When using hazardous substances, it is necessary to conduct a substitution check.
A substitution check involves assessing whether there are alternative products available that are less hazardous and could be used instead of the current hazardous substances. The purpose of the check is to identify and evaluate potential substitutes that can reduce the risks associated with the use of hazardous substances.
A substitution check involves several steps. Firstly, the hazardous substances to be replaced are identified. Next, an assessment of the hazards associated with the current hazardous substances is conducted. Research is then conducted to explore alternatives, evaluating their effectiveness, cost, and environmental impact. A feasibility analysis of the selected alternative is performed to assess its implementability. Finally, the measures are monitored, and their effectiveness is evaluated. The analysis of substances follows the column model (TRGS 600).
The aim of the substitution check is to replace hazardous substances with safer alternatives while ensuring formally comparable results, which are presented according to the column model. The following hazards are examined:
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.
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.
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.
With the clear dashboard of the compliance platform, you always have an overview of the processing status. You can set deadlines and assign tasks to specific contacts. All data and documents come together here. When visiting the authorities, all documents can be handed over easily and there are no delays. You can save time and nerves. Even if a new contact person comes along, no data can be lost.
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.
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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.
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.
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.
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.
- 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
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:
- Reduced storage requirements
- Elimination of recurring inspection costs
- No or lower requirements for personal protective equipment
This is just a small excerpt of ways in which substitution testing and its implementation can save costs.
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