RISK ASSESSMENT
EMKG explained: the simple control-banding model for hazardous substances
The EMKG derives a concrete control approach for an activity from three inputs – hazard, release and quantity – without any measurements of your own. It explains what the group A–E and the level 1–4 in your risk assessment mean.
What is the EMKG?
The EMKG (Einfaches Maßnahmenkonzept Gefahrstoffe, "simple control approach for hazardous substances") is a control-banding method developed by the German Federal Institute for Occupational Safety and Health (BAuA). It lets companies carry out a risk assessment for activities involving hazardous substances without having to take their own air measurements.
The idea: instead of measuring a limit value, you assign a substance to a hazard group from its classification, estimate how readily it is released and how much is used, and read off a matching control approach with concrete measures. The result is decision support, not a legally binding determination.
In Caventi's risk assessment you see exactly these two values next to each activity: the hazard group (as "Group A" to "Group E") and the control approach derived from it (as "Level 1" to "Level 4"). This page explains how both come about.
The eight steps of the EMKG
The EMKG works in eight steps. Steps 1 to 4 lead to the measures needed for inhalation, steps 5 to 7 to the additional measures for skin contact, step 8 checks effectiveness.
- 1 Step 1: hazard group inhalation The group A to E follows from the classification.
- 2 Step 2: quantity and activity duration The amount handled during the activity is assigned to a quantity range.
- 3 Step 3: release group How readily the substance reaches the air: low, medium or high.
- 4 Step 4: measures needed for inhalation Group, quantity and release give the control level via the decision table.
- 5 Step 5: hazard group skin contact The skin group HA to HE follows from the classification.
- 6 Step 6: contact area and contact time How large the wetted area is and how long the contact lasts.
- 7 Step 7: measures needed for skin contact Skin group, contact area and contact time give the low, extended or high level of measures.
- 8 Step 8: effectiveness check Whether the chosen measures meet the limit values and stay effective.
The three inputs
For the inhalation assessment the EMKG needs three inputs. Caventi derives the first two automatically from the safety data sheet; you state the quantity per activity.
1. Hazard (hazard group A–E)
One of five hazard groups is determined from the product's H and EUH statements. If several products are involved in the activity, the highest group applies ("the worst product wins").
2. Release (volatility)
How easily does the substance reach the air? Liquids release according to their boiling point or vapour pressure, solids according to their dustiness. Caventi determines low / medium / high from physical state, dustiness and vapour pressure. The EMKG is not designed for the handling of gases (see "What the EMKG does not cover").
3. Quantity
How much is handled during the activity? Small (grams/millilitres), medium (kilograms/litres) or large (tonnes/cubic metres). You provide this on the activity itself.
Before the steps begin
A few groundwork points come before the eight steps: who assesses, reliable data, the substitution check and the question whether a low hazard exists at all.
Who assesses
Only a competent person may carry out the risk assessment, for example an occupational-safety specialist or the occupational physician. The EMKG supports them but does not replace them.
Reliable data from the safety data sheet
The EMKG is only as good as its inputs. First check the safety data sheet for obviously incomplete or faulty data: does the labelling in section 2 fit together, is the classification plausible, are workplace limit values and the boiling point or vapour pressure (sections 8 and 9) given? If section 11 lacks tests for acute toxicity, irritation, mutagenicity or skin sensitisation, these properties must be assumed (under CLP roughly H331/H311/H301, H315, H341 and H317) – unless the sheet expressly declares the product not subject to labelling and without harmful effects. Work only from a current data sheet: an outdated classification leads to wrong protective measures, and the supplier automatically redelivers an updated safety data sheet within a year of the last delivery when hazard-relevant data has changed; otherwise request it from the manufacturer. Mind the limit of the labelling as well: it shows only those hazardous properties known to the manufacturer, because large gaps in knowledge about the harmful effects of chemical substances remain.
Substitution first
Every risk assessment begins with the substitution check: can the hazardous substance be replaced by a less hazardous one? This applies to every activity with hazardous substances, not only from a certain group upward. The tool is the column model (TRGS 600). All properties must be weighed – including fire, explosion and environmental hazards, which the EMKG itself does not assess.
Low hazard
A "low hazard" exists only when every condition holds together: the working conditions, only a small quantity used and an exposure that is low in level and duration exclude a health hazard with high probability, no technical or personal protective measures are necessary, and the workplace limit value is met. For corrosive substances (H314) it is ruled out as soon as skin contact cannot be excluded. In practice this mainly concerns household products used at the workplace under household conditions. Where the case applies, it suffices to document the finding in the risk assessment: the substance need not enter the hazardous-substance register, and no operating instruction is required. This is not the same as level 1 (100 series): that already requires operating instructions, instruction of workers and occupational-medical advice.
Terms and version
The EMKG is at version 2.2. It replaced the earlier term "Maßnahmenstufe" with "Maßnahmenstufe" and dropped entry via the old hazard symbols; the eight steps themselves stayed unchanged. Important for reading this page: the printed tables of version 2.2 still assign the groups via the old R-phrases, because old and new classification do not always agree - some harmful substances count as toxic under CLP, and irritant preparations can be classified as corrosive, which leads to different measures. This page nevertheless works throughout with today's CLP classification (H/EUH statements), because that is all a safety data sheet still carries; the assignment follows the conversion table in Annex VII of the CLP Regulation. Where old and new classification diverge, that conversion yields the higher hazard group, and Caventi always takes the stricter group in such cases.
What the EMKG does not cover
The EMKG covers health hazards from inhalation and skin contact. For some activities it cannot derive measures; a separate assessment is then required:
- Activities that can lead to fire and explosion hazards. These are assessed by the second EMKG module, fire and explosion.
- Activities in which hazardous substances first arise or are released from articles, such as soldering and welding fumes, pyrolysis products, exhaust gases or decomposition processes.
- Activities requiring special measure approaches, such as demolition, remediation or recycling work releasing substances not deliberately used.
- The industrial and commercial handling of gases.
- Substance-related environmental hazards.
The EMKG derives no measures for the handling of gases. Caventi does assess gases from their H statements, but flags the result as a cautious extension beyond the proven scope; consult a specialist for activities involving gases.
The hazard group (inhalation): A to E
The hazard group captures how harmful a substance is to breathe in. It is derived from the H/EUH statements of the classification and graded from A (low) to E (very high). The most severe statement determines the group.
| Group | Meaning | Governing H/EUH statements |
|---|---|---|
| A | Low hazard by inhalation | H304, H319, H335, H336 – plus any product not assigned to B–E. Purely skin-related statements such as H315 or EUH066 do not count for inhalation; they act through the skin-contact group (HB resp. HA) and leave the product in A only because no inhalation-related statement applies. |
| B | Medium hazard by inhalation | H302, H318, H332, H371 |
| C | Raised hazard by inhalation | H301, H314, H331, H334, H341, H351, H361, H373, EUH029, EUH031 |
| D | High hazard by inhalation | H300, H330, H370, H372, H360D, H360Df, EUH032 |
| E | Very high hazard (carcinogenic, mutagenic or damaging to fertility, H360F) | H340, H350 (incl. H350i), H360, H360F, H360FD, H360Fd |
Purely skin-related statements (H310, H311, H312) carry no inhalation hazard and do not affect the group; they drive the skin assessment instead (steps 5-7, see the skin-contact section). Respiratory-sensitising (H334), irritant and corrosive substances additionally get no level reduction for short activities.
For substances with a workplace limit value (AGW), the EMKG has a second route: the group comes from the air-concentration band of the limit value instead of from the H statements, one group per power of ten. For solids (dusts, in mg/m³): A 1 < c ≤ 10, B 0.1 < c ≤ 1, C 0.01 < c ≤ 0.1, D 0.001 < c ≤ 0.01, E c ≤ 0.001. For liquids (in ppm): A 50 < c ≤ 500, B 5 < c ≤ 50, C 0.5 < c ≤ 5, D 0.05 < c ≤ 0.5, E c ≤ 0.05. The band states the concentration the protective measures must at least achieve. Preparations and substances without a limit value always run through the classification instead. Hydrocarbon mixtures are likewise assigned via the mixture's group limit value: aliphatic C5–C8 in group A, aliphatic C9–C15 in group B, aromatic C7–C8 in group B, aromatic C9–C15 in group B; where a mixture consists of several fractions or contains components with a limit value of their own, a limit value for the mixture has to be determined first. Caventi bands exclusively from the classification (H/EUH statements) and does not use this AGW route, so for substances with a limit value you take that route yourself.
In Caventi this is the "Group A" to "Group E" value next to each activity and product.
Release / volatility
Release describes how readily a substance reaches the air you breathe. It is estimated in three levels:
For liquids the boiling point is the primary key at room temperature: above 150 °C means low, 50 to 150 °C medium, below 50 °C high. If a range is given, the lowest value applies. At a different application temperature (AT) the group shifts: low if the boiling point reaches at least 5 × AT + 50, high if it is at most 2 × AT + 10. Aqueous solutions count as low, provided the dissolved substances are of low volatility and are not sprayed. For some volatile solids (e.g. naphthalene) the vapour pressure can raise the release group - never lower it.
Quantity
The third input is the amount handled during the activity. The EMKG knows three quantity ranges:
What counts is the amount typically handled during the activity - for large-area application (e.g. painting, cleaning) the amount per working day; for the small quantity band this must not exceed 1 litre per working day. When in doubt, pick the higher quantity band.
The control approach (control level): 1 to 4
The control approach follows from hazard group, release and quantity via a lookup table. It says what kind of protective measure is appropriate to the risk.
| Level | Measure type | What it means |
|---|---|---|
| 1 | Minimum standards (general protective measures) | The minimum standards are enough: good general room ventilation and the basic organisational and hygiene rules (100-series guidance sheets). For solids with medium or high release, the measures for dusty workplaces are added: capture dust where it arises, prevent dust deposits, clean regularly in a low-dust way (no dry sweeping, no blowing down with compressed air) and keep containers closed (guidance sheet 240). Level 1 always also includes an operating instruction, substance- and activity-specific instruction of workers, occupational-medical and toxicological advice, safety precautions for lone working and for work involving several companies, and measures for responding to malfunctions, accidents and emergencies. |
| 2 | Engineering measures / extraction | Additional engineering measures such as targeted local exhaust at the point of release. |
| 3 | Closed system / containment | The activity must run largely enclosed or contained. |
| 4 | Seek expert advice | The simple measures do not suffice. First check whether vetted guidance already exists for the substance or the activity (for instance substance- and activity-specific assessments for carcinogens such as asbestos, wood dust, ceramic fibres, pyrolysis products or diesel engine emissions, plus sector guidance and the substance databases of the accident insurers). Where none exists, an in-depth risk assessment is required; it generally calls for the particular expertise of an engineer to design a closed system or other technical measures. The planning and implementation of all technical, organisational and personal measures is accompanied by the occupational-safety specialist or the occupational physician. |
The higher the group, the larger the quantity and the stronger the release, the higher the level. Group E always leads directly to level 4 (seek expert advice).
The EMKG matrix at a glance
Hazard group, quantity and release potential together give the control level. The table shows every combination for groups A to D; group E is not in the matrix, it always leads to level 4.
| Group | Quantity | Release potential | ||
|---|---|---|---|---|
| Low | Medium | High | ||
| A | Low (small) | 1 | 1 | 1 |
| Medium | 1 | 1 | 2 | |
| High (large) | 1 | 1 liq. 2 sol. | 2 | |
| B | Low (small) | 1 | 1 | 1 |
| Medium | 1 | 2 | 2 | |
| High (large) | 1 | 2 liq. 3 sol. | 3 | |
| C | Low (small) | 1 | 2 liq. 1 sol. | 2 |
| Medium | 2 | 3 | 3 | |
| High (large) | 2 | 3 | 3 | |
| D | Low (small) | 2 | 3 liq. 2 sol. | 3 |
| Medium | 3 | 4 | 4 | |
| High (large) | 3 | 4 | 4 | |
Example: group C with quantity "small" and release "medium" is a split cell - liquids give level 2, solids level 1.
Four cells fork by physical state: the value marked "liq." applies to liquids, the one marked "sol." to solids. For an unknown or mixed state the stricter value applies.
Group E always leads directly to level 4 (seek expert advice), regardless of quantity and release.
If the activity takes less than 15 minutes per day, the printed method allows one level lower (level 2 instead of 3, level 1 instead of 2). This does not apply to locally irritant (H335), corrosive (H314), respiratory-sensitising (H334) or strongly odorous substances, and never to level 4. Caventi does not apply this reduction automatically - just like the BAuA online tool - so duration and frequency do not change the level.
The measures build on one another: a higher level includes those of the lower one. Integrated extraction counts as a closed system because of its high effectiveness. The documented assessment can also serve as the hazardous-substance register when the safety data sheet is referenced in it.
One effective lever is release itself: the same substance in a form with lower release (e.g. granulate instead of powder) often reaches a lower level. In the guide's example a group-B solid drops from the 300 series (powder, high release, large quantity) to the 100 series (granulate, low release).
In Caventi this is the "Level 1" to "Level 4" value next to each activity.
A fully worked example: decanting xylene
Here is how the derivation runs for a concrete activity - decanting xylene - from the H statements to the level and the skin contact.
| Step | Result |
|---|---|
| H statements | H226, H332, H312, H315 |
| Hazard group inhalation | H332 ⇒ group B |
| Quantity | decanting in the litre range ⇒ medium |
| Release | boiling point 135 °C ⇒ medium |
| Control level (matrix B / medium / medium) | level 2 - local exhaust at the point of release |
| Skin hazard group | H312 ⇒ HC (H315 ⇒ HB; the highest counts) |
| Contact area / contact time | large / short |
| Skin measures needed (Tab. 7.1) | extended |
In its form-sheet example the guide additionally uses the AGW route (Tab. 1.2, AGW 100 ppm) and thereby reaches group A; Caventi bands exclusively from the classification and therefore assigns xylene to group B.
Ventilation and room size: the workplace inputs
For each workplace you record the ventilation situation and the room size in Caventi. Both are documentation and effectiveness-check inputs - they do not change the EMKG control level.
Ventilation
In the EMKG, ventilation is not an input to the control level but the measure side: level 1 demands good general room ventilation as the minimum standard (guidance sheet 100), level 2 local exhaust at the point of release, level 3 a closed system.
Caventi therefore compares the ventilation present at the workplace (none, natural or mechanical ventilation, local exhaust) with the derived control level and warns when the ventilation on site does not reach the recommended level.
Practical note: ventilation systems must be checked for effectiveness regularly - at least every three years, dust-extraction systems at least yearly. Daily visual and function checks are recommended.
Room size
The room size (small, medium, large) documents the spatial situation of the workplace. It is not an EMKG input and does not change the control level.
It does help with the professional judgement: in a small, poorly ventilated room the same released amount reaches critical concentrations sooner. The input supports the judgement whether general ventilation suffices as the minimum standard, and belongs to the documentation of the working conditions.
Step 8: checking effectiveness
The final step checks whether the measures meet the workplace limit value and stay effective. The duty follows from the law applicable at your site (see "Legal framework" at the end of this page); the EMKG guide describes it as a central requirement for assuring the quality of the measures chosen.
Two goals, with or without measurement
For substances with a workplace limit value (AGW), compliance with it must be proven; for substances without one, the effectiveness of the measures. Both can be done by measurement or without; the EMKG is the non-measurement method.
One category stricter for AGW substances
Anyone using the EMKG as non-measurement proof of AGW compliance must choose the hazard group one category stricter (e.g. group C instead of B). Example isopropanol (AGW 200 ml/m³): measurement would give the 100 series, the non-measurement method the 200 series. Once the 200-series engineering measures are implemented, workplace measurement is no longer mandatory. Caventi does not apply this shift: the application holds no workplace limit values and derives the group from the classification alone. The level it displays is therefore not yet a non-measurement proof of AGW compliance; for that you choose the group one category stricter yourself.
Preparations with AGW ingredients
Mixtures follow a rule of their own, not the one-category bump. Check the ingredient list first: if the mixture contains substances with a workplace limit value, compliance with those limits must be verified, and the higher the share of the substance carrying the limit, the more important the check. The EMKG may serve as the non-measurement method here when the hazard group derived from the mixture's classification is stricter than every group that follows from the limit values of the individual components. The list of ingredients with a limit value is in section 8 of the safety data sheet. Only health-based workplace limit values count for this approach.
Check engineering systems and skin protection
Ventilation systems must be checked for effectiveness at least every three years, dust-capture systems at least yearly; daily visual and function checks are recommended. For skin protection, PPE must be checked for function before use and skin agents for their expiry date; findings from occupational-medical care feed into improvement.
Skin contact: steps 5 to 7 of the EMKG
Besides inhalation, the EMKG assesses the hazard from skin contact. The H statements yield a skin hazard group (HA to HE); together with the contact area and contact time this gives the level of skin measures needed.
Steps 5 to 7 come on top of the measures needed for inhalation. You may skip them only if skin contact is ruled out on technical grounds - merely wearing protective gloves does not count as exclusion.
| Group | Meaning | Governing H/EUH statements |
|---|---|---|
| HA | Low skin hazard | EUH066 |
| HB | Skin irritant | H315 |
| HC | Raised skin hazard | H312, H317, H371, H373 - plus H302/H332 (assumed skin effect) |
| HD | High skin hazard | H311, H341, H351, H361, H372 - plus H301/H331 (assumed skin effect) |
| HE | Very high skin hazard | H310, H314, H340, H350, H360, H370 - plus H300/H330 (assumed skin effect) |
If a substance is known not to be skin-resorptive, the assignment may be dropped, but only for the starred entries of the table: H341, H351 and H361 in HD, and H340, H350 and H360 in HE. The remaining entries (H311, H314, H310, H370, H372) keep their group whatever the resorption data says, because those substances damage the skin themselves or act on contact. Beware of carrier substances such as DMSO, DMF or glycol ethers: they can transport other, non-resorptive substances through the skin. When in doubt Caventi always assigns (the safe side).
Contact area
Small: small-area wetting, such as splashes. Large: large-area wetting, e.g. the whole hand. Indirect skin contact via gases, vapours or aerosols and via contaminated clothing and work equipment counts too. Protective gloves already worn are disregarded in this estimate.
Contact time
Short: under 15 minutes per day. Long: over 15 minutes per day - repeated skin contacts add up over the day. The contact time starts at contamination and ends only at effective removal.
The skin-contact decision table
Skin group, contact area and contact time give the level of measures needed - just as the EMKG matrix gives the control level for inhalation.
| Group | small | large | ||
|---|---|---|---|---|
| short | long | short | long | |
| HA | low | low | low | extended |
| HB | low | extended | extended | extended |
| HC | low | extended | extended | high |
| HD | extended | extended | extended | high * |
| HE | high ** | high | high | high |
The skin measures needed
Wet work - more than two hours in a wet environment, liquid-tight gloves for over two hours, or frequent intensive cleaning or disinfecting of the hands - always demands at least the organisational and hygiene measures of the low level and the technical solutions of the extended level (see above; guidance sheets 120 and 250).
Two special cases soften the result: if group HD stems only from H361, the extended level suffices for a large area and long duration (footnote * in the table). If group HE stems only from H314, the extended level likewise suffices for a small area and short duration (footnote **).
In Caventi you record contact area, contact time and wet work per activity; the result appears as a skin badge (e.g. "Skin HD") next to the activity. When wet work alone triggers the need without a skin group, the badge reads "Wet work".
Measures by the STOP principle
Concrete measures belong to each control approach. The EMKG follows the legal hierarchy STOP: the source first, the person last.
Substitution
First check whether the hazardous substance can be replaced by a less hazardous one. This substitution check is the first duty for every activity with hazardous substances, regardless of the group.
Technical
Engineering measures: ventilation, extraction, closed systems – cumulative as the level rises.
Organisational
Organisational measures: limit exposure time, reduce the number of people exposed.
Personal
Personal protective equipment as the last measure, when the others are not enough.
In addition, Caventi derives skin and eye protection and handling rules from the H statements.
Especially hazardous substances: lock-up and maternity protection
Very toxic, toxic and CMR substances of category 1 and 2 must be kept under lock; only responsible, competent persons may have access, and special instruction is required – this also applies to respiratory-sensitising substances. For substances carrying H361d the rules of the Maternity Protection Act (MuSchG) must additionally be observed. For H360D, H360F, H350 (including H350i) and H340, employment restrictions for expectant and nursing mothers apply.
What is documented
A complete documentation records per activity: the hazardous substance, the classification with workplace limit value and hazard group, quantity and duration, physical state, boiling point and release group, the protective measures for inhalation and skin, and the effectiveness check. It also records the persons involved in the assessment, the result of the substitution examination, and the deadlines for implementing and checking the measures. If additional measures of level 2 (engineering measures) or level 3 (closed system) become necessary, or if carcinogenic, mutagenic or reprotoxic substances of category 1 or 2 are used, the assessment must justify why no substitute substance and no less hazardous procedure was chosen. Caventi produces the technical part automatically; the persons involved, the substitution examination and the deadlines you add yourself. The documentation can also serve as the hazardous-substance register when the safety data sheet is referenced in it.
Legal framework
In Germany, the risk assessment is mandatory under the GefStoffV and ArbSchG. The EMKG assigns the general protective measures of section 8 GefStoffV to control level 1 and the further measures of sections 9 and 10 to the higher levels. It is a recognised BAuA aid for meeting that duty without your own measurements; it is backed by the Technical Rules for Hazardous Substances (TRGS 400, TRGS 500). It remains decision support and does not replace the employer's responsibility.
How Caventi applies the EMKG
Caventi reads your safety data sheets, derives the hazard group and release for every product and computes the control approach for each activity, including STOP measures and PPE. You only maintain the quantity, duration and frequency – the rest comes back as a traceable assessment you can update at any time.
Sources
Basis: BAuA, Einfaches Maßnahmenkonzept Gefahrstoffe (EMKG), guide and mapping of the H/EUH statements. Legal frame: GefStoffV, ArbSchG, TRGS 400 and TRGS 500.
This account is decision support and does not replace a case-by-case risk assessment. The safety data sheet governs and responsibility remains with the employer.
Frequently asked questions about the EMKG
What does the abbreviation EMKG stand for?
EMKG stands for "Einfaches Maßnahmenkonzept Gefahrstoffe" (simple control approach for hazardous substances). It is a control-banding method by the German BAuA for the risk assessment of activities with hazardous substances.
What does the group A to E mean?
The hazard group describes how harmful a substance is to breathe in – from A (low) to E (very high). It is derived from the H/EUH statements; the most severe statement determines the group.
What does the level 1 to 4 mean?
The control approach (control level) says what kind of protective measure is appropriate: 1 = general ventilation, 2 = extraction, 3 = closed system, 4 = seek expert advice. It follows from hazard group, release and quantity.
Do you need measurements for the EMKG?
Usually not. The whole point of the EMKG is to determine an appropriate control approach without your own air measurements, from classification, release and quantity alone. For substances with a workplace limit value this holds only if you choose the hazard group one category stricter; otherwise compliance with the limit value must be proven another way.
The second EMKG module: fire and explosion
Besides inhalation and skin contact, the EMKG assesses the same activity for the fire and explosion hazard - with the hazard group pc-A to pc-E and the control level 1 to 3.
To the EMKG fire and explosion moduleRead more
The EMKG in practiceRisk assessment without a spreadsheet
Caventi assesses every activity by the EMKG: hazard group and control approach derived from your safety data sheets, with STOP measures and PPE.