DGUV regulation 2: Calculate basic care, step by step with a formula

Since 2011, DGUV Regulation 2 (DGUV V2) has specified company medical and safety support in accordance with Section 2 ASiG for companies with more than ten employees. Appendix 2 of the regulation divides companies into three care groups (BG 1, BG 2, BG 3) and assigns each group a factor in hours per employee per year. This number, multiplied by the relevant number of employees, results in the basic care. The formula is simply: working time for basic care per year = number of employees × hour factor of the care group. The division between occupational safety specialists (Sifa) and company doctors is at least 40 to 20 percent or vice versa, depending on the risk situation. The underlying requirement is clear: plannable minimum operating times for the central occupational safety functions, depending on size and risk.

What sounds technically simple often fails in practice due to three points: the incorrect assignment to the care group, the inaccurate counting of employees (part-time, work contracts, trainees) and the lack of documentation of the company-specific support according to Appendix 4. This article shows the calculation step by step, explains the impact profiles of the care groups, and goes into the special cases and arranges the duties in the file cycle of an audit-proof occupational safety system. Others run compliance like a filing cabinet. We run it like software. At the end you will know how many hours you need per year, how they are divided and how the evidence can be kept in an audit-proof manner.

DGUV Regulation 2 is the specification of the Occupational Safety Act (ASiG) that is binding for statutory accident insurance. Section 2 ASiG obliges the employer to appoint an occupational safety specialist and a company doctor for companies with more than ten employees on a regular basis. DGUV V2 supplements this obligation with specific operating times, depending on the size of the company and the risk situation. Every professional association and accident insurance company has issued DGUV V2 as an accident prevention regulation, so that it applies directly to member companies. Violations are unlawful according to § 25 ASiG and according to the fine provisions of the accident prevention regulations.

According to § 13 ArbSchG and § 13 OWiG, the entrepreneur or the management is responsible for implementation. The appointment of the occupational safety specialist and the company doctor is made in writing. The appointment certificate must contain tasks, authorities, reporting line and time budget. Without a verifiable appointment certificate, the Sifa function is not formally set up, which can lead to complaints from the responsible supervisory service or the professional association. The appointment certificate, signed, filed, verifiable: It is precisely this reflex that distinguishes tested occupational safety from improvised ones. In the event of damage, the order and the time budget are often the first documents that investigative authorities ask for.

For small businesses (10 or fewer employees), a separate alternative support model with entrepreneurial model training applies, which is not the subject of this article. For companies with more than ten employees, the calculation according to Appendix 2 DGUV V2 must be used. The regulation does not have a general de minimis limit: Even companies with eleven employees in a purely office environment must calculate and document the working time using a formula. The apparently low number of hours in BG 3 does not relieve the obligation to formally order and provide written documentation.

Appendix 2 DGUV V2 divides companies into three support groups. The allocation is made by economic sector based on the WZ classification. Care group 1 (high risk) includes companies with an increased risk of accidents and illness, such as the construction industry, metal processing and the chemical industry. The hourly factor is 2.5 hours per employee per year. Care group 2 (medium risk) includes, for example, the wood and furniture industry, catering, and care facilities with moderate risk. The hourly factor is 1.5 hours per employee per year. Support group 3 (low risk) includes administration, banks, insurance, advice. The hourly factor is 0.5 hours per employee per year. The range between BG 1 and BG 3 is deliberately set at a factor of five: The regulation therefore reflects the different risk profiles directly in the required operational time.

Assignment to the correct economic sector is not trivial. Mixed operations (e.g. an administration with an attached warehouse) receive the assignment of the predominant activity or, depending on the professional association, a differentiated assignment for each part of the company. In case of doubt, the responsible professional association will make a binding decision. Anyone who uses a table on the Internet should compare it with the decision from their own professional association, because the assignment can change over the years, especially after changing industries or starting new activities.

The hourly factors are the basic care together for Sifa and the company doctor. They are not shown individually per function. Only in the second step is the division between Sifa and the company doctor according to Appendix 2 with the 40-to-20 percent scheme. This is the most common misunderstanding: The number 1.5 hours in BG 2 refers to the sum, not the proportion of a single function. Anyone who calculates individually will end up in a costly explanation loop during the audit.

The basic formula is: Operating time for basic care per year = N × F. N stands for the number of employees and F for the hourly factor of the care group. Example: A mechanical engineering company with 240 employees in care group 1 (F = 2.5 hours) has basic care of 240 × 2.5 = 600 hours per year. These 600 hours are divided between Sifa and the company doctor, with each function receiving at least 20 percent and the other person receiving a maximum of 80 percent. In practice, many companies in BG 1 distribute around 60:40 in favor of Sifa because the safety-related tasks predominate.

Second example: An administration with 80 employees in BG 3 (F = 0.5 hours) has basic care of 80 × 0.5 = 40 hours per year, with a split of around 50:50 between Sifa and the company doctor. Third example: A nursing home with 120 employees in BG 2 (F = 1.5 hours) has 180 hours of basic care per year, often with a 50:50 split because of the equally strong safety and occupational health components.

Important: The calculated hours are minimum values. DGUV V2 allows a longer operating time if the risk assessment requires this. However, it fundamentally prohibits any undercutting. Audit-proof, documented, § ASiG-proof: The calculation is recorded in writing, with reference to the BG decision on assignment, the number of employees as of the reference date and the division between Sifa and the company doctor. Any change in the number of employees or the activity structure triggers a recalculation, at least annually. Sifa's activity report shows the current calculation and distribution, supplemented by the actual hours worked.

Counting employees is the second common stumbling block. According to Appendix 2, all employees who are employed by the company, including part-time employees, are counted. Part-time employees are converted into full-time employees (e.g. two half-day employees = one full-time equivalent), although this does not necessarily have to be done on a head-by-head basis; The professional associations often also allow the head count. Trainees, interns and working students count. Part-time employees also count as long as they work regularly in the company. Employees on parental leave and with a dormant employment relationship must also be examined on a case-by-case basis.

Temporary workers who are insured by the temporary employment agency, as well as self-employed and freelance employees are not counted, provided they are not bound by instructions. In the case of work contracts, it is important to check carefully whether it is a genuine work contract or a hidden temporary employment contract. In case of doubt, the people are counted because the professional association checks in the audit who is actually employed in the company, not who is formally included in the payroll program. A short written explanation of the counting method protects against later questions. In holding structures, each business location must be counted separately because DGUV V2 is based on the company, not the group.

The key date for counting is not regulated nationwide. The average number of employees from the previous year or the reference date of January 1st of the calculation year is usual. Consistency is important: If you use the average once, you should continue to do so in subsequent years. If the number of employees fluctuates significantly (e.g. seasonal operations), a justified method must be chosen and documented in the Sifa report to management. A change in method without justification leads to questions in the audit.

According to Appendix 2, Section 2.2 DGUV V2, basic care is divided between Sifa and the company doctor. The minimum ratio is not rigid, but depends on the risk situation of the company. Usual distributions are 50:50 as standard, 60:40 in favor of the Sifa in technical and safety-oriented companies (production, construction sites) and 60:40 in favor of the company doctor in health-oriented companies (nursing, laboratory, piecework production with stress areas). The division requires justification and should be recorded in the appointment certificate or a separate division document. The Sifa and the company doctor agree on the division together; In the event of disagreement, management decides on the basis of the risk assessment.

The division may be adjusted over the years if the risk situation changes. A justification for this adjustment must be anchored in the risk assessment document. It is not the exact percentage that is relevant to the audit, but rather the consistency between distribution, risk assessment and actual operational times. Anyone who has planned 60 percent for the Sifa but has only provided 40 percent of the Sifa has a deviation that requires justification. A short written statement with corrective measures closes this gap before the audit.

The evidence is provided via activity reports. Sifa prepares a written activity report for management at least annually, as does the company doctor. Both reports contain the hours worked, the focus of the work, identified risks and recommendations. The auditor calls, the evidence is ready.: Exactly this reflex is the simplest form of audit resistance. In the CIVAC workspace, the activity reports are maintained as a template and linked to the hour tracker so that target and actual hours are shown in a single view. The appointment certificate, signed, filed, verifiable: Audit-proof is created through exactly this link.

Basic care is only one half of DGUV V2. Appendix 4 also requires company-specific support, which is not included in the basic support. It is described in a catalogue with eleven areas of responsibility, including examining new jobs, purchasing work equipment, investigating accidents and occupational diseases, advising on reorganization, company integration management and occupational health care. For each area of ​​responsibility, it must be checked on a company-specific basis whether it is relevant in the individual case, and the planned care time must be documented.

In contrast to basic care, there is no fixed hourly factor for company-specific care. The time required results from the risk assessment and the specific operational events. A company that sets up a new production line has significantly higher costs in the areas of procurement and new jobs in the year in question. A company that has had an accident at work resulting in personal injury will have to spend more time investigating the accident. These fluctuations are desirable and part of the regulatory logic; they do not have to be capped by fixed hours. It is important to provide a comprehensible justification for each amount of hours in the activity report. A plausibility check of the Sifa number of hours compared to the payroll is recommended so that target and actual are consistent.

In practice, company-specific support is often underestimated or under-documented. Anyone who only shows basic care in the audit has a gap. The professional associations are increasingly specifically examining Annex 4 tasks because this is where most of the real protection gaps become visible. A realistic ratio is approximately 1 to 1 between basic support and company-specific support, with large fluctuations depending on the industry and event situation. These hours are in addition to basic care and must be shown separately in the activity report with reference to the respective areas of responsibility.

The documentation requirements of DGUV V2 include three core documents. Firstly, the written appointment of Sifa and company doctor with tasks, authorities, time budget and reporting line. Secondly, the written calculation of the basic care and company-specific care with reference to the number of employees, the care group and the distribution. Thirdly, the annual activity reports of both functions to the management, with hours worked and key content areas. In addition, there are the protocols of the Occupational Safety and Health Committee (ASA) in accordance with Section 11 ASiG for companies with more than twenty employees.

Supervision is carried out by the responsible professional association or accident insurance fund, supplemented by the state occupational safety and health supervision of the federal states. Complaints typically occur in four patterns: missing or outdated appointment certificate, missing calculation of operating times, documented distribution deviates from actual performance, company-specific support according to Appendix 4 is only documented cursorily or not at all. The fines are moderate (up to 10,000 euros according to Section 25 ASiG per violation), but the liability consequences in the event of accidents can be significant because they affect the organisational negligence of the management.

In the event of damage, for example after a serious accident at work, the documentation of the DGUV V2 becomes a question of evidence. Anyone who cannot prove the calculation or activity reports are not available will quickly find themselves in a discussion about organisational culpability. Audit-proof, documented, § ASiG-proof is not created by volume, but by clear evidence: appointment certificate, calculation sheet, allocation document, activity reports with date and signature, annual update. An electronic audit trail in the workspace reliably replaces hand-held filing and is available for inspection at any time. The auditor calls, the evidence is ready. A clearly managed file inventory reduces audit preparation from days to hours.

The DGUV V2 is administratively manageable, but in practice it is often distributed into several Excel files, Word documents and file folders. The result is a fragmented file situation in which consistency between calculations, orders and activity reports is difficult to maintain. Anyone who is asked in the audit about the current number of employees, the hourly factor and the distribution must be able to answer quickly, with evidence. In the stressful situation of the audit, three scattered files become the source of contradictory statements.

The CIVAC workspace bundles the DGUV-V2 obligations in a structured module: calculation sheet with automatic updating when the number of employees changes, appointment certificate templates for Sifa and company doctor, allocation document with justification field, hour tracker for actual working hours and activity report generator. 490 ready-to-use audit templates cover occupational safety, fire protection, hazardous materials and other related duties. EU data residency is standard, which is relevant when the activity reports and preventive examinations are related to personnel. Data protection and occupational safety are closely intertwined here, which is why the interface to the data protection officer is documented. Order processing with the external Sifa service provider is stored and versioned in the workspace. The appointment certificate is also maintained centrally with the date and signature, instead of disappearing in email attachments.

The integration with other representatives is structurally present in the workspace: Fire protection officer, hazardous materials officer, first responder and company emergency organisation can be mapped as linked roles. CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. The SLA for the external appointment of the Sifa or the company doctor is two working days; two to six weeks are typical. This speed is particularly helpful when a change becomes urgent, for example when the previous Sifa is terminated.

If you have to keep the DGUV-V2 calculation up to date, you are typically faced with one of three questions: Is the assignment to the care group still correct, is the calculation documented and up to date, and is the company-specific care according to Appendix 4 clearly recorded. These three questions can be answered in a one-hour inventory. The result is either the all-clear or a small list of defects that can be dealt with in a few days. If you do this annually, you spread out the effort instead of having to spend time catching up before the next audit. A lean routine replaces the hustle and bustle of the end of the year.

CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. In the workspace model you get the DGUV-V2 module with calculation sheet, appointment certificate templates, allocation document and activity report generator. In the officer model, an appointed external occupational safety specialist or a company doctor with DGUV V2 experience takes over operational control. The first order is placed in two working days, instead of two to six weeks in the classic market. The reporting line to management is contractually secured and managed in a structured manner in the workspace.

Both models can be combined: workspace for ongoing maintenance, external SIFA for technical control. If you would like an initial assessment of whether your DGUV-V2 file is audit-proof, write to info@civac.de or use the contact form on civac.de. You will receive an initial evaluation with a model recommendation and a specific order path within two working days. Turn reading into a mandate.: The fastest way from an Excel calculation to a verifiable DGUV-V2 file is the reliable order, supported by a Sifa with a mandate and a workspace that knows the calculation.