: possible risk of irreversible effects through inhalation.

R 68/20/21 Harmful: possible risk of irreversible effects through inhalation and in

contact with skin.

R 68/20/21/22 Harmful: possible risk of irreversible effects through inhalation, in

contact with skin and if swallowed.

R 68/20/22 Harmful: possible risk of irreversible effects through inhalation and if

swallowed.

R 68/21 Harmful: possible risk of irreversible effects in contact with skin.

101
 R 68/21/22 Harmful: possible risk of irreversible effects in contact with skin and if
swallowed.

R 68/22 Harmful: possible risk of irreversible effects if swallowed.

C. EU Safety-Phrases:

Safety-Phrases
[Changes from the 28th Adaptation to the Technical Progress (ATP 28) of 6 August 2001 are
indicated in blue]

S1 Keep locked up.

S½ Keep locked up and out of the reach of children.

S2 Keep out of the reach of children.

S3 Keep in a cool place.

S 3/7 Keep container tightly closed in a cool place.

S 3/7/9 Keep container tightly closed in a cool, well-ventilated place.

The phrase has been deleted by ATP 28 (6 August 2001), but may still
appear in cards not modified since then.

S 3/9 Keep in a cool, well-ventilated place.

The phrase has been deleted by ATP 28 (6 August 2001), but may still
appear in cards not modified since then.

S 3/9/14 Keep in a cool, well-ventilated place away from (incompatible materials

to be indicated by the manufacturer).

S 3/9/14/49 Keep only in the original container in a cool, well-ventilated place away
from ... (incompatible materials to be indicated by the manufacturer).

S 3/9/49 Keep only in original container in a cool, well-ventilated place.

S 3/14 Keep in a cool place away from ... (incompatible materials to be

specified by the manufacturer).

S4 Keep away from living quarters.

S5 Keep contents under ... (appropriate liquid to be specified by the

manufacturer).

S6 Keep under ... (inert gas to be specified by the manufacturer).

S7 Keep container tightly closed.

S 7/8 Keep container tightly closed and dry.

S 7/9 Keep container tightly closed and in a well-ventilated place.

S 7/47 Keep container tightly closed and at a temperature not exceeding ... °C
(to be specified by the manufacturer).

S8 Keep container dry.

S9 Keep container in a well-ventilated place.

S 10 ---

102
S 11 ---

S 12 Do not keep the container sealed.

S 13 Keep away from food, drink and animal feedstock.

S 14 Keep away from ... (incompatible materials to be indicated by the

manufacturer).

S 15 Keep away from heat.

S 16 Keep away from sources of ignition -- No smoking.

S 17 Keep away from combustible material.

S 18 Handle and open container with care.

S 19 ---

S 20 When using do not eat or drink.

S 20/21 When using do not eat, drink or smoke.

S 21 When using do not smoke.

S 22 Do not breathe dust.

S 23 Do not breathe gas/fumes/vapour/spray (appropriate wording to be

specified by the manufacturer).

S 24 Avoid contact with the skin.

S 24/25 Avoid contact with skin and eyes.

S 25 Avoid contact with eyes.

S 26 In case of contact with eyes, rinse immediately with plenty of water and
seek medical advice.

S 27 Take off immediately all contaminated clothing.

S 27/28 After contact with skin, take off immediately all contaminated clothing,
and wash immediately with plenty of … (to be specified by the
manufacturer).

S 28 After contact with skin, wash immediately with plenty of ... (to be
specified by the manufacturer).

S 29 Do not empty into drains.

S 29/35 Do not empty into drains; dispose of this material and its container in a
safe way.

S 29/56 Do not empty into drains, dispose of this material and its container at
hazardous or special waste collection point.

S 30 Never add water to this product.

S 31 ---

S 32 ---

S 33 Take precautionary measures against static discharges.

103
S 34 Avoid shock and friction.
The phrase has been deleted by ATP 28 (6 August 2001), but may still
appear in cards not modified since then.

S 35 This material and its container must be disposed of in a safe way.

S 36 Wear suitable protective clothing.

S 36/37 Wear suitable protective clothing and gloves.

S 36/37/39 Wear suitable protective clothing, gloves and eye/face protection.

S 36/39 Wear suitable protective clothing and eye/face protection.

S 37 Wear suitable gloves.

S 37/39 Wear suitable gloves and eye/face protection.

S 38 In case of insufficient ventilation, wear suitable respiratory equipment.

S 39 Wear eye/face protection.

S 40 To clean the floor and all objects contaminated by this material, use ...
(to be specified by the manufacturer).

S 41 In case of fire and/or explosion do not breathe fumes.

S 42 During fumigation/spraying wear suitable respiratory equipment

(appropriate wording to specified by the manufacturer).

S 43 In case of fire, use ... (indicate in the space the precise type of fire-
fighting equipment. If water increases the risk, add “Never use water”).

S 44 If you feel unwell, seek medical advice (show label where possible).
The phrase has been deleted by ATP 28 (6 August 2001), but may still
appear in cards not modified since then.

S 45 In case of accident or if you feel unwell, seek medical advice

immediately (show the label where possible).

S 46 If swallowed, seek medical advice immediately and show container or

label.

S 47 Keep at temperature not exceeding ... °C (to be specified by the

manufacturer).

S 47/49 Keep only in the original container at a temperature not

exceeding ... °C (to be specified by the manufacturer).

S 48 Keep wet with ... (appropriate material to be specified by the

manufacturer).

S 49 Keep only in the original container.

S 50 Do not mix with ... (to be specified by the manufacturer).

S 51 Use only in well-ventilated areas.

S 52 Not recommended for interior use on large surface areas.

S 53 Avoid exposure -- obtain special instructions before use.

S 54 ---

104
S 55 ---

S 56 Dispose of this material and its container to hazardous or special waste

collection point.

S 57 Use appropriate container to avoid environmental contamination.

S 58 ---

S 59 Refer to manufacturer/supplier for information on recovery/ recycling.

S 60 This material and its container must be disposed of as hazardous

waste.

S 61 Avoid release to the environment. Refer to special instructions/safety

data sheets.

S 62 If swallowed, do not induce vomiting: seek medical advice immediately

and show this container or label.

S 63 In case of accident by inhalation: remove casualty to fresh air and keep

at rest.

S 64 If swallowed, rinse mouth with water (only if the person is conscious).

105
 Annex 2: CARDS

The following cards provide advice to prevent exposure to hazardous chemicals in

the workplace.33

They are presented in an easy to follow, structured form that can help you better
collect, analyse and summarize information, particularly for individuals who are not
too familiar with risk prevention at the workplace. They seek to provide you with
some basic guidance on how to structure and develop your work on chemical risk
prevention in the workplace.

Hearing from you!

We welcome any suggestions, comments, and observations you may want

to send in. To do this, complete the cards and attach additional
information that can be shared with the rest of us.

Card 1a – Identification of risk situations: flowchart of the production

process

Flowchart of the production Map of the working place

process

Activity:
Production process:

33 Based on ISTAS. “Chemical risk prevention in the workplace. Guide for intervention”
http://www.istas.net/web/abreenlace.asp?idenlace=1367 (in Spanish – last accessed 15 April 2008)

106
Card 1b - Identification of risk situations

Section: List of products used Resulting products

and wastes

Production process:

Tasks:

Production process:

Tasks:

Card 2 – Identification of hazardous substances

Risk situation: _______________________________________________

Section: Process: Task
Simple Substance Occupational Environmental Observations
product or CAS / ICSC health and Risk
mix product Number safety risk

Card 3 – Risk identification

Risk situation:
_______________________________________________
Section: Production process:
Task: Risk factors:
dfadg
gargr

107
Card 4 – Risk evaluation

On a scale that goes from “very low risk” to “very high risk” for human health and
the environment.

Risk situation: _______________________________________________

Section: Productive process:
Task Substances Working Existence of Workers’ Evaluation
used conditions harm to human perception of risk
/ health and the
potential environment
risk

Card 5 – Plan of implementation

Risk situation:
_______________________________________________
Section: Productive process:
Task Priority Objectives Measures to Actions to
(high, adopt put on place
medium or
low)

Card 6 – Follow up

Risk situation: _______________________________________________

Section: Productive process:
Task Measures Proposed Actions Implementation Result
to adopt and agreed with dates and
suggested the person
actions employers responsible
from the
working centre

108
 Annex 3: QUESTIONNAIRES

A. – Questionnaire to workers

Identification of chemical risk

This questionnaire gives examples of questions that can be formulated (either orally
or in written form) to workers to find out more about their working situation and
conditions, their exposure to risk, and to ascertain the knowledge they have
regarding these issues.

These questions are a general guide. When developing the questionnaire,

consideration should be given to whether to shorten or enlarge the list, based on
the extent of information already available, the amount of time the workers have to
answer, and how predisposed they are to give answers.

Working area: ______________________________________________

Position: __________________________________________________
Gender: Woman Man

Special working conditions

Pregnant or breastfeeding women
Person sensible to certain products
Others

1. Do you use or are you exposed to chemical materials or Yes No

products in your work?

2. What are they used for and where do they come from? ____________________
____________________

3. Are the containers labelled? Yes No

4. Do you know the chemical names of products besides the Yes No

commercial names?

5. If it is a compost product (mix). Do you know the name of Yes No

each of the products (components)?

6. Do you have information about the effects or harm the Yes No

chemicals you use might cause to human health and the
environment?

7. How can these products penetrate your organism? Respiratory system

Ingestion
Through skin

8.a. Does the presence and manipulation of these products Yes No

create a risk situation that might cause an accident (splashing,
etc.)

8.b. Why does a risk exist? What are the reasons? ____________________
____________________

109
9. Have you suffered or are you suffering from any health Yes No
problem, nuisance or pain related with the chemical products
in your work (eyes irritation, etc.)

10. If you have suffered intoxication, which symptoms showed Short after using the
up? product (few minutes or
hours): Acute.

Long time after using

the product: Chronic

11. Can materials and/or products used or present in your Yes No

working centre be the cause of pollution in the surrounding
and immediate/local external environment?

12. Are hazardous and polluting substances spilled in waste Yes No

pipes or drains?

13. Are containers of chemical products separated from the Yes No

rest of the waste and treated specially as hazardous waste?

14. Are there hazardous wastes in drums or other open Yes No

containers, broken or without labelling?

15. Do you know at what level of concentration, or amount of Yes No

chemical exposure harmful effects occur to human health
or/and the environment?

16. Are there any first aid kid in your working centre? Yes No

17. What does it contain? ____________________

____________________

18. Are you aware if there is any risk prevention plan at your Yes No
working centre?

19. If so, can you describe what you know about this? ____________________
____________________

20. Are you aware if there is an emergency plan in case of an Yes No

accident? (emergency telephones, transport, etc.)

21. Do you know the substances that cannot be mixed with Yes No
the products you are using?

22. Do you know what to do in case of spillage of a chemical Yes No

product?

23. Have you ever heard about possible alternatives to the Yes No
hazardous substances you are using?

24. If so, please describe briefly what you know about this ____________________
____________________

110
25. Do you know how chemical risk could be reduced, Yes No
minimized and eliminated in work position?

26. If so, please describe briefly what you know about this ____________________
____________________

27. Do you know the collective and individual measures the Yes No
employer has to put in place to control pollution in the
workplace?

28. Is there any periodical revision of the equipment or the Yes No

ventilation mechanisms at your workplace?

29. Do know what personal protective equipment (gloves, Yes No

respiratory masks, etc.) are used at your workplace?

30. If so, please describe them briefly ____________________

____________________

31. Do you know what personal protective equipment should For the correct
be adequately used when? manipulation of products

For the correct storage

of products
For the correct
transport of products

B. – Inspection guide to identify chemical risk

Working area: ______________________________________________

Position: __________________________________________________
Gender: Woman Man

Special working conditions

Pregnant or breastfeeding women
Person sensible to certain products
Others

>> Training and information

1. Do workers know the potential risk of stored substances, Yes No
substances used or generated in the workplace?

2. Have they received information and training on the safe way to Yes No
manipulate toxic substances?

3. Are all containers labelled? Yes No

4. Are those pipes through which chemical substances circulate Yes No

clearly signed and marked?

5. Have procedures been established in case of a spillage, Yes No

emergencies, etc.?

6. Do workers know when they have to use personal protective Yes No

equipment?

111
7. Are workers told of the hygienic habits to have during working Yes No
time, e.g. before consuming food and drinks, as well as those
habits away from the workplace?
8. Have workers been informed about the risk and the danger to Yes No
the environment and the way to treat and eliminate wastes,
emissions and spillage?

>> Control of contamination

1. Are the toxic substances used necessary or can they be Yes No
replaced with others which are less harmful to human health
and the environment?

2. When toxic substances are not used are they placed in a Yes No
closed/sealed space?

3. Do you feel there are workers unnecessarily exposed to Yes No

toxic and hazardous chemicals?

4. If so, please describe in which situations? ____________________

____________________

5. Are there any systems of ventilation or respiration installed? Yes No

6. Is the workplace cleaning done frequently and regularly to Yes No

avoid any accumulation or dispersion of particles?

7. Are there any systems of health and biological surveillance Yes No

of these workers exposed to toxic risk in place?

8. Are the toxic substances present at the workplace regularly Yes No

measured?

9. Are the workers informed about the results of the tests? Yes No

10. Are there any measures to avoid air, water and waste Yes No
pollution in place?

11. Are toxic products stored in closed/sealed containers? Yes No

12. Are the toxic products collected by a responsible and Yes No

competent authority?

13. Are toxic substances poured into water through pipes, Yes No
ending up in the sewers or elsewhere?

14. Are the emissions of pollutants to the exterior through Yes No

windows, systems of ventilation, or chimneys?

15. Are there dangerous substances in the products produced Yes No

by the company?

112
>> Workers protection
1. In those areas where irritant, corrosive and hazardous Yes No
substances are used, are there any fountains, washbasins, or
showers?

2. Does the working centre look after the laundry of working Yes No
clothes?

3. Do workers receive enough information and training to permit Yes No

them to work in safe conditions?

>> Organization and working rhythms

1. Do working rhythms and demands to finalise tasks make it Yes No
difficult to comply with security and prevention measures

2. Is the salary based on bonuses from production? Yes No

3. In the different working shifts, particularly at night, are the Yes No

prevention measures the same?

4. Do measures proposed to prevent and control chemical risk Yes No

stop, prevent or adversely interfere with production and work?

113
Annex 4: EXAMPLE OF A BASIC CARD TO SUMMARIZE
INFORMATION ABOUT THE WORKING CENTRE

Data card:

Name of the
company:
Activity:
Number of workers:
Address:
Postal code:
City and country:

Brief description of the company activity:

Hazardous substances and products used:

PRODUCT/SUBSTANCE USE OBSERVATIONS

Hazardous wastes generated:

WASTE PROCESS MANAGEMENT

Observations:

114
NOTES:

115
116
 MODULE 3:
CHEMICALS REGULATION

From an international to a workplace perspective:

what is the progress needed?

Shipbreaking, Pakistan
© F. Ardito / UNEP / Still Pictures

Module objectives:

The module aims at:

Introducing the international environmental negotiations and processes related to

management of chemicals;
Raising awareness on the importance of stakeholders involvement in the
negotiation process, particularly workers and trade unions;
Highlighting concrete success stories of negotiation agreements, social alliances,
etc;
Identifying steps to ensure workers’ and stakeholders’ participation in negotiations
and local/workplace initiatives.

Learning outcomes:

At the end of the session, the trainee will be familiar with:

the Strategic Approach to International Chemical Management;
the objective and scope of action of the following Conventions: Stockholm,
Rotterdam and Basel;
the Pollutant release and transfer registers and regional processes as REACH;
The potential for stakeholders alliances on this topic through concrete examples;
Existing initiatives in the workplace.

117
 Unit 1: INTERNATIONAL GOVERNANCE
OF CHEMICAL SUBSTANCES

Unit 1 will first present the most relevant international instruments that regulate
the management of chemicals. It will address the following issues:
1. What are the objectives of international instruments and agreements?
2. How do they work?
3. How do we stimulate debate and contributions towards more strategic
actions?

Box 3.1. Taking action!

The most useful for workers and trade unions is probably to know what they can do and
what already happens in the workplace and at the national level, as it is their every-day
fields of intervention whereas international dynamics are likely seen as far way processes.

Indeed, it is important to mobilize and push for further regulation and/or collective
agreements from the workplace level and perspective. Trade unions and workers know and
have experienced that labour and social rights are best guaranteed when there are
pressures and demands at the ground level.

Dynamics at the international level influence and can condition what happens at the
national level. Indeed, global treaties, conventions and other agreements can serve as
frameworks that mark the paths and guide country actions. This is particularly true when
the actions involve legally binding agreements. They can still be instructive and helpful
when they are applicable merely on a voluntary basis, since they can be used to apply
external pressure in similar situations.

If others can make progress in getting what is right for them, why could we not
too? Knowing what other countries are doing collectively, also gives a reference point for
determining whether similar, more stringent or adapted processes are needed at the
national level. And of course, if trade unions and workers can use international measures
to help influence national legal framework, it may help them achieve various rights and
guarantees, and demand more easily that they be implemented in the workplace.

Source: Sustainlabour, 2008

GLOBAL VOLUNTARY STRATEGIES: THE CASE OF SAICM

STRATEGIC APPROACH TO INTERNATIONAL CHEMICAL MANAGEMENT34

Acknowledging that the existing international policy framework was inadequate and
needed to be further strengthened, the International Conference on Chemicals
Management (ICCM) endorsed the Strategic Approach to International Chemicals
Management (SAICM) in February 2006.

SAICM is an ambitious, non-legally binding policy framework that aims to facilitate

the elimination and reduction of risks of chemicals throughout their life-cycle. This
international chemicals regulation has made some significant steps forward, moving
from regulating specific problems to addressing generic issues including governance.

34 Based on the Strategic Approach to International Chemicals Management (SAICM)

http://www.chem.unep.ch/saicm/ (last accessed 14 April 2008)

118
The SAICM process involved a multi-stakeholder and multi-sectoral consultation in
which over 140 Governments and around 60 civil society groups participated.
Among them, the International Trade Union Confederation (ITUC), public interest
groups focussed on the environment and health, industry associations and the
scientific community.

How it works…
SAICM supports the goal of Johannesburg’s 2002 World Summit on Sustainable
Development of ensuring that, “by the year 2020, chemicals are produced and used
in ways that minimize significant adverse impacts on the environment and human
health”.

SAICM comprises three core outputs:

• The Dubai Declaration, which expresses the commitment to SAICM by
Ministers, heads of delegation and representatives of civil society and the
private sector;
• The Overarching Policy Strategy (OPS), which sets out the scope of
SAICM, the needs it addresses and objectives for risk reduction, knowledge
and information, governance, capacity-building and technical cooperation,
illegal international traffic, as well as underlying principles and financial and
institutional arrangements; and
• A Global Plan of Action, which proposes “work areas and activities” for
implementation of the Strategic Approach.

In addition, the negotiators agreed on a “Quick start programme (QSP)” that

involves a time-limited trust fund to provide seed money to support the objectives
and strategic priorities of the SAICM. Developing countries and countries with
economies in transition are eligible for support from the trust fund. Representatives
of civil society networks participating in SAICM may also present project proposals,
on an exceptional basis, and subject to endorsement of the application by the
SAICM focal point at government level in the countries hosting the projects. There
are already some trade union programmes approved under this fund, aiming at
strengthening their participation and capacity building to implement SAICM.

Box 3.2. The Dubai Declaration

“The sound management of chemicals is essential, if we are to achieve sustainable

development, including the eradication of poverty and disease, the improvement of human
health and the environment, and the elevation and maintenance of the standard of living in
countries at all levels of development.”

Source: Strategic Approach to International Chemicals Management (SAICM)

http://www.chem.unep.ch/saicm/ (last accessed 14 April 2008)

Examples of substances and working areas under SAICM …

Some of the substances prioritized under SAICM are the highly toxic pesticides,
lead in gasoline, persistent, bioaccumulative and toxic substances (PBTs); very
persistent and very bioaccumulative substances; chemicals that are carcinogenic,
mutagenic or that adversely affect, among others, the reproductive, endocrine,
immune or nervous systems; persistent organic pollutants (POPs), mercury; and
chemicals produced or used in high volumes.

119
The main working areas are Occupational Health and Safety, cleaner production,
sound agricultural practices, waste management, the implementation of the
Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and
of the pollutant release and transfer register (PRTRs) including the creation of
national and international registers, as well as the prevention of illegal traffic in
toxic and dangerous goods

What still needs to be done…

Success of SAICM will depend on the commitment of the different stakeholders.
Implementation is perhaps the biggest challenge facing SAICM – as for most, if
not all, chemicals MEAs - along with funding needs. To this end, the development of
national Strategic Approach implementation plans is the first important milestone..

For trade unions, as for the rest of civil society organizations, it is essential to
demand rights for effective participation in chemicals management forums at
all levels of governance. In so doing, it also is necessary to collaborate with
other stakeholders and to monitor and follow what governments, the private sector,
and other interested parties are doing.

Financial and technical resources are necessary for implementation. Indeed, a

proper governmental allocation of expertise and capabilities, as well as an adequate,
international funding mechanism are key to achieve objectives under SAICM.

Box 3.3. What is the Intergovernmental Forum on Chemical Safety (IFCS)?

The Intergovernmental Forum on Chemical Safety (IFCS) is a unique forum where

governments, international, regional and national organizations, industry groups, public
interest associations, labour organizations, scientific associations and representatives of
civil society meet to discuss of international chemical policy issues and priorities.

IFCS provides a forum for discussing issues of common interest and new and emerging
issues in the area of sound management of chemicals.

SAICM, substitution of hazardous chemical substances, nanomaterials and nanotechnology

are some of the next issues generating interest and attention within IFCS.

The functions of IFCS are consultative and advisory, and include :

Defining priorities for cooperative action and facilitating this cooperation;
Recommending concerted international strategies;
Helping strengthen national chemicals management coordination mechanisms;
Identifying gaps in scientific understanding;
Fostering information exchange and technical cooperation;
Reviewing effectiveness of relevant ongoing activities;
Advising governments in their work on chemical safety;
Promoting cooperation among governmental and nongovernmental organizations;
Evaluating progress on agreed actions and recommendations.

Read more at: http://www.who.int/ifcs/en/

Source: Intergovernmental Forum on Chemical Safety. “Global Partnerships for Chemical Safety”
http://www.who.int/ifcs/en/

Where to get more information?

• Strategic Approach to International Chemical Management http://www.chem.unep.ch/saicm/

120
MULTILATERAL ENVIRONMENTAL AGREEMENTS TRIO: BASEL, ROTTERDAM AND
STOCKHOLM CONVENTIONS

Multilateral Environmental Agreements (MEAs) 35 are a subset of the universe of

international agreements. What distinguishes them from other agreements is that
they focus on environmental issues, create binding international law, and include
multiple countries. Over the years, many MEAs have been negotiated and agreed at
the international and regional levels. Some have only a limited number of
“Parties”,36 while others involve almost all the countries around the world.

MEAs differ in scope and substance. Nevertheless, they tend to be formulated

through a similar process that moves through recognizable stages. These stages
include pre-negotiation, negotiation, adoption and signature, ratification and
accession, and entry into force.

MEAs come in a variety of forms. They can be:

• Global: for example, the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and their Disposal applies throughout the
world; or
• Regional: for example, the Bamako Convention on the Ban of the Import
into Africa and the Control of Transboundary Movement and Management of
Hazardous Waste within Africa, which applies only within the African Region.

Civil society participation is allowed in many MEAs, though, for some of them, not
at the scope and degree that civil society might want. Nonetheless, civil society
should use any available means and forum to make their voices and views clear. In
particular, workers and trade unions must bring to these forums their expertise, in
terms of their experiences in the workplace, and knowledge of the realities of
hazardous chemical contamination and impacts. MEAs and their mechanisms must
be seen as genuine opportunities to push forward in the struggle to achieve labour
rights, social justice, and fair and equitable development.

Indeed, social dialogue has an important role to play in framing MEA regimes. For
this to happen, it is important that trade unions spot where and how they can best
intervene and participate. Therefore, the following section presents the three most
relevant MEAs related to sound and sustainable management of chemicals.

BASEL CONVENTION: ABOUT CHEMICALS INTERNATIONAL TRADE MOVEMENT37

The Basel Convention on the Control of Transboundary Movements of Hazardous
Wastes and their Disposal is the most comprehensive global environmental
agreement on hazardous and other wastes.

It is a global treaty to protect human health and the environment from risks posed
by hazardous wastes and their transboundary movement. When hazardous wastes
are dumped indiscriminately, spilled accidentally or managed improperly, they can
cause severe health problems, or even death, and poison water and land for
decades.

35 Based on UNEP. “Guide for Negotiators of Multilateral Environmental Agreements”

http://www.unep.org/DEC/docs/Guide%20for%20Negotiators%20of%20MEAs.pdf (last accessed 14
April 2008)
36 “Party” is the name given to refer to those countries that have ratified a Convention
37 Based on the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes
and their Disposal, http://www.basel.int/

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In the late 1980s, a tightening of environmental regulations in industrialized
countries led to a dramatic rise in the cost of hazardous waste disposal. Searching
for cheaper ways to get rid of the wastes, “toxic traders” began shipping hazardous
waste to developing countries and to Eastern Europe. When this activity was
revealed, international outrage led to the drafting and adoption of the Basel
Convention, which entered into force on May 1992. By 2007, 169 countries and the
European Community were Parties to the treaty.

How it works… 38
First, the Basel Convention regulates the transboundary movements of
hazardous and other wastes applying the “Prior Informed Consent” procedure
(shipments made without consent are illegal). Shipments to and from non-Parties
are illegal unless there is a special agreement. Each Party is required to introduce
appropriate national or domestic legislation to prevent and punish illegal traffic in
hazardous and other wastes. Illegal traffic is criminal.

Second, the Convention obliges its Parties to ensure that hazardous and other
wastes are managed and disposed of in an environmentally sound manner
(ESM). To this end, Parties are expected to minimize the quantities that are moved
across borders, to treat and dispose of wastes as close as possible to where they
were generated and to minimize the generation of wastes at the source. Strong
controls have to be applied from the moment of generation of a hazardous waste to
its storage, transport, treatment, reuse, recycling, recovery and final disposal.
Wastes under the Basel Convention are substances or objects that are disposed of,
or are intended or required to be disposed of by the provisions of national law.
Annex I of the Convention, as further clarified in Annexes VIII and IX, lists those
wastes that are classified as hazardous and subject to the control procedures under
the Convention. Annex II of the Convention identifies those wastes that require
special consideration (referred to as “other wastes”, and which primarily refer to
household wastes).
Parties may also inform the Convention Secretariat of additional wastes, other than
those listed in Annexes I and II of Convention, that are considered or defined as
hazardous wastes under their national legislation and of any requirements
concerning transboundary movement procedures applicable to such wastes.
As defined by the Convention, “management” means the collection, transport and
disposal of hazardous wastes or other wastes, including after-care of disposal sites;
and “disposal” means any operation specified in Annex IV to this Convention.

Examples of wastes regulated by the Basel Convention…

• Biomedical and healthcare wastes;
• Used oils;
• Used lead-acid batteries;
• Persistent Organic Pollutant wastes (POPs wastes), chemicals and pesticides
that persist for many years in the environment. They are transported over
great distances from their point of release, they bioaccumulate (thus
threatening humans and animals at the top of the food chain), and cause a
range of adverse health effects;
• Polychlorinated Biphenyls (PCBs), compounds used in industry as heat
exchange fluids, in electric transformers and capacitors, and as additives in
paint, carbonless copy paper, sealants and plastics; and
• Thousands of chemical wastes generated by industries and other consumers.

38 Based on “The Basel Convention at a Glance” http://www.basel.int/convention/bc_glance.pdf (last

accessed 14 April 2008)

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Did you know? Transboundary movement of hazardous substances

Reports to the Basel Convention suggest that there are at least 8.5
million tonnes of hazardous waste moving from country to country each
year.

Of these millions of tonnes of hazardous wastes sent for disposal

abroad, much is received as a welcomed source of business. However,
many countries do complain that they are receiving shipments which
they never agreed to and which they are unable to deal with properly.

Source: Based on national reports transmitted to the Secretariat of the Basel

Convention in 2001

The Basel Convention also has 14 Basel Convention Regional and Coordinating
Centres in the following locations: Argentina, China, Egypt, El Salvador, Indonesia,
the Islamic Republic of Iran, Nigeria, the Russian Federation, Senegal, the Slovak
Republic, the South Pacific Regional Environment Programme (Samoa), South
Africa, Trinidad and Tobago and Uruguay. The Centres develop and undertake
regional projects, and deliver training and technology transfer for the
implementation of the Convention.

What still needs to be done…

On 19 August 2006, a ship (the Probo Koala) chartered by a Dutch company
offloaded 400 tons of gasoline, water and caustic washings used to clean oil drums.
The cargo was dumped at Akouedo and at least 10 other sites around the city,
including in a channel leading to a lake, roadsides and open grounds. Six people
died and close to 9,000 others sought treatment since the toxic wastes were
dumped on open-air sites around Abidjan.39

Why did it happen? Could have been avoided? Actually, since 1995 the Parties
approved the Basel Ban Amendment, which would prohibit globally the export of
hazardous waste from rich to poorer countries, whatever the reason. The rationale
behind the ban was that there is the high risk that hazardous wastes will not be
safely managed in developing countries, and that risk should simply not be taken.
It also reflected the "polluter pays principle," according to which whoever causes
pollution should assume its costs.

Unfortunately, the Ban Amendment has not yet entered into force. It first
needs to be ratified by at least three-fourths of the Parties who accepted it. Thus
far, as of mid-2007, there have been only 63 ratifications.

Ironically, many of the countries that are currently having their workers and
environmental health severely impacted by hazardous waste have failed so far to
ratify it. These countries include India, Pakistan, Bangladesh, the Philippines, and
Cote d’Ivoire (Ivory Coast). Meanwhile, some countries like the United States,
Canada, Australia, New Zealand and South Korea have openly opposed the global
ban. Worst of all, the US, the nation that produces the most hazardous waste per
capita, has failed to ratify the original Basel Convention.

39 Based on “MAC and Communities: ToxiCities” (2006)

http://www.minesandcommunities.org/article.php?a=1798 (last accessed 14 April 2008)

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Likewise, old ships are exported to horrific, dirty recycling operations in the South
Asian countries of India, Pakistan and Bangladesh. A study40 released by the Indian
government in 2006 revealed that 1 in 6 workers at the Indian shipbreaking yards
are suffering from asbestosis from inhaling hazardous asbestos waste from the ship
construction.

This is why the Basel Convention and the Basel Ban were created. It is time to
make it effective.

Workers, particularly dockers and transport workers from developing countries are
the first to suffer from these legal loopholes. To prevent it from being foisted on
developing countries, the proper and real implementation of international legal
instruments, including the Basel Convention and the Basel Ban, needs to be
ensured.

This is why it is so important to ensure workers and trade unions’ participation

in international decision making processes like the Basel Convention. As workers
are victims, and witnesses to chemical tragedies, and they can best explain the
health and environmental impacts of inadequate action.

Where to get more information?

For more information, go to the reading material on the Basel Convention.

http://www.basel.int/
More information about the fourteen regional centres for training and technology transfer is
available at: http://www.basel.int/centres/regdescr.html

Civil Society Organizations:

Basel Action Network (BAN): http://www.ban.org/

ROTTERDAM CONVENTION: INFORMATION EXCHANGE AND PRIOR INFORMED CONSENT41

The dramatic growth in chemicals’ production and trade during the past three
decades has raised concerns about the potential risks posed by hazardous
chemicals, including pesticides. Countries lacking adequate infrastructure to
monitor the import and use of these chemicals are particularly vulnerable.

In response to that, since the mid-1980s some programmes were initiated to

develop and promote voluntary information exchange. Twenty years later, they lead
to the Rotterdam Convention, which was adopted on 10 September 1998. This
Convention entered into force on 24 February 2004. As of mid-2007, there were
117 Parties to the Convention.

How it works…
The Convention covers pesticides and industrial chemicals that have been banned
or severely restricted for health or environmental reasons by Parties, which are
listed in what is called Annex III.

40 Based on Basel Action Network (BAN)

http://www.ban.org/ban_news/2006/060926_activists_call.html (last accessed 14 April 2008)
41 Based on Rotterdam Convention official website http://www.pic.int/ (last accessed 14 April 2008)

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The objectives of the Convention are:
• To promote shared responsibility and cooperative efforts among Parties in
the international trade of certain hazardous chemicals in order to protect
human health and the environment from potential harm; and
• To contribute to the environmentally sound use of those hazardous
chemicals, by facilitating information exchange about their characteristics,
by providing for a national decision making process on their import and
export and by disseminating these decisions to Parties.

To achieve its objectives, the Convention includes two key provisions, namely the
Prior Informed Consent (PIC) and Information exchange.

The PIC procedure is a mechanism for formally obtaining and disseminating the
decisions of importing Parties as to whether they wish to receive future shipments
of those chemicals listed in Annex III of the Convention and for ensuring
compliance with these decisions by exporting Parties.

All Parties are required to take a decision as to whether or not they will allow future
import of each of the chemicals in Annex III of the Convention. Import decisions
taken by Parties must be “trade neutral.” It means that, if a Party decides not to
accept imports of a specific chemical, it must also stop domestic production of the
chemical for domestic use and refuse imports from any source, including from non-
Parties.

All exporting Parties are required to ensure that exports of chemicals subject to the
PIC procedure comply with the decision of each importing Party.

Information exchange is the other mechanism of the Rotterdam Convention. The

Convention facilitates information exchange among Parties for a very broad range
of potentially hazardous chemicals. A developing country Party or a Party with an
economy in transition that is experiencing problems caused by a severely
hazardous pesticide formulation may report such problems to the Secretariat. A
chemical that is banned or severely restricted by a Party can be exported from its
territory, if an individual importing Party accepts it and is notified of its status
before the first shipment, and annually thereafter.

Examples of substances regulated…

There are 39 chemicals listed in Annex III of the Convention and subject to the PIC
procedure: 24 pesticides, 4 severely hazardous pesticide formulations and 11
industrial chemicals.

Mercury compounds that are used as pesticides are on the list. So are the
pesticides aldrin, dieldrin, lindane, monocrotophos and DDT, the latter famous for
contaminating the milk of nursing mothers and for decimating bald eagles, ospreys,
and other predatory birds. Also on the list is the industrial class of chemicals known
as PCBs.

Other chemicals that are on the list and covered by the PIC procedure include
various forms of asbestos, known to be a major cause of mesothelioma and
occupational lung cancer.

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What still needs to be done…42
The Rotterdam Convention aims at promoting exchange of information and
transparency in the international trade of certain hazardous chemicals in order to
protect human health and the environment from potential harm. However,
important steps still need to be undertaken to ensure a proper and fair system.

For example, currently the burden of preventing an export falls on the

importing country. Exporting countries must inform importing countries of their
exports and respect the importing countries’ decisions in relation to PIC substances.
Meanwhile, the importing countries must analyse the data received, consider
potential existing alternatives, and make a decision on the future importation of a
chemical consistent with their national legislation and the rules of international
trade. In addition, they must be able to control effectively imports of the chemicals
they have severely restricted or banned. However, in practice, the limited resources
of developing countries greatly reduce their governments’ ability to test, monitor,
or regulate pesticides imported across their borders.

Another challenge is to enlarge as much as possible the number of Party member

countries. Probably the easiest way to achieve this goal would be to proscribe trade
of PIC chemicals with non-Parties, so that all exporting countries would feel
compelled to ratify the Convention. The Rotterdam Convention originally included a
rule on trade with non-parties, but the provision was subsequently deleted. As a
result, there are no incentives for exporting countries to become parties to the
treaty. Serious consideration should be given to readopting a provision that
precludes trade with non-Parties as a way to promote participation of all
exporting countries.

In addition, there is an important loophole in the Rotterdam Convention, because

chemicals for which no registration has been sought remain completely
outside of its scope of coverage. It seems very appropriate and urgent, as a matter
of urgency, to expand the PIC list to include those chemicals as well, taking into
account the growing number of hazardous chemical substances in commerce.

Although the Rotterdam Convention is not intended to deal directly with chemicals
management, but instead with information exchange and prior informed consent
(PIC), a concept that lies on the idea that importing countries have a real choice in
the type of products they decide to authorize. However, many countries, and
especially developing ones, usually have no access to alternatives to the chemicals
included in the PIC list. As a result, following Prior Informed Consent procedures
becomes just a formal process, in the absence of any real alternatives or other
options (e.g. in dealing with some pesticides). In the end, if the ultimate goal of the
Rotterdam Convention is to protect human health and the environment from the
potential harmful effects of some hazardous chemicals and pesticides, alternatives
should be somehow promoted, disclosed and, if necessary, supported.

Where to get more information?

For a full list of the chemicals in Annex III of the Convention that are subject to the prior
informed consent procedure, consult the Convention website and for more information, go
to the reading material on the Rotterdam Convention. http://www.pic.int/

42 Based on Barrios, P. (2004). “Rotterdam Convention on Hazardous Chemicals: A Meaningful Step

toward Environmental Protection?”. Georgetown International Environmental Law Review

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STOCKHOLM CONVENTION: “RIDDING THE WORLD OF POPS!”43
The Stockholm Convention is a global treaty designed to protect human health and
the environment from persistent organic pollutants (POPs).

POPs are very toxic chemical substances that also persist in the environment – and
can thus travel long distances - and tend to bio-accumulate as they move upwards
through the food chain. They pose a serious risk of adverse effects to human health
and the environment.

The Stockholm Convention entered into force on 17 May 2004, and counted with
153 Parties as of March 2008.

Box 3.5. Spread the message: take POPs to Court!

In court, a person is innocent until proven guilty. Chemicals suspected of bioaccumulating,

persisting in the environment, and harming human beings and animals do not deserve that
kind of protection. The Stockholm Convention has enough evidence to convict the 12 POPs
of posing a significant risk. However, it also recognizes that there are other suspects out
there that could pose the same or similar threats. For POP no. 13 and beyond, the
Convention clearly states that the required standard of evidence will be based on the need
for precaution.

Source: UNEP (2005). “Ridding the world of POPs: A guide to the Stockholm Convention on Persistent
Organic Pollutants” http://www.pops.int/documents/guidance/beg_guide.pdf (last accessed 8
February 2008)

How it works…
The Stockholm Convention requires countries to ban the production of POPs
pesticides and industrial chemicals and to reduce, and wherever feasible, eliminate
the release of unintentional chemical by-products. The Convention aims to:
• Eliminate the intentional production and use of POPs;
• Minimize releases from unintentional production of POPs, such as dioxins
and furans, which are produced by incomplete combustion;
• ensure that stockpiles and wastes of the listed chemicals are managed and
disposed of in an environmentally sound manner; and
• Impose certain trade restrictions.

Although the Stockholm Convention agreed an initial list of twelve compounds or

groups of compounds, criteria have been established for the inclusion of new POPs
to the initial list. Any Party can submit a proposal to the Secretariat to list a
chemical in Annex A (Elimination), Annex B (Restriction) or Annex C (Unintentional
Production) however, the proposal needs to contain the information specified in
Annex D (Screening Criteria).

To this end, a subsidiary body of the Convention was established, the POPs Review
Committee, for the purpose of analysing and recommending new additions to the
original list.

43 Based on the official website of the Stockholm Convention on Persistent Organic Pollutants
http://www.pops.int

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Examples of substances regulated…
The Convention initially targeted a list of 12 POPs (the “Dirty Dozen”) but has a
procedure for adding others.
• Nine of the POPs are pesticides: aldrin, chlordane, DDT, dieldrin, endrin,
heptachlor, hexachlorobenzene, mirex, and toxaphene;
• Two industrial chemicals: hexachlorobenzene (HCB), which here gets
counted twice since it is also used as a pesticide and can be a byproduct of
pesticide manufacture; and the class of industrial chemicals known as PCBs,
or polychlorinated biphenyls. PCBs have received a great deal of publicity for
polluting rivers and lakes in industrial regions, killing or poisoning fish, and
causing several human health scandals, including contamination of rice oil;
and
• A group of 2 unintentional chemical by-products: polychlorinated dioxins
and furans. These compounds have no commercial use. Dioxins and furans
result from combustion and from industrial processes such as the production
of pesticides, polyvinyl chloride, and other chlorinated substances. Dioxins
and furans are the most potent cancer-causing chemicals known; they
gained worldwide attention in the late 1990s when they were found to have
contaminated chicken meat in several European countries.

There is enough scientific evidence that POPs inflict serious harm and damage to
the environment and human health, including to the offspring of current
generations. Solid evidence has been gathered associating human exposure to
specific POPs or classes of POPs with:
• Cancers and tumours at multiple sites;
• Neurobehavioral impairment including learning disorders, reduced
performance on standard tests and changes in temperament;
• Immune system changes;
• Reproductive deficits and sex-related disorders;
• A shortened period of lactation in nursing mothers; and
• A variety of diseases such as endometriosis (a painful, chronic
gynaecological disorder in which uterine tissues grow outside the uterus),
and increased incidence of diabetes, among others.

Much still needs to be done…

As a management tool, the Stockholm Convention calls upon each Party to develop
a plan, as part of implementing its obligations. The National Implementation Plan
(NIP) must be transmitted to the Secretariat of the Convention within two years of
the entry into force of the Convention for such Party. The National
Implementation Plans (NIPs) are meant to be reviewed and updated, as
appropriate.

The Convention recognizes –article 7 paragraph 2- that all parties, where

appropriate, shall cooperate directly or through global, regional and subregional
organizations, and consult their national stakeholders in order to facilitate the
development, implementation and updating of their implementation plans. As these
National Implementation Plans are submitted, implemented, and updated, workers
and trade unions need to engage your national governments, requesting
opportunities to participate, monitor and help revise the National
Implementation Plans to improve their effectiveness.

The complete list of POPs candidates goes far beyond the initial twelve. It is
therefore important to push to have the list enlarged and to ensure proper
implementation. To demand for effective compliance mechanisms are also
important issues that need to be put forward and addressed.

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 Box 3.6. Success story: Trade union participation in the Spanish National
Implementation Plan

Spanish trade unions have participated in the elaboration of the Spanish National
Implementation Plan. This National Implementation Plan has been elaborated through a
participatory process that has included employers, trade unions and environmental and
other non-governmental organizations.

Source: National Implementation Plans. Spain

http://www.pops.int/documents/implementation/nips/submissions/NIP_spain.pdf (last accessed 14
April 2008)

Where to get more information?

For more information, go to the reading material on the Stockholm Convention

http://www.pops.int/

Civil Society Organizations:

• International POPs elimination network (IPEN) http://www.ipen.org/
• Trade union clearing house on POPs http://www.sustainlabour.org/pops/

ILO CONVENTIONS AND RECOMMENDATIONS ON CHEMICAL SAFETY

One of the key functions of the International Labour Organization since the
beginning has been the establishment of international standards on labour and
social matters. These international labour standards take the form of Conventions
and Recommendations. About 70 of them deal with occupational safety and health
matters.

How it works…
Conventions are comparable to multilateral international treaties: they are open to
ratification by member States and, once ratified, create specific, binding obligations.
A State that has ratified a Convention is expected to apply its provisions by
legislation or by other appropriate means as indicated in the text of the Convention.

In addition to the ILO Conventions and Recommendations dealing with occupational

safety and health matters, further guidance is provided in Codes of Practice and
manuals used as reference material by those in charge of formulating detailed
regulations or responsible for occupational safety and health.

Examples of the most relevant conventions on chemical safety…

Some of the most relevant Conventions on Chemical Safety are listed below, which
you most likely know:
• ILO Convention 174 concerning the Prevention of Major Industrial
Accidents (1993) and its accompanying Recommendation 1993 (No. 181)
aims to protect workers, the public and the environment from major
industrial accidents, in particular through the prevention of major accidents
involving hazardous substances and the limitation of their consequences;
• ILO Convention 170 concerning Safety in the use of Chemicals at
Work (1990) and its accompanying Recommendation (No.177) represent
international efforts to upgrade the national measures and harmonize
regulatory standards. They emphasize the need to establish a coherent

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 national policy of chemical safety ranging from the classification and
labelling of chemicals to the control in all aspects of the use of chemicals;
• ILO Convention 162 concerning Asbestos (1986) advances
organizational, technical and medical measures to protect workers against
hazardous asbestos dust;
• ILO Convention 155 concerning Occupational Safety and Health
(1981);
• ILO Convention 148 concerning Working Environment (Air Pollution,
Noise and Vibration) (1977);
• ILO Convention 139 concerning Occupational Cancer (1974) and its
related accompanying Recommendation No.147 provides for efforts to
replace carcinogenic agents with safe products;
• ILO Convention 136 concerning Benzene (1971); and
• ILO Convention 135 concerning Workers’ Representatives
Convention (1971).

What still needs to be done…

Ratification, in addition to effective implementation, is a core problem for
the ILO Conventions. For example, only 15 countries have ratified ILO
Convention 170, and only 50 countries have done so for ILO Convention 155.

There are over 180 ILO conventions in many areas of labour law, industrial
relations and social security, but they have not been universally ratified. For the
conventions adopted between 1975 and 1995, the average ratification is about 13
percent 10 years after their adoption.44

There are different views or explanations for these low figures. For developing
countries, the economic costs of ratification are one of the major reasons for
refusing to be legally bound. For industrialized countries, the ratification of ILO
conventions is more likely to depend on internal political factors such as
government preferences, or the power of left-wing parties in parliament.

Regardless of the reasons for failures to ratify, those most directly and adversely
affected are workers. Therefore, urging Governments to ratify and adopt the
necessary measures is a priority.

Where to get more information?

ILO. “Standards on Safety and Health”

http://www.ilo.org/public/english/protection/safework/standard.htm#cr_specrisk

Based on ILO Conventions official website http://www.ilo.org/ilolex/english/convdisp1.htm

POLLUTANT RELEASE AND TRANSFER REGISTERS (PRTRS)

Following the 1992 United Nations Conference on the Environment and

Development (UNCED), including its adoption of Agenda 21, there has been
increased support among the international community and individual governments
for the establishment of national Pollutant Release and Transfer Registers
(PRTRs) as a means of improving environmental management at the national level.

44 Boockmann B. (2000). “The ratification of ILO conventions: A failure time analysis”. ZEW Discussion
Paper No. 00-14, Centre for European Economic Research (ZEW)

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How it works…
A Pollutant Release and Transfer Register (PRTR) is a catalogue or database of
releases and transfers of potentially harmful chemicals including information on the
nature and quantity of such releases and transfers. The data for PRTRs can be
collected from point sources of pollution, such as factories, as well as from diffuse
sources, such as agricultural operations or transportation activities. A PRTR usually
covers releases to air, water and land as well as wastes transported to treatment
and disposal sites.

A PRTR is a means of obtaining regular, periodic information about releases and/or

transfers of chemical substances of interest and for making this information
accessible to those who may be interested in and/or affected by it. As such, a PRTR
is a tool for promoting efficient and effective policies for environmental protection
and sustainable development.

Several national and regional government organizations have developed systems to

collect and disseminate data on environmental releases and transfers of toxic
chemicals from industrial facilities. International bodies, environmental groups,
industrial firms and associations, and other non-governmental organizations are
also involved in developing these systems.

Examples of data introduced…

Key features of a PRTR include: periodic collection of information to allow tracking
of trends over time; the use of common identifiers for chemicals, facilities and
locations to facilitate comparison and aggregation of the data; computerization of
the information for ease of analysis; and dissemination of the information to
government policy makers and the public. Some potential applications of PRTR
information include mapping the data to discern the proximity of pollution sources
to population centres or to ecologically sensitive areas, as a way of highlighting
potential health or environmental impacts and effectively targeting management
efforts. Trends in the data can reveal the progress made by individual facilities or
industrial sectors in reducing waste and minimizing pollution, or help identify
opportunities for improvement.

What still needs to be done…

One of the reasons for the success of PRTR systems is that they entail benefits for
and can possibly used by not only for governments, but also for the reporting
industries and the public. For example, PRTRs provide government authorities with
useful data for setting environmental management priorities, enhance knowledge
within industry about inefficient and wasteful production processes, raise public
awareness about potentially toxic releases, and increase the ability of all
stakeholders to participate in environmental decision making.

It is important to ensure that workers and trade unions have easy access to
information and use it. They should also keep track of how data are produced. With
this view, effective, externally monitored mechanisms are necessary to guarantee
the quality of the information provided by companies.

Indeed, well-informed workers can take measures to protect themselves and their
facilities from chemical-related disasters. Similarly, well-informed communities can
promote and monitor the progress of environmental improvement efforts.

Moreover, PRTRs can be a source of valuable information to fire departments, the

police, hospitals and other emergency response professionals who must respond to
chemical-related emergencies. PRTRs are also useful to teachers and academics
who use PRTR information for educational activities and research purposes.

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It is important, then, to demand the development and use of PRTR information
in Developing Countries, and to ensure the collection of PRTR data by the various
levels of government, industry, trade unions, non-governmental and community
groups. When it becomes available, this information should also be made easily and
readily accessible to the public.

Where to get more information?

GOVERNMENTS
- Australia - National Pollutant Inventory (NPI) www.npi.gov.au
- Canada - National Pollutant Release Inventory (NPRI) - http://www.ec.gc.ca/pdb/npri - On February
16, 2001, the National Pollutant Release Inventory (NPRI) launched a new and improved web site.
Some of the new features include the organization of the site by topic, the compilation of previous
years’ information in one location and features that enhance the usability and functionality of the site.
- Czech Republic http://www.ecn.cz/PRTR
- France http://www.pollutionsindustrielles.ecologie.gouv.fr/IREP/
Mexico - http://www.ine.gob.mx/ueajei/publicaciones/libros/327/i.html?id_pub=327
- Spain http://www.eper-es.es/
- Switzerland Swiss PRTR (Swiss Pollutant Release and Transfer Register), Swiss Agency for the
Environment, Forests and Landscape
(SAEFL)http://www.bafu.admin.ch/chemikalien/01389/01401/index.html?lang=en
- United Kingdom Environment Agency Pollution Inventory http://www.environment-agency.gov.uk/pi
- United States http://www.epa.gov/tri

ORGANIZATIONS
- Commission for Environmental Cooperation (CEC) Taking Stock North American Pollutant Releases
and Transfers
http://www.cec.org/programs_projects/pollutants_health/prtr/index.cfm?varlan=english
- Environmental Defence Fund The Chemical Scorecard http://www.scorecard.org
- Environmental Management and Law Association (EMLA) - http://www.emla.hu
This Hungarian non-governmental civil expert association is a pioneer and advocate of PRTR in
Hungary.
- Europe Includes information on the http://eper.cec.eu.int/(EPER)
- Friends of the Earth Factory Watch http://www.foe.co.uk/factorywatch
- Global Chemical RTK Resources http://www.mapcruzin.com/globalchem.htm
- Intergovernmental Forum on Chemical Safety (IFCS) http://www.who.int/ifcs/
- Inter-Organization Programme for the Sound Management of Chemicals (IOMC)
http://www.who.int/iomc/en/
- IOMC PRTR Coordinating Group Terms of Reference http://www.who.int/iomc/groups/prtr/en/
- IOMC Coordinating Groups Standard Operating Procedures
http://www.who.int/iomc/groups/en/
- The Right-to-Know Network (RTK NET) http://www.rtk.net/
- United Nations Environment Programme Pollutant Release Transfer Registers (UNEP PRTR)
http://www.chem.unep.ch/prtr/default.htm
- United Nations Institute for Training and Research (UNITAR)
http://www.unitar.org/cwm/b/prtr/
- UNITAR Chemical and Waste Management Publications – PRTRs
http://www.unitar.org/cwm/publications/#BT1
- World Bank New Ideas in Pollution Regulation (NIPR) http://www.worldbank.org/nipr/
- World Health Organization PRTRs and emission estimation models
http://www.who.int/docstore/water_sanitation_health/HIA/EEmodels.htmlhttp://www.who.int/water_
sanitation_health/HIA/EEmodels.html

REACHING REGIONAL AGREEMENTS

The European Union is the world’s largest chemical producer, representing about
28% of worldwide chemical output. Seven years of intense debate has culminated
in the EU chemicals legislation reform, finally adopted by the European Parliament
and Council in December 2006.

On the 1st June 2007, REACH regulations for the Registration, Evaluation and
Authorization, and Restrictions of CHemicals entered into force in the
European Union.

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How it works…
REACH unifies more than 40 norms and regulations on this issue and affects 30,000
substances of the estimated 103,000 substances which are already in the European
market. REACH establishes a new system of management and control of human
and environmental risks caused by hazardous chemical substances.45

REACH introduces the principle of precaution and establishes a framework for the
substitution of the most dangerous substances where safer alternatives already
exist in the market. In addition, it shifts the burden of proof: from now on
producers, importers and intermediate users of chemical substances and
compounds –instead of the Administration or victims having to prove the hazard-
will have to demonstrate and guarantee that they only produce, trade or use
substances that do not negatively affect human health or the environment.

To ensure this, REACH mandates companies to provide information, and to

guarantee in chemical uses that the risks these substances can entail are managed
in a responsible way. The cornerstone of REACH is the potential to generate and to
provide access to information on the uses, dangers, risks and preventative
measures associated with various families of the substances and compounds.

While the costs of implementation of REACH will be significant, these are primarily
incurred by industry for testing purposes. So far, most analyses have not
considered the health and ecosystems benefits associated with REACH or its
potential to stimulate innovation in safer substances.

REACH has been eagerly awaited, and while views differ as to whether this new EU
regime is strong enough, it does represent an important step forward towards a
more secure and transparent chemical industry. The measures included within
REACH will result in increased information on the effects of substances on human
health and the environment, and will promote more sustainable production and
uses of chemistry.

Box 3.7. Success story: the role of European trade unions

European trade unions, lead by the European Trade Union Confederation (ETUC), have
campaigned for years to establish an effective framework for safeguarding the
environment and workers’ health. The approval of the REACH regulation is an important
step in the management of chemical substances and has to be recognized as such.

Nevertheless, ETUC clearly acknowledges the strong lobby and pressure exercised by the
chemical industry, and regrets that some provisions were consequently weakened or
dropped. More specifically, European trade unions take issue with the fact that information
vital to protecting workers’ health given in the chemical safety reports will now only be
required for a third of the chemicals originally planned. This means that workers who are
exposed to the 20,000 chemicals produced in quantities of from 1 to 10 tonnes will be
denied access to information that is vital to their safety.

Source: ETUC. REACH. Press releases on REACH http://www.etuc.org/r/830 (last accessed 15 April
2008)

45 Based on http://europa.eu/scadplus/leg/en/lvb/l21282.htm (last accessed on 15th February 2008),

Substance: a chemical element and its compounds in the natural state or obtained by any manufacturing
process, including any additive necessary to preserve its stability and any impurity deriving from the
process used, but excluding any solvent which may be separated without affecting the stability of the
substance or changing its composition.

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What still needs to be done…
REACH marks clear progress, because industry will now have to provide information
on the safety of their chemicals before they can put them on the market. However,
the success and great challenge for the success of this regulation depends on the
way it will be implemented, to ensure proper application, control and surveillance
of chemicals.

In this field, trade unions have a key role to play in promoting training, information,
control and pressure. Several questions are relevant, and need to be answered in
the coming months and years:
• What consequences will REACH have for current legislations that address
workers’ and environmental protection?
• How can workers participate in the process?
• How will REACH help improve workers and the public’s health, as well as
environmental protection?

At the international level, it will be interesting and important to consider how

REACH-generated information can be used beneficially, not only under that regime,
but also in support of other programs and regimes, including:
• How the Unions will be able to use the REACH-related information on
chemical substances and compounds, including the use, dangers, risks and
preventive measures as well as the array of substances and processes
referred to as alternatives?
• How global Unions and Federations will be able to be include various REACH
aspects into Global Framework Agreements with multinational companies;
• How agreements can be promoted between the European Commission and
other governments for the exchange and use of information similar to that
called for under the REACH regulation?

For these and other potential follow-on initiatives, there are many paths and
avenues to be explored. These include the possibility in the medium- or long-term
that REACH might provide the core elements and basis for a global chemicals
management convention and regime that addresses similar to, if not even more far
reaching requirements than the current REACH regulation? In any case, these are
some of the questions and debates that deserve sustained attention and focused
attention from now onwards.

Where to get more information?

For information produced by trade unions on REACH:

European Trade Union Institute (ETUI) http://hesa.etui-rehs.org/uk/dossiers/dossier.asp?dos_pk=1

For more information on REACH:

European Chemicals Agency (ECHA) http://ec.europa.eu/echa/home_es.html
European Chemicals Bureau (ECB) http://ecb.jrc.it/
International Uniform Chemical Information Database (IUCLID) http://ecb.jrc.it/iuclid/

The European Commission has launched in an informative video on REACH in EUtube that can be
downloaded from http://nl.youtube.com/watch?v=cURiPGJDjSA

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 Unit 2: NEGOTIATION AT THE NATIONAL LEVEL: OUR
NEIGHBOURS ADOPTED IT, WHY CAN’T WE?

This unit will address the following issues:

1. What is the role of tripartism?

2. What is the importance of social alliances for a sustainable management of
chemicals?

DEMANDS TO GOVERNMENTS: ENHANCING TRIPARTISM

A considerable number of international bodies are working on chemical safety.

However, all the different international instruments presented above require
national enforcement mechanisms and actual application to be effective.

Social pressure is important to ensure their approval and implementation. Trade

unions have long been characterized by their political activity in this field, both for
the promotion of legislation favourable to the interests of their members or workers
as a whole; and for their engagement in broader political and social struggles46 for
the well-being of people and of society as a whole. To this end campaigns, lobbies,
demonstrations and strikes are undertaken, and will be again in the future.

Occupational safety and health has been and still is an important area of trade
union concern and action. In this regard, it involves a multi-faceted focus that
includes:
• Preventing job displacement or disabilities as a result of conditions that were
hazardous and harmful to workers’ health;
• Protecting workers in their employment from broader risks, caused by
factors that adversely affect their health; and
• Placing and maintaining support for workers so that they benefit from an
occupational environment adapted to his/her physiological and psychological
capabilities.

Environmental concerns have gradually been introduced into the trade unions’
agendas. That said, these issues need to be introduced and pushed much more
strongly at the national level. The current model of development is socially unfair
and environmentally unsustainable. A sustainable and fair development requires
broader labour rights along with broader environmental protection. In this context,
workers and trade unions are in a unique position to stimulate dialogue
around positive social and environmental dimensions of sustainable
development while simultaneously contributing to economic development.

Chemistry as practised nowadays is damaging to human health and the

environment. Society, collectively, must to act for the substitution and in some
cases the ban of some chemicals, while simultaneously looking for non-chemical
alternatives. These critical steps are essential, as part of broader efforts to advance
towards a sound and sustainable management of chemicals, based on the
development of clean production and green-chemistry.

46 This latter group include a broad array of activities such as political and social democracy, civil and
democratic rights, the elimination of poverty, equality, and the rule of law, etc.

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Social dialogue, which includes all types of negotiation between, or among,
representatives of governments, employers and workers, is an important tool that
can explain many success stories. It is important to operate within tripartite
processes, ones that enable a joint negotiation process with the government, the
employers, and the employees as the official parties.

Concrete experience demonstrates the importance and necessity of such tripartite

processes. The following “success” stories recount only a few examples of why such
a process can be extremely effective in achieving Occupational and
Environmental Health and Safety:

Box 3.8. Success story: Trade union “Environment delegate” in Navarra, Spain

In the Employment Plan in Navarra, Spain for 2005-2007, agreement was reached on the
creation of a Territorial Delegate for the Environment, as a result of the negotiations
between the regional Government of Navarra, employers (Business Association CEN), and
the Spanish trade unions CCOO and UGT.

They agreed that:

As with occupational risks, prevention is the basic orientation that is needed to
avoid environmental risks; and
Paths toward clean production that are non-polluting and respectful of the
environment and the use of the natural resources. These paths also lead toward
healthier working and living conditions.

The main characteristic of the Delegate for the Environment is that it is not linked directly
to a business or the workplace. Instead, its field of action and basis for interventions will
be the territorial Community of Navarra. There will be six delegates, with four appointed by
the trade unions and two by the employers.

The Delegates will collaborate on the implementation of Environmental Management

Systems and their regulations, and will work closely with trade union representatives, and
with business management in the productive sectors. Based on available information and
thanks to her/his expertise, any Delegate can bring to the table actions that contribute to
social, labour, industrial and economic advances towards Sustainable Development.

Source: ISTAS, Union Institute of Work, Environment and Health of the CCOO,
http://www.istas.net/web/daphnia.asp?articulo=763 (last accessed 10 February 2008)

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 Box 3.9. Success story: A tripartite agreement on Benzene in Brazil

The National Tripartite Agreement on Benzene, concluded in 1995 between Brazilian trade
unions, the petrochemical industry, and the national government, provides a model of
employer-union cooperation for sustainable development. It was signed by industrial
associations, Brazilian trade union centres, the Government, and Fundacentro, after a
vigorous campaign led by the Unified Workers Confederation (CUT). The agreement makes
it mandatory for companies and sub-contractors to carry, store, use or handle benzene and
its derivatives in a prescribed manner, to register its use with the Ministry, and to define a
“Programme of Prevention” of benzene’s hazards in every workplace.

Standards and procedures define objectives, applications, and responsibilities for each
workplace party, and a Technical Standard for safe exposure determined by workers,
employers and government. Strict procedures are defined for evaluation, and workers are
involved in monitoring. In each plant, workers participate in a Representative Group of
Workers (GTB), educated and responsible for monitoring and enforcing the designated
Programme for Prevention of Occupational Exposure to Benzene (PPEOB). They also have
equal representation on a "Permanent National Commission for Benzene" (CNPBz) that
oversees developments, monitors compliance, promotes studies, supplements laws and
regulations, and issues Certificates for the Controlled Use of Benzene to companies.
Periodic seminars on Benzene organised under the Accord provide for joint evaluation of
the Accord.

Source: Ministerio do Trabalho e Emprego, Acordo Benzeno,

http://www.mte.gov.br/seg_sau/comissoes_benzeno_acordo.asp (last accessed 15 April 2008)

The structure of employment laws affects unions’ roles and the way they carry out
their business. Different States take different approaches to legislation, regulation,
and enforcement. For example, in many Western European countries, wages and
benefits are largely set by governmental action. Instead, the United States takes a
more laissez-faire approach, setting minimum standards but leaving most workers’
wages and benefits to collective bargaining and market forces.

However, in many countries, unions still do not have the legal right to represent
workers, or this right is disputed. This non-existent or uncertain status can result in
non-recognition of a union, or even in political harassment or criminal prosecution
of union activists and members, with many cases of violence and deaths recorded
historically, until nowadays.

International solidarity and external pressure are key in the efforts to promote
these basic labour rights. Moreover, efforts should also concentrate on denouncing
the double standards applied by some countries.

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 Box 3.10. ITUC Annual Survey of violations of trade union rights

The 2007 edition of the ITUC Annual Survey of violations of trade union rights, covering
138 countries, shows an alarming rise in the number of people killed as a result of their
trade union activities, from 115 in 2005 to 144 in 2006.

Colombia is still the deadliest country in the world for trade unionists. Another challenge is
the sharp increase in the number of deaths in both Asia and Africa. Literally thousands of
trade unionists were arrested during the past year for their part in strike actions and
protests to defend their rights, while thousands more were dismissed, in some cases for
simply trying to form or join a union. In industrialised countries, several governments
sought to restrict trade union rights through changing labour legislation, removing or
restricting the rights to bargain collectively, to strike or even to organize.

Source: Annual Survey of violations of trade union rights (2007), http://survey07.ituc-

csi.org/getcontinent.php?IDContinent=0&IDLang=EN (last accessed 14 April 2007)

THE IMPORTANCE OF SOCIAL ALLIANCES IN THE DECISION MAKING47

It is important to integrate workers, trade unions and the labour movement as a

whole into broader coalitions for social and economic justice, where they can
support each other on what they see as mutually beneficial goals.

Social relations and alliances have a long history, particularly between the labour
movement and local communities. The cooperation between trade unions and NGOs
is more recent and more complex, ranging from close cooperation to more
problematic relationships, but it offers important potential and opportunities for
collaboration. When unions and NGOs co-operate, their joint impact on social and
political events can be quite powerful. When such cooperation fails, it can hinder
significantly the agenda of both.

When the modern movement for environmental protection arose in the 1960s, its
relations with the labour movement were ambivalent. In the short term, many
trade unions saw ecological movements as threats to employment. At the same
time, the environmental movement had difficulties to relate environmental concerns
with the social and labour dimension.

In recent years, awareness of the need for long-term sustainable development is

spreading throughout the labour movement, as it is gradually doing among the
public. This growing awareness is leading to forms of cooperation among Unions
and environmental NGOs.

The capacity of environmental NGOs to mobilize public opinion, and consequently

bring powerful transnational corporations to the bargaining table has contributed to
this favourable shift. Unions and NGOs began seen each other more as potential
allies.

Cooperation has also developed with research institutes and universities on

social/labour issues are also important to strengthening workers’ and trade union’s
efforts towards social and economic justice.

47 Based on Gallin, D. (posted on December 2006). “Trade Unions and NGOs in Social Development: a
Necessary Partnership”. Global Labour Institute
http://www.globallabour.info/en/2006/12/trade_unions_and_ngos_in_socia.html (last accessed 19
December 2007)

138
Looking to the future, the way society develops will that are resulting from common
struggles and social alliances among these various non-governmental forces.

Box 3.11. Successful alliances: An agreement on chlorine

The International Federation of Chemical Energy, Mine & General Workers’ Unions (ICEM)
has worked with Greenpeace on an agreement with the chemical industry on chlorine. In
this matter, ICEM also collaborated with other NGOs and indigenous defence groups on a
campaign against Rio Tinto Zinc (RTZ), a leading mining company accused of conducting
its operations in socially and environmentally unacceptable conditions.

Source: Based on Gallin, Dam (posted on December 2006) Trade Unions and NGOs in Social
Development: a Necessary Partnership, Global Labour Institute,
http://www.globallabour.info/en/2006/12/trade_unions_and_ngos_in_socia.html (last accessed 19
December 2007)

Box 3.12. Successful alliances: Clean Clothes Campaign (CCC)

The International Textile, Garment & Leather Workers’ Federation (ITGLWF) participates in
the Clean Clothes Campaign (CCC), a coalition started in the Netherlands in 1990 with the
objective of improving working conditions in the garment industry worldwide.

It includes trade unions, consumer organizations, women’s groups, solidarity

organizations, development organizations, several shops around the world, and other
NGOs. Since 1995, CCC has expanded to other European countries. Similar campaigns
were also held in Australia, Canada and the US, in the wake of the CCC campaign.

Initially focused on Asia, CCC has more recently become active in Africa and in Central and
Eastern Europe. The organizations involved in the different national CCCs are trade unions
and NGOs who have their own partner organizations in the producing countries. CCC
organizes support for workers in a conflict situation, and also has a small strike fund.

Source: Based on Gallin, Dam (posted on December 2006) Trade Unions and NGOs in Social
Development: a Necessary Partnership, Global Labour Institute (last accessed 19 December 2007)

Box 3.13. Successful alliances: Campaign against the scrapping of contaminated

ships

The International Transport Workers’ Federation (ITF) and International Metalworkers’

Federation (IMF) have supported a Greenpeace campaign against the scrapping of
contaminated ships in Asia, particularly in India.

Some ships are contaminated with high levels of toxic and hazardous materials, including
heavy metals and asbestos. The two international federations point out that offshore
scrapping pollutes the environment and endangers the health of the workers involved;
ships scrapped in Asia should be free of substances such as asbestos, lead, other heavy
metal compounds, oily wastes and polychlorinated biphenyls. Ship owners should be
responsible for rendering ships non-hazardous before breaking them up. There must be
adequate safeguards for the environment and nearby communities. Shipbreaking workers
should enjoy significantly improved health and safety conditions

Source: Based on Gallin, D. (posted on December 2006). “Trade Unions and NGOs in Social
Development: a Necessary Partnership”. Global Labour Institute
http://www.globallabour.info/en/2006/12/trade_unions_and_ngos_in_socia.html (last accessed 19
December 2007)

139
Box 3.14. Successful alliances on pesticides

The International Union of Food Agric. Hotel Rest.Cater.Tobac.& Allied Work. Assoc. (IUF)
works with the Pesticide Action Network (PAN) and its regional bodies as well as with the
Brazil-based Grupo Interdisciplinario de Pesquiza e Acção em Agricultura e Saúde (GIAS)
on pesticides.

In response to the situation relating to genetically modified food, especially problems

caused by the use of pesticides and concerns about sustainable agriculture, the Latin
American Regional Organization of the IUF initiated, in September 1998, a joint project,
named BioMater, involving trade unions, peasant organizations and NGOs aimed at
preserving, producing and distributing seeds. BioMater has established a seed bank for
organic production of seeds that will be registered in most Latin American countries.

Source: Based on Gallin, D. (posted on December 2006). “Trade Unions and NGOs in Social
Development: a Necessary Partnership”. Global Labour Institute
http://www.globallabour.info/en/2006/12/trade_unions_and_ngos_in_socia.html (last accessed 19
December 2007)

140
 Unit 3: NEGOTIATION IN THE WORKPLACE: NOT WORTH
DYING FOR A JOB

There are three main types of reasons for employers to establish better
occupational and environmental safety and health standards:
• Moral - An employee should not have to risk injury at work, nor should
others associated with the work environment;
• Economic - Employing organizations also sustain costs in the event of an
incident at work (such as legal fees, fines, compensatory damages,
investigation time, lost production, lost goodwill from the workforce, from
customers and from the wider community); and
• Legal - Occupational safety and health requirements are reinforced in civil
law and/or criminal law; it is accepted that without the extra
"encouragement" of potential regulatory action or litigation, many
organizations would not act upon their implied moral obligations.

The mechanism to achieve the occupational and environmental and health

standards is through collective agreements.

Collective bargaining is an important tool for raising living standards and

improving working conditions. Even though safety and health are addressed in the
national laws of almost all countries, collective bargaining often provides the
mechanism through which these laws are actually implemented in the workplace.
For example, the law may mandate joint safety and health committees or works
councils, but leave the details to negotiation between the employers and the
workers’ organizations.

There are certain legal and structural pre-conditions for collective bargaining to
function properly. The democratic foundations and the appropriate legal framework
to ensure independence and the effective participation of social partners are
essential.

Unfortunately, collective bargaining is under attack by authoritarian employers and

repressive governments, both in developed and developing countries. It rarely
exists in the informal sector or in small, traditional enterprises. As a result, the
majority of the world’s workers do not yet enjoy the benefits of effective collective
bargaining under a legal framework that guarantees labour rights.

Collective bargaining takes place between an employer, a group of employers or

one or more employers’ organizations on the one hand, and one or more workers’
organizations on the other. It may take place at many different and often
complementary levels: a unit within an enterprise, the enterprise level, or the
sector, regional or national level.48

48 Based on ILO Social Dialogue website http://www.ilo.org/public/english/dialogue/themes/cb.htm (last

accessed 19 December 2007)

141
Collective bargaining serves a dual purpose:
• It provides a means of determining the wages and conditions of work
applying to the group of workers covered by the ensuing agreement through
free and voluntary negotiations between the two independent parties
concerned; and
• It enables employers and workers to define by agreement the rules
governing their relationship.
These two aspects of the bargaining process are closely interrelated.

Collective bargaining can be advantageous for both workers and employers:

• For workers, collective bargaining, more so than individual employment
relations, ensures adequate wages and working conditions by providing
them with a “collective voice”; and
• For employers, collective bargaining helps to stabilise industrial relations by
maintaining industrial peace that otherwise may be disrupted by labour
unrest.

The scope of collective agreements can be limited to a single workplace centre, or

to the different working centres a company has in the same country. However, they
can also be agreed at the regional and international level as Global Framework
Agreements, which are a really important tool.

In many situations, multinational enterprises reinforce dualistic economic structures

and exacerbate income inequalities. Multinationals use their economic power to
influence government policies in directions that may not favour development. They
are able to extract sizeable economic and political concessions from competing
governments in the form of excessive protection, tax rebates, investment
allowances and the cheap provisions of factory sites and services. As a result, a
non-regulated environment appears to be a condition for investment. This allows
irresponsible and unsustainable social and environmental behaviours.

The weakness of regulation leaves an open space for the evolution of voluntary
practices. Trade union action in developing countries faces at least two challenges
regarding the corporate accountability:
• Firstly, the governments need to be pressed by the Unions to strengthen
regulatory frameworks for private investment, including in export processing
zones (EPZ), in order to ensure their social and environmental sustainability.
• Secondly, Unions need to guard against the adoption of voluntary
approaches to corporate responsibility that do not undermine the first goal,
and to help ensure a conducive environment for trade union action on
environment and social issues.

International coordination is important to face these situations. In this regard, the

development of Global Union Federations’ Global Framework Agreements is a
good example of international solidarity among trade unions. They become an
important tool when making demands to Multinational companies, particularly when
the trade unions involved are strong enough to ensure implementation and follow-
up.

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Box 3.15. Success Story: Responsible Care programme on chemicals

The Responsible Care programme is a voluntary worldwide initiative on health, safety and
the environment by the chemicals industry. It was launched in 1985 in Canada by the
Canadian Chemical Producers’ Association (CCPA). It was taken up in 1989 in Europe by
the European Chemical Industry Council (CEFIC) and in 1998 in the USA.

In 2003, the European social partners in the chemicals sector - the European Mine,
Chemical and Energy Workers’ Federation (EMCEF) on the trade union side and CEFIC and
the European Chemical Employers Group (ECEG) on the employers’ side - signed a
“memorandum of understanding” on the basis of the Responsible Care programme. This
agreement sought to develop the involvement of workers and their representatives in
Responsible Care. The European programme is seen as very important because:
• it has focused attention in Europe on workers’ involvement in health, safety and
environmental issues, despite the failure to reach a global agreement on the issue,
which was reportedly blocked by US companies in 2000/01;
• it has set high health, safety and environment protection standards as a top
priority on the agenda of all European chemical companies; and
• it has recognized the right of workers’ and workers’ organizations to participate
actively in Responsible Care programmes.

Source: European Industrial Relations online observatory. “Information from European Foundation for
the improvement of living conditions” http://www.eurofound.europa.eu/eiro (last accessed 19
December 2007)

143
Module 3 references

Official websites:
Basel Convention. http://www.basel.int/
European Foundation for the improvement of living conditions, European Industrial Relations
observatory on-line http://www.eurofound.europa.eu/eiro
Intergovernmental Forum on Chemical Safety http://www.who.int/ifcs/en/
ILO Conventions official website http://www.ilo.org/ilolex/english/convdisp1.htm
ILO Social Dialogue website http://www.ilo.org/public/english/dialogue/themes/cb.htm
Rotterdam Convention. http://www.pic.int/
Stockholm Convention. http://www.pops.int/
Strategic Approach to International Chemical Management http://www.chem.unep.ch/saicm/

144
NOTES:

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EP 05/08#2008-40693
 www.unep.org
United Nations Environment Programme
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