Substitution of
    hazardous chemicals

Step 1: Obtaining information on the existing product

Identifying the hazardous properties of the product.

Find out whether you are using hazardous substances in the product or process you are using now or intend to use. Is there a risk of injury to health or environmental damage during production, use or storage of the product, when it is discarded as waste or during waste recovery? You can ask the manufacturer, importer or vendor of the product for information.

Suppliers are required to provide occupational users with information relating to the health and environmental effects of their products. You may also be able to find information in safety data sheets or similar documents.

Section 3 of the Product Control Act sets out the duty of due care, which requires manufacturers to assess:
• what harmful properties their products may have
• how likely it is that these properties represent a risk
  to health or the environment
• what measures are necessary to protect health and
  the environment during handling of their products
• what measures are necessary to deal with waste
  from their products.

Making an exposure assessment
To assess whether the product is likely to have adverse effects on health and the environment, you need to determine:
• whether use of the product is likely to lead to
  exposure to hazardous chemicals
• whether people and the environment can be affected
­ at the workplace
­ via emissions to air or water
­ via the product itself
­ via waste when the product is landfilled or incinerated
• whether use of the product may involve risks to
  people and the environment.

Once these assessments have been made, you can decide whether you need to reduce the level of risk, and whether substitution would be an appropriate step to take.

Deciding whether to avoid the product
It is important to weigh up how dangerous the properties of the product are in relation to the likelihood that they will injure people’s health or cause environmental damage. A product that has very dangerous properties constitutes a serious risk to health and the environment even in small quantities, but a less dangerous product may also represent a serious risk if it is used in large quantities.