Cleaning products, toner and disinfectants count as hazardous substances under the German Hazardous Substances Ordinance as soon as they are classified as hazardous. In office and administrative businesses this almost always amounts to low risk under section 6 paragraph 13 GefStoffV. The assessment remains mandatory, but the register then falls away.
A hazardous substance under section 2 paragraph 1 GefStoffV is a substance or mixture that meets the criteria for classification as hazardous under Regulation (EC) No 1272/2008. What decides the question is the label, not a gut feeling. The duties quick-check sorts out which other office duties run alongside.
| Product | Typical classification | What follows |
|---|---|---|
| All-purpose and glass cleaners | usually not classified | no separate duty, still worth listing |
| Sanitary and drain cleaners | corrosive (H314) or irritant (H319) | risk assessment, operating instructions if used in-house |
| Alcohol-based hand and surface disinfection | highly flammable (H225) | limit stock quantities, keep ignition sources away |
| Toner cartridges and ink cartridges | usually not classified | no register entry, guidance for cartridge changes |
What actually counts as a hazardous substance
The decisive rule is Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures. A product is classified if its label carries a GHS pictogram, a signal word such as Warning or Danger, and at least one H statement. Where all three are missing, there is no hazardous substance.
Suppliers must provide a safety data sheet under Article 31 of Regulation (EC) No 1907/2006 for every substance and mixture classified as hazardous. In an office that sheet is the single most useful document: section 2 gives the classification, section 7 handling and storage, section 8 the protective measures.
In practice this means one walk through four rooms: the cleaning cupboard, the kitchen, the printer room and the first aid cabinet. Anything carrying a pictogram goes on the list. Everything else is a household product with no separate duty and should not be turned into a hazardous substance on paper.
The risk assessment applies to plain offices too
Under section 6 paragraph 1 sentence 1 GefStoffV the employer must establish, as part of the risk assessment, whether employees carry out activities involving hazardous substances or whether such substances can arise or be released. That finding does not depend on headcount and has to be made even where the answer turns out to be no.
The hazardous substances assessment is not a separate document alongside the assessment under section 5 ArbSchG but part of it. Under section 6 paragraph 11 GefStoffV only competent persons may carry it out. The ordinance names the occupational safety specialist and the company doctor explicitly as competent.
Substitution comes before every protective measure. Under section 7 paragraph 3 GefStoffV the employer must check first whether a hazardous substance can be replaced by a less hazardous one. In an office that is often trivial: a neutral cleaner does the same job as an acidic sanitary cleaner. Structure and minimum content are set out in Risk assessment in the office.
Low risk: when the register falls away
Low risk exists under section 6 paragraph 13 GefStoffV where four points together produce only a low level of risk: the hazardous properties of the substance, a small quantity in use, exposure that is low in both level and duration, and the working conditions overall. All four have to hold, not just one of them.
The consequence sits in section 6 paragraph 12 sentence 3 GefStoffV: the duty to keep a register does not apply where only low-risk activities are carried out. In a plain office that is the normal case. Dropping the register is not the same as doing nothing, though. It is a reasoned result that has to be readable in the risk assessment.
Where the threshold is crossed, for example because in-house staff regularly use a corrosive sanitary cleaner, a register under section 6 paragraph 12 GefStoffV becomes mandatory. It lists the name of the substance, its classification or hazardous properties, the quantity ranges in use, the work areas affected and a reference to the safety data sheet.
| Record | Legal basis | Required in an office? |
|---|---|---|
| Risk assessment including the hazardous substances finding | section 6 paragraph 1 GefStoffV, section 5 ArbSchG | always, even where the answer is no |
| Register with the five mandatory entries | section 6 paragraph 12 GefStoffV | only above the low-risk threshold |
| Operating instructions and annual training | section 14 paragraphs 1 and 2 GefStoffV | as soon as in-house staff use classified products |
Cleaning products: usually the contractor's job, not always
Cleaning products are the most common hazardous substance in an office and the most commonly misfiled one. Where a cleaning contractor is engaged, that contractor is the employer responsible for its own staff. Operating instructions, training and register sit where the products are actually used.
That does not end the client's responsibility. Under section 15 paragraph 1 GefStoffV the client may only engage firms with the necessary expertise and must inform them about hazards on site. Under section 15 paragraph 2 GefStoffV the risk assessments have to be coordinated where mutual hazards are possible, and the coordination must be documented.
As soon as in-house staff do the cleaning themselves, the full set of duties applies. Two rules from section 8 GefStoffV are the ones that fail in practice: under section 8 paragraph 5 GefStoffV hazardous substances must not be kept in containers whose shape or labelling invites confusion with food, and not stored next to food. Under section 8 paragraph 2 GefStoffV every decanted container needs labelling with sufficient information on the classification.
Toner and laser printers: better than their reputation
Toner dust from laser printers and copiers is not treated as a particular health risk at office workstations. The Federal Environment Ministry classifies laser printers as one of many sources of indoor air pollution and states that they do not represent a specific health hazard. The BAuA sees no reliable evidence of particular health risks from laser printers at work.
The benchmark for the assessment is the general dust limit value in TRGS 900: 1.25 milligrams per cubic metre for the respirable fraction and 10 milligrams per cubic metre for the inhalable fraction. Concentrations measured at office workstations sit well below that. A printer therefore triggers neither a register entry nor operating instructions.
One caveat remains. BG ETEM points out that direct contact with toner dust during a cartridge change or maintenance work can irritate eyes, skin or airways and that a sensitising effect is possible. Spilt toner should therefore be picked up damp or with a suitable vacuum, not wiped dry.
Anyone wanting to go further as a precaution puts high-volume printers in a room of their own and ensures an adequate air exchange rate. The Federal Environment Ministry recommends low-emission devices carrying the Blue Angel label. What applies to office ventilation anyway is set out in Indoor climate, ventilation and temperature.
Disinfectants: flammable, biocidal and quickly too much
Alcohol-based hand and surface disinfectants usually contain 70 to 80 percent ethanol and therefore carry the H statement H225 for highly flammable liquids and vapours. The relevant risk in an office is not toxicity but fire safety. Surface disinfectants are also biocidal products under Regulation (EU) No 528/2012.
The most effective measure is a quantity limit. Under section 8 paragraph 1 number 6 GefStoffV the quantity of a hazardous substance present at the workplace must be limited to what the work actually requires. One dispenser at the entrance and a refill bottle in the cupboard meet that. A box of twelve five-litre canisters beside the kitchen does not.
Many offices still hold stock from the years of generous supply. It is worth checking: expiry date, seal, location. Storage should be cool, tightly closed, away from ignition sources and separate from food. What to check in the first aid cabinet at the same time is covered in First aid in the office.
Operating instructions and training: the second record
As soon as in-house employees work with classified products, section 14 paragraph 1 GefStoffV requires written operating instructions. They name the hazardous substances present and the hazards involved, the precautions including hygiene rules and personal protective equipment, and the action to take in the event of malfunctions, accidents and emergencies.
TRGS 555 in its version of 20 April 2017 sets out the detail. Operating instructions are specific to the workplace, the activity and the substance, must be accessible in a form and language employees understand, and have to be updated at every material change, such as a new product or an updated safety data sheet. There is no fixed revision interval.
Training is the part with a fixed deadline. Under section 14 paragraph 2 GefStoffV it takes place before work begins and at least annually thereafter, verbally and specific to the workplace. Content and date must be recorded in writing and signed by the people trained. How this meshes with the other deadlines is set out in Safety training in the office.
A defensible record in six steps
In an office the whole exercise costs half a day and ends with two or three pages that hold up during an inspection. The order matters, because step four decides how much work the remaining steps involve.
- Take stock. Walk through the cleaning cupboard, kitchen, printer room and first aid cabinet and note every product whose label carries a GHS pictogram or an H statement.
- Request safety data sheets. Ask the supplier for the safety data sheet under Article 31 of Regulation (EC) No 1907/2006 for every classified product and file it digitally.
- Check for substitution. Under section 7 paragraph 3 GefStoffV, check whether a less hazardous product does the same job, for example a neutral cleaner instead of an acidic sanitary cleaner.
- Assess low risk. Work through the four criteria of section 6 paragraph 13 GefStoffV for each activity and record the result with its reasoning in the risk assessment.
- File a register or the reasoning. Where the risk is low, document the reasoning; otherwise keep a register under section 6 paragraph 12 GefStoffV with the five mandatory entries.
- Write operating instructions and train. Draw up operating instructions under section 14 paragraph 1 GefStoffV for work with classified products and train staff verbally at least once a year.
To review the state of the remaining paperwork at the same time, work through the office safety checklist.
Safety Club supports office and administrative businesses with exactly this exercise: an occupational safety specialist on site plus digital, audit-proof documentation that belongs to the business. We go through the specific case together in an initial consultation.
This article is general orientation and does not replace individual legal advice. What governs are the current versions of GefStoffV and ArbSchG, the Technical Rules for Hazardous Substances and the classification of the specific product in the manufacturer's safety data sheet.
