Have you ever seen signed an operating instruction? Or are they perhaps signed in your company by default? This raises the question whether the signature field is mandatory or voluntary. Before I answer this question, I will summarize a few basics on operating instructions in general.
Why create an operating manual at all?
All companies and laboratories that work with chemicals or hazardous substances are required to create operating instructions for the substances they use. They are also required to make it available to their employees [1]. These documents contain comprehensible information about what hazards a chemical entails and what protective measures must be taken when handling it. For example, section 3 of the operating instruction lists whether to use gloves or face protection.
The operating instructions not only serve to provide the personnel with an overview of where and which chemicals are handled. Or which measures must be observed. They are also very important in the event of an accident. For example, information is provided on how to act in the event of fire, eye contact or vapor inhalation. In the event of an emergency, this information is important for first responders or the fire department. Despite this great importance of the operating instructions, there is a lack of clarity in many places as to who draws up the operating instructions and whether they must subsequently be checked or signed.
The legal basis – Ordinance on Hazardous Substances
The legal basis for protective measures for employees is laid down in the Ordinance on Hazardous Substances [1]. For example, regular hazardous substance risk assessments are part of the employer’s obligation. The obligation to prepare operating instructions can also be derived from the Ordinance on Hazardous Substances.
In addition to the contents of the operating instructions, it is stated that the instruction of the employees take place on the basis of the operating instructions. Thus, the contents of the operating instructions form the basis of this instruction. From this context, it is easy to see how important the careful preparation of the operating instructions is.
The technical rule for hazardous substances – TRGS 555
More detailed explanations on the preparation of operating instructions can be found in the Technical Rule for Hazardous Substances (TRGS 555) [2]. According to this TRGS, the employer is responsible for ensuring that written operating instructions are available. Tthese must be made available to the employees before they start work. It is also the employer’s duty to prepare the operating instructions. In most companies, this obligation is delegated to an occupational safety specialist, a hazardous substances officer or a laboratory manager.
In addition to the manufacturer’s specifications or legal requirements, the knowledge of other experts can also serve as the basis for the content. The section structure is also specified in TRGS 555. It ensures that uniformity can be seen in operating instructions from different companies. This makes orientation in the operating instructions much easier. For example, the first section of the operating instructions always contains information about the place of work and the activity carried out there, while the sixth section describes first aid measures.
Is a signature mandatory or not?
In many templates for operating instructions, there is a line at the bottom for a signature, which is normally provided by the supervisor. This signature is intended to make it clear that the contents of the operating instructions must be observed. Or that, for example, wearing the listed protective equipment is mandatory. However, there is no legal requirement to have the operating instructions signed.
Neither the Ordinance on Hazardous Substances itself, nor the TRGS 555 provide more detailed instructions. However, a corresponding signature line is also intended to appeal to the conscientiousness of the creator. It additionally provides employees with a contact person for questions. If the signature field therefore leads to the operating instructions being created more carefully and the measures recorded in them being implemented more strictly, it is recommended that the operating instructions be signed by the supervisor.
Sources:
[1] Technical Rule for Hazardous Substances (TRGS 555)
[2] Ordinance on Hazardous Substances (GefStoffV)