THE NEW TECHNOLOGIES TO PROTECT

LIFE AND OCCUPATION

Progetto approvato
con D.D.R.T. 7772/2000
all'interno del
POR R.T. Ob.3 FSE




 

AGRICULTURE INDEX

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:

a)     explosive

b)     combustive

c)     extremely inflammable

d)     easily inflammable

e)     inflammable

f)       very toxic

g)     toxic

h)     harmful

i)        corrosive

j)       irritant

k)      sensitising

l)        cancerogenous

m)    mutagenic

n)     toxic for the reproductive cycle

Substances and preparations that are only dangerous for the environment are instead excluded from the field of application of Law 25/02.

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.

Detailed risk evaluation

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

The employer shall periodically measure the agents that can involve risk for the workers, unless he can show that an adequate safety level has been reached using other means, and confronts these measurements with the professional exposure limit values.

It is possible to compare the actual exposure to the maximum allowed when exposure limits exist.  Taking as a given that the threshold levels should not be exceeded, it will be possible to evaluate what ratio exists between actual exposure and the maximum exposure allowed.

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.