Calculate company doctor deployment time according to DGUV regulation 2: basic care, company-specific share, documentation

DGUV regulation 2 (company doctors and occupational safety specialists) has been in effect since 2011 and was most recently updated with regard to systems and care groups. It specifies the Occupational Safety Act (ASiG) and specifies the minimum working time a company must reserve for company medical and safety-related care. The regulation binds all member companies of the commercial professional associations and accident insurance funds.

The calculation of the operating time is not a calculation problem with a number, but a two-part process: basic support according to Appendix 2 based on the WZ support group and the number of employees, plus company-specific support based on the specific risk profile. This article explains both shares, the documentation requirements and the most common errors in calculations in medium-sized businesses. The focus is on test-proof implementation, not on an abstract formula derivation.

The Occupational Safety Act (ASiG) has required employers to appoint company doctors and occupational safety specialists since 1973. The professional associations and accident insurance funds have regulated the specific design with DGUV Regulation 2. In 2011, it replaced several older accident prevention regulations and applies nationwide to the member companies of the respective providers.

The scope of application includes all companies with at least one employee. There is no lower limit; However, small businesses with up to ten employees have the option of choosing between standard care and alternative needs-based care (entrepreneur model). This article focuses on the standard care that is applicable to companies with eleven or more employees.

The regulation not only appoints the company doctor, but also the occupational safety specialist. Both roles are functionally separate, but their working times are calculated according to the same logic and documented together in the written order. The appointment is made in writing with the area of ​​responsibility, working hours and reporting path. The appointment certificate, signed, filed, verifiable. A change in the number of employees or the company structure triggers an adjustment to the working hours, which must also be documented.

Appendix 2 of DGUV Regulation 2 assigns each economic class (WZ code) to one of three care groups. The group determines the amount of basic care time. Care group I includes activities with a high level of risk (e.g. construction, metal production, chemistry). Care group II includes medium risk (mechanical engineering, logistics, food production). Care group III includes lower risks (banks, insurance companies, administration, IT service providers).

The basic care time per employee per year is 2.5 hours in group I, 1.5 hours in group II and 0.5 hours in group III. This time is the sum of company medical and safety care. The division between the two functions is not rigid; it is agreed between the company, the company doctor and the specialist and recorded in writing. The usual split is 20 to 80 or 30 to 70 in favor of the safety specialist, with significant deviations depending on the industry.

The WZ allocation is based on the classification system of the Federal Statistical Office. In the case of mixed operations (several WZ activities in one company), the activity with the highest proportion is usually used, alternatively a weighted calculation across the sub-operations. If anything is unclear, the responsible professional association will provide binding information. The assignment is made once and is valid until there is a significant structural change. It is part of the written documentation.

An example illustrates the mechanics. A mechanical engineering company with 320 employees falls into care group II. The basic care time is 1.5 hours per employee per year, multiplied by 320 employees results in 480 hours per year. With a division of 25 to 75, 120 hours are allocated to the company doctor and 360 hours to the occupational safety specialist.

An insurance company with 800 employees in administrative work (care group III) has a basic care time of 0.5 hours per employee, multiplied by 800 results in 400 hours per year. With a 30:70 split, 120 hours are allocated to the company doctor and 280 hours to the specialist. Despite a significantly larger workforce, the absolute working time is no higher than in a mechanical engineering company because the risk profile is lower.

A construction company with 90 employees in Group I has 2.5 hours per employee, i.e. 225 hours of basic care per year. Here the typical division in favor of the safety specialist is even more pronounced, often 15 to 85, i.e. 34 hours of company doctor and 191 hours of specialist. This only applies to basic care. The company-specific portion is added and can double or multiply the volume. The auditor calls, the evidence is ready.

Basic care includes nine areas of responsibility, which are listed in Appendix 2. Firstly, support in the preparation and updating of the risk assessment in accordance with Section 5 ArbSchG. Second, the principles and concepts of prevention. Thirdly, the tasks to improve the working situation from an occupational health and safety perspective. Fourth, the investigation of work accidents and work-related illnesses.

Fifth, general advice to employers and employees. Sixth, monitoring and evaluating the effectiveness of protective measures. Seventh, participation in the Occupational Safety and Health Committee (ASA) for 21 or more employees. Eighth, the self-organisation of the representatives (further training, methodology, quality assurance). Ninth, the preparation of the annual report to the employer.

These tasks are not conclusively defined in terms of the time required per task; The assignment is left to the agreement between the company, the company doctor and the specialist. But it must be documented. In practice, this means a written definition of which tasks are included in the basic care and to what extent and which tasks form the company-specific part. This determination is the basis for later reporting and for the examination by the professional association as part of the supervisory visits.

The company-specific support is the second portion of the deployment time that must be determined individually. Appendix 3 of DGUV Regulation 2 lists 16 task fields in which a need may arise, such as regular occupational medical examinations, special hazards (noise, hazardous substances, radiation, psychological stress), changing jobs, travel, mobile work, shift work, pregnancy and breastfeeding, inclusion and reintegration.

The entrepreneur determines for each of the 16 fields whether there is a task or cause-related issue in the company and what time expenditure is realistic. The investigation is carried out together with the company doctor and specialist and results in a written justification. The professional association typically checks three things during the supervisory visit: whether all 16 fields have been evaluated, whether the evaluations are conclusive and whether the derived operating time fits the reasoning.

Mistakes are often made here in medium-sized companies. Either the company-specific share is set as a flat rate of zero hours, which is vulnerable to any relevant activity. Or an order from the company doctor's contract is taken over without your own analysis, which also doesn't help in the event of an audit. A reliable company-specific calculation typically includes 30 to 100 percent additional hours of basic care, depending on the industry and risk profile. CIVAC provides audit templates with which the 16 fields can be evaluated in a structured manner and the justification can be stored in a workspace with EU data residency.

The documentation includes five elements that must be present in full in the event of an audit. Firstly, the written appointment of the company doctor and the occupational safety specialist with areas of responsibility, working hours and reporting channels. Secondly, determining the care group with justification for the WZ assignment. Thirdly, the division of the basic care time between the company doctor and the specialist.

Fourthly, the written determination of the company-specific care with the 16 task areas and the respective assessment. Fifthly, the annual report from the company doctor and the specialist to the employer, in which the hours worked, the essential activities and the derived measures are presented. This annual report is the most important ongoing documentation; It is typically created in the first quarter of the following year and presented to the Occupational Safety and Health Committee.

The retention period for the orders and reports is usually ten years, based on standard tax and social security deadlines. Effectiveness checks and repeat risk assessments are carried out at intervals of one to three years, depending on the activity. CIVAC's audit templates structure the documentation according to the DGUV-V2 requirements and enable versioned storage in the workspace, which is directly accessible in the event of an audit. Audit-proof, documented, § ASiG-proof.

Three errors occur particularly frequently in medium-sized businesses. The first is the missing or outdated order. An order from 2014 that has not been adapted to the current number of employees, the current activity structure and the updated DGUV V2 systems is not an effective order in the audit case. Correction: annual review as part of the annual report, new issuance of the order in the event of significant changes.

The second error is the general calculation without company-specific determination. Only basic care is calculated here and Appendix 3 is ignored. This leads to a gap in every company with even just one relevant task (hazardous substances, shift work, screen work above certain thresholds, travel, pregnancy). Correction: go through the 16 fields annually or when there are structural changes and evaluate them in writing.

The third mistake is the lack of division of the working time between the company doctor and the specialist. The regulation requires a written determination of how the hours are distributed between the two functions. An agreement that only mentions a total volume does not meet the requirement. Correction: State the division explicitly in the order, document the actual division in the annual report and justify any deviations. If there is an accumulation of deviations, it is obvious that the original distribution does not match the actual needs; then the order will be adjusted.

The company doctor can be employed internally or appointed externally. In medium-sized companies, external appointments clearly predominate because the calculated working times are in most cases less than half a full-time position and having an internal company doctor is not economical. External orders are placed via inter-company occupational health services, established occupational physicians with appropriate qualifications or specialised service providers.

Before ordering, check your professional qualifications. A company doctor is a doctor with additional training in occupational medicine or recognition as a specialist in occupational medicine in accordance with the further training regulations of the respective state medical association. Other specialist groups with the corresponding additional training can also be recognised. An order without formal qualifications is ineffective and usually excludes the supervisory authorities immediately.

Licence the workspace for your internal representatives, or have our representatives appoint you. CIVAC is a compliance platform and officer-as-a-service. External company doctors are recruited via the network and kept in the workspace with an appointment certificate, working time calculation, annual report and task log. The CIVAC SLA of two working days until the signed order also applies to occupational health care, provided the candidate's qualification test has been completed. The operating time is calculated and documented together with the internal contact person before the operational activity begins.

The calculation of the working time according to DGUV regulation 2 is a two-part process consisting of basic care according to appendix 2 and company-specific care according to appendix 3. The documentation includes the written order, the determination of the care group, the division of the hours between the company doctor and the specialist, the determination of the 16 company-specific fields and the annual report. Anyone who leaves out one of these components will have a gap in the audit.

CIVAC is a compliance platform and officer-as-a-service. In the workspace you carry out the order, the tool assignment, the operating time calculation with Annex 2 and Annex 3 shares and the annual report with documented versioning and EU data residency. 490 audit templates cover the typical areas of responsibility. External orders are placed under the standard SLA of two working days, with a defined reporting path to management.

Turn reading into a mandate. Write to info@civac.de or use the contact form. In an initial discussion, we determine whether your existing order meets the requirements of DGUV V2, which adjustments Annex 3 requires and whether an external company doctor from the CIVAC network is the most economical solution. The result of this conversation is a concrete working time calculation with a suggestion for the order, not a generic offer.