2.
The impact of chemical agents on worker's health in agriculture
2.1
Chemical
products in agriculture
2.2 Toxicity,
exposure and precautions
2.3 Evaluation of the risks of exposure to chemical agents according to Law 25/2002
2.1
Chemical products in agriculture
There are many circumstances in which a farmer uses chemical products,
including the protection of plants and productions from
parasites, the control of weeds, the fertilization of
the soil. The advantages
are undeniable in terms of increase in productions and
the conservation of exertion deriving from their use. On the other hand, their “abuse”, instead of
producing the desired advantages, transforms itself into
an economic disadvantage and into serious harm to the
environment and to human health. Unfortunately, however, the danger of these
products is not always fully evaluated and sometimes behaviours
are noted that show inattention with respect to the necessary
precautions.
Phytosanitary
products can be classified in different ways depending
on their properties. One
classification that takes into account the target that
they strike divides them into insecticides (substances
used to combat insects present on agricultural crops and
that cause damage to crops or that attack already stored
foodstuffs. The different substances can act on the insect
in very different ways; some act on the nervous system,
others on growth, and others on respiration, etc.) and
fungicides (substances used to control the fungi that
attack crops or stored fruit. Similarly to insecticides,
some of these substances are capable of combating only
the fungi that develop on the surface of the leaves or
of the fruit, while others are also able to control fungi
that have penetrated more or less deeply inside the vegetable
tissue, and they are called systemic, subdivided in their
turn into cytotropic and translaminar products) and weedkillers
or herbicides (chemical substances used to combat the
weeds in crops or to eliminate all of the vegetable species
in uncultivated areas.
Some of these substances can be applied to the
soil before the weeds and the crops grow, others with
the crop already present but without weeds, others in
the presence of both crops and weeds, still others must
be applied on the aerial part of the crop and/or on the
weed. Weedkillers
that kill all the vegetables with which they come into
contact are called total herbicides, while those that
only damage the weeds, leaving the crop intact, are called
selective).
Normally the
farmer does not use the active principles as is, but mixtures,
called preparations, in which the active principles against
parasites or weeds are present, together with other substances
(supporting and co-preparations) that facilitate and improve
their application, activity, persistence, etc.
Depending
on their origin, phytosanitary products can be divided
into inorganic and organic.
The most anciently used products belong to the
first group, i.e. fungicides derived from copper (Bordeaux
mixture, copper oxychloride, etc.), sulphur and phosphides
(which release phosphine when in contact with the humidity
in the air), etc. They are solid substances, quite water soluble,
which are generally used at high doses given their low
specific activity.
On the contrary,
the majority of phytosanitary products currently on the
market are organic substances, i.e. derived from carbon.
Some of them are of natural origin since they are
obtained from some plants (such as the natural pyrethrins
from the chrysanthemum, nicotine from tobacco, etc.) or
from microorganisms (ex. Bacillus
thuringiensis Berliner). The
majority, however, are produced through chemical synthesis
using industrial procedures.
Based on this last characteristic,
those of natural origin can be further distinguished from
those of synthesis. The
former are often mixtures of chemical substances and their
natural origin should not deceive about their toxicity
and danger: they contain substances that can be toxic
and dangerous even more than those of synthetic origin
as, for example, nicotine, a cancerogenous substance present
in tobacco extract and geraniol, an irritant and allergy
causing substance present in geranium extract.
Phytosanitary products of industrial origin represent a wide range of products
with very different characteristics between them that
determine their modality of use, the type of formulation,
the toxicity, the persistence on treated crops, in the
soil and in the environment. In general, they are products that are not very
water-soluble; however, the more soluble ones are those
that move more easily in the environment.
Therefore, the
commercial product is a mixture in which, besides the
active principle, other auxiliary substances can also
be found, such as:
- Supports
and diluents: they dilute the active principle, increase
the covering power, reduce phytotoxicity;
- Wetting
substances: generally surface-active agents, they facilitate
the dispersion of the preparation in water;
- Emulsifiers:
surface-active agents that allow obtaining stable emulsions
between non miscible phases;
- Deflocculants:
dispersing surface-active agents that delay the sedimentation
of solid particles;
- Adhesives:
inert, increase product adhesiveness on treated surfaces;
- Solvents:
they solubilize the active principle and facilitate
the formation of stable solutions;
- Transmitting
agents: compressed gasses used to drag the preparation
(propane, butane, freon).
For a complete listing of the auxiliary substances, refer to the list
in Law no. 194 of 15 March 1995 (enclosure III).
The preparations are found on the market in the shape of:
·
dry powders: used for dry treatments;
·
wettable powders: used in aqueous dispersion;
·
soluble powders: used in aqueous solution;
·
emulsifiable concentrates: liquid preparation (in solvent),
dispersed in water;
·
pastes: liquid preparations in which the active principle
is dispersed and emulsified in a solvent;
·
microcapsules: in this case, the active principle is enclosed
in capsules, which, once dispersed in water, form suspensions;
·
granules: preparations similar to dry powders except for
greater granulometry of the particles;
·
aerosol: the preparation is dissolved in a solvent and propellant
gas is added.
The examination of the preventive problems tied to the use
of phytosanitary products must take into consideration
some fundamental aspects, moreover exhaustively regulated
at the normative level: production, labelling, commercialisation
and purchase, storage, use and, finally, the health protocols
to be followed to control the health of the workers that
use them or that come into contact with them.
Provisions can also be found that impose specific
authorizations (temporary license) for those that must
purchase and use products of a higher toxicological class
(very toxic (T+), toxic (T) and harmful (Xn)), as well
as detailed information regarding the toxicological characterisation
and relative cautions and warnings on the main health
risks.
Over the past years, the companies that produce phytosanitary
products, guided also by the specific relative standards,
have been putting into effect some production strategies
aimed at the synthesis of substances that are ever more
specific and specialised, for the purpose of striking
well defined and distinctive “biological targets”, favouring
the study of molecules characterized by lower toxicity
even to the detriment of lower efficiency.
Another line of research that production companies are involved
in consists of the realization of preparations that are
more easily handled and, therefore, characterized by a
decrease in the possibilities of exposure and contact
by operators with the active principle (an example is
the realization of “microcapsules”, which enclose the
product, subsequently released after administration).
This shows that, at least in part, research and
productive processes are oriented towards new concern
for the health of workers and for protection of the environment.
Farm workers that devote themselves to operations in which
chemical products like those described up to now are used
are involved in a sequence of operations (treated in more
detail in the next section), which we can summarize as
follows:
·
purchase and transport;
·
storage and conservation;
·
preparation of the mixture to be applied and treatment of
the crops with the product;
·
post-treatment phase.
All of these operations present moments and situations in
which the worker can find himself exposed in various ways
to contact with chemical substances.
In order to eliminate or at least reduce this exposure
as much as possible, compliance with operating procedures
and the adoption of precautions dictated both by the regulations
and by the rules of good technique are required.
Unfortunately, experience in this regard leads to an often-critical
judgment on user behaviour.
In particular, the most recurrent causes of accidents
or contaminations are due to excessive familiarity with
the products used (the warnings written on the label and
on the technical cards are not given enough consideration),
to lack of compliance with the doses recommended for the
treatments, to the transport of the products with unsuitable
means, to insufficiencies concerning the correct criteria
for storing and conserving them (unsuitable rooms, scarcity
of cautions for keeping them, mixing together of several
products without verifying their chemical-physical compatibility,
lack of fire extinguisher), or to the fact that adverse
weather conditions are not taken into account (rain or
contrary wind) during the treatment phase. Sometimes the operator neglects to check if
the area to be treated is located near dwellings or watercourses;
clothing specifically dedicated for the purpose is not
worn during the operations; careful decontaminations of
the equipment and personal protection devices are not
carried out at the end of the treatment, and the “reentry”
and “safety interval” times are not always respected.
Furthermore, poor sensitisation concerning the ecological
problems that derive from the use of these substances
(as regards man, animals, soil and water) can be found.
It is obvious that, before setting other objectives,
interventions of a preventive nature must be aimed at
the education and training of phytosanitary product users,
to inform them of the precautions and rules of good behaviour
that are dictated by the standards and constantly reviewed
and updated by experts on the subject.
2.2 Toxicity, exposure and precautions
Chemical products
can be sources of considerable risks if used incorrectly. Operators must be informed and prepared to know
the potential risks and the precautions to be used to
avoid any harm that can be caused to man and to pets,
as well as to the environment. In this way, the substances that we are dealing
with can be used without excessive danger.
The toxicity
of phytosanitary products is given by their ability to
produce undesired effects on the organisms with which
they come in contact and by which they are absorbed.
The main introduction routes that allow absorption
in the organism are oral (through the mouth and the digestive
tract), inhalatory (through the nose and the respiratory
tract) and cutaneous (through the skin and eyes).
Contact between
chemical products and the skin is a frequent cause of
poisoning. This contact can occur through direct squirts
on the skin but also through contaminated clothing or
continuous exposure to a source, for example, powders.
Chemical products easily pass through healthy skin,
without the presence of wounds.
Oral absorption,
very harmful, can be avoided by following simple precautions,
for example, using suitable masks, or avoiding eating,
drinking or smoking during treatments or when hands are
contaminated by the chemical product. After the handling or use of the phytosanitary
product, it is essential to carefully wash your hands:
it is also a good idea to keep the preparations in their
original packages and separate from foodstuffs to avoid
accidental ingestion, but also from bait, rodenticides
and treated seeds.
Absorption
by inhalation can be dangerous, especially when concentrated
volatile products are handled in closed or poorly ventilated
places. Therefore, it is a good idea to make sure that
there is good air circulation during handling, as well
as to wear a mask when recommended.
Naturally
animals are also susceptible to poisoning, which can occur
through absorption through the skin or by the ingestion
of water or food contaminated by phytosanitary products.
Therefore, they should be kept away from fields
during treatment and for as long as necessary.
The toxicity
of a substance is divided into acute, measured by the
DL50 parameter (the dose that kills 50% of laboratory
animals subjected to the absorption of that active principle)
and chronic, determined by the accumulation of low doses
of phytosanitary products, distributed over a lifetime.
The DL50 is
expressed in milligrams of active principle per kilogram
of body weight (mg/kg).
It is understood administered orally to the rat
or through the skin to the rat or rabbit. The CL50 (which refers to the Lethal Concentration
in the air or water of the product that acts in the gaseous
or vaporous state) is instead the concentration in the
air (mg/l) that kills through inhalation 50% of the animals
tested: the lower the values of DL50 and CL50, the higher
the acute toxicity of the chemical product.
The preparations,
based on the acute toxicity of the active principle, on
the concentration in the preparation and on the type of
the latter (liquid, powder, etc.), are divided into 3
classes, distinguishable from the label, on which words
and/or pictures appear (DPR [Decree by the President of
the Republic] n° 223 of 24.05.1988):
Fig.
2.1 - Symbols of danger on label of phytosanitry products
Symbol on label
|
pp
|
EX
class
|
CHEMICAL PRODUCTS
|
ccccccc
|
ll
|
nnnn
|
SOLIDS
DL50 (mg/kg)
|
LIQUIDS
DL50 (mg/kg)
|
GASEUS
CL50 (mg/l)
|
lllll
|
kk
|
bbb
|
oral
|
cutaneous
|
oral
|
cutaneous
|
inhalatory
|
|
T+
|
I
very
toxic
|
<=5
|
<=10
|
<=25
|
<=50
|
<=05
|
|
T
|
I
toxic
|
5<=DL50<=50
|
10<=DL50<=100
|
25<=DL50<=200
|
50<=DL50<=400
|
<=2
|
|
Xn
|
II
harmful
|
5<=DL50<=500
|
100<=DL50<=1000
|
200<=DL50<=2000
|
400<=DL50<=4000
|
2<=DL<=20
|
|
Xi
|
III
irritant
|
>500
|
>1000
|
>2000
|
>4000
|
>20
|
As highlighted
in Fig. X, “very toxic” products are marked with the letter T+ and with the picture of a skull
and belonged to ex Class I; “toxic” products are marked with the letter T and with the picture of a skull,
and they also belonged to ex Class I; “harmful” products are marked with the
letter Xn and with
the picture of St. Andrew’s cross, and belonged to ex
Class II; “irritant” products
are marked with the letter Xi and with the picture of St. Andrew’s cross, and belonged
to ex Class III or IV; finally, “unclassified” products are not marked with
symbols indicating health risks and, as a rule, carry
the words “Warning: handle with care”; these belonged
to ex Classes III and IV.
The harmful
effect caused by toxic substances on the vital functions
of the human organism is defined as poisoning, and the
disturbances correlated to it can be immediate, such as:
lacrimation and sight disturbances, headache, irritability,
drowsiness or insomnia, tiredness, dizziness, tremors,
mental confusion, salivation, nausea and vomiting, abdominal
pains and diarrhoea, itching and irritation of the skin,
coughing and pressure in the chest; or else delayed, such
as: diminished sight, muscular aches and loss of strength,
weight loss, decreased memory and concentration, depression.
Phytosanitary
products can also cause effects that are allergenic (oculo-rhinitis,
allergic dermatitis, respiratory asthma), cancerogenous
(development of tumours), teratogenic (malformations of
the embryo and of the foetus) and even mutagenic (alteration
of the genetic patrimony with possible insurgence of tumours
or malformations in subsequent generations).
The farmer
who, after all, is the person most directly exposed to
health risks, can reduce exposure by carrying out the
chemical treatment only when it is essential and always
complying with all of the rules for correct use. Let us analyse in more detail the operations
already listed in the preceding section:
Purchase
and transport
First of all,
in order to purchase very toxic (T+), toxic (T) and harmful
(Xn) phytosanitary products, an authorization (the so-called
“temporary licence”) issued by the Regional Department
of Agriculture competent by territory is required, following
participation in a preparation course that lasts 15 hours
before taking the qualifying examination (Art. 24 D.P.R.
n° 1255/68). The interviews for purchase qualification regard
the dangers connected to the possession, conservation,
handling and use of chemical products; the modalities
for correct use of the same and the precautionary measures
to be adopted, and also include the basic notions for
correct use from the agricultural point of view with rules
for biological, guided and integrated protection.
The qualification is valid for 5 years and is renewable,
after an additional interview.
The purchase of irritant phytosanitary products
(Xi) does not require any previous authorization for use
in agricultural production.
In any case,
the purchase of loose products is forbidden, as is the
purchase without temporary licence, that is, from unauthorized
or itinerant stores. Additional prohibitions concern the possibility
of loaning or giving the products to third parties, as
well as transporting them haphazardly intermingled with
passengers, animals or foodstuffs.
Storage and conservation
Storage of
antiparasitical products on farms is not subject to particular
regulations except for very toxic (T+), toxic (T) and
harmful (Xn) phytosanitary products, which must be kept
in rooms or cabinets that are always locked and that have
a POISON sign. Nevertheless,
it is advisable to make sure that the rooms are dry, protected
from heat and cold, ventilated, with washable walls, waterproofed
floors for easy cleaning and with wells or other containment
structures in case liquid products are spilled.
It is a good
idea to limit access to the room only to qualified persons,
to not store foodstuffs or fodder in it, and to provide
a portable multi-purpose powder ABC extinguisher.
It is not necessary to transfer or keep phytosanitary
products in containers different from the original ones
and without labelling, and smoking, eating or drinking
are severely prohibited inside the storehouse.
In the case
of spills due to broken packages, the area concerned must
be immediately decontaminated.
If the spilled product is in granules or powder,
the decontamination shall be carried out with a suction
device; if it is liquid; it must first be absorbed with
proper material (sawdust, fossil flour or bentonite).
Preparation of the
mixture to be applied and treatment of the crops with
the product
Before using
a product, it is always necessary to read the instructions
given on the label. The
mixture should be prepared outdoors, wearing suitable
clothing and using proper tools. It is necessary to carefully calculate the amount
of product to use in the treatment in relation to the
doses to be distributed and to the surface area to be
treated, and to mix the products with water using a suitable
stirrer and safe from possible squirts.
The antiparasitic
treatment should be carried out with an all-purpose tractor
that has a closed cab, equipped with an air recirculation
system that uses suitable filters.
Otherwise, it is necessary to protect the operator’s
body by wearing suitable coveralls that are easily washable
or disposable, using rubber gloves that are specific for
handling toxic substances and a suitable mask or, better
yet, a helmet with filters that are specific for the categories
of product that are being distributed, following the regulations
for use of the Personal Protection Devices.
Furthermore,
it is necessary to verify at regular intervals the efficiency
of every element of the machines used for the treatments,
and consequently evaluate and adjust the uniformity of
distribution and the speed of advancement. Finally, it is a good idea to check the volume
actually distributed.
In equipment control and calibration operations,
it is necessary to wear suitable clothing and to supply
oneself with specific personal protection devices. Lastly, it is a good rule to carry out the treatments
when it is not windy or anyhow take into proper account
the meteorological and climatic conditions.
Eating, drinking, smoking or bringing any object
up to the mouth is absolutely forbidden during the treatment
phases, and it is advisable to eat low fat foods and not
to drink alcoholic beverages.
Post-treatment phase
Once the treatment
has been performed, it is necessary to carefully wash
the equipment used, to remove the Personal Protection
Devices and, if not disposable, to wash them carefully,
being especially careful when cleaning mask and filter,
if present. The
operator must also wash up carefully with soap and water
after the treatment activity.
Waste deriving
from an agricultural enterprise operation is classified
as special; this means that even phytosanitary product
containers contaminated by the product cannot be given
to the urban solid waste collection service, nor can they
be buried, abandoned in canals or burned.
Even the rinse waters of the tanks used for distribution
of phytosanitary products cannot be discharged in canals
or in the ground (except for proper municipal authorizations)
since they can cause pollution.
Therefore, in order to allow rational disposal
of the above-mentioned residuals in compliance with the
current regulations (Art. 10 bis Law n° 441/87), it is
necessary to turn to specialized companies.
It is appropriate
to mark the treated plots of land with signs containing
the words “Crop treated with phytosanitary products” and
to comply with the reentry time, i.e. the term foreseen
between the treatment and the moment in which one can
return to the field without risk.
This interval allows the residuals to drop to an
acceptable level and allows avoiding the risk of contamination
for persons that work in or cross the field.
When such risks exist, the labels indicate the
minimum amount of time that must pass before returning
to the field. If
it is not indicated, it is a good idea to wait at least
24 hours from the day of application. Therefore, persons and animals must be kept
away from the places in which the treatments are carried
out and chemical products or work equipment must never
be left unsupervised.
Depending
on the nature of the product, the label specifies the
time that must pass between the last treatment and the
harvest so that the residual level does not exceed the
limits set.
Emergencies
In the case
of accidental contact with a product or poisoning, the
subject must be moved away from the source of poisoning
and taken to the hospital, avoiding the administration
of milk, alcoholic beverages, medicines. The package of the product used should be given
to the doctor.
Legislation concerning
the use of phytosanitary products
The information relative to authorized uses, to the safety
intervals and to the maximum residual limits of the active
substances contained in phytosanitary products are updated
with reference to the following legislative provisions:
D.M. (Minister’s Decree)
9 May 2000 (G.U. (Official Gazette) ordinary supplement
05.09.2000, n. 207)
Maximum limits of residuals of the active substances of phytosanitary
products allowed in products destined for food. (Acknowledgement
of directives n. 97/41/CE, n. 1999/65/CE and n. 1999/71/CE).
D.M. 10 July 2000 (G.U.
16.09.2000, n. 217)
Acknowledgement of directive n. 2000/24/CE concerning the
maximum limits of residuals of the active substances of
phytosanitary products allowed in cereals, in products
of animal origin and in products of vegetable origin,
including fruits and vegetables; revocation and modification
of some uses relative to phytosanitary products.
D.M. 3 January 2001 (G.U.
ordinary supplement 10.2.2001, n. 34)
Updating of Ministry of Health decree of 19 May 2000 and
acknowledgement of directives n. 2000/42/CE and n. 2000/48/CE
concerning the maximum limits of residuals of active substances
of phytosanitary products allowed in cereals, in products
of animal origin and in products of vegetable origin,
including fruits and vegetables; revocation and modification
of some uses relative to phytosanitary products.
D.M. 2 May 2001 (G.U.
n. 177 of 1-8-2001)
Modifications and supplements to minister’s decrees 19 May
2000, 10 July 2000 and 3 January 2001 concerning “Maximum
limits of residuals of active substances of phytosanitary
products allowed in products destined for food".
D.M. 8 June 2001 (G.U.
n. 203 of 1-9-2001- Ordinary supplement n.223)
Updating of the Health Ministry decree of 19 May 2000 and
acknowledgement of directives n. 2000/57/CE, 2000/58/CE,
2000/81/CE and n. 2000/82/CE concerning the maximum limits
of residuals of active substances of phytosanitary products
allowed in cereals, in products of animal origin and in
products of vegetable origin, including fruits and vegetables.
D.M. 6 August 2001 (GU
n. 239 of 13-10-2001)
Acknowledgement of directives n. 2001/35/CE, n. 2001/39/CE
and n. 2001/48/CE and modification of Ministry of Health
decree of 19 May 2000 concerning the maximum limits of
residuals of active substances of phytosanitary products
allowed in products destined for food.
Bulletin relative to Ministry
of Health decree 6 August 2001, containing:
"Acknowledgement of directives n. 2001/35/CE, n. 2001/39/CE
and n. 2001/48/CE and modification of Ministry of Health
decree 19 May 2000 concerning the maximum limits of residuals
of active substances of phytosanitary products allowed
in products destined for food. (Decree published in the
Official Gazette – general series - n. 239 of 13 October
2001). (GU n. 254 of 31-10-2001)
D.M. 20 November 2001
(GU n. 25 of 30-1-2002)
Modifications to minister’s decrees 8 June 2001 and 6 August
2001 concerning, respectively, “Updating of Ministry of
Health decree 19 May 2000 and acknowledgement of directives
2000/57/CE, 2000/58/CE, 2000/81/CE and 2000/82/CE concerning
the maximum limits of residuals of active substances of
phytosanitary products allowed in cereals, in products
of animal origin and in products of vegetable origin,
including fruits and vegetables” and “Acknowledgement
of directives 2001/35/CE, 2001/39/CE and 2001/48/CE and
modification of Ministry of Health decree 19 May 2000
concerning the maximum limits of residuals of active substances
of phytosanitary products allowed in products destined
for food".
D.M. 29 March 2002 (GU
n. 87 of 13-4-2002)
Acknowledgement of directive n. 2001/57/CE and modification
of Ministry of Health decree 19 May 2000 concerning the
maximum limits of residuals of active substances of phytosanitary
products allowed in products destined for food.
D.M. 9 May 2002 (GU n.
160 of 10-7-2002)
Acknowledgement of directive n. 2002/5/CE and modification
of Ministry of Health decree 19 May 2000 concerning the
maximum limits of residuals of active substances of phytosanitary
products allowed in products destined for food; revocation
and modification of some uses relative to phytosanitary
products.
D.M. 18 June 2002 (GU
n. 179 of 1-8-2002)
Acknowledgement of directive n. 2002/23/CE and modification
of Ministry of Health decree 19 May 2000 concerning the
maximum limits of residuals of active substances of phytosanitary
products in products destined for food.
2.3 Evaluation of the
risks of exposure to chemical agents according to Law
25/2002
The
document evaluating the risks of exposure of workers to
dangerous chemical agents must be drawn up according to
Law n. 25 of 2 February 2002, “Fulfilment of directives
89/391/CEE, 89/654/CEE, 89/655/CEE, 89/656/CEE, 90/269/CEE,
90/270/CEE, 90/394/CEE, 90/679/CEE, 93/88/CEE, 95/63/CE,
97/42, 98/24 and 99/38 concerning the improvement of worker
safety and health during work”; it is an integral part
of the risk evaluation document and is subject to periodic
updating if considerable changes occur that could have
made it obsolete or when the results of the medical control
prove it to be necessary.
The
risk evaluation is carried out in concert by the Prevention
and Protection Service Manager, with the collaboration
of the medical doctor in charge and the preventive involvement
of the Workers Safety Representative.
Law 25/2002 applies to all activities in
which dangerous substances are present and, in
particular, in the: production, handling, storing, transport,
elimination and treatment of waste.
Chemical agents are those that are classified
or classifiable as:
- dangerous
substances
according to legislative decree n. 52 of 3 February
1997, and subsequent modifications;
- dangerous
preparations
according to legislative decree n. 285 of 16 July 1998,
and subsequent modifications;
- substances
that can involve risk for the safety and health of workers
because of their chemical-physical, chemical or toxicological
properties and the way in which they are used or present
in the workplace;
- all
chemical agents to which a professional exposure limit
value has been assigned.
In particular, substances and preparations
should be referred to as:
The classification can be identified by
the risk phrases (R phrases) present on the safety cards
(see table in Attachment A).
Speaking of the risk of exposure, it is
possible to differentiate, as indicated by Law 25/02,
between Moderate risk of exposure, which imposes the obligations
of risk evaluation and education and training, and Immoderate,
which also foresees provisions in case of accidents or
emergencies and health supervision.
Both cases in point are related to Law n. 626 art.
72-quinquies paragraph 2 of 19 September 1994.
We recall that the analysis of the
risk of exposure to cancerogenous agents, where pertinent,
shall be carried out according to Law n. 66 of 25 February
2000 and in the evaluation of risks in the work environment
according to Law n. 626 of 19 September 1994, through
compilation of the register of exposed workers and consequent
sending of the same to the proper authorities.
A picture of the main normative references
relative to chemical risk is attached.
In
the process, it is possible to identify two separate and
sequential risk evaluation phases: preliminary evaluation
and detailed evaluation since, from the considerations
made on the field of application of the standard, it follows
that the preliminary evaluation cannot be an analytical
evaluation of the risk of exposure of the individual workers
but only an identification of the danger of exposure to
chemical agents.
Only with this interpretation is it possible
to explain the terminologies of “moderate” and “immoderate”
risk, which otherwise would be in contrast with the evidence
that the risk of exposure has to be in any case low, even
in complex realities that use dangerous agents in significant
quantities.
The detailed risk evaluation is mandatory
only for situations in which the danger is immoderate;
in these same cases it is also necessary:
- to
adopt specific prevention and protection measures;
- to
update the emergency plan to include possible accident
scenarios relative to chemical risks;
- to
provide for health supervision for those exposed to
agents that are dangerous to health;
- to
prove, even through measurements of chemical agents
in workplaces, that adequate safety levels have been
reached.
The various phases into which the risk evaluation must
be divided are explained below.
Information gathering
The first operation to be carried out in every case is the gathering
of pertinent information.
The data relative to the products are contained
on the safety cards; it is essential to verify
their reliability, completeness and updating. .
For the professional exposure
limit values or the biological
limit values (if pertinent), it is necessary to refer
to attachments VIII-ter e VIII-quater of Law 626/94.
Given that these attachments are presently only
illustrative, in practice it is necessary to identify
the agents for which laws exist, while for the others,
it is necessary to refer to the recognized technical standards. These data are particularly useful if it is
necessary to subsequently proceed with the detailed evaluation.
At the European Community level, the definition of limits was realized
for lead (Attachment II Dir. 98/24/CE) and for some specific
agents (Attachment Dir. 2000/39/CE), as well as for benzene,
wood dusts and CVM (Directive acknowledged with Law 66/2000).
For the other substances, it is necessary to refer
to internationally recognized limit values.
The data relative to jobs and activities are obtained through the analysis
of the productive cycle; in fact, the first action for
reducing the danger consists in good planning and in the
reduction of risk agents to the minimum.
The
description of the productive cycle must include a block
diagram that highlights the incoming/outgoing flows, an
identification of the layout of the area under examination
(in order to evaluate interconnections with surrounding
areas) and the identification of the substances present
and of any additional dangers.
Once the danger of
exposure to harmful agents has been identified, it is
a good idea to circumscribe the analysis to subjects that
are actually exposed (job analysis), since it is onerous
and inefficient to consider all of the operators exposed
in the same way:
It is then necessary
to analyse possible preventive and protective measures,
both already adopted and to be adopted.
Among the latter it is possible to identify:
·
the planning
of adequate work processes and technical controls, as
well as the use of equipment and suitable materials, in
order to avoid or reduce to the minimum the release of
dangerous chemical agents that could present a risk for
the safety and health of workers in the workplace;
·
the application
of collective protection measures at the source of the
risk, such as adequate ventilation and appropriate organizational
measures;
·
the application
of personal protection measures, including personal protection
equipment, whenever it is not possible to avoid exposure
through other means;
·
education
and training courses and activities carried out (recorded
and verified).
Preliminary evaluation
of the danger
In regard to the evaluation of risks for
workers due to the presence of dangerous chemical agents,
it is essential, first of all, to distinguish between
the different modalities of interaction between chemical
agent and potentially exposed operator. The different ways of contact must be taken
into consideration. As
far as the health dangers are concerned, it is necessary
to distinguish between effects of:
·
Acute toxicity
·
Irritation
·
Corrosiveness
·
Sensitisation
·
Toxicity
due to repeated dose
·
Mutagenicity
·
Cancerogenicity
·
Reproductive
toxicity
·
Explosiveness
·
Inflammability
·
Oxidizing
power
and effects deriving from instability or incompatibility
and from the chemical-physical state of the dangerous
chemical agent. Furthermore, from the point of view of the type
of work situation in which exposure is possible, it is
necessary to distinguish between:
1.
Activity
with normally foreseen exposure: this is the situation in which exposure to the chemical agent is normally
foreseen during the operations carried out by the operator
(for example, for the manual addition of the agent to
a tank or for the need to enter into physical contact
with the agent).
2.
Activity
with accidental exposure:
this is the situation in which exposure to the chemical
agent is not foreseen, that is, closed cycle cultivations.
In this case, exposure to the agent can occur only
following operational anomalies or accidents.
3.
Activity with exposure from contamination
of the work environment: this is the case in which exposure to the chemical
agent is possible because of small, uncontrolled leaks
that involve the diffusion of the agent in the work environment.
If the exposure risk can be defined as
moderate, the evaluation phase is considered comprehensive
and, except for particularly critical situations, a more
detailed analysis is not carried out.
It is still mandatory to educate and train the
workers.
If the analysis has identified the presence
of a n immoderate risk of exposure, it becomes necessary
to adopt the specific protection and prevention measures,
the provisions in case of accidents and emergencies and
the health supervision, and to proceed with a detailed
analysis as described below.
The detailed evaluation must lead to identification of the
workers’ actual level of exposure to the risk.
Therefore, it is necessary to evaluate the risk
in all operative phases (normal, maintenance and emergency),
to define the specific risk reduction measures, the need
for health supervision and possibly environmental monitoring.
The purpose of the detailed evaluation is anyhow
to make sure that the residual risk is brought to the
minimum level possible and in any case correspondent to
an exposure that is below the limits.
In the simplest cases, it is a matter of
considering all of the measures adopted on the farm to
verify any possibilities of improvement and anyhow to
take into consideration at least those foreseen by the
law for immoderate risk exposure.
The evaluation can be conducted both qualitatively
(identification of the number of independent events necessary)
and quantitatively. In
the second case, we estimate the expected accidental frequencies
through the preparation and mathematical solving of logical
trees (failure trees and event trees). At the end of the analysis, once all of the
measures for risk exposure elimination or reduction have
been undertaken, it is necessary to re-evaluate the residual
risk in order to evaluate the effectiveness also.
Analysis of the risk reduction measures
Once the risk of exposure to dangerous
agents has been evaluated as “immoderate”, it is necessary
to identify the measures aimed at reducing the risk.
It is possible to single out some provisions
(to be adopted in order of priority and in addition to
the general measures valid for all situations) as per
art. 72-sexies, paragraph 1, such as:
a.
planning of appropriate working processes
and technical controls, as well as the use of adequate
equipment and materials;
b.
appropriate organizational and collective
protection measures at the source of the risk;
c.
individual protection measures, including
individual protection devices, whenever it is not possible
to prevent exposure using other means;
d.
health supervision of workers according
to articles 72-decies and 72-undecies.
It is in any case top priority to evaluate
the possibility of elimination or replacement of the dangerous
agents.
Measuring of the dangerous agents
Establishment of health supervision
Law 25/2002 introduces a significant novelty
as far as the health supervision obligation is concerned. In fact, while the preceding regulations singled
out the obligation for specific substances, the present
decree extends the obligation to all employees whose level
of exposure to very toxic, toxic, harmful, sensitising
and irritant agents and to those that are toxic for the
reproductive cycle is considered immoderate.
Consequently, the medical doctor in charge shall
identify the parameters to be controlled both at the environmental
level and at the biological exposure indicators level.
The doctor in charge establishes and updates
a health and risk file for each of the workers identified
above, which is kept at the company (farm) or productive
unit and gives the worker concerned all of the information
foreseen. The levels
of professional exposure identified, supplied by the prevention
and protection service, are indicated, among others, in
the health file. The health files are kept at the company (farm)
in a form that allows consultation, while respecting privacy,
and must also be made available subsequent to the termination
of the work relationship and sent to the external competent
agencies (ISPESL, ASL).
How to act in an emergency
Having defined the analysis in emergency
conditions as an integral part of the risk of exposure
evaluation, it is necessary to supplement the Internal
Emergency Plan (if it exists) so that it takes into account
events that could cause exposure of the workers, their
consequences, and so that it defines the necessary interventions
and establishes the modalities and contents of employee
training and of periodic practices.
Analysis of the training
and education activities
The training and education activities are
mandatory for all of the different case histories identified.
Drawing up of the risk
evaluation document
The risk evaluation document shall contain
the information mentioned above and shall update the risk
evaluation relative to Law 626/94 and subsequent modifications
and supplements. It must be periodically updated and in any case
when there are substantial modifications that involve
a variation of the exposure levels.