Munich Hazardous Materials and Safety Days: A New Era of Regulation and Innovation

The 41st Munich Hazardous Materials and Safety Days, held in Darmstadt, marked a significant turning point for the renowned conference. Not only did the event relocate from its traditional Munich venue to Darmstadt, but it also saw a change in organizational leadership, with Ultima Media Germany GmbH taking the reins from Süddeutscher Verlag Veranstaltungen GmbH. This transition, stemming from Süddeutscher Verlag’s acquisition of Ultima Media Ltd in 2017 and the subsequent outsourcing of its specialized events in early 2025, signaled a strategic move towards internationalization. While this shift raised questions about the conference’s core focus on German hazardous materials law, the event proceeded to deliver a comprehensive overview of crucial regulatory updates and emerging trends in occupational health and safety.

A New Beginning in Darmstadt: Organizational Shifts and Initial Impressions

The conference commenced on the morning of November 26th, under the guidance of a new project leader from Ultima Media and moderators Prof. Dr. Anke Kahl and Dr. Birgit Stöffler. The program began with an exclusive site visit to Merck in Darmstadt. This ambitious undertaking, originally slated for two hours, involved a bus tour of the expansive 1.25 km² facility. While participants observed new construction, indicative of a substantial €1.5 billion investment program in Darmstadt over recent years, the tour primarily consisted of a company video and a drive-by of ongoing developments. This initial experience, while offering a glimpse into Merck’s significant investment, perhaps set a tone of practical demonstration over in-depth technical exploration, a theme that would subtly echo throughout the conference.

Navigating Asbestos Regulations: A Deep Dive into the Amended Hazardous Substances Ordinance

The core of the first day’s proceedings focused on critical updates to German hazardous materials law, with a particular emphasis on asbestos. Andrea Bonner from BG BAU (Berufsgenossenschaft der Bauwirtschaft) provided a detailed presentation on the amendments to the Hazardous Substances Ordinance (GefStoffV), specifically addressing their impact, including on private households.

Bonner clarified that while the GefStoffV generally does not apply to private households unless explicitly stated, specific provisions concerning asbestos in Sections 5a and 11 do extend to domestic settings. The primary focus of her presentation was on the December 2024 amendments to the GefStoffV and their implications for the construction industry, particularly for renovations and existing buildings. A key objective of these changes is to enhance protection against carcinogenic substances in the workplace. This includes the full integration of the risk-based risk assessment concept from TRGS 910 (Technical Rule for Hazardous Substances 910) into the ordinance and the introduction of new regulations for asbestos, stemming from the national asbestos dialogue.

The Role of the Initiator and Employer in Asbestos Management

A significant development highlighted was the enhanced role of the initiator of construction measures. The new Section 5a of the GefStoffV now obliges the initiator to provide all available information regarding the construction or usage history of a building. This duty extends to private clients. Bonner outlined the types of information that can reasonably be expected from clients or building owners, such as the construction year derived from a purchase contract, or by inquiring with the responsible building authority. Any further information, such as from a technical survey, must also be shared with the executing company.

Under Section 6, the employer of the executing company remains responsible for the risk assessment. They must verify the plausibility of the information provided under Section 11a and incorporate it into their assessment. A crucial presumption is that if construction began after October 31, 1993, asbestos is generally not present. Conversely, construction prior to this date raises a presumption of asbestos presence, which can be refuted through further investigation. A guideline for asbestos surveys has been published to support this process.

Addressing Information Gaps and Special Services

The amended ordinance also addresses situations where provided information is insufficient for a risk assessment. New paragraph 2b in Section 6 clarifies that employers must conduct a special assessment in such cases. These "special services" in construction refer to tasks beyond standard basic services that require specific agreement and separate remuneration. If an employer lacks the necessary expertise for such an assessment, they must seek external expertise, for instance, for a technical survey.

Furthermore, the asbestos presumption for buildings constructed before October 31, 1993, can also be disproven through a historical survey, for example, if asbestos-containing components have already been identified and removed. Importantly, further investigation is not required if only activities are planned that do not exceed an exposure limit of 1,000 fibers/m³. However, the Technical Rule for Hazardous Substances (TRGS) 519 will need to define additional activities that fall below this exposure threshold. In such cases, only general dust control measures are necessary. This also applies if the asbestos presumption has been refuted through historical or technical surveys. If a technical survey confirms the presence of asbestos, protective measures according to TRGS 519 must be implemented, even if a technical survey was initially waived.

New Regulations for Asbestos Activities

Two new paragraphs, Sections 11 and 11a, specifically regulate activities involving asbestos. Section 11 outlines restrictions on use and activities. Beyond numerous prohibitions, exceptions for demolition, remediation, and maintenance work are crucial. For demolition, which involves the complete removal of asbestos-containing components or materials, the processing of partial surfaces or areas is now permitted. Remediation work is limited to the spatial separation of asbestos-containing materials or temporary securing of damaged components if complete removal is not immediately feasible.

A notable update concerns maintenance work. Previously restricted to tasks like servicing and inspecting asbestos-containing fire dampers, these activities are now expanded to include functional maintenance of structural facilities. This encompasses various craft activities in existing buildings, provided they occur within an exposure range of up to 100,000 fibers/m³ (low to medium risk areas). These restrictions in Section 11 also apply to private households. Private individuals undertaking these permitted activities are obligated to prevent the generation, release, and spread of asbestos fibers and dust as much as possible, necessitating the implementation of TRGS 519 protective measures.

Section 11a details the requirements for employers involved in asbestos activities. This includes provisions for risk assessment, risk-based requirements for protective measures, authorization for activities in high-risk areas, and notification procedures. It also clarifies qualification requirements for responsible persons and employees. These regulations are supplemented by Annex I No. 3 of the ordinance and TRGS 519. The latter is currently undergoing revision to align with the risk concept and other changes in the GefStoffV. With the new TRGS 519 expected to be finalized by the Committee for Hazardous Substances (AGS) in autumn 2026, the Federal Institute for Occupational Safety and Health (BAuA) has already provided transitional guidance, information on authorization and notification, new sample forms, and an overview of the new modular qualification system on its website.

Air Limit Values and the Evolving TRGS 910

The second thematic block of the conference addressed air limit values and their implications for the new TRGS 910. Dr. Birgit Stöffler of Merck explored the question of which limit values must be observed in light of the GefStoffV amendments. She introduced the Binding Occupational Exposure Limit Values (BOELVs) as a new category of limit. While not explicitly mentioned in the GefStoffV, Section 7(8) requires employers to ensure that Occupational Exposure Limits (AGWs) and the limit values in Annex III of Directive 2004/37/EC are adhered to. This directive, formerly known as the Carcinogens Directive, was expanded in 2022 to include reprotoxic substances, leading to the term CMR Directive. Annex III lists substances with binding air limit values. Currently, Annex III contains 38 BOELVs. For 18 of these, an AGW exists in TRGS 900. For 17 substances, TRGS 910 provides acceptance (AK) and tolerance (TK) concentrations. Three other substances are regulated through specific rules, with TRGS 553 defining an AGW for hardwood dusts. For fine crystalline silica, TRGS 559 states that the AGS has decided on an assessment criterion. In November 2025, a new TRGS 505 was adopted by the AGS, designating the BOELV for lead as a binding air limit value.

Aligning BOELVs and AGWs: Navigating Risk and Compliance

Of the 18 substances in TRGS 900, the BOELV and AGW coincide for 14. In the remaining four cases, the BOELV is higher than the AGW. Since Germany enforces the stricter AGW, this poses no compliance issue. For the 17 substances in TRGS 910, 15 BOELVs fall within the medium or high-risk categories. As Section 7 of the GefStoffV does not mandate adherence to AK and TK values, solely observing the BOELV could lead to higher risks for employees. This is where Sections 10 and 10a become relevant, requiring an action plan for activities in medium and high-risk areas. The TRGS 910 plays a crucial role in implementing the risk concept for carcinogenic hazardous substances, now particularly reflected in the revised Sections 10 and 10a.

Consequently, TRGS 910 is currently being revised, with a project outline discussed at the AGS meeting in May 2025. Dr. Markus Schwind of Sanofi presented insights into the design of the new TRGS 910, emphasizing practicality and an employer-centric approach. The goal is for employers to achieve sustained compliance with AK or an AGW through an action plan. The TRGS aims to include a simplified concept for such a plan, complementing the risk assessment without creating duplication of effort. Protective measures will be described in more detail, and the TRGS will be geared towards its presumed effect. As before, the TRGS will list AK and TK values and, importantly, will offer employers future guidance through detailed examples of protective measures.

Emergency Showers: A New Standard for Safety

In a concise company presentation, Miriam Kühne from DENIOS introduced the new standard DIN EN 15154 for emergency showers. This six-part standard covers body and eye showers, with and without water connections, for laboratories and other locations. While TRGS 526 (Laboratories) mandates emergency showers, its structural requirements are less stringent than those outlined in the new standard.

The Employee Perspective: Navigating Regulatory Changes

Following the lunch break, Vadim Lenuck from the Mining, Chemical, and Energy Industrial Union (IG BCE) evaluated the Hazardous Substances Ordinance from the perspective of employees. He provided a brief overview of the unsuccessful attempts to revise the GefStoffV since 2010, before detailing the key changes introduced in the 2024 revision. While acknowledging an improvement in readability, Lenuck also pointed to numerous interpretation and application challenges. The direct validity of BOELVs, for instance, raises the question of whether further minimization is still required if a BOELV is met.

Lenuck emphasized that a definitive assessment of whether the revised ordinance represents a significant advancement can only be made by observing its practical implementation in companies. Given that many decisions have been deferred to the technical regulatory framework, and the new rules (TRGS 519 and 910) are yet to be finalized, he could not offer a conclusive judgment. Looking ahead, he expressed hope that digital assistants could help reduce uncertainties in regulatory application. For the use of Artificial Intelligence (AI) in occupational safety, including risk assessment verification, AI must not only be capable of digitally reading data but also of processing it through a structured representation of regulatory frameworks and other information.

Metals: Indispensable Yet Potentially Hazardous

Under the heading "Metals: Sometimes Dangerous, Always Indispensable," Dr. Martin Wieske from the German Non-Ferrous Metals Association (WirtschaftsVereinigung Metalle) provided an overview of the role of metallic raw materials as a key element in industrial value creation. He highlighted the EU’s designation of many metals as critical or even strategic raw materials under the Critical Raw Materials Act (CRMA, EU 2024/1252). Critical raw materials are of significant economic importance, yet face a high risk of supply disruption. Strategic raw materials are particularly crucial for key technologies and the transition to a climate-neutral, digital economy, including lithium, cobalt, rare earths, and gallium.

Wieske also addressed the occupational safety implications of certain metals due to their inherent properties. TRGS 561 regulates activities involving carcinogenic metals and their compounds. The important requirement in Section 10 of the GefStoffV, mandating the use of carcinogenic hazardous substances of category 1A or 1B in a closed system, is not always feasible for carcinogenic metals. Therefore, TRGS 561 outlines specific protective measures to minimize employee exposure and clarifies the requirements of TRGS 910. The revised version of TRGS 561 was adopted by the AGS in November 2025, alongside the new version of TRGS 505 "Lead." While lead is not classified as carcinogenic, it has a BOELV due to its reprotoxic properties. This value has been implemented in TRGS 505 as a binding air limit. As the value is not health-based, with no direct correlation between air measurements and bodily effects, TRGS 505 emphasizes the importance of biomonitoring.

Celebrating 20 Years of EMKG: Enhanced Tools for Risk Assessment

The subsequent presentation marked an anniversary: the Simple Measures Concept for Hazardous Substances (EMKG) developed by BAuA has supported companies in their risk assessments for two decades. Annette Johnen, who leads the development of EMKG at BAuA, presented several enhancements. Previously, EMKG comprised three core modules: assessment of inhalation and skin contact hazards, and fire and explosion hazards. It has now been expanded with two additional modules. The "Eye" module allows for specific assessment of eye hazards, which were previously subsumed under skin contact. The "Storage" module provides assistance in assessing the storage of hazardous substances, developed based on TRGS 510, with measure levels based on hazard group and storage quantity. A new poster visually illustrates the process of using the five modules. The assessment is further complemented by "protective guidance sheets," largely updated, which describe minimum standards in Measure Level 1. Risk-based additional protective measures may be required, outlined in Measure Levels 2 and 3. For activities involving highly hazardous substances, such as carcinogens, Measure Level 4, "Consultation," may be necessary, requiring specialized expertise for defining and implementing protective measures.

Heike Lehmann of Steinway & Sons complemented this presentation by describing the application of EMKG and the assessment of physical strain using BAuA’s "leading characteristic methods" in the manual production of pianos and grand pianos, highlighting the hazards faced by employees in this craft.

Expert Risk Assessment: A Collaborative Endeavor

In her second, and this time planned, presentation, Annette Johnen addressed the topic of expertise under the title "An Expertly Conducted Risk Assessment is Teamwork." She referenced Section 3 of the German Occupational Safety and Health Act (ArbSchG), which obligates employers to take measures, and Section 5, which requires them to determine necessary measures through risk assessment. However, the ArbSchG itself does not specify the knowledge required for expert execution. This expertise is further detailed at the ordinance level. A comparison of various ordinances reveals minimal deviations in interpreting this expertise. Technical regulations provide further specification, with the scope and depth of knowledge varying by industry, activity, and hazard. Crucially, these competencies do not need to reside in a single individual, underscoring that risk assessment typically necessitates teamwork.

The Second Congress Day: Digitalization and Climate Adaptation

The second day of the congress focused on digitalization and adaptation to climate change. Dr. Sascha Wischniewski from BAuA opened the morning with an overview of digitalization in occupational safety within companies. He explained how technological advancements are transforming the world of work, impacting work organization and methods, and consequently altering job requirements for nearly all employees. BAuA is actively researching criteria for human-centered work design. A book titled "Safety and Health in the Digitalized World of Work: Criteria for Human-Centered Design" offers insights into the extent of digitalization in various professions and its impact on specific work requirements.

Christian Kuckartz, CEO of BGM-Solutions, shared experiences from his consulting and service company, emphasizing that the best digital solutions arise from integration and adaptation to established analog processes, rather than their outright replacement.

A compelling example of digital transformation was presented by Dr. Andreas Mainka of Mainka Bau, a company that has received the German Occupational Safety Award twice. Over a decade ago, Mainka successfully implemented the "Continuous Improvement Process" (KIP), earning recognition in 2019. Since then, the company has digitized all its formerly paper-based processes. The result is a remarkable zero reportable work accidents per 1,000 full-time employees, significantly lower than the industry average of 44.55. The Mainka app serves as a central digital tool, enabling the scanning of QR codes on construction sites. These codes, attached to activities, areas, and equipment, facilitate the identification of potential hazards and the effective communication of protective measures.

Adapting to a Changing Climate: Heat and UV Protection

In the afternoon, Prof. Anke Kahl and Magnus Nauth from the University of Wuppertal presented findings and conceptional measures from the "Climate Changes Work" policy workshop. This initiative, running from November 2023 to February 2025, focused on heat and UV protection, analyzing the impacts of climate change on the working world and developing solutions for climate-resilient, safe, and healthy working conditions. While heat stress has been extensively researched, existing assessment methods and limit values have limitations. Heat-related illnesses can affect anyone, but certain individuals are more susceptible and thus at increased risk. Their risk factors for heat exposure are often highly personal. To effectively implement protective measures for these risk groups in Germany, a concept is needed for the data-protection-compliant collection of necessary information.

Gabriele Renner from Pervormance International concluded the presentations by discussing health and safety issues at high temperatures. While air conditioning systems are costly and ineffective outdoors, cooling clothing offers a practical solution, especially during hot summer days. By maintaining normal body temperature, it significantly reduces cardiovascular strain caused by excessive heat transfer. Cooling clothing is available in various forms, including hats, trousers, neck scarves, and cooling vests.

Outlook: The Future of the Munich Hazardous Materials and Safety Days

The 42nd Munich Hazardous Materials and Safety Days are scheduled to take place from November 25th to 26th, 2026, back in Munich. Further information will be provided by UniQMoments UG in due course.

Editorial Note: The Munich Hazardous Materials and Safety Days will again be held in November 2026. This year, however, the event will take place a week earlier, on November 18th and 19th, 2026, serving as a central platform for professional exchange on current developments in occupational health and safety. UniQMoments will be organizing the event for the first time in 2026. Registration for the 42nd Munich Hazardous Materials and Safety Days is now open.

LITERATURE
[1] Ordinance Amending the Hazardous Substances Ordinance and Other Occupational Safety Ordinances. Ed.: Federal Ministry of Labour and Social Affairs (BMAS).
[2] Guideline for Asbestos Surveys to Prepare for Work in and on Older Buildings. Ed.: Federal Institute for Occupational Safety and Health (BAuA), 2020.
[3] Documents for TRGS 519. Ed.: Federal Institute for Occupational Safety and Health (BAuA).
[4] Wieske, M.; Pallapies, D.: The Anchoring of the Risk Concept for Carcinogenic Hazardous Substances in the GefStoffV. Gefahrstoffe – Reinhalt. Luft 85 (2025) No. 3/4, pp. 53-57.
[5] Tisch, A.; Wischniewski, S. (Eds.): Safety and Health in the Digitalized World of Work. Criteria for Human-Centered Design. 1st Edition. Baden-Baden: Nomos Verlagsgesellschaft mbH & Co. KG, 2022.
[6] The Policy Workshop "Climate Changes Work." Federal Ministry of Labour and Social Affairs (BMAS), 2026. 42nd Munich Hazardous Materials and Safety Days. Ed.: UniQMoments UG.

THE AUTHOR
Dipl.-Chem. Rainer Dörr, Berufsgenossenschaft der Bauwirtschaft (BG BAU), Wuppertal.

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