Harmonization and implementation of the directives about dangerous substances, carcinogens and explosive atmospheres Difficulties and suggestions Dr. Gyula Körtvélyessy Honorary Secretary General Hungarian Chemical Society MSzT

2 Review General overview about definitions, legislations and processes Short summary of the Directives Implementation problems because of the own national systems –Linguistic –In timing –Legislative –In enforcement Main elements of the best practices learned

3 Risk assessment, in general Poisoning, Fire, Explosion, Cancer, Unusable legislations, Standards not convenient for our company  PROBLEMS How to avoid them –Preventive actions –Corrective actions –Think first to avoid later damages! Tool: risk assessment

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5 Main types of European legislative tools Directives  National legislations: Acts + Decrees Regulations  Valid immediately in the Member States Harmonized standards  How to put the legislation into practice in an acceptable way?

6 Parliament Council Harmonized standards Lobbying Turkish Federations Turkish Standardization Institute Cefic

7 Activities in the processing industry Nature Basic chemicals Active ingredients Preparations Parts Mining Chemical transformations Equipment

8 From petrochemicals to paints and car-making Crude oil Toluene, Propene Acrylates Polyacrylates Paint Parts Mining Cracking Chemical transforma tions Equipment

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10 Terms and Definitions in the Directives 1999/92: (flammable) substances 1998/24: chemical agents: substances + preparations 1990/394: carcinogens: substances + preparations  R45: „may cause cancer” 1997/42: carcinogens  C-1 and C /38: + mutagens

11 Terms and definitions Chemical agents Hazardous chemical agents Hazardous substances and preparations in the meaning of 67/548 Directive but not those dangerous to environment Any substances or preparations present risk to the workers or having occupational exposure limits

12 Hazard and Risk 'Hazard` means the intrinsic property of a chemical agent with the potential to cause harm `Risk` means the likelihood that the potential for harm will be attained under the conditions of use and/or exposure

13 Hazard and risk LD 50 =6-8 g/kg 500 g/70kg 1L Pálinka Exposure!!! S2: Keep out of the reach of children.Keep out of the reach of children. S7: Keep container tightly closed!

14 Which chemical agents? Produced intentionally or not intentionally –Separating from nature –Chemical reactions –Mixing Released –As a waste Used Independently from placing on the market or not –Marketed products –By-products –Wastes –Internal products Through work activities

15 Tasks in the Directives Risk assessment Identification of the chemical agents present on the workplace Identification of the hazardous properties of the agents –MSDS –Occupational exposure limit values –Literature The level, type and duration of exposure –Endpoints (skin, lung, digestion, etc.) –Measured airborne concentrations if available The effect of preventive measures taken or to be taken –Substituting substances, processes –Reduction of level of exposure by technical, administrative measures –Reduction of the number and time of exposure of workers…. –Personal protective equipment –Training –Monitoring exposure level at workplace, workers exposure Risk evaluation –Ratio of the exposure to the acceptable level = 1

16 Substance Measure the acceptable parameters to given endpoints of the given workers group(s) NO EFFECT LEVEL >? <? =? Compare! Risk Assessment Measure the exposure on the workplace to the given exposure routes

17 Distributions of occupational diseases

18 Transposing problems: language Chemicals, Chemical agents, Substances, Materials, Matter, Compounds, Components, Constituents Preparations, Mixtures, Blends Anyag, Vegyület, Vegyszer, Kemikália, Komponens, Összetevő Készítmény, Keverék, Blend Take care of the translations of legislations!

19 Transposing problems: Timing Publications of directives Ten Joining Countries 2004 Two Joining Countries 2008 Turkey Joining

20 Transposing problems: Structure of national legislation system

21 Transposing problems: Structure of enforcement system Equipment safety Seveso Health Environment Fire brigades All separate enforcement institutions

22 Transposing problems: Extra national measures Hungary: –Extra notification to national authority about hazardous chemicals and preparations used –Extra transfer of MSDS to national authority –More stringent occupational limits for chemicals –More stringent measures for fire safety Turkey: –Do not follow it! –Competitive disadvantage for the national industry

23 Solutions 1: Preventive measures To „install” health and safety into your processes from the very beginning –Check every stage of scale-up by HSE people Do not use „bad” chemicals in R and D –Carcinogens, Mutagens and Toxic for Reproduction –Persistent, Bioaccumulative and Toxic –Highly Flammable chemicals and solvents –Any solvents Use normal conditions if possible –Temperature, pressure Advantages of continuous process

24 Solutions 2: Databases Product database –Add subtance(s) content known to your products –Add CAS, EC data of substances –Add health and safety data Workplace database –List of dangerous or not dangerous equipment –List of processes running –Noise data –Workplace air monitoring data Worker database –Health monitoring data of the exposed –Biological monitoring –Time of exposure to carcinogens –Exposure monitoring data

25 Solutions 3: Management systems Quality management system –System available for recording everything –Clean processes (to avoid contaminations and cross- contamination) Environmental and Safety Management Systems –Practice for continual improvement –Established performance indicators

26 Solutions 4: Technical development General technical development helps with improving workplace conditions –Better sealing  Less released chemicals –Automatic control  Safer process management –Automatic centrifuging  no exposure –Automatic sampling  no exposure –Better ventilation system  less exposure –Better personal protective equipment

27 As a last option

28 Thank you for your kind attention!