Appointing a SiGeKo: Step-by-Step Guide for Clients

§ 3(1) of the Construction Site Ordinance (BaustellV) requires the client to appoint a Safety and Health Protection Coordinator (SiGeKo) for certain construction sites. The obligation arises by operation of law as soon as the statutory conditions are met – regardless of whether the client is aware of this or not. An appointment that contains formal errors or refers to an unqualified person does not protect the client from liability. The obligation to appoint exists from the time of planning, not merely from commencement of construction.

This article describes the complete appointment process: when the obligation arises, what formal requirements a legally compliant letter of appointment must fulfil, how the SiGeKo's qualification is verified and documented, what must be observed regarding prior notification under § 2 of the Construction Site Ordinance (BaustellV), and how CIVAC simplifies the process from appointment to project documentation.

Before the appointment comes the check of whether the obligation exists at all. § 3(1) of the Construction Site Ordinance (BaustellV) lists two main statutory conditions. The first: where employees of multiple employers work simultaneously or sequentially on the construction site. Even two companies – such as a shell construction contractor and an electrician – trigger this condition. The second: where the site is subject to prior notification under § 2(1) of the Construction Site Ordinance (BaustellV), i.e. where the anticipated scope of work exceeds 30 working days and simultaneously more than 20 workers are employed, or the workload exceeds 500 person-days.

Additionally, Annex II of the Construction Site Ordinance (BaustellV) lists work for which the SiGeKo obligation always applies, regardless of size or the involvement of multiple employers. These include demolition work where hazardous substances are suspected, underground work, diving work, and work in compressed air.

For mid-sized businesses that have construction work carried out by external tradespeople – whether a site extension, refurbishment, or roof renovation – the following applies: as soon as two trade groups are active simultaneously, the coordination obligation generally exists. The appointment obligation is frequently underestimated at this early stage. Deadlines run from the point of knowledge – those who appoint too late risk fines even for the period without a SiGeKo.

The role of the site manager, which is frequently confused with the SiGeKo, is clearly delineated: the site manager under LBO and BaustellV is responsible for execution in compliance with building regulations; the SiGeKo coordinates the occupational health and safety of employers.

Before the letter of appointment is issued, the qualification of the intended person must be verified. RAB 30 of the Committee for Safety and Health Protection at Construction Sites sets the minimum requirements. These are: a completed technical or natural science qualification with a construction focus, at least two years of relevant professional experience in the construction sector, and a basic SiGeKo training course.

The basic SiGeKo training course must cover at least 56 teaching hours in accordance with RAB 30 Annex A for sites not subject to prior notification. For sites subject to prior notification, 112 teaching hours are required. DGUV Information 212-001 describes the learning objectives and training content in detail.

Qualification must be verified before appointment by presentation of the training certificate, proof of education, and proof of professional experience. The client must retain these documents. For external SiGeKos commissioned through service providers, the provider supplies this evidence.

CIVAC verifies the qualification of placed SiGeKos to RAB 30 standard and stores the evidence in the CIVAC workspace. The client receives the complete qualification documentation without their own verification effort. Letter of appointment: signed, filed, demonstrable.

The letter of appointment is the core document of the SiGeKo mandate. Although the Construction Site Ordinance (BaustellV) contains no detailed formal requirement for the letter of appointment, it follows from the general principles of occupational health and safety law that the appointment must be made in writing and must contain certain minimum contents.

A legally compliant letter of appointment contains at least the following information: complete identification of the construction site with address and building description, name and qualification of the appointed SiGeKo, description of tasks under § 3(2) of the Construction Site Ordinance (BaustellV) (planning and/or execution phase), commencement of mandate, reporting route to the client, and signatures of client and SiGeKo as acceptance of the mandate.

The letter of appointment must be attachable to, or at least temporally associable with, the prior notification under § 2(1) of the Construction Site Ordinance (BaustellV). It becomes part of the project documentation and must be retained beyond the duration of the project.

A common error is the retrospective issue of the letter of appointment after construction has begun. The coordination tasks begin in the planning phase – § 3(2) no. 1 of the Construction Site Ordinance (BaustellV) is unambiguous. A retrospective letter of appointment does not cover the already elapsed planning phase.

§ 2(1) of the Construction Site Ordinance (BaustellV) requires clients of sites subject to prior notification to submit a prior notification to the competent authority before construction work commences. In most federal states, the competent authority is the state occupational health and safety authority (trade supervision authority or office for occupational health and safety). The prior notification must be in place at the latest by the commencement of earthworks; in practice, it should be submitted considerably earlier.

§ 2(3) of the Construction Site Ordinance (BaustellV) governs the minimum content of the prior notification: date of submission, exact address of the construction site, client (name and address), architect or site manager (name, address), anticipated construction period, anticipated maximum number of workers simultaneously employed, anticipated number of employers and self-employed persons, contractors already named, and the name and address of the SiGeKo.

The prior notification must be displayed prominently at the construction site. For material changes – such as a change in the SiGeKo or a significant extension of the construction period – an updated prior notification must be submitted. The initial submission by e-mail or post is governed differently depending on the authority.

A missing or incorrect prior notification is a regulatory offence under § 25 ArbSchG and can result in fines. The authority uses the prior notification as the basis for construction site inspections by the supervisory service.

With the appointment, the SiGeKo's obligation to prepare, or coordinate the preparation of, the Safety and Health Protection Plan (SiGe Plan) commences. § 2(3) of the Construction Site Ordinance (BaustellV) defines the minimum content. The client is responsible for ensuring that the SiGeKo receives the necessary planning documents in good time.

The SiGe Plan must be ready before construction work begins. For projects with a planning phase, this means: the SiGe Plan is developed in parallel with the technical planning and adapted in the event of planning changes. A SiGe Plan produced only after construction has begun does not fulfil the statutory requirement.

On completion of the construction work, the SiGeKo prepares a health and safety file under § 3(2) no. 3 of the Construction Site Ordinance (BaustellV), which contains safety-relevant information for future work on the structure. This file describes, for example, the location of utility lines, load-bearing structures, hazardous substances used, or special risk areas. It is handed over to the client and must be retained for the entire lifetime of the structure.

In the CIVAC workspace, the SiGe Plan and health and safety file are produced digitally, versioned, and handed over to the client. The entire documentation flow is traceable and complete – audit-ready, documented, and compliant with the Construction Site Ordinance (BaustellV).

Many clients from the mid-market sector do not have their own SiGeKo function. External commissioning is the practical solution: an external SiGeKo mandate brings project-specific qualification, no internal blind spots, and clear contractual accountability.

The service contract with an external SiGeKo should at minimum govern: the exact scope of SiGeKo services (planning phase, execution phase, or both), the frequency of site inspections, the reporting route and escalation path, the obligation to provide proof of qualification, liability provisions for breach of duty, and remuneration and termination terms.

A contract that merely names the function but does not specify service content is risky for the client: in a dispute, the SiGeKo can argue that their contractual obligations were fulfilled even if the coordination activities were incomplete. Specific service obligations protect the client.

Those who commission an external site manager or SiGeKo through CIVAC receive a standardised service contract with clearly defined service obligations, a complete letter of appointment, and access to the CIVAC workspace for the entire project documentation. Licence the workspace for your internal officers or appoint our officers.

The costs for an external SiGeKo depend on project size, complexity, and duration. The following factors serve as reference points: the SiGeKo's hourly rate (typically €80 to €150 net depending on region and qualification), frequency and effort of site inspections, and effort for the SiGe Plan, prior notification, and handover documentation.

For a small to medium-sized construction project – such as a site extension with a six-month construction period and three to four trade groups – a total effort of 15 to 40 hours can be expected. This corresponds to a fee of typically €1,500 to €5,000, depending on the hourly rate and project requirements.

For comparison: fines for failure to appoint a SiGeKo or inadequate coordination can fall in the four-figure range under § 25 ArbSchG. In cases of personal injury, claims for compensation arise that far exceed any SiGeKo fee invoice.

A calculable framework contract for recurring construction projects – such as for companies with multiple sites or regular refurbishment programmes – significantly reduces the administrative effort for each new appointment. CIVAC offers this framework model as part of the Officer-as-a-Service offering.

Based on authority inspection practice at construction site visits and workplace accident investigations, typical errors in the SiGeKo appointment can be identified:

• Too late an appointment: The appointment is made only after construction has begun, even though the coordination obligation begins in the planning phase. The planning phase remains undocumented.
• Missing qualification check: The client appoints a SiGeKo without verifying the qualification under RAB 30. Missing evidence establishes a fault in selection.
• Incomplete letter of appointment: The SiGeKo's name and the construction site are given, but the task description, reporting line, and phase demarcation are missing.
• Prior notification forgotten: For sites subject to prior notification, the prior notification under § 2 of the Construction Site Ordinance (BaustellV) is not submitted.
• SiGe Plan without update: The SiGe Plan is produced once at the start of planning and is not subsequently adapted to planning changes or new hazards.
• No handover documentation: On completion of the project, the handover of the health and safety file under § 3(2) no. 3 of the Construction Site Ordinance (BaustellV) to the client is absent.

All the above errors can be prevented through a structured appointment process with standardised templates and a digital documentation platform. The inspector calls, the evidence is ready.

CIVAC offers the SiGeKo appointment as an Officer-as-a-Service. The process is designed to take two working days: upon receipt of the project description, CIVAC assesses the requirements, assigns a qualified SiGeKo, and produces the letter of appointment with full proof of qualification. The mandate is formally established in writing before planning work proceeds.

The appointed SiGeKo is given access to the CIVAC workspace. All coordination steps – SiGe Plan versions, site inspection records, prior notification, deficiency reports, handover documentation – are managed there digitally and are accessible to the client at any time. The system runs on ISO/IEC 27001:2022-compliant EU infrastructure, with data residency exclusively within the EU.

Those who regularly need SiGeKos on different construction sites can conclude a CIVAC framework agreement: one phone call, one e-mail, the new mandate runs within two working days. Not a week later.

The CIVAC model creates the structural conditions for the SiGeKo appointment obligation to be fulfilled on time, completely, and in an audit-ready manner for every project. Compliance platform and Officer-as-a-Service – both models, one platform.

Turn reading into action. Contact us for the SiGeKo appointment directly at info@civac.de or use the contact form on civac.de.