AMS Go
Hazardous substances

Hazardous substances risk assessment in Germany: duties, TRGS 400 procedure and checklist

Anyone who has employees work with hazardous substances in Germany must first assess and document inhalation, skin contact and fire and explosion hazards. Duties under the Hazardous Substances Ordinance, the TRGS 400 procedure and a checklist.

Last updated on 8 min readAMS Go editorial team

Key points at a glance

  • Employers whose staff work with hazardous substances must carry out a risk assessment under Section 6 of the German Hazardous Substances Ordinance beforehand; work may only start once it exists and the protective measures are in place (Section 7 (1) GefStoffV).
  • Documentation is mandatory before work starts, regardless of the number of employees, and includes the hazards, the result of the substitution check and the protective measures (Section 6 (8) GefStoffV).
  • Hazards from inhalation, skin contact and physico-chemical effects such as fire and explosion must be assessed separately and then brought together; the procedure is described in TRGS 400, TRGS 401 and TRGS 402.
  • Only competent persons may carry out the assessment, and technical protective measures must be checked for function and effectiveness at least every third year (Section 6 (11) and Section 7 (7) GefStoffV).

What is the risk assessment for hazardous substances?

The hazardous substances risk assessment is the part of the risk assessment (Gefährdungsbeurteilung) under Section 5 of the Occupational Safety and Health Act (ArbSchG) in which the employer records all activities involving hazardous substances, assesses the hazards from inhalation, skin contact and fire and explosion, and sets protective measures. The legal basis is Section 6 of the Hazardous Substances Ordinance (Gefahrstoffverordnung, GefStoffV); the procedure is described in the Technical Rule TRGS 400.

Hazardous substances are not only products with a hazard pictogram. Substances that are formed or released during work – welding fume, wood dust from sanding, solvent vapours from cleaners or drilling dust – also belong in the assessment. All operating states must be considered, explicitly including cleaning, servicing, maintenance and fault clearance.

Who may carry out the risk assessment?

The employer is responsible. Only competent persons (fachkundige Personen) may carry out the assessment; if employers lack the knowledge themselves, they must obtain competent advice. The occupational safety specialist and the company doctor in particular can be competent (Section 6 (11) GefStoffV). Competence requires relevant vocational training, professional experience or recent professional activity, plus specific further training (Section 2 (16) GefStoffV).

According to TRGS 400, knowledge is needed in areas including the following – it does not have to be combined in one person:

  • sources of information such as the safety data sheet, TRGS and substance databases
  • the substances used and formed and their properties
  • the activities in the company and how to carry out the assessment
  • substitution and technical, organisational and personal protective measures
  • effectiveness checks and documentation
Hazardous substances management in AMS GoManage safety data sheets centrally, let AI extract classification, H statements, exposure limits and protective measures with source references and keep the hazardous substances register up to date as the starting point of the assessment.

Hazardous substances risk assessment in 7 steps

  1. 1

    Record activities and substances

    Go through the company area by area and record who uses which hazardous substances and how – including substances that are formed. The hazardous substances register is the starting point.

  2. 2

    Gather information

    The most important source is the current safety data sheet: section 2 for classification, 8 for exposure limits and PPE, 9 for flash point and explosion limits, 15 for restrictions. If test data are missing, for example on acute toxicity or skin sensitisation, the substances must be treated like correspondingly classified hazardous substances (Section 6 (14) GefStoffV).

  3. 3

    Check for a low hazard

    Clarify whether substance properties, quantity, exposure and working conditions together lead to only a low hazard. In that case the general protective measures under Section 8 GefStoffV are sufficient.

  4. 4

    Assess the hazards

    Inhalation under TRGS 402 using the workplace exposure limits of TRGS 900, skin contact under TRGS 401 with the categories low, medium and high – depending on classification, duration (under or over 15 minutes per working day) and area –, fire and explosion under Section 6 (4) GefStoffV.

  5. 5

    Check substitution

    Look for substitute substances and alternative processes with an overall lower hazard in line with TRGS 600 and document the result.

  6. 6

    Set protective measures

    Always the general measures under Section 8, additional ones under Sections 9 and 10 depending on the hazard – following the hierarchy of the STOP principle, with owners and deadlines.

  7. 7

    Check effectiveness, document and update

    Set methods and intervals for checking effectiveness, document everything before work starts and schedule a review date.

Simplified assessment for a low hazard

If the assessment shows that, given the substance properties, a small quantity, exposure that is low in level and duration and the working conditions, there is only a low hazard overall and the measures under Section 8 are sufficient, no further protective measures are needed (Section 6 (13) GefStoffV). Detailed documentation can be dispensed with (Section 6 (10)), as can the entry in the hazardous substances register (Section 6 (12)). However, it must be recorded that a low hazard was found – with reasons based on quantity, frequency, exposure and substance properties (TRGS 400 no. 8).

As examples, TRGS 400 names household products used under household conditions, such as touching up small paint damage with a paint pen, gluing with household quantities of adhesive or loading dishwasher tablets.

Protective measures following the STOP principle

The Hazardous Substances Ordinance sets a fixed order: substitute first, then protect by technical and organisational means, and use personal protective equipment last (Section 7 (3) and (4) GefStoffV). TRGS 500 describes the levels in detail.

  • S – Substitution

    ExamplesWater-based cleaner instead of solvents, brushing instead of spraying, granules instead of dusty powder

    BasisSection 7 (3) GefStoffV, TRGS 600

  • T – Technical

    ExamplesClosed system, extraction at the source, room ventilation – decreasing in effectiveness in this order

    BasisSection 7 (4) GefStoffV, TRGS 500

  • O – Organisational

    ExamplesLimit quantities at the workplace, limit exposure time and number of employees, hygiene, operating instructions, instruction

    BasisSections 8 and 14 GefStoffV

  • P – Personal

    ExamplesChemical protective gloves, safety goggles, respiratory protection

    BasisSection 7 (4) and (5) GefStoffV

Personal protective equipment is only used where higher-ranking measures are not sufficient – for example for short tasks with high exposure or as a temporary measure until technical solutions are in place (TRGS 500). Burdensome PPE such as respiratory protection must not be a permanent measure (Section 7 (5) GefStoffV).

Documentation, effectiveness and updates

The form of documentation is free; the hazardous substances register, measurement reports and operating instructions can be part of it. Under Section 6 (8) GefStoffV it includes, among other things:

  • the hazards of the activities involving hazardous substances
  • the result of the substitution check and, where measures under Sections 9 or 10 are needed, the reasons for not making a technically possible substitution
  • the protective measures to be taken and those planned
  • the reasons for any deviation from the technical rules
  • results that show compliance with limit values or the effectiveness of the technical protective measures

If hazardous explosive mixtures can occur, an explosion protection document (Explosionsschutzdokument) is added (Section 6 (9)). The assessment must be reviewed regularly – the employer sets the interval (TRGS 400) – and updated immediately if significant changes, new information or results of occupational health checks require it (Section 6 (10)). Typical triggers are new substances, changed quantities or processes, new workplace exposure limits and accidents or near misses.

Checklist: hazardous substances risk assessment

  • All activities involving hazardous substances recorded, including cleaning, servicing and fault clearance
  • Current safety data sheets available and checked for plausibility
  • Competent person appointed or competent advice obtained
  • Inhalation, skin contact and fire and explosion assessed separately
  • Low hazard checked and the result justified
  • Substitution check carried out and documented
  • Protective measures following STOP set with owners and deadlines
  • Effectiveness checked, finding and check intervals defined
  • Operating instructions prepared, instruction given and signed
  • Documentation completed before work starts, review date set

Free templates for this guide

As PDF and Excel, free – to use in your own company.

Frequently asked questions

Is a risk assessment for hazardous substances mandatory in Germany?

Yes. As soon as employees carry out activities involving hazardous substances, or hazardous substances can be formed or released during work, the employer must assess the hazards (Section 6 (1) GefStoffV). Documentation is mandatory before work starts, regardless of the number of employees (Section 6 (8)) – small businesses included.

Who may prepare the risk assessment for hazardous substances?

Only competent persons (Section 6 (11) GefStoffV). The employer remains responsible; if they lack the knowledge, they must obtain competent advice, for example from the occupational safety specialist or the company doctor. They can also delegate the work to competent persons such as managers and must provide them with the necessary documents.

How often must the hazardous substances risk assessment be updated?

The Hazardous Substances Ordinance sets no fixed interval. The assessment must be reviewed regularly – the employer sets the interval – and updated immediately when substances, quantities, processes or limit values change or health checks bring new findings (Section 6 (10) GefStoffV). Technical protective measures must be checked at least every third year, and instruction is due every year.

Do I need a separate risk assessment for every hazardous substance?

No. It is activities that are assessed. Where working conditions are similar at comparable workplaces, assessing one workplace is enough; the activities assessed together must be clear from the documentation (TRGS 400 no. 4.2). Activities with particularly hazardous substances, high exposure or infrequent work such as maintenance should be assessed individually.

Terms from the glossary

This guide gives a general overview of German occupational safety law and does not replace legal advice. The regulations in force and the rules of the statutory accident insurance institutions are authoritative.

Organise occupational safety digitally

With the occupational safety software AMS Go you handle risk assessments, safety instructions, inspections and more in one system – mobile and with AI support.

Request a demoSee all modules

Newsletter

Occupational safety, straight to your inbox

New templates, guides and changes to regulations – free from AMS Go. The newsletter is in German. You can unsubscribe at any time via the link in every email.

Privacy information

More guides

Contact

Get in touch

Book an appointment with us – or send us a message.

Kim Marius GräfeFrank MezlerLukas KleinBenjamin Kostrzewa

Personal and direct – with our founding team. Meet the founding team