Posting of the operating instructions in the workplace

The Hazardous Substances Ordinance (GefStoffV), §14 [1] states that one must prepare operating instructions for certain hazardous substances and make them available to employees. In Germany, the TRGS 555 [2] provides more specific information on the preparation of the operating instructions. Here, it also defines that the posting of the operating instructions must take place “if possible in the vicinity of the workplace”. In this blog post, I look at what that means exactly.

General requirements for the operating instructions

According to GefStoffV and TRGS 555, the operating instructions are the basis for the instruction of the employees. The employer is responsible for drawing up the operating instructions. However, the employer often delegates this responsibility to hazardous substances officers. Furthermore, one has to prepare the operating instructions in a language that the employees understand. In addition, they should have access to the operating instructions before they start working with the hazardous substance. In most cases, the question of what this means for the posting of the operating instructions already arises during the drafting process.

What does “close to the workplace” mean?

The term “proximity to the workplace” has no precise definition either in the GefStoffV or in TRGS 555. In the case of operating instructions for machinery, the proximity for posting is often simpler. Here, they are an attachement to the corresponding machine or hang next to it. This is also suitable, for example, for operating instructions for hazardous substances that are only required in a specific fume cupboard or on a specific machine. However, if several places or machines use the hazardous substance, the question arises as to how one can understand the “proximity to the workplace”. The purpose of this proximity should of course be that an employee who works with the hazardous substance can see at any time what he or she must observe when handling the substance. If one floor includes several laboratories, it is probably advisable to display the operating instructions in each of them and not just once in a central location.

Conclusion

Ultimately, GefStoffV and TRGS 555 do not give a precise definition of what is meant by “proximity to the workplace”. Thus, the responsibility to select a suitable place lies in the hands of the employer. However, one should ensure quick access to the operating instructions. Once the operating instructions have been posted, the question often arises as to how long operating instructions must be kept. I have already dealt with this issue in an earlier blog post.

[1]        GefStoffV, §14

[2]        Technische Regeln für Gefahrstoffe, TRGS 555 (currently only available in German), as of 20.04.2017, BAuA website