The Guidance

The Netherlands Labour Authority have developed a comprehensive document tailored to provide employers or inspectorates guidance on how to interpret the extent of the obligations to search for alternatives for using carcinogenic substances. This resource offers a step-by-step plan, consisting of 3 diagrams, which describe 3 different situations:

• The carcinogenic substance is the company’s end product, or it is part of it;
• The carcinogenic substance is a process substance/auxiliary substance;
• The carcinogenic substance is released unintentionally in the process (process emission)

Within each step of the plan, users will find detailed sub-questions along with accompanying suggestions and links for reference.

Following the guidance

After reading through guidance, companies will be equipped to address key inquiries, including:

• What justifies the necessity of using the substance or process, and why is technical substitution impractical?
• What initiatives has the company undertaken to explore potential replacements?

For now, the guidance is only available in Dutch.