SiGeKo (Construction Site Safety Coordinator): Obligations, Tasks, and Appointment Requirements on the Construction Site
The SiGeKo coordinates occupational health and safety on construction sites involving multiple companies. This article explains the statutory obligation under the Construction Site Ordinance (BaustellV), the core tasks, the qualification requirements, and how clients document the appointment in a structured manner.
The Construction Site Ordinance (BaustellV) of 10 June 1998, last amended in 2004, requires clients to appoint a Safety and Health Protection Coordinator – known as a SiGeKo – for construction sites with special hazards or the simultaneous employment of multiple employers. § 3(1) of the Construction Site Ordinance (BaustellV) governs the appointment obligation, § 3(2) the tasks. The provision implements the European Construction Sites Directive 92/57/EEC and is mandatory: if the SiGeKo is absent, the client is personally liable for any resulting workplace accidents.
In practice, the SiGeKo appointment obligation is frequently underestimated. Many clients assume that the BaustellV only applies to large projects. This is incorrect: even with the simultaneous activities of two employers on a construction site, the obligation to coordinate arises if special hazards under Annex II of the Construction Site Ordinance (BaustellV) are present. This article clarifies when the obligation to appoint arises, what tasks the SiGeKo has, how the qualification is regulated, and how documentation is structured in an audit-ready manner.
Key Takeaways
- § 3 of the Construction Site Ordinance (BaustellV) requires clients to appoint a SiGeKo as soon as multiple employers are simultaneously active on the construction site and special hazards under Annex II of the Construction Site Ordinance (BaustellV) are present.
- The SiGeKo coordinates in the planning phase (SiGe plan) and in the execution phase – both phases must be documented, as coordination begins with the commencement of planning.
- If a written letter of appointment is absent or the SiGeKo's qualification is not demonstrated, there is a significant risk of fines and liability under § 25 ArbSchG and §§ 9, 130 OWiG.
Legal Foundations: Construction Site Ordinance (BaustellV), DGUV, and the Construction Sites Directive
The Construction Site Ordinance (BaustellV) of 10 June 1998 forms the national legal basis for the SiGeKo. It implements the EU Construction Sites Directive 92/57/EEC on minimum health and safety requirements at temporary or mobile construction sites. The BaustellV is directed at the client, not the executing contractor. The client is the addressee of the obligation and remains responsible even where the SiGeKo function is transferred to a third party.
In addition to the Construction Site Ordinance (BaustellV), the following rules and regulations are relevant: DGUV Information 212-001 describes the qualification requirements for SiGeKos. RAB 30 (Rules on Occupational Health and Safety at Construction Sites) of the Committee for Safety and Health Protection at Construction Sites concretises the requirements of the BaustellV. The LBOs (state building codes) of the individual federal states contain supplementary provisions for construction management that the SiGeKo should be aware of.
The obligation to appoint is subject to fines. § 25(1) no. 3 ArbSchG provides for fines. In cases of negligent breach, civil law claims for compensation from injured employees are additionally possible. The Construction Trade Association (BG BAU) is the competent accident insurance carrier and supervises compliance with the BaustellV in the course of its oversight activities.
An overview of all construction-related officer roles, including the site manager under LBO and BaustellV, is provided in the CIVAC roles section.
Appointment Obligation: When is a SiGeKo Mandatory?
§ 3(1) of the Construction Site Ordinance (BaustellV) specifies two alternative sets of circumstances in which the client must appoint a SiGeKo. First: when employees of multiple employers work simultaneously or sequentially on the construction site. Second: when the site is subject to prior notification under § 2(1) of the Construction Site Ordinance (BaustellV), meaning when the scope of the site exceeds 30 working days or 500 person-days, or the volume of construction work exceeds 100 person-days.
Annex II of the Construction Site Ordinance (BaustellV) deserves particular attention: it lists work for which the SiGeKo obligation always applies, regardless of project size. These include underground work, diving work, compressed air work, demolition work involving hazardous substances, and work near high-voltage power lines.
A practical example: a mid-sized manufacturing company has its production hall extended. A construction company and an electrical installer work simultaneously on the site. The BaustellV applies, the SiGeKo appointment is mandatory, regardless of whether the client coordinates the project personally or a general contractor is engaged. The obligation remains with the client.
In practice, the appointment obligation is frequently only recognised after construction has begun. Deadlines run from the point of knowledge – retrospective appointments are possible but do not protect against fines for the period without a SiGeKo.
Tasks in the Planning Phase: SiGe Plan and Health and Safety File
§ 3(2) no. 1 of the Construction Site Ordinance (BaustellV) governs the SiGeKo's tasks in the planning phase. They coordinate the implementation of the general principles under § 4 ArbSchG in the planning of the structure, particularly in the allocation of trades. Concretely, the SiGeKo prepares or accompanies the preparation of the Safety and Health Protection Plan (SiGe Plan) under § 2(3) of the Construction Site Ordinance (BaustellV).
The SiGe Plan must contain the following minimum contents: a description of the construction site and the intended measures, specification of the sequence of activities and trades, notes on special hazards and the intended protective measures. It is not a static document: the SiGe Plan must be updated in the event of material planning changes or new hazards.
In addition, the SiGeKo prepares a health and safety file for future works on the structure (§ 3(2) no. 3 of the Construction Site Ordinance (BaustellV)). This file documents safety-relevant information for future conversion, maintenance, or demolition work and is handed over to the client. It must be kept accessible, as it is binding for future construction measures.
Those who commission an external site manager or SiGeKo through CIVAC receive an officer who fully documents and versions the SiGe Plan and file in the CIVAC workspace. Changes are recorded in a traceable manner.
Tasks in the Execution Phase: Coordination, Site Inspection, and Authority to Give Instructions
In the execution phase, the SiGeKo coordinates the implementation of health and safety measures under § 3(2) no. 2 of the Construction Site Ordinance (BaustellV). They align the measures of the individual employers and ensure that the SiGe Plan is observed and updated where necessary.
Concrete tasks in the execution phase include: regular inspections of the construction site, coordination of work at interfaces between different trades, checking the order and cleanliness of the construction site, control of personal protective equipment, and documentation of coordination activities. The obligation to coordinate does not confer immediate authority to give instructions to individual employees – this remains with the respective employer. The SiGeKo coordinates at the level of employers.
The coordination of interfaces is particularly critical where civil engineering works run in parallel with above-ground construction work, and for roofing work with fall-risk areas. Demarcations in the SiGe Plan must be explicitly regulated and made visible on the construction site.
In the event of serious deficiencies or imminent danger, the SiGeKo may recommend measures to the client. The client is required to implement these. If the client ignores the recommendations, the SiGeKo must document this – and if necessary lay down their mandate. The documentation of this escalation is relevant to liability.
Qualification: What a SiGeKo Must Demonstrate
The BaustellV does not directly regulate the SiGeKo's qualification in the text of the legislation but refers to the general principles. RAB 30 specifies: the SiGeKo must hold a completed technical or natural science qualification with a construction-related focus and must demonstrate at least two years of relevant construction experience. In addition, a SiGeKo training course of at least 56 teaching hours covering the content of RAB 30 Annex A is required.
For larger construction sites within the meaning of § 2(1) of the Construction Site Ordinance (BaustellV) – i.e. sites subject to prior notification – 112 teaching hours are prescribed. Regular continuing education is required to maintain the qualification. DGUV Information 212-001 contains detailed specifications on learning objectives and training content.
The qualification must be demonstrated and documented at the time of appointment. The client bears responsibility for appointing a qualified SiGeKo. Appointing an unqualified person does not fulfil the obligation under § 3 of the Construction Site Ordinance (BaustellV) – regardless of whether that person is formally described as a SiGeKo.
For external SiGeKos – which are particularly suitable for SMEs without their own construction department – a written letter of appointment with proof of qualification and a clear description of tasks is mandatory. CIVAC issues this letter of appointment within two working days.
Liability and Fines: Consequences of a Defective SiGeKo Appointment
The client is liable for fines under § 25(1) no. 3 ArbSchG in the event of a breach of Construction Site Ordinance (BaustellV) obligations. § 130 OWiG opens the possibility of imposing a fine on the client as a legal person if the regulatory offence was enabled by a failure to exercise proper supervision. In the case of personal injury, civil law liability under §§ 823 ff. BGB is additionally possible.
The Construction Trade Association (BG BAU) systematically checks in the event of accidents whether a SiGeKo was appointed and whether they actually performed their coordination tasks. A paper-only appointment without demonstrated activity does not protect against liability. What is decisive is whether coordination is documented: site inspection records, meeting notes with the employers, updates to the SiGe Plan.
For managing directors of mid-sized businesses, it is relevant that liability for fines under § 9 OWiG can also fall on them personally if, as legal representatives, they have violated the obligations under the Construction Site Ordinance (BaustellV). A clearly documented SiGeKo appointment with proof of qualification and activity significantly reduces this risk.
Others manage compliance like a filing cabinet. CIVAC manages it like software. All coordination steps are logged in the workspace, site visits recorded, and reports versioned. The inspector calls, the evidence is ready.
SiGeKo vs. Site Manager: Demarcation and Collaboration
The SiGeKo and the site manager have related but clearly distinct functions. The site manager under LBO is responsible for the proper execution of the construction project under public building law. They are the client's technical representative before the building authority. The SiGeKo under the Construction Site Ordinance (BaustellV) is responsible for coordinating the health and safety of employers working on the construction site.
Both roles may be held by the same person, provided they meet the qualification requirements of both functions. In practice, separation is recommended for more complex projects, because the task profiles overlap only partially in content and the time commitment is considerable.
Collaboration between the site manager and SiGeKo should be governed by a written coordination protocol: who communicates with which trade, who documents the interfaces, who escalates in the event of safety deficiencies? Unclear responsibilities between site manager and SiGeKo are a frequent cause of coordination failure on construction sites.
In the CIVAC role model, both functions are mapped. Those who need both roles on a project can appoint and coordinate site manager and SiGeKo through the same platform – with shared documentation in the CIVAC workspace and clear role demarcation in the letter of appointment.
Documentation Obligations: What Must Be Retained in an Audit-Ready Manner
Complete documentation is not merely recommended for the SiGeKo but legally required. The following documents must be produced and retained:
- Letter of appointment: Written appointment of the SiGeKo by the client, with proof of qualification, identification of the construction site, and description of tasks.
- Prior notification under § 2(1) of the Construction Site Ordinance (BaustellV): For sites subject to prior notification, the notification must be submitted to the competent authority (occupational health and safety authority or trade association) and filed.
- SiGe Plan: Initial plan at the commencement of planning, updates upon planning changes, versioned with date and signature.
- Coordination records: Site inspection records with date, participating employers, and findings. Meeting notes on coordination discussions.
- Deficiency reports and action tracking: Safety deficiencies identified with date, responsible employer, and corrective action.
- Health and safety file under § 3(2) no. 3 of the Construction Site Ordinance (BaustellV): Handover to the client on completion of construction works, with a handover record.
The retention period is governed by general civil law limitation periods. In cases of personal injury, limitation periods of up to 30 years are possible (§ 199(2) BGB). Documentation should therefore be retained for at least 10 years.
Appointing an External SiGeKo: Process and the CIVAC Model
For companies that commission construction projects but do not wish to build their own SiGeKo function, external appointment is the pragmatic route. An external SiGeKo brings project-specific qualification, no internal blind spots, and clear contractual accountability.
The requirements for external appointment do not differ from internal: written letter of appointment, proof of qualification, clear task description, and a defined reporting line to the client. For sites subject to prior notification, the name of the SiGeKo must be stated in the prior notification under § 2 of the Construction Site Ordinance (BaustellV).
CIVAC offers the appointment of a qualified external SiGeKo as an Officer-as-a-Service. The mandate is formally established within two working days: letter of appointment, signed, filed, demonstrable. The SiGeKo manages the project fully in the CIVAC workspace; all coordination records, SiGe Plan versions, and site inspection records are stored digitally and are accessible at any time.
Licence the workspace for your internal officers or appoint our officers. For the SiGeKo, both routes are possible; the workspace runs in both cases on ISO/IEC 27001:2022-compliant EU infrastructure.
Turn reading into action. Contact us for the SiGeKo appointment directly at info@civac.de or use the contact form on civac.de.
FAQ
When must a client appoint a SiGeKo?
The obligation to appoint arises under § 3(1) of the Construction Site Ordinance (BaustellV) when employees of multiple employers work simultaneously or sequentially on the construction site, or when special hazards under Annex II of the Construction Site Ordinance (BaustellV) are present. A SiGeKo is also mandatory where prior notification is required (more than 30 working days or 500 person-days).
Can the site manager simultaneously be the SiGeKo?
Yes, provided the person meets the qualification requirements of both functions. The site manager is responsible for execution in compliance with building regulations; the SiGeKo coordinates occupational health and safety. For more complex projects, separation of the roles is recommended as both demand considerable time.
What qualification does a SiGeKo require?
Under RAB 30, the SiGeKo requires a completed technical qualification with a construction focus, at least two years of relevant construction experience, and a SiGeKo training course of at least 56 teaching hours (112 hours for sites subject to prior notification). Regular continuing education is required to maintain the qualification.
Does the SiGeKo have authority to give instructions to employees?
No. The SiGeKo coordinates at the level of employers and has no immediate authority to give instructions to individual employees. The authority to direct employees remains with their respective employers. The SiGeKo makes recommendations to the client and coordinates between employers.
What consequences does the client face if no SiGeKo is appointed?
The client risks fines under § 25 ArbSchG and, as a legal person, under § 130 OWiG. In cases of personal injury, civil law claims for compensation under §§ 823 ff. BGB arise additionally. Managing directors may be personally liable under § 9 OWiG if they have violated the obligations under the Construction Site Ordinance (BaustellV).
How long must SiGeKo documents be retained?
No specific statutory minimum retention period for SiGeKo documents is prescribed. Given the civil law limitation periods for personal injury claims of up to 30 years (§ 199(2) BGB), a retention period of at least 10 years is recommended. This applies to the SiGe Plan, site inspection records, the letter of appointment, and the health and safety file.
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