Many cleaning products in use are labelled with a flame, an exclamation mark, a symbol for corrosiveness or a health hazard. The cleaning products work, staff wear protective equipment, and everything seems under control. Nevertheless, it is worth taking a closer look: Labelled cleaning products involve extra effort in terms of storage, training and risk assessment; they pose a risk to health; and the Hazardous Substances Ordinance requires organisations to check, in any case, whether less hazardous alternatives are available. This article summarises what matters and how to make a successful switch.
What hazardous substances in cleaning products mean
The CLP Regulation determines whether a cleaning agent is classified as hazardous. Classified mixtures bear hazard pictograms as well as H-statements (hazard statements) and P-statements (precautionary statements). Typical examples from industrial cleaning:
- Acetone, isopropanol, MEK: Highly flammable, irritating to the eyes; vapours may cause drowsiness and dizziness.
- NMP: Classified as toxic to reproduction, it may therefore damage fertility or harm the unborn child.
- Toluene: is suspected of causing harm to the unborn child and, if exposure is prolonged, may damage the organs.
- Strong acids and alkalis: Corrosive to the skin and eyes.
Some solvents have an intoxicating effect. People who are exposed to them over a period of years may suffer damage to their nervous system. Solvent encephalopathy, also known as ‘painters’ disease’, is recognised as an occupational disease (BK 1317).
The requirement: substitution test
Under Section 7 of the Hazardous Substances Ordinance, the employer must assess whether hazardous substances can be replaced by less hazardous ones. The TRGS 600 „Substitution“ sets out how this is to be done. If a technically suitable alternative exists, it must be given priority. The result is documented in the risk assessment. Particularly stringent requirements apply to carcinogenic, germ cell mutagenic and reprotoxic substances (CMR substances) such as NMP.
What „not classified as dangerous“ means
A mixture that does not fall into any hazard class under the CLP Regulation does not carry any hazard pictograms or hazard statements. A safety data sheet may still be available, often bearing the EUH210 statement „Safety data sheet available on request“. The instructions on use, storage and disposal set out in the safety data sheet also apply to non-classified cleaning products. Many of Eco-Nova’s cleaning products are not classified as hazardous.
Areas where costs are falling: storage, protective equipment, training
Labelled cleaning products entail a whole range of obligations:
- Storage: well-ventilated storage rooms or hazardous substances cupboards. In accordance with TRGS 510, it must be checked which substances may be stored together; for example, acids must be kept separate from alkalis.
- Larger quantities: additional requirements relating to fire safety and the retention of fire-fighting water, as well as obligations under the Ordinance on Installations for the Handling of Substances Hazardous to Water (AwSV).
- Explosion protection: in the case of highly flammable solvents such as acetone or isopropanol.
- Protective equipment and training: Suitable gloves, safety goggles, respiratory protection where necessary, and regular training.
If a labelled cleaning product is replaced with one that is not classified, many of these measures will no longer be necessary or will be simpler. The extent of the impact depends on your business and the quantities involved.
VOCs: the underestimated vapours
VOCs (Volatile Organic Compounds) are volatile organic compounds that evaporate even at room temperature. The EU Industrial Emissions Directive defines them as organic compounds with a vapour pressure of at least 0.01 kPa at 20 °C. During cleaning, they are released into the air we breathe. High concentrations can cause headaches, dizziness and irritation of the respiratory tract. VOCs also contribute to the formation of ground-level ozone.
For many solvents, workplace exposure limits apply in accordance with TRGS 900. Businesses that use large quantities of solvents are also subject to the 31st BImSchV (Solvent Ordinance). The VOC content of a cleaner can be found in the safety data sheet, usually in Section 9. It is a useful benchmark when comparing different cleaners. For example, according to the safety data sheet, Plexinova by Eco-Nova contains 0 % VOC.
Eco-Nova’s Hazardous Substances Check
Many businesses know they should make a change, but carrying out a needs assessment is time-consuming, and taking the step towards a new cleaning product takes some effort. This is exactly where we can help with our free Hazardous Substances Check:
- Current situation: We record your labelled cleaning products on the basis of the safety data sheets.
- Rating: We check the classification, intended use, contamination and surface.
- Proposal: For every application, we recommend a less hazardous cleaner; if required, we can also provide a bespoke formulation.
- Test: You can try it out with a free sample, or we can demonstrate it directly on your equipment, comparing it with your current cleaner.
- Documentation: You will receive the documents you need for your risk assessment and substitution assessment.
Is the check worth it for you? Yes, if at least one of the following applies:
- There are hazard pictograms on your cleaning products.
- Your staff will need protective gloves, safety goggles or respiratory protection when cleaning.
- They store cleaning products in hazardous substances cupboards or special storage rooms.
- Explosion protection or special ventilation is required during cleaning.
- Cleaning takes a long time or has to be repeated frequently.
- You have a stain that no cleaner has been able to remove satisfactorily so far.
How to make the transition a success
- Start with an app: ideally where the most hazardous cleaning agent is used or where the greatest effort is required.
- Testing within your own process: depending on the type of contamination, the surface and the drainage system.
- Involving staff: New cleaning products often work differently; for example, they may take longer to take effect but last longer. If you know this in advance, it’s easier to accept the change.
- A fair comparison: Sometimes, a less hazardous cleaner requires an extra step. You can decide whether it’s worth it based on the test results.
Safe working conditions also pay dividends externally: during audits, with customers who prioritise health and safety, and when recruiting skilled staff.
The best way to determine which cleaner can replace the one you’ve specified is to discuss it together. Please describe your application to us or request a free hazardous substances assessment. Our technical advisers can also visit you on request.