The regulations concerning the labelling and the use of dangerous chemicals are widely dominated by the law of the European Community, EC.
EC legislation uses three major tools:
While Regulations come into force without further action on the national level, Directives are instructions to the national governments and/or parliaments, to transfer the content of the Directive into national law by a date specified in the Directive. If a member state fails to comply or is late in the implementation process, any EC citizen may refer to the Directive itself, if he is denied a specified personal right. Decisions are administrative actions of the EC concerning only the case and the persons addressed in the Decision. The law of dangerous substances is mainly based on Directives.
Directives concerning packaging and labelling of chemicals are usually based on Article 100a of the EC treaty, which means that they lay down precisely how a certain topic has to be implemented. As the EC started off as the European Economic Community and basically has remained so, the European Commission is very strict if they feel that something might impede free trade within the EC.
(The European Commission may be called the "government" of the EC, based in Brussels, as compared to the Council, where the national governments are represented, and to the European Parliament, based in Brussels, Strasbourg and Luxemburg)
Directives concerning the use and handling of chemical substances are based on Article 118a, which means that they only contain minimum standards which may be tightened on a national basis.
The EC has identified 15 dangerous properties which a chemical might have:
- extremely flammable
- highly flammable
- very toxic
- toxic to reproduction
- impaired fertility
- developmental injuries
- dangerous for the environment
Dangerous materials must be labelled accordingly. The most important part of the labelling is the symbol of danger, an orange-coloured square showing a black sign.
O F+ F T+ T oxidizing extremely
very toxic toxic
E C N Xi Xn explosive corrosive dangerous
These signs have to be taken seriously. What is labelled as dangerous, is dangerous.
What is not labelled as dangerous, may be dangerous anyway, because
- the material is not covered by the regulations, e.g. hazardous waste;
- it has only become dangerous with time, e.g. by chemical decomposition;
- a harmless material is in a dangerous state, e.g. compressed air or liquid nitrogen;
- the dangerous properties are not known yet, e.g. carcinogenics or other substances with chronic effects.
The dangers indicated by the danger symbols are explained further in the risk phrases. Risk phrases are numbered and officially worded explanations of these dangers. There are 62 risk phrases, which may be combined. No chemical is attributed more than four risk phrases.
R 11 Highly flammabe R 25 Toxic if swallowed R 31 Contact with acids liberates toxic gas R 35 Causes severe burns R 40 Possible risks of irreversible effects R 45 May cause cancer R 57 Toxic to bees R 36/38 Irritating to eyes and skin
The risk phrases must be written out in full on the label; in lists, however, the symbol of danger is usually represented by its letter and the risk phrase by its number.
There are three ways for a dangerous substance to penetrate into the body:
- penetrating the intact skin
The last possibility is often overlooked. As a rule, the skin protects the body quite effectively against water-soluble chemicals. On the other hand, lipophilic substances and, even better, polar chemicals with lipophilic and hydrophilic groups are readily absorbed by the skin. So most of the common organic solvents are rather likely to penetrate the skin. Even protective gloves may not provide sufficient protection, as not all materials are tight to every substance.
To prevent the dangers mentioned above, safety advice is given. Similar to the risk phrases, there are 52 (though there are numbers as high as 62) safety phrases.
S 9 Keep container in a well-ventilated place S 16 Keep away from sources of ignition - No smoking S 25 Avoid contact with eyes S 29 Do not empty into drains S 30 Never add water to this product S 33 Take precautionary measures against static discharges S 20/21 When using do not eat, drink or smoke
Again, these phrases must be taken seriously !
It is hard to imagine how much reasoning and sometimes conflict there is between manufactureres and authorities over the risk and safety phrases.
While the EC Directives on the handling of dangerous substances are of a somewhat general nature (save some special cases, e.g. carcinogens), the Directives on the labelling of substances and preparations (i.e. mixtures of substances) are very detailed.
There is a list of about 1,500 industrially important chemicals whose labelling is laid down very precisely; the categories given there must neither be omitted nor altered. The danger must neither be played down nor exaggerated. If for a certain substance there is no official labelling, the manufacturer or importer to the EC is resonsible for the appropriate label. There are sizeable standards for this purpose.
For preparations, which are by far the better part of the materials sold, there are extensive regulations on how to distil a single symbol of danger, risk and safety phrases from the concentrations of the substances contained. These regulations, of course, are also used to avoid the obligation to label a preparation as dangerous.
Labelling for transport
Another way of labelling dangerous materials is for transport purposes. These labels are standardized world-wide. They are rhombuses of different colours and also carry symbols in black.
The leading figure of the label's number roughly designates the danger it warns of; the following figure, if any, gives more details.
1 explosive 2 compressed gas, non-toxic and non-flammable 3 flammable liquid or gas 4 flammable solid 5 oxidizing 6 toxic 7 radioactive 8 corrosive 9 other danger 10, 11,
advise how to handle the cargo
Tanks on vehicles (lorries, railway wagons) are labelled with orange rectangles carrying two rows of numerals and, perhaps, an X.
The upper line is called the Kemler Number (in Germany at least), which describes the danger the substance brings about. The digits refer to the dangers listed above. The leading figure designates the more prominent danger, doubling increases the warning. A leading "X" means: avoid contact with water (important to the fire brigade !)
The lower line contains the UN Number, which has always four digits and designates common chemicals or mixtures of chemicals. This figure is just a number and contains no information on the substance inside unless you have the list of UN numbers at hand. 1717 is acetyl chloride,.
X338 means: it is a highly flammable, corrosive liquid, which must not be contacted with water.
Safety data sheet
Under EC legislation, every dangerous product (substance or preparation) must be accompanied by a safety data sheet.
The safety data sheet must cover the following items (directive 91/155/EC):
- identification of substance
- composition of substance (roughly)
- hazard designation, risk and safety phrases
- first aid measures
- fire fighting measures
- accidental release measures
- handling and storage
- exposure controls and personal protection
- physical and chemical properties
- stability and reactivity
- toxicological information
- ecological information
- disposal considerations
- transport information
- regulatory information
- other information.
The data sheet must be supplied with the first delivery of the product free of charge.
Take a look at a safety data sheet in Finnish , English or German .
The employer is obliged to determine whether in his factory dangerous chemicals are used, and take appropriate measures if necessary.
The following order should be applied
- substitute the dangerous material;
- enclose the apparatus where it is used;
- install suction equipment as near to the source of the dangerous fumes as possible;
- ventilate the whole room; if dangerous fumes are exhausted into the open air, there is a conflict between safety at the workplace and environmental protection. If the amount of substance emitted is too big, waste gas treatment must be performed.
- provide personal protection equipment; gloves, body protection, or respiratory protection may be necessary. Respiratory protection is only allowed for short-term operations and under medical surveillance.
For this field a very detailed EC Directive exists. Technical measures always take priority over personal protective equipment.
The effect of suction hoses must not be over-estimated. The figure beside shows how quickly the flow in the direction of the hose decreases with distance.
So equipment meant to be "suction at the source" often only is general ventilation. Directing devices may have tremendous effects. Monitoring of performance always is necessary.
Suction at the edge
Fan and suction hood combined
Flow 2 must be several times greater than flow 1
depending on W.
Gas velocity at P should be 5 ... 10 m/s.
H = W · tan 10°
If dangerous substances can occur in the air at the workplace, the employer is obliged to determine whether their concentrations reach a dangerous level. For this purpose, concentration limits have been set. This used to be on a national basis for decades, but now the EC more and more regulates this field, too.
The first step in this check may be a calculation; if doubts remain, measurements must be performed. Concentrations may be measured at a certain place with stationary equipment, with portable devices which a person carries with it, or in blood, urine, or exhaled air. If certain limits are exceeded (not necessarily identical with those mentioned above), regular medical examinations must be performed, on the employers' expense.
Orsa 5 (Dräger)
Monitor 3500, 3520 (3M)
Collecting device for active sampling (NIOSH)