March 2007 Horizon scanning SR012

HSE Horizon Scanning Intelligence Group Short Report

1. Issue
In general, when dealing with the environmental impact of substances of high Status:
concern the tendency has been to focus on specific chemicals, with a view to Active
banning their use or replacing them with more environmentally friendly alternatives. Monitoring
Increasingly, the approach at the EU level is to adopt a more holistic approach when
developing new environmental and H&S legislation, breaking down the perceived
barriers between these areas. REACH and other legislation1 will act as a key driver of
change, affecting the choice of materials and/or processes used in future in a wide
range of industries. This legislation is aimed at both environmental and human health
protection and as such its effects are expected to be generally benign. However, it
would appear that there are instances where the new regulations and directives have
the potential to adversely affect health and safety in the workplace and that this may
warrant more detailed consideration within HSE.
2. Relevance to Occupational Health & Safety
2.1 Waste Management and Recycling - Directives on Hazardous Waste,
Landfill, Packaging, End-of-Life Vehicles, Waste Electrical and Electronic
Equipment (WEEE) etc. are expected to drive a significant expansion in waste
collection and recycling activities. It is estimated for example that up to 45,000 new
jobs will need to be created in this sector to enable the government to meet its target
of recycling 30% of municipal waste by 2010. Given that the industry already has
higher than average incident and fatality rates, any such growth in the workforce or
recycling activities may be expected to give rise to increasing accident statistics.
Similarly, increased exposure to existing and new biohazards and toxic materials
from the handling, sorting and dismantling of various types of waste is likely.2
2.2 The Electronics Industry - The Restriction of Hazardous Substances
(RoHS) and WEEE regulations will have a major impact on the Electronics industry.
The RoHS Directive restricts the use of materials such as lead, mercury, cadmium,
chromium and certain polymers, notably polybrominated fire retardants, while the
WEEE Regulations promote re-use, recovery and recycling of components. An
example where the RoHS Directive has the potential for adversely affecting worker
health & safety is in the introduction of lead-free solder. Although replacing the lead
in solder by other materials is clearly beneficial to the environment, the alternatives
tend to need higher working temperatures and an increase in the quantity of rosin
added to the flux in the solder. As “rosin-based solder fumes are one of the most
important causes of occupational asthma in Britain”,3 an increase in usage of such
material must be of concern.
2.3 The Chemical Industry - Substitution of Chemicals of High Concern - The
REACH regulations have been described as the “most significant development in EU
legislation in 20 years” and are predicted to come into force from the Spring of 2007

1
See EA “netregs” site at: http://www.netregs.gov.uk/netregs/legislation/?lang=_e&region=
2
HSIG Short Report on Recycling, SR002, October 2006
3
Institution of Engineering and Technology: http://www.iee.org/Policy/Areas/Health/hsb16.cfm

This document is produced for horizon scanning purposes and gives only a brief guide to the topic. Where the topic
is already receiving attention in HSE there will be links to other relevant pages. Given the nature of horizon scanning
activity, Horizon Scanning Short Reports do not necessarily reflect HSE policy or guidance.
onwards. The legislation provides a broad framework aimed at reducing risks to both
the environment and workers but there is no guarantee that alternative, more
environmentally-friendly chemicals, which may in future replace existing chemicals of
high concern, will not have an adverse effect on workplace health & safety. An
example of this is the withdrawal of PFOS (PerFluoroOctaneSulphonate), the use of
which is to be banned in consumer goods on environmental grounds. PFOS performs
a beneficial function in industrial chrome plating operations, as a mist suppressant to
protect workers from exposure to highly carcinogenic hexavalent chromium and a
derogation has been necessary to enable its continued use in this application as a
means of worker protection.
The recently introduced Solvent Emissions Regulations are intended to limit the
emission of “high VOC” solvents such as certain hydrocarbons, ketones, alcohols
and the like into the environment. These solvents find wide application in the
manufacture of paints, pharmaceuticals, polymers and adhesives etc. and industries
as diverse as printing and agriculture. Options for the substitution of high VOC
solvents, which include waterborne formulations, high boiling or ionic solvents, super-
critical fluids or radiation-curable systems, may present their own H&S issues, e.g.:
o u-v curable products tend to be based on acrylics, which can cause
problems by inhalation
o aqueous systems are prone to bacterial growth, requiring the use of
biocides, which may be linked to dermatitis & asthma
o high boiling solvents can give rise to liver & kidney problems via skin
absorption.
Another emerging area, for which environmental legislation is a key driver, is “Green
Chemistry”, where the aim again is to “reduce or eliminate the use and generation of
hazardous substances”.4 A basic intention here is to convert biomass (derived e.g.
from waste or non-food crops) into a wide variety of chemical products and
intermediates. Once again, although the materials involved here may well be more
environmentally friendly than those derived from conventional, oil-based feedstocks,
they may still have significant workplace risks associated with their large-scale use.
3. Implications
The potential for developing legislation (largely EU and environmentally driven) to
impact on workplace health & safety would appear to be an emerging, cross-cutting
theme. Directives aimed at tackling environmental and human health protection
issues in a more holistic way could have far-reaching effects on a diverse range of
industrial processes and are likely to require new or modified guidance and control
measures to be developed. In particular, there are concerns that the substitution of
substances of high concern by more environmentally friendly alternatives may in
some cases give rise to new hazards and adverse occupational health effects.
4. Recommendations
The potential impacts on workplace health & safety of some specific new or
expanding technologies and materials as noted above, are clearly in some cases,
already appreciated within HSE. However, given the breadth and rapid rate of
expansion in the field, it is suggested that continued, proactive monitoring of the wide
range of existing and new legislation and its potential to give rise to new workplace
risks, is warranted. There is a need to ensure that the findings from such studies are
brought to the attention of policy makers in an effective manner, to enable
appropriate action to be considered.

Roger Brentnall, Horizon Scanning Section, HSL

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