4. How do you set up a substitution program?
Substitution must be the subject of a proper study and be associated with a risk assessment.
Indeed, the substitution of a hazardous or CMR chemical agent by a less hazardous chemical agent or process may result in a possible shift in risks.
For example: replacing a CMR agent with a non-CMR agent classified as flammable, which creates a risk of fire and explosion.
It is advisable to involve the occupational physician, staff representatives, the prevention department, the design office and exposed employees in the process.
The "INRS" and "substitution-cmr" websites provide useful documents such as substitution assistance sheets, and feedback from companies that have implemented the same approach.
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How do you set up a substitution program?
Bibliography
Also in our database
Regulations
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articles L. 4412-1, articles R. 4412-59 to R. 4412-93.
Websites
On this site, you'll find the FAS (Fiche d'aide à la substitution) established for a carcinogenic product in a given field of activity (when its presence is proven and substitution is possible).
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