Online hygiene training: Which digital methods the health department recognises

According to Section 43 Paragraph 1 of the Infection Protection Act (IfSG), people who come into contact with food are only allowed to carry out their activities for the first time if they have received instructions from the health department. The follow-up instructions in accordance with Section 43 Paragraph 4 IfSG must be repeated by the employer every two years. According to Section 73 IfSG, violations are punished with fines of up to 25,000 euros.

Since 2020, many health authorities have been expanding their forms of instruction to include digital offerings. Depending on the federal state and office, the online initial instruction is permissible, subject to conditions or excluded. This article shows which online formats are considered legally secure instructions, how the follow-up instructions are organised digitally and which documentation obligations you cannot delegate.

§ 43 IfSG regulates the instruction of people who come into contact with certain foods on a commercial basis. The obligation applies to employees in food production, in restaurants, canteens, snack bars, bakeries, butcher shops and in community facilities that prepare or serve food.

The initial instruction is the responsibility of the health authority (Section 43 Paragraph 1 IfSG). It includes information on activity bans according to Section 42 IfSG, symptoms of the diseases mentioned there, personal hygiene requirements and reporting obligations. The instruction must be given before the first start of work and must be certified in writing or electronically.

The certificate must be kept by the employer and presented to the authorities upon request. The retention period is at least the period of employment; in supervisory practice, certificates should be kept for three years after leaving the company in order to be able to cover inquiries.

The follow-up instructions in accordance with Section 43 Paragraph 4 IfSG are provided by the employer at least every two years. It covers the same topics as the initial instruction and must also be documented in writing or electronically. This duty is most often violated in practice because awareness of the two-year deadline decreases.

An overview of the hygiene role and the operational tasks of the hygiene officer can be found on the CIVAC role page hygiene officer. The function is not mandatory for all companies, but it makes sense in community facilities, nursing homes and larger food companies as the person responsible for the follow-up instructions.

There is no uniform federal regulation for online instructions in accordance with Section 43 IfSG. Each health authority decides independently which formats it accepts as initial instruction. Three models have been established since 2020: live video conference with identity verification, asynchronous online module with subsequent examination, hybrid form with online learning content plus present identification.

Live video conference instruction is the most widespread online format. It typically takes place in groups of 10 to 25 people, lasts 45 to 60 minutes and ends with a short comprehension test. Identity verification is carried out by presenting your ID into the camera. The certificate is then issued electronically.

The asynchronous online module is permitted in some offices (e.g. in Bavaria, Hesse, NRW). The person completes a web-based learning module with a test, and the certificate is issued after a successful test. Identity verification is carried out via Video-Ident or via ID scan plus selfie. Format is flexible in terms of time, but not recognised everywhere.

The hybrid form combines e-learning for the content with a short face-to-face phase or video conference for identification and checking understanding. This model is preferred by authorities that have concerns about pure e-learning but want to enable efficiency gains.

Before each booking, the responsible health authority should confirm in writing that the planned form is recognised. Telephone information is inadequate. If the place of business changes, the old certificate continues to apply, but the new location may have stricter requirements for the subsequent instructions.

The follow-up instructions in accordance with Section 43 Paragraph 4 IfSG are the employer's obligation. It can be done completely digitally because the law does not prescribe a specific form. The prerequisite is that content is conveyed, participation is demonstrated and understanding is checked. These three elements must be kept documented.

In terms of content, the follow-up instruction includes the same mandatory topics as the initial instruction: activity bans according to § 42 IfSG, symptoms of the diseases mentioned there (cholera, typhoid, hepatitis A, infectious gastroenteritis, salmonellosis, etc.), personal hygiene requirements, reporting obligations to employers and health authorities.

The training duration should be at least 30 minutes, in many companies it is 45 up to 60 minutes. The subsequent comprehension test can be designed as a short online test with 8 to 15 questions. A success rate of 80 percent is considered an appropriate benchmark in supervisory practice.

Documentation: A certificate of date, duration, content, test result and signature (digital or physical) must be kept for each employee. The certificate must be able to be presented to the food inspectorate during workplace inspections. The appointment certificate, signed, filed, verifiable.

In the event of a delay: Anyone who exceeds the two-year deadline must follow up on the instruction immediately. According to strict interpretation, the person concerned is not allowed to work with food during this period. In practice, health authorities tolerate short overruns of up to four weeks, as long as follow-up training is documented and planned.

The mandatory topics of instruction are regulated in Section 43 Paragraph 1 IfSG with reference to Section 42 IfSG. § 42 lists the diseases for which an activity ban applies: abdominal typhus, paratyphoid, cholera, shigellosis, salmonellosis, yersiniosis, Campylobacter enteritis, other infectious gastroenteritis, viral hepatitis A or E as well as excretors of these pathogens without symptoms of illness.

Mandatory content one: activity bans. The person being instructed must know that if one of the diseases mentioned is suspected or diagnosed, they must not work with food. She must understand that infected wounds on the hands and forearms also trigger a ban on activity, as do purulent skin rashes or eczema.

Mandatory content two: symptoms. The person must know the main symptoms of the diseases in order to detect suspected cases early: diarrhea, vomiting, fever, jaundice, severe nausea. The duration of the elimination period after illness (often several weeks) is also discussed.

Mandatory content three: personal hygiene. Wash your hands before starting work, after using the toilet, after breaks, and after contact with raw poultry. Clean work clothes, tie your hair back, no jewelry on your hands, and no wearing nail polish. These points must be supported with concrete examples in the training.

Mandatory content four: reporting obligations. The person must understand that they must report suspected cases to the employer and the employer to the health department. Deadline begins as soon as we become aware of it. The report must be made immediately as soon as there is reasonable suspicion, not only after a medical diagnosis.

The market for online hygiene training has grown significantly since 2020. Providers range from individual training platforms such as WebID, GehMa or gastromedia to e-learning platforms such as pinktum or Cornelsen. The prices are between 7.50 euros and 35 euros per initial instruction, and for subsequent instructions 5 to 20 euros.

When selecting a provider for the initial instruction, the question of official recognition is central. Some providers advertise recognition in many federal states, which is rarely true because recognition is office-specific. A written confirmation from the health authority responsible for the place of employment is mandatory before placing an order.

Official recognition is not required for follow-up instructions because the employer bears the obligation. Internal e-learning solutions or generic providers also come into consideration here. What is important is the completeness of the content against the mandatory topics from Section 42 IfSG, a test with documented results and a machine certificate.

Frequent pitfalls: Firstly, missing the two-year deadline for follow-up instructions, often because there is no central deadline management. Secondly, there is a lack of documentation of the test results (just a certificate of participation is not enough). Third, training in a language that employees cannot understand.

Language: If there are a significant number of employees with limited knowledge of German, the training must be offered in a language they can understand or with an interpreter. Otherwise, the mandatory content cannot be conveyed in a verifiable manner, which will be viewed in the audit as a failure to provide instruction.

During inspections by the health department or food inspection, the instruction documentation is regularly checked at random. You must present the current certificate within minutes for each employee checked. Anyone who searches for longer than 15 minutes already has a problem in the supervisory practice.

The documentation includes per person: confirmation of the initial instruction from the health department, certificates of all subsequent instructions with date, content and test result, language version (if not German), signature of the person instructed. Even if the employee leaves, the certificates must be retained for three years after termination.

In the CIVAC Workspace, the instruction documentation is stored as an audit template: employee base, instruction dates, reminders three months before the end of the two-year period, automatic escalation to the hygiene officer and the human resources department when the deadline approaches. The auditor calls, the evidence is ready.

Data protection: The instruction data contains personal data and, if necessary, health information (if you have withdrawn status). Processing is permitted as a legal obligation in accordance with Article 6 Paragraph 1 Letter c of the GDPR, but technical and organisational measures in accordance with Article 32 of the GDPR are required. EU data residency, access restrictions and deletion routines according to retention period.

Structured preparation helps in the audit itself. A list of employees with status (instructed on, follow-up instruction due on, test result) significantly reduces sampling stress. Others run compliance like a filing cabinet. We run it like software.

The instruction in accordance with Section 43 IfSG is one of several training obligations in food businesses. In addition, EU Regulation (EC) No. 852/2004 requires training in the area of ​​food hygiene and HACCP principles according to Annex II, Chapter XII. The content of these training courses is different from the IfSG instructions and should not be confused with it.

The HACCP training includes hazard analysis, critical control points, corrective measures and company-specific hygiene standards. It is graded according to area of ​​responsibility: management, hygiene managers, line employees. The scope of training varies from 60 minutes for assistants to 16 hours for HACCP team leaders.

Sectors with increased risks (nursing homes, daycare centres, hospital kitchens) are also subject to infection hygiene in accordance with state law. In North Rhine-Westphalia, for example, the hygiene regulations require hygiene officers with documented qualifications and regular training. The § 43 IfSG instruction does not serve as a substitute here.

An integrated training map for each company includes: § 43 IfSG initial instruction (all relevant employees, once), § 43 IfSG follow-up instruction (every two years), HACCP basics (at least annually), company-specific hygiene (at least annually), industry-specific special obligations. The training map is maintained centrally and accompanied by reminders.

This training map is preconfigured in the workspace. All necessary training courses are conducted for each employee, with deadlines, content and evidence. Audit-proof, documented, § 43-proof, § 5 LMHV-proof, HACCP-proof. Duplicate training and deadline violations are avoided through automated workflows.

For smaller companies with 5 to 20 employees, the § 43 IfSG instruction requirement can be organised internally, provided that one person is responsible for deadline management and documentation. With online follow-up instruction providers, costs and effort are kept manageable.

Once you have around 30 employees or several locations, operational maintenance becomes prone to errors. Follow-up instructions are forgotten, certificates cannot be found, language versions are missing. At this scale, it is worth setting up a structured platform or external support from a hygiene officer.

Sectors with increased supervision intensity (hospital kitchens, daycare centres, nursing homes, large-scale catering) should generally set up hygiene compliance in a more structured manner. External support ensures consistency across all training courses, audits and supervisory inquiries.

External hygiene officers take over the administration of instruction requirements, organise online follow-up instructions, document certificates in an audit-proof manner and represent them in supervisory contact. The CIVAC SLA for the order is two working days instead of the classic two to six weeks.

In conjunction with HACCP support and food hygiene training, an integrated compliance system is created that centrally maps all training obligations. The reporting line to management is clear, the escalation paths are documented, and the audit response time is less than 24 hours.

Online hygiene training saves time and significantly simplifies the follow-up instruction requirement. The initial instruction in accordance with Section 43 IfSG remains the responsibility of the health authority, whose recognised online formats can be used. The employer can organise the follow-up instructions digitally themselves, provided the content, participation and understanding are documented.

CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. The workspace maps the instruction documentation, deadline management, language versions and audit path with EU data residency in the ISO/IEC 27001:2022-certified ISMS.

Model one, workspace licence: Your own hygiene officer maintains the training map for each employee, coordinates external providers, documents certificates in an audit-proof manner. Reminders three months before the deadline, automatic escalation to the HR department when the deadline approaches.

Model two, officer-as-a-service: CIVAC appoints an external hygiene officer who takes over the administration of the instruction requirement, organises follow-up instructions and represents him in supervisory contact with the health department and food control. Appointment certificate within two working days.

Both models integrate Section 43 IfSG instructions with HACCP training and industry-specific hygiene requirements. Turn reading into an assignment. Write to info@civac.de or use the contact form on civac.de for a structured initial discussion about hygiene compliance.