Skin protection at work in Germany: wet work, skin protection plan and health checks
Skin diseases are among the most frequently reported occupational diseases in Germany. How to assess wet work and skin contact with hazardous substances under TRGS 401, which measures work and what the skin protection plan and health checks involve.
Last updated on 7 min readAMS Go editorial team
Key points at a glance
- In 2025, the German statutory accident insurance received 14,315 reports of suspected occupational disease no. 5101 “severe or recurrent skin diseases”; 1,899 cases were recognised.
- Under TRGS 401, wet work (Feuchtarbeit) exists when employees regularly have skin contact with water or aqueous liquids for more than two hours per working day, wash their hands at least 15 times a day or frequently alternate between wet hands and liquid-tight gloves.
- For wet work of regularly more than two hours a day, the employer must offer occupational health care; from four hours or more it is mandatory (ArbMedVV Annex Part 1).
- Protective gloves and skin products are the last stage of the STOP principle; based on the risk assessment, TRGS 401 provides for a task-based skin protection plan (Hautschutzplan) posted at the washbasins.
What does skin protection at work mean?
Skin protection at work covers all measures that prevent wet work or skin-damaging substances from harming the skin or entering the body through it. The basis is the risk assessment (Gefährdungsbeurteilung) under the Hazardous Substances Ordinance (GefStoffV); how it works for the skin is described in the Technical Rule for Hazardous Substances TRGS 401 “Hazards from skin contact” (2022 edition, last amended 2024). Protective gloves and creams are the last stage – substitution, technology and organisation come first.
The topic affects many companies: in 2025, the German statutory accident insurance received 14,315 reports of suspected work-related skin disease and recognised 1,899 cases as occupational disease no. 5101 (DGUV). Eczema on the hands and forearms is typical – it often starts inconspicuously with dry, cracked skin.
Which activities put the skin at risk
- Wet work, for example in cleaning, care, kitchens, food production or hairdressing
- Water-mixed metalworking fluids, oils and greases in metalworking
- Cleaning agents and disinfectants, solvents and thinners
- Skin-sensitising substances such as uncured epoxy resins or isocyanates
- Aggravating conditions such as heat, cold, UV radiation or small skin injuries
For hazardous substances, the hazard statements in the safety data sheet are the starting point – for example H315 “Causes skin irritation”, H317 “May cause an allergic skin reaction”, H310 “Fatal in contact with skin” or EUH066 “Repeated exposure may cause skin dryness or cracking”. TRGS 401 assigns the hazard to the levels low, medium or high according to classification, duration (under or over 15 minutes per working day) and the area of skin affected. Wet work is not assessed with this matrix but with its own thresholds.
Wet work: definition and thresholds
Under TRGS 401 section 3.3.6, wet work exists if one of the following criteria is met regularly. The same values determine occupational health care (TRGS 401 section 7, ArbMedVV Annex Part 1):
Skin contact with water or aqueous liquids
Wet work, offered check frommore than 2 hours
Mandatory check from4 hours or more
Skin contact with water or aqueous liquids, frequently alternating with liquid-tight gloves
Wet work, offered check frommore than 10 changes
Mandatory check frommore than 20 changes
Hand washing
Wet work, offered check fromat least 15 times
Mandatory check fromat least 25 times
Liquid-tight gloves frequently alternating with hand washing
Wet work, offered check frommore than 5 changes
Mandatory check frommore than 10 changes
Protective measures according to the STOP principle
TRGS 401 requires the familiar order: substitution before technical, organisational and personal measures. If one measure is not enough, several are combined.
Substitution
ExamplesChoose less skin-damaging products, lower-concentration mixtures or low-exposure forms of use
Technical
ExamplesSuitable tools and fixtures, enclosures, extraction and ventilation, machines instead of manual work
Organisational
ExamplesSpread unavoidable wet work across several employees, no rings or bracelets, limit hand washing to what is necessary, change soiled workwear, clean contaminated surfaces immediately
Personal
ExamplesSuitable protective gloves, skin protection, gentle skin cleansing and skin care according to the skin protection plan
The effectiveness of the measures must be checked regularly, technical protective measures at least every third year (Section 7 (7) GefStoffV). Warning signs include expired gloves or gloves worn for too long, conspicuously low consumption of skin products or dried-up dispensers.
Using protective gloves and skin products correctly
For chemical protective gloves, section 8.2 of the safety data sheet states the material, thickness and breakthrough time. The breakthrough time is tested at 23 °C – inside the glove it is about 33 °C, and in practice it can drop to a third. According to TRGS 401:
- Only put gloves on clean, dry hands and check them for cracks, hardening or swelling before each use
- Observe the maximum wearing time – it starts with the first contact with the chemical
- Change gloves regularly, at the latest every working day; earlier if hands sweat, or use undergloves made of sweat-absorbing material
- When taking them off, do not let the outside touch the skin, and afterwards only dry the hands instead of washing them
- Only use powder-free latex gloves
Skin protection plan, operating instructions and instruction
Based on the risk assessment, a skin protection plan is drawn up for skin products (TRGS 401 section 6). The TRGS recommends recording all personal protective measures by task and posting the plan in suitable places such as the washbasins. For each task it answers:
- Which protective gloves – material, type and change interval?
- Which skin protection before work and after breaks?
- What are hands cleaned with?
- Which skin care after work?
- Whether and when are hands disinfected?
The measures defined also belong in the operating instructions (Betriebsanweisung) under Section 14 GefStoffV and TRGS 555. Based on them, employees receive oral, workplace- and task-specific instruction – before starting work and at least once a year thereafter, with documentation. This includes general occupational medical and toxicological advice, for example on skin changes caused by wet work. Practising putting on and taking off gloves with fluorescent training products under UV light has proven effective.
Occupational health care and occupational disease
For wet work of regularly more than two hours a day, the employer must offer health care; from four hours or more it is mandatory (ArbMedVV Annex Part 1). Other triggers include skin-sensitising substances, isocyanates, uncured epoxy resins and natural rubber latex gloves with a high protein content.
Redness, itching, scaling or cracks on the hands are warning signs that employees should report early. Through the dermatologist procedure (Hautarztverfahren) of the accident insurance institutions, dermatologists can act as soon as a skin disease begins; the accident insurance must counter the risk of an occupational disease with all suitable means (Section 3 of the Occupational Diseases Ordinance, BKV).
Checklist: skin protection in the company
- Activities involving wet work and skin contact with hazardous substances recorded
- Hazard statements from the safety data sheets evaluated
- Substitution, technical and organisational measures checked
- Protective gloves selected according to the safety data sheet, change intervals defined
- Skin protection plan drawn up and posted at the washbasins
- Skin products provided in dispensers
- Operating instructions updated and instruction given at least once a year
- Offered or mandatory health checks for wet work organised
- Effectiveness of the measures checked regularly
Free templates for this guide
As PDF and Excel, free – to use in your own company.
Frequently asked questions
When does wet work apply?
Under TRGS 401, when employees regularly have skin contact with water or aqueous liquids for more than two hours per working day, wash their hands at least 15 times a day or frequently alternate between wet hands and liquid-tight gloves. Wearing tight gloves alone does not count.
Is a skin protection plan mandatory?
TRGS 401 provides for one if the risk assessment identifies skin products as a protective measure. Companies that follow the TRGS can assume they meet the requirements of the Hazardous Substances Ordinance; those that proceed differently must achieve equivalent protection.
Who pays for protective gloves and skin products?
The employer – costs of occupational safety measures must not be passed on to employees (Section 3 (3) ArbSchG). For skin cleansers, TRGS 401 recommends dispenser systems.
Does barrier cream replace protective gloves?
No, only in exceptional cases: where gloves are not permitted, for example because of the risk of entanglement on machines, and only for water, aqueous liquids or brief, small-area contact with substances labelled, for example, H315 or EUH066. For substances with H310, H314 or H317, gloves cannot be replaced by cream.
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.
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