In-houseCMR substances in industry: what you need to know and what actions to take
A variety of chemicals are used every day across all industries, including potentially CMR substances. CMR substances (Carcinogenic, Mutagenic and Reproductive Toxic Substances) are chemicals that can have serious effects on human health. Because of their hazardous properties, manufacturers, distributors, and processors are legally obligated to take measures to minimise exposure and to understand their responsibilities regarding the registration and safe use of these substances. In this blog, we discuss the main concerns and rules surrounding CMR substances.
What are CMR substances?
CMR substances are chemicals classified as hazardous due to their potential impact on human health. The abbreviation CMR stands for Carcinogenic, Mutagenic, and Reproductive Toxic. This means that these substances are carcinogenic, can cause genetic changes (mutagenic), or can be harmful to reproduction, respectively. Exposure to these chemicals can lead to serious health problems, including developing cancer, damaging genetic material, and fertility problems or damage to unborn children.
In the UK, the Health and Safety Executive (HSE) compiles and maintains a list of CMR substances. This list is updated regularly, and businesses can refer to the HSE’s Hazardous Substances database to identify substances that are classified as CMRs and to access guidance on managing these substances safely.
Hazards for industry
Exposure to carcinogenic, mutagenic, and reprotoxic substances can happen in various ways and in many different environments, such as industrial settings, construction sites, and laboratories, often under unsuspected conditions. Examples include hardwood sawing or diesel engine emissions. Exposure can also occur when using products containing these substances, such as paint, glue or quartz (silica) in sand and rocks.
To minimise these risks, it is crucial that manufacturers, suppliers and processors are well aware of which substances are classified as CMR. And that they take the necessary precautions in doing so, such as the use of personal protective equipment (PPE), and registration and labelling of these hazardous substances must be closely monitored.
Laws and regulations: why is registration important?
CMR substances are subject to strict UK regulations designed to protect both workers and consumers. In the UK, the management of hazardous substances, including CMR substances, is governed by a combination of regulations aimed at minimising exposure and safeguarding health.
- Under UK-REACH regulations, companies that manufacture, import, or distribute CMR substances are required to register these substances with the Health and Safety Executive (HSE). This registration process requires businesses to provide detailed information on the hazards associated with these substances, as well as safe handling and usage instructions. Read more about the REACH regulations.
- The Control of Substances Hazardous to Health (COSHH) regulations play a crucial role in managing workplace exposure to hazardous substances, including CMR substances. COSHH requires employers to assess the risks associated with hazardous substances, including CMR substances, and implement control measures to protect workers from exposure. This may involve providing personal protective equipment (PPE), ensuring proper ventilation, and offering training on handling hazardous materials.
- The CLP (Classification, Labelling and Packaging) regulations also apply to CMR substances, ensuring they are correctly classified, labelled, and packaged. This mandates clear hazard warnings and pictograms on products containing CMR substances, helping buyers and processors understand the risks and take appropriate safety precautions.
Supply chain responsibility
UK-REACH legislation requires all parties in the supply chain to actively request and provide information, both upstream and downstream. Each link in the chain plays a crucial role in ensuring that carcinogenic, mutagenic and reprotoxic substances are produced, traded and applied in a safe and legal manner:
- Manufacturers are responsible for the initial identification and registration of CMR substances, and must develop alternatives.
- Distributors and traders must pass on correct information on these substances and advise customers on safe alternatives.
- Processors bear responsibility for using hazardous substances safely in the workplace and protecting their employees.
Because there is a legal obligation to actively collect and share information, it is not credible for a party to claim it was not aware. If there are signs indicating potential risks, parties are expected to investigate on their own. Ignoring this obligation makes responsibility inevitable. Indeed, working unsafely with hazardous substances can lead to serious damage. For an overview of the requirements, guidelines, and best practices for safely handling, storing, and working with hazardous substances, see our white paper ‘Laws and Regulations on CMR Substances and REACH’.
How to recognise CMR substances?
CMR substances can be identified in materials by paying close attention to product labels and safety data sheets (SDS). These documents contain essential information about a product’s composition and associated hazards, including the presence of harmful chemicals.
1. Product labels
Chemicals containing harmful substances must be labelled with specific hazard pictograms, such as a skull and crossbones or an exclamation mark. In addition, CMR substances are accompanied by H-phrases (hazard statements) to indicate the hazards and specific health risks.
Common H-phrases:
- H340 – May cause genetic damage (mutagenic effect).
- H341 – Suspected of causing genetic damage.
- H350 – May cause cancer (carcinogenic effect).
- H351 – Suspected of causing cancer.
- H360 – May damage fertility or the unborn child (reproductive toxic effect).
- H361 – Suspected of damaging fertility or the unborn child.
- H362 – May be harmful via breastfeeding.
2. Safety Data Sheets (SDS)
The SDS provides detailed information on the product, such as chemical composition, hazards of the substances, and recommendations for safe use and storage. Processors can find specific sections in it that state whether there are CMR substances in the product, including safety measures to be taken during processing. For example, section 2 of an SDS deals with hazard identification and section 3 provides information on the composition and components of the product.
Checking for harmful chemicals
The Health and Safety Executive (HSE) in the UK carries out thorough and effective inspections to monitor exposure to CMR substances. While they enforce strict health and safety regulations, the responsibility for compliance rests entirely with employers. Companies are legally required to identify potential exposure risks to CMR substances and implement measures to minimise or eliminate these risks. Failure to comply with these regulations may result in significant fines or other legal penalties. The HSE or other regulatory authorities not only expect companies to meet legal requirements but also encourage them to act proactively by developing innovative and practical solutions.
Conclusion: safety first
Workplace safety starts with a thorough understanding of the hazards posed by CMR substances and a proactive approach to risk management. It is crucial that all parties in the chain – from manufacturers to traders and processors – are aware of these hazardous substances and continue to improve safety procedures. Handling harmful chemicals carefully, registering them correctly, and reading the information on labels and safety data sheets properly can significantly reduce risks. This not only ensures compliance with legal requirements, but also contributes to employee health and safety.