Warning

Danger

The GHS Column Model 2020

An aid to substitute assessment
 1 Risk 2a A
 cute health hazards 2b Chronic health hazards 3 Environmental hazards 1)
(single exposure) (repeated exposure)

very high • Acutely toxic substances/mixtures, Cat. 1 or 2 • Carcinogenic substances/ • Substances/mixtures

(H300, H310, H330) mixtures, Cat. 1A or 1B acutely hazardous to the
• Substances/mixtures that in contact with acids (H350, H350i) aquatic environment,
liberate highly toxic gases (EUH032) • Carcinogenc activities or Cat. 1 (H400)
processes according to TRGS 906 • Substances/mixtures
• Substances/mixtures mutagenic chronically hazardous to
to germ cells, Cat. 1A or 1B the aquatic environment,
(H340) Cat. 1 (H410)
• Substances/mixtures of
German Water Hazard
Class WGK 3
• PBT substances
• vPvB substances

high • Acutely toxc substances/mixtures, Cat. 3 • Substances/mixtures toxic to • Substances/mixtures

(H301, H311, H331) reproduction, Cat. 1A or 1B chronically hazardous to
• Substances/mixtures toxic in contact with eyes (H360, H360F, H360D, H360FD, the aquatic environment,
(EUH070) H360Fd, H360Df) Cat. 2 (H411)
• Substances/mixtures that in contact with water • Carcinogenic substances/ • Substances hazardous to
or acids liberate toxic gases (EUH029, EUH031) mixtures, Cat. 2 (H351) the ozone layer (H420)
• Substances/mixtures with specific target organ • Substances/mixtures mutagenic
toxicity (single exposure), Cat. 1: Organ damage to germ cells, Cat. 2 (H341)
(H370) • Substances/mixtures with speci-
• Skin sensitising substances/mixtures fic target organ toxicity (repeated
(H317, Sh) exposure), Cat. 1: Organ damage
• Substances/mixtures that sensitise the (H372)
respiratory organs (H334, Sa)
• Substances/mixtures corrosive to the skin,
Cat. 1, 1A (H314)
medium • Acutely toxic substances/mixtures, Cat. 4 • Substances/mixtures toxic to • Substances/mixtures
(H302, H312, H332) reproduction, Cat. 2 chronically hazardous to
• Substances/mixtures with specific target organ (H361, H361f, H361d, H361fd) the aquatic environment,
toxicity (single exposure), Cat. 2: Possible • Substances/mixtures with speci- Cat. 3 (H412)
organ damage (H371) fic target organ toxicity (repeated • Substances/mixtures of
• Substances/mixtures corrosive to the skin, exposure), Cat. 2: Possible organ German Water Hazard
Cat. 1B, 1C (H314) damage (H373) Class WGK 2
• Eye-damaging substances/mixtures (H318) • Substances/mixtures that can
• Substances/mixtures with corrosive effect on harm babies via their mothers’
respiratory organs (EUH071) milk (H362)
• Nontoxic gases that can cause suffocation by
displacing air (e.g. nitrogen)
low • Skin-irritant substances/mixtures (H315) • Substances chronically harmful in • Substances/mixtures
• Eye-irritant substances/mixtures (H319) other ways (no H-phrase, but still chronically hazardous to
• Skin damage when working in moisture a hazardous substance!) the aquatic environment,
• Substances/mixtures with a risk of aspiration Cat. 4 (H413)
(H304) • Substances/mixtures of
• Skin-damaging substances/mixtures (EUH066) German Water Hazard
• Substances/mixtures with specific target organ Class WGK 1
toxicity (single exposure), Cat. 3: irritation of
the respiratory organs (H335)
• Substances/mixtures with specific target organ
toxicity (single exposure), Cat. 3: drowsiness,
dizziness (H336)
negligible • Safe substances on the basis of experience (e.g. water, sugar, paraffin and the like) • Substances/mixtures not
hazardous to the aquatic
environment
(nwg)
1)
T he water hazard class is only referred to as an assessment criterion for substances/mixtures that have not (yet) been
classified in terms of their environmental hazard properties.
4 Physico-chemical effects 5 Hazards from release beha- 6 Process-related hazards
(fire, explosion, corrosion et al.) 2) viour
H-phrases marked in blue occur several times.
• Unstable explosive substances/mixtures (H200) • Gases • Open processing
• Explosive substances/mixtures/articles, divisions 1.1 (H201), • Liquids with a vapour pressure • Possibility of direct skin
1.2 (H202), 1.3 (H203), 1.4 (H204), 1.5 (H205) and > 250 hPa (mbar) contact
1.6 (without H-phrase) (e.g. dichloromethane) • Large-area application
• Flammable gases, Cat. 1A (H220, H230, H231, H232) and • Dust-generating solids • Process index 4 according
Cat. 1B and 2 (H221) • Aerosols to TRGS 500 (open design
• Pyrophoric gases (H232) or partially open design,
• Flammable liquids, Cat. 1 (H224) natural ventilation)
• Self-reactive substances/mixtures, Types A (H240) and B
(H241)
• Organic peroxides, Types A (H240) and B (H241)
• Pyrophoric liquids or solids, Cat. 1 (H250)
• Substances/mixtures which in contact with water emit
flammable gases, Cat. 1 (H260)
• Oxidising liquids or solids, Cat. 1 (H271)
• Aerosols, Cat. 1 (H222 and H229) • Liquids with a vapour pressure • Process index 2 according
• Flammable liquids, Cat. 2 (H225) 50 ... 250 hPa (mbar) (e.g. to TRGS 500 (partially
• Flammable solids, Cat. 1 (H228) methanol) open design, process-
• Self-reactive substances/mixtures, Types C and D (H242) related opening with
• Organic peroxides Types C and D (H242) simple extraction, open
• Self-heating substances/mixtures Cat. 1 (H251) with simple extraction)
• Substances/mixtures which in contact with water emit
flammable gases, Cat. 2 (H261)
• Oxidising gases, Cat. 1 (H270)
• Oxidising liquids or solids, Cat. 2 (H272)
• Desensitised explosives, Cat. 1 (H206) and Cat. 2 (H207)
• Substances/mixtures with certain properties
(EUH001, EUH014, EUH018, EUH019, EUH044)

• Aerosols, Cat. 2 (H223 and H229) • Liquids with a vapour ­pressure • Closed processing with
• Flammable liquids, Cat. 3 (H226) 10 ... 50 hPa (mbar), with possibilities of exposure,
• Flammable solids, Cat. 2 (H228) the exception of water (e.g. e.g. during filling, samp-
• Self-reactive substances/mixtures, Types E and F (H242) toluene) ling or cleaning
• Organic peroxides, Types E and F (H242) • Process index 1 according
• Self-heating substances/mixtures, Cat. 2 (H252) to TRGS 500 (closed
• Substances/mixtures which in contact with water emit design, tightness not
flammable gases, Cat. 3 (H261) ensured, partially open
• Oxidising liquids or solids, Cat. 3 (H272) design with effective
• Gases under pressure (H280, H281) extraction)
• Corrosive to metals (H290)
• Desensitised explosives, Cat. 3 (H207) and Cat. 4 (H208)
• Aerosols, Cat. 3 (H229 without H222, H223) • Liquids with a vapour pressure • Process index 0,5
• Not readily flammable substances/mixtures 2 ... 10 hPa (mbar) according to TRGS 500
(flash point > 60 ... 100 °C, no H-phrase) (e.g. xylene) (closed design, tightness
• Self-reactive substances/mixtures, Type G (no H-phrase) ensured, partially closed
• Organic peroxides, Type G (no H-phrase) design with integrated
extraction, partially open
design with highly effec-
tive extraction)

• Non-combustible or only not at all readily flammable • Liquids with a vapour pressure • Process index 0,25
substances/mixtures < 2 hPa (mbar) according to TRGS 500
(flash point of liquids > 100 °C, no H-phrase) (e.g. ethylene glycol)
• Non-dust-generating solids
2)
Due to their specific problems, substances with a dust explosion hazard must be tested in individual cases by experts and
therefore are not assigned to any below-mentioned hazard class.
Notes on Evaluating Substitute
Substances by the Column Model
Are recommendations already 2. Refer to the Material Safety Data Sheet for the
available on substitute substances? requisite information. There you will find the
hazard classes, H-phrases in Chapter 2 and the
Answering the question of which product has the German Water Hazard Classes in Chapter 15 of
lower health risk is difficult. Recommendations for a the Material Safety Data Sheet and information
series of questions regarding substitute substances on the exposure potential in Chapter 9. You can
can be applied directly, such as: also find additional information in Chapters 3,
5, 11, and 12. Check the presence of supplemen-
• Technical Rules for Hazardous Substances in the tal information for classification as skin sensiti-
600 series, www.baua.de/EN/Service/Legisla- zing, respiratory sensitizing, carcinogenic, germ
tive-texts-and-technical-rules/Rules/TRGS/TRGS. cell mutagenic or toxic for reproduction sub­
html stance by the German Committee on Hazardous
Substances (AGS) in the TRGS 900, 905 or 907.
• National governmental or accident insurance
recommendations, 3. Note the information you find for the respective
product on the copy of the Column Model table.
• Industry guidelines. Note the procedure used in the last column.

Procedures 4. Now compare the columns below separately for

each product to be evaluated:
If there are no recommendations available to help
you solve your substitute substance problem, the –– acute and chronic health hazards
Column Model can help you make a quick compari- –– environmental hazards
son of substances and mixtures. To do so, you only –– physico-chemical effects
need the brief information found in the Material –– hazards from release behaviour
Safety Data Sheet or on the package labelling. –– hazards caused by procedures

Proceed as follows:

1. Copy the Column Model table once for each

product and note each product’s name on
a different copy.

Please bear in mind:

• Comparisons are only to be made within a • Also mixtures are assessed only on the basis of
column, and never within a line. The columns their labelling with respect to their acute and
for “acute health hazards” and “chronic health chronic health hazards.
hazards” count as one single column.
Interpretation of the results

On the basis of the outcome of the risk assess- columns 2 to 4, but the probability of a hazard
ment, a product must be substituted if it reduces becoming effective according to columns 5 and
the risk to employees. A risk exists if employees are 6 is considerably greater, this substance may not
capable of spatially and temporally encountering a be suitable as a substitute substance.
hazard source (hazardous substance). The hazards • With the Column Model, mixtures are not
inherent in hazardous substances have to first assessed on the basis of their components. The
become effective (e.g. through exposure, fire, explo- practicality of this procedure is obtained at the
sion) in order to become relevant risks. expense of certain disadvantages resulting, for
instance, from the existence of classification
The columns 2, 3 and 4 constitute hazards. The boundaries for mixtures.
columns 5 and 6 are to be interpreted as „hazards • Document your decisions in an appropriate
becoming effective”. manner (e.g. by attaching the copies described
above).
• If the potential substitute product rates better
in all five columns than the product in use, the Technical remarks
substitution problem is solved.
• It will mostly be the case that the potential • Substances, mixtures and articles of the hazard
substitute product rates better in some columns, class “Explosives”, which are not classified as an
but worse in one or two to other columns. This unstable explosive: All divisions of this class are
obliges you to assess which potential hazards – listed in the “Very high risk” line, as the divisions
in other words, which columns – play a larger role do not include any gradation of risk on the basis
in your particular situation. If, for example, sour- of their intrinsic properties, but subdivides sub­
ces of combustion cannot be excluded in your stances, mixtures and articles in their packaged
production processes, then the fire and explosion form. If explosives are unpackaged, the risk from
characteristics together with the exposure poten- the substances/mixtures/articles in division 1.5
tial will have the greater weight. If your produc- is in principle the same as that in division 1.1. A
tion methods result in large quantities of waste generally applicable statement on recommended
by-products, then the environmental hazards will substitutes cannot therefore be made within this
be emphasized. hazard class.
• Minor differences in the hazard classification only • Flammable gases: Categories 1A, 1B and 2 of the
justify the introduction of a substitute substance “Flammable gases” hazard category are listed
if the data available for the substitute substance together in the “Very high risk” line. Flammable
is similar in quantity and quality to that of the gases of Categories 1A, 1B and 2 have an explo-
substance being substituted. sion range and the same safety measures have
• In the event of opposing reasons, the difference to be taken. Unlike flammable liquids, Category 2
in a single hazard classification may not be flammable gases should not be considered less
sufficient for the introduction of a substitute hazardous, and these substances/mixtures have
substance. been given the highest risk classification.
• Columns 2 to 4 (hazards) and 5 and 6 (hazards
becoming effective) must always be assessed
collectively. If, for instance, a potential substitute
substance is only a minor hazard according to
Conditions for Using the Column Model according to
the German Hazardous Substances Ordinance
What is the problem? 2. If no information is available on tests of skin cor-
rosion/irritation, then the substance or mixture
A supposedly less dangerous product can be more has to be categorized at least as a “low risk” in
dangerous in reality; yet the concrete hazardous the column “acute health hazards” (in terms of a
characteristics may not have been tested. For the “skin irritant”, H315).
risk assessment, the Hazardous Substances Ordi-
nance therefore states: “If no test data or suitable 3. If no information is available on tests for skin
sound information is available on the acutely toxic, sensitisation, then the substance or mixture has
irritant, skin-sensitizing or germ cell mutagenic to be categorized at least as a “high risk” in the
effects or on the specifiv target organ toxicity after column “acute health hazards” (in terms of a
repeated exposure, the substances or mixtures are “skin sensitizer, category 1”, H317).
to be treated in the risk assessment as substances
with hazard class Acute Toxicity (oral, dermal and 4. If no information is available on tests for germ
inhalative) Category 3, Skin Corrosion/Irritation cell mutagenicity, then the substance or mixture
Category 2, Skin Sensitisation Category 1, Germ Cell has to be categorized at least as a “high risk” in
Mutagenicity Category 2 or Specific Target Organ the column “chronic health hazards” (in terms of
Toxicity after repeated exposure (STOT RE) Category a “germ cell mutagenic substance, category 2”,
2.” H341).

What effect does this have on the Column Model? 5. If no information is available on tests for specific
target organ toxicity after repeated exposure,
If the Material Safety Data Sheet gives details on then the substance or mixture has to be catego-
none or only a few required tests and if an inquiry rized at least as a “medium risk” in the column
with the manufacturer has not yielded any infor- “chronic health hazards” (in terms of “possible
mation, then it must be assumed when using the organ damage” H373).
Column Model that the respective characteristics
are present. The most consistent procedure is the one in which
those products lacking information with regard to
What does this mean specifically? the five basic tests described here are not even
considered as potential substitutes, or in which
1. If no information is available on tests for acute products lacking such information are replaced by
toxicity, then the substance or mixture has to others that are backed by studies and tests.
be categorized at least as a “high risk” in the
column “acute health hazards” (in terms of
“acute toxic substances/mixtures, category 3“,
H301, H311, H331).
The Legal Basis
for Finding Substitutes
The German Hazardous Substances Ordinance
demands, among other things, the following from
the em­ployer:

Article 6 (1) of the German Hazardous Substances

Ordinance:

When conducting a risk assessment as part of the

assessment of working conditions in accordance
with Article 5 of the Occupational Safety & Health
Act, the employer has to ascertain whether emplo-
yees are engaged in activities with hazardous sub­
stances or whether hazardous substances may arise
or be released during such activities. If this is the
case, he must assess all the resultant risks to the
health and safety of employees from the following
points of view: … 4. Scope for substitution …
Edited by:
Article  7 (3) of the German Hazardous Substances Dr. Thomas Smola
Ordinance: Institut für Arbeitsschutz der Deutschen
Gesetzlichen Unfallversicherung (IFA)
On the basis of the outcome of the substitution test Alte Heerstr. 111
in accordance with Article 6, Section 1, Sentence 2, 53757 Sankt Augustin
Number 4, the employer must give priority to sub­ Germany
stitution. He must replace hazardous substances or Phone: ++49 (0)30 13001-3140
processes with substances, mixtures, products or Fax: ++49 (0)30 13001-38001
processes that are not hazardous or are less hazar- Internet: www.dguv.de/ifa
dous to the health and safety of employees under
the associated conditions of use. With participation of:
Dr. Wolfgang Pflaumbaum (IFA)
Dr. Eberhard Nies (IFA)
Prof. Dr. Herbert Bender
(Gefahrstoff Consulting Compliance)
Dr. Petra Schulte
(BAM Bundesanstalt für
Materialforschung und -prüfung)

– January 2020 –
Deutsche Gesetzliche
Unfallversicherung e. V. (DGUV)

Glinkastr. 40
10117 Berlin
Germany
Phone: ++49 (0)30 288763800
Fax: ++49 (0)30 288763808
E-mail: info@dguv.de
Internet: www.dguv.de