Substitution check for hazardous substances according to TRGS 600

If hazardous substances are used, a substitution check must be carried out. This means that it has to be checked whether other, less hazardous products could also be used.

Substitution check

In the field of hazardous substances, a substitute substance is understood to be a less hazardous working substance that can be used as an alternative to a hazardous substance and thus minimizes the risk to people and the environment already at the source of the hazard. The Hazardous Substances Ordinance stipulates that, as part of the risk assessment before a hazardous substance is used, it must be checked whether a substitute substance or an alternative work process with a low health risk can be used (substitute substance test or substitution test).

There is often a perception that substitution testing is a huge time commitment because of the need to compare a wide variety of hazard types.

This does not take into account the advantages that the substitution of hazardous substances can also bring economically. Easing or eliminating protective measures can save the company money, for example by:

This is just a small excerpt of ways in which substitution testing and its implementation can save costs.

Contents of the substitution check

Analysis of the substances according to the column model TRGS 600

  • Investigation of acute health hazards
  • Investigation of chronic health hazards
  • Investigation of environmental hazards
  • Investigation of fire and explosion hazards
  • Investigation of the hazards due to release

Formally comparable results

Presentation of the results according to the column model

How do we proceed?

Safety data sheets

You provide us with the safety data sheets of all hazardous substances to be examined as a pdf document. If you do not have the information in this form, please contact us.

Analyzing

We analyze for the hazardous substances according to the column model according to TRGS 600 and provide you with the formal comparison of which hazardous substance would pose less danger.

Documentation

After completion, we will send you the result of the test for substitution according to TRGS 600 as a pdf or Excel file for documentation for your records.

We do substitution checks according to the Ordinance on Hazardous Substances

Substitution checks are part of the risk assessment and may only be performed by competent persons (GefStoffV). Our experts can provide you with holistic support in risk assessment and substitution checks for compliance with legal requirements.

Markus Höhfeld

Prices for substitution check

Prüfung

27,50 €/ SDS
  • Basic fee € 55
  • Analysis of the safety data sheets (SDS)
  • Execution of the test
  • Results as pdf or Excel file

All prices are exclusive of VAT.

Maria Leitner

Expert Customer Management

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    FAQ – Substitution check

    What is a substitution check?

    The Ordinance on Protection against Hazardous Substances (GefStoffV) requires, among other things, that possibilities for substitution, i.e. replacing the existing process, be examined as part of the information determination and risk assessment (§6).

    Substitution check should consider various alternatives that avoid or minimize the risk to worker health and safety. The alternatives that can be used for comparison are many and far-reaching. For example, a substitute substance could result in a lower overall risk, or handling could be made safer through technical protective measures.

    What if there are no recommendations for the substance in the substitute check yet?

    If there are not yet any recommendations for the substance, the “column model” of the Institute for Occupational Safety and Health of the German Social Accident Insurance (IFA) helps with the substitute substance test. The information required for this can be taken from the safety data sheet.

    Is substitution checks for hazardous substances mandatory?

    Yes, substitution testing is mandatory. It can only be waived if there is a low risk. According to § 7 para. 3 GefStoffV, the employer must give priority to substitution on the basis of the result of the substitution test according to § 6 para. 1 sentence 2 no. 4. He must substitute hazardous substances or processes with substances, mixtures or products or processes that are not hazardous or are less hazardous to the health and safety of employees under the respective conditions of use.

    Who is allowed to perform the substitution check?

    Substitution testing may only be carried out by competent persons (GefStoffV). A competent person is someone who has sufficient knowledge of hazardous substances on the basis of his or her training and experience, is familiar with the hazardous substances legislation and the activities in the company, and regularly undergoes further training on this subject.

    What is specified in the Technical Rules for Hazardous Substances Substitution (TRGS 600)?

    The Technical Rules for Hazardous Substances (TRGS) reflect the state of the art in technology, occupational medicine and industrial hygiene as well as other established scientific findings for activities involving hazardous substances, including their classification and labeling.They are issued by the Committee for Hazardous Substances (AGS) and published by the Federal Ministry of Labor and Social Affairs (BMAS) in the Joint Ministerial Gazette (GMBl).

    These TRGS specify the requirements of the Ordinance on Hazardous Substances (GefStoffV) in their scope of application. If the Technical Rules are complied with, the employer can insofar assume that the corresponding requirements of the Ordinance are met. If the employer chooses a different solution, he must achieve at least the same level of safety and health protection for the employees.

    What has changed in the new version of TRGS 600 “Substitution”?

    • Adaptation to the current status of the regulatory framework, in particular the Hazardous Substances Ordinance and TRGS 400 “Risk assessment for activities involving hazardous substances”.
    • Changes with regard to classification according to the CLP Regulation in determining the urgency of substitution.
    • Differentiation from the REACH regulation, e.g. with regard to REACH approval and substitution
    • Changeover of the column model to the CLP Regulation
    • Deletion of the previous impact factor model

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