Limit values and the Ordinance on Hazardous Substances

The new German Hazardous Substance Ordinance (Gefahrstoffverordnung) is conceived such that employers can implement the necessary measures even in the absence of an occupational exposure limit value and such that the effectiveness of the steps taken can be assessed. This also applies to carcinogenic substances. More specific guidelines for activities involving hazardous substances that lack limit values can be set down in the form of process- and substance- related criteria (PSC). Devising appropriate PSCs should be pursued with greater haste. PSCs as aids for employers are given special emphasis in the Hazardous Substance Ordinance. A return to the old concept of technical exposure limits can and should be avoided. Having the Hazardous Substances Commission set the risk-based limit values for carcinogenic substances opens a new, positive horizon in the spirit of occupational safety devised in a manner to maintain the health of workers and employees. The current German presidency of the EU Council provides an opportunity that should be used to introduce national thinking into the EU-level discussions more forcefully. This applies in particular to the greater consideration of occupational safety and health in the future design and application of REACH.