Workshop on the safe use of chemicals by SMEs SMEs: time to update your CLP labels! Bruxelles 16 September 2014 Ludovica Malaguti Aliberti

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1 Ref. Ares(2014) /09/2014 Workshop on the safe use of chemicals by SMEs SMEs: time to update your CLP labels! Supporting EU industry and SMEs to become aware of and comply with CLP the Italian Initiative Bruxelles 16 September 2014 Ludovica Malaguti Aliberti Center for Chemical Substances National Health Institute Rome, Italy 1

2 The ECHA CSA programe Work package 2.1: DU support package aims at supporting companies belonging to sectors that typically do not have specific expertise in chemicals and have difficulties in understanding and implementing their obligations under CLP and REACH and to integrating new criteria CLP in their Environmental, Health and Safety related activities. 1. Workshops and congresses 2. Training events REACH/CLP which emphasize links with current EHS activity 3. Education (Institute-University) 4. Information packages and publications 2

3 Permanent Advisory Commission on Health and Safety at Work (D.Lgs 81/08 Art. 6): Tasks Draw up an annual report on the state of the art about the application on occupational health and safety at workplaces in Italy Elaborate standardised procedures for the risks evaluation Elaborate prevention activities Enhance union agreements and the codes of ethical conduct Promote Gender Perspective in Occupational Safety and Health Policies as regards the risks evaluation and prevention and protection measurements Express opinions on annual plans elaborated by the Supervision Committee on Health and Safety (Ministry of Health) Evaluate problems regard the implementation of EU Directives, Regulations and the international conventions Validate best practices on occupational health and safety Individuate models for the occupational organization and management

4 Permanent Advisory Commission on Health and Safety at Work Technical Committees Committee 2 Standardised procedures Committee 3 Qualification system sfor companies and self-employed Committee 4 Models of occupational organization and management Committee 1 Best practices Committee 8 Work equipment and Personal Protective Equipments. Committee 9 Chemical, Physical and Biological Agents Committee 5 Criteria for the qualification of the trainer in the topic of Occupational health and safety. Committee 6 Evaluation of the work-related stress risk Chemical hazard in fireworks Committee 7 Temporary or mobile construction sites, Personal Protective Equipment 4

5 Connection among REACH, CLP, SDS and the D.Lgs 81/2008 and further amendment/supplements: critical aspects discussed in the document 1. Definition and identification of the subjects (manufacturer, importer, downstream user, distributor, supplier, employer, manager in charge of launching dangerous chemical agents) 2. terminology (conform to that of the new Regulations) 3. new labelling system (there is not always a correspondence between the H and P phrases and the hazard pictograms of the CLP, respectively with the R and S phrases and the old pictograms of DSD) 4. contemporary presence of the labelling according to the CLP Regulation and DPD until June 1 st Possible update of the risk assessment document to dangerous chemical agents and carcinogenic and mutagenic agents; 6. Update, formation and information of workers and the other subjects of the prevention system in workplaces by the employer 7. Health surveillance based on the new classification of the dangerous chemical agents and the carcinogenic and mutagenic agents 8. Update of the safety signs according to the new CLP pictograms

6 New sub-committee online interactive Risk Assesment (OiRA) Italy is in the first phase of the preparation and development of the OiRA project (the partnership of Italy Ministry of Labourstarted on on 31 th July 2013). Project has been developed by the EU-Occupational Safety and Health Agency. In Italy in order to develop an OiRA tool, according to the OiRA project guide, participants representing Public Institutions (such as the Ministry of Health, Italian Workers Compensation Authority - INAIL and the Technical Coordination of Regions), trade Unions, employers associations and sector specialists were involved. One of the main aim of this project is to make available the new obligations for chemicals at workplace (new classifications, new H Statements and pictograms). This program will be addressed to employers that make use the chemicals but they don t produce it.

7 Future plans/sectors to work on Sectors considered for Italian OiRA tool: the bakery sector; storage and transportation; woodworking; the butchery sector (slaughterhouse); bars and restaurants; the hairdressing sector; the plumbing sector; gas station sector; farms; commercial stores; auto bodywork sector.

8 A case study: NIS observation Occurrence of severe silicosis in workers (occupational exposure during installation/cutting): Italian Peripheral Health Bodies reported cases of serious silicosis of workers exposed to dust released during the cutting of artificial stones articles. CONCLUSIONS Risk Management Measures seems to be not adequate No label according CLP Safety Data Sheets not available Crystalline silica is the main constituent of new composite materials containing 70-90% or more of free crystalline silica (>% quartz/cristobalite) and 7-8% polyester resin as well as pigments and additives 8

9 Best Practice Respirable Silica Risk assessment Health effect and of exposure route Environmental monitoring and analytical methods procedures 9

10 NATIONAL HELPDESK applicants Helpdesk CLP: National Center of Chemical Substances National Health Institute 10

11 Thank you for your attention 11

12 Elements for consideration of ECHA Forum Artificial stones products are articles according to REACH. They are not designed to release RCS under reasonably foreseeable use, but they can release them not intentionally during their use and lifecycle Professional conditions of use (in particular the act of cutting with consequent release of silica dust) are not covered by the reasonably foreseeable ones, thus registration requirements are not applicable to the above articles. Silica does not have at present a CLH according to CLP but several notifications of both quartz and cristobalite as CARC 1A have been submitted to ECHA C&L Inventory. 12

13 New requirements for drawing up the SDS and new classification of dangerous substances and mixtures Considering the new hazard classes which could modify the evaluation of the risk to dangerous chemical agents and carcinogenic and mutagenic agents. When in the SDSs are inclosed the Exposure Scenarios (e-sds) for the use of chemical agents, the employer is not exempted from performing the risk assessment according to the risk assessment for chemical agents (Article 223 of D.Lgs 81/2008) and carcinogenic and mutagenic agents (Article 236 of D.Lgs 81/2008). The Exposure Scenarios are useful sources of information for the employer in the risk assessment. The employer, where the conditions of the Artt. 37, 38 e 39 of REACH are applicable, has to communicate to the supplier (or to ECHA) the use or the conditions of use when those are not covered in the exposure scenarios. 13

14 Permanent Advisory Commission on Health and Safety at Work (D.Lgs 81/08 and subsequent amendments, Title I, Chapter II Institutional System, Art. 6) 40 representative members 1 representative: Ministry of Labour and Social Policy 9 representatives: -Presidency of the Council of Ministers (dep. Equal opportunities) - Min. of Economic Development - Min. of the Interior - Min of Defence - Min of Infrasctructures - Min. of Agriculture and Forestry - Min. of Social Solidarity -Presidency of the Council of Ministers (Public Service Department.) 10 representatives: - Regions - Autonomous Provinces (Trento and Bolzano) 10 experts: trade unions 10 experts: trade unions of employers (also crafts and small and medium enterprises) 14

15 Our plans in terms of promotion The promotion of the OiRA project will be done by: a specific event (such as a Conference) during the Italian Presidency in the Advisory Committee on Safety and Health at Work (ACSH) of the European Commission : second semester of the web site of the Ministry of Labour ( but also through the channels of the participants in the Italian group (Public Institutions Italian Workers Compensation Authority - INAIL and the Technical Coordination of Regions, Trade Unions, employers and sector specialists.

16 ARTIFICIAL STONES Crystalline silica is the main constituent of new composite materials containing 70-90% or more of free crystalline silica (>% quartz/cristobalite) and 7-8% polyester resin as well as pigments and additives These products are similar to natural materials and processed in the same way. They have excellent technical quality (scratch-resistant and unstainable) Available on the market under a variety of trade names; widely used for the production of kitchen countertops, bathrooms, floors and wall cladding etc. The only information provided by the manufacturers concern environmental certifications They haven t label according CLP Artificial stones are articles under REACH