Audit-ready occupational safety records meet five marks: they are complete, dated, attributed to an accountable person, findable inside the business and kept current. If one of these five marks is missing, the document exists but does not prove what it is meant to prove, namely that occupational safety is actually organised in the business.
An audit-ready record is a document that shows what was assessed, decided and implemented without its author having to explain it. The legal core is section 6 paragraph 1 ArbSchG: the employer must hold records from which the result of the risk assessment, the measures laid down and the result of their review are apparent. The questions asked about them during an inspection are covered in Top 5 questions during an inspection. This article is not about which records must exist, but about what decides whether an existing record works as proof.
| Mark | Test question | Legal basis |
|---|---|---|
| 1. Complete | Is there a record for every duty? | section 6 ArbSchG, section 4 DGUV Regulation 1 |
| 2. Dated | Is it clear when this version was created? | section 6 ArbSchG |
| 3. Attributed | Is it clear who is accountable for it? | section 13 ArbSchG, section 5 ASiG |
| 4. Findable | Can it be produced within minutes? | section 6 ArbSchG (holding records) |
| 5. Kept current | Does the version match the business today? | section 3 paragraph 1 ArbSchG |
Mark 1: complete
Occupational safety records are complete when every applicable duty has a matching record. In an office business those are regularly six documents: the risk assessment with measures and effectiveness review, instruction records, appointments of the occupational safety specialist and the occupational physician, designations of first aiders and fire safety helpers, test records for electrical equipment, and first-aid records.
Completeness is measured against the duties of your own business, not against the thickness of the folder. A template from another industry can run to 40 pages and still be incomplete if mental workload under section 5 paragraph 3 number 6 ArbSchG does not appear in it.
| Record | Legal basis | Trigger for updating |
|---|---|---|
| Risk assessment with measures | sections 5 and 6 ArbSchG | relocation, refurbishment, new activity, accident |
| Instruction record | section 12 ArbSchG, section 4 DGUV Regulation 1 | at least annually, on hiring |
| Appointment of the safety specialist | section 5 ASiG, section 2 DGUV Regulation 2 | change of person or provider |
| Designation of first aiders and fire safety helpers | section 26 DGUV Regulation 1, ASR A2.2 | staff turnover, expiring deadlines |
| Test record for electrical equipment | DGUV Regulation 3, section 3 BetrSichV | after every test |
| First-aid record | section 24 DGUV Regulation 1 | after every instance of first aid |
The list grows with the business: if an office employs young people, the six-monthly instruction under section 29 paragraph 1 JArbSchG is added, and for display screen work the record of the offer of occupational health care under ArbMedVV. Which records are due in your own business is listed by the office safety checklist.
Mark 2: dated
A record is dated when the creation date and the version appear on the document itself, not only in the file system. A modification date in the file browser proves nothing: it changes when the file is merely opened and saved, and it is lost when the file is copied to another folder. Without a date, currency cannot be claimed.
The date is where most otherwise sound records fail. A risk assessment without a date may be five weeks or five years old, and the burden of proof sits with the business. For instruction records the date is also the basis of the deadline calculation: without a date of delivery, the annual deadline under section 4 DGUV Regulation 1 cannot be checked.
In practice three details belong in the header of every record: creation date, version and the next planned review date. When the next instruction is due is calculated by the instruction deadline calculator.
Mark 3: attributed to an accountable person
A record is attributed when it is clear who produced it and who stands behind the measures laid down in it. Section 6 ArbSchG does not expressly require a signature on the risk assessment. Written form is required in two places: for the appointment of the occupational safety specialist and for delegating employer duties.
The appointment of the occupational safety specialist must be made in writing under section 5 paragraph 1 ASiG, as must the appointment of the occupational physician under section 2 paragraph 1 ASiG. Delegating employer duties to reliable and competent persons is likewise done in writing under section 13 paragraph 2 ArbSchG. On an instruction record the signature of the person instructed is not expressly required, but it is the usual evidence in practice that the instruction took place.
For all other records: accountability vs. signature are two different things. What is required is that the attribution is apparent. A line with name, function and date at the end of the document meets that. The other typical findings on a risk assessment are covered in 7 mistakes in the office risk assessment.
Mark 4: findable
A record is findable when it is available during the appointment without anyone having to search or make a phone call. Section 6 paragraph 1 ArbSchG requires the employer to hold the records. Anyone who first has to call the service provider during an inspection does not hold them in the legal sense, even if the document exists somewhere.
Paper form is not required: section 6 ArbSchG prescribes no format, digital storage is permitted and usually better. Three things must be settled for that: who has access, which device is available on site, and who retrieves the records when the person normally responsible is on holiday. A portal login whose password only one person knows is storage, but not access.
Two special cases: first-aid records contain health data and specifically must not sit in the open, as described in First aid in the office. And if the records sit in a service provider's portal, release in a readable format belongs in the support contract, at any time and after the contract ends.
Mark 5: kept current
Records are current when their version matches the business today. Under section 3 paragraph 1 ArbSchG the employer must review the measures taken for effectiveness and adapt them to changing circumstances. German occupational safety law names no fixed interval for updating the risk assessment, but it does name concrete triggers.
In an office business the triggers are nearly always the same: relocation or refurbishment, new work equipment such as sit-stand desks or a second monitor, new activities, an accident or near miss, a pregnancy with the assessment under section 10 MuSchG, and a move to regular work from home. Two deadlines run alongside them: instruction at least annually under section 4 DGUV Regulation 1 and six-monthly for young people under section 29 paragraph 1 JArbSchG.
Keeping records current does not mean rewriting them. If a review finds nothing changed, exactly that is what gets documented: date, scope reviewed, result unchanged. That line takes two minutes and is the difference between a maintained record and a forgotten one. Test intervals for equipment are calculated by the DGUV Regulation 3 test interval calculator.
What the folder holds at 8, 30 and 80 employees
The volume of records grows with the headcount thresholds, not with the floor area. The overview below shows which records are added across three typical office sizes. It lists records and quantities, not page counts: the size of a risk assessment depends on the number of workplace types, not on the number of people.
| Record | 8 employees | 30 employees | 80 employees |
|---|---|---|---|
| Risk assessment under section 6 ArbSchG | yes | yes | yes |
| Instruction record, annual | yes | yes | yes |
| Appointment of specialist and physician | yes | yes | yes |
| First aiders, administrative business | 1 person | 2 people | 4 people |
| Safety committee minutes | not required | 4 a year | 4 a year |
| Appointment of safety officers | not required | not required | required |
The risk assessment and the instruction record apply from the first employee onwards. Between 8 and 30 the minutes of the occupational safety committee under section 11 ASiG are added, which must be set up above 20 employees and meets at least once each calendar quarter. Between 30 and 80 the appointment of safety officers under section 22 SGB VII is added, required from 50 regular employees since 29 May 2026.
Reviewing your own records in five steps
The review takes around 90 minutes and needs nothing but access to the existing records. Once a year is sensible, ideally on the same cycle as the annual instruction.
- List what exists. Record every existing document with title, date and storage location in a single list, whether it sits on paper, on a drive or in a service provider's portal.
- Compare against the list of duties. Match the list against the duties that apply to your own business and mark every duty without a matching record as a gap.
- Check date and attribution. Look at each document to see whether it carries a creation date and whether it is clear who is accountable for it.
- Test access under real conditions. Call up a sample of three documents without preparation and time how long it takes, using the deputy rather than the person normally responsible.
- Schedule the next review. Set the next review date for each document and enter it, together with the recurring deadlines, in one calendar.
If more than one mark fails, the problem rarely lies in the content of the individual document. It lies in the fact that nobody in the business runs the records as an ongoing task, and everyone produces them case by case instead.
Safety Club covers the statutory scope for office and administrative businesses in one contract: an occupational safety specialist on site plus digital, audit-ready documentation in which date, accountability and deadlines sit in one place. Which of the five marks your business already meets is something we go through in an initial conversation.
This article is general orientation and does not replace legal advice on an individual case. The applicable versions of ArbSchG, ASiG and DGUV Regulations 1, 2 and 3 govern, together with the interpretation of the employers' liability insurance association responsible for your business.
