Germany: PAPR Rules for Welding — ArbSchG, TRGS 528, DGUV Regel 112-190 and TH Classes

Germany regulates welding-fume respiratory protection through a dual system: state law (Arbeitsschutzgesetz, Gefahrstoffverordnung, concretised by TRGS 528 for welding work) and the statutory accident insurers’ rules (DGUV Regel 112-190 for respirator selection and use). PAPR units sold in Germany are CE-certified Category III PPE under Regulation (EU) 2016/425 to DIN EN 12941 (TH classes, helmet/hood) or DIN EN 12942 (TM classes, mask). TRGS 528 lists powered helmets/hoods of class TH2P/TH3P among the respiratory-protection options for welding where fume cannot be controlled at source, and its section 4.7(4) caps “burdening” respirators (over 3 kg, or with breathing resistance — including filtering facepieces) at 120 hours per three months without special authority approval, so non-burdening designs — powered welding helmets/hoods and supplied-air helmets/hoods alike — are preferred for continuous wear. This hub summarises what the regulators and standards state; it is information, not compliance advice. Current as of 6 July 2026.

Which rules apply

German respiratory-protection duties sit in a two-track system. The state track starts with the Arbeitsschutzgesetz (ArbSchG, Occupational Safety and Health Act): section 5 obliges every employer to carry out a risk assessment (Gefährdungsbeurteilung) covering, among other factors, chemical hazards such as welding fume. Below the Act, the Gefahrstoffverordnung (GefStoffV, Hazardous Substances Ordinance) governs work with hazardous substances, and the Technical Rules for Hazardous Substances (TRGS) set out the recognised state of the art. TRGS are drawn up by the Committee on Hazardous Substances (Ausschuss für Gefahrstoffe, AGS), with input from the Committee on Occupational Medicine (AfAMed), and announced by the Federal Ministry of Labour and Social Affairs (BMAS) in the Gemeinsames Ministerialblatt (GMBl); the Federal Institute for Occupational Safety and Health (BAuA) hosts the texts online but does not itself issue them. TRGS 528 ‘Schweißtechnische Arbeiten’ (welding-technical work) is dated 26 February 2020 (GMBl 2020 No. 12/13 of 30 March 2020, p. 236), amended August 2020 (GMBl 2020 p. 463), and is the welding-specific rule. The second track is the statutory accident insurance system: the DGUV and its sector Berufsgenossenschaften issue both legally binding Vorschriften (accident-prevention regulations, Unfallverhütungsvorschriften) and non-binding Regeln, Informationen and Grundsätze that carry a presumption of conformity with the underlying duties rather than binding force of their own. DGUV Regel 112-190 ‘Benutzung von Atemschutzgeräten’ (Use of respiratory protective devices, November 2021 edition, webcode p112190) is one such non-binding Regel and is the central reference document for selecting and using respirators, including PAPR.

Approval and certification of PAPR

There is no separate German national approval for PAPR: devices are placed on the market under Regulation (EU) 2016/425 on personal protective equipment. Respiratory protective equipment against ‘substances and mixtures which are hazardous to health’ is Category III PPE (Annex I). Under Article 19(c) that requires EU type-examination by a notified body (Module B) plus ongoing production conformity via Module C2 (supervised product checks) or Module D (production quality assurance), and under Article 17(3) the CE marking must be followed by the identification number of the notified body. The device standards used in Germany are DIN EN 12941 (powered filtering devices incorporating a helmet or hood — classes TH1, TH2, TH3) and DIN EN 12942 (powered filtering devices with full, half or quarter masks — classes TM1, TM2, TM3). DGUV Regel 112-190 additionally expects a warning device that alerts the wearer to falling or failed blower performance for the higher classes; the accident insurer BG BAU cites its section 10.2.4.5 for this requirement and excludes TH1 devices from its funding scheme precisely because TH1 does not require such a warning device.

Employer and programme duties

The employer’s duties follow the classic German hierarchy. TRGS 528 section 4.1 orders measures as: substitution (choose lower-emission processes and consumables), technical measures (extraction as close as possible to the point of fume generation), organisational and hygiene measures, and only then personal protective equipment — PPE must be used where the relevant hazardous-substance limit values still cannot be met. DGUV Information 209-096 states that, per TRGS 528, the company occupational physician (Betriebsarzt) should be involved in the risk assessment, particularly where exposure to carcinogenic substances is possible. Where exposure to carcinogenic, germ-cell-mutagenic or reproduction-toxic substances of category 1A or 1B cannot be excluded, section 10a of the GefStoffV — ‘Besondere Aufzeichnungs-, Mitteilungs- und Unterrichtungspflichten bei Tätigkeiten mit krebserzeugenden, keimzellmutagenen oder reproduktionstoxischen Gefahrstoffen der Kategorie 1A oder 1B’ — requires an exposure register recording the activity and the level and duration of exposure, retained for at least 40 years after exposure ends for carcinogenic/germ-cell-mutagenic substances (5 years for reproduction-toxic substances); employers can discharge the record-keeping and hand-over duties via the DGUV’s central exposure database (ZED). This provision replaced the former section 14(3), which is now marked ‘(weggefallen)’ (repealed) on the consolidated text, and was broadened to cover reproduction-toxic substances by the GefStoffV amendment in force from December 2024, transposing Directive (EU) 2022/431. Training and instruction of respirator wearers is addressed separately in DGUV Grundsatz 312-190, split out of DGUV Regel 112-190 in the 2021 revision. Occupational medical care duties under the ArbMedVV apply in addition (see the medical-surveillance section).

Welding-fume specifics: TRGS 528

TRGS 528 applies to welding, cutting and related processes on metallic materials that generate gaseous and particulate hazardous substances; ‘welding fume’ is defined as the particulate fraction. Section 4.7 sets the respiratory-protection duty as a backstop, not a fixed dust-concentration trigger: where the measures in sections 4.1 to 4.6 are not sufficient or cannot be technically implemented, the employer must provide, and employees must use, suitable respiratory protective equipment (section 4.7(1)). Permitted device types (section 4.7(2), selected per DGUV Regel 112-190) are: powered helmets/hoods with particle filter TH2P or TH3P; powered masks with TM1P-TM3P filters; full masks or mouthpiece sets with P2 or P3 filters; half/quarter masks with P2 or P3 filters, or filtering facepieces FFP2 or FFP3; or supplied-air/isolating devices such as powered helmets/hoods with external compressed-air supply — with the highest filter class (P3) always required for carcinogenic substances. Suitable combination filters must be used where gaseous hazardous substances are also generated (section 4.7(3)). Burdening respirators (device weight over 3 kg, or with breathing resistance) may not be used as a permanent measure — more than 120 hours in any three-month period — without approval from the competent authority; non-burdening respirators, such as powered welding helmets/hoods, are therefore preferred and are also exempted from the ArbMedVV’s respirator-related medical-surveillance triggers and from DGUV Regel 112-190’s wearing-time limits (section 4.7(4)). Where carcinogenic hazardous substances are released — in particular when welding high-alloy steels and nickel-base alloys, whose fume can contain chromium(VI) compounds and nickel oxides — suitable respiratory protection under section 4.7(2) must be provided, except for low-emission-group processes such as submerged-arc (UP) and TIG (WIG) welding; wear is mandatory above the substance’s tolerance concentration (recommended above its acceptance concentration), and for chromium(VI) compounds mandatory above the risk-based assessment benchmark (section 4.7(5)). For confined spaces (e.g. shipbuilding, box girders, double floors), section 4.7(7) prescribes a five-step approach: ventilation under section 4.3 where possible; powered hoods or helmets where ventilation is spatially impossible or insufficient; FFP3 masks (only — no FFP2 option and no low-alloy/high-alloy split in the current edition) where hoods/helmets cannot be used for spatial reasons; suitable respiratory protection for nitrous gases (half/quarter masks with an NO-P3 combination filter, e.g. for flame straightening), per DGUV Regel 112-190; and isolating (self-contained/supplied-air) equipment where oxygen deficiency is possible. Separately, TRGS 528 section 6 (concretising Annex Part 1 of the ArbMedVV) sets a distinct welding-fume medical-surveillance trigger: mandatory occupational care (Pflichtvorsorge) applies once airborne exposure to welding fume exceeds 3 mg/m3 (respirable A-fraction), and offered care (Angebotsvorsorge) applies at or below that level — this is a medical-surveillance threshold, not the trigger for providing respiratory protection. For comparison, the general workplace dust limit under TRGS 900 is a separate, lower figure of 1.25 mg/m3 (A-fraction), used to assess general dust exposure rather than welding fume specifically.

Selection and protection levels: TH classes under DGUV Regel 112-190

DGUV Regel 112-190 (November 2021) structures selection as a step-by-step process with flow diagrams and assigns each device class a ‘Schutzniveau’ (protection level — the multiple of the limit value up to which the device may be used; the 2021 edition replaced the older term ‘Vielfaches des Grenzwertes’). For powered filtering devices with helmet or hood to EN 12941 the protection levels are: TH1 = 5, TH2 = 20, TH3 = 100. For powered filtering devices with mask to EN 12942: TM1 = 10, TM2 = 100, TM3 = 500. The rule also notes a critical limitation of helmet/hood devices: if the blower fails or its output drops, they no longer provide adequate protection — hence the warning-device expectation for TH2/TH3. For welding work, TRGS 528 section 4.7(2) lists TH2P/TH3P powered helmets among the permitted device types, and DGUV Information 209-096’s worked example records that a TH2/TH3 powered welding helmet is sufficient under TRGS 528. Because helmet/hood PAPR imposes no significant weight or breathing resistance, TRGS 528 section 4.7(4) treats it — like other non-burdening RPE, e.g. supplied-air helmets/hoods — as suitable for continuous wear, whereas burdening respirators (over 3 kg, or with breathing resistance, which includes filtering facepieces) are capped at 120 hours per three months without special authority approval; filtering facepieces are, in practice, an interim solution for extended limits-exceeding work rather than a category the rule singles out by name.

Medical surveillance and wearer fitness

Occupational medical care for respirator wearers is governed by the ArbMedVV (Ordinance on Occupational Medical Care), with devices classified into groups 1-3 by AMR 14.2 ‘Einteilung von Atemschutzgeräten in Gruppen’ (GMBl 2014, last amended 2016) according to device weight and inhalation/exhalation resistance. Wearing group 2 or 3 devices triggers Pflichtvorsorge (mandatory medical care) under Annex Part 4 of the ArbMedVV; group 1 devices (under 3 kg, no relevant breathing resistance) trigger only Angebotsvorsorge (care that must be offered) when worn more than 30 minutes per day. Powered helmet/hood devices, which supply air without breathing resistance, are treated as the lowest-burden category — BG BAU states that wearing such devices alone does not require Pflichtvorsorge, citing DGUV Information 240-260 No. 4.3. Independently of the device, welding-fume exposure itself creates a separate set of care triggers under TRGS 528 section 6 (concretising Annex Part 1 of the ArbMedVV): mandatory care (Pflichtvorsorge) applies once airborne exposure to welding fume (from welding and thermal cutting of metals) exceeds 3 mg/m3 measured as the respirable A-fraction, offered care (Angebotsvorsorge) applies where the risk assessment shows this value is reliably kept below 3 mg/m3, and post-exposure care (nachgehende Vorsorge) follows exposure to category 1A/1B carcinogens such as chromium(VI) compounds, nickel oxides or cobalt metal, with examinations per the DGUV recommendation ‘Schweißen und Trennen von Metallen’ (successor to the former ‘G 39’-style Grundsätze). This 3 mg/m3 figure is a medical-surveillance threshold and is distinct both from the section 4.7 respirator-provision duty (which has no fixed concentration trigger) and from the general workplace dust limit of 1.25 mg/m3 (A-fraction) set by TRGS 900.

The Berufsgenossenschaften: BGHM, BG BAU and funding for PAPR

The DGUV (Deutsche Gesetzliche Unfallversicherung) is the umbrella of the statutory accident insurers (Berufsgenossenschaften). Most welding businesses fall under the BGHM (Berufsgenossenschaft Holz und Metall — wood and metal); construction trades fall under BG BAU. These bodies do more than insure: they issue and co-author the applicable prevention documents — DGUV Information 209-096 ‘Schweißrauchminderung im Betrieb’ (August 2023) was produced by the DGUV expert committee for wood and metal, with BGHM involvement, and is distributed via bghm.de. Several BGs also subsidise PAPR purchases. BG BAU’s Arbeitsschutzprämien scheme (device list dated 27 October 2025) funds powered filtering starter packages that meet defined criteria: blower unit to DIN EN 12941 class TH3 or TH2, head-top with industrial safety helmet to DIN EN 397, at least 4 hours blower runtime on a full battery and new filters, and a low-flow warning device per DGUV Regel 112-190 section 10.2.4.5. The funded welding lists name specific systems and part numbers, including 3M Adflo with Speedglas 9100 MP, CleanAIR CA-40 packages, GVS PX5 with Z-Link, Optrel Swiss Air and e3000x with HELIX helmets, and Sundström SR 500/SR 700 with SR 580/SR 575 helmets.

What changed recently and what is changing

Current as of July 2026, the key recent movements are: (1) TRGS 528 was fully revised on 26 February 2020 (GMBl 2020 No. 12/13, p. 236) and amended in August 2020 (GMBl 2020 p. 463), sharpening the emission-class-based risk assessment and the respirator triggers, including the carcinogen provisions for high-alloy steel welding. (2) DGUV Regel 112-190 was reissued in November 2021, replacing the 2011 BGR/GUV-R 190 edition: content was restructured around the selection process, a new section on fit testing (Anpassungsprüfung) was added — including quantitative fit checks where CMR substances are involved — ‘Gebrauchsdauer’ replaced ‘Tragezeit’, ‘Schutzniveau’ replaced ‘multiple of the limit value’, and training was split into the new DGUV Grundsatz 312-190. (3) DGUV Information 209-096 (August 2023) introduced a structured in-company welding-fume reduction programme and confirms TRGS 528’s rule that only non-burdening respiratory protection (under 3 kg, no significant breathing resistance — typically powered welding helmets/hoods, though other non-burdening designs qualify) may be used as a permanent measure under section 4.7(4), with burdening devices such as filtering facepieces capped at 120 hours per three months absent special authority approval; it also notes that recirculating filtered air when welding high-alloy steels is only permitted with extraction equipment tested to DIN EN ISO 21904-1. (4) The GefStoffV was amended with effect from December 2024, transposing Directive (EU) 2022/431: the former exposure-register duty in section 14(3) was repealed (‘weggefallen’) and replaced by a broader, renumbered section 10a covering carcinogenic, germ-cell-mutagenic and now also reproduction-toxic substances of category 1A/1B, with retention periods of 40 years (carcinogens/mutagens) and 5 years (reproduction-toxic substances). (5) BG BAU’s funded PAPR device list was refreshed on 27 October 2025.

Sources & disclaimer

This page is information, not legal or safety advice. It summarises the cited public sources as of the date above; regulations change — verify against the primary source before relying on it. Product-level approval status is covered by our four-tier compatibility system.