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On 14 March 2022 Germany's Federal Institute for Occupational Safety and Health (BAuA) reissued the technical rules for dangerous substances (TRGS) on national aspects when compiling safety data sheets (TRGS 220). This guidance document, which has not been updated since 2018, is based on the European Chemical Agency’s (ECHA) guidance on the compilation of safety data sheets.
3E Review
The vast majority of the changes made in this revision of TRGS 220 are minor in nature. Many of them focus on updating the footnotes to the guidance document—particularly the URLs referenced in the footnotes. In addition, references to newer or recently revised TRGSs— such as TRGS 505 on lead—have been updated, and several references to TRGS 910 on the risk-related concept of measures for activities involving carcinogenic hazardous substances have been expanded.
It should be noted that the BAuA usually provides an unofficial translation of this TRGS in English on its website. An official English-language version of the reissued TRGS 220 is not yet available.
3E Analysis
Although the TRGSs are technically guidelines, all corporate entities within Germany are expected to abide by these rules. As the TRGS 220 notes, all occupational exposure limit and biological imit values contained in the TRGSs are expected to be included on all safety data sheets (SDSs) associated with substances and preparations marketed in Germany. Values and limits indicated in other TRGSs mentioned in TRGS 220 also are expected to be included in all SDSs issued in Germany.
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