REGULATIONS ON CHEMICAL LEGISLATION
REGULATIONS ON CHEMICAL LEGISLATION
Labelling and handling requirements for building products
Chemical products that contain hazardous components are labelled with hazard warnings and safety measures (H and P sets), as well as the accompanying pictograms. The globally harmonised system for classification and labelling of chemicals (GHS) was implemented in Europe by the CLP regulation (Classification, Labelling, and Packaging). This clarifies how chemicals substances and mixtures are to be labelled. The hazard identification alerts the user to the fact that the product harbours possible health hazards; at the same time, they provide recommendations for the safe handling of the product.
The GefStoffV of 26/08/1986 can be found here along with revisions since then.
The GefStoffV comprehensively regulates the classification, labelling, and handling of all types of hazardous substances.
The GefStoffV imposes the following obligations, among others (abridged), on everyone who deals with hazardous substances or tasks others with doing so (employers).
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. Measure 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.
Level 4 - extremely 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 617 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 617, 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.
The GISCODE is a German classification system for building products. GISCODE encompasses products from a certain group of materials that pose similar risks to the health of those who process them. This allows for simple, safe selection of protective measures required for the respective product. GISCODE is jointly supported by the Bau BG and concerned industry and trade associations. The user maintains a high level of safety despite the overall low cost of labelling.
Labelling is done independently by the manufacturer on safety data sheets, product containers, and technical fact sheets.
Common Giscode examples are
- Giscode W2+ Water-dilutable lacquer, solvent content up to 5%, free of N-Methylpyrrolidon
- Giscode W2/DD+ Water-based lacquer with hardener based on isocyanates, solvent content up to 5%, free of N-Methylpyrrolidon
- Giscode Ö10+ Oil/wax, solvent-free, oxim-free
You can find a detailed overviewhere.
Technical rules are recommendations and technical suggestions, primarily in the field of work and health safety, which recommend ways to adhere to laws, regulations, technical procedures, etc. The Technical Rule for Hazardous Substances 610 (TRGS 610) regulates “replacement substances and replacement procedures for heavily solvent-based primers and adhesives in flooring”
Dated: January 2011
TRGS 610 (GMBI 3/2011) divides primers and adhesives for working with floor coverings and wood flooring into the following 4 categories based on solvent content:
- Solvent-free: 0-0.5% solvent content
- Low-solvent: up to 5% solvent content
- Solvent-based: 5-10% solvent content
- High solvent-based: over 10% solvent content
Solvents are defined as fluid, highly volatile, organic substances with a boiling point of < = 200 °C. In terms of work safety, this encompasses any substance or constituent that is released as a hazardous fume while processing the product.
TRGS 610 provides clear decision-making criteria for the investigation and substitution requirements. From this it can be assumed that the occupational exposure limit values according to TRGS 900 for individual components are exceeded in the use of heavily solvent-based primers and adhesives in flooring. High solvent-based products should therefore be replaced with solvent-free products. A new point in the revised TRGS 610 is that now not only solvent-free dispersion-based adhesives (GISCODE D 1) may be designated as replacement substances, but also SMP adhesives (GISCODE RS 10) and solvent-free PU adhesives (GISCODE RU 0.5 and RU 1) are now considered replacement substances. Thus solvent-free, sophisticated alternatives now exist for all types of floor-laying work.
PALLMANN products that are covered by TRGS 610’s purview and meet the recommendation given there are labelled with “GISCODE D 1, GISCODE RS 10, or GISCODE RU 1”.
Technical rules are recommendations and technical suggestions, primarily in the field of work and health safety, which recommend ways to adhere to laws, regulations, technical procedures, etc. The Technical Rule for Hazardous Substances 617 (TRGS 617) regulates “replacement substances and replacement procedures for heavily solvent-based lacquer systems for parquet and other hardwood floorings”
Dated: February 2017
TRGS 617 divides lacquer systems for parquet and other hardwood floorings into the following 4 categories based on solvent content:
- Solvent-free: 0-0.1% solvent content
- Low-solvent: up to 5% solvent content
- Solvent-based: 5-15% solvent content
- High solvent-based: over 15% solvent content
Solvents are defined as fluid, highly volatile, organic substances with a boiling point of < = 250 °C. In terms of work safety, this encompasses any substance or constituent that is released as a hazardous fume while processing the product.
TRGS 617 provides clear decision-making criteria for the investigation and substitution requirements. From this it can be assumed that the occupational exposure limit values according to TRGS 900 for individual components are exceeded in the use of heavily solvent-based primers and adhesives in flooring. High solvent-based products should therefore be replaced with solvent-free products.
PALLMANN products that are covered by TRGS 617’s purview and meet the recommendation given there are labelled with “GISCODE W2+, GISCODE W2/DD+ or GISCODE Ö10+”.
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:
<= 2 ppm soluble chromate (→ GISCODE ZP 1 label)
> 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 cured 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 cured, they release practically no relevant amounts of volatile (harmful) substances into the room air, and can thus be used in living areas with no risk at all.