Risk assessment for psychological stress: template, obligations and procedure

Section 5 Paragraph 3 No. 6 ArbSchG has required every employer since it was clarified in 2013 to also include psychological stress at work in the risk assessment. The Joint German Occupational Safety Strategy (GDA) has published a guideline that is used as a benchmark in the supervisory practices of the federal states. Professional associations and accident insurance funds check the implementation as part of their regular inspections, and the trade supervisory authorities of the federal states have made the GBU of psychological stress a fixed focus of their examinations in recent years. Anyone who does not provide a documented assessment risks not only complaints, but also subsequent fines according to § 25 ArbSchG of up to 30,000 euros per violation and, in the event of damage, personal liability of the management according to § 130 OWiG.

This article describes the legal obligations, the required content and methods, an audit-proof template structure and the interaction with the occupational safety specialist and the company doctor ASiG. It addresses the common practical errors that become visible in inspections and shows how the co-determination process is carried out properly via Section 87 BetrVG. You will also learn how the CIVAC compliance platform and officer-as-a-service constellation combine the risk assessment of psychological stress in a uniform reporting line with versioning, action tracking and SiFa appointment certificates. This creates a continuous evidence path from the assessment through the measures to the effectiveness control. Licence the workspace for your internal representatives, or have our representatives order it.

The legal anchoring of the risk assessment of psychological stress is carried out centrally in Section 5 of the ArbSchG. Paragraph 1 obliges the employer to assess the risks to employees associated with their work. Paragraph 3 gives examples of possible sources of danger in a non-exhaustive list. With the 2013 amendment, number 6 was expressly supplemented to include psychological stress at work. This clarification ended years of discussions about whether psychological stress is part of the risk assessment.

The Joint German Occupational Safety Strategy (GDA) is the strategic cooperation between the federal government, the states and accident insurance providers. It has published a guideline for advice and monitoring of psychological stress in the workplace, in which seven process steps are described: definition of activities and areas, determination of psychological stress, assessment of psychological stress, development and implementation of measures, effectiveness control, updating and updating as well as documentation.

In supervisory practice, trade regulators and professional associations check whether these seven steps are available with concrete evidence. If there is only a general note in the occupational safety concept without a specific assessment, this is a typical complaint. The occupational safety specialist according to ASiG supports the employer in the implementation; The employer remains responsible. CIVAC maintains the appointment certificate from the SiFa, the company doctor and the reporting line for the risk assessment in an integrated data structure. The appointment certificate, signed, filed, verifiable. The seven GDA steps are managed for each activity cluster with status, person responsible and deadline, so that the supervisory authority does not find any reason to object to the procedure, but can immediately start assessing the content. Audit-proof, documented, § 5-proof. 490 audit templates and EU data residency run in the background, so that survey data can also be processed without additional third-country transfer.

The GDA guidelines structure psychological stress into four areas, which must be considered separately in each assessment. First field: work content and work task. Topics include completeness of the task, scope for action, variability, information and information provision, responsibility, qualifications and emotional involvement. Specific indicators range from frequent interruptions to a lack of feedback to emotional stress in jobs with customer or patient contact.

Second field: work organisation. Working time, workflow and communication are evaluated here. Indicators include rotating shifts, night work, frequent overtime, work on call, deadline and performance pressure, lack of breaks and inadequate communication structures. Third field: Social relationships in the workplace. Topics include relationships with colleagues, superiors, conflicts, bullying, lack of support and lack of appreciation.

Fourth field: working environment. This is where physical and psychological stress overlap. Noise, climate, lighting, vibrations and ergonomic conditions can also have a psychological impact. Added to this are unsuitable work equipment and inadequate software ergonomics. The 490 CIVAC audit templates contain a structured assessment form for each of the four fields with indicators, scale evaluation and free text field for activity-specific observations. Others run compliance like a filing cabinet. We run it like software. The forms can be adapted according to activity and are maintained with a valid date for each version, so that even after reorganizations it remains traceable which activity was assessed at which point in time and with which assessment basis. Anyone who operates multiple locations and shifts also stores shift models and staffing because they have a direct impact on the stress areas of working hours and social relationships. The four areas of stress are evaluated separately in the reporting line so that there is no mixing in the action plan and effectiveness checks for each field are possible. The appointment certificate, signed, filed, verifiable. This means the methodology remains comparable over several years.

The GDA guidelines do not prescribe a specific survey method, but rather require a suitable methodology. In practice, four approaches have been established, which are often combined. First method: observation interview. A trained observer analyses the activity on site and conducts structured interviews with the employees. Strength: high validity, activity-specific knowledge. Weakness: high effort per workstation and training requirements for observers.

Second method: standardised questionnaire. Validated instruments such as the COPSOQ (Copenhagen Psychosocial Questionnaire), the KFZA (short questionnaire for work analysis) or industry-specific forms from the professional associations are used. Strength: scalable to large workforces and benchmarkable. Weakness: Minimum number of participants and data protection requirements because sensitive information is provided.

Third method: moderated workshop. Employees and managers assess the stress situation together and develop suggestions for measures. Strength: high acceptance and direct action orientation. Weakness: Group dynamics can be distorting, and those who are silently stressed often do not speak. Fourth method: key figure analysis. Sick leave, absence structure, fluctuation, BEM frequency and complaints are evaluated. Strength: existing database without additional effort. Weakness: retrospective, difficult to assign causes. The clock starts on awareness. In practice, a combination of standardised questionnaires for the general workforce and moderated workshops for particularly stressful areas of activity, supplemented by routine key figure analysis, which is reported quarterly to the hygiene and occupational safety committees, has proven successful. The mix of methods increases validity and reduces the risk that a single method creates systematic blind spots. CIVAC allows several methods to be stored in parallel in a GBU with clear assignment per activity cluster.

An audit-proof template for the risk assessment of psychological stress consists of eight components that are systematically managed in the reporting line. First: cover sheet with scope (location, department, activities), reference period, person responsible and version number. Second: description of the methodology used including justification for the selection. Third: List of the activities and employee groups included with information on the number of employees.

Fourth: Assessment forms for each activity and stress area with documented indicators and evaluation (typically on a three-stage scale: inconspicuous, check, act). Fifth: List of results with specific findings for each stress area and activity. Sixth: Action plan based on the STOP principle (substitution, technology, organisation, person-related) with responsible person, deadline and funding requirements. Seventh: effectiveness control after implementation with date, observation and evaluation. Eighth: Update plan with a repeat frequency (usually two years, shorter if necessary).

The CIVAC template also takes DGUV regulation 2 into account with the operating times of the occupational safety specialist and the company doctor. Both roles are shown in the assessment as advisory functions; responsibility remains with the employer. The company doctor's appointment certificate and the SiFa appointment certificate are linked to the respective GBU. Audit-proof, documented, § 5-proof. Licence the workspace for your internal representatives, or have our representatives order it. There are 490 audit templates, a versioned reporting line and EU data residency running in the background. The auditor calls, the evidence is ready., filtered by activity cluster, validity date and action status. External consultants are integrated into the workspace with their own role and appointment certificate, without any data permanently leaving the company. If you use several consulting partners, you also provide proof of qualifications and areas of activity so that it is immediately clear in the audit which content is the responsibility of which contributor.

Measures from the risk assessment of psychological stress follow the STOP principle from occupational safety, adapted to psychological stress. Substitution is rarely considered directly (eliminating a stressful activity completely), but rather in the form of redesigning the task (eliminating superfluous activities, bundling micro-tasks). Example: Instead of six different sources of information, they are bundled in one system, so that the mental strain of searching is eliminated.

Technical measures include software ergonomics, reduction of interruptions through notification systems, workflow automation and ergonomic workplace design with a psychological effect (screen breaks, lighting control). Organizational measures are the most important in practice: task distribution, shift schedule design, break regulations, transparent escalation paths, clear role descriptions, regular employee discussions, conflict procedures and co-determination and participation structures.

Person-related measures are secondary and complement the other three levels. They include training on stress management, resilience training, coaching, company integration management (BEM) in accordance with Section 167 SGB IX and offers from the psychological company doctor. Each measure is documented with the person responsible, deadline, funding required and effectiveness indicator. Anyone who only lists measures but does not assign them will be criticized in supervisory practice. CIVAC bundles the action plan with resubmission, escalation path if deadlines are exceeded and effectiveness assessment in the reporting line. The auditor calls, the evidence is ready. In addition, there is the explicit separation between relationship prevention (design of working conditions) and behavioral prevention (individual measures), which is laid out in the GDA guidelines as a sequence with priority given to relationship prevention and must be recognizable in every assessment. Anyone who only documents behaviour prevention will be criticized in supervisory practice because this would circumvent the principle of avoiding danger at the source and shift organisational responsibility to the individual employees.

Certain error patterns occur repeatedly in supervisory practice and in inspections by professional associations. Mistake one: The GBU of psychological stress is integrated into the concept of general risk assessment, without an independent methodology. Consequence: The specific areas of psychological stress are not systematically recorded and the supervisory authority criticizes the lack of selectivity. Mistake two: A survey is carried out, but the results are not included in a documented action plan. Surveying without measures is not methodologically permissible and also leads to declining participation in the next round.

Mistake three: activities are summarized too roughly, so that specific burdens on individual functions disappear. A GBU for the entire administration does not adequately capture the burden on the telephone exchange or personnel administration. Mistake four: Data protection aspects are not sufficiently taken into account. Anyone who evaluates data at a personal level violates Section 26 BDSG if there is no legal basis. Aggregation with a minimum group size is mandatory, usually at least 5 to 10 people per evaluable item.

Mistake five: The GBU is created once and never updated. However, significant changes such as new software, reorganization, change of location or pandemic conditions trigger an obligation to update. Error six: The works council is not involved, although Section 87 Paragraph 1 No. 7 BetrVG provides for a right of co-determination for occupational health and safety regulations. Mistake seven: No effectiveness control after implementation of measures. CIVAC addresses all seven errors through templates with mandatory fields, a co-determination module and effectiveness control. Audit-proof, documented, § 5-proof. Eighth point from practice: Anyone who only carries out a GBU of psychological stress as a compulsory exercise in anticipation of the next inspection will neither reach the employees nor the supervision and will invest the resources twice.

The risk assessment is a task of the employer, but it is implemented in a network of consultation, participation and co-determination obligations. The occupational safety specialist according to ASiG advises the employer on methodology and measures and supports the assessment. The company doctor according to ASiG brings in occupational medicine expertise, especially when assessing the effect of stress on the health of employees.

According to Section 87 Paragraph 1 No. 7 BetrVG, the works council has a right of co-determination on regulations for the prevention of work accidents and occupational diseases as well as for health protection. The case law of the Federal Labour Court has made it clear several times that this also includes the GBU of psychological stress. Anyone who proceeds without the involvement of the works council risks having the GBU repealed in the decision-making process and the subsequent repetition of the entire survey.

The employees themselves must be informed about Section 81 BetrVG and Section 12 ArbSchG and be involved. An employee survey is often useful, but at least the transparent communication of the methodology, results and measures is legally required. If necessary, additional training on psychological stress and coping strategies is offered. CIVAC lists the participation steps as a mandatory part of the GBU template with proof of participation and information. Licence the workspace for your internal representatives, or have our representatives order it. CIVAC-SLA: two working days instead of the classic two to six weeks. If there are several locations and collective agreement areas, the responsible staff representatives are kept with local information and co-determination protocols. This creates a continuous chain of participation that can be proven in the audit without any additional effort and that will stand up in the event of a dispute before the labour court. Audit-proof, documented, § 87-proof according to the co-determination situation.

How much does a professionally conducted psychological stress risk assessment cost? The range is wide because it depends on the size of the workforce, the variety of activities, the chosen methodology and the proportion of consulting. For a medium-sized company with around 200 employees and five to seven activity clusters, the external consulting costs are typically between 8,000 and 20,000 euros for the initial implementation, plus the internal costs for the participation of employees, the SiFa, the company doctor and the works council.

The internal costs are often underestimated. Each employee should spend 45 to 90 minutes on a workshop or survey methodology, plus the preparation of the workshops or surveys, the evaluation and the development of the measures. For a medium-sized company, this results in a one-off initial effort of 4 to 8 working days for SiFa, plus similar effort on the works council and management side. The follow-up costs in the update cycles fall by 40 to 60 percent with clean versioning.

The real lever lies not in the costs of the assessment, but in the effect of the measures. Data analyses from professional associations show that psychological stress is responsible for a significant proportion of days of incapacity for work in Germany. An effective GBU with implemented measures therefore has a measurable impact on sickness absence, fluctuation and productivity. CIVAC bundles initial implementation, action tracking and effectiveness monitoring in the compliance platform and provides Officer-as-a-Service as an ordering option for the SiFa and the external company doctor. Licence the workspace for your internal representatives, or have our representatives order it. The CIVAC SLA is two business days for the initial setup instead of the classic two to six weeks.

An effective GBU strategy for psychological stress begins with an assessment of the situation. What activity clusters are there in the company? Which GBU of psychological stress has been carried out so far, with which methodology and with what timeliness? Which measures were derived from previous assessments and which of them have been implemented? What involvement was documented? What key figures for sick leave, absenteeism, fluctuation and complaints are available? This assessment leads to a roadmap with clear priorities for each area.

In the second step, the assessment is converted into an audit-proof process. This includes the selection of a suitable methodology, the training of the people involved, transparent communication to the employees, the formal participation of the works council in accordance with Section 87 BetrVG, the implementation of the survey with data protection in accordance with Section 26 BDSG and the subsequent evaluation. In the third step, measures are documented according to the STOP principle with the person responsible, deadline and effectiveness indicator.

CIVAC provides ready-made building blocks for each of these three steps: methodical templates for each stress area, participation forms for the works council, action plans with resubmission and effectiveness checks. The platform works in two modes: licence the workspace for your internal representatives, or have our officers appointed it. In both models, the CIVAC SLA of two business days applies to the initial setup and EU data residency for all data.

Turn reading into a mandate. Write to info@civac.de or use the contact form on civac.de/faq. We will send a concrete proposal for your GBU of psychological stress within two working days, tailored to the size of the workforce, activity cluster, existing SiFa structure and the requirements of the professional association responsible for you, including choice of method, participation plan for the works council and update frequency.