The number of safety officers depends on two questions under section 22 SGB VII: are 50 or more people regularly employed, and is there a special hazard? An office with 50 to 249 employees and no special hazard meets the duty with a single safety officer. From 250 employees, five criteria determine the number.
A safety officer (Sicherheitsbeauftragter) is an employee who supports the employer in preventing accidents on a voluntary basis under section 22(2) SGB VII, with no authority to give instructions and no additional responsibility. Duties, appointment and choosing the right person are covered in Safety officers in the office. This article is about the number: how many people does it have to be, and how do you justify it?
| People regularly employed | Duty to appoint | How many |
|---|---|---|
| up to 20 | no duty | voluntary, usually one person |
| more than 20 up to 49 | only where the risk assessment shows a special hazard | one person |
| 50 to 249, no special hazard | required | one person is enough |
| 50 to 249, special hazard | required | by the five criteria |
| 250 or more | required | by the five criteria |
| any size | order by the accident insurance institution possible where there is a special hazard | as ordered |
What section 22 SGB VII has required since May 2026
Since 29 May 2026 businesses with 50 or more regularly employed people must appoint safety officers; before that the threshold was more than 20. Also new is a special rule for smaller businesses: below 250 employees without a special hazard, a single safety officer is enough, regardless of floors or sites.
Four sentences of the provision decide the number:
- Sentence 1: From 50 regularly employed people the employer appoints safety officers "taking into account" the accident and health hazards and the number of employees.
- Sentence 3: With more than 20 and fewer than 50 employees a safety officer must be appointed only if the risk assessment under section 5 ArbSchG shows a special hazard to life and health.
- Sentence 4: With fewer than 250 employees and no special hazard, the duty under sentence 1 is met by appointing one safety officer.
- Sentence 5: The accident insurance institution can order appointments where there is a special hazard.
For office and administrative businesses sentence 4 is the key line. Screen work does not as a rule create a special hazard, so the vast majority of offices with 50 to 249 employees need exactly one person. Whether there is a special hazard after all, for example from a laboratory or a workshop, is decided by the risk assessment.
One point deserves attention: section 20(1) of DGUV Regulation 1, in the version published so far, still names the old threshold of more than 20 employees. If in doubt, ask your accident insurance institution directly how it handles the transition.
Who counts towards the number
What counts is the number of people regularly employed, by head, not full-time positions. Section 22(1) sentence 2 SGB VII also expressly includes certain other insured persons, among them learners in vocational training under section 2(1) no. 2 SGB VII. Part-time staff count in full.
Three points lead to mistakes in practice:
- No weighting by hours. Unlike the deployment times under DGUV Regulation 2, part-time staff count in full here. A law firm with 38 full-time positions spread over 52 people is above the threshold of 50.
- "Regularly" means normal operations. A short-term spike from temporary staff in December does not move the threshold. If you hover between 48 and 52 people, appoint as a precaution.
- Children, pupils and students count in their institutions, because section 22(1) sentence 2 SGB VII also refers to section 2(1) no. 8 SGB VII. Relevant for nurseries and school operators, not for offices.
The obligations quick check shows which duties apply at your headcount overall.
The five criteria for the number under DGUV Regulation 1
Where sentence 4 does not apply, that is from 250 employees or where there is a special hazard, the employer sets the number under section 20(1) DGUV Regulation 1 using five criteria: accident and health hazards, spatial proximity, temporal proximity, professional proximity and number of employees. There has been no fixed headcount scale since DGUV Regulation 1.
The former appointment scales were Annex 2 of BGV A1. The criteria in detail, as the employers' liability insurance associations read them:
- Accident and health hazards follow from the risk assessment under section 5 ArbSchG.
- Spatial proximity exists when the safety officer works at the same site in the same work area. According to the BGHM guide, work in different buildings points to a lack of spatial proximity.
- Temporal proximity means the person works at the same time, in the same shift or with overlapping shifts.
- Professional proximity exists when safety officer and employees permanently do the same or similar work.
- Number of employees: someone who no longer knows their colleagues has little effect.
All five criteria rank equally. For headcount the BGHM guide gives a reference point: if more than 250 people work in a low-hazard building or area, an additional person with their own area of responsibility is recommended. For technical work with higher hazards it assumes at most 80 employees per safety officer. Both values are recommendations of one insurance association, not statutory limits.
Three office businesses worked through
Three typical set-ups show how the law and the criteria play out. The tax adviser with 45 people needs nobody, the agency with 140 employees on two sites exactly one person, the insurance administration with 420 employees three to four. The 250 threshold and the shifts make the difference.
| Business | Structure | Legal basis | Required number | Recommendation |
|---|---|---|---|---|
| Tax advisory firm, 45 employees | one site, one floor | section 22(1) sentence 3 SGB VII | 0 | one person voluntarily |
| Agency, 140 employees | Berlin 100, Hamburg 40 | section 22(1) sentence 4 SGB VII | 1 | second person in Hamburg voluntarily |
| Insurance administration, 420 employees | two buildings, customer service in two shifts | section 22(1) sentence 1 SGB VII, section 20 DGUV Regulation 1 | 3 to 4 | 4 |
Tax advisory firm, 45 employees. Between 21 and 49 employees without a special hazard there is no duty. Because the firm is set to grow past 50, a voluntary appointment still makes sense.
Agency, 140 employees at two sites. Below 250 without a special hazard: under section 22(1) sentence 4 SGB VII one person is enough, even if they sit in Berlin. In practice they will not notice that the escape route in Hamburg is blocked by trade fair boxes. A voluntary second appointment in Hamburg closes that gap.
Insurance administration, 420 employees. From 250 the five criteria apply. Building A with 240 employees in case handling gets one person. In building B, customer service works with 110 employees on the early shift and 50 on the late shift without overlap: temporal proximity calls for two people. Facilities, post room and storage with 20 employees are either covered by one of them, depending on professional proximity, or get their own person.
For your own set-up the safety officer calculator gives an orientation based on employees, sites and shifts.
How to determine the number in five steps
The number is worked out with reasons, not guessed. The right forum is the occupational safety committee, where employer, occupational safety specialist, company doctor and works council already sit together. The result belongs in writing in the occupational safety records so that you can explain it during an inspection by the employers' liability insurance association.
- Gather the basics: floor plan or site plan, organisation chart, headcount per site, building and department, and the current risk assessment.
- Check the threshold and the special rule: are 50 or more people regularly employed, and does the risk assessment show a special hazard? Below 250 without a special hazard one person is enough.
- Define areas of responsibility: from 250 employees or where there is a special hazard, cut the areas by spatial and professional proximity, typically per building or per clearly different activity.
- Match working hours: for each area check whether the designated person works at the same time as the employees. Separate shifts without overlap each need their own person.
- Fix the result in the safety committee: compare target and actual, set the number with the involvement of the works or staff council, issue the appointments in writing and document the reasoning.
When the committee meets and who belongs to it is covered in Occupational safety committee: when is it required?.
Common mistakes with the number
Most mistakes happen at transitions: headcount passes 50 or 250, a site is added or the appointed person leaves. Anyone who sets the number once and never checks it again is often understaffed without noticing after the next growth step.
- Counting full-time positions instead of heads. The threshold of 50 is then recognised too late.
- Overlooking sentence 4. One person per floor with 120 employees is fine voluntarily, but it is not required.
- Ignoring shifts. From 250 employees, a person on the early shift does not provide temporal proximity for the late shift.
- No deputy. During parental leave or long-term illness of the only person the duty is effectively vacant. If you need exactly one person, plan a second as a deputy.
- No documented reasoning. If the number is not documented, you cannot explain it during an inspection, even if it is correct.
Safety officer vs. occupational safety specialist
The number of safety officers says nothing about safety support under the ASiG. The safety officer under section 22 SGB VII contributes day-to-day observation, the occupational safety specialist (Fachkraft für Arbeitssicherheit) under the ASiG the expertise and the proof of support. The specialist must be in place from the first employee, even where no safety officer is needed.
Safety Club provides office and administrative businesses with an occupational safety specialist on site plus digital, audit-proof documentation, where appointments and the reasoning behind the number are filed as well. We are happy to discuss your set-up in an initial call.
This article is general guidance and does not replace legal advice on individual cases. The current versions of SGB VII and DGUV Regulation 1 and the interpretation of your responsible employers' liability insurance association are authoritative.
