New DGUV Vorschrift 2: what changes for occupational physicians and Sifa support

DGUV Vorschrift 2 governs how companies fulfil their obligations under the Occupational Safety Act (Arbeitssicherheitsgesetz): who may be appointed as occupational physician or occupational safety specialist, the extent of support and how it is reported. On 28 November 2024, the DGUV general meeting adopted a new model text. It only becomes valid once the relevant accident insurance institution brings its own version into force. BG Holz und Metall led the way on 1 April 2025.

The most important changes in the model text

The threshold for small businesses rises from 10 to 20 employees. Up to this size, support is based on Anlage 1; above it, on Anlage 2, with deployment times depending on the sector. Part-time staff continue to count pro rata: up to 20 hours a week as 0.5 and up to 30 hours a week as 0.75.

Advice by telephone or video is now expressly regulated (§ 6). In principle, support is provided in person. Up to a third of the services may be delivered digitally if the business is known from an initial inspection. The accident insurance institution may permit a higher proportion, but no more than 50 per cent. Services delivered digitally must be documented in the report.

People with a degree in physics, chemistry, biology, human medicine, ergonomics, work and organisational psychology, occupational hygiene or occupational science can now also become occupational safety specialists, after two years of professional experience and the qualification course (§ 4 Abs. 6).

Also new is the obligation to provide proof of further training: the regular reports of the occupational physician and Sifa must show which further training necessary for their tasks they have completed (§ 5). For existing contracts, the model text provides for a transitional period of three years.

Explanations and examples that used to be in the annexes have moved to the new DGUV Regel 100-002.

What this means for your business

What matters for you is the status at your employers' liability insurance association (Berufsgenossenschaft) or public accident insurance fund (Unfallkasse). As long as it has not brought the new version into force, the previous Vorschrift 2 applies there. Not every institution adopts individual points such as the alternative support models in Anlagen 3 and 4. If you are concluding new contracts with an external service, you should include digital components and proof of further training in them from the outset.