Calculate SiFa operating time according to DGUV regulation 2: Appendix 2 and Appendix 3 explained

The working time of the occupational safety specialist (SiFa) results from DGUV regulation 2 on occupational medical and safety-related care. The regulation distinguishes between standard care with basic care in accordance with Appendix 2 and company-specific care in accordance with Appendix 3 for companies with eleven or more employees, and alternative care for companies with up to ten employees. The basic care is expressed in hours per employee per year and depends on the care group into which the company is classified based on its tool industry. The company-specific support results from a risk analysis with eleven task areas, which the company carries out and documents together with SiFa and the company doctor. An incorrect calculation leads to undersizing with liability risk according to § 130 OWiG or to oversizing with unnecessary costs.

This article explains the logic of DGUV regulation 2 step by step, shows an example calculation and describes typical errors. You will also learn how CIVAC, as a compliance platform and officer-as-a-service, manages calculations, ordering and documentation in an audit-proof workspace. Licence the workspace for your internal representatives or have our representatives order it. The appointment certificate, signed, filed, verifiable. Anyone who manages the system in a verifiable way protects employees, management and operations alike. A verifiable calculation is therefore the ticket to an orderly BG examination.

DGUV Regulation 2 is an accident prevention regulation of the professional associations and accident insurance funds, which specifies Section 2 of the Occupational Safety Act (ASiG). It obliges all employers to have their company looked after by an occupational safety specialist and a company doctor. The regulation distinguishes between two models. Standard care for companies with eleven or more employees, divided into basic care according to Appendix 2 and company-specific care according to Appendix 3, as well as alternative care for companies with up to ten employees with simplified requirements.

The hourly calculation follows two logics. Basic care is standardised and expressed in hours per employee per year, depending on the care group. The company-specific support is individual and results from eleven task areas that the company evaluates. Both parts must be combined and divided between SiFa and company doctor because DGUV regulation 2 provides for a joint consideration of both roles. The division follows the responsibility for content, not a rigid quota.

The written appointment of the occupational safety specialist is mandatory according to Section 5 ASiG. Contents include the tasks according to Section 6 ASiG, the operating time according to DGUV regulation 2, the reporting line to the management and access to all relevant areas of the company. Without a written order, the SiFa is deemed not to have been ordered, which leads to complaints during inspections by the BG and, in the event of damage, to the personal liability of the management in accordance with Section 130 OWiG. The CIVAC workspace maintains appointment certificates as versioned documents with reminders of extension dates. The regulation is part of the employer's canon of duties in accordance with Section 3 of the ArbSchG and is the subject of review for every supervisory measure taken by the professional association in the ongoing care relationship. In this way, the order remains alive and adapts to personnel changes and task shifts without disruption.

Appendix 2 of DGUV Regulation 2 classifies each company into one of three care groups. Group I includes industries with high risk potential such as construction, mining, metal production and parts of the chemical industry. Group II includes medium-hazard sectors such as mechanical engineering, logistics, hospitality and parts of the healthcare sector. Group III includes low-risk sectors such as offices, banks, insurance companies and parts of public administration. The classification is based on the WZ industry number of the company in a table printed in the regulation.

The hourly rate per employee and year follows from the classification. Group I is 1.2 hours, Group II 0.3 hours, Group III 0.3 hours, each as a total for SiFa and company doctor together. The distribution key between the two roles is not rigidly defined in the regulations, but is determined based on the substantive tasks. In practice, ratios between 70:30 and 50:50 in favor of SiFa are common, depending on the industry and the existing risks in the company.

The basic care costs arise from the hourly rate and the number of employees. An office service provider with 100 employees in Group III has a basic care requirement of 30 hours per year, of which typically 18 to 21 hours are spent on SiFa. A metal processing company with 100 employees in Group I has a basic care requirement of 120 hours per year. The CIVAC workspace offers a calculation mode in which the tool industry, number of employees and distribution key are stored and the effort is updated per quarter if the number of employees changes. Clean documentation of the classification with reference to the WZ number is mandatory and avoids discussions with the professional association about the correct group and thus the correct hourly rate.

Appendix 3 of DGUV Regulation 2 defines company-specific support as a proportion to be measured individually. It results from eleven task areas that the company evaluates together with SiFa and the company doctor. The areas of responsibility are regularly recurring tasks such as risk assessments, company-specific instructions, investigation of accidents, participation in safety and health committees, as well as temporary topics such as the introduction of new machines, construction projects, audits or findings from occupational safety management. The regulation provides a list of fields without rigid hourly rates.

The evaluation is carried out in a structured procedure. Firstly, the eleven fields are tested against the reality of the operation. Which are relevant and which are not. Secondly, expenses are estimated for the relevant fields, with hourly budgets per year. Thirdly, temporary topics are added with calculated project quotas. The assessment is documented in writing and checked at least annually, and adjusted immediately in the event of significant changes such as new locations or production changes. The written agreement is part of the order.

In practice, the company-specific shares are between 30 and 200 percent of the basic care costs. An office service provider without any particular risks usually ends up at 30 to 50 percent, an industrial company with shift operations and several locations at 100 to 200 percent. The CIVAC workspace maintains an evaluation mask with examples for each of the eleven fields so that the occupational safety specialist can verifiably coordinate the evaluation with management. The written agreement is automatically generated and versioned. Audit-proof, documented, paragraph-proof. The eleven task areas must be included in the assessment with specific hourly budgets so that the total remains comprehensible and can be compared over the years. This creates comparable control parameters over the years.

A metal processing company with 250 employees in Group I results in the following basic care costs. 250 employees times 1.2 hours equals 300 hours per year for SiFa and company doctor combined. With a distribution ratio of 70 to 30, 210 hours are spent on the SiFa and 90 hours on the company doctor. These hours are fixed minimum hours from which no downward deviation can be made.

The company-specific support results from the assessment of the eleven task areas. In the example company, risk assessments for 40 types of workplaces are to be calculated with 80 hours, regular training with 30 hours, a new machine project with 40 hours, inspections with 20 hours, consulting and committee work with 25 hours and accident investigations with 15 hours. The total amounts to 210 hours, of which 80 percent are allocated to the SiFa according to the distribution key, i.e. 168 hours. In total, the SiFa accounts for 210 plus 168 equals 378 hours per year.

378 hours correspond to 8.5 weeks of full-time work for an employee. This time must be contractually secured and reflected in the operational process. If the requirement permanently exceeds 50 percent of a full-time position, it is common practice to appoint an internal full-time SiFa, otherwise an external SiFa with a clear hourly quota is sufficient. The CIVAC workspace calculates these values ​​automatically and maintains the hourly budget as a life account in which hours worked are planned and tracked against the target value. The management can see the status of fulfilment at any time. The calculation must be deposited with the management with the date, signature and reasons for adjustment so that auditors can trace the progress of the calculation over previous years. This transparency also makes the management's annual budget planning easier.

DGUV regulation 2 does not prescribe a rigid division of basic care between SiFa and the company doctor. Instead, the division is derived from the content of the tasks. The DGUV's FBOH publication provides information on this with typical distribution ranges that are used as guideline values ​​in practice. The division must be agreed in writing and checked at least annually because it changes with the company's task profile.

Typical ratios in practice are 70:30 in favor of SiFa in sectors with a high proportion of technical and machine safety-related tasks, 60:40 in sectors with a balanced mix of technology and occupational medicine, and 50:50 in sectors with a high proportion of occupational health topics such as nursing or health services. A blanket division without justification is considered non-compliant and can be criticized as a formal deficiency in a BG audit.

The written agreement must contain the division with justification, as well as the contact details of the appointed persons, the reporting line to the management and the procedure for the annual review. The report line is managed in the CIVAC workspace as a workflow in which SiFa, company doctor and management release the distribution key annually and document the justification. A reminder mechanism ensures that the check actually takes place and does not remain as a non-binding dead file in subsequent years. Without a documented division, the obligation to order is not considered to have been fully fulfilled, which, as a formal deficiency, leads to requirements with a deadline during inspections. The hours that are incurred for journeys, travel times and external appointments must also be taken into account in the key so that the effective working time is not reduced by taking into account general travel time.

Companies with up to ten employees can choose alternative care in accordance with DGUV regulation 2. Instead of continuous support, the entrepreneur completes a basic qualification, regular training and guarantees needs-oriented support. The basic qualification typically lasts ten to forty hours, depending on the scope of care and the industry. It is organised by the professional association and is a prerequisite for choosing the model.

The advantage of alternative care is the cost savings compared to continuous external care. The disadvantage is the entrepreneur's personal responsibility and the obligation to undergo regular training. In the event of significant changes such as new jobs, changes in the risk situation or special occasions, an external SiFa or a company doctor must be consulted in order to ensure needs-oriented care. Anyone who fails to do this loses the status of alternative care and falls under regular care.

The obligation to carry out a risk assessment according to Section 5 ArbSchG applies regardless of the care model. Even in small businesses, risks must be assessed, measures determined and effectiveness checked. The CIVAC workspace also offers a mode with reduced complexity for small businesses, in which appointment certificates, qualifications, training certificates and needs-oriented consultations are managed as a workflow. Licence the workspace or have our SiFa ordered if you do not want to bear the responsibility yourself or consider the obligation to undergo further training to be too time-consuming. Both models meet DGUV regulation 2. A mixed staffing with internal basic support and external top support is permitted in small businesses and is in many cases the most economically sensible option. This mixed model is stored in the workspace as a separate template and facilitates the transitional development of the business from small to medium-sized businesses.

The professional associations usually check compliance with DGUV regulation 2 as part of their supervisory visits. The written orders from SiFa and the company doctor, the calculation and documentation of the operating time according to appendix 2 and appendix 3, the reporting line to the management, the minutes of the occupational safety committee as well as the risk assessments and the involvement of SiFa and the company doctor are checked.

Typical complaints are missing or incomplete orders, insufficient documentation of company-specific support, lack of annual reviews of the Allocation key and unminuted meetings of the Occupational Safety and Health Committee in accordance with Section 11 ASiG. In the event of repeated defects, there is a risk of imposing conditions with deadlines, and in the case of serious defects, a fine procedure according to Section 209 SGB VII. In addition, there is always civil liability of the management for work accidents according to Section 130 OWiG, which is significantly reduced with documented fulfilment of duties.

Preparation is the decisive lever. Companies that keep their DGUV Regulation 2 documentation in a structured workspace can complete exams in under an hour because all evidence is linked digitally. Others run compliance like a filing cabinet. We run it like software. The CIVAC workspace provides a ready-made test mode for the test with prepared dossiers for orders, operating time, reporting line and occupational health and safety committee. The auditor calls, the evidence is ready. The inspections by SiFa and the company doctor in accordance with DGUV Rule 100-001 are also queried as a test item and compared with the protocols. The reports from the occupational safety committee, the company doctor and the SiFa are brought together in a dossier and presented in one access at the supervisory appointment. Those responsible who choose the Officer-as-a-Service model receive an accompanying examination by our appointed occupational safety specialist, who is familiar with the testing routines of the respective professional association and defuses unpleasant discussions at an early stage.

The most common mistake is the isolated application of basic support without company-specific support. Some companies consider the hours in Appendix 2 to be the full mandatory scope and completely ignore Appendix 3. This leads to significant undersizing, which becomes a liability issue in the event of damage. The second most common mistake is the mechanical calculation of company-specific support as a percentage mark-up without evaluating the eleven task areas individually. This is also not in accordance with the regulations and is criticized in exams.

Another error is the lack of adaptation to changes. The operating time must be checked at least annually, and immediately in the event of significant changes. New locations, new machines, new numbers of employees, new risk assessments must be incorporated. In practice, calculations are often made once and not adjusted for three years, which can cause both under- and over-sizing and is criticized as a formal deficiency in BG inspections.

A fourth error concerns the distribution key between SiFa and the company doctor. A general 50-50 distribution without substantive justification is not considered sufficient. The division must be derived from the actual task content and justified in writing. The CIVAC workspace keeps a checklist with these four typical sources of error so that the SiFa and management can systematically exclude them during the annual review. Audit-proof, documented, paragraph-proof. This discipline reduces the risk of complaints in BG tests to practically zero. A checklist with the date of the last adjustment, reason for the adjustment and version number is a standard template in the workspace and is automatically reminded. This mechanic relieves management of the task of thinking about the update themselves. A systematic quarterly self-examination of the four sources of error also significantly reduces the risk that complaints only become visible during the supervisory appointment of the professional association.

The working time of the occupational safety specialist is not an estimate, but a verifiable calculation from DGUV regulation 2 with appendix 2 and appendix 3. Anyone who carries out the calculation correctly avoids under- and over-dimensioning, excludes complaints in BG tests and reduces the liability risk of management according to § 130 OWiG. CIVAC is the compliance platform and officer-as-a-service for companies that do not want to manage this discipline as a filing cabinet, but as software. Others run compliance like a filing cabinet. We run it like software.

You have two options. If you licence the workspace for your internal SiFa or your external service provider, then the representatives work in an environment with calculation mode for Annex 2 and Annex 3, ready-made appointment certificates, distribution agreements, occupational health and safety committee minutes and audit mode for BG visits. Or have our SiFa ordered. CIVAC then takes on the role of external occupational safety specialist with an appointment certificate, reporting line and SLA. Both models result in the same proof. The appointment certificate, signed, filed, verifiable.

If the next BG inspection is due, a new location is opened or the number of employees changes significantly, the quality of your DGUV Regulation 2 documentation determines the inspection process and the liability picture. CIVAC shortens the calculation and adjustment of the deployment time to two working days instead of the classic three to six weeks. Turn reading into an assignment. Write to info@civac.de or use the contact form on civac.de/faq to start an initial assessment of your SiFa deployment time. You will receive a response within 24 hours with the next steps and a verifiable calculation. The initial evaluation includes a check of your current calculation, a correction of typical errors and a suggestion for annual maintenance in the workspace with clear information on the effort.