Online safety training is allowed if three conditions are met: the content is tailored to your own business and workplace, understanding is checked, and questions to a trainer are possible at any time. That is what DGUV Rule 100-001 says. It applies in the office and in the home office, where additional topics come on top.
Safety training (Unterweisung) is the explanation of hazards and protective measures required by section 12 ArbSchG, aimed specifically at the employee's workplace or area of work. Deadlines and topics for office training in general are covered in Safety training in the office. This article is about when digital training holds up and what the home office adds.
What do the law and the DGUV say about online training?
Neither the Occupational Safety and Health Act nor DGUV Regulation 1 prescribes a particular format for safety training. DGUV Rule 100-001, section 2.3.1, calls for training in person but allows electronic aids if workplace relevance, a comprehension check and questions at any time are secured. Pure self-study does not meet the duty.
The legal bases in detail:
- Section 12(1) ArbSchG requires sufficient and appropriate training during working time, with instructions and explanations aimed specifically at the workplace.
- Section 4(1) DGUV Regulation 1 states that training takes place at least once a year and is documented.
- Section 6(4) ArbStättV requires training before work starts, repetition at least once a year and a form and language the employees understand.
- DGUV Rule 100-001, section 2.3.1 adds that insured persons must be able to put questions to the trainer and that additional practical teaching of some procedures may be needed when electronic aids are used.
The DGUV sums it up: electronic media can support training but do not replace the conversation.
Live online vs. e-learning: what is the difference?
Live online training is training by video call in which a trainer presents in real time and answers questions. An e-learning module, by contrast, is completed alone at the computer at a time of the employee's choosing. The live format meets the requirement for questions by itself; e-learning needs a separate channel for it.
| Criterion | In-person training | Live online by video | E-learning module |
|---|---|---|---|
| Questions | directly in the room | directly in chat or by raising a hand | only via a named question channel |
| Comprehension check | questions, demonstration, observation | questions, poll, short test | automatic test, result per person |
| Practical exercise | possible, e.g. extinguisher, escape route | not possible | not possible |
| Catch-up for absentees | separate session needed | recording alone is not enough | any time within the deadline |
| Typical use | induction, fire wardens | distributed teams, annual training | annual training, refreshers |
| Biggest risk | absences, missing records | camera off, other work on the side | clicking through without business relevance |
A recording of live training is not a full substitute for absentees as long as no question channel is named. With control questions and a reachable contact person it becomes a usable e-learning module.
Where online training reaches its limits
Online training reaches its limits as soon as something has to be practised or shown on site. New employees learn escape routes, emergency exits and the assembly point best on a short walk-through, and under section 6(3) ArbStättV fire wardens must be trained in operating the fire-fighting equipment. Neither works in front of a screen.
Three cases in which an in-person part should be planned in the office:
- Induction on hiring. Rooms, escape routes, first aid supplies and first aiders are shown on site. The module can prepare, the walk-through cannot be replaced.
- Fire wardens. The practical extinguishing exercise is part of their training, background in Fire safety in the office.
- Hazardous substances. For work with hazardous substances, section 14(2) GefStoffV requires oral, workplace-specific training based on the operating instructions, with content and date confirmed by the trainees' signature.
Language is another limit: a German module full of technical terms is not training in an understandable form within the meaning of section 6(4) ArbStättV for employees with little German.
Which topics belong in home office training?
Home office training covers all hazards that the risk assessment identifies for working at home or on the move. Typical topics are setting up the display screen workstation, working time and availability, electrical safety, tripping hazards and what to do after an accident. Without a matching section in the risk assessment, the training lacks its basis.
How to build the risk assessment for the home office is explained in Risk assessment for the home office and telework. For training, the distinction matters: under section 2(7) ArbStättV a telework station is a display screen workstation set up permanently by the employer in the employee's private space. Under section 1(4) ArbStättV, section 6 ArbStättV applies to telework stations, including the duty to train at least once a year. For mobile work without a fixed set-up the ArbStättV does not apply, but the training duty under section 12 ArbSchG and section 4 DGUV Regulation 1 applies unchanged.
| Topic | What employees need to know | Legal basis |
|---|---|---|
| Display screen workstation | chair, desk height, screen distance, light, external keyboard rather than the laptop alone | ArbSchG section 5, for telework ArbStättV annex no. 6 |
| Working time and breaks | maximum working time, breaks, rest period of generally eleven hours | ArbZG sections 3 to 5 |
| Availability and strain | fixed hours, handling messages after work, contact persons | ArbSchG section 5(3) no. 6 |
| Electrical safety | no damaged cables, no daisy-chained power strips | DGUV Regulation 1 |
| Tripping and falling | cable routing, clear paths, no working on the stairs | ArbSchG section 5 |
| Accident and reporting | who is informed how, insurance cover in the household | SGB VII section 8(1) sentence 3, section 193 |
| Mobile locations | train, hotel, café: short stints, breaks, glare | ArbSchG section 5 |
One clear sentence on insurance belongs in the training: under section 8(1) sentence 3 SGB VII, insured work carried out in the employee's household is covered to the same extent as work on the company premises. An accident in the home office must therefore be reported just like one in the office.
For setting up at home, Setting up a display screen workstation properly works well as an annex to the training.
How to set up compliant online safety training
Compliant online training is built in six steps: derive the content from the risk assessment, make it specific to the business, build in a comprehension check, name a channel for questions, add practical parts on site and file the record with deadline tracking. If one of these steps is missing, digital training remains open to challenge.
- Derive the content from the risk assessment. For each group of activities, decide which hazards and measures the training must cover, including a separate part for home office and mobile work.
- Make it specific to the business. Add your own rooms, escape routes, first aiders, reporting routes and contact persons to generic modules, with photos and names instead of placeholders.
- Build in a comprehension check. Ask control questions on each topic that refer to your own business, such as "Where is the assembly point?", and decide what happens after wrong answers.
- Name a channel for questions. Give a reachable person with name, time window and contact route and offer at least one live question session per round.
- Add practical parts on site. Walk the escape routes and assembly point and run the fire extinguisher exercise for fire wardens in person, above all for new hires.
- File the record and track deadlines. Store date, topics, module version, test result and confirmation for each person and remind those outstanding before the deadline.
When the next training is due for each person is calculated by the training deadline calculator, including the six-monthly cycle for young people under section 29 JArbSchG.
If the business has a works council or staff council, involve it early. The design of safety training falls under co-determination on health protection under section 87(1) no. 7 BetrVG. A learning system that stores completion times and results per person may also touch co-determination on technical equipment under section 87(1) no. 6 BetrVG.
Worked example: hybrid annual training in three business sizes
A hybrid model combines a business-specific e-learning module with a live question session and in-person parts only where something must be practised. In the example below the module takes 30 minutes per person, the live session 30 minutes, and the in-person version 60 minutes in groups of up to 20. The assumptions are set, not measured.
| Business | In person: sessions | In person: employee hours | Hybrid: employee hours | Hybrid: trainer hours |
|---|---|---|---|---|
| 12 employees, one office | 1 | 12 | 6 plus question session | 0.5 plus questions |
| 45 employees, 60 percent home office | 3 | 45 | 22.5 plus question session | 1 plus questions |
| 140 employees, two sites | 7 | 140 | 70 plus question session | 1.5 plus questions |
The bigger advantage lies with absentees: with seven in-person sessions some people are always missing, and each needs a separate date. The module is completed within the deadline instead. In return it has to be updated whenever the risk assessment changes.
What the record of online training should contain
The record of online training contains the same details as for in-person training, plus the module version and the result of the comprehension check. Section 4 DGUV Regulation 1 does not require a handwritten signature. A digital confirmation with date and topics is sufficient, except for hazardous substances under section 14(2) GefStoffV.
- Date of completion or of attendance at the live training.
- Topics in detail and the module version, so it is clear later which version was taught.
- Result of the comprehension check and what happened after failed questions.
- Name of the responsible trainer and the named question channel.
- Confirmation per person, for example a click with time stamp in the employee's own account.
- Outstanding persons and the date of the catch-up.
Safety Club combines both: digital training with records and deadline reminders in the customer portal, and an occupational safety specialist on site who handles in-person parts and questions. How getting started works is shown in the four-step process.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the regulations cited, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets them.
