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Substitution assessment template (PDF & Excel) based on TRGS 600

Form and Excel sheet for the substitution assessment in Germany – with starting point, research sources, comparison of the current substance with up to three alternatives across 13 criteria, TRGS 600 standard sentences, justification and reassessment date.

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Employers in Germany must check in the risk assessment (Gefährdungsbeurteilung) whether hazardous substances or processes can be replaced by less hazardous ones, and on that basis substitute as a priority (Section 6 (1) sentence 2 No. 4 and Section 7 (3) of the Hazardous Substances Ordinance, GefStoffV). The result must be documented; if protective measures under Section 9 or 10 are needed, a decision not to carry out a technically possible substitution must be justified (Section 6 (8)).

This template guides you through the TRGS 600 procedure in its own structure: starting point and function of the substance, research, comparison of the current situation and alternatives in terms of health, fire, explosion and environmental hazards, technical suitability and operational factors, decision, justification and next steps. In Excel, you also keep a register of all assessments with an automatically calculated reassessment date.

What the template contains

  • Three-page landscape PDF with header data, starting point and a checklist of research sources
  • Comparison table for the current situation and up to three alternatives with 13 predefined criteria
  • Decision using the TRGS 600 standard sentences, a justification field and a plan of next steps
  • Excel register with drop-down lists for result and need for measures, and automatic calculation of the next assessment
  • Second worksheet for the comparison by criterion with ratings from ++ to – –

How to use the template

  1. 1

    Record the starting point

    Describe the substance or process in use with its classification, quantity, duration and function in the process. Clarify whether protective measures under Section 9 or 10 GefStoffV are needed – if so, a decision not to carry out a possible substitution must be justified.

  2. 2

    Find and compare alternatives

    Research the TRGS on substitutes, industry solutions, databases and suppliers, including alternative processes. Enter the current situation and alternatives in the comparison table and only ever compare within one criterion; the details are mainly in sections 2, 9 and 11 of the safety data sheet.

  3. 3

    Decide and set a date

    Tick the matching standard sentence, justify the decision and plan the next steps – from a trial run to instruction. Set the date by which the assessment will be repeated and transfer the result to the risk assessment and the hazardous substances register.

Hazardous substances management in AMS GoUpload safety data sheets, have AI extract classification and H statements with source references, and assign and approve hazardous substances by site, department or area of use.

Legal basis

  • Section 6 (1) sentence 2 No. 4 of the Hazardous Substances Ordinance: possibilities of substitution as part of the risk assessment
  • Section 6 (8) sentence 2 Nos. 2 and 3 of the Hazardous Substances Ordinance: documenting the result of the substitution assessment and the justification for not substituting
  • Section 7 (3) of the Hazardous Substances Ordinance: priority substitution with non-hazardous or less hazardous substances or processes
  • Section 18 (3) of the Hazardous Substances Ordinance: reporting the result of the substitution assessment for carcinogenic, germ cell mutagenic and reprotoxic substances of category 1A or 1B to the authority on request
  • TRGS 600 “Substitution”: procedure, key criteria, column model, weighing-up criteria and documentation

Frequently asked questions

Is a note in the risk assessment enough?

Yes, no particular format is prescribed. TRGS 600 recommends documenting the result together with the risk assessment, for example in extra columns in the hazardous substances register showing the date, result and reference. For more complex decisions – such as when a possible substitution is not carried out – a separate form like this template helps record the weighing-up in a traceable way.

What is the column model?

An assessment aid from Annex 2 of TRGS 600: the current substance and the alternative are each assigned a level from “very high” to “negligible” in columns such as acute and chronic health hazards, environmental hazards, fire and explosion, release behaviour and process. Comparisons are made only within a column; if the alternative is two or more levels better, there must be important reasons for not using it.

When do I have to repeat the substitution assessment?

There is no fixed interval. The assessment is part of the risk assessment, which is reviewed regularly and updated without delay after significant changes or new information (Section 6 (10) GefStoffV). Enter a reassessment date and check earlier if new substitute products, technical rules or changed classifications become known.

You may use and adapt the template freely in your own company and for your own clients. It reflects the regulations named as they stand.

Never search a spreadsheet for a deadline again

In AMS Go, what this template covers lives in one system with reminders, history and records at the push of a button – mobile and with AI support.

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