Substitution

Chemical substitution involves replacing a hazardous chemical with a safer alternative. This may mean substituting substances that pose health or environmental risks, or changing work processes so that the chemical is no longer required. Substitution should be considered whenever an organisation introduces new products, processes or technologies, particularly where chemicals with health or environmental risks are used.

A risk assessment for chemical substitution is carried out by identifying the current chemical and the associated risks. Risks related to use, exposure, storage and waste management are assessed for both the existing chemical and potential alternatives, while also taking technical performance and functionality into account. A safer alternative should be chosen where possible, provided this does not result in an unreasonable cost or operational disadvantage.

There are digital chemical management systems that support mapping, risk assessment and substitution of chemicals. Such tools provide an overview of chemicals, safety data sheets, hazard classifications and can suggest or compare alternative products with lower risk. In Workplace Safety, substitution can also be supported using artificial intelligence for more automated decision support.

Health and environmental risks are reduced by replacing hazardous chemicals with less harmful alternatives based on systematic risk assessments. This includes evaluating chemical properties, exposure, areas of use and required protective measures, as well as updating work routines and employee training when changes are introduced.

Lists of substances of concern are published by public authorities and international regulatory bodies, such as the REACH Candidate List. These lists are used as a basis for identifying chemicals with significant health or environmental risks that should be considered for substitution.

The substitution obligation set out in Section 3a of the Product Control Act requires organisations to assess safer alternatives if a chemical poses a significant risk to health or the environment.

The option that presents the lowest risk must be chosen, provided this does not involve unreasonable costs or disadvantages.

A typical substitution assessment usually involves identifying:

• The hazardous properties of the current chemical
• Which alternative products or solutions are available
• The occupational, technical and environmental consequences of the alternatives

Digital chemical management systems can simplify this process by suggesting safer alternatives and flagging substances that should be replaced.

No, not always. However, the substitution obligation still requires organisations to investigate alternatives. If no realistic or justifiable alternatives exist, the continued use must be documented and appropriate risk-reduction measures implemented.

The employer is responsible for ensuring that chemicals are used and handled safely and must ensure that procedures for substitution are established and followed.

Yes, several digital HSE and chemical management systems can automatically suggest safer alternatives and identify substances included on relevant hazard lists.

A hazard list provides an overview of particularly hazardous substances that are subject to the substitution obligation. These substances represent a high risk to health and the environment and should be replaced where possible. Hazard lists are updated regularly, often several times a year.

Examples of Norwegian and international hazard lists include:

• The Norwegian Priority List
• The Prohibition List (Working Environment Regulations, Section 3-19)
• The Chemical Weapons Convention (Schedules 1, 2 and 3)
• Peroxide-forming chemicals
• REACH Candidate List
• REACH Authorisation List
• REACH Restriction List