Work program ‘Safe handling of carcinogenic substances’ (3rd Joint OSH initiative)
Overview
Type of intervention(s):
Inspection campaignNumber of inspections undertaken:
3761 (based on Q1/25)
Duration of campaign:
01.01.2020 to 31.12.2025 including generating training materials and training of inspectors, site visits and evaluation.Scope of intervention
Key duties
Seven questions:
Is a hazardous substance inventory present?
Are operating instructions available for workers?
Is medical surveillance offered to workers?
Was the exposure assessed?
Are limit values complied with?
If limit values are exceeded, is a risk reduction strategy plan present?
Is high risk exposure documented?
Focus of the Campaign
The campaign had the goal to gather the state-of-play of legal compliance regarding the 12 carcinogens especially in small and medium-sized enterprise and to promote substantial improvement in awareness
Key findings of intervention
Positive findings
Accompanying self-evaluation tools have a clear positive impact. It is an important and beneficial approach in reaching SMEs.
Negative findings
Compared to the 2nd GDA inspection campaign in which one significant finding was that only 52% of companies carried out the risk assessment, now 72.1% of companies were found to carry it out (although only approx. 1/3 adequatly). A very negative finding is that 80-85% of companies that are obliged to document high-risk exposure do not carry out that duty.
General findings
The twelve focus carcinogens can be found in almost all sectors (with a larger proportion in construction, repair and the processing sector) and where one carcinogen is present the likelihood of further carcinogens is quite substantial. The quality of the risk assessment improves with the way of safety-related attendance: If in-house, the risk assessment is adequate in 50% of the cases, with no attendance only under 5%. From the generated data, it is further possible to conclude that the legal compliance is higher when companies purchase a substance directly (i.e. a SDS delivered) and poorer when process-generated carcinogens are involved.
Key outcomes following intervention
The setup of the GDA inspection campaign aimed at investigating the state-of-play regarding the legal compliance of companies in which carcinogens are present. A follow-up visit to monitor any progress or improvement after the 1st intervention was not foreseen. The campaign showed that the legal compliance must improve in all company sizes but the biggest problems are present in very small companies. The substantial lack in documenting exposure should be in focus of any future inspection campaign to boost the awareness for this legal obligation and to promote the use of external offers (see ZED). Process-generated carcinogens need further awareness as well and their adequate assessment is generally more demanding compared to purchased chemicals.
Level and type of enforcement issued
- Verbal advice
- Written advice
- Improvement notice
- Prohibition notice
- Fines
N/A
Key EU legislation
- CMRD
Additional information
Next to the core process that aimed at answering the key objectives (seven question as indicated before), the campaign supported these inspections by accompanying processes that were designed to last longer than the inspection campaign itself. The two outstanding processes are the GDA Hazardous substance check (link) and the GDA Best practice database (link). The first is an online tool that guides the user through the nine steps of the risk assessment and provides the user with a systematic assessment for their legal compliance in a traffic light model. The latter gathered best practice examples (to date 228 helpful entries) that can be searched by substance and sector along the hierarchy of control and is designed to grow over time with helpful and applicable practice advice from companies to companies.
