May an operating instruction be made available exclusively in digital form?

In the course of digitalisation, many companies are also changing their document management. They replace paper documents as much as possible. Even safety data sheets are hardly ever passed on “analogue” today, but distributed as PDF documents. This raises the question of how to proceed in hazardous substance management – may one pass on operating instructions to employees exclusively in digital form? Or is the classic notice board obligatory?

General requirements for the operating instructions

The obligation to prepare operating instructions results from the Hazardous Substances Ordinance, §14 [1]. The preparation of the operating instructions must be in writing and accessible at all times. The Hazardous Substances Ordinance does not impose any further restrictions. In Germany, the TRGS 555 [2] provides more specific information on the preparation of such instructions. It defines here, for example, that one must post the operating instructions near the workplace. I have already described what this means exactly in this blog post. However, the TRGS do not provide any precise information on how the operating instructions must be made available. However, it clearly states one thing: The instruction of the employees must be in writing. It is therefore not sufficient to provide a digital document.

Digital distribution of the operating instruction

You often see operating instructions on fume cupboards, walls or shelves. Legally, however, neither the Hazardous Substances Ordinance nor TRGS 555 explicitly state that you have to do it in this form. The only thing that is clear is that employees must have access to the operating instructions. Ultimately, of course, this must also ensure that everyone can consult the operating instructions at any time when handling a hazardous substance.

Conclusion

In summary, there is no information in the Hazardous Substances Ordinance or the TRGS 555 on how one should make the operating instructions available. The aim should always be quick access to the document. If the operating instructions are to be digitally accessible, then quick access must be possible.

Digital transmission is also a good option, for example, if employees work in the field. In this case, the instruction can first take place verbally, as the Ordinance on Hazardous Substances states. Afterwards, the operating instructions can be retrieved digitally at any time. A field worker does not have to carry a folder with operating instructions on paper, but only a tablet with the relevant documents, for example.

[1]        Ordinance on Hazardous Substances, §14

[2]        Technische Regeln für Gefahrstoffe, TRGS 555, as of 20.04.2017, BAuA website