Does a hazardous substances officer have to be appointed?

No, at any rate not under the Hazardous Substances Ordinance, which does not contain the role. The term does not appear in the text. Something else is binding: § 7 Abs. 1a GefStoffV requires occupational safety for work with hazardous substances to be embedded appropriately into the organisation together with the necessary personnel, financial and organisational conditions, and § 6 Abs. 11 Satz 1 GefStoffV permits the risk assessment only by competent persons. Naming someone internally and calling them Gefahrstoffbeauftragter does nothing wrong; it discharges a duty to organise, not a duty to appoint. The difference matters the moment someone claims a fine follows from the missing title. None follows from the title. Fines follow from the omissions listed in § 22 Abs. 1 GefStoffV.

What separates a fachkundige from a sachkundige person?

The ordinance defines both and means different things. Under § 2 Abs. 16 GefStoffV a person is fachkundig who has the knowledge required for a task set by the ordinance; the requirements depend on the nature of the task and include relevant vocational training or experience, or recently exercised relevant professional activity, plus attendance at specific further training. Under § 2 Abs. 17 GefStoffV a person is sachkundig who has extended existing competence by attending an officially recognised Sachkundelehrgang, depending on the field with a passed examination. For the risk assessment § 6 Abs. 11 Satz 1 GefStoffV requires Fachkunde. Sachkunde is required for particular activities, asbestos work among them.

Can the risk assessment be outsourced?

Writing it, yes. The duty, no. § 6 Abs. 11 Satz 2 GefStoffV says so expressly: where the employer does not himself have the relevant knowledge, he must obtain competent advice. That is an obligation to get help, not permission to hand over responsibility. The assessment remains the employer's, is answered for by him and is documented by him under § 6 Abs. 8 GefStoffV. In practice: we draft, you review and release, and the record shows the two steps separately.

What does a missing hazardous substances register cost?

Up to fifty thousand euros, and the figure sits in a different statute from the duty. § 6 Abs. 12 Satz 1 GefStoffV requires the register. § 22 Abs. 1 GefStoffV makes its absence, incorrectness or incompleteness an administrative offence within the meaning of § 26 Absatz 1 Nummer 8 Buchstabe b of the Chemicals Act. Only § 26 Abs. 3 ChemG names the amount, and Nummer 8 Buchstabe b sits there in the tier up to fifty thousand euros. The two hundred thousand euros often quoted in this market belong to other numbers in para. 1 and not here. Negligence suffices in every case.

Does this mandate replace the safety specialist?

No. Appointing a safety specialist and a company doctor follows the Arbeitssicherheitsgesetz and is a separate duty with its own scope. The Hazardous Substances Ordinance even refers to both expressly in § 6 Abs. 11 Satz 3, where it says that the safety specialist and the company doctor may in particular be competent. Where both are appointed, this mandate supports them on the hazardous substances side rather than duplicating their work; the demarcation is written down at the start so two functions do not each assume the other has it covered.

Do classification, labelling and safety data sheets belong here?

Only in so far as they arrive on site. This service is employee protection: we read the safety data sheets your suppliers provide and reconcile them with what is actually used. Writing your own safety data sheets, classifying and labelling your own products and the notification duties on placing goods on the market are product and market law. § 4 Abs. 1 GefStoffV refers for that to Verordnung (EG) Nr. 1272/2008 and § 5 Abs. 1 GefStoffV to Artikel 31 der Verordnung (EG) Nr. 1907/2006. Those duties fall on manufacturers, importers and downstream users and are the subject of the chemicals compliance service, not this one.

What does the service cost at CIVAC?

The price has four components: the one-off inventory with first assessment, an ongoing retainer for the competent person, site visits and briefings per date, and the optional special cases under §§ 10, 11, 11a and 12 GefStoffV. The figure depends on the number of sites and areas, on the number of substances and the state of the existing safety data sheets, on whether carcinogenic or asbestos work occurs, and on whether a competent person already exists in house. Anyone comparing offers should ask two questions: is the documentation of the risk assessment included, which § 6 Abs. 8 GefStoffV requires and whose omission § 22 Abs. 1 GefStoffV lists as an administrative offence? And is revision when new substances appear part of the price or a separate item? You receive a fixed figure per component. The platform costs 49 € per officer role per month and is shown separately.

All services

Service

Appoint a hazardous substances officer

One point first, because it decides the shape of this service: the German Hazardous Substances Ordinance (Gefahrstoffverordnung, GefStoffV) does not know the Gefahrstoffbeauftragter. The term does not appear in the text of the ordinance. What the ordinance does require is something else and, for you, more binding. § 7 Abs. 1a GefStoffV obliges the employer to embed occupational safety for work with hazardous substances appropriately into the organisation and to create the personnel, financial and organisational conditions for it. § 6 Abs. 11 GefStoffV permits the risk assessment to be carried out only by competent persons and, in sentence 2, requires an employer who does not have that knowledge to obtain competent advice. That is where this service attaches: CIVAC supplies the competence and runs the hazardous substances organisation, while the employer's responsibility under § 13 Abs. 1 ArbSchG does not move. Anyone selling you a Gefahrstoffbeauftragter with a statutory appointment duty is selling a role the ordinance does not contain.

Employers whose people work with hazardous substances within the meaning of § 2 GefStoffVProduction, maintenance, laboratory, warehouse and cleaning, at any headcountSites with no competent person of their own within the meaning of § 2 Abs. 16 GefStoffVSafety specialists and company doctors who want the hazardous substances side reinforcedManagement as the responsible person under § 13 Abs. 1 ArbSchG

What CIVAC operates

Competence and risk assessment

Competent advice under § 6 Abs. 11 Satz 2 GefStoffV where the necessary knowledge is not available in house.
The determination required by § 6 Abs. 1 Satz 1 GefStoffV of whether employees carry out work with hazardous substances, or whether hazardous substances arise or are released during that work.
Assessment of the hazards under § 6 Abs. 1 Satz 2 GefStoffV, including the substitution check required by § 6 Abs. 1 Satz 2 Nr. 4 GefStoffV.
Documentation of the risk assessment, whose omission § 22 Abs. 1 GefStoffV lists separately as an administrative offence.
Revision when activities change, when substances are added and when new findings appear, so the assessment does not become a document about the past.

Register, operating instructions, briefings

Building and maintaining the register of hazardous substances used on site that § 6 Abs. 12 Satz 1 GefStoffV requires.
Written operating instructions, made accessible as § 14 Abs. 1 Satz 1 GefStoffV prescribes, in the language of the workforce.
Preparation and material for the spoken briefing under § 14 Abs. 2 Satz 1 GefStoffV on the hazards that arise and the protective measures.
Reconciling the safety data sheets, whose requirements follow from Artikel 31 der Verordnung (EG) Nr. 1907/2006 via § 5 Abs. 1 GefStoffV, against what is actually used on site.
Check points for the function and effectiveness of technical protective measures, which § 7 Abs. 7 Satz 1 GefStoffV places on the employer.

Organisation and evidence

Shaping the hazardous substances organisation around § 7 Abs. 1a GefStoffV, that is around the personnel, financial and organisational conditions the ordinance expressly demands.
A draft written delegation under § 13 Abs. 2 ArbSchG where your house wants tasks carried out under the delegate's own responsibility, stating plainly what is delegated and what is not.
Continuous documentation in the CIVAC workspace, exportable for the trade supervisory authority, the employers' liability insurance association and audit.
A written demarcation against the safety specialist under the ASiG and the company doctor, so two mandates neither overlap nor each assume the other has it covered.
Handover to your deciding body as soon as a protective measure, an investment or a substitution has to be decided.

How it runs

1
Inventory of activities
We record which activities involving hazardous substances take place, which substances and mixtures are used and which safety data sheets exist for them. § 6 Abs. 1 Satz 1 GefStoffV requires exactly this determination as the first step, and it covers hazardous substances that only arise or are released during the work. The result is the list everything else runs against.
2
Risk assessment by competent persons
The assessment is carried out by a competent person within the meaning of § 2 Abs. 16 GefStoffV, because § 6 Abs. 11 Satz 1 GefStoffV permits nothing else. It covers the aspects listed in § 6 Abs. 1 Satz 2 GefStoffV including the substitution check. Where your house has its own competence we support it rather than replace it; where it does not, the advice is precisely the case § 6 Abs. 11 Satz 2 GefStoffV describes.
3
Register and operating instructions
The register under § 6 Abs. 12 Satz 1 GefStoffV is built or cleaned up and tied to procurement, so a new substance does not sit unregistered for months. Written operating instructions are produced for the activities and made accessible as § 14 Abs. 1 Satz 1 GefStoffV requires, together with the material for the briefing under § 14 Abs. 2 Satz 1 GefStoffV. § 22 Abs. 1 GefStoffV lists both omissions expressly as administrative offences.
4
Ongoing operation
New substances, changed processes and new findings travel back into the register, the assessment and the operating instructions along a fixed route. The check on the function and effectiveness of technical protective measures under § 7 Abs. 7 Satz 1 GefStoffV runs as a monitored date. Decisions on protective measures, investment and substitution go to your deciding body with the facts and the options, and are taken there.
5
Evidence that survives an inspection
Documentation runs continuously in the workspace and is built to withstand a question from the trade supervisory authority or the employers' liability insurance association. You receive the risk assessment, the register, the operating instructions and the briefing records in exportable form, each with date, author and version.

The legal frame

The provisions below determine what an employer owes for work with hazardous substances, who may carry out the assessment and what an omission costs. A provision appointing a Gefahrstoffbeauftragter is not among them, because none exists. Each is quoted in the original German wording.

§ 7 Abs. 1 and Abs. 1a GefStoffV: Der Arbeitgeber darf eine Tätigkeit mit Gefahrstoffen erst aufnehmen lassen, nachdem eine Gefährdungsbeurteilung nach § 6 durchgeführt und die erforderlichen Schutzmaßnahmen nach Abschnitt 4 ergriffen worden sind. Der Arbeitgeber hat die Belange des Arbeitsschutzes bei Tätigkeiten mit Gefahrstoffen angemessen in seine betriebliche Organisation einzubinden und die dafür erforderlichen personellen, finanziellen und organisatorischen Voraussetzungen zu schaffen.
This is the provision that in practice produces the role the law has no name for. Para. 1a demands an organisation and expressly the personnel conditions for it; it demands no appointment and no title. Filling the task externally satisfies para. 1a; not filling it at all does not, even though no officer appears anywhere in the text of the ordinance.
§ 6 Abs. 11 GefStoffV: Die Gefährdungsbeurteilung darf nur von fachkundigen Personen durchgeführt werden. Verfügt der Arbeitgeber nicht selbst über die entsprechenden Kenntnisse, so hat er sich fachkundig beraten zu lassen. Fachkundig können insbesondere die Fachkraft für Arbeitssicherheit und die Betriebsärztin oder der Betriebsarzt sein.
Sentence 2 is the legal basis for this service, and it is a different kind of basis from § 14 Abs. 1 HinSchG. It does not permit the duty to be transferred; it obliges an employer to obtain competence where he lacks it. The distinction is not academic: the assessment remains the employer's even when an external competent person writes it. Competence is defined in § 2 Abs. 16 GefStoffV as having the knowledge the particular task requires.
§ 13 Abs. 2 ArbSchG: Der Arbeitgeber kann zuverlässige und fachkundige Personen schriftlich damit beauftragen, ihm obliegende Aufgaben nach diesem Gesetz in eigener Verantwortung wahrzunehmen.
This is the only genuine appointment provision within reach, and it sits in the Occupational Safety Act, not in the Hazardous Substances Ordinance. The wording says "Aufgaben nach diesem Gesetz", tasks under that Act. That is why nothing on this page claims the GefStoffV permits the appointment of an external Gefahrstoffbeauftragter. It does not, and a provider who says otherwise is citing a provision they have not read. What § 13 Abs. 2 ArbSchG carries is written delegation of occupational safety tasks; what it leaves untouched is responsibility under § 13 Abs. 1 ArbSchG.
§ 22 Abs. 1 GefStoffV in conjunction with § 26 Abs. 1 Nr. 8 lit. b and Abs. 3 ChemG: Ordnungswidrig im Sinne des § 26 Absatz 1 Nummer 8 Buchstabe b des Chemikaliengesetzes handelt, wer vorsätzlich oder fahrlässig entgegen § 6 Absatz 12 Satz 1 ein Gefahrstoffverzeichnis nicht, nicht richtig oder nicht vollständig führt. Die Ordnungswidrigkeit kann in den Fällen des Absatzes 1 Nummer 4a, 4b, 4e und 7 Buchstabe b und des Absatzes 2 Nummer 2 Buchstabe d mit einer Geldbuße bis zu zweihunderttausend Euro, in den Fällen des Absatzes 1 Nummer 4, 4c, 4f, 4g, 5, 6, 7 Buchstabe a, Nummer 8 Buchstabe b und Nummer 10 und des Absatzes 2 Nummer 1 Buchstabe a, Nummer 2 Buchstabe a bis c und f und Nummer 3 Buchstabe c bis i mit einer Geldbuße bis zu fünfzigtausend Euro und in den übrigen Fällen mit einer Geldbuße bis zu zehntausend Euro geahndet werden.
The figure is not in the GefStoffV. § 22 Abs. 1 GefStoffV points to § 26 Abs. 1 Nr. 8 lit. b ChemG, and only § 26 Abs. 3 ChemG names the amount. Nummer 8 Buchstabe b sits in the fifty thousand euro tier, not in the two hundred thousand tier; quoting the higher figure for hazardous substances omissions means the chain was not read to the end. Negligence is enough, and the catalogue in § 22 Abs. 1 GefStoffV covers the everyday failures: undocumented assessment, missing register, missing operating instruction, briefing not given.

Wording retrieved on 22 September 2026 from gesetze-im-internet.de. The governing text is the Gefahrstoffverordnung of 26 November 2010 as amended by Artikel 1 der Verordnung vom 17. Dezember 2025 (BGBl. 2025 I Nr. 337; 2026 I Nr. 44). The term Gefahrstoffbeauftragter does not appear in that text; it is industry practice and a market term, not a legal figure. This page is named after it because that is what people search for, and says in its first paragraph what the term is in law.

How the price is built

The price has four components, shown separately. The first is regularly the largest here, because a hazardous substances inventory is rarely documented the way the ordinance requires.

Inventory and first assessment

One-off. Recording activities and substances, reconciling the safety data sheets, the risk assessment under § 6 GefStoffV including the substitution check and its documentation, and building the register under § 6 Abs. 12 Satz 1 GefStoffV.

Retainer for the competence

Ongoing. Availability of the competent person, revision of assessment, register and operating instructions, the check dates under § 7 Abs. 7 Satz 1 GefStoffV, and reporting to your deciding body.

Site visits and briefings

Per date, graded by site and area. On-site visits and delivery of the briefing under § 14 Abs. 2 Satz 1 GefStoffV where you do not want to run it yourself.

Special cases

Optional. Work with carcinogenic, germ cell mutagenic or reproductive toxic substances of category 1A or 1B under § 10 GefStoffV, asbestos under §§ 11 and 11a GefStoffV, and explosion protection under § 12 GefStoffV.

The number of sites and areas where work with hazardous substances takes place.
The number of substances and mixtures in use and the state of the existing safety data sheets.
Whether work under § 10 GefStoffV or asbestos work under §§ 11 and 11a GefStoffV occurs.
Whether a competent person within the meaning of § 2 Abs. 16 GefStoffV already exists, whom we support, or whether the competence comes entirely from outside.
Whether the briefing under § 14 Abs. 2 GefStoffV is taken alongside.

You receive a fixed figure per component once sites, substance count and special cases are settled. The platform costs 49 € per officer role per month and is shown separately in the mandate.

Where the service ends

CIVAC is not a law firm and does not provide legal services within the meaning of the German Legal Services Act (Rechtsdienstleistungsgesetz). What this page describes is risk indication and organisational support; the legal assessment of an individual case belongs to your legal advisers.

There is no statutory duty to appoint a Gefahrstoffbeauftragter, because the GefStoffV does not contain that role. We are not selling you an appointment duty. What does exist are the employer duties in §§ 6, 7 and 14 GefStoffV, and they exist regardless of what the person preparing them is called.
Responsibility under § 13 Abs. 1 ArbSchG stays with the employer and the people named there. § 13 Abs. 2 ArbSchG permits written delegation of tasks under that Act; it does not move the responsibility in para. 1.
The risk assessment remains the employer's even when an external competent person writes it. § 6 Abs. 11 Satz 2 GefStoffV requires advice; it does not transfer the duty.
Decisions on protective measures, on substitution and on the investment they require are taken by your house. We prepare them with the facts and the options.
Appointing a safety specialist and a company doctor under the Arbeitssicherheitsgesetz is a separate duty with its own scope and is not discharged by this mandate.
Duties on placing substances and mixtures on the market, that is classification, labelling, safety data sheets and notifications, are product and market law and belong on the chemicals compliance page, not here. This service is employee protection inside the plant.
Installation-related duties under the BImSchG, the WHG and the StörfallV remain separate duties and are not covered.

Common questions

Does a hazardous substances officer have to be appointed?: No, at any rate not under the Hazardous Substances Ordinance, which does not contain the role. The term does not appear in the text. Something else is binding: § 7 Abs. 1a GefStoffV requires occupational safety for work with hazardous substances to be embedded appropriately into the organisation together with the necessary personnel, financial and organisational conditions, and § 6 Abs. 11 Satz 1 GefStoffV permits the risk assessment only by competent persons. Naming someone internally and calling them Gefahrstoffbeauftragter does nothing wrong; it discharges a duty to organise, not a duty to appoint. The difference matters the moment someone claims a fine follows from the missing title. None follows from the title. Fines follow from the omissions listed in § 22 Abs. 1 GefStoffV.
What separates a fachkundige from a sachkundige person?: The ordinance defines both and means different things. Under § 2 Abs. 16 GefStoffV a person is fachkundig who has the knowledge required for a task set by the ordinance; the requirements depend on the nature of the task and include relevant vocational training or experience, or recently exercised relevant professional activity, plus attendance at specific further training. Under § 2 Abs. 17 GefStoffV a person is sachkundig who has extended existing competence by attending an officially recognised Sachkundelehrgang, depending on the field with a passed examination. For the risk assessment § 6 Abs. 11 Satz 1 GefStoffV requires Fachkunde. Sachkunde is required for particular activities, asbestos work among them.
Can the risk assessment be outsourced?: Writing it, yes. The duty, no. § 6 Abs. 11 Satz 2 GefStoffV says so expressly: where the employer does not himself have the relevant knowledge, he must obtain competent advice. That is an obligation to get help, not permission to hand over responsibility. The assessment remains the employer's, is answered for by him and is documented by him under § 6 Abs. 8 GefStoffV. In practice: we draft, you review and release, and the record shows the two steps separately.
What does a missing hazardous substances register cost?: Up to fifty thousand euros, and the figure sits in a different statute from the duty. § 6 Abs. 12 Satz 1 GefStoffV requires the register. § 22 Abs. 1 GefStoffV makes its absence, incorrectness or incompleteness an administrative offence within the meaning of § 26 Absatz 1 Nummer 8 Buchstabe b of the Chemicals Act. Only § 26 Abs. 3 ChemG names the amount, and Nummer 8 Buchstabe b sits there in the tier up to fifty thousand euros. The two hundred thousand euros often quoted in this market belong to other numbers in para. 1 and not here. Negligence suffices in every case.
Does this mandate replace the safety specialist?: No. Appointing a safety specialist and a company doctor follows the Arbeitssicherheitsgesetz and is a separate duty with its own scope. The Hazardous Substances Ordinance even refers to both expressly in § 6 Abs. 11 Satz 3, where it says that the safety specialist and the company doctor may in particular be competent. Where both are appointed, this mandate supports them on the hazardous substances side rather than duplicating their work; the demarcation is written down at the start so two functions do not each assume the other has it covered.
Do classification, labelling and safety data sheets belong here?: Only in so far as they arrive on site. This service is employee protection: we read the safety data sheets your suppliers provide and reconcile them with what is actually used. Writing your own safety data sheets, classifying and labelling your own products and the notification duties on placing goods on the market are product and market law. § 4 Abs. 1 GefStoffV refers for that to Verordnung (EG) Nr. 1272/2008 and § 5 Abs. 1 GefStoffV to Artikel 31 der Verordnung (EG) Nr. 1907/2006. Those duties fall on manufacturers, importers and downstream users and are the subject of the chemicals compliance service, not this one.
What does the service cost at CIVAC?: The price has four components: the one-off inventory with first assessment, an ongoing retainer for the competent person, site visits and briefings per date, and the optional special cases under §§ 10, 11, 11a and 12 GefStoffV. The figure depends on the number of sites and areas, on the number of substances and the state of the existing safety data sheets, on whether carcinogenic or asbestos work occurs, and on whether a competent person already exists in house. Anyone comparing offers should ask two questions: is the documentation of the risk assessment included, which § 6 Abs. 8 GefStoffV requires and whose omission § 22 Abs. 1 GefStoffV lists as an administrative offence? And is revision when new substances appear part of the price or a separate item? You receive a fixed figure per component. The platform costs 49 € per officer role per month and is shown separately.