Hazardous substance list template: what is mandatory and what gaps templates typically leave

The Hazardous Substances Ordinance obliges employers in Section 6 Paragraph 12 GefStoffV to keep a list of all hazardous substances used in the company. The technical rule for hazardous substances TRGS 400 specifies the requirements for the risk assessment and refers to the list as its input variable. In the supervisory practice of the federal states, the list of hazardous substances is one of the first documents that the head of the occupational safety department or the responsible authority in accordance with Sections 19 ff. ArbSchG sees. If the list is missing or is obviously incomplete, a more comprehensive check follows regularly with the risk of higher fines according to § 26 GefStoffV of up to 50,000 euros per violation.

This article explains which mandatory fields a reliable hazardous substance list template contains, where the typical gaps in Excel templates lie, how the trace to the safety data sheet according to Regulation (EC) No. 1907/2006 (REACH) is kept and how The directory is automatically integrated into the risk assessment and instruction. CIVAC is a compliance platform and officer-as-a-service with workspace, 490 audit templates and appointment certificates. Licence the workspace for your internal representatives or have our representatives order it. You will learn how to set up a template so that it not only fulfils the formal obligation, but also remains maintainable in day-to-day business.

The Hazardous Substances Ordinance is the central occupational health and safety regulation for the handling of hazardous substances. Section 6 GefStoffV regulates information gathering and risk assessment. Paragraph 12 obliges the employer to keep a list of hazardous substances used in the company if a risk to employees cannot be ruled out. According to the Federal Institute for Occupational Safety and Health (BAuA), mere storage without use is already a sufficient requirement because use is possible at any time in the event of damage (fire, leakage, incorrect handling). In practice, every hazardous substance with a relevant storage quantity must be included in the list.

The mandatory content is listed in Section 6 Paragraph 12: name of the hazardous substance, classification or information on the dangerous properties, information on the quantity ranges and work areas used in the company as well as references to the safety data sheet. These four fields are the minimum that a template must contain. TRGS 400 supplements the link to risk assessment. Without a documented risk assessment, the directory is just a collection, not a control instrument. The professional associations regularly check exactly this connection in DGUV audits.

Hygiene, environmental and occupational safety obligations often overlap when it comes to hazardous substances. CIVAC offers the role Hazardous Substances Officer preconfigured in the workspace, with an appointment certificate, directory template, link to the risk assessment and reporting line to management. Although GSB status is not mandatory under German law, it is actually necessary in companies with more than a manageable portfolio of hazardous substances because the occupational safety specialist alone cannot provide ongoing care. The appointment certificate, signed, filed, verifiable. In companies with a mix of materials and cleaning agents, this can quickly amount to 50 to 200 entries, which can hardly be managed stably without digital support.

A reliable hazardous substance list template contains at least ten fields that are considered the minimum standard in supervisory practice. Firstly, the name of the hazardous substance with its trade name and chemical name. Secondly, the classification according to the CLP Regulation (Regulation (EC) No. 1272/2008) with hazard pictograms (GHS01 to GHS09), signal word, H-phrases and P-phrases. Thirdly, the CAS number for unique identification. Fourthly, the range of quantities used in the operation, usually as a size class from less than 1 kilogram to over 100 kilograms. Fifthly, the work area or areas in which the substance is used.

Sixthly, the intended use with a brief description of the working process. Seventh, reference to the safety data sheet with date and version number. Eighth, the storage location. Ninth, the associated risk assessment with date. Tenth, the status of the training of employees on this material. Templates that only show the first four fields formally fulfil the obligation under Section 6 Paragraph 12, but leave the audit trail incomplete. Supervisory officers regularly ask about fields 6 to 10 because they reflect actual practice and not just formal completeness.

CIVAC provides a template in the workspace with all ten mandatory fields, which also contains a link to the stored safety data sheet document, to the risk assessment and to the training register. One click on the entry opens the SDB, a second shows the risk assessment, and a third lists the instructed employees. Others run compliance like a filing cabinet. We run it like software. This link is practically impossible to create in Excel format, which is why even maintained Excel directories regularly lag behind their digital counterparts in audits. Audit preparation is significantly shortened by the links because the trace does not have to be reconstructed first.

The safety data sheet (SDB) is the information basis for the list of hazardous substances. In accordance with Article 31 of the REACH Regulation, it is provided by the manufacturer or distributor in the respective national language and contains 16 standardised sections, from the identification of the substance to hazard characteristics and first aid measures to disposal. The SDB is the input variable for inclusion in the directory and for the risk assessment. A missing or outdated version of the SDB is a classic reason for complaints during an audit. The supervisory authority specifically checks samples for the currently valid version.

SDS are regularly updated by the supplier, often several times a year. The update does not occur automatically at the recipient, but must be actively requested or downloaded via supplier portals. In practice, this leads to significant gaps because updates end up in email inboxes and downloads folders instead of being stored centrally. During an audit, there is no traceable versioning, and in the event of damage it remains unclear which version of the SDS was the basis for the risk assessment.

CIVAC maintains an SDS register with automatic version management in the workspace. When a new SDS is uploaded, the old version is archived, the entry in the list of hazardous substances is automatically updated and the associated risk assessment is marked for review. In the event of significant changes, such as new H phrases or new protective measures, the platform escalates to the hazardous substances officer and the occupational safety specialist. The auditor calls, the evidence is ready. A supplier request for a specific date can be answered in two clicks without having to search through historical emails. An official request about the version history of an SDB can also be immediately verified with the archived version.

TRGS 400 describes the risk assessment for activities involving hazardous substances and, alongside Section 6 GefStoffV, is the most important technical reference. It follows a seven-stage procedure: definition of the activity, information gathering, assessment of the risk, determination of protective measures, effectiveness testing, documentation and updating. The list of hazardous substances is the input for levels 1 and 2. Without a list, the risk assessment is incomplete in the strict sense because it is not clear which substances are used in which activities.

A substantial risk assessment requires more than just listing substances. It describes the workflow, the routes of exposure (inhalation, dermal, oral), the frequency and duration of exposure, the protective measures taken according to the STOP principle (substitution, technical, organisational, personal) and the effectiveness test. For very toxic, carcinogenic, mutagenic or reproductively toxic substances (CMR substances according to Section 10 GefStoffV), additional substitution tests are required, which must be verified regularly. In case of doubt, the supervisory authority checks the substitution documentation as a first step.

In the CIVAC workspace, every entry in the list of hazardous substances is linked to the associated risk assessment. If a new substance is added, the platform automatically requests the risk assessment. If an existing substance is used in a new work area, the platform checks whether the existing risk assessment covers this area. CMR substances are marked separately and have increased requirements. Audit-proof, documented, § 6 GefStoffV-proof. When audited by the professional association or the supervisory authority, the complete path from the substance to the risk assessment can be shown in seconds. Substitution tests for CMR substances are versioned with date, reason and result so that older decisions remain traceable and the supervisory authority recognises the testing process as a regular activity.

The list of hazardous substances is not an end in itself. Its content is incorporated into the instruction of employees in accordance with Section 14 GefStoffV. The instruction takes place before working with hazardous substances for the first time and at least annually. It includes the content and meaning of the SDB, the risk assessment, the protective measures and what to do in the event of damage. The instruction must be carried out orally or in writing and documented in writing with the date, content and signature. An electronic signature is permissible if the employee's identity can be established beyond doubt.

In practice, the instruction is often carried out as a collective appointment in which all hazardous substances are dealt with in one block. This is organizationally efficient, but has the disadvantage that the instruction is not material-specific and can be assessed as superficial in the audit. Reliable is instruction that specifically goes through at least the hazardous substances used in the employee's work area, with reference to the SDB, risk assessment and protective measures. Seasonal workers and temporary workers who come into contact with hazardous substances need the full instruction like permanent employees, which is often overlooked and leads to complaints in the audit.

CIVAC keeps the instruction register in the workspace with individual deadlines for each employee and per hazardous substance. Employees with access to CMR substances receive extended instruction with precautionary measures in accordance with ArbMedVV. The platform reminds you 30 days before expiry, escalates to the reporting line 7 days before expiry and, upon request, exports a training pass for each employee. During an audit by the professional association, the question of who was instructed, when and what can be answered in seconds, instead of hours of research through folders and email logs. The examiner can tell from the trace whether the instruction is actually being practiced or is just a mandatory artifact.

In addition to the list, the Hazardous Substances Ordinance requires safe storage of hazardous substances in Section 8 Paragraph 7. TRGS 510 specifies the requirements for storage quantities, bans on joint storage and structural protective measures. The obligation to keep a register of hazardous substances with quantities does not exist in the narrower sense from Section 6 GefStoffV, but actually arises from TRGS 510 because the maximum permissible quantities per storage class cannot be monitored without an overview of quantities. A register is therefore standard in practice, at least in companies with relevant storage quantities.

The storage classes follow the recommendations of the Chemical Industry Association (VCI) and divide hazardous substances into ten classes (LGK 1 to 13 with gaps). The TRGS 510 storage table shows which classes can be stored together, which can only be stored separately and which cannot be stored together at all. Violations of collective storage are a recurring theme in audit reports from professional associations and regulatory authorities because the assessment is different if a fire breaks out or a reaction can arise from contact between two substances. In the event of damage, the management's liability is significantly increased.

CIVAC connects the list of hazardous substances with the storage register by providing each entry with the storage location, storage class and maximum storage quantity. When a new substance is added, the platform automatically checks whether co-storage is permitted at the specified location and alerts in the event of conflicts. If the quantity changes, the excess of the LGK limit values ​​is detected and reported to the hazardous substances officer. Anyone who works with an Excel template carries out this check manually, which is difficult to do with larger product ranges and is regularly omitted in day-to-day business. The platform closes this gap without any additional effort for the agent.

Excel templates are the most common form of hazardous substance lists in German medium-sized companies. They are quick to set up, cheap to buy and seemingly uncomplicated. However, audits reveal recurring weaknesses that are not due to Excel as a tool, but rather to the lack of a link to the other mandatory documents. Firstly, versioning is regularly missing. Who changed which entry and when cannot be traced in the audit. Secondly, there are no links to the SDB documents, so that the directory and the SDB are managed separately and quickly diverge.

Thirdly, there is no link to the risk assessment and instruction. An entry in the table does not indicate which risk assessment applies and whether the employees have been trained. Fourth, there is no guided input to prevent input errors. A forgotten mandatory field is not recognised in Excel; in a system the entry remains open until the mandatory fields are complete. Fifth, an Excel file is not audit-proof. Each change overwrites the previous one without the history being traceable. In the event of damage, this can lead to significant problems with evidence.

CIVAC does not replace the Excel template with a more complex system, but with a system that structurally closes the five weak points. Versioning, SDB linking, GBU linking, mandatory field check and audit-proof history are preset in the workspace and cannot be switched off. The input effort for the hazardous substances officer is no higher than in Excel, and often even lower because many fields are automatically taken over from the stored SDB. Others run compliance like a filing cabinet. We run it like software. A migration from an existing Excel template is carried out using an import assistant that maps the data fields to the CIVAC structure and marks missing mandatory fields.

A hazardous substances inventory is only as good as its maintenance. Section 6 Paragraph 12 GefStoffV requires that the list is up to date. The regulation leaves open what current means. Regulatory practice typically requires an update whenever the range changes and a full review at least once a year. In companies with frequent product changes (laboratories, workshops, cleaning service providers), this means continuous care. In companies with a stable range (paint shops, classic production), an annual review with ad hoc updates in the event of changes to the range is sufficient.

In practice, maintenance rarely fails due to will, often due to organisation. Anyone who does not link the procurement process with inclusion in the directory runs the risk of new hazardous substances appearing in the company without being included in the directory. The result is an incomplete list, which is criticized as a gap in the audit. A simple organisational solution is the four-eye rule: no ordering of a new hazardous substance without submitting the SDS and listing it in the directory. This step can be integrated into digital procurement systems.

CIVAC maintains a procurement path in the workspace that forces inclusion in the directory before the order is released. Purchasing stores the SDS, the hazardous substances officer checks and approves the entry, only then is the order released. During annual reviews, the platform automatically initiates a review of each entry, with a receipt from the person responsible. Deadline begins as soon as we become aware of it. Outdated SDSs are flagged, missing training is escalated, and unused materials are suggested for disposal. The directory therefore remains a living document, not a mandatory artifact that has been created once and then neglected and is only briefly updated during the audit.

A template alone does not create compliance. It is a format into which content must be entered. Reliable compliance only arises when the format is embedded in an organisation that systematically manages the input, maintenance and evaluation. This is exactly what CIVAC is designed for. CIVAC is a compliance platform and officer-as-a-service with workspace, 490 audit templates, appointment certificates, reporting line and EU data residency. Licence the workspace for your internal representatives or have our representatives order it. Hazardous substances officers receive a preconfigured role with directory, SDB, GBU, instruction and storage logic in one system.

The model is tailored to medium-sized businesses. Anyone who has an experienced hazardous materials officer in-house licences the workspace and uses the templates and links as a tool. If you do not have a GSB or need a temporary solution in the event of a change in personnel, appoint a CIVAC representative with documented insurance and a fixed 2-working day SLA. In both variants, the document track is identical and can be accessed immediately in the audit. The auditor calls, the evidence is ready. A combination is also possible, such as internal GSB with external representation during vacation and illness periods.

If you want to have an existing Excel directory checked for audit integrity or want to set up a digital hazardous substances directory from scratch, we start with a structured initial recording. Turn reading into an assignment. Write to info@civac.de or use the contact form to arrange an initial assessment. Within two working days you will receive a list of gaps and a suggestion as to which variant (workspace licence or officer-as-a-service) suits your organisation. The result is a directory that supports the audit and relieves the burden in day-to-day business instead of creating effort.