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Protecting Workers
from Dermal Exposure - The German Experience
Eva Lechtenberg-Auffarth, PhD, Federal Institute for Occupational Safety
and Health (BAuA), Dortmund, Germany
Bruno Orthen, PhD, Federal Institute for Occupational Safety and Health
(BAuA), Dortmund, Germany (Corresponding Author)
Skin diseases
Skin diseases are the most frequent occupational diseases in Germany.
About 20000 suspected occupational skin diseases were communicated to
the statutory accident insurance institutions in 2000. Each suspected
case is estimated to produce costs mounting to 14000 €. If skin diseases
are confirmed to have an occupational origin (ca. 8000 in 2000) or if
workers have to give up their occupation (ca. 450 in 2000) allowances
are significantly higher. These figures only reflect cases of irritative
and allergic contact dermatitis, systemic effects via the dermal route
are not included.
Legal framework
A broad legal framework for risk characterisation and protective measures
against (dermal) risks of chemical agents exists which is in close relation
to the EU legislation
| German legislation |
EU legislation |
| Arbeitsschutzgesetz (Act
on Workers´Health Protection) from 7.8.1996 |
Council Directive 89/391/EEC
on the introduction of measures to encourage improvements
in the safety and health of workers at work |
| Gefahrstoffverordnung
(Hazardous Substances Ordinance) from 7.8.2000 |
Council Directive 98/24/EEC
on the protection of the health and safety of workers from
the risks related to chemical agents at work |
| PSA-Benutzungsverordnung
(Ordinance on Use of PPE) from 4.12.1996 |
Council Directive 89/656/EEC
on the minimum health and safety requirements for the use by workers
of personal protective equipment at the workplace
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| Gefahrstoffverordnung
(Hazardous Substances Ordinance) from 7.8.2000 |
Commission Directive
2001/58/EEC “Safety Data Sheets” |
| Chemikaliengesetz (Chemicals
Act) amended 14.5.1998 |
Council Directive 67/548/EEC
on the approximation of the laws, regulations and administrative
provisions relating to classification packaging and labelling
of dangerous substances |
Fundamental demands for workers´
protection are outlined in the Act on Workers´ Health Protection (corresponding
to Directive 89/391/EEC) and Hazardous Substances Ordinance (corresponding
to Directive 98/24/EEC):
• Risks resulting from work must be minimised
• Risks must be assessed and protective measures must be implemented
• Risk assessment and measures have to be documented
A general ranking for protective measures against chemical agents is also
formulated:
• General and technical prevention is to be applied first
• Hazards are to be prevented at the source
• Personal protective measures are last choice
In Hazardous Substances Ordinance,
which addresses dermal hazards explicitly, the hierarchy of measures is
supplemented:
• substitution
• technical measures
• measures via changes in organisation
• personal protective equipment as last choice
Directive 98/24EEC addresses
risk assessment and precautionary measures for handling chemical substances.
Though the words “skin” or “dermal” do not occur in the directive, it
is important for dermal risk management, because it gives a definition
of “hazardous substance” that includes more substances than those that
are formally classified. It creates a legal basis for protective measures
for any chemical substance causing a risk in specific workplace scenarios
(e.g. degreasing of skin, mechanical stress).
Personal protective equipment
Personal protective equipment, though ranking last in hierarchy, is important
and frequently applied at workplaces. In the Ordinance on Use of PPE it
is stated:
• The employer is legally responsible for selecting and providing
PPE
• PPE must meet European standards
• PPE must be adequate and ergonomically acceptable
• Use of PPE must not cause a significant hazard
• Workers have to be instructed and trained on the use of PPE
• Skin barrier and skin care products are regarded as PPE
Substance specific information
Substance specific information is in principle available via Directive
67/548/EEC. It contains criteria for assigning dermal risk phrases to
substances, describing skin damaging properties or a systemic hazard following
dermal exposure. All substances must be classified. If a substance is
not included in the official list of Annex I of this directive producers
are obliged to classify on their own responsibility. Labelling and Safety
Data Sheets (SDS) are established means to inform employers and represent
a central instrument of communication. The new Directive 2001/58/EEC on
SDS is far-reaching, since it allows to identify nearly a large number
of hazardous ingredients in nearly all chemical products.
Technical rules
Technical rules (TRGS) have been developed on the basis of the Hazardous
Substances Ordinance; they specify the requirements and support enforcement
of the regulation. Some of these TRGS address dermal exposure explicitly:
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TRGS 150
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Direct dermal exposure to substances
that may be absorbed through the skin (first ed.1989) |
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TRGS 530
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Hairdressers (first ed. 1992) |
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TRGS 531
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Wet work (first ed. 1996) |
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TRGS 540
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Sensitising substances (first ed. 1996)
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TRGS 710
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Biomonitoring (first ed. 2000) |
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TRGS 900
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Skin notations in the list of Occupational Exposure
Limits (first ed. 1992) |
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TRGS 903
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Limit values for biomonitoring (first ed. 2001) |
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TRGS 907
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Inventory of sensitising substances
(first ed. 1997) |
TRGS 531 "Wet work"
Especially TRGS 531 “Wet work” should be regarded as innovative approach
for skin protection. It is of considerable practical relevance, since
many skin problems are caused by frequent exposure to water or prolonged
work with protective gloves leading to a wet milieu within gloves.
Statutory accident insurance
institutions
The statutory accident insurance institutions have their own responsibility
for reducing risks at workplaces. In parallel to the 16 federal states
that enforce national legislation there are 36 branch-specific and regionally
based statutory accident insurance institutions which are commissioned
to prevent and compensate occupational injuries and diseases. In accordance
with the federal legal framework, they have their own set of rules and
guidance, which may be very effective, because it is tailored to the specific
needs of a certain branch. Examples for such rules are:
| BGR 196 |
Chemical protective gloves |
| BGR 197 |
Use of skin care products |
| BGI 584 |
Skin cleaning, care and disinfection
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Replacement of a skin damaging
substance
Replacement of a skin damaging substance is the first choice of available
measures. In Germany, the process of substitution has been started and
maintained several times by discussions on new technical rules (TRGS)
in the Hazardous Substances Committee with all affected parties. Discussions
were often complemented by activities of the statutory accident insurances.
Some campaigns have been successful in recent years:
•Latex allergies
Latex allergies developed into a significant problem, since the use of
gloves became routine in the health care services. As most problems were
associated with powdered gloves, these were restricted by the TRGS 540
in 1997. At the same time, the responsible statutory accident insurance
ran a broad information campaign. As a result, in 2001 there were about
75% less suspected latex allergies compared to 1998.
•Hairdressers
Hairdressers have combined exposures to sensitising and irritating substances
under wet work conditions. A bundle of precautionary measures including
not only the elimination of known sensitising substances (esters of thioglycolic
acid, nickel, latex, introducing products with reduced emission potential)
but including also measures concerning the organisation (e.g., to reduce
prolonged contact with water) and personal protection (use of gloves for
certain work, skin care measures) were formulated in the TRGS 530 and
mainly enforced by extensive campaigns of the responsible statutory accident
insurance. As a result, the communications of suspected occupational skin
diseases decreased from 4500 in 1991 to 1500 in 2001.
•Sensitisation to chromate
In Germany, about 400 cases of sensitisation to chromate (in cement) are
confirmed every year in construction industries. Starting from a TRGS
on the substitution of cements containing chromate, the German cement
producing industry made a voluntary commitment to reduce chromate in cement
during the mid-nineties. This approach has not been sufficiently effective.
Therefore, Germany proposed on the EU-level to classify cements containing
more than 0,2 ppm chromate as sensitising. This has been agreed and as
a next step a proposal is under way to ban marketing and use of such cements
at least for manual activities.
Hairdressers are also an encouraging
example that it may be possible to restore health of persons with dermal
diseases. By an integrated approach (secondary individual prevention)
of seminars, training and risk assessment at workplaces, the incidence
of severe skin problems could be reduced considerably.
Discussion items
Despite the existing legal framework, specific rules and campaigns, dermal
diseases remained a main problem of workers´ health protection. In addition
uncertainties about systemic effects after dermal exposure represent an
important field of concern. The following items reflect actual discussions:
• Only existing toxicological information has to be used for classification
and labelling, but many substances have not been tested sufficiently and
exhibit data gaps.
• A quantitative risk characterisation is often connected with considerable
uncertainties, because dermal exposure is difficult to assess in a quantitative
sense. Actually, we are awaiting the results of a European project (RISKOFDERM)
and have started national discussions on a respective Technical Rule.
• Skin permeation is a prerequesite of systemic effects after dermal
contact. The scientific database to estimate the permeation rate is in
many cases weak. Worst case assumptions are often used, which can weaken
the reliability of a risk characterisation. Research projects are intended
to be initiated and coordinated.
• Technical measures need to be systematically developed and endorsed.
There are some strategies and examples of “good practice”, but there is
no systematic technical guidance up to now. Research projects are intended
to be initiated and coordinated.
• The use of gloves seemed a safe resort for risk management for
a long time. However, many presumptions have been questioned during the
last years.
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- A list of sensitising substances in gloves has
been established for the German market.
- It has also been questioned, whether the European Standards
for glove testing are adequate (testing temperature, stretching
of material) and whether permeation resistance can be sufficiently
predicted from data bases that only contain rough information
on the glove material. Several producers of chemical substances
have begun to indicate in their SDS gloves, that have been tested
especially for the specific product.
- There are current discussions whether it is possible to characterise
workplace situations, in which contact with chemicals is a minor
risk than prolonged wearing of protective gloves.
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• It has become open
to discussion how often protective creams keep their promises or whether
they might even enhance the risks in certain cases.
Literature and links:
EU-legislation
Council Directive 89/391/EEC, Council Directive 98/24/EEC, Council Directive
89/656/EEC, Commission Directive 2001/58/EEC, Council Directive 67/548/EEC
German legislation
Arbeitsschutzgesetz, Gefahrstoffverordnung, PSA-Benutzungsverordnung,
Chemikaliengesetz, TRGS 150, TRGS 530, TRGS 531, TRGS 540, TRGS 710, TRGS
900, TRGS 903, TRGS 907
Statistics of occupational
diseases
http://www.hvbg.de/d/pages/infomat/wir/g-r/g-ergeb/bk/kap4.pdf
Statistics of occupational
diseases
http://de.osha.eu.int/index.cfm?B8FCFBA9A7B442FB83AA36697A6B3D13
Statutory accident insurance
institutions
http://www.hvbg.de/e/pages/index.htm
Neumeister, L., Hautschutz
in der Textilindustrie, Der Sicherheitsschirm, 1/2002, S. 3-4
Elsner, P., Brandenburg, S.,
Rechtliche Grundlagen des Hautschutzes,Dermatol. Beruf Umwelt/Occup. Emnviron.
Dermatol. 49 (2001), S. 54-58
Latex campaign
http://www.bgw-online.de/pressezentrum/pressearchiv/detail_presse.jsp?lfdDokNr=1035
Hairdressers campaign
http://www.bgw-online.de/pressezentrum/presseinformationen/detail_presse.jsp?lfdDokNr=1967
Sensitisers in gloves
http://www.gisbau.de/Allergen/Allergenliste.pdf
DIN EN 374 und Entwurf einer
Neufassung prEN 374, Schutzhandschuhe gegen Chemikalien und Mikroorganismen,
Berlin: Beuth 1994 und 1998
Oppl, R., Chemikalienschutzhandschuhe
- Entwicklung, Erprobung und Dokumentation eines praxisgerechten und kostengünstigen
Verfahrens zur Ermittlung der Durchlässigkeit (Permeation) von Schutzhandschuhen
für gefährliche Zubereitungen, St. Augustin, Hauptverband der
gewerblichen Berufsgenossenschaften (Hrsg.) 2000
http://www.hvbg.de/d/bia/pub/rep/rep01/forsch/handsch.pdf
Oppl R., Braun R., Schutzwirkungen
von Schutzhandschuhen beim Umgang mit einer kaltverarbeiteten Bitumen-Emulsion,
Schutzwirkungen von Schutzhandschuhen beim Umgang mit einer kaltverarbeiteten,
lösemittelhaltigen Bitumen-Zubereitung - Prüfberichte. Hamburg:
MILJÖ-CHEMIE 1999
www.deutsche-bauchemie.de/2verband/ausschus/fa4_bitu.htm
Hebisch, R. Rühl, R. :
Hautkontakt mit Arbeits- und Gefahrstoffen- ein Diskussionspapier des
AGS. ErgoMed 1/2002 S. 24-26
Gefährdungen durch dermale
Exposition
http://www.baua.de/prax/ags/dermal.pdf
Aktueller Sachstand zur Branchenregelung
„Chromatarme Zemente und Produkte“
http://www.cramif.fr/pdf/aiss/seance_poster/kluger.pdf
Chromatarme Zemente und zementhaltige
Produkte
http://www.vdz-online.de/downloads/chr_arm/chr_arm.pdf
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