OSH in Hamburg The inspection concept

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1 OSH in Hamburg The inspection concept Hamburg

2 Abbreviations ASMK Arbeits- und Sozialministerkonferenz - Conference of the German regional ministers of labour and social affairs GDA Gemeinsame Deutsche Arbeitsschutzstrategie - Common German OSH Strategy LASI Länderausschuss für Arbeitsschutz und Sicherheitstechnik - Commission for occupational safety and safety engineering of the German regional governments OSH Occupational safety and health SCS Surveillance, consultancy, system audits SME Small and medium-sized enterprises According to the EU definition, small enterprises are those with fewer than 50 employees, medium-sized enterprises those with between 50 and 249 employees.

3 CONTENT 1 FUNCTIONS AND ORGANIZATION OF THE OCCUPATIONAL SAFETY AND HEALTH DEPARTMENT 3 2 TERMS OF REFERENCE German Occupational Safety and Health Act Common German OSH Strategy, European Community strategy on health and safety at work Changes in the world of work 6 3 TARGETS Adaptation to the structure of the economy in Hamburg Joint activities 8 4 THE HAMBURG INSPECTION CONCEPT Principles System audits Projects Circumstantial tasks Special areas of activity Exposure Assessment Division Consumer protection 13 5 QUALITY INSURANCE AND QUALITY IMPROVEMENT Quality management Data resources Qualification of the personnel EVALUATION AND FURTHER DEVELOPMENT 16

4 THE INSPECTION CONCEPT SURVEILLANCE, CONSULTANCY, SYSTEM AUDITS In accordance with the German Occupational Safety and Health Act, surveillance, consultancy and system audits (SCS) have been the key elements in the Hamburg inspection concept of the Occupational Safety and Health Department since Within this concept, the focus of our staff's activity in companies lies upon information, consultancy and advocacy. Where necessary, however, the department also exercises its jurisdiction. Systematic inspection of in-plant OSH organization is the cornerstone of the inspection concept, the aim of which is the continual improvement of occupational safety and health. Progress has chiefly been observed in large enterprises; in the last ten years, the Occupational Safety and Health Department has therefore concentrated its efforts upon improving occupational safety and health in small and medium-sized enterprises (SMEs) in particular, and will continue this policy in the future. The elements of the inspection concept are presented below. The concept constitutes the basis for our work within companies in Hamburg. 2

5 1 FUNCTIONS AND ORGANIZATION OF THE OCCUPATIONAL SAFETY AND HEALTH DEPARTMENT The mission of the Occupational Safety and Health Department is to assure the safety of employees in companies and public bodies in Hamburg, to protect their health comprehensively, and to contribute to a human-centric organization of work. The Occupational Safety and Health Department, equivalent to the OSH departments and labour inspectorates of the other German regional authorities, is part of the Health and Safety Office. Traditional activities of the department are: The design of working premises, including occupational hygiene The safe use and operation of engineered work equipment The safe and proper use of hazardous materials and biological agents The observance of regulations governing working hours The protection of particular population groups, such as pregnant women, in an occupational context, children and young people Owing to changes in the world of work and the extended scope of the German Occupational Safety and Health Act, other areas of activity are becoming increasingly important: Inspection of in-plant OSH organization Avoidance of work-related diseases and promotion of human-centric work design Elimination of mental strain in working life Consideration for demographic change Ergonomic design of workplaces and work procedures Use of methods for in-plant health promotion and organizational development As a department within the Health and Consumer Protection Office, we also assume responsibility for tasks in the area of consumer and patient protection: Under the Atomic Energy Act, and in particular the Radiation and X-ray Regulations Under the Chemicals Act, with regard to the duties of manufacturers, distributors and importers concerning the placing of substances and formulations on the market Under the Explosives Act and its associated regulations The Exposure Assessment Division provides analytic capacity for the performance of competent measurements at workplaces. This particularly concerns measurements of: Organic, inorganic and biological agents Physical exposure factors The assessment of products and chemicals 3

6 The Occupational Safety and Health Department is sub-divided by sector and subject. The subdivision of our department by sector into four divisions, each of which is responsible for surveillance and consultancy in companies within specific sectors, enables us to monitor sectorspecific developments in occupational safety and health appropriately, and to exploit the specific expertise of our staff adequately. Within the divisions, groups of three to five persons work in key sectors, which are based upon the sectoral classification of LASI. Staff are assigned to specific sectors, in which they then monitor developments and maintain contacts with the relevant industry associations and guilds. Within the key sectors, concepts for the inspection activity are produced based upon inspection plans, and the focus of sectorspecific projects is defined. 4 The work of cross-sector subject groups is geared to the traditional OSH issues listed above, and to emerging issues. The subject groups ensure that "enforcement" is based upon a consistent view within the department. They also ensure that all staff receive information on changes to provisions and new developments, and that further training is provided where necessary. Within the subject-specific working groups, close co-operation with the Department of Ministerial and Legal Affairs is assured. Within the divisions, staff from a range of disciplines work closely together, pooling their expertise. At present, the staff includes skilled craftspeople, technicians, engineers, scientists and occupational physicians.

7 2 TERMS OF REFERENCE 2.1 German Occupational Safety and Health Act The entry into force of the Occupational Safety and Health Act in 1996 resulted in a far-reaching paradigm shift in occupational safety and health. The substantially stricter requirements upon employers, for example to produce hazard assessments and in the process also to consider mental and social strain, presented new challenges for the state labour inspectorates. This was reflected in the decision passed by the 73rd conference of the German regional ministers of labour and social affairs (ASMK) in 1996, the core statement of which was: "In future, the OSH administration's activities must cease to be driven by spot checks, which are largely inefficient; instead, the surveillance of systems, audits of OSH management systems, consultancy (particularly in the promotion of good health), joint projects, and the launching of participative processes must take precedence over penalties." This decision also ushered in a fundamentally new approach to the functions of the Hamburg Occupational Safety and Health Office. The decision was implemented in 1998 in the form of the Hamburg SCS occupational safety and health model: surveillance, consultancy, system auditing. It has been revised and developed further several times in the intervening years. The essential principles have remained the same, however. 2.2 Common German OSH Strategy, European Community strategy on health and safety at work Since 2003, the ASMK has adopted a number of decisions addressing the ongoing development of "health and safety at work" as an area of policy. The discussion process was completed in 2005 with a decision by the 82nd ASMK committing to further development of the Dual System. In the subsequent resolutions, the German regional and national governments and the statutory accident insurance institutions received the mandate to implement the Common German OSH Strategy (GDA) in programmes of action, and to prepare an evaluation of its implementation. In fulfilment of this mandate, the German national and regional governments and the accident insurance institutions produced a strategic paper on the Common German OSH Strategy and on targets based upon it for occupational safety and health and organization (2006), together with a detailed concept document (2007). At local level in Hamburg, the Occupational Safety and Health Department is involved in the Common German OSH strategy in a number of joint projects relating to the key topics. The framework for the Common German OSH Strategy and thus also the orientation of our department's inspection concept is defined through the European Community strategy on health and safety at work, 5

8 6 which was last updated for the period from 2007 to The focus of the EU strategy lies upon particular support for SMEs. For us, this includes promoting and supporting: The development and dissemination of simple instruments for facilitating risk assessment The dissemination of good practice at local level Better access to information Better access to external, high-quality prevention services at affordable prices for SMEs Changes in the world of work Owing to the shift in the spectrum of exposure in the world of work and structural changes to the economy, the labour inspectorates must continually adjust their concepts to changes in the terms of reference. The transfer into plant practice of the results of research into new risks presents a continual challenge for the state labour inspectorates. For us, this means that stresses such as mental strain or musculoskeletal disorders must be considered with an eye to the future during planning of central issues and the structure of the organization. The same applies to changes in the world of work which are the result of demographic change or the growth of "precarious" employment conditions. Against this background, the Hamburg inspection concept has been developed further in recent years. Since 1995, organization of the department has been modified in a number of stages. In the process, consideration has been given to the changes in Hamburg's economic structure and to the shift in principal forms of exposure among employees: although Hamburg continues to be a significant centre of manufacturing industry, the greater part of the workforce can be found in the service sector. For this reason, it was ensured that in each of the department's four divisions, sectors were represented from both manufacturing and the service industries. For subjects such as mental and ergonomic strain, new interdisciplinary subject-specific working groups were created, as they also were for the particular issues facing SMEs. 1 SME: Small and medium-sized enterprises According to the EU definition, small enterprises are those with fewer than 50 employees, medium-sized enterprises those with between 50 and 249 employees.

9 3 TARGETS 3.1 Adaptation to the structure of the economy in Hamburg The objective of the Hamburg SCS inspection concept is to promote occupational safety and health in Hamburg; as such, it transposes the European Community strategy for safety and health at work and the Common German OSH Strategy. Our annual focus particularly in project planning is geared to the requirements of these strategies, and we ensure that a substantial part of our own surveillance activity is devoted to attainment of the common targets. At the same time, the Occupational Safety and Health Department must satisfy the particular needs of Hamburg as a commercial location. These are characterized by Hamburg's status as an autonomous city state, and also by the major role of the port for the entire economy of the city. In this context, the sectors devoted to the transport and distribution of goods and to trade are also of key importance for OSH in Hamburg. The city continues to be a significant manufacturing location, with a focus upon aircraft construction and shipbuilding, metallurgical processes, and the chemical and petrochemical industries. New industries such as the health products and services sector are also increasing in importance. The service sector has a dominant role in Hamburg, the focus here being upon publishing, insurance and media. This sectoral make-up primarily describes the larger enterprises. Over 95 percent of businesses in Hamburg are SMEs, with fewer than 250 employees. For this reason, it was decided as early as 1998, with the adoption of the SCS inspection concept, that the OSH systems of large enterprises should be audited and their inspection intervals extended according to the results, thereby enabling more resources to be devoted to activities in SMEs. 7

10 8 Employees in selected sectors of the economy in Hamburg, 2007 Banking and insurance Other Transport and communications Manufacturing industry 10% 9% 14% 6% In order for a broad impact to be attained among the approximately 100,000 SMEs in Hamburg, sectoral projects are conducted in conjunction with guilds, industry associations and other bodies, and in the form of targeted public information work. In this context, our department increasingly regards itself as a prime mover and coordinator of OSH activities which benefit SMEs. 3.2 Joint activities Construction sector 4% 17% Trade 22% 18% Business-tobusiness services Public and private services (excluding public administration) Employees subject to compulsory social charges, total: Source: Statistikamt Nord, Statistische Berichte A VI, 5 June 2007 Our strategy is to exploit joint activities and co-operation with all institutions and associations of relevance to occupational safety and health in Hamburg. Such activity is frequently conducted jointly with guilds and industry associations at sectoral level with reference to the OSH issues in the sectors concerned. In addition, co-operation between state bodies, commerce, industry associations, employers' and employees' representative bodies, and the statutory accident insurance institutions in Hamburg assumed a new form in 2005 with the creation of the "ArbeitsschutzPartnerschaft Hamburg" OSH partnership. The parties involved aim to promote both competitiveness and health and safety at work by conducting joint activities. For this purpose, they contribute their skills for the development of carefully selected in-plant solutions. Occupational health and safety is to be organized more efficiently by means of modern, serviceoriented surveillance methods, joint ventures addressing specific issues and sectors, and greater responsibility on the part of employers and employees. The OSH partnership is based upon a common understanding of modern occupational safety and health: the desires on the part of industry, health policymakers, and employers and employees for competitive companies and human-centric working conditions which are conducive to good health should be made compatible with each other. Individual projects are conducted by the partner bodies under the umbrella of the ArbeitsschutzPartnerschaft OSH partnership.

11 4 THE HAMBURG INSPECTION CONCEPT 4.1 Principles The cornerstone of the Hamburg inspection concept is the assignment of companies to the categories A, B and C according to hazards and exposure. All companies listed in the Occupational Safety and Health Office's registry of commercial and public premises are assigned a sector number according to a classification system of the Federal Office of Statistics. The system of sector numbers distinguishes according to commercial class, and is applied uniformly throughout Germany by all OSH authorities. Based upon the combination of the sector number and the size class, each company in the database is assigned to one of the hazard categories A, B or C, according to an algorithm used within the department: Category A companies Approx. 400 companies Category B companies Approx. 16,000 companies Category C companies Approx. 50,000 companies Category A companies exhibit a complex exposure spectrum. They are classified individually, based essentially upon their specific hazard potential. The hazard potential includes: The handling of large mass flows The use of hazardous substances or energy Above-average risk of fire and explosion A high potential of physical hazard to employees in the form of noise or vibration The moving of heavy loads Major use of machinery Particular manufacturing technologies Large service companies with a complex corporate structure and range of exposures may also be classified in Category A, however. Companies with an extended scope of duties under the terms of the Hazardous Incident Regulation are by definition Category A companies. All companies with a medium hazard potential and high accident rates, such as craft companies and other companies in general with over 50 employees (or 100 employees in the case of office staff) are assigned to Category B, unless they have already been placed in Category A. All other companies are assigned to Category C. Based upon these principles, the surveillance and consultancy activity is concentrated upon the following components: Category A companies System audits, i.e. review and assessment of the integration of occupational safety and health into the corporate organizational and procedural structure Inspections launched by the office based upon the results of the system audit Circumstantial inspections and consultancy 9

12 10 Category B companies Sector-specific projects addressing key sectoral issues and conducted primarily in conjunction with affected institutions (the statutory accident insurance institutions for the industrial sector, guilds, industry associations, etc.) and supported by selective publicity work (e.g. codes of practice, brochures, information events) Projects for reinforcing systematic occupational safety and health in SMEs Inspections in Category B plants launched by the office, during which the organization of occupational safety and health is reviewed against a checklist for SMEs which is drawn up specially for the purpose Circumstantial inspections and consultancy Category C companies Circumstantial inspections and consultancy In some cases, involvement in projects for Category B companies 4.2 System audits System audits examine the integration of occupational safety and health into the existing corporate organizational and procedural structure, in conjunction with spot checks of adherence to regulations in plant practice. The system audit list employed for this purpose covers all important aspects of OSH organization at plant level. A comprehensive system audit list exists for Category A and large Category B companies, and an abridged checklist for small and medium-sized enterprises. System audits in Category A and large Category B companies are announced in advance with agreed dates and with provision of the system audit list. The required contacts are the company management, the works council, the OSH professional, the company physician, and the relevant supervisory staff and employees where spot checks are performed on-site. In SMEs, system checks are performed in the course of plant inspections. The focus of system audits lies upon performance and documentation of the inplant hazard assessment. All companies which have been subjected to a system audit are assigned to one of the following groups: Group I Companies with an exemplary OSH system Group II Companies which satisfy the OSH regulations in every respect Group III Companies which do not fully satisfy the OSH regulations Companies are assigned to a group based upon the assessment performed at the end of each section of the system audit list, in conjunction with the spot checks performed on site. Should a company be placed in Group III, the system audit ends only when classification in Group II is possible. For Group I companies, i.e. those with an exemplary OSH system, "OSH recognition" can be declared for a fixed term;

13 the criteria for this declaration over and above the requirements for Group II are as follows: Occupational health and safety forms an integral part of company policy Dedicated processes for human-centric work arrangements Number and severity of accidents below the average for the sector The criteria for OSH recognition for SMEs are adjusted to their in-plant conditions. The status is awarded for OSH arrangements which are exemplary. Companies in Hazard Category A which have been classified in Group III are subjected to an annual inspection. The strategy and focus of the inspection are defined by the staff responsible, at their own discretion and in writing. Where the system audit has resulted in classification in Categories I or II, inspections are performed at longer intervals (3 and 2 years respectively). 4.3 Projects Since global surveillance in SMEs is not possible, an approach involving sectoral projects was developed within the inspection concept as early as Together with the system audits, these projects form the core of the inspection concept. Greater coverage is attained by the inspection of companies in a sector, involvement of and co-operation with the relevant industry associations and guilds, and targeted public information work. The profile of the sector-specific projects is planned with great care. The topics and target groups are selected in the key sectors and units in consultation with the divisional management. Projects concerning cross-sector topics such as protection for non-smokers or lifting and carrying may also be carried out. The majority of projects focus upon supporting SMEs in the performance of hazard assessments. The project topics are primarily selected based upon: Principal hazards and forms of exposure identified in the sectors during the department's own surveillance activity and the pooling of experience with other German regional authorities, statutory accident insurance institutions for the industrial sector, and employers' and employees' representative organizations The evaluation of relevant literature and the department's own data (such as occupational accident and disease statistics, specialist journals) Further developments in occupational safety and health observations, the state of the art, or changes to regulations Foci of the European Community strategy on health and safety at work and the Common German OSH Strategy Agreements reached in the ArbeitsschutzPartnerschaft OSH partnership The projects are planned, prepared and executed in conjunction with partner bodies. Internal measures within the department ensure that the essential 11

14 12 planning variables are recorded uniformly. Interim project progress reports are mandatory; the relevant project plan is reviewed and updated in this context. The projects are primarily performed in Category B companies, and in some cases also in Category C companies. Category A companies may also be involved for certain subjects. 4.4 Circumstantial tasks Some procedures arise in response to topical external or internal events. In particular, these are: Occupational accidents Reported cases of occupational disease Applications submitted under the Hamburg building by-laws and the German Federal Control of Pollution Act Applications for exemption from the statutory OSH regulations in force Complaints made by employees or members of works and staff councils concerning deficits in occupational safety and health in a plant All reported serious occupational accidents are investigated at the site; the cause of the accident is identified, together with any measures to be taken immediately where applicable. Where necessary, the facts of the case are determined. These may be employed in civil or criminal proceedings. Statements concerning occupational safety and health in response to building applications and applications made under the Federal Control of Pollution Act are processed to fixed deadlines. Receipt and dispatch of the applications is recorded in a separate database. Structuring of the statements is facilitated by the availability of text modules developed by the subjectspecific workgroups. The use of standard forms facilitates assessments of and rulings upon applications for exemptions from various statutory provisions, such as those governing working hours. Complaints made by employees, frequently anonymously, to the central OSH hotline are always followed up, generally by an inspection which if at all possible does not reveal the reason for its performance. In the course of investigations into reported cases of occupational disease, the results of investigations by the statutory accident insurance institutions are presented to the medical OSH inspectorate in the Occupational Safety and Health Department for assessment of the causal relationship between the occupational activity and the disorder. The factory medical inspectors assess the issue of a possible relationship in a concluding report. Individuals who have contracted occupational diseases may consult the medical OSH inspectorate regarding medical issues. 4.5 Special areas of activity Owing to the very specific provisions governing them, certain areas of occupational safety and health and consumer protection are dealt with by particular persons or groups. These areas are: radiation protection, genetic engineering, explosives, remediation of contaminated facilities, the protection of

15 pregnant workers, and the employment of minors. Inspections and projects are conducted with regard to particular issues in these units and at their discretion. In some cases, the procedures followed differ considerably from those in generic occupational safety and health, and are governed by special procedural instructions. Protection for specific groups particularly concerns pregnant workers, decisions concerning termination of employment during parental leave, and the granting of approval for the employment of minors. In the Radiation Protection Unit, notifications and applications for approval which fall under the Radiation and X-ray Regulations are processed, and company inspections focusing upon radiation protection issues performed at the instigation of the unit itself, in some cases in the context of projects. The Genetic Engineering Unit deals with occupational safety and health issues in installations which are subject to the legislation governing this area. The Explosives Unit issues licences in accordance with the German Explosives Act. The Contaminated Sites Unit monitors occupational safety and health on contaminated sites undergoing remediation. All members of staff in these units may also be involved in sectoral projects or conduct projects of their own. 4.6 Exposure Assessment Division In the Exposure Assessment Division, chemical and physical measurements are conducted in support of the inspection and consultancy activity performed by the other divisions. The tasks include measurement and assessment of hazardous substances in workplace atmospheres/physical exposure, consultancy concerning engineered measures for abatement of this exposure, selected chemical and physical product inspections, and information on hazardous substances. These services are delivered by the Exposure Assessment Division in support of the various projects conducted by the other divisions. In addition, the Exposure Assessment Division conducts projects of its own concerning special subjects relating to chemical or physical exposure. 4.7 Consumer protection Among the functions of the Occupational Safety and Health Department are consumer protection tasks within the scope of the chemicals legislation. The department monitors the distribution of hazardous substances and formulations, and follows up consumer protection warnings and complaints by consumers. It also serves as the regional reception point for chemicals. In such cases, the department responds to events. Active market surveillance is conducted in consideration of central issues, in the context of projects. 13

16 5 QUALITY INSURANCE AND QUALITY IMPROVEMENT Quality management Under the terms of its annual agreement with the director of the Occupational Safety and Health Office, the Occupational Safety and Health Department is required to meet mandatory targets. These relate to various parameters (such as certain inspections and system audits) and to attainment of the targets described for projects. Attainment of the targets is reviewed quarterly; for the projects, reports are produced biannually. In 2000, a quality management system to DIN EN ISO 9001 was introduced in the Occupational Safety and Health Department which is closely linked to the generic quality management system of the Consumer Protection Department. All essential core and auxiliary processes are described in procedural instructions, and are continually updated. The quality management system is reviewed by internal audit every four years and by regular management assessments. The Exposure Assessment Division possesses its own quality management system based upon the EN standard "General requirements for the competence of testing and calibration laboratories". 5.2 Data resources Companies in Hamburg are listed in our department's registry of commercial and public premises in accordance with the classification system. A company's size, its assignment to a sector of industry and the district of Hamburg in which it is located automatically result in it becoming the responsibility of a particular member of staff. Each member of staff is the contact person for the companies assigned to him or her in all occupational safety and health matters. The special areas stated under 4.5 constitute exceptions and are handled by the units. All departmental business is recorded in the specialist database together with the department's registry of commercial and public premises. The registry of commercial and public premises is part of a database system created specifically for our department and comprising the following program components: Commercial and public premises information system Comments on construction projects Exposure database (EDL) Hazardous substances database of the regional authorities (GDL) Documentation of occupational diseases Radiation protection Regional accident data of the statutory accident insurance institutions (10% statistic) Special modules for asbestos remediation work and construction work performed in compressed air

17 Where field services have been performed at a site with a permanent address, the data are archived for the plant in the record for the site concerned. Other inspections, for example on construction sites or oceangoing vessels, and other field services, such as discussions concerning joint activity, trade events and court hearings, are not archived by company. Traceability of the field services is assured by virtue of the results being recorded in writing by the staff responsible and archived in accordance with a system described by procedural instructions. The specialist database offers numerous search functions and constitutes a key instrument for comprehensibility, planning and control of the department's fulfilment of its responsibilities. The plant data are improved and updated continuously. In line with the Common German OSH Strategy, the plant data are handled in such a way that they can be exchanged with the statutory accident insurance institutions. In future, this exchange of data will form the basis for a co-ordinated division of field operations between the statutory accident insurance institutions and the Occupational Safety and Health Department Qualification of the personnel The surveillance and consultancy staff in our department possess at least two years' vocational experience as skilled craftspeople, technicians, engineers or scientists prior to their employment at the Occupational Safety and Health Office. In addition, all staff employed in general factory inspectorate functions complete a 1?-year course of training at the office at the beginning of their employment, during which they are familiarized with the comprehensive body of rules and regulations and the methods for their application within companies. The factory medical inspectors employed in the Occupational Safety and Health Department are all qualified specialists in occupational medicine. A comprehensive programme of further training ensures that all members of staff are informed of changes in the legal terms of reference, and that account is taken of personal training requirements. Courses are also held regularly by which methodical and social skills and teamforming and leadership ability are improved. Hazard assessments are performed continually internally with the involvement of staff and with consideration for mental strain. 15

18 6 EVALUATION AND FURTHER DEVELOPMENT Since 1998, the inspection concept and particular aspects of it have been reviewed at regular intervals and adjusted to changes in the terms of reference. The system audit lists for example, both for larger companies and for SMEs, have been revised several times. In 2005, a generic framework was created in the form of the ArbeitsschutzPartnerschaft OSH partnership which facilitates the completion of projects in co-operation not only with statutory accident insurance institutions, but also with employers' associations, trade unions and chambers of commerce and crafts. In recent years, conceptual planning and scheduling of projects has been geared more closely to the generic objectives of the European Community strategy. Since 2007, projects have been aligned more closely to the targets and areas of activity of the Common German OSH Strategy. 16 A preliminary evaluation of the Hamburg OSH concept was undertaken in 2006 as part of pilot comparison, performed by LASI, of the concepts and foci of the German regional governments (the "scoreboard of the regions"). In future, the regional governments are expected to perform such stock-taking exercises of the OSH concepts at regular intervals. In addition, attainment of the targets of the Common German OSH Strategy is evaluated. This applies to participation in campaigns and the conducting of projects, in addition to routine procedures and collaborative activity.

19 LEGAL INFORMATION Published by: Contact: Available from: Design: Translation: Druck: Behörde für Soziales, Familie, Gesundheit und Verbraucherschutz Amt für Arbeitsschutz Billstraße Hamburg OSH hotline: Dr. Sabine Eligehausen This brochure can be downloaded on the Internet at: Headword: Hamburger Aufsichtskonzept Kerstin Herrmann Marc Prior Dynamik Druck GmbH 1 st edition, September 2008 Remarks on distribution: This leaflet is published in the context of the public information work conducted by the Senate of the Free and Hanseatic City of Hamburg. It may be used neither by political parties, nor by election candidates or their election assistants for the purpose of election campaigning or in any other way which might be interpreted as partisan support by the state government for particular political groups.

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