In my last blog, I looked at what a hazardous substances register actually is. Anyone who deals with hazardous substances and the Hazardous Substances Ordinance [1] will sooner or later stumble across the term “low hazard”. Today I would like to look at when a low hazard is assumed and what consequences this has.
Hazardous substances with low risk
The definition of low risk can be found in the Hazardous Substances Ordinance, Section 6, paragraph 13.
- the hazardous properties of the hazardous substance
- the small amount of material used
- low exposure in terms of height and duration
- the working conditions,
that the general measures to be taken under Section 8 are sufficient, no further measures under Section 4 need to be taken. Section 4 of the Hazardous Substances Ordinance deals with protective measures. The definition also makes it clear that a hazardous substance that is classified and has pictograms can still be assessed as a low hazard if, for example, the quantity used is very small. This can of course vary from activity to activity and is therefore not only specific to the hazardous substance, but also depends on the activity carried out. The definition of “low hazard” is therefore a result of the hazardous substance hazard assessment carried out.
Examples of TRGS 400
TRGS 400 [2] specifies the requirements of the Hazardous Substances Ordinance. It also contains some examples of activities with low risk. For example, repairing minor paint damage with touch-up pens, cleaning a coffee machine with tabs or inserting dishwasher tabs are mentioned. In addition, activities are also listed that cannot be low-risk activities. These include, for example, working with hazardous substances in confined spaces and containers or activities involving corrosive hazardous substances where skin contact cannot be ruled out.
Consequences for occupational health and safety
No further protective measures are necessary for activities with low risk. This includes, for example, checking for substitution, personal protective equipment or the creation of operating instructions. For occupational health and safety, this means considerably less work compared to activities involving a hazard. In some companies, further measures are nevertheless taken even in the event of a low risk and, for example, operating instructions are still drawn up. However, this is not legally binding.
Conclusion
If the risk assessment reveals that there is only a low risk for a specific activity with a hazardous substance, e.g. due to the small quantity, this reduces the subsequent effort. It is important that the exceptions listed in TRGS 400 are observed. There are situations in which a low hazard can never be determined.
[1] Ordinance on Protection against Hazardous Substances (GefStoffV), status 07/2021
[2] Technical Rules for Hazardous Substances, TRGS 400, version 08.09.2017, BAuA website
