Ann. occup. Hyg., Vol. 46, No. 1, pp. 119-125, 2002
© 2002 British Occupational Hygiene Society
Published by Oxford University Press
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The Development of Process-specific Risk Assessment and Control in Germany
1Bau-Berufsgenossenschaft Frankfurt am Main, Hungener Straße 6, D-60389 Frankfurt; 2Bundesanstalt für Arbeitsschutz und Arbeitsmedizin, Fritz-Henkel-Weg 1–25, D-44149 Dortmund; 3Landesamt für Arbeitsschutz, Kühnauser Straße 70, D-06846 Dessau, Germany
Received 12 February 2001; in final form 11 July 2001.
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ABSTRACT |
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After reading the series of articles on a new approach to controlling chemicals, an initiative targeted especially on small and medium-sized businesses, in the Annals of Occupational Hygiene (1998; 42: 355–411), German specialists for health and safety at work realized that problems in this area are very similar in the UK and Germany. Also, in Germany different institutions have developed an array of solutions to help small and medium-sized enterprises during recent years. In this paper, we present these activities and hope to promote an international discussion about practical support for work with chemical substances.
Keywords: chemicals; control; risk assessment; process-specific
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INTRODUCTION |
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‘Only 1 per cent of all companies carry out measurements’ (Bartels, 1998) and ‘Above all in small and medium-sized companies, those who process chemicals are often not able to protect themselves even if they are motivated to do so’ (Voullaire, 1995). These statements are characteristic of the present debate in Germany about regulating protection from hazardous substances. Small and medium-sized companies—the vast majority of companies—lack the general knowledge required for protection from hazardous substances, especially the information needed in specific cases. For example, safety data sheets, the major source of information for companies, are inadequate both in qualitative and in quantitative terms, particularly as far as safe handling recommendations are concerned (Rühl, 1989; Rühl and Rheker, 1994; Geyer et al., 1999; Kaup and Pohl, 1999).
To train hazardous substances experts in all companies is just as inappropriate as an approach satisfied with a low level of protection. ‘Deregulation’, such as the deletion of prescriptive provisions in favour of less prescriptive, goal-setting measures, will not help these companies either. Small and medium-sized companies need prescriptive requirements but only where such requirements are necessary for their specific activities.
Following this thesis, sector-specific arrangements are a promising new way to promote the safe handling of hazardous substances. Such solutions use the existing set of rules as a base. The provisions relevant to the respective sector of industry are selected, and generally applicable examples and guidance for action are prepared.
In Germany, such sector- and substance-specific prescriptive guidance is being developed in many fields, and by a large number of institutions. This contribution will inform the debate.
Recently, action on how to improve the situation has been developed in the UK; this action is based on similar circumstances prevailing in businesses there.
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DEFICITS IN THE MANAGEMENT OF HAZARDOUS SUBSTANCES |
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In the UK there are similar problems to Germany regarding protection from hazardous substances, and there is a similar need to improve the situation. In the UK, across all industries, 74% (in manufacturing 55%) of firms have <10 employees.
In the UK, legislation has placed responsibilities for health and safety firmly on employers. But despite the vast amount of publicity and excellent guidance produced by the Health & Safety Executive (HSE) over the past 10 years, a recently published survey (commissioned by HSE) showed that two-thirds of chemical users were still unaware of the relevant legislation (Topping et al., 1998). According to this study, one-tenth of these small firms (with <10 employees) claimed to monitor airborne concentrations of hazardous substances, but experts judged the true number to be much less than that. On the other hand, most respondents to the study reported that they had taken steps to protect employees.
Risk assessment is a series of common sense judgements based on information about the type of the substance, its health effects and how it is being used in the workplace. The use of personal protective equipment features very highly, followed by the use of process controls (ventilation systems, enclosed systems or modification of the process). Clearly, little thought is given to eliminating the hazardous substance or using it in a safer form. This is the opposite of the approach required by the Control of Substances Hazardous to Health Regulations—the UK law requiring protection from hazardous substances.
In deciding what steps to take to protect employees, chemical users rely mainly on information from suppliers, including safety data sheets, rather than the carefully crafted regulatory system of legislation and guidance. In response to this, in the UK the HSE has developed a simple system of generic risk assessment to identify appropriate control strategies and a series of control guidance sheets providing good practice examples of those strategies (Russel et al., 1998). To help the advice reach small firms, the HSE is seeking to involve key intermediaries in its dissemination.
The scope of application of the British system described is clearly more comprehensive than that of the industry-specific and substance-specific guidance that is being worked on in Germany. However, points of similarity do exist. Because of its comprehensive approach, the British system could be applied to situations for which more specific solutions have not yet been developed. On the other hand, the experiences and data upon which the specific German guidance is based could be used to underpin the theoretical assumptions behind the UK system. The UK concept and the German one that is described later have one thing in common, however: they assume that small and medium-sized companies that use chemicals receive support from those who they already trust and who have committed themselves to ‘responsible care’.
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GUIDANCE FOR COMPANIES |
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‘The risk situation in the companies of a given branch of industry or related to a certain activity is often comparable. Therefore, it would be appropriate to group risks together on the basis of branches of industry or activities and to provide information about suitable protective measures and the relevant safety and health regulations.’ This is the résumé of the principles for risk assessment under the Safety and Health at Work Act jointly adopted by the Federal Ministry of Labour and Social Affairs and the institutions responsible for health and safety at work (BArBI, 1997).
Industry-related guidance or sector-specific arrangements are support concepts beyond the level of the individual company. They are drafted centrally to help companies without lowering the standards of health and safety at work. Industry-specific arrangements should be worked out with the involvement of, or at least in consultation with, all institutions responsible for health and safety in the respective sector. These are, as a rule, the social partners, the industrial accident insurance funds of that sector, the health and safety authorities of the federal states, and the manufacturers of the respective products. If these bodies are involved, it is highly likely that the arrangements worked out will meet the demands of all parties concerned. With regard to such a procedure, the Federal Ministry of Labour and Social Affairs has stated elsewhere: ‘Good results are those which realise the special policy aim without overtaxing companies’ (Bieneck, 1994).
What is behind the call for industry-specific arrangements is the consideration that central bodies with technically qualified staff can deal better and more cost effectively with the respective subject matter than many hundreds or even thousands of individual companies.
Industry-specific arrangements may assist a large number of companies with the identification and assessment steps required for the management of hazardous substances, yet still—or, rather, therefore—help them achieve the aim of safe handling of hazardous substances (Fig. 1). Depending on the industry-specific arrangement, some of the steps normally necessary may not need to be taken at the company level. In the case of the hazardous substances list for pharmacies (see Table 1), for example, a proposal is made for only one step of the hazardous substance management. Ideally, it would be possible to prepare all steps. The Rules for Handling Cleansing and Care Agents offers support to companies ranging from the testing of substitutes to user instructions. Managers then check whether the concept is applicable to their respective companies and complete the task, e.g. by revising a prepared list of hazardous substances, completing draft operating instructions, organizing workers’ instruction and taking necessary protective measures.
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THE HIGH DEGREE OF ACCEPTANCE FOR INDUSTRY-SPECIFIC ARRANGEMENTS |
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For these reasons, industry-specific arrangements increasingly meet with official acceptance in Germany. In the Technical Regulations for Hazardous Substances (Technische Regeln für Gefahrstoffe, or TRGS) 400, 402, 440 and 500, reference is made to industry-specific arrangements. TRGS 400, ‘Identifying and assessing risks caused by hazardous substances at the workplace: requirements’, states: ‘If the areas of work in a given sector have already been assessed in the context of an industry-specific arrangement, the employer may use this assessment as a basis for any further measures’.
The industry-specific arrangements (i) the GISCODE for adhesives for floor coverings, (ii) the management system for dangerous substances in VW garages and (iii) the management and training system promoted by MALEG (which is under the purchasing cooperative for painters equipment at Lübeck) (Table 2) received the German Hazardous Substances Award in 1994, 1996 and 2000, respectively, which is another indication of the high degree of acceptance of these concepts.
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EXISTING INDUSTRY-SPECIFIC ARRANGEMENTS |
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The technical regulations governing the use of less hazardous substances and products (Table 3) may be regarded as the forerunners that paved the way for today’s concept of industry-specific arrangements. They date back to the 1980s, when they were drafted by the Hazardous Substances Committee—which, according to the Hazardous Substances Ordinance, includes representatives from all relevant groups of society—and state in which applications particularly hazardous substances and products should be replaced.
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Requirements for safe handling procedures for substances are laid down in TRGS 420, ‘Procedure- and substance-specific criteria to permanently safeguard compliance with occupational exposure limits’. If, in a certain industry, sector activities and procedures are rather uniform, these criteria are often also industry specific. If an employer finds out, in the context of a working area analysis, that his activities meet the criteria of TRGS 420 and he documents this result, he may not need to perform measurements, or may use a simpler strategy. He might also use further preventive and protective measures instead of monitoring. Unfortunately only a limited number of such criteria have been laid down in TRGS 420 so far. Procedure- and substance-specific criteria exist to permanently safeguard compliance with occupational exposure limits in cases where
• organic liquids are filled into packing drums with a capacity of up to 250 l
• tyres are retreaded
• polyvinyl chloride is processed
• working substances are handled in plants, plant sections or working processes.
Help to deal with concrete issues of occupational health and safety (especially in new areas of work and technology) is also offered by the LASI (Federal Committee of Occupational Health and Safety) guidelines. Issued by the occupational health and safety authorities of the federal states, they include guidance for action and provide information and concrete recommendations on various steps of the identification process. The need to deal with these issues resulted from the practical work of the occupational health and safety authorities (Table 4).
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BG/BIA (German Berufsgenossenschaften/Central Research Institute of the BG) recommendations refer to a large number of representative monitoring results to describe hazardous substances exposures for certain substances, methods and areas of use. Table 5 shows the result of >80 measurements at workplaces using strippers containing dichloromethane (these strippers contain >75% dichloromethane). It can be seen that the limit value (350 mg/m3) is exceeded 6-fold—even when working in the open air! Because of this, TRGS 612 describes the use of substitutes.
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BG/BIA recommendations may thus serve as a basis for relatively safe statements about the exposure to be expected in the context of certain activities without the need for companies to carry out measurements of their own. This shows the positive trend that, on the one hand, an ever increasing number of such recommendations are worked out by official bodies, and on the other hand, manufacturers identify the expected exposures for their products when used as intended, thus providing their customers with valuable assistance (Table 6).
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It is also possible, of course, that information supplied by the manufacturer enables clients to handle the product safely without the need to carry out all the steps of identification themselves. ‘Product responsibility does not end at the factory gates but begins with research and development, continues with production, storage and distribution, includes use and recycling and ends only with disposal’ (Hulpke, 1998). As with industry-specific arrangements, appropriate information supplied by manufacturers helps to manage hazardous substances while maintaining the level of health and safety. Responsible manufacturers will assume this duty (responsible care). The first steps have been taken with the BG/BIA recommendations on the use of wood protectants based on copper-HDO, and on the handling of bitumen and bitumen-content materials, and with the industry-specific arrangement for the production of cement with a low content of chromate.
One possibility to promote initiatives on the part of manufacturers could be the drafting of guidelines for ‘sound product information’ as industry-specific arrangements. Such sound product information could be structured in the same way as the technical information sheets, for example—which are often well presented and clear. The safety data sheet could contain the same information, or refer to these information sheets. If a technical information sheet bore the quality mark ‘sound product information in accordance with standard xyz’, clients could use this information as a basis for their measures.
In Germany, an appropriate body for a broad-based initiative for the drafting of such guidelines would certainly be the Hazardous Substances Committee, but initiatives on the part of industry representations and associations are also possible. Such a proposal should be of interest for the member companies of VCI (German Chemical Industry Association) in particular, since it offers a concrete possibility to meet the requirements of responsible care.
Sound product information is already available for many product groups in the building industry. The GISCODE or product code is an essential part of nearly all industry-specific arrangements in the construction industry. This code classifies all products that are to be used for one purpose according to comparable risks (e.g. 21 groups in the GISCODE for primers and adhesives; Table 2). Manufacturers may refer to this code on packing drums, in safety data sheets and any other information. The code goes together with information collected by GISBAU (www.GISBAU.de) on the respective products, including draft operating instructions, and information on the substitutes, exposure and concrete protective measures that are required (Rühl, 1997).
Special reference is made to the Rules for Handling of Cleansing and Care Agents. For the first time, all those concerned with health and safety at work, including the supervisory authorities, were involved in the preparation of such information. The information sheet was drafted at the same time as TRGS 440, which refers to it. It is not only the first industry-related implementation of the said TRGS, but also provides concrete information on exposure to hazardous substances in cases where cleansing agents are handled.
The first generally applicable, i.e. not industry-specific, arrangement is currently being prepared. It is aimed at all relevant uses of bitumen. Exposure levels and the required protective measures are being identified for all work practices involving bitumen. The exposure scenarios for these workplaces are described in BG/BIA recommendations. In addition, detailed studies are being carried out focusing on the dermal impact and the constituents of the various types of bitumen, and in a further study the question of a possibly carcinogenic potential is to be clarified.
In addition to the documents already mentioned, further industry-specific arrangements exist, especially in the construction sector. Table 1 contains the arrangements in Germany that are known to the authors.
Other countries, too, seem to regard industry-specific solutions as a way to have regulations accepted and implemented adequately. In Switzerland, the new ‘Directive on the use of occupational health specialists and other experts for safety at work’ is a further instrument to help companies prevent accidents. The technical association for sand and gravel pushed the implementation of the directive by means of an industry-specific solution (Furrer, 1997).
The PISA system of Stichting ARBOUW (Stichting ARBOUW, 1996) in the Netherlands is a product register similar to the GISCODE. PISA (Produktgroep Information Systeem Arbouw) also forms clusters of the products of several manufacturers based on their use and hazards. PISA includes the major building materials, inter alia cements and mortar, insulation materials, adhesives, and roofing materials.
By means of industry-specific arrangements, the management of hazardous substances in the companies is made much easier in certain sectors. For example, if a floor layer follows TRGS 610 and uses an adhesive with a low solvent content (GISCODE D2), he does not need to worry about the issue of substitutes. The BG/BIA recommendation on this work informs the company that the limit values of the constituents are not exceeded when these adhesives are processed—which means that there is no need to identify the hazardous substances concentration in the company. Table 7 informs about the possible support that may be provided by industry-specific arrangements—arrangements which make the management of hazardous substances much easier while the level of protection is maintained.
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OUTLOOK |
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TOPABSTRACTINTRODUCTIONDEFICITS IN THE MANAGEMENT...GUIDANCE FOR COMPANIESTHE HIGH DEGREE OF...EXISTING INDUSTRY-SPECIFIC...OUTLOOKREFERENCES |
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After a detailed description of the situation in the UK (Topping et al., 1998), the German considerations have been presented. In so doing, we want to highlight that not only are the shortcomings in handling hazardous substances comparable between the two countries, but also the approaches to the solutions that are being discussed go into the same direction. Consequently, a Europe-wide discussion of the issue could be very constructive and lead to a uniform way of acting.
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FOOTNOTES |
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* Author to whom correspondence should be addressed. e-mail: reinhold.ruehl@bg24.bgnet.de
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REFERENCES |
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