Occupational health care G 37 VDU work: duration, deadlines, documentation

The occupational health care according to DGUV principle G 37 for activities at computer workstations has been an offer of care since the amendment to the Occupational Health Care Ordinance (ArbMedVV) in 2013 in accordance with Section 5 ArbMedVV in conjunction with Annex Part 4 Paragraph 2. This means: The employer must offer the care, participation is voluntary, documentation of the offer is mandatory. The pure examination time is typically between 20 and 40 minutes. The intervals, documentation and retention periods are regulated in ArbMedVV, Section 6 Paragraph 4 ArbMedVV and DGUV Regulation 2.

This article answers the operational questions that human resources departments, management and company doctors ask about G-37 prevention: How long does a single examination take? At what intervals must it be offered? What components does the examination contain? How is the preventive care file maintained in accordance with Section 3 ArbMedVV? How long should findings be kept? And how does CIVAC's compliance platform and officer-as-a-service map the company doctor role with preventative care files, offer documentation and reminder workflows. The appointment certificate, signed, filed, verifiable. The answer to these questions determines whether the professional association finds an orderly pension record during the visit or opens a fine file. Management is also personally liable if the system does not work. The following article is therefore not a theory, but rather a guide for operational implementation.

The occupational health care at computer workstations is regulated in the ArbMedVV (Ordinance on occupational health care). § 5 ArbMedVV in conjunction with Annex Part 4 Paragraph 2 stipulates provision for activities involving computer screen work. The DGUV principle G 37 “VDU workstations” defines the technical content of the investigation. Before the ArbMedVV amendment in 2013, G 37 was a mandatory examination according to BGV A4 and was often used as a pre-employment examination. It has been an express offer since 2013, participation is voluntary, and the results of the examination may not be communicated to the employer.

The offer of preventive care must be organised in accordance with Section 5 Paragraph 1 ArbMedVV if the activity carried out is likely to pose a health risk within the meaning of the appendix. Screen work falls under Annex Part 4 Paragraph 2: Activities on screen devices, unless employees only work with them in exceptional cases. The interpretation “not only in exceptional cases” is specified in DGUV information 250-008: Employees whose work is predominantly carried out (more than half of their daily working hours) on screen devices are included. In practice, this affects almost every office, IT and administrative activity. The obligation to offer applies regardless of the size of the company, even in small companies. It is part of the employer's obligations according to Section 3 ArbSchG and is implemented by the company doctor according to Section 7 ASiG. Violations are prosecuted as an administrative offense according to Section 9 ArbMedVV. In addition, the responsible state authority (usually the respective occupational safety office) can issue a prohibition order if precautionary measures are systematically not carried out. In the event of damage, insurers and professional associations will consider the lack of an offer as contributory negligence on the part of the employer, which noticeably worsens the recourse position.

The pure examination time is typically between 20 and 40 minutes according to DGUV principle G 37. The standard procedure includes seven components: medical history (5 to 10 minutes), distance vision test (optical acuity, 3 to 5 minutes), near vision test (5 to 8 minutes), phoria and stereo test (2 to 4 minutes), colour vision test with Ishihara charts (2 to 3 minutes), intraocular pressure (tonometry, optional, 2 to 4 minutes), and consultation (5 to 10 minutes). The total duration depends on the findings; If there are any abnormalities, you will be referred for a specialist clarification; the initial consultation will then take longer.

In addition, there is the organisational preparation and follow-up. The employee receives an anamnesis form in advance, which is filled out before the examination. After the examination, the company doctor creates a medical certificate about the preventive care carried out in accordance with Section 6 Paragraph 4 ArbMedVV, which does not list the result, but only the fact that the preventive care took place. This certificate is stored in the pension index in accordance with Section 3 ArbMedVV. Including preparation, examination and documentation, company doctors expect 45 to 60 minutes per employee. Anyone planning preventive campaigns should calculate with a company doctor slot of around one hour per employee; in large company medicine, a frequency of 30 to 40 minutes is possible if the anamnesis and eye test take place in parallel rooms. Anyone planning a prevention campaign for 80 employees should plan around four to five prevention days, plus preparation and follow-up. The appointments are displayed to employees in the CIVAC workspace with a read confirmation; canceled appointments are automatically re-offered. With distributed locations, the workspace can manage location-specific slots, mobile preventative care appointments and occupational health consultations in parallel without the data storage diverging.

The initial offer of preventative care is made in accordance with Section 5 Paragraph 1 ArbMedVV before starting work, in practice within the first two weeks of employment. Follow-up offers must be made regularly every three years. In some companies, the interval is extended to five years for employees under 40 years of age, and shortened to two years for employees over 40 years of age or in the case of visual abnormalities. The DGUV recommendation stipulates 36 months as the standard interval, with the possibility of individual shortening on the recommendation of the company doctor.

Preventive care must be offered if special circumstances arise: employee complaints about the eyes or vision, change of workplace (new monitor, new software, new activity), or after illnesses with a potential impact on the ability to use screens. In the case of pregnant women, preventive care must be offered at the request of the employee and the computer workstation design must be adjusted if necessary. The offer must always be documented in writing, even if the employee rejects it. The rejection itself must be recorded with a date and signature. CIVAC maintains a reminder function in the company doctor workspace that sends a note to the company doctor and the human resources department 90 days before the interval expires. The offer can be made via email with a read confirmation; the documentation is automatically added to the pension file. The deadline begins as soon as it is known; the system timestamps each offer with the date of delivery to the employee. The auditor calls, the evidence is ready. The rejection is also kept in a separate list and reflected in the quarterly report to management. This makes it possible to understand which employees have taken advantage of the pension provision, which have rejected it and which have postponed it for scheduling reasons, which is usually the first evaluation in the professional association's audit.

The content of the G-37 investigation follows the DGUV principle G 37 in the current version. The anamnesis records professional and private viewing habits, existing visual aids, complaints such as headaches, burning eyes, blurred vision, and previous personal illnesses such as diabetes, high blood pressure or thyroid diseases that can affect vision. The medical history is recorded in the screening form, which is part of the medical file and is not disclosed to the employer.

The vision test is divided into distance (at 5 metres) and near (at 33 to 40 centimeters, corresponding to the typical screen distance). The phoria test checks the position of the eye muscles at rest, the stereo test checks spatial vision, and the colour vision test checks colour acuity. If you have any visual abnormalities, you will be recommended to see an ophthalmologist for a specialist examination. If the examination shows that visual aids are specifically required for computer work (so-called computer workstation glasses), the employer bears the costs for appropriate visual aids in accordance with Section 6 ArbStättV in conjunction with ArbStättV Annex Point 6 if normal visual aids are not sufficient. The consultation ends with concrete recommendations: break planning, screen position, lighting, visual aids. The advice is part of the examination and is noted in the precautionary statement without the employer being able to see it. CIVAC uses a structured template in the workspace that integrates the anamnesis form, documentation of findings and consultation notes and links them to the preventative care file. This template corresponds to the recommendations of DGUV information 250-008 and is checked every six months against changes in principle G 37. Others run compliance like a filing cabinet. We run it like software. The company doctor thus receives a standardised diagnosis logic without losing the individuality of the advice, which results in a measurable quality advantage with changing staff and cooperating medical practices.

The preventive care file according to § 3 ArbMedVV is the central documentation instrument for occupational health care. It is run by the employer, often with technical support from the company doctor. Mandatory content is: name of the employee, activity, reason for the preventive care (obligation, offer, request), date of offer, date of implementation, processing of findings in such a way that the result is not included, but only a reference to further appointments, and the name of the doctor carrying out the preventive care. § 3 Para. 2 ArbMedVV makes it clear that the examination results do not belong in the preventative care file, but only the medical note about the implementation.

The card file is kept electronically or in paper form. In the case of electronic management, the requirements for personal data apply in accordance with Art. 9 GDPR (special categories) and Section 22 BDSG. The preventative care file may only be accessible to the company doctor and the person responsible for supervision; human resources management does not have direct access to the medical findings. CIVAC maintains the preventive care file as a separate data area in the workspace, with separate access rights between the company doctor (full access including findings) and HR (access only to offer and implementation data). The encryption is carried out according to AES-256, the data resides in the EU, the storage runs under ISO/IEC 27001:2022 certified ISMS controls. The appointment certificate, signed, filed, verifiable. Audit-proof, documented, § 130 OWiG-proof. Employees can view their own data records via a self-disclosure module; information rights according to Art. 15 GDPR are served completely electronically, without HR or management having access to the medical findings. This separate data path is part of the ISMS architecture. The medical file therefore remains under the authority of the company doctor, the pension index remains the responsibility of the employer, and both data sets are managed with clearly separated rights.

The retention periods arise from several sources. Section 3 Paragraph 4 ArbMedVV requires that the pension index is maintained at least until the employee leaves. For particularly hazardous activities (e.g. carcinogenic substances according to Annex Part 1), the obligation is extended to up to 40 years. For G 37 screen work, the standard deadline applies until departure. After leaving the company, the employee must be informed about the fate of their data. The medical files are also subject to the medical retention requirement in accordance with Section 10 MBO-Ä, usually for 10 years.

Additional requirements apply under data protection law. Precautionary data is health data within the meaning of Art. 9 Para. 1 GDPR and can only be processed under the conditions of Art. 9 Para. 2 GDPR. Section 22 BDSG specifies processing in the employment context and requires appropriate technical and organisational measures. The pension index must be encrypted, access restricted and maintained with a documented deletion routine. CIVAC implements the deletion routine as a time-controlled workflow: When the employee leaves, the file is transferred to the archive, where it remains in accordance with the legal obligation, it is then deleted in a controlled manner and the deletion process is documented. The auditor calls, the evidence is ready. Data protection authorities, professional associations and staff councils can view the deletion documentation at any time without violating medical confidentiality. In the event of a dispute, verifiable deletion is the decisive argument against a later accusation of unlawful storage of health data, which can be sanctioned with fines of up to 20 million euros according to Article 83 (5) GDPR. Even in the context of internal audits, group compliance audits and takeover due diligence checks, the traceable deletion chain is crucial evidence that the company has fulfilled its obligations.

If the G-37 precaution shows that special visual aids are required for screen work, the employer will bear the costs. The legal basis is § 6 ArbStättV in conjunction with appendix point 6.1 (screen devices). The prerequisite is that the employee has been prescribed special visual aids (computer workstation glasses) by a doctor, that the normal visual aids are not sufficient for the distance from the screen, and that the prescription is documented in writing. The employer must finance appropriate visual aid that corresponds to the individual's visual performance.

The term "appropriate" is often controversial. The case law (e.g. LAG Lower Saxony, judgment of April 30, 2008 - 6 Sa 1352/07) has made it clear that appropriate, functional glasses are to be financed, but not luxury equipment such as designer frames or high refractive index above the medically necessary level. In practice, the costs are between 150 and 400 euros per pair of glasses, depending on the lenses and visual complexity. The glasses remain the property of the employee; the claim arises again every three years or if there is a significant change in visual performance. CIVAC documents the computer workstation glasses in the workspace with regulations, proof of cost assumption and date of handover, so that in the event of a dispute, proof can be provided that the employer has fulfilled its obligation according to Section 6 ArbStättV. The link to the preventive care file ensures that the glasses offer is synchronized with the underlying examination. For existing employees with existing visual aids, it is documented in the workspace whether the existing glasses are sufficient for computer work, so that new prescriptions are only made where they are medically necessary, without legitimate claims being overlooked. The optician's invoice, the doctor's prescription and the delivery receipt are filed together so that the tax office can provide proof of the operational reason without any questions as part of an external income tax audit.

The management is responsible for organising occupational health care in accordance with Section 3 ArbSchG and Section 2 ArbMedVV. The professional associations check compliance with their duties as part of their regular supervision and during occasional audits. The following are checked: Appointment of a company doctor according to § 2 ASiG, preventive care file according to § 3 ArbMedVV, risk assessment according to § 5 ArbSchG, documentation of offers and offers, training of managers, and the obligations to use computer workstation glasses.

Violations of ArbMedVV are prosecuted as an administrative offense according to § 9 ArbMedVV, with fines up to 5,000 euros per violation. If the violation is intentional or linked to other violations, significant sums can be incurred cumulatively. There are also consequences under civil law: If an employer does not offer preventative care and the employee suffers damage to their health that could have been detected if preventive measures had been taken in a timely manner, they risk claims for damages and recourse claims from the professional association. CIVAC maps the operational obligations in a structured workflow: appointment of the company doctor with appointment certificate, precautionary index, reminder function for follow-up offers, precautionary triggers when changing jobs, documentation of offer acceptance or rejection, training module for managers on precautionary obligations. Licence the workspace for your internal representatives or have our representatives order it. The appointment certificate, signed, filed, verifiable. During the visit, the professional association receives a coherent database, instead of a series of Excel lists, the up-to-dateness of which can only be clarified by comparing them with the human resources system. This saves testing time and reduces complaints to substantial points. Where complaints remain, they can be processed in a structured manner using the corrective action function in the workspace, with clear responsibilities, deadlines and final documentation, so that the professional association is received with a completely resolved list of requirements the next time.

If you want to set up the G-37 preventive care in your company properly, you start with three components: an appointed company doctor, a preventive care file according to § 3 ArbMedVV and a workflow for offers, event prevention and computer workstation glasses. The appointment of the company doctor is made in writing in accordance with Section 2 ASiG, the pension record is kept by the employer, and the workflow synchronizes the two. Without a structured system, pension provision remains a collection of Excel lists and paper folders that regularly fall apart in the professional association's audit.

CIVAC connects all three components in one workspace. The appointment of the company doctor is stored in the system as an appointment certificate, the preventive care file runs as an encrypted data area with separate access rights, and the workflow for offers and event prevention is equipped with reminder functions. Licence the workspace for your internal representatives or have our representatives order it. The SLA for appointing an external company doctor via CIVAC is 2 working days. Audit-proof, documented, § 130 OWiG-proof. Turn reading into an assignment. Write to info@civac.de or use the contact form on civac.de. In the 30-minute initial consultation, the number of employees, the job profiles and the existing pension organisation are recorded, the next pension cycle is planned and the ordering model is agreed. Within two working days, the workspace is activated, the precautionary file is set up and the first precautionary cycle is scheduled. Anyone who chooses the classic route via separate providers for company doctors, file management and reminders typically plans four to six weeks in which the preventive care obligation remains open and the OWi risk continues. The auditor calls, the evidence is ready. Audit-proof, documented, § 130 OWiG-proof. Turn reading into an assignment.