Workplaces that handle chemicals have a responsibility to be aware of and manage the risks associated with exposure to CMR substances. In this article, we outline what you need to consider and offer practical tips on how to reduce the risks when working with CMR substances in the workplace.
What are CMR Substances?
CMR stands for Carcinogenic, Mutagenic, and Reprotoxic – referring to chemical substances that can cause serious harm to human health, such as cancer, genetic mutations, and reproductive disorders.
For many CMR substances, there is no known safe level of exposure, meaning that even minimal contact can increase the risk of illness. Common examples include certain solvents, heavy metals, and pharmaceutical compounds. These substances are used across a range of industries and can be present in various work environments, making it essential to understand their potential risks and how to handle them safely.
What Does the Legislation Say About CMR Substances?
Because even low levels of exposure to CMR substances can be harmful, their use and handling are regulated under several pieces of legislation designed to minimise risks to workers.
The regulations place strict requirements on proper labelling, thorough risk assessments, and the implementation of appropriate protective measures. CMR substances are subject to more stringent rules than those applied to hazardous chemicals in general.
The UK framework is comprehensive and multilayered, from broad employer duties under HSWA and COSHH, to specific chemical laws like REACH and CLP, and sectoral restrictions in cosmetics and medical devices. Together, they ensure that CMRs are carefully controlled and, where possible, substituted or strictly regulated.
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How Can the Risks of Working with CMR Substances Be Reduced?
A thorough risk assessment is essential to identify and manage the risks associated with CMR substances and products. This includes evaluating potential exposure routes, quantities, and health hazards in order to implement appropriate control measures and safety procedures.
To reduce the risks when working with CMR substances, the use of personal protective equipment (PPE) – such as respiratory protection and gloves – is crucial in minimising exposure. Training and awareness are also key to ensuring that all employees handling these substances are well-informed about the risks and understand how to manage them safely. In addition, implementing control measures at the source, such as closed systems or ventilation, is a fundamental strategy for limiting exposure.
We’ve developed a dedicated procedure for managing CMR products to support you in this work:
Procedure for Handling CMR Substances
1. Purpose
Clearly define the aim of the procedure. Here is a suggested wording you can adapt for your organisation:
The purpose of this procedure is to outline how CMR substances and products are to be handled, stored, and documented in order to meet legal requirements and minimise risks to human health and the environment associated with carcinogenic, mutagenic, or reprotoxic (CMR) chemicals.
2. Scope
Specify which parts of the organisation this procedure applies to. This could be by department, process, or role.
3. Responsibilities
Define who is responsible for what. For example:
- Employees are responsible for following the procedures and written safety and handling instructions, and for reporting any exposures.
- Managers or supervisors with delegated health and safety responsibilities are accountable for ensuring that the following requirements are met.
4. Implementation
Specific requirements apply to the handling of CMR-classified chemical products, in addition to general chemical regulations. Key requirements include:
- Substitution: CMR-classified chemical products must not be used if technical alternatives are available. A documented assessment must confirm that substitution is not possible.
- Closed systems: If feasible, CMR-classified products should be handled within a closed system.
- Written instructions: Protective and handling instructions must be documented and cover the entire handling process.
- Risk assessment and monitoring: The handling must be risk assessed, and implemented measures monitored to detect deviations that could increase exposure risks.
- Exposure registry: Individuals exposed to CMR products must be recorded in an exposure register.
The rules in points 3, 4, and 5 also apply to workplaces where employees may be exposed to the following carcinogens:
- Respirable crystalline silica dust
- Asbestos-containing dust
- Diesel engine exhaust emissions
- Work involving skin exposure to mineral oils that have been used to lubricate and cool moving parts of combustion engines
4.1 Assessment and Documentation
A documented assessment must be carried out to determine whether it is technically possible to substitute the CMR product with another chemical product that poses a lower risk to health or safety.
Key considerations during the assessment:
- Anyone purchasing and using a chemical product for a specific purpose must investigate which alternatives are available to achieve the desired result. The substitute may not have identical properties, but it should meet the essential functional requirements.
- Chemical users are expected to search among commercially available alternatives. However, the assessment must not be limited to the range offered by a single supplier — it should cover several of the available options on the market.
- Organisations within the same industry using a CMR-classified chemical product for the same purpose can collaborate to assess whether a less hazardous product can be used instead.
- If a client requests the use of a CMR-classified product, it may be appropriate to ask the client to provide the substitution assessment before accepting the assignment.
- During the development of new products, efforts should be made, wherever possible, to avoid the need for CMR-classified substances in future production processes.
4.2 Use a Closed System Where Possible
Where technically feasible, CMR-classified chemical products must be handled in a closed system – meaning there is no risk of the chemical coming into contact with the surrounding environment.
If closed handling is not possible, the following measures must be taken:
- Equipment and working methods must be selected and designed to minimise the release of airborne contaminants and to prevent splashing or spraying.
- Contaminated air must be captured at the source using local exhaust ventilation.
- Protective clothing and gloves must be worn whenever there is a risk of contact with the chemical. These must be changed when switching to a different task.
- Spills must be contained and cleaned up as quickly and safely as possible.
- Any surfaces that may have become contaminated should be cleaned daily and after each completed task.
- The chemical product and any waste generated from handling it must be stored and transported in impact-resistant, sealed, and clearly labelled containers.
4.3 Information and Written Instructions
The manager or supervisor is responsible for ensuring that written safety and handling instructions are developed to cover all stages of the process, including maintenance, cleaning, waste disposal, spill management, inspections, and more, in accordance with the requirements of this procedure.
The manager or supervisor is also responsible for ensuring that all relevant personnel have received, read, and understood the safety and handling instructions.
4.4 Risk Assessment
CMR substances are particularly hazardous when inhaled, ingested, or absorbed through the skin. It is therefore essential to assess risks across the entire handling process — including equipment cleaning and waste management. Be mindful not to spread contamination via, for example, soiled gloves or clothing. Exposure to CMR substances must always be limited as far as is reasonably practicable.
All control measures identified during the risk assessment must be documented in the risk assessment itself. These include both protective measures that the worker must follow and any technical installations that are required. The manager or supervisor must approve these measures, ensuring they feel confident in taking responsibility for preventing work-related ill health.
It is vital that all affected employees are informed of the control measures decided upon. These must also be included in the written handling and safety instructions, as outlined in the previous section.
4.5 Monitoring or Regular Measurements
For any control measures deemed necessary to ensure safe exposure levels, the manager or supervisor must also determine and document how these measures will be monitored to ensure they function as intended. What should be checked, how, when, and by whom?
The written safety and handling instructions must clearly outline the monitoring procedures, so that the employer can be confident the handling is safe.
Monitoring can be carried out through:
- Continuous monitoring using detectors to identify, for example, leaks.
- Regular air sampling to measure airborne concentrations.
- Surface contamination checks, to detect residues of hazardous substances on surrounding surfaces.
If direct measurement is not feasible, monitoring can be done by verifying that the agreed control measures are in place and functioning properly. Where process ventilation is used, a control system must be in place to alert if the ventilation is not operating effectively.
Areas where CMR substances are handled must be clearly identified and restricted, ensuring that only personnel required for the task are present in those locations.
4.6 Recording and Reporting Exposure
If exposure is found to have reached a level where there is a risk to health, it must be reported as outlined below.
Causes of excessive exposure may include:
- Working in airborne concentrations that exceed any applicable occupational exposure limit
- Inadequate ventilation for any reason
- An accidental incident resulting in a temporary but high exposure
- Personal protective equipment (PPE) not being used or being insufficient
- Failure to follow handling and safety instructions
- Inadequate planning, monitoring, or communication of the hazards involved
In the event of exposure, the employee must report it as contact with a harmful substance. The manager is responsible for investigating the incident, implementing corrective actions, and ensuring follow-up, as well as registering the incident.
Seek Expert Support
Bringing in expert support can be a smart move — whether you’re just getting started or want to ensure that all processes comply with current legislation. We offer specialist knowledge and guidance to help businesses identify, manage, and reduce the risk of exposure to CMR substances.
Our services include conducting risk assessments, providing training, and ensuring that your company complies with all relevant legal requirements. By partnering with us, you can create a safer, healthier workplace for your employees while fulfilling your legal obligations and reducing the risk of CMR-related harm and illness.
Being aware of and actively managing the risks associated with CMR substances is essential for protecting your workforce — and it’s also an investment in the long-term sustainability and success of your business.
