Occupational Health Services in Germany: English-Speaking Company Doctors and the ASiG Framework

Under section 2 of the Arbeitssicherheitsgesetz (ASiG) of 12 December 1973, every employer in Germany is required to appoint occupational physicians and safety specialists in writing, regardless of company size or sector. The accompanying DGUV Vorschrift 2, which has been binding since 1 January 2011, defines the minimum care hours per employee, the scope of basic and operational care, and the documentation requirements that supervisory authorities such as the Berufsgenossenschaften will check during an audit. For international employers running German subsidiaries with English as the working language, the obligation itself is not the problem. The problem is that the legal framework, the works-council coordination, and the G-examination catalogue of the DGUV are originally written in German, and any non-compliance still triggers fines of up to 25,000 euros per case under section 25 ArbSchG.

This guide explains how occupational health services are structured in Germany, which examinations are mandatory, and how an English-speaking company doctor (Betriebsarzt) can be integrated into a bilingual documentation chain. You will see which records the Berufsgenossenschaft expects, how the works council is involved, and how CIVAC bundles the documentation in a workspace that produces both a German legal record and an English management summary. The article focuses on the operational reality for HR and compliance leads who need to brief international headquarters while remaining audit-proof in Germany.

Section 2 paragraph 1 of the Arbeitssicherheitsgesetz states that the employer has to appoint occupational physicians and grant them the tasks listed in section 3 ASiG. The obligation applies from the first employee, irrespective of legal form, sector, or revenue. There is no threshold and no exemption for international subsidiaries or for branch offices of foreign parent companies. DGUV Vorschrift 2 then translates this principle into operational care hours. For a typical office environment in care category III, the minimum is 0.6 hours of occupational-medical care per employee per year, split between basic care and operational care. Production environments in category I or II reach 1.6 to 2.5 hours per employee, with specific add-ons for hazardous substances, biological agents, or radiation work.

The appointment must be in writing, naming the physician, the scope, and the contractual basis. A purely verbal arrangement does not satisfy section 2 ASiG and will be challenged in any audit by the Berufsgenossenschaft. International employers often default to a contract in English, which is permitted, but the German supervisory authority will still ask for a German-language version of the appointment letter, the care concept, and the annual report. CIVAC operates as a Compliance-Plattform und Officer-as-a-Service and offers a bilingual Betriebsarzt appointment record with synchronised German and English versions, so the document is filed once and exported in either language on request. Bestellurkunde, unterschrieben, abgelegt, belegbar. The works council, where one exists, has co-determination rights under section 87 BetrVG on the selection and on the care concept, which means the appointment process is not purely an HR decision but a tripartite arrangement between employer, works council, and physician.

DGUV Vorschrift 2 distinguishes basic care (Grundbetreuung) and operational care (betriebsspezifische Betreuung). Basic care covers the recurring duties such as workplace inspections, advice on workplace design, occupational-medical examinations, risk assessments, and participation in the Arbeitsschutzausschuss. Operational care covers project-driven tasks such as the introduction of new substances, organisational changes, restructuring, or specific incidents. The care category, defined in Annex 2 of DGUV V2, determines the minimum hours: category I for high-risk operations such as construction or chemicals (2.5 hours per employee per year), category II for medium-risk operations such as logistics or food processing (1.5 hours), and category III for office and administrative work (0.6 hours).

For a 200-employee German office subsidiary in category III, this translates into 120 hours of occupational-medical care per year, split between basic care and operational care, plus the hours for the safety specialist (Fachkraft für Arbeitssicherheit) under the same regulation. The works council and the employer agree on the split each year. The annual report (Jahresbericht) of the company doctor is the central document that the Berufsgenossenschaft will request in an audit, and it must show the hours actually delivered, the topics covered, and the recommendations issued. An English-speaking physician network ensures that the report is written in German for the authority and summarised in English for the international parent. The safety specialist (SiFa) works alongside the physician on the same care concept, and the workspace synchronises both schedules so that double-bookings and gaps are visible before the year ends. Andere führen Compliance wie einen Aktenschrank. Wir führen sie wie Software.

The German occupational-medicine system uses a catalogue of so-called G-examinations, defined by the DGUV (Deutsche Gesetzliche Unfallversicherung). Each G-number stands for a specific examination protocol tied to a workplace hazard. G25 covers driving and steering activities, G37 covers screen workstations, G41 covers work at heights, G42 covers biological agents, and G46 covers musculoskeletal stress. The examinations are classified as Pflichtvorsorge (mandatory, with a Bescheinigung required before work assignment), Angebotsvorsorge (offered by the employer, with the employee deciding whether to attend), and Wunschvorsorge (requested by the employee). The Verordnung zur arbeitsmedizinischen Vorsorge (ArbMedVV) of 18 December 2008, last amended 2019, defines which examinations fall into which category.

In an English-speaking environment, the most common examinations are G37 for screen workstations, requested by the employee, and G46 for office ergonomics. Production and laboratory settings add G42, G24 (skin protection), and G20 (noise). The Bescheinigung issued by the company doctor is a structured German document with a fixed format defined by the DGUV. It does not contain the diagnosis, only the fitness verdict, which protects the employee under section 6 ArbMedVV. International HR teams sometimes ask for a translated diagnosis, which is not permitted. What is permitted, and useful, is a bilingual fitness-verdict summary that captures the legally relevant outcome (fit, fit with restrictions, not fit) and the recommended follow-up. The CIVAC workspace stores the original Bescheinigung in German and produces a bilingual cover note that the HR business partner can share with the international line manager without breaching ArbMedVV. Der Prüfer ruft an, der Nachweis liegt bereit.

Section 87 paragraph 1 number 7 of the Betriebsverfassungsgesetz (BetrVG) grants the works council a co-determination right on matters of accident prevention and health protection, which directly covers the appointment of the company doctor, the care concept, and the annual hours. Section 9 ASiG requires the employer to consult the works council before appointing or dismissing the physician. In practice this means three documented steps: a draft proposal from HR, a council session with a documented vote, and a written confirmation that is added to the appointment record. International subsidiaries often underestimate this step because the parent organisation is unfamiliar with the German co-determination system. The result is an appointment that is legally invalid because the council was not consulted, which the Berufsgenossenschaft will note in an audit.

The Arbeitsschutzausschuss (ASA), required under section 11 ASiG for employers with more than 20 employees, brings together the employer, two works-council members, the company doctor, the safety specialist, and the safety officers (Sicherheitsbeauftragte). The ASA meets at least quarterly and produces a written protocol that becomes part of the audit trail. CIVAC provides a bilingual ASA protocol template with agenda blocks for risk topics, follow-up actions, and decisions, so that the international parent can read the outcome in English while the legally binding version remains in German. Lizenzieren Sie den Workspace für Ihre internen Beauftragten, oder lassen Sie unsere Beauftragten bestellen. In both models, the ASA cadence is tracked in the workspace with reminders before each quarter, and the protocols are versioned with timestamps so that no meeting falls off the calendar by accident.

The principle is simple: the German supervisory authority always sees German documents, the international parent always sees English summaries, and both versions reference the same underlying record. The appointment letter of the Betriebsarzt is in German because the Berufsgenossenschaft will check it against the wording of section 2 ASiG. The risk assessment under section 5 ArbSchG is in German because labour-court proceedings and authority correspondence happen in German. The G-examination Bescheinigung is in German because the format is fixed by DGUV. What can and should be bilingual are the cover notes, the executive summaries, the policy statements, and the works-council communications that the international HR team uses to brief headquarters.

A common mistake is to translate the legally binding documents into English and lose the original German version. This makes the document unusable in an audit and creates a documentation gap that the Berufsgenossenschaft will flag. The reverse mistake, keeping only German documents, leaves the international parent in the dark about its German obligations. CIVAC solves this with a synchronised document model: each compliance artefact has a German master and an English summary, both with the same version stamp, signed by the responsible officer. The workspace also produces an English annual report extract that takes the legally binding German Jahresbericht and reduces it to the key indicators that an international HR director needs for the global health-and-safety dashboard. Bestellurkunde, unterschrieben, abgelegt, belegbar. The dual layer also helps in mergers and due diligence, where a foreign buyer or auditor needs to assess the German occupational-health setup quickly without a full legal review of every German document.

Section 5 of the Arbeitsschutzgesetz (ArbSchG) requires every employer to assess the working conditions and to derive concrete protection measures, including measures against psychological strain. The Bundesarbeitsministerium added the explicit mention of psychological strain (psychische Belastung) in 2013, and since then the Berufsgenossenschaft routinely asks for documented evidence in audits. The risk assessment must cover physical hazards, biological hazards, ergonomics, working-time arrangements, and psychological strain, with a documented review when the working conditions change or after a relevant incident. The company doctor and the safety specialist support the employer in the risk assessment but do not replace the employer's responsibility, which remains with the legal representative of the company.

For international subsidiaries with English as the working language, the practical challenge is the employee survey on psychological strain. The standardised instruments such as the BAuA tool or the Copenhagen Psychosocial Questionnaire (COPSOQ) exist in German and English, but the cultural calibration is sometimes lost in translation, which produces questionable results. The CIVAC workspace uses a bilingual COPSOQ instrument with culturally validated wording, runs the survey in pseudonymous form, and produces a heat map at the team level rather than the individual level, which protects employee privacy under the DSGVO. The results then feed back into the risk assessment under section 5 ArbSchG, and the documented measures become part of the audit trail. Frist laeuft ab Kenntnis. The 93 controls of ISO/IEC 27001:2022 cover the data-protection side of the survey, so the same workspace satisfies both the occupational-health obligation and the information-security obligation in one record.

International groups often send expatriates to Germany or assign German employees abroad. The ArbMedVV regulates the medical examinations for such assignments in section 4 and Annex 1, with G35 (tropical and subtropical climates) and G31 (overpressure work, relevant for diving and tunnel construction) as the most frequent. For expatriates inbound to Germany, the employer must offer a G-examination at the start of the assignment if the workplace falls under the relevant category, and the examination must be repeated at the intervals defined in the ArbMedVV. The Bescheinigung is in German and follows the same format as for local employees, which sometimes confuses HR teams who expect a globally portable medical record.

For German employees sent abroad, the G35 examination must be offered before the assignment, during the assignment at defined intervals, and at the end of the assignment. The examination protects the employee, satisfies the section 5 ArbSchG risk assessment for the foreign workplace, and is the basis for the social-security clearance under the SGB VII for accident insurance. CIVAC integrates the assignment management with the Betriebsarzt schedule, so that an inbound expatriate is automatically scheduled for the relevant G-examination at start, mid-term, and end. The workspace also tracks the validity of each Bescheinigung and warns HR sixty days before a required follow-up examination, which avoids the situation where an employee continues to work in a hazard category without a current fitness verdict. Der Prüfer ruft an, der Nachweis liegt bereit. The audit-relevant trail covers appointment, schedule, conduct, and result, with timestamps that satisfy both the Berufsgenossenschaft and the international assignment auditor.

The cost of occupational health services in Germany depends on care hours, location, and the seniority of the physician. As a benchmark, a category III office subsidiary with 200 employees pays between 12,000 and 24,000 euros per year for the company-doctor service, plus 8,000 to 16,000 euros for the safety specialist, plus the cost of the G-examinations on a per-case basis. G37 typically costs between 60 and 120 euros per examination, G42 between 90 and 180 euros, and G35 between 250 and 450 euros depending on the destination and the diagnostic scope. The annual report, the ASA protocols, and the risk assessment are usually included in the basic care, while operational care is billed by the hour at rates between 140 and 220 euros for a senior occupational physician.

Contract models split into three patterns. First, a single external provider contract with a fixed annual flat fee covering all care hours and a separate price list for examinations. Second, an officer-as-a-service contract where CIVAC appoints the Betriebsarzt as an external officer, includes the workspace licence, and bills a transparent monthly subscription with all documentation included. Third, a hybrid where internal HR uses the workspace licence and CIVAC provides the physician only for specific G-examinations or for the ASA chairing. CIVAC-SLA: 2 Werktage statt 2-6 Wochen klassisch. The right model depends on workforce volatility, audit exposure, and the readiness of internal HR to operate a German-language documentation system. For international groups with three or more German entities, the officer-as-a-service model usually wins on cost because the workspace licence is shared and the documentation chain is unified across all entities, instead of paying three separate providers with three different filing systems.

The path from an English-language enquiry to a fully compliant German occupational-health setup takes four to eight weeks in a structured rollout. Week one and two cover the workforce profile, the care category, the care-hour calculation under DGUV V2, the works-council briefing under section 9 ASiG, and the drafting of the bilingual appointment letter. Week three and four cover the first ASA meeting, the risk assessment under section 5 ArbSchG, and the schedule of the initial G-examinations. Week five onward enters the regular operational rhythm with quarterly ASA, annual report, and rolling examinations. CIVAC delivers all of this as a Compliance-Plattform und Officer-as-a-Service, with 490 ready-to-use audit templates, the bilingual Bestellurkunde, an ASA agenda module, and a G-examination tracker that synchronises with HR systems via secure data exchange on EU servers.

You decide how deep you go: Lizenzieren Sie den Workspace für Ihre internen Beauftragten, oder lassen Sie unsere Beauftragten bestellen. The workspace alone is the right answer if you already have a German-speaking HR team that runs the documentation and only needs the bilingual master records. The officer-as-a-service answer is the right one if your German entity is small, recently founded, or post-acquisition, and you need a turnkey appointment that satisfies section 2 ASiG within two weeks rather than two months. Aus dem Lesen einen Auftrag machen. Write to info@civac.de or use the contact form on civac.de and you will receive a maturity assessment, a care-hour calculation, and a transparent offer in English and German within five working days. The Berufsgenossenschaft will check the German record. Your global HR team will read the English summary. Both documents will say the same thing, because they come from the same workspace, with the same version stamp, signed by the same responsible officer.