Chemical agents at work

What are chemical agents in the workplace?

The legal definition is deliberately broad. It includes purchased and labeled products (solvents, paints, cleaning products, reagents), but also agents generated by the process itself that no one has purchased: welding fumes , wood or silica dust, combustion gases, thermal decomposition vapors, oil mists. Many of the most serious exposures fall into this second category, which lacks labels and safety data sheets and can only be identified by analyzing the process.

A chemical agent is considered hazardous when it meets the classification criteria of Regulation (EC) 1272/2008, known as CLP, or when, even without being classified, it may pose a risk due to its physicochemical, chemical, or toxicological properties and the way it is used or present in the workplace. Carcinogenic, mutagenic, and reprotoxic agents are subject to stricter regulations under Royal Decree 665/1997.

The regulatory framework combines two levels. The first is marketing, regulated by the European REACH (Registration, Evaluation and Authorisation of Substances) and CLP (Classification, Labelling and Packaging) regulations, which require manufacturers and importers to characterize hazards and communicate them through the label and safety data sheet . The second level is workplace protection, regulated by Royal Decree 374/2001 and Law 31/1995, which requires employers to assess and control exposure.

The safety data sheet and the label

The Safety Data Sheet (SDS) is the document that the supplier must provide for each hazardous substance or mixture, with sixteen sections defined in Annex II of the REACH Regulation: identification, hazards, composition, first aid measures, fire-fighting measures, spillage measures, handling and storage, exposure controls and personal protection, properties, stability and reactivity, toxicological and ecological information, disposal, transport, regulatory information, and other information. The exposure scenarios annexed to the extended SDS describe the conditions for safe use.

The CLP label summarizes hazards using pictograms, a signal word, hazard statements (H phrases), and precautionary statements (P phrases). The label and SDS are the starting point of the assessment, not its conclusion: they describe the intrinsic hazard of the product, while the risk depends on how, how much, and under what conditions it is used.

How is exposure assessed and controlled?

1. Inventory: list of all agents present, purchased or generated, with their updated SDS and their classification.
2. Identification of tasks with exposure and routes of entry: inhalation, skin and eye contact, ingestion.
3. Assessment: qualitative estimation of exposure and, where necessary, measurement using standardized methods and comparison with the occupational exposure limits published annually by the INSST; separate assessment of fire and explosion risks.
4. Measures according to Article 5 of Royal Decree 374/2001: elimination or substitution by less dangerous agents, process design and technical controls at the source, organizational measures, individual protection as a last resort.
5. Specific measures in the face of accidents, incidents and emergencies: action plans, alarm systems, first aid, information to the emergency services.
6. Health surveillance with specific protocols, training and information for workers and periodic review of the assessment.

The INSST Technical Guide for the assessment and prevention of risks related to chemical agents develops these criteria and includes qualitative assessment methods applicable when measurement is not possible or necessary.

Organizational application

• Purchasing. Require the updated SDS before the first purchase, consider substitution with less hazardous products, and avoid the entry of uninventoried products.
• Production and maintenance. Identify the agents generated by the process, maintain the extraction and ventilation systems, and apply the handling and storage procedures.
• Prevention service. Assess exposure, plan measurements, define individual protection and coordinate health surveillance.
• Warehouse. Segregation by incompatibilities, containment of spills, ventilation, signage and quantity control, in accordance with the regulations for the storage of chemical products .
• Workers. Training on labels, SDS, procedures and protective equipment; information on the results of assessments and measurements.

Exposure documentation has long-term value, especially for agents with delayed effects. Digital systems facilitate inventory, management of up-to-date Safety Data Sheets (SDS), and exposure history by person and position.

Limits and common mistakes

1. Evaluate only the labeled products and forget about the agents generated by the process (fumes, dust, gases).
2. Working with outdated, in another language, or incomplete SDSs; the SDS must be in Spanish and correspond to the current version of the product.
3. Confusing danger with risk: a highly dangerous product in a closed system may pose less risk than a moderately dangerous one used manually and without extraction.
4. Using respiratory protection and gloves as a first measure, without considering replacement or control at the source.
5. Ignore the dermal route and mixtures of simultaneous exposures.
6. Not assessing safety risks (fire, explosion, reactivity) together with health risks.

Royal Decree 374/2001 does not apply to risks regulated by specific regulations, such as ionizing radiation or the transport of dangerous goods, and carcinogenic, mutagenic and reprotoxic agents are governed by Royal Decree 665/1997 in the aspects it regulates.

Regulatory framework in Spain and Europe

• Royal Decree 374/2001 . Protection of the health and safety of workers against risks related to chemical agents during work.
• Royal Decree 665/1997 . Protection against carcinogenic, mutagenic and reprotoxic agents during work.
• Regulation (EC) 1907/2006 (REACH) . Registration, Evaluation, Authorisation and Restriction of Chemicals; Safety Data Sheet (Annex II).
• Regulation (EC) 1272/2008 (CLP) . Classification, labelling and packaging of substances and mixtures.
• Occupational exposure limits for chemical agents in Spain (INSST, annual edition) . Environmental and biological reference limit values.
• Technical guide for the assessment and prevention of risks related to chemical agents (INSST) . Criteria for the application of Royal Decree 374/2001.

The storage of chemical products is regulated by Royal Decree 656/2017 (Regulations on the storage of chemical products and their supplementary technical instructions). Explosive atmospheres are regulated by Royal Decree 681/2003. Directive 98/24/EC is the European standard from which Royal Decree 374/2001 originates.