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Tanner: The risks and solutions

As a tanner, your work mainly involves the processing of animal hides into leather, and it is crucial to be aware of potential occupational hazards, including those related to carcinogenic risks. The nature of your work may expose you to substances that could increase the risk of developing cancer. As a tanner you might be exposed to chemicals used in the tanning process, such as formaldehyde and various dyes and solvents. Prolonged exposure to these substances, especially through inhalation or skin contact, can pose serious health risks, including an increased risk of developing cancer.

Although the presence of carcinogenic chromium VI compounds in leather articles is restricted in the EU, you have to be aware that imported products might still contain Chromium VI compounds and exposure to these products may be associated with an elevated skin sensitising risk to Chromium compounds.

To mitigate the risks for the occupation of tanners, it is essential to implement safety measures and adhere to best practices in tanning operations. This includes utilising proper ventilation systems and following established safety protocols that can help reduce the spread of harmful fumes and particles in the workplace. Wearing appropriate personal protective equipment (PPE), such as gloves, goggles, and respirators, will help minimising exposure to hazardous chemicals.”

  • Foundry workers: under the personal measures we do not have the link button to the general personal measures here which we usually have when we do not have specific personal measures at hand.
  • Stone mason, stone cutter, etc.

We somehow have lost all Nepsi task guidance sheets linked to these jobs that are associated with exposure to silica dust. I remember investing a lot of hours in assigning the NEPSi guidance sheets to jobs and I was wondering what is the reason for them not being shown?

Note: The CarcCheck is based on data collected for the EU. Therefore, uses of a substance might not be of equal relevance in all member states. The CarcCheck indicates were a carcinogen can potentially be involved or released; exposure potential will also vary in different sectors. Only the risk assessment will show whether this is the case in a real workplace or in a user situation.

Table of contents

Tanner: The risks and solutions

As a tanner, your work mainly involves the processing of animal hides into leather, and it is crucial to be aware of potential occupational hazards, including those related to carcinogenic risks. The nature of your work may expose you to substances that could increase the risk of developing cancer. As a tanner you might be exposed to chemicals used in the tanning process, such as formaldehyde and various dyes and solvents. Prolonged exposure to these substances, especially through inhalation or skin contact, can pose serious health risks, including an increased risk of developing cancer.

Although the presence of carcinogenic chromium VI compounds in leather articles is restricted in the EU, you have to be aware that imported products might still contain Chromium VI compounds and exposure to these products may be associated with an elevated skin sensitising risk to Chromium compounds.

To mitigate the risks for the occupation of tanners, it is essential to implement safety measures and adhere to best practices in tanning operations. This includes utilising proper ventilation systems and following established safety protocols that can help reduce the spread of harmful fumes and particles in the workplace. Wearing appropriate personal protective equipment (PPE), such as gloves, goggles, and respirators, will help minimising exposure to hazardous chemicals.”

  • Foundry workers: under the personal measures we do not have the link button to the general personal measures here which we usually have when we do not have specific personal measures at hand.
  • Stone mason, stone cutter, etc.

We somehow have lost all Nepsi task guidance sheets linked to these jobs that are associated with exposure to silica dust. I remember investing a lot of hours in assigning the NEPSi guidance sheets to jobs and I was wondering what is the reason for them not being shown?

Note: The CarcCheck is based on data collected for the EU. Therefore, uses of a substance might not be of equal relevance in all member states. The CarcCheck indicates were a carcinogen can potentially be involved or released; exposure potential will also vary in different sectors. Only the risk assessment will show whether this is the case in a real workplace or in a user situation.

Which carcinogen(s) are present?

As Tanner, the following (process-generated) carcinogens could be a potential risk for your health.
Azodyes
Estimates of current numbers of exposed workers to azo dyes, which can break down in aromatic amines, in the EU are not available. Occupational exposure to azo dyes may occur,...
Read more
Chromium VI compounds
It is estimated that about 900,000 workers in the EU are potentially exposed to chromium VI. Studies of workers in chromate production, chromate pigment and chrome electroplating industries employed before...
Please note that this substance or some of it's compounds are listed in Annex XIV (REACH regulation). This substance or some of it's compounds are only allowed to be used, imported, or brought into the market, if authorisation requirements of REACH are fulfilled.
Read more
Formaldehyde
According to the latest existing assessment from the early 1990s, 971,000 workers were estimated to be exposed to formaldehyde. Formaldehyde is a skin-sensitizing agent that can cause an immune system...
Read more
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Can the carcinogen(s) or process(es) be replaced?

Substitution is the first and top prevention measure to avoid exposure to carcinogens. The following substances or processes are considered safer alternatives for these carcinogens or represent less exposure potential.

Substitute for: Azodyes, Chromium VI compounds, Formaldehyde
Recommended
Substitution of dangerous substances
Read more
Substitute for: Azodyes, Chromium VI compounds, Formaldehyde
Work environment carcinogens: what should an employee know?
Read more
Substitute for: Azodyes, Chromium VI compounds, Formaldehyde
Factsheets for identifying and substituting carcinogens
Read more
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Are technical prevention measures in place?

Technical measures have to be used first, when substitution was not possible. The first technical measure of choice is the use of a closed, encapsulated system. Various possibilities and technical solutions are available that might be suitable to reduce exposure to as low as technically possible. These risk reduction measures vary in their effectiveness and need to be assessed for your working environment individually.

Furthermore, the following list provides you with general or technically targeted solutions provided by others within your occupation.

Short videos on carcinogenic substances and hygiene in the workplace
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
The Austrian Workers’ Compensation Board (AUVA) has translated two of their short instructional videos on carcinogenic substances and hygiene in the workplace to English. This way, other countries and organisations...
Read more
Work environment carcinogens: what should an employee know?
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
The Estonian National Institute for Health Development published this guide about carcinogens in different work environments and work areas. What are possible effects of working with carcinogens, which measures should...
Read more
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Are organisational prevention measures in place?

Organisational measures can support your exposure reduction strategy. Organisational measures must be used only when substitution was not possible, and all technical measures have been exhausted. Various organisational measures are available that might be suitable to reduce exposure. These risk reduction measures vary in their effectiveness and need to be assessed for your working environment individually.
 
Furthermore, the following list provides you with general or organisational targeted solutions provided by others within your occupation/branch.
Creating Control Guidance Sheets (CGSs)
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
Recommended
Control Guidance Sheets (CGSs) are essential tools designed to help employers manage and mitigate the risks associated with exposure to carcinogenic substances in the workplace. These documents serve as practical...
Read more
Managing the risks of carcinogens in the workplace through an educational game
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
Recommended
True to the motto ‘You can’t teach an old dog new tricks’ it is necessary to start with integrating activities that raise awareness in primary schools and in vocational educational...
Read more
Basic training module 'Chemicals Hazards at the Workplace'
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
...
Read more
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Are limit values in place?

Limit values for carcinogens are one mean to assess the exposure situation and to assess whether minimum requirements are met, or further risk reduction strategies have to be applied. The links provided above can support assessment whether technical and organisational measures have been sufficiently exhausted to minimise exposure. Please be aware that you can also assess internal exposure by biomonitoring.

Independent whether there is an European limit value in place or not, it is mandatory to minimise exposure to carcinogens as low as technically achievable. Please refer to your national legislation how to comply with minimisations duties.

As Tanner, the following (process-generated) carcinogens could be a potential risk for your health and the following EU limit values are in place.
Azodyes EU Limit values
Exposure limit: Unknown, but national limits might apply.
Chromium VI compounds EU Limit values
EU directive 2017/2398
Exposure limit: Until 17.01.2025 0,01 mg/m³
As of 18.01.2025 0,005 mg/m³
Read more
Formaldehyde EU Limit values
EU directive 2019/983
Exposure limit: 0,37 mg/m³ and 0,63 mg/m³ until 11.07.2024 in health care sectors.
Read more
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Is exposure determined?

Azodyes on the GESTIS substance database.
You should check the likelihood of exposure and route of exposure by checking the GESTIS substance database.
Read more (External link)
Chromium VI compounds on the GESTIS substance database.
You should check the likelihood of exposure and route of exposure by checking the GESTIS substance database.
Read more (External link)
Formaldehyde on the GESTIS substance database.
You should check the likelihood of exposure and route of exposure by checking the GESTIS substance database.
Read more (External link)
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If you come to the conclusion that exposure is likely, there are multiple options to assess your exposure situation.

Descriptions by the occupational prevention organisation or insurances, in practice approved control guidance sheets, REACH exposure scenarios or exposure modelling are further and eligible sources that help assessing the exposure situation as well as by comparing workplace situations. This must be documented in the risk assessment. Finally, if these methods do not allow for a conclusive exposure assessment, exposure measurements with the help of your respective insurance organisation or an external company can be performed.

Furthermore, you might want to check exposure data sources compiled here.

Is personal protective equipment provided?

You should be aware that personal protection equipment (PPE) should be used only after technical and organisational measures have been used to reduce exposure as much as possible.

Furthermore, there are strict rules for the use of PPE. For respiratory protection equipment (RPE), the filter class needs to fit the purpose, the size of the mask needs to fit the individual worker, maximal wearing time needs to be defined and workers need training for correctly equipping/un-equipping RPE.

For dermal protective equipment, adequate glove material and size needs to be assessed. Commonly, there are very rare situation when handling carcinogens, that PPE is not necessary to fulfil minimisation duties. When you decide to not use PPE, this has to be well-documented.

Furthermore, the following list provides you with solutions provided by others:

Short videos on carcinogenic substances and hygiene in the workplace
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
The Austrian Workers’ Compensation Board (AUVA) has translated two of their short instructional videos on carcinogenic substances and hygiene in the workplace to English. This way, other countries and organisations...
Read more
Work environment carcinogens: what should an employee know?
Is a good measure to reduce exposure to Azodyes, Chromium VI compounds, Formaldehyde
The Estonian National Institute for Health Development published this guide about carcinogens in different work environments and work areas. What are possible effects of working with carcinogens, which measures should...
Read more
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Further duties and additional helpful measures

Ensuring the well-being of your employees is further guaranteed by certain duties laid down in the Carcinogens, Mutagens and Reprotoxicants Directive (CMRD). Additionally, other measures have a positive impact on workplace safety and workers health by boosting awareness of all involved actors.

The following list provides support for these important aspects. However, national requirements might deviate from the Directive and therefore, please consult with your national authorities about regulatory requirements for hazardous substances:

  • Performing a risk assessment is mandatory.
  • Instructing and training before workers start a task is mandatory.
  • Documentation of tasks involving carcinogens is mandatory.
  • Offering medical surveillance is mandatory.
  • Organising the chemicals within a substance inventory is regarded as very helpful.
  • Getting ‘external expertise’ from occupational physician or safety experts is regarded as very helpful.

Your well-being is further guaranteed by certain duties of your employer laid down in the Carcinogens, Mutagens and Reprotoxicants Directive (CMRD). However, it is also important that you act according to i.e. workplace instructions.

  • Performing a risk assessment is mandatory for your employer and serves to identify all potential health risks and install countermeasures to prevent or reduce these risks.
  • You have to be instructed and trained before you start a task. Repetition of training and adaption of operational instructions help you to stay alert to the risks.
  • Should you ever experience health problems that might be work-related even after changing the company or retirement, the documentation duty for tasks involving carcinogens will ensure that you receive recognition for an occupational disease.
  • Offering medical surveillance to you is your employers duty and serves to inform you about potential health risks related to your task.
  • Please be aware that cooperation with your employer is your duty as well. Workplace and personal hygiene protocols (for example, do not carry work clothes home) are one key factor to ensure your health and that of your family and should be followed at any time.
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