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Keeping an exposure register for carcinogenic substances

Employers whose staff carry out activities with carcinogenic, germ cell mutagenic or reprotoxic hazardous substances of category 1A or 1B must keep an exposure register (Expositionsverzeichnis) if the risk assessment shows a risk to health. This article explains who is covered, what the register contains, how long it must be kept and how the Central Exposure Database of the German Social Accident Insurance can be used.

Hands leafing through a binder with index tabs, a monitor with a table next to it, behind the glass a joinery workshop with dust extraction
Contents
  1. Purpose of the register
  2. Employees covered
  3. Content
  4. Updating, retention and extract
  5. Access to the data
  6. Central Exposure Database
  7. In practice

Purpose of the register

Cancers caused by hazardous substances often appear only decades after exposure. Under § 10a para. 1 of the Hazardous Substances Ordinance (GefStoffV), the register is meant to make it possible to trace the level and duration of exposure if a disease occurs later. It secures evidence for possible occupational disease proceedings and is the basis of the post-exposure occupational health check-up. The duty used to be in § 14 GefStoffV; since the amendment of the ordinance in December 2024 it is set out in § 10a and also covers reprotoxic substances.

Employees covered

The register covers employees who carry out activities with carcinogenic, germ cell mutagenic or reprotoxic hazardous substances of category 1A or 1B where the risk assessment shows a risk to their health. What counts is therefore not every contact with such a substance but the risk. Typical examples are work with asbestos, hardwood dust, benzene or polycyclic aromatic hydrocarbons, and the welding of chromium-nickel steels. The Technical Rule for Hazardous Substances TRGS 410 uses the risk to set out when the register must be kept. Its September 2026 edition names criteria for inclusion, for example exceeding the occupational exposure limit or the acceptable concentration, wearing respiratory protection or missing exposure data.

Content

Under § 10a para. 1 GefStoffV, the activity and the level and duration of exposure must be recorded. In practice this includes:

  • details that clearly identify the employee
  • the hazardous substance or process and the activity carried out
  • type, level, duration and frequency of exposure
  • start and end of the activity

The level of exposure is based on measurements or a traceable estimate from the risk assessment; TRGS 410 describes how it is to be stated. Findings and diagnoses do not belong in the register. The data are subject to the safeguards of § 22 para. 2 of the Federal Data Protection Act.

Updating, retention and extract

For as long as exposure continues, the register must be kept up to date. After exposure ends it must be kept for at least 40 years for carcinogenic and germ cell mutagenic hazardous substances and for at least five years for reprotoxic hazardous substances. When employment ends, the employer hands the employee an extract with the details concerning them and keeps proof of the handover like personnel records.

Access to the data

Under § 10a para. 4 GefStoffV, the employer must give access to the physician who carries out the occupational health check-ups and to the competent authority, to the employees concerned for their own data, and to the employee representatives for data that are not personal.

Central Exposure Database

The German Social Accident Insurance (DGUV) provides the Central Exposure Database (ZED) for all accident insurance institutions. Using it is voluntary and free of charge. Companies can keep their register there; if the employer transmits the data to the accident insurance institution, this meets the duties of retention and of handing over the extract under § 10a para. 3 GefStoffV. Through the ZED, employees can also be registered for post-exposure check-ups with the check-up services of the accident insurance institutions.

In practice

If, for an activity with carcinogenic or germ cell mutagenic hazardous substances of category 1A or 1B, the occupational exposure limit is not met or the activity falls within the high-risk range, it must also be notified to the competent authority under § 10a para. 5 GefStoffV within two months after the activity begins, stating the exposure determined; a plan of measures under § 10 para. 5 GefStoffV must be attached. When we take on a company, we use the risk assessment to check which employees must be covered, whether the register is complete and up to date, whether extracts have been handed over and whether occupational health check-ups, including post-exposure check-ups, are organised. We arrange on-site appointments with companies in the Ingolstadt, Munich and Upper Bavaria area. Advice and meetings are available nationwide by video.

Questions on this article

Does every company working with carcinogenic substances have to keep an exposure register?

No. The duty applies if the risk assessment for activities with hazardous substances of category 1A or 1B shows a risk to health. TRGS 410 names criteria for inclusion in the register.

How long must the register be kept?

After exposure ends, for at least 40 years for carcinogenic and germ cell mutagenic substances and for at least five years for reprotoxic hazardous substances of category 1A or 1B.

Do findings belong in the register?

No. It contains the activity and the level and duration of exposure. Findings from occupational health check-ups stay with the physician.

All questions by topic →

Legal basis and sources

This article is based on the following statutory texts and publications of the competent bodies.

§ 10a GefStoffV — Recording, notification and information duties

Federal Ministry of Justice — exposure register: employees covered, details, retention for 40 or five years, extract, transfer to the accident insurance institution, access.

TRGS 410 — Exposure register for activities with carcinogenic, germ cell mutagenic or reprotoxic hazardous substances of categories 1A or 1B (September 2026 edition)

Federal Institute for Occupational Safety and Health (BAuA) — criteria for inclusion in the register, details of exposure; GMBl 2026 p. 528.

IFA — Exposure register

Institute for Occupational Safety and Health of the DGUV — duties, details, retention, Central Exposure Database.

Central Exposure Database (ZED)

German Social Accident Insurance — keeping the register free of charge and transmitting it to the accident insurance institution.

Links checked in October 2026. They lead to the publishers' websites.

Checking your exposure register

We use the risk assessment to check who must be covered and advise on setting up the register and on registration for post-exposure check-ups.

Go to the service: Occupational health check-ups