What many don't know, or don't want to know, about occupational health and safety

If the release of carcinogenic substances cannot be ruled out, the following basic obligations apply, which can be found in Germany, for example, in §7 of the Hazardous Substances Ordinance:

Hazardous substances are, for example, carcinogenic substances, or substances that are acutely or long-term hazardous to water.

The chromium (VI) compound calcium chromate, which is frequently released after the use of calcium-containing insulations, is classified as "carcinogenic cat. 1B" (H350) and as "very toxic to aquatic organisms with long-term effects" (H410) and is thus considered a hazardous substance.

Thus, and there are no two opinions about this, the following basic obligations apply:?

1. The employer may only allow an activity involving hazardous substances to commence after a risk assessment has been carried out in accordance with Section 6 and the necessary protective measures have been taken in accordance with Section 4.
2. In order to ensure the health and safety of employees during all activities involving hazardous substances, the employer shall take the necessary measures in accordance with the Occupational Safety and Health Act and, in addition, the measures required by this Ordinance. In doing so, he shall take into account the rules and findings published in accordance with Section 20 (4).
3. The employer shall give priority to substitution on the basis of the result of the substitution test in accordance with Section 6, §1, Sentence 2, Number 4.
4. The employer shall exclude hazards to the health and safety of employees during activities involving hazardous substances. If this is not possible, he shall reduce them to a minimum. The employer shall take these requirements into account by determining and applying suitable protective measures.

He (the employer) shall substitute hazardous substances or processes with substances, mixtures or products or processes which are not hazardous or are less hazardous to the health and safety of employees under the respective conditions of use.

The practice of carrying out stripping work in personal protective equipment alone indicates that a hazard exists.        

However, the wearing of personal protective equipment must not be regarded as a permanent measure, which, moreover, can only be expected of the employee for a limited period of time.

If the protective suit is worn, it is actually already too late, even if it is of course indispensable at that moment.

The contractor (insulator/service company) is therefore obliged, in accordance with the above-mentioned legal requirements, to minimize or eliminate the present danger for the next time.

However, further use of contaminated insulation must be ruled out in any case!

This would mean that hazardous substances are put into circulation again against better knowledge and cannot be excused with a terse "we only had the old insulation set available".

The hazard assessment must be carried out before work is started and would have prescribed the provision of a new set of replacement insulation, at best the substitute product.

The magic word is therefore substitution.

If substitution is technically possible, it must be applied.

In our example, the harmful substance is calcium chromate (CaCrO4).

The formation of these chromates is due to an unfortunate thermochemical reaction during the use of the (calcium-containing) high-temperature insulating materials in conjunction with, for example, chromium-containing hot parts (engine/turbine/pipeline) at application temperatures of more than 300°C.

The actually harmless substance calcium oxide (CaO) as a component of almost all common insulating materials is, so to speak, the driving force in the oxidation process:

chromium (in the form of chromium (III) (Cr2O3)) +

calcium (in the form of calcium oxide (CaO)) =
 
calcium chromate (CaCrO4)        

Consequently, calcium-free insulating material is the substitution solution:

No calcium - No calcium chromate

Since calcium-free insulating materials are available, most of which have even better insulating properties than the materials used so far, and these calcium-free materials prevent the formation of the hazardous substance calcium chromate, substitution must be carried out to meet the regulations already mentioned above:

(2) In order to ensure the health and safety of employees during all activities involving hazardous substances, the employer shall take the necessary measures in accordance with the Occupational Safety and Health Act and, in addition, the measures required by this Ordinance. In doing so, he shall take into account the rules and findings announced in accordance with Section 20 (4).

(3) The employer shall give priority to substitution on the basis of the result of the substitution test in accordance with Section 6, § 1, Sentence 2, Number 4.?

"He shall substitute hazardous substances or processes with substances, mixtures or products or processes that are not hazardous or are less hazardous to the health and safety of employees under the respective conditions of use."

"The employer shall exclude hazards to the health and safety of employees during activities involving hazardous substances."

The exhaust pipe can still look like this after the (calcium-containing) insulation has been removed.

After substitution (calcium-free insulation after previously decontaminated hot parts), the exhaust line looks like it should:

Compliance with the Ordinance on Hazardous Substances and the Occupational Health and Safety Act ensure safe working and environmental conditions and symbolize the sense of responsibility of employers and service companies!?

And no matter how you want to bend the paragraphs and regulations, there can be no two opinions about the need for substitution, mainly because there are neither technical nor economic reasons not to do it.

Take care of yourself and stay healthy!

Olesnica, 2020-07-13