Guidance for Employers’ obligations of the substitution of carcinogenic substances

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.