A new German site can be fully staffed, insured and ready to trade, yet still be missing a required appointment: the company doctor (Betriebsarzt). Company doctor obligations are not a wellness perk or something to arrange only after an employee becomes ill. They form part of an employer’s statutory occupational health and safety system and need to fit the real risks of your work.
For an office team, the work may focus on screen work, ergonomic advice and preventive care. For a warehouse, retailer, laboratory or logistics operation, it may also cover shift work, noise, hazardous substances, manual handling and workplace accidents. The right level of support depends on your workforce, activities and accident insurance institution, not simply on company size.
What company doctor obligations mean in Germany
Under the Occupational Safety and Health Act (Arbeitsschutzgesetz, ArbSchG), employers must identify workplace hazards, take suitable protective measures and review whether those measures work. The Occupational Safety Act (Arbeitssicherheitsgesetz, ASiG) requires employers to appoint a company doctor and an occupational safety specialist (Fachkraft für Arbeitssicherheit, or SiFa) where the rules apply.
The company doctor is an independent medical adviser in occupational health. Their job is not to replace an employee’s GP or manage general sickness absence. They help you prevent work-related ill health by considering how work, equipment, working time, substances and workplace conditions affect people.
Your accident insurance institution (Berufsgenossenschaft, or BG) usually applies the requirements of DGUV V2. This sets out how occupational medical and safety support is organised, including basic support and occasion-related support. The required input varies according to your sector, risk group, headcount and operational changes.
A small, low-risk office should not assume it has no duties. Equally, a growing warehouse should not rely on a generic annual visit. The support has to be proportionate to the risks identified in your risk assessment (Gefährdungsbeurteilung).
The employer’s core responsibilities
You remain responsible for workplace safety even when you appoint external experts. A company doctor brings specialist medical judgement, but you must make the appointment, provide access to relevant workplace information and act on justified recommendations.
In practice, your responsibilities include appointing a suitably qualified company doctor, agreeing a scope of support that meets the applicable DGUV V2 requirements, and involving the doctor early when conditions change. Opening a new site, introducing night shifts, using new cleaning chemicals or recording repeated musculoskeletal complaints are all reasons to review what occupational health input is needed.
You must also ensure that the company doctor can inspect relevant work areas and speak with employees where necessary. A desk-only review will rarely be enough for a business with operational risks on the floor, in a stockroom or on the road.
Preventive medical care is a separate duty
The Ordinance on Occupational Medical Precautions (ArbMedVV) distinguishes between mandatory preventive care, offered preventive care and preventive care requested by employees. The category depends on the exposure and activity, rather than an employer’s preference.
Mandatory preventive care must be arranged before employees carry out certain work that creates defined health risks. Offered preventive care must be made available for other relevant exposures. Employees may also request preventive care in certain circumstances where they believe their work is affecting their health.
Examples may include work involving particular hazardous substances, significant noise exposure, night work or activities requiring respiratory protective equipment. The precise trigger needs to be assessed against the work actually performed and the applicable rules. This is why an up-to-date risk assessment and competent occupational medical advice belong together.
Preventive care is not a general fitness test. It is intended to identify and prevent health effects from work. Where a role genuinely requires evidence of medical suitability, that question must be handled carefully and separately, with a clear legal and operational basis.
Confidentiality is not optional
Medical confidentiality is central to the company doctor’s role. You should receive the information needed to manage safety, such as whether preventive care has taken place or whether workplace measures should be considered. You do not receive diagnoses, examination results or personal medical history.
This boundary protects employees and helps the doctor provide candid advice. It also means managers should not ask the company doctor to explain an individual’s medical condition or use occupational health as a shortcut for absence management.
Keep your own records of appointments, risk assessments, preventive care arrangements and actions taken. The company doctor maintains medical documentation separately. Clear records demonstrate that occupational health has been organised and that recommendations have been considered, without compromising personal data.
How the company doctor supports safer decisions
The company doctor should be part of your prevention process, not a name on a service agreement. Their advice can inform workplace design, ergonomic measures, personal protective equipment, working-time arrangements and the health aspects of emergency planning.
For example, if warehouse pickers report recurring shoulder pain, the answer may not be an individual medical intervention. The company doctor and safety specialist may identify a need to review lifting heights, load weights, task rotation, training or break arrangements. The employer then decides and implements appropriate controls.
Where you employ more than 20 people, you will generally need a safety committee meeting (Arbeitsschutzausschuss, or ASA) at least quarterly. The company doctor is normally a required participant, alongside the employer or representative, safety specialist, works council representatives where present, and other defined participants. These meetings should address real incidents, hazards and outstanding actions, rather than exist only as meeting minutes.
Company doctor obligations during change and after incidents
Occupational health duties become particularly visible when a business changes quickly. International employers often appoint a company doctor when a BG letter arrives, but the better time is before opening, expansion or a new work process creates an avoidable gap.
Review your arrangements when you move premises, increase headcount, introduce shift patterns, start using hazardous substances, purchase new equipment, or change the layout of a warehouse. The company doctor can help assess health implications while the safety specialist focuses on technical and organisational controls.
After a reportable workplace accident, occupational medical input may also be relevant. The immediate priority is emergency response, reporting and investigation. But a proper corrective plan should examine whether health risks, fatigue, task design, training or protective measures contributed to the event. A narrow focus on employee behaviour can miss the conditions that allowed the accident to happen.
A practical three-step route to compliance
1. Establish your actual risk profile
Start with an on-site review of work activities, premises, workforce structure and existing documents. Check whether your risk assessment reflects current operations and identify exposures that may trigger occupational medical precautions. This step is especially valuable if your German entity has grown faster than its safety documentation.
2. Appoint and integrate the right support
Arrange a qualified company doctor and occupational safety specialist with a scope based on the relevant DGUV V2 framework. Give them access to the workplace and the information they need. Make clear who internally owns actions, because expert advice only improves safety when someone follows through.
3. Document, act and review
Record appointments, assessments, preventive care arrangements, committee meetings and corrective actions. Review the plan after operational changes, incidents and employee feedback. Regular review is less disruptive than trying to reconstruct evidence after an inspection or deficiency notice.
Captain Safety can coordinate occupational medical support alongside safety specialist input, risk assessments, training and corrective work, so that separate legal duties become one manageable programme. If you are unsure whether your current arrangement reflects your German operation, request a quote for an initial review.
The most useful question is not whether you have a company doctor on paper. It is whether occupational health advice is reaching the people, tasks and risks that need it before someone is harmed.