Germany sets the benchmark

The new TRGS 561 of the Committee for Hazardous Substances and the model operating instructions of the BG BAU

With the version of May 4, 2026 (GMBl 2026 pp. 308–336), TRGS 561 “Activities with carcinogenic metals and their compounds” describes for the first time what happens to insulated, chromium-alloyed hot parts. The previous version had not covered this area of application.

In parallel, BG BAU provides a sample operating instruction for the " removal of chromate-contaminated insulation materials " in its hazardous substance information system WINGIS.

This means that in Germany there are two documents that definitively classify the topic and make it tangible for practical application: one sets the rules, the other implements them on the construction site.

What TRGS 561 specifies

Section 3.3.4 paragraph 5 states that chromium(VI) compounds can form on thermally stressed chromium-alloyed industrial components, such as steam pressure lines or turbine housings, and can be deposited on the surrounding components.

This can lead to relevant exposure of employees during work such as the dismantling of insulation systems or the maintenance of exhaust systems .

The newly added section 5.9.3 goes into further detail .

The TRGS lists the following influencing factors: operating temperature, chromium content of the alloy, reaction time, atmospheric oxygen and moisture on the steel surface, as well as the presence of alkali and alkaline earth metal oxides, e.g. from insulating materials or assembly pastes.

It notes that chromium(VI) compounds can accumulate in the insulation materials and that workplace measurements show exposures above 1 µg/m³, especially during revisions, dismantling and troubleshooting .

This 1 µg/m³ is not a mere formality. According to section 3.3.4 paragraph 2, this concentration corresponds to an additional lung cancer risk of approximately 4 in 1000 over a working lifetime; above this level, there is a high risk .

When working on industrial components where chromium(VI) contamination is present or cannot be ruled out, it is necessary to implement protective measures in accordance with the requirements of chapters 4.1 and 4.2.

For work on contaminated or unsafe components, section 5.9.3 paragraph 5 refers to the protective measures of sections 4.1 and 4.2 and supplements them with chemical protective suits type 5 with hood, nitrile-coated gloves, eye protection, respiratory protection of at least FFP2 or P3 for longer work periods and the covering of gratings .

The first item listed in section 4.1 paragraph 1 is substitution :

The employer must examine the possibility of substitution with substances or mixtures that pose a lower health risk and implement this as a priority. Technical measures take precedence over organizational and personal measures (4.1 paragraph 2) .

Removal of chromate-contaminated insulation materials "These activities or processes are carcinogenic" Danger!

The BG BAU's model operating instructions classify the removal of chromate-contaminated insulation materials as a carcinogenic activity with the signal word "Danger" .

Among other things, it demands:

• demarcated work areas with "No unauthorized access" signs

• Chromium-reducing fiber binders and low-dust processes ,

• Dust extraction and dust removal of dust class H; no blowing with compressed air, no dry sweeping ,

• a black and white facility with separate changing rooms and showers ,

• Respiratory protection P3 or FFP3 “always” and disposable protective suit type 5 ,

• Waste is collected directly at the point of origin in labeled bags or big bags .

In addition, there is a requirement that is easily overlooked:

Used mineral wool products must not be reused.

This means that the removal of insulation from hot parts will be treated organizationally in the same way as other work involving carcinogenic substances. Anyone who previously planned a revision as routine work will now have to plan these works as a renovation.

The workplace, previously considered normal and safe, is thus transformed into a special construction site; a large part of the measures are reminiscent of asbestos remediation regulations.

Danger not only in power plants

In its technical publication on potential chromium(VI) exposure, the BG ETEM (German Social Accident Insurance Institution for the Energy, Textile, Electrical and Media Industries) states that , according to current knowledge, all industries where these influencing factors coincide can be affected. It mentions, among others, coal, biomass and gas power plants, combined heat and power plants, heating plants, waste incineration plants and chemical plants, as well as chromium-alloyed screw connections on turbine housings and flanges .

The metrological services of the employers' liability insurance associations carry out further measurements during maintenance work and are looking for companies whose systems may be affected by the problem.

We are aware of affected companies and also of laboratories specializing in chromium(VI) analysis that have signaled their support to the employers' liability insurance associations, but unfortunately there has been no response so far.

What this means for operators and insulation companies

The duties are clearly described:

Risk assessment, written operating instructions before commencing work, instruction on exposure levels and risk areas, use of competent or job-specific trained persons (4.1 paragraph 4 no. 2) .

Every revision of an insulated, chrome-alloyed component thus becomes a process that must be prepared, documented and secured.

The substitution test aims to identify the cause. If the TRGS (Technical Rules for Hazardous Substances) lists alkali and alkaline earth metal oxides from insulation materials as an influencing factor, then the choice of insulation material itself must be included in the test.

Insulation that does not contain these oxides eliminates one of the factors mentioned in the TRGS (Technical Rules for Hazardous Substances).

This is not a question of marketing, but rather the ranking that the rules themselves dictate:

first substitution,

then technology ,

then organization ,

Lastly, personal protective equipment.

Conclusion

With the TRGS 561 in the version of May 2026 and the model operating instructions of the BG BAU, Germany has for the first time created a clear framework that names the cause, risk and protective measures.

Operators and specialist companies that implement it now are prepared for their next inspection. Those who choose insulation during new construction or renovation in such a way that chromate does not form in the first place will have less work during future inspections.

Sources: TRGS 561, edition May 2026, GMBl 2026 pp. 308–336, sections 3.3.4, 4.1, 5.9.3; TRGS 561, version of October 4, 2017, GMBl 2017 No. 43 p. 786 (repealed on May 4, 2026); BG BAU / GISBAU, WINGIS online: Operating instructions “Removal of chromate-contaminated insulation materials” (accessed May 23, 2026); BG ETEM: “Possible chromium(VI) exposure”, web code 23391453 (accessed May 23, 2026)