A cleaning cupboard with unlabelled sprays, a maintenance shelf with oils and aerosols, or a warehouse store holding batteries and solvents can quickly become a compliance issue. Hazardous substances register requirements apply whenever hazardous substances are used in your German workplace, not only in laboratories or industrial plants. If you cannot show what substances are present, where they are used and how people are protected, it becomes much harder to demonstrate that your safety arrangements are under control.
What is a hazardous substances register?
A hazardous substances register (Gefahrstoffverzeichnis) is a documented inventory of hazardous substances and mixtures used in the workplace. It is required under the Ordinance on Hazardous Substances (GefStoffV) and is a core part of hazardous substances management.
The register is not a folder of safety data sheets and it is not the same as a risk assessment (Gefährdungsbeurteilung). It is the working overview that tells you what is on site, in which quantities, in which work areas and with which hazardous properties. Safety data sheets provide supporting technical information. The risk assessment considers the actual work, exposure routes and controls needed.
For a small office, the register may be short and focus on cleaning products, printer chemicals, batteries or maintenance supplies. A logistics operation may also need to record forklift battery chemicals, fuels, lubricants, aerosols, adhesives and products damaged in transit. What matters is the real use of substances at your site, not the size of the business alone.
Hazardous substances register requirements in Germany
Under GefStoffV, your register should cover all hazardous substances used at the workplace. At a minimum, each entry needs the substance or product designation, its classification of hazardous properties, the quantity used, and the work areas in which it is used.
In practice, a useful register also records the product manufacturer or supplier, the latest safety data sheet, relevant hazard statements, storage location and the internal person responsible for keeping the record current. These additional fields make the register more useful during an inspection and, more importantly, during day-to-day safety decisions.
The classification should come from the current label and safety data sheet. Do not guess from a product name or assume that a familiar household-style product is harmless. Products labelled as irritant, corrosive, flammable, toxic, environmentally hazardous or hazardous to health may all need to be included. Certain substances can also be hazardous even where a label is not obvious, for example dusts generated during work, welding fumes, wood dust or diesel engine emissions.
Where substances present only a low hazard, the law allows a grouped entry in some cases. This is a practical simplification, not permission to ignore the products. Grouping is only sensible where the substances, hazards and use conditions are genuinely comparable. A mixed collection of aerosols, degreasers and adhesives should not be placed into one vague line called “chemicals”.
Keep safety data sheets available
A safety data sheet should be available for each registered product where one is required. Suppliers normally provide it, but your business should actively request the current version when it is missing. Keep the sheets accessible to the people who manage the risk assessment and to employees who may need emergency information.
A safety data sheet alone does not prove that workplace controls are suitable. It describes the product in general terms. Your workplace risk assessment must consider how your staff actually use it: whether a cleaner decants it into a spray bottle, whether an operative works in a poorly ventilated area, or whether a maintenance worker handles it during a night shift without immediate supervision.
Build the register from a site inspection
The most common failure is building the register from purchase records alone. Procurement records miss old containers, samples, contractor supplies, products kept in vehicles and chemicals bought locally by a team lead. The strongest starting point is a walk-through of every area where substances are stored, used, generated or disposed of.
Check cleaning cupboards, workshops, plant rooms, goods-in areas, production lines, laboratories, warehouses, offices, waste areas and company vehicles. Speak with the people doing the work. They will often identify the product that is used “only occasionally” but creates the highest exposure, such as a descaler, solvent cleaner or repair adhesive.
During the inspection, confirm that every container is labelled. Decanted substances require suitable workplace labelling too. An unmarked bottle is not just an inventory problem. It creates avoidable risks during use, first aid and fire response.
Connect the register to your risk assessment
Every register entry should lead into a proportionate risk assessment. The Occupational Health and Safety Act (Arbeitsschutzgesetz, ArbSchG) requires employers to assess workplace risks, while GefStoffV sets more specific duties for hazardous substances.
The assessment should establish whether substitution is possible. Can a solvent-based cleaner be replaced with a lower-hazard alternative? Can a ready-to-use product remove the need for decanting? Can a process be enclosed or moved to a ventilated area? Substitution is often the first question, before relying on gloves or masks.
If a hazardous substance remains necessary, define controls in the right order. Technical and organisational controls should come before personal protective equipment. This may mean local extraction, closed containers, restricted access, defined storage, spill arrangements and clear work instructions. Gloves, eye protection or respiratory protective equipment may still be required, but they should not be the only measure where exposure can be controlled at source.
For substances that are carcinogenic, mutagenic or toxic to reproduction, duties can become more demanding. Exposure must be reduced as far as possible, and additional documentation, health surveillance and retention requirements may apply depending on the substance and work activity. The Technical Rules for Hazardous Substances (TRGS) help explain expected control measures in specific situations. This is a point where competent specialist advice is particularly valuable.
Update the register when work changes
A register created for an opening inspection will become inaccurate unless someone owns it. Update it when a new product arrives, a formulation changes, a supplier issues a revised safety data sheet, a substance is removed, or a work process moves to another area.
Changes in quantity matter too. A small container used occasionally may create a different storage and fire risk when several cartons are kept on site. The same applies when your business opens a new site, introduces a workshop, starts handling returns or expands warehouse operations.
Set a routine review date, usually alongside your wider occupational safety review. However, do not wait for the annual review if a product or process changes. The register should reflect the workplace your people enter today.
Make the information usable for employees
Employees do not need to read every safety data sheet before starting work, but they do need clear instruction on the substances they handle. Training should cover the hazards, safe handling steps, required protective equipment, storage rules, what to do with a spill and what to do in an emergency.
Written operating instructions are often required for hazardous activities and must be understandable to the people carrying out the work. For international teams, that may mean providing instruction in a language employees genuinely understand. A signed attendance list is useful evidence, but it is not a substitute for practical, task-specific instruction.
Your occupational safety specialist (Fachkraft für Arbeitssicherheit, or SiFa) can support the assessment and preventive controls. A company doctor (Betriebsarzt) should be involved where occupational health questions, health surveillance or exposure-related precautions arise. Together, they help turn a static register into a functioning safety system.
A practical three-step route to compliance
Start by identifying every hazardous substance through a structured site inspection and collecting the relevant labels and safety data sheets. Next, create or update the register, then link each entry to a suitable risk assessment, storage arrangement and operating instruction. Finally, train the affected employees, appoint a clear internal owner and review the documents whenever work changes.
If you have received a deficiency notice from the accident insurance institution (Berufsgenossenschaft, or BG), avoid treating the register as a quick paperwork exercise. Inspectors will usually look beyond the document to see whether labels, storage, training and workplace controls match what it says. Captain Safety can help you assess the site, organise the documentation and address the practical actions behind it.
A well-maintained register is not glamorous paperwork, but it gives you a reliable answer when someone asks a simple, critical question: what are our people exposed to, and how are we protecting them?