The four documents
- Gefährdungsbeurteilung (risk assessment documentation), one per substance: documented before the work starts, regardless of the number of employees (§ 6(8) GefStoffV), in the eleven points of TRGS 400 No. 8(3), or the short form for low hazard (No. 8(6)), with the hazards sorted into inhalation, skin and physico-chemical as § 6(6) asks;
- Gefahrstoffverzeichnis (register of hazardous substances, also called Gefahrstoffkataster): the name, the classification, the quantity ranges used, the work areas where workers may be exposed and a reference to the safety data sheet (§ 6(12)), plus its version and date;
- Betriebsanweisung (written operating instruction), one per substance and language: § 14(1), under the seven headings of TRGS 555 No. 3.2.1, with the pictograms, the signal word and the hazard and precautionary statements in the wording of that language's version of the CLP Regulation;
- Unterweisungsnachweis (instruction record): the oral instruction before work starts and at least once a year, its content and date recorded and confirmed by the signature of those instructed (§ 14(2)), with the latest date of the next one.
What the kit fills in, and what stays TO COMPLETE
From the classification you copy from section 2 of the safety data sheet: pictograms, signal word, the H and EUH statements in the official wording, and the precautionary statements you tick, sorted under headings 4 to 7 of the Betriebsanweisung. Your workplace facts are yours to enter: work areas, quantities, the glove and respirator models in use, technical and organisational measures, first aiders and emergency numbers, the result of the substitution check. Anything not entered prints TO COMPLETE with the reason. Text you type is printed only in the language you typed it in; it is never translated.
Codes not in the CLP lists, and two categories of one hazard class, are refused. A claim of low hazard (geringe Gefährdung) needs all four reasons (quantity, frequency, exposure, properties) and is refused for H314 when skin contact is not excluded, for flammable liquids when an explosive atmosphere is not excluded, and for work in confined spaces (TRGS 400 No. 6.2(5)). Where section 11 of the safety data sheet says only "no data" for an endpoint, the classification § 6(14) prescribes is printed. Substances that are carcinogenic, mutagenic or toxic for reproduction in category 1A or 1B, and flammable ones, are flagged with the duties the kit does not cover.
No size exemption, and the fines
The ordinance applies to every employer whose workers handle hazardous substances, a small workshop included: § 6(8) asks for the documented assessment regardless of the number of employees, and § 7(1) forbids the work before it. A risk assessment, register, Betriebsanweisung or instruction that is missing or incomplete is an administrative offence under § 22(1) GefStoffV with § 26(1) No. 8(b) of the Chemicals Act (ChemG), with a fine of up to EUR 50,000 (§ 26(3) ChemG).
Who uses it
Any business whose staff work with products that carry a hazard pictogram, for example a car repair workshop (Kfz-Werkstatt) with brake cleaner and paints, a cleaning company (Reinigungsbetrieb), a hair salon (Friseursalon) with dyes and bleaches, a dental practice (Zahnarztpraxis) with disinfectants, a laboratory or a small manufacturer.
The free tools of the Berufsgenossenschaften
WINGIS (BG BAU) and GisChem (BG RCI and BGHM) are free and also produce operating instructions, registers and assessments, built around their member sectors' products. This kit works for any sector, takes the statements from each language version of the CLP Regulation, needs no account, writes all four documents from one entry, and nothing you type leaves your browser.
What the kit does not do
It does not classify a substance, choose protective equipment, measures, quantities or work areas, or translate what you type. It does not replace the competent (fachkundig) person of § 6(11): if you lack that knowledge yourself, have the assessment advised, for example by your occupational safety specialist (Fachkraft für Arbeitssicherheit) or company doctor (Betriebsarzt). It does not write the explosion protection document (Explosionsschutzdokument, § 6(9)), the exposure register for CMR substances (§ 10a) or any workplace measurement, and it does not cover machine operating instructions, biological agents or asbestos. Generated instructions must be adapted to the workplace (TRGS 555 No. 3.1(12)), and the employer stays responsible. For a CLP label on its own, use the free CLP label generator.
Nothing you type leaves your browser; the files are built on your device. Templates, not legal advice.
Sources
- Gefahrstoffverordnung (GefStoffV), as last amended on 17 December 2025 (gesetze-im-internet.de)
- Chemikaliengesetz (ChemG), § 26: administrative offences
- BAuA: TRGS 555 Betriebsanweisung und Information der Beschäftigten (February 2017)
- BAuA: TRGS 400 Gefährdungsbeurteilung für Tätigkeiten mit Gefahrstoffen (July 2017)
- Regulation (EC) No 1272/2008 (CLP), consolidated text of 1 July 2026 (EUR-Lex)
- BG BAU: WINGIS online
- BG RCI and BGHM: GisChem