Hazardous substances in everyday life: How to store and transport cleaning products in a legally compliant manner

What facility managers, operations managers and compliance officers need to consider now

In many companies - from building cleaning to industrial production - cleaning and care products are part of the basic equipment. The associated risk is often less well recognised: many of these products are considered hazardous substances as defined by the German Hazardous Substances Ordinance (GefStoffV). If they are not stored or transported properly, there is not only the risk of accidents, but also legal consequences.

What is the legal basis?

Classification as a hazardous substance follows the CLP Regulation (EC) No 1272/2008supplemented by the REACH Regulation (EC) No 1907/2006. At national level, the :

• Hazardous Substances Ordinance (GefStoffV)

• Technical rules for hazardous substances (TRGS 510, TRGS 400)

• Ordinance on Installations for Handling Substances Hazardous to Water (AwSV)

• ADR / GGVSEB for the transport of dangerous goods

These regulations are not only relevant for the transport of hazardous goods, but also for internal processes - such as the provision of sanitary cleaners on a cleaning trolley.

Obligations for employers and responsible persons

1. risk assessment (§§ 5 ArbSchG, 6 GefStoffV)
Before handling hazardous substances, a risk assessment must be carried out and documented - also for the storage itself.

2. operating instructions and instruction (§ 14 GefStoffV)
Operating instructions must be drawn up for each hazardous substance used. Employees must be instructed before starting work and at least once a year thereafter.

3. list of hazardous substances (§ 6 GefStoffV)
Every company must keep a register of all hazardous substances used - with details of the product name, hazard class, storage location, H/P phrases, SDS status, etc.

4. storage requirements (TRGS 510)

• • Storage quantitiesSpecial obligations apply from 200 kg (e.g. leakage prevention, labelling, display)

  • SeparationAcids and alkalis, oxidising and flammable substances must not be stored together

  • LabellingHazardous substance storage areas must be clearly signposted (e.g. W021, W023)

  • Sump traysMandatory for liquid hazardous substances, dimensioned according to the largest container

1. 5. transport regulations (ADR)
   
   

   Special regulations apply depending on the quantity and classification:

   • Craftsmen regulation (ADR 1.1.3.1c)

   • Limited quantities (Limited Quantities)

   • 1000-point rule

Recommendation: Use the IHO guidelines

The current IHO guidelines for the storage and transport of cleaning products (status: 01/2025) summarises all essential requirements in a practical way. The storage matrix by storage class (LGK) and the presentation of typical sources of error and recommendations for action are particularly valuable.

Conclusion: Compliance begins on a small scale

Precisely because many cleaning agents are "everyday products", they are often underestimated in practice. However, a single incorrectly stored canister or an untrained employee can result in liability issues, fines or accidents at work. Compliance does not begin with abstract rules and regulations, but with structured implementation in day-to-day operations.

Obligate your service provider to implement it. Request the documented information.

Further information and advice

I would be happy to support you in the preparation of risk assessments, hazardous substance inventories, the introduction of a practical hazardous substance management system or service provider management.