ORDINANCE ON HAZARDOUS SUBSTANCES & Regulations
Substances and products whose handling poses a health risk are called "hazardous substances".
Anyone who handles hazardous substances must be aware of the dangers they pose and take appropriate safety measures. Whether a product is classified as a hazardous substance and which hazards it poses can be seen from the container label or in detail from the safety data sheet (to be found under Downloads on the respective product page).
The Ordinance on hazardous substanced imposes the following obligations on anyone who handles hazardous substances or who commissions others to do so:
Obligations from the ordinance on hazardous substanced
Establishing information and assessing risk (GefStoffV § 6)
Before commencing work, the employer must determine whether workers are carrying out activities with hazardous substances. Container imprints, product information, safety data sheets, and manufacturer disclosures may all be referred to as information sources. If this review concludes that hazardous substances have been used in work, the employer must assess all threats to the health and safety of the workers from here on out, and take the necessary measures for protection. The assessment will take place with respect to the following:
- hazardous properties of the substances or formulas,
- degree, type, and duration of exposure,
- work conditions and procedures,
- occupational exposure limit values,
- determining and assessing the effectiveness of protective measures, such as ventilation, suction, respiratory/dust protection, protective clothing
Consult the TRGS and GISCODE product group information for notes on the required work safety measures, or enquire with the Bau BG (German Building Trade Association). The results of this assessment must be documented.
Protective measures (GefStoffV §§ 8-11)
The results from the risk assessment will reveal the risk potential from hazardous substances that are processed, as well as the quantities used and the duration of contact. This information will be used to determine the protective measures that should be stipulated, whereby it applies that the less hazardous substance used, the fewer safety measures are required; the more hazardous substances are used, the higher the technical and organisational requirements and personal protective equipment must be used for the safety of the worker. The protection level concept abandoned with the revised form of the GefStoffV 2010, which provided increments of measures based on the actual risk, still offers a practicable, user-friendly aid for arranging suitable safety measures for dealing with hazardous substances:
Level 1 - low risk:
Minimum measures for low risk and exposure, e.g., repair work with a repair mortar labelled as an irritant. Minimise the risk through organisational measures, such as supplying and using simple protective clothing (e.g., protective gloves or dust mask).
Level 2 - moderate risk:
Applies to working with corrosive or highly flammable substances that are hazardous to health. Minimise the risk, if technically feasible, by choosing less hazardous products (substitution). If this cannot be done, use technical safety measures such as suction kit, blower, barrier. Personal protective gear is mandatory to wear. EMeasure to determine occupational exposure limit values (OELs). If OELs are exceeded, repeat the risk assessment and determine more effective measures.
Level 3- High risk:
Applies to handling toxic or carcinogenic substances. Minimise the risk through substitutions or closed systems. Measure and abide by occupational exposure limit values. Restrict access, seal toxins.
Stufe 4 - Very high risk:
Only applies to carcinogenic substances. Not relevant to floor/tile-laying practice.
Substitution requirement (GefStoffV § 6, paragraph 1, item 4)
Check whether products with lower risk to health can be obtained. Substitute hazardous products with ones that are less or not hazardous if technically feasible and reasonable. Change procedures or conditions if doing so will negate the need for hazardous products or can reduce the presence of hazardous substances in the work place. If a hazardous substance is used despite determining a risk, document the investigation results and reasoning for usage in writing. Industry-specific TRGS (Technical Rules for Hazardous Substances) such as TRGS 610 offer good support with respect to suitable options for substitution.
Supervisory requirement (GefStoffV § 6, paragraph 1, item 6)
The employer must determine whether the occupational exposure limit values are being complied with. This can be done through work place measurements or other equivalent assessment methods. If work is being done with replacement products in accordance with TRGS 610, the employer may assume that occupational exposure limit values are being complied with. Measurement is not required in this case.
Operating instructions (GefStoffV § 14)
Create and publish written operating instructions specific to the work place and product, including information on dangers, establishment of protective measures and rules for procedures, instructions for dangerous situations, first aid, disposal, etc. . Operating instructions must be written in a comprehensible format. Briefings must be conducted before commencing activity with hazardous materials, and at least once a year after that.
Information requirement (GefStoffV § 14, paragraph 2)
Briefing and hearing with concerned employees regarding investigations, hazards, safety measures, measurement results, etc.
Hazardous substances in the construction sector
Hazardous substances in the construction sector include solvent-based products, reaction resin products, cements and cement-based dry mortars. In order to ensure knowledge of the correct handling of hazardous substances, there are laws, technical rules for hazardous substances (TRGS) and voluntary labelling systems such as GISCODE and EMICODE.
Every relevant employer and craftsman should be familiar with these regulations. As the information given is often only comprehensible to safety experts and chemists, codex provides a brief overview of EU Regulation 1907/2006/EC (REACH), Annex XVII and the facts about the use of reactive resins, which must be observed when working with tiles and screeds.
(The following information makes no claim to completeness and does not release you from the obligation to inform yourself about all necessary measures for occupational safety and environmental protection by means of original texts, product information and safety data sheets)
EU REGULATION 1907/2006/EC (REACH), APPENDIX XVII
EU REGULATION 1907/2006/EC (REACH), APPENDIX XVII
The requirements for “replacement substance(s), replacement procedures, and restrictions on use of chromate-based cements and chromate-cement-based formulas” originally regulated in TRGS 613 were transferred to Appendix XVII of the REACH regulation in 2009, and appear there under the entry No. 47.
This standardises the use of low-chromate cements and cement products. According to this, the use of non-low-chromate products is prohibited. The background is that cement and cement-based products with humidity have strong alkaline reactions (alkaline effect). Contact with skin or eyes can cause irritation or chemical burns. Portland cements can also contain traces of soluble chromate (VI) salts. This chromate is considered a trigger for certain skin allergies, the so-called “bricklayer’s itch”.
Cements and cement-based products have been divided into the following 2 categories in TRGS 613:
- low-chromate: <= 2 ppm soluble chromate (→ GISCODE ZP 1 label)
- non-low-chromate: > 2 ppm soluble chromate
Through our monitoring in quality assurance, we ensure that all cementitious Uzin and codex products always adhere to the specifications from the REACH regulation. They carry the notation “low-chromate as per directive EU-VO 1907/2006 (REACH) – GISCODE ZP 1.”
Practically all reaction resins, such as polyurethanes and epoxy resins, are hazardous substances.
Unlike solvent-based products, however, solvent-free reaction resin products can generally be processed with perfectly normal ventilation in the work rooms without exceeding the air threshold limit, based on today’s level of knowledge.
It is true that reaction resin components can cause sensitisation or allergies in particularly sensitive people if carelessly handled.This is true of both components in epoxy resins, and only true of hardener components in polyurethanes. Skin and eye contact with fluid reaction resins that have not yet hardened should thus be avoided, and the information on work safety and suitable personal protective equipment in the safety data sheet should be observed. Processing epoxy resins and polyurethane products requires wearing protective gloves and impermeable sealed goggles at the very least, and in special cases, additional protective clothing may be required as well. Using skin protection cream is also advisable to supplement protection of the skin.
With respect to work safety, silane-based reaction resin products that require less or even no labelling constitute a user-friendly alternative. These products carry the GISCODE RS 10.
Separate from our labelling, this applies to all reaction resin products as a matter of principle:
Reaction resins are completely harmless in their dried condition, and then they even meet the EMICODE EC 1 or EC 1 PLUS classification in many cases. This means that once they have hardened, they release almost no more volatile (harmful) substances into the room air, and can thus be used in living areas with no risk at all.