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Technical Rules for Hazardous Substances (TRGS) 600 “Substitution”

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1. Elaborated by:

German Committee on Hazardous Substances (AGS), 2008

2. Description

The German Hazardous Substances Ordinance (GefStoffV) states that the employer has the duty to determine, test and decide on substitution and to document it. The Committee on Hazardous Substances (AGS) is in charge of establishing and adapting Technical Rules for Hazardous Substances (TRGS) which reflect the state of technology, occupational safety and health and occupational hygiene as well as other scientific knowledge relating to the requirements concerning the placing on the market and handling of hazardous substances.

The aim of the Substitution TRGS is to support employers:

  1. in avoiding activities involving hazardous substances,
  2. to replace hazardous substances by substances, preparations or processes which are not hazardous or less so under the relevant conditions of use or
  3. to replace hazardous processes by less hazardous ones.

TRGS 600 includes a framework for deciding on substitution that considers criteria for assessing technical suitability and health and physicochemical risk of alternatives.

In first place it establishes general criteria comparing the risks of the substance in use with the risks alternative substances. The risk of the substance can be reduced by substitution along the series in the respective line:

Health hazards:

  1. substances with a low occupational exposure limit (OEL) > substances with a higher occupational exposure limit (with comparable substance properties and exposures, the ratio of occupational exposure limit to vapour pressure is relevant, for example, in the case of liquids)
  2. systemic effect: highly toxic(T+) > toxic(T) > health hazard (Xn) > none of these features
  3. corrosive/irritant effect: corrosive (C) > irritant (Xi ) > none of these features
  4. carcinogenic, mutagenic, toxic to fertility (cmr) > not cmr

Physicochemical hazards:

  1. extremely flammable (F+) or pyrophorous (F, R 17) > highly flammable (F) > flammable (R 10) > none of these features
  2. combustion-enhancing (O) > not combustion-enhancing
  3. explosive (E) > non-explosive

Release potential:

  1. large quantity > small quantity
  2. process with wetting of large areas > process with wetting of small areas
  3. gas > liquid > paste
  4. dust-producing solid > non-dust-producing solid
  5. sublimating solid > non-sublimating solid
  6. low boiling point (high vapour pressure) > high boiling point (low vapour pressure)
  7. open process > closed process
  8. process at high temperatures > process at room temperature
  9. process under pressure > unpressurised process
  10. process involving generation of aerosols > aerosol-free process
  11. solvent-bearing systems > aqueous systems, etc.

When deciding on the suitability of a substitution possibility, estimation models should be used, – and in particular the Column Model and the Effect Factor Model – if it is not possible to make use of the general recommendations, or if the assessment of the risk is not absolutely clear.

The assessment of the technical suitability and health and physicochemical risk of alternatives are afterwards integrated to take a final decision on substitution.

In the case of activities involving hazardous substances which are toxic, highly toxic, carcinogenic, mutagenic or toxic to fertility (categories 1 and 2) substitution must be implemented if alternatives are technical practicable and lead to an overall lower risk to workers. In other cases the employer may take into account the economic assessment criteria.

3. Reliability

The main sources of information for this method are Chemical Safety Data Sheets. Several studies conducted in Europe (read more) have shown important shortcomings of these sheets, especially regarding classification. It is recommendable to double-check R phrases assigned to products and chemicals using additional sources as the European Chemical Substances Information System (ESIS) database. The implementation of the new European Regulation on Chemicals (REACH) must expedite the classification of more substances in the next years.

4. Applicability

Applicability is restricted to single cases of substitution of one product or chemical by another. It is not possible to compare products with alternative procedures or technologies. This method is aimed at SME’s and non-specialized users. It is applicable only to chemical hazards and risks.

5. User friendliness

The model is easy to handle by non-professional users and does not require special expertise if Chemical Safety Data Sheets are available.

6. Limitations

Since the method is based on R phrases, it  covers 7000 chemicals classified with such phrases, included in Regulation (EC) 1272/2008 CLP. However,  once the CLP inventory is published at the ECHA website, the classification of all substances placed on the EU market will be available independent of their registration status. Estimates can also be drawn using the description of hazards associated with R phrases if there is an additional source of information on the assessed risks. For these estimations a higher level of expertise would be recommended.

The most important advantage of this method is that is very easy to handle by non-professional users and facilitates a quick assessment on possible substitutes and alternatives.

7. Availability

TRGS 600 (in German or English) can be downloaded free of charge at Federal Institute for Occupational Safety and Health (BAuA) website.

8. Links

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Restricted and priority substances database» link
Case story database » link