Substitution of carcinogens, mutagens and reprotoxins (CMRs), the role of ANSES

Chemical substances, singly or combined in mixtures, may have various harmful effects on human health. Some of them are categorised as “CMRs” because they are carcinogenic, mutagenic or reprotoxic. In view of the hazards they present, these classified substances and mixtures are subject to restrictive regulations, especially in occupational settings. Preventing chemical risks in the workplace is primarily based on replacing a hazardous product with another that is not hazardous or is less harmful (substitution). In the case of known CMRs, substitution should be sought systematically, which means proscribing the use of these substances in the workplace, except in cases where this is technically infeasible, and when this has been properly substantiated by the employer.

The role of ANSES

In this context, in late 2006 the Agency began a study on the substitution of categories 1A and 1B carcinogenic, mutagenic, and reprotoxic (CMR) substances (European Union classification). This study was conducted at the request of the Directorate General for Labour to contribute to Action 4.9 of the Occupational Health Plan (2005-2009): “To promote the principle of substitution for the most hazardous chemical substances (CMR)”. Its main objective was to improve the substitution process for CMR 1A and 1B substances.

Research and studies have helped to identify:

• the different industries and processes in which CMR categories 1A and 1B substances are used in France (sector study);
• substitutions (by substances, mixtures or processes) implemented or discontinued, during research or development in these different sectors.

Two surveys on the use of CMRs and substitutions were set up

The first survey (2008-2009) was used to study 23 priority CMR categories 1A and 1B substances. Added to these 23 substances were others that were the subject of specific study within ANSES. Thus, data on glycol ethers classified as category 1B reprotoxins, refractory ceramic fibres and formaldehyde were included.

A second survey (2009-2010) was used to study 56 other CMR categories 1A and 1B substances.

Substitution of CMRs became an ongoing mission for ANSES in 2010. The continuation of actions taken to incentivise and help with substitution was clearly articulated in Occupational Health Plan 2 (Action 11).

Since 2009, ANSES has been working with the CNAMTS[1]  on actions to be taken on the substitution of CMRs. The Agency used the results of the National Plan of Coordinated Actions (PNAC) (2009-2012) to supplement its database with concrete examples of substitution taken from the field. The PNAC aims, among other things, to assist 5000 facilities with the identification, substitution or control of CMR risk in order to safeguard 100,000 employees. These actions have helped to identify many businesses that have implemented substitution and are interested in working with ANSES.

In November 2012, more than 350 examples of substitution were available on the website for over a hundred CMR substances studied. These data were collected from 500 companies:

In conjunction with this ongoing mission on CMRs, ANSES is working to establish an observatory of substances, a permanent system for organising, exploiting, supplementing and sharing various sources of information on the knowledge of chemicals and their use in various industrial sectors. A scheme of this type will help to identify exposed populations and highlight any gaps in knowledge both in metrology as well as in toxicity. This tool will also enable development of a system of assessment to offer better guidance on primary prevention efforts, identify populations at risk and monitor exposure levels. It will provide a decision support tool, whether in matters of risk management or research priorities.

[1] National Health Insurance Fund for Salaried Workers.