Create an explosion protection document: template and obligations according to the Industrial Safety Ordinance 2026

§ 6 of the Industrial Safety Ordinance (BetrSichV) obliges the employer to create and keep up-to-date an explosion protection document for every workplace with a dangerous, explosive atmosphere. The regulation in conjunction with the Hazardous Substances Ordinance (GefStoffV) and the Technical Rules for Hazardous Substances (TRGS) 720, 721, 722, 723 and 724 specifies the content, updates and testing obligations. Supervision is carried out by the responsible occupational safety authorities of the federal states and the professional associations. Violations are administrative offenses according to Section 22 BetrSichV with fines of up to 25,000 euros, in serious cases criminal offenses according to Section 23 BetrSichV or Section 327 StGB with a prison sentence of up to three years. In addition, there is the personal liability of the management in accordance with Section 130 OWiG in the event of breaches of supervisory duties.

This article is aimed at hazardous materials officers, occupational safety specialists, operations managers and management with explosion risks in production, storage or processing. It describes the eight mandatory contents of an explosion protection document according to Section 6 Paragraph 9 BetrSichV, the methodological requirements from TRGS 720, the definition of Ex zones, the ignition source analysis according to TRGS 723 and the interlinking with risk assessment, testing obligations, instructions and external company coordination. CIVAC, a compliance platform and officer-as-a-service, maintains documentation on a workspace with 490 ready-to-use audit templates, documented reporting line and EU data residency.

§ 6 BetrSichV obliges the employer to create and update the explosion protection document before starting work and immediately with any relevant changes. The obligation applies regardless of the number of employees: even a single workplace with a dangerous, explosive atmosphere triggers the full obligation. The explosion protection risk assessment according to § 4 BetrSichV is the basis and must be completed before the documents are created.

The regulations are multi-layered. The BetrSichV implements Directive 1999/92/EC (ATEX 137) into German law. The GefStoffV also regulates the risk assessment for activities involving hazardous substances. TRGS 720 (hazard assessment for explosion protection, as of 2024) provides the methodological instructions. TRGS 721 (Assessing the probability of hazardous explosive atmospheres) and TRGS 722 (Avoiding or limiting hazardous explosive atmospheres) are supplemented. TRGS 723 covers the avoidance of effective ignition sources, TRGS 724 covers constructive measures.

Anyone who deviates from the TRGS must justify that at least equivalent safety is achieved (Section 4 Para. 3 BetrSichV). This justification must be presented in writing and documented in the explosion protection document. CIVAC maintains the explosion protection document together with the risk assessment for hazardous substances and the test documentation on a workspace with versioning and the four-eye principle. The reporting line to management is documented, the Hazardous Substances Officer is operationally responsible. In systems that are classified according to the Major Accident Ordinance (12th BImSchV), the incident representative is added, whose duties run parallel. The interface to DGUV Regulation 1 and the TRBA rules must also be taken into account if biological or other hazards are involved. Interaction with the fire protection officer is regularly recommended because explosions can result in fires. The appointment certificate, signed, filed, verifiable.

§ 6 Paragraph 9 BetrSichV finally lists what the explosion protection document must contain. First, a description of the workplace and work processes including location and function. Secondly, the results of the risk assessment according to § 4. Thirdly, the dangerous explosive atmospheres in question and their probability, i.e. the division into zones according to Annex 1 BetrSichV.

Fourth, the protective measures taken or to be taken according to the state of the art, including technical, organisational and personal measures. Fifthly, the determination of the areas in which minimum regulations according to Annex 2 BetrSichV apply, including the requirements for the device and protective system categories according to Directive 2014/34/EU (ATEX 114). Sixth, the measures to protect against dangerous, explosive atmospheres, including testing before initial commissioning and after testing changes.

Seventh, the documentation of the measures taken with those responsible, due dates and evidence. Eighth, the coordination regulations for the activities of several employers in the same area. These eight mandatory contents are the minimum requirement. In practice, experts add additional sections: substance data, system list, graphical Ex zone plan, test plan, training plan, emergency plans, change and release regime, test protocols. CIVAC provides a structured template that covers all eight mandatory contents and links them to the versioned files. Each mandatory information is linked to a document list so that the supervisory inspector can navigate directly to the document for each content without having to search in unconnected folders. The graphical plant plans are also managed and versioned in the workspace, including the zone marking and the location identifiers according to Appendix 3. Changes to the plant status generate automatic check tasks so that the document correctly reflects the plant status at all times. Audit-proof, documented, § 6 BetrSichV-proof.

The division into Ex zones follows Appendix 1 BetrSichV and distinguishes gas/vapor/mist areas (zones 0, 1, 2) from dust areas (zones 20, 21, 22). Zone 0 (gas) or Zone 20 (dust) describes areas in which a dangerous, explosive atmosphere is present permanently or for long periods or frequently. Zone 1 or Zone 21 describes areas in which it occasionally forms. Zone 2 or Zone 22 describes areas in which it only occurs for a short time or in the event of a fault.

The determination is based on TRGS 721 with specific probability thresholds: Zone 0 from 1,000 hours per year, Zone 1 between 10 and 1,000 hours, Zone 2 under 10 hours. The thresholds are orientation values ​​and can be justified differently in individual cases if measurement or calculation data prove this. The definition of the zone controls the permissible device category according to ATEX 114: In zone 0 only devices of category 1G are permitted, in zone 1 at least category 2G, in zone 2 at least category 3G. Analogous for dust.

The zones must be shown graphically in system plans and marked at the workplaces, usually with the EX warning sign according to Appendix 3 BetrSichV. Determining zones is a technically demanding activity and is often accompanied by external experts. CIVAC documents the zone definition with justification, data, graphic attachments and versioning in the workspace. The occupational safety specialist provides advice and the company doctor is involved in health-related aspects. Experts in accordance with Section 14 BetrSichV or VdS-recognised bodies are also documented and integrated via the workspace. Others run compliance like a filing cabinet. We run it like software.

TRGS 723 lists 13 categories of ignition sources that must be processed in the analysis. Hot surfaces, flames and hot gases including hot particles, mechanically generated sparks, electrical systems, stray currents and cathodic corrosion protection, static electricity, lightning, electromagnetic waves, ionizing radiation, ultrasound, adiabatic compression and shock waves, chemical reactions, biological activity such as self-heating. Each category is systematically checked.

The evaluation follows the principle of taking into account normal operation, foreseeable malfunctions and rare malfunctions. In zone 0/20, only ignition sources that remain ineffective even in the event of rare malfunctions are permitted. In zone 1/21, protection against ignition sources in the event of foreseeable faults must be guaranteed. In zone 2/22, protection is sufficient in normal operation. The measures are documented and made traceable per zone, per system and per ignition source category.

The analysis of static electricity when conveying bulk goods, the grounding of containers and pipelines and the selection of tools made of low-spark materials require special attention. Maintenance and cleaning work also often creates unnoticed sources of ignition. CIVAC carries out the ignition source analysis as a systematic checklist with 13 categories for each system and zone, with note fields for measures and evidence. The participation of the occupational safety specialist, the electrical expert according to DGUV regulation 3 and the system operator is documented in the workspace. Changes to the system automatically generate a test task for the ignition source analysis, so that there is no situation in which the measures no longer reflect the system status. Training needs are derived from the identified sources of ignition and are integrated into the training plan. Own measures that follow from the 13 TRGS categories are linked to the due date, person responsible and inspection interval. The auditor calls, the evidence is ready.

§ 14 BetrSichV regulates the testing of work equipment, supplemented by Appendix 2 for systems in potentially explosive areas. Before initial use, an inspection by a person authorised to inspect (zPbP) or by an approved monitoring body (ZUeS) is required, depending on the type of system. Systems in zones 0, 1, 20, 21 are subject to inspection by a ZUeS in accordance with Annex 2, Section 3 BetrSichV.

The recurring inspection follows set intervals. For systems in zones 0, 1, 20, 21 the interval is usually three years, for systems in zones 2 and 22 it is six years, counting from the last inspection. Change and repair tests are necessary when changes are made to systems that require testing. The test reports must be kept until the next test is carried out, but at least for six years.

The test intervals and results must be documented in the explosion protection document. Changes to the system or the substance trigger an obligation to update, as do changed procedures or new scientific findings. CIVAC keeps the test file for each system with due dates, test reports, responsible persons and escalation paths in the workspace and automatically reminds you of expiring intervals. The ISO/IEC 27001:2022 workspace ensures that electronic test reports and digitized evidence are kept under EU data residency and with an audit trail. During ongoing operation, workspace filters recognise expiring test intervals 90 days before they are due and control the test order to the system operator and the responsible body. This means there are no untested remaining stocks and no outliers in the test file. Test reports are stored with reference to the respective system, so that the test history remains traceable even after personnel changes in maintenance. The appointment certificate, signed, filed, verifiable.

§ 6 Para. 9 BetrSichV requires the explosion protection document to be updated immediately with every relevant change. A regular update is not mandatory, but makes sense in practice: an annual check of the topicality protects against silent obsolescence. Typical reasons are changes to facilities, substances, processes, facility locations, personnel levels with relevant functions, or changed legal situations including new TRGS versions.

The supervisory authority checks the topicality based on the date, version status and reason for the last update. A document that refers to TRGS 720 in an outdated version will be objected to in the examination. Likewise, a document that describes a system that has since been dismantled or converted. The version history must be traceable, with the reason for the change, those responsible and the release regime.

CIVAC carries out the versioning automatically and requires a documented reason and four-eye approval for each change. When changes are made to systems, an update task is automatically generated for the hazardous materials officer, with a due date and escalation path. Licence the workspace for your internal representatives, or have our representatives order it. The officer-as-a-service mode is particularly suitable for medium-sized companies without their own hazardous materials team, who would otherwise lose out on continuous updates. CIVAC also automatically reminds you of external changes such as new TRGS versions, new ATEX guidelines or professional association information, so that no external update obligations go unnoticed. For metabolisms in production, the currentness of the substance data sheets (safety data sheet according to Regulation No. 1907/2006 REACH) is automatically checked and integrated into the update process. Changes in the CLP classification according to Regulation No. 1272/2008 are also reflected in the investment area. A separate overview of the adjacent roles can be found on the Rolueübersicht.

§ 12 ArbSchG and § 14 GefStoffV oblige the employer to instruct employees. For workplaces in potentially explosive areas, § 9 BetrSichV is supplemented: Employees must be instructed about dangers, protective measures and behaviour in an emergency, upon starting work and at least once a year. The instruction is workplace-related and cannot be replaced by general safety instructions.

The content of the instruction is the location and significance of the Ex zones in the workplace, the material properties of the combustible substances present (data sheets according to EU Regulation No. 1907/2006), the protective measures taken, the permitted work procedures and tools, the behaviour in the event of disruptions and emergencies, the first aid measures, how to deal with personal protective equipment. The instruction must be documented with the date, content, person responsible and signatures of the participants.

Special situations include the use of external companies, maintenance and repair work as well as work with ignition sources. Here, the coordination according to Section 8 BetrSichV must be documented with a release certificate (permission certificate). Hot work in potentially explosive areas requires a documented hot work approval procedure. CIVAC maintains training and instruction plans together with the appointment certificates and test files on a workspace, with annual reminders, participant lists and electronic signature. Templates for permits, safety instructions and hot work clearances are provided for external companies, including feedback to the client and archiving of the evidence. Anyone who uses the workspace can prove the annual training status per employee and per workplace with just one click. Lost evidence and signatures that cannot be found are a thing of the past. Trainees, temporary workers and interns are also recorded in the training register and provided with separate content. Repeat training courses will be automatically announced 30 days before expiry. Audit-proof, documented, § 9 BetrSichV-proof.

Recurring categories of findings can be identified from the practice of occupational safety supervision and professional associations. First, missing or outdated zone definition: Ex zones are not defined, not updated or not graphically represented. Secondly, incomplete ignition source analysis: The 13 categories of TRGS 723 were not processed systematically, static electricity was overlooked, maintenance was not taken into account.

Thirdly, expired test intervals: systems have not been tested by ZUeS or zPbP for years, test reports are missing or cannot be found. Fourth, lack of training: employees cannot describe the location of the zones, work permits are issued without a documented process. Fifthly, expired or missing appointment of the hazardous substances officer: The position is not occupied or not currently occupied, the reporting line is not documented.

Sixth, lack of coordination among external companies: The obligations according to Section 8 BetrSichV are not implemented, permits are missing or are incomplete. Seventh, lack of integration with the risk assessment for hazardous substances: the GefStoffV assessment and the BetrSichV assessment run separately instead of integrated. Eighth, missing hot work permits: Welding work and other hot work were carried out without documented approval, the fire station was not defined. Ninth, inadequate labelling of the zones: EX warning signs are missing, illegible or deviate from the current system status. Tenth, lack of interaction with the incident representative in systems according to the 12th BImSchV. Eleventh, inadequate emergency and alert plans that cannot be substantiated by realistic practice evidence in the exam. CIVAC addresses these categories of findings with 490 ready-to-use audit templates, automatic reminders for inspection intervals and instructions, as well as an integrated assessment logic that keeps BetrSichV and GefStoffV on one file. The auditor calls, the evidence is ready.

CIVAC is a compliance platform and officer-as-a-service for German companies with explosion risks in production, storage or processing. The workspace manages 25 representative roles on one reporting line, with 490 ready-to-use audit templates, 93 ISO/IEC 27001:2022 controls as a platform basis, EU data residency and a documented reporting line to management. The explosion protection document sits centrally in this model, together with the risk assessment for hazardous substances, the test plans, the training certificates and the appointment certificate for the hazardous substances officer.

Licence the workspace for your internal representatives, or have our representatives order it. The typical initial assessment starts with an inventory of the existing documentation, an inspection of the potentially explosive areas and a gap analysis against Section 6 BetrSichV. This is followed by the appointment of the hazardous substances officer (appointment certificate, signed, filed, verifiable) and the workspace provisioning within 2 working days SLA. The creation or updating of the document follows a structured template with the eight mandatory contents and automatic versioning.

Auditors from the occupational safety authority and auditors from the professional association find a closed file. Management finds a documented reporting line. The hazardous materials officer finds a workspace that does not complicate the ongoing duties, but rather organises them. Turn reading into an assignment. Reach the CIVAC team at info@civac.de or via the contact form on civac.de to discuss a specific scoping plan for your system landscape. If requested, CIVAC can also coordinate with the professional association, the occupational safety authority and the ZUeS to plan inspection dates, as well as provide ongoing support in the quarterly reports to the management. You will receive a written cost estimate with audit trails and investment requirements.