Specification of carcinogenic substances requiring ASA registration to be amended as of 1 January 2020

In Finland, employers are obligated by law to maintain a list of any carcinogenic or mutagenic substances, compounds and working methods used at the workplace. The employer must also maintain a list of the employees exposed to said factors. The employer must report these individuals to the ASA register maintained by the Finnish Institute of Occupational Health. As the specification of substances is amended at the beginning of the year, the ASA registration obligation will also change.

Press release 56/2019

Moving forward, any substances classified as carcinogenic (Carc. 1A/1B; H350 or H350i) or mutagenic (Muta. 1A/1B; H340) must be reported to the ASA register. At the beginning of the year, the ASA registration obligation will be removed from some substances but, at the same time, added to hundreds of new substances. The registration obligation will also cover some new carcinogenic working methods.

The most significant new exposure agents requiring ASA registration include formaldehyde, quartz dust and all types of deciduous wood dust.

New substances and working methods requiring registration


Formaldehyde has a large variety of uses and is present in several industries and work tasks. Operations such as chemical industry processes, use of adhesive resins and laboratory work expose workers to formaldehyde.

Work involving exposure to crystalline silicon dioxide (quartz dust)

Quartz dust occurs in any work involving the processing of stone substances. Operations such as the construction industry, manufacture of cement, sandblasting work, mining and foundry work expose workers to quartz dust.

Work involving exposure to hardwood dust, i.e. deciduous wood dust

Work involving exposure to oak and beech dust was originally included in the list of working methods requiring ASA registration. Now, the section has been expanded to cover all deciduous wood dust, such as birch. Operations such as the board and panel industry, manufacture of wood products and furniture and the construction industry expose workers to deciduous wood dust.

Work involving exposure to used motor oils

Moving forward, the registration obligation will apply to work involving the handling of oils previously used to lubricate and cool down any moving parts in internal-combustion engines. This usually means automotive service, repair and overhaul work. Service of other vehicles and machinery as well as industrial maintenance work involving the handling of motor oils are also included in the registration obligation. Collectors of waste oils, waste treatment recycling jobs and employees of recovery plants are also included in this category.

Exposure to used motor oils primarily takes place through the skin.

Work involving exposure to diesel engine exhaust

Work in tunnels, mines, warehouses and terminals may significantly expose workers to exhaust fumes from diesel engines.

Welding and flame cutting stainless steel

In this context, stainless steel also refers to acid-proof steel and any steel containing both chromium and nickel. Welding stainless steel exposes workers to hexavalent chromium and nickel. In welding, most of the exposure comes from filling agents, which is why it is important to take such agents into account in risk assessments. Previously, welders of stainless steel were registered as exposed to both nickel and chromium. Moving forward, the registering party will not need to separately register the exposure to chromium and nickel when selecting this working method as the exposure agent. When welding a substance other than stainless or acid-proof steel and knowing that the filling agents only contain nickel or chromium, the registration should only include either chromium and nickel instead of registering this working method.

Work involving exposure to carcinogenic substances created in the combustion process

This working method applies to workers such as firemen, chimneysweeps, post-fire renovators, fire researchers and fire prevention trainers, among others. Registration of individual combustion products, such as PAHs or benzene, is not required when registering this working method as the cause for exposure.

Work involving exposure to carcinogenic cytostatics with Anatomical Therapeutic Chemical (ATC) classification

Previously, the individual cytostatics were registered separately. Moving forward, it will not be necessary to report the individual cytostatic; instead, the registering party can select this working method.

Classification of the substances and compounds to be registered is based on the CLP Regulation of the EU

In the upcoming ASA legislation, the substances to be listed will be determined according to the so-called CLP Regulation (1272/2008/EC) aligning the classification, labelling and packing of substances. The employer must list the substances and compounds classified as carcinogenic (Carc. 1A or Carc. 1B) or mutagenic (Muta. 1A or Muta. 1B) under the CLP Regulation. The corresponding hazard statements are H350 or H350i and H340.

Some of the substances have been given a so-called harmonized classification by the EU. The harmonized classification can be checked from the database of the European Chemicals Agency: https://echa.europa.eu/information-on-chemicals/cl-inventory-database. The employer’s obligation to maintain a list and report to the ASA register applies both to substances given a harmonized classification and to substances classified by each manufacturer (so-called self-classified substances). Self-classified substances do not have a harmonized, EU-level classification, which is why there may be variation in the classifications of different manufacturers. Reports to the ASA register are always made according to the classification of the specific product used at the workplace. Check the classification of a substance or a product from its safety data sheet.

The Finnish Institute of Occupational Health will make the registration easier by publishing an advisory list of the substances covered by the ASA registration obligation in early 2020.

“The list will contain the substances covered by the ASA registration obligation that have a harmonized classification under the CLP Regulation at that time. The list will only be advisory and will not include all the substances requiring registration as substances classified as carcinogenic by the industry must also be reported to the ASA register,” explains Senior Advisor Sanni Uuksulainen from the Finnish Institute of Occupational Health.

The employer must report any information concerning the year 2020 to the ASA register by the end of March, 2021. Reports concerning the year 2019, registered by the end of March 2020, will be conducted in accordance with the legislation valid at this time. The Finnish Institute of Occupational Health will create more detailed instructions on the ASA registration policies.

Further information

Senior Advisor Sanni Uuksulainen, Finnish Institute of Occupational Health, sanni.uuksulainen[at]ttl.fi, tel. +358 (0)30 474 2942

The press release by the Ministry of Social Affairs and Health on 12th December 2019: Binding limit values for 22 new carcinogenic agents


Share content on social media!