Carcinogenic drugs added to the list of working methods subject to report in a new decree

Finnish Institute of Occupational Health media release 12 April 2024

The ASA register is a statutory register of workers exposed to carcinogenic substances and methods. At the beginning of April, the current ASA law (452/2020) has been clarified with regard to the method of submitting ASA reports. In addition, the new decree on the prevention of cancer risk at work (113/2024) introduced changes to the carcinogenic work methods that are subject to reporting to the ASA register.

After the legislative change, the employer must report the information to be registered in the ASA register annually using an electronic notification system maintained by the Finnish Institute of Occupational Health. A paper report or one submitted via secure mail will no longer be accepted.

Reports must be submitted by 31 March of the following year, as usual. The electronic reporting requires that the reporting party has been granted Suomi.fi authorization from their employer.

Changes to working methods subject to reporting

Employees exposed to carcinogenic and mutagenic drugs should be recorded in the ASA register. The reporting obligation applies to medicinal products that meet the CLP classification criteria for carcinogenic or mutagenic substances Carc. 1A/1B (H350; H350i) or Muta. 1A/1B (H340), meaning they are known or presumed to be carcinogenic or mutagenic to humans. There are several different groups of such drugs.

Exposure to carcinogenic drugs may concern employees who handle these drugs in their work and who come into contact with the secretions containing them, such as people in the pharmaceutical industry and hospital pharmacies, nurses, practical nurses and institutional nurses. Exposure may occur in particular during the handling of powders, solutions and inhaled medicinal products.

In the ASA report, carcinogenic drugs are indicated as a working method with the ASA substance number 307. This working method also covers carcinogenic and mutagenic chemotherapeutic agents that were already part of the working method subject to reporting.

More detailed instructions on how to report drug exposures to the ASA register can be found in the ASA register's Frequently Asked Questions (FAQ) web page (in Finnish).

A working method newly subject to ASA reporting is work involving exposure to arsenic and its inorganic compounds. Arsenic is an old exposure agent and a known carcinogen. The addition has been made in order to clarify the reporting obligation and because so far only some arsenic compounds have been classified as carcinogenic in accordance with the CLP regulation in the EU.

In the working method regarding wood dust exposure, the expression “hardwood dust” has been replaced with the “deciduous wood dust” for the sake of comprehensibility. Welding and flame-cutting of stainless steel has been changed to welding and thermal cutting of stainless steel, which covers all cutting methods that generate fumes. For used motor oils, it is emphasized that exposure occurs through skin contact and thus the new working method is called “work involving dermal exposure to used motor oils”.

The employer has a duty to investigate and assess

Changes to the list of carcinogenic work methods mean that the employer must take into account the work methods added to the list.  It must be determined whether these carcinogenic or mutagenic exposure agents are present in the workplace and whether employees are exposed.

If there are exposure agents present, assessment data should be added to the employer's own list. ASA reports on exposed persons should only be submitted for employees who meet the exposure criteria.

Persons exposed to carcinogenic drugs and all arsenic work must be reported in the 2024 ASA report, which can be submitted from 1 January 2025 until 31 March 2025. The responsibility for investigating and assessing the exposure lies with the employer.

The Finnish Institute of Occupational Health maintains an up-to-date indicative list of ASA substances (in Finnish).

Learn more

• ASA register (in Finnish)
• ASA register Frequently Asked Questions (FAQ) (in Finnish)
• Act on carcinogens,… 452/2020 - Up-to-date legislation - FINLEX ® (in Finnish)
• Government Decree on the carcinogenic… 113/2024 - Original decrees - FINLEX ® (in Finnish)

Submit an ASA report

• ASA reports must be submitted annually via the electronic ASA notification system (in Finnish).
• The report for the past year must be submitted by March 31. 
• The website also includes a guide and instructional video on how to submit the report.
• If the reporting obligation of a work department has ended, this must be notified by sending a message to asa@ttl.fi.  

Further information

• Sanni Uuksulainen, Senior Specialist, Finnish Institute of Occupational Health, Sanni.Uuksulainen@ttl.fi 
• Piia Taxell, Senior Specialist, Finnish Institute of Occupational Health, piia.taxell@ttl.fi, +358 30 4742 234