Help for substitution – the TRGS 600
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I have already presented the column model of TRGS 600 [1] to you in recent weeks. However, the TRGS 600 naturally also offers further information and assistance on the subject of substitution. I would like to present some of the contents of the TRGS in this article.
TRGS
The Technical Rules for Hazardous Substances (Technischen Regeln für Gefahrstoffe – TRGS) contain information that is relevant, for example, for the preparation of operating instructions (TRGS 555) or safety data sheets (TRGS 220). The TRGS thus specify certain topics that are prescribed by the Gefahrstoffverordnung (GefStoffV) [2]. If the employer complies with the TRGS, you can assume that the obligations and requirements of the GefStoffV are also met.
TRGS 600
TRGS 600 deals with the subject of substitution. In the GefStoffV, the obligation to check for substitution possibilities is mentioned in the context of information determination and risk assessment. The result must be documented. The GefStoffV does not provide much further information. It is therefore worth taking a look at TRGS 600, which provides further information and assistance on substitution.
After defining the scope and some terms at the beginning, the TRGS lists some important sources of information on substitution. For example, reference is made to other TRGS (500 ff. and 600 ff.) as well as to information systems such as WINGIS or to the safety data sheet itself. If far-reaching decisions have to be made that relate to a high hazard or to a large number of people at risk, a correspondingly in-depth search must be carried out.
Guiding criteria and decision
In the course of the substitution test, several possibilities for substitution can also be identified. In order to make a preliminary selection here, TRGS 600 suggests comparing certain criteria, for example physical-chemical properties or health hazards.
The aim of substitution is to reduce the hazard posed by hazardous substances at the workplace without increasing other hazards or endangering other objects of protection. Of course, the substitution solution must also be technically suitable; the function of the hazardous substance is relevant here, for example. Replacing an adhesive with water is not technically a sensible solution.
Documentation
The GefStoffV specifies that the substitution test must be documented. The TRGS 600, for example, also provides guidance here by means of various standard phrases.
Annexes
The majority of TRGS 600 consists of annexes. Here, various examples and use cases are used to explain what a substitution test can look like. The column model is also explained in detail and provides a good basis for comparing different hazardous substances. A substitution is often not only a technical decision, but must also be checked economically. The TRGS also provides a clear table for this purpose, with which the operational use can be well weighed up.
Conclusion
The substitution of hazardous substances is a complex topic in which many different points must be taken into account. The information in the GefStoffV is very concise, so it is definitely worth taking a look at TRGS 600. In addition to important information, the TRGS also offers various tools such as the column model, which can be applied directly in practice.