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 external occupational safety specialist is a standing member of the committee under section 11 ASiG and in practice sends the agenda before each meeting.
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 21 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, but part-time staff count proportionally under section 11 ASiG: up to 20 hours a week as 0.5, up to 30 hours as 0.75, above that in full. A business with 18 full-time staff and six part-timers at 15 hours reaches 21 and needs a committee; one with 15 full-time staff and ten part-timers at 20 hours reaches only 20 despite 25 people and does not.
| Workforce | People | Counted | Committee required? |
|---|---|---|---|
| 18 full-time, 6 part-time at 15 hours | 24 | 18 + 6 × 0.5 = 21 | yes |
| 15 full-time, 10 part-time at 20 hours | 25 | 15 + 10 × 0.5 = 20 | no |
| 12 full-time, 12 part-time at 25 hours | 24 | 12 + 12 × 0.75 = 21 | yes |
| 20 full-time, 1 part-time at 32 hours | 21 | 20 + 1 = 21 | yes |
The duties quick-check shows which duties apply at your headcount.
Who takes part
The composition is set by law:
- The employer or a person they appoint. It matters that this person can take decisions, otherwise every measure gets deferred.
- Two members of the works council, where one exists.
- The occupational physician, see The occupational physician in the office.
- The occupational safety specialist, see Does an office need an occupational safety specialist?.
- The safety officers.
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.
What applies to the meetings?
The committee meets at least once per calendar quarter under section 11 ASiG, so at least four times a year. What counts is the calendar quarter, not an interval of three months. The law does not require minutes, but they are the only evidence that the committee met and decided anything.
A meeting on 31 March and one on 1 April cover two quarters; two meetings in May and June cover only one. The dates are therefore best set for a full year at once. The committee meeting planner works them out from the date of the last meeting.
How a single ASA meeting runs, with participants, sample agenda, procedure and minutes, is covered in its own article. For the obligation itself three points count:
- The cycle applies permanently, not only in the first year after setting up.
- Every measure needs an owner and a deadline, otherwise it has been discussed but not decided.
- The minutes are filed with the rest of the safety documentation, because the Berufsgenossenschaft can request them.
A template for the occupational safety committee with invitation, sample agenda for office businesses and minutes with a decision log is available (in German) at arbeitsschutzausschuss-vorlage.de.
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.
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 existing 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.
Establishment or company: where the threshold is counted
The threshold of more than 20 employees refers, by the wording of section 11 ASiG, to the business establishment, not to the company. A company with two sites of 15 employees each therefore needs no committee if both sites are separate establishments. If they form one establishment organisationally, all 30 are counted together.
Whether a site is an establishment of its own depends mainly on whether it has its own management with authority over staff and safety matters. A branch office with three workstations run from headquarters is usually not a separate establishment. In case of doubt the occupational safety specialist clarifies this with the Berufsgenossenschaft before the headcount decides the obligation.
What happens if the committee is missing?
The absence of the committee is not in itself subject to a fine. The competent authority can, however, order it to be set up under section 12 ASiG. Anyone who ignores such an enforceable order risks a fine of up to 25,000 euros under section 20 ASiG. During an inspection the missing committee can be recorded as a shortcoming.
In practice something else weighs more: without a committee there is no fixed place where the specialist, the physician and the business bring their findings together. After an accident it is then hard to show that measures were discussed and followed up. How orders and fines connect is set out in Fines in occupational safety.
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.
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.
More in the article How many safety officers does a business need?.
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.
Without an appointed occupational safety specialist the committee cannot be fully staffed. How to engage an external occupational safety specialist is explained on the dedicated page.
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.