A safety officer must be appointed as soon as a business regularly employs at least 50 people, and since the amendment to section 22 SGB VII on 29 May 2026 that applies to pure office and administrative businesses too. Between 20 and 49 employees the duty applies only where there is a special hazard to life and health, so in a classic office usually not. Below 20 employees nobody has to be appointed. A voluntary appointment is possible at any size and often makes sense in practice.
Who counts towards the threshold
What is counted is the people regularly employed in the business, not full-time positions. Part-time staff, apprentices and generally temporary agency workers must be included. Anyone sitting just below or above the line should confirm the counting method with their responsible employers' liability insurance association, which also holds the sector-specific requirements.
When a voluntary appointment is worth it
Below the mandatory threshold there is no legal obligation. Two arguments still speak for filling the role earlier.
First, it clarifies the reporting route. In small businesses, shortcomings either land directly with management or nowhere at all. A named contact lowers the barrier to reporting something small in the first place, and it is exactly the small things that cause accidents in administrative businesses. Second, the business is prepared when the threshold is reached. Start early and by the time you reach 50 you have an established role rather than a new construction site.
The effort is modest: a written appointment, a seminar run by the insurance association and a bit of everyday attention.
How many people you actually need
The number does not come from a fixed formula but from Annex 2 of DGUV Regulation 1. Three factors decide it: the number of employees, the accident and health hazards present, and physical proximity. The last of these is the one most often underestimated.
The underlying idea is simple: a safety officer should be approachable and notice what happens day to day. Someone sitting on the third floor does not see conditions in the basement. Three situations in concrete terms:
- One site, one floor, 60 employees: one person is generally enough.
- One site, three floors, 90 employees: one person per floor is the obvious answer, because traffic routes, escape routes and first-aid supplies differ from floor to floor.
- Two sites with 55 employees each: at least one person per site. A single shared responsibility across two addresses does not satisfy the purpose of physical proximity.
The safety-officer calculator gives you a quick orientation, sites and shifts included. The duties quick-check shows which duties apply at which headcount.
What the duties are
The safety officer supports the employer in implementing occupational safety, alongside their regular job and on a voluntary basis, not as a separate function with authority to give instructions. Typical duties in an office:
- Watching for safe conditions: clear escape routes, intact cable management, reachable first-aid kits.
- Speaking to colleagues about risky behaviour, for example blocked doors.
- Reporting shortcomings and near misses to the manager or the occupational safety specialist.
- Contributing to walkthroughs, safety training and the risk assessment.
- In businesses with more than 20 employees, taking part in the occupational safety committee.
What expressly does not belong to the role: the safety officer carries out no inspections, does not produce the risk assessment and takes no decisions about measures. They report, contribute and advise from the perspective of daily work. Overloading the role with tasks that require professional expertise overstretches it and creates a false sense of security.
Important: the safety officer carries no additional responsibility under occupational safety law. Responsibility stays with the employer and the managers. The role also creates no extended personal liability.
Whom it makes sense to appoint
The regulation makes no stipulations about the person beyond requiring them to act close by in time and place. In practice four criteria work well:
- Knows the business. New colleagues still on probation are rarely the right choice.
- Approachable day to day. Someone mostly in the field or working remotely does not see enough.
- Has acceptance. The role depends on being able to speak to a colleague about a blocked door without it feeling like surveillance.
- Not necessarily a manager. On the contrary: a person without authority to give instructions often learns more about actual conditions than a supervisor does.
Anyone who already carries employer responsibility is unsuitable. Management cannot appoint itself as safety officer, because the role is meant to provide precisely the supporting counter-perspective to the level that is responsible.
How the appointment works
The appointment is made in writing by the employer, after involving the works council. The appointment should name the duties, the area of responsibility and the time frame, and be filed with the occupational safety records.
The safety officer must be released from work during working hours for initial and continuing training; the insurance associations offer suitable seminars, often free of charge for member businesses. The attendance records belong in the documentation.
The role across the year
The effort is small, but it is not zero, and it spreads across the year. A realistic picture for one office location:
- Ongoing, day to day: looking and speaking up. Clear escape routes, cables in a walkway, a first-aid kit that needs restocking. This costs no separate time; it is a matter of attention.
- Once or twice a year: taking part in the walkthrough with the occupational safety specialist. This is where the safety officer contributes most, because they know where the boxes usually sit when nobody is looking.
- Quarterly, above 20 employees: the occupational safety committee meeting.
- As occasions arise: contributing after an accident or near miss, during a relocation or when new workstations are set up.
- Every few years: a refresher seminar run by the insurance association.
The safety officer on the occupational safety committee
The occupational safety committee must be set up from more than 20 employees and meets at least once per calendar quarter (section 11 ASiG). Where a safety officer is appointed, they are a statutory member there, alongside the employer, the occupational safety specialist, the occupational physician and works council representatives. From 50 employees both obligations coincide; between 20 and 49 the committee exists even where no safety officer has to be appointed for lack of a special hazard.
In practice this is the role's most important lever: on the committee, everyday observations turn into decisions. Anyone who merely attends without raising what they see day to day misses the point of the role. Dates for a full year ahead can be planned with the ASA planner. What else the committee has to settle is covered in Occupational safety committee (ASA): from when?.
Common mistakes with the appointment
- Named verbally only. Without a written appointment the obligation is not formally met, and during an inspection the evidence is missing.
- Appointed but never trained. Release for initial and continuing training is part of the obligation, not a courtesy.
- Appointment not updated after someone leaves. If the named person leaves the business or moves department, a new appointment is required. An appointment naming someone who left two years ago is spotted at every inspection.
- Duties not described. Without an area of responsibility, neither the person nor the business knows what the role covers.
- Misunderstood as a way to save. A safety officer replaces neither the specialist nor the occupational physician, and does not reduce the support hours.
Not a substitute for the occupational safety specialist
A common misconception: an appointed safety officer does not satisfy the requirement for safety support under the ASiG. The two exist side by side. The safety officer is the person on the ground day to day; the occupational safety specialist brings the professional advice and the evidence of support. The occupational physician remains a separate obligation as well.
In practice the two work well together when both roles are properly appointed and the reporting routes are clear. Safety Club provides office and administrative businesses with an occupational safety specialist on site and makes sure that appointments, training sessions and records are documented ready for inspection. We are happy to clarify open points in an initial conversation.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the SGB VII and DGUV Regulation 1, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets it.
