Annual occupational safety briefing: planning deadlines and records correctly

Many businesses decide in December when safety briefings will take place in the coming year. The basis is § 12 ArbSchG: the employer must give employees sufficient and appropriate instruction during working hours, tailored to their workplace or area of responsibility. The briefing is due before the employee starts work, i.e. on recruitment, when tasks change and when new work equipment or technologies are introduced. For agency workers, the obligation lies with the hirer.

Where the annual interval comes from

The Occupational Health and Safety Act (Arbeitsschutzgesetz) only requires the briefing to be adapted to changes in hazards and repeated regularly where necessary. The accident prevention regulation (Unfallverhütungsvorschrift) DGUV Vorschrift 1 is more specific: under § 4, the briefing must take place at least once a year and be documented. The content must be conveyed in an understandable way.

Several ordinances contain their own requirements:

• § 12 BetrSichV: before work equipment is used for the first time, and at least once a year thereafter; the date and names of those instructed must be recorded in writing.
• § 6 ArbStättV: at least once a year, covering first aid, fire protection and escape routes, among other things.
• § 14 GefStoffV: for activities involving hazardous substances, orally and specific to the workplace on the basis of the operating instructions, at least once a year; the content and date must be recorded in writing and confirmed by the signatures of those instructed.
• § 29 JArbSchG: young people must be instructed again at least every six months.

For annual planning, this means that apprentices under 18 need their own date in the calendar, otherwise the second briefing of the year can easily fall by the wayside.

What belongs in the record

The regulations result in minimum content: the date, the names of the participants and the topics covered, and for hazardous substances the signature as well. It also makes sense to name the person giving the briefing and the operating instructions used. A list of signatures under the heading "Safety briefing" without any indication of the topics makes it almost impossible to tell afterwards what was discussed.

In addition to the annual date, the occasions set out in § 12 ArbSchG still apply. If a new machine arrives in March, employees are instructed before using it, not at the next annual briefing.

E-learning as an aid

Electronic briefings can support face-to-face instruction. According to DGUV Regel 100-001, the DGUV sets three conditions for this: the content is tailored to the specific workplace, understanding is tested, and a conversation between employees and the person giving the briefing is possible at any time. A general video with no connection to your own business does not meet these requirements. For employees with limited German, the briefing must be given in a form and language they understand; § 14 GefStoffV states this explicitly for hazardous substances.