Basics

Occupational safety committee (ASA): from when?

Occupational safety committee (ASA): from when?

An occupational safety committee must be set up as soon as a business has more than 20 employees, so from 21 people (section 11 ASiG). It meets at least once per calendar quarter and brings the employer, the occupational safety specialist, the occupational physician, any safety officers and the works council to one table. For growing office businesses it is usually the first organisational duty of this scale.

The threshold and what arrives with it

At 21 employees the occupational safety committee under section 11 ASiG applies. The appointment of safety officers under section 22 SGB VII was decoupled from this on 29 May 2026 and, in a classic office, is only mandatory from 50 employees (between 20 and 49 only where there is a special hazard). Where safety officers are appointed, they are at the same time members of the committee.

What is counted is the people regularly employed, not full-time positions. Part-time staff and apprentices count. In practice this means businesses cross the threshold without noticing: growing from 19 to 22 people, three of them part-time, makes a committee mandatory from that moment. The duties quick-check shows which duties apply at your headcount.

Who takes part

The composition is set by law:

This composition is not a formality. It ensures that the medical, the technical safety and the operational perspectives come together. If the occupational physician is regularly absent, the perspective that matters most for mental stress and ergonomics is the one that goes missing.

Cycle: at least quarterly

The committee meets at least once per calendar quarter. The exact wording matters: what counts is the calendar quarter, not an interval of three months. A meeting on 31 March and one on 1 April are a day apart and still cover two quarters. Two meetings in May and June are further apart and cover only one. In practice: one meeting per quarter, and it is better to fix the dates a year in advance.

That is exactly what the ASA planner is for: enter the date of the last meeting and it shows the next four quarterly dates.

What belongs on the agenda

A meeting without an agenda turns into an exchange of impressions. These points carry a committee meeting in an office business and can be worked through in 60 to 90 minutes:

  • Accidents and near misses since the last meeting, with the sequence of events and the measures derived. See Accidents at work in the office.
  • Status of the risk assessment: what was updated, which measures are open, which deadlines are running.
  • Effectiveness review of the measures from previous quarters. This point is the one most often missing and the one asked about during an inspection.
  • Upcoming safety training and its status.
  • First aid and fire safety: status of first aiders and fire safety helpers, upcoming refreshers, test intervals.
  • Observations from the safety officers from day-to-day work.
  • Upcoming changes: relocation, refurbishment, new work equipment, introduction of remote work.
  • Mental stress: status of the survey, measures derived.

How a meeting that achieves something runs

The difference between a committee that satisfies an obligation and one that actually advances occupational safety lies in the preparation. This sequence works well:

Before the meeting. The occupational safety specialist circulates a short agenda with the open measures from the previous quarter. Whoever owns a measure brings its status. That avoids the most common waste of time: collectively reconstructing what was discussed last time.

During the meeting. First close or extend the open points from the previous quarter, with reasons. Then the new topics. Finally confirm the dates. New measures get an owner and a deadline immediately, otherwise they are not decided but merely mentioned.

After the meeting. The minutes go to all members within a few days and go into the same file as the rest of the occupational safety documentation. Whoever owns a measure has the deadline in their own calendar.

A committee working this way rarely needs more than 60 minutes per quarter. A committee without preparation takes longer and produces less.

The first meeting in a new committee

Anyone setting the committee up for the first time should structure the first meeting differently from those that follow. It serves to take stock, not to work through items.

Four points make sense: clarify responsibilities, meaning who chairs, who takes minutes and who convenes. Take stock of the safety organisation, meaning which appointments exist, whether the risk assessment is current and when training last took place. Turn that into a list of open points, each with an owner and a deadline. And fix the dates for the following three quarters.

Experience shows this first meeting takes longer than 60 minutes, because it lays the foundation. All the following ones are considerably shorter once the list exists.

The committee in businesses without a works council

Many office businesses between 21 and 50 employees have no works council. The committee must still be set up; it then consists of the employer, the occupational safety specialist and the occupational physician. Safety officers usually do not yet have to be appointed at this size (mandatory only from 50) and join only where they exist.

In practice this removes the voice that brings observations from the workforce. That gap should be closed deliberately, otherwise only the perspective of the appointed roles and management is represented. Two simple routes: ask the safety officers expressly to canvass colleagues for open points before each meeting, or invite one person from another area as a guest at each meeting.

What the committee is not

Two distinctions save a lot of discussion. The committee is not a decision-making body in place of the employer: it advises and coordinates, but responsibility for implementation stays with the employer. And it is not a substitute for ongoing support: four meetings a year do not cover the specialist's advisory duty; they are the place where its results come together.

Conversely, the committee is not merely a compliance exercise either. In office businesses it is often the only fixed appointment at which occupational safety is discussed in a structured way at all. Taking it seriously saves the scramble when a letter from the employers' liability insurance association arrives.

Why the minutes matter

The law does not expressly require minutes. In practice they are nonetheless the most important part, because they are the only evidence that the committee met and what was decided.

Usable minutes contain: date, participants with their function, the points covered, the decisions taken, and for each measure an owner and a deadline. That last part is the difference between minutes that document a meeting and minutes that actually steer occupational safety.

When the employers' liability insurance association makes an enquiry, the minutes of recent quarters are among the documents regularly requested. How to respond to such a letter is set out in A letter from the Berufsgenossenschaft; the BG risk check gives a read on where your business stands.

Common mistakes

  • Dates not planned in advance. Searching for a slot each quarter regularly costs a quarter.
  • The employer sends someone without decision-making authority. Measures then get discussed but not decided.
  • No minutes, or only keywords. Without owners and deadlines they are not a steering instrument.
  • The same points recurring without closure. A topic appearing in four consecutive sets of minutes shows an inspection exactly the opposite of what it should.
  • Committee set up but dormant after the first year. The cycle applies permanently, not only in the founding year.
  • Quietly disbanding the committee when headcount drops below 21. While the number fluctuates it is simpler to keep the cycle running than to restart it each time the threshold is crossed.

Safety Club supports the committee for office and administrative businesses: the occupational safety specialist on site brings the professional perspective, and the results go into audit-proof documentation. Get in touch when your business reaches the 20-employee mark.

This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the regulations mentioned, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets it.

Frequently asked questions

From how many employees is the committee mandatory?

Above 20 employees, so from 21 people (section 11 ASiG). Below that there is no obligation, although a committee can be set up voluntarily.

How often must the committee meet?

At least once per calendar quarter, so four times a year. What counts is the calendar quarter, not an interval of three months: two meetings in the same quarter do not cover the next one.

Who must sit on the committee?

The employer or a person they appoint, two works council members (where a works council exists), the occupational physician, the occupational safety specialist and the safety officers.

Must minutes be kept?

The law does not expressly require minutes, but in practice they are the central evidence that the committee actually met. They are regularly requested during an inspection. Without minutes the meeting cannot effectively be evidenced.

What happens if we do not set up a committee?

Its absence is a shortcoming in the safety organisation and can be objected to during an inspection. What weighs more in practice is that without the committee there is no forum in which the specialist, the physician and the business coordinate.

Can meetings be held online?

Yes, the law does not require attendance in person. What matters is that all members can take part and that the discussion actually happens. An exchange of emails alone does not replace the meeting.

Do part-time staff count towards the 20-employee threshold?

Yes. What matters is the number of people regularly employed, not the number of full-time positions. Part-time staff and apprentices count.

Sources

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