An occupational health physician is a medically trained specialist who advises companies on the prevention of workplace accidents, health promotion, and the protection of employees. Appointment is required by law — under Germany's Occupational Safety Act (ASiG), it applies to all companies regardless of size. The scope and required service hours are determined by the company's hazard category under DGUV Regulation 2.
Definition: What Is an Occupational Health Physician?
An occupational health physician (German: Betriebsarzt) is a specialist physician with the recognised qualification in "occupational medicine" (Arbeitsmedizin) or the additional designation "occupational health medicine" (Betriebsmedizin). Their primary role is not the treatment of illness but its prevention: occupational health physicians advise both employers and employees on work-related health risks, ergonomic working conditions, and measures to promote workplace health.
Section 2 of Germany's Occupational Safety Act (ASiG) defines occupational health physicians as qualified professionals whom employers are required to appoint to carry out specific tasks in the areas of occupational health and accident prevention.
Occupational Health Physician vs. Works Physician: What Is the Difference?
The two terms are frequently used interchangeably. "Works physician" (Werksarzt) is, however, a historical term that was previously used mainly for salaried physicians employed directly within large industrial companies. "Occupational health physician" (Betriebsarzt) is the legally defined term under the ASiG. Today, occupational health duties are often fulfilled by inter-company occupational health services — that is, external specialists who cover multiple organisations.
What Qualifications Does an Occupational Health Physician Need?
A person may only be appointed as an occupational health physician if they hold one of the following qualifications:
- Specialist recognition in "Occupational Medicine" (Arbeitsmedizin) or
- Additional designation "Occupational Health Medicine" (Betriebsmedizin)
A general practitioner without these qualifications may not be appointed as an occupational health physician — even if their practice is located close to the company premises.
Legal Framework: ASiG and DGUV Regulation 2
Occupational health care in Germany is governed by two central pieces of regulation:
Occupational Safety Act (ASiG): The Act on Occupational Physicians, Safety Engineers and Other Occupational Safety Specialists obliges all employers in Germany to appoint occupational health physicians. Section 2 ASiG defines the duties; Section 5 ASiG makes clear that all costs associated with the appointment are borne by the employer.
DGUV Regulation 2: This regulation of the German Social Accident Insurance (Deutsche Gesetzliche Unfallversicherung) specifies the requirements of the ASiG in practical terms: it sets out how many service hours the occupational health physician and safety specialist must provide per year per employee. Companies are classified into hazard categories ranging from 1 to 4.
When Is an Occupational Health Physician Required?
The short answer: always. Under the ASiG, all employers in Germany are obliged to appoint an occupational health physician — there is no minimum employee threshold. What varies depending on company size and sector is the required scope of care.
Does the Obligation Apply to Small Companies Too?
Yes — but for small businesses with up to 10 employees and a low hazard potential, DGUV Regulation 2 provides for simplified care models. This so-called "alternative needs-based care" allows employers to first attend information events run by the relevant trade association (Berufsgenossenschaft) before engaging an occupational health physician directly.
Service Hours by Hazard Category (DGUV Regulation 2)
DGUV Regulation 2 divides companies into four hazard categories. The higher the occupational risk, the more service hours are required:
Note: The exact classification is determined by the relevant trade association. The table shows guideline values — deviations are possible depending on individual circumstances.
Duties of an Occupational Health Physician
The scope of duties for occupational health physicians is set out in Section 3 ASiG and encompasses far more than routine health checks.
Preventive Duties and Advisory Services
- Workplace inspections: Regular visits to work sites to identify hazards
- Risk assessments: Participation in the assessment of work-related health risks
- Occupational health surveillance: Mandatory, recommended, and voluntary health checks (e.g. for screen work, noise exposure, shift work)
- Ergonomics consulting: Recommendations on workplace design and equipment
- First aid: Advice on the organisation of workplace first aid
- Workplace reintegration: Support for the gradual return to work after extended illness (occupational reintegration management, BEM)
What an Occupational Health Physician Is Not Permitted to Do
Occupational health physicians are bound by medical confidentiality — including towards the employer. In practice, this means:
- No disclosure of diagnoses without the explicit consent of the person concerned
- No assessment of fitness for work in the sense of issuing sick notes — this remains the responsibility of the treating physician
- No disclosure of examination findings from health surveillance to the employer
The occupational health physician communicates only the outcome of the health surveillance to the company: "fit", "conditionally fit", or "unfit" — without medical explanation or reasoning.
Appointing an Occupational Health Physician: Step by Step
Employed vs. Inter-Company: What Suits Your Organisation?
For most small and medium-sized enterprises, inter-company occupational health care is the practical solution:
- Employed occupational health physician: Appropriate from approximately 400–500 employees with high hazard potential. High fixed costs, but full on-site availability.
- Inter-company occupational health physician: An external specialist who covers multiple companies. Flexible, more cost-effective, and the standard approach for SMEs.
Steps for appointment:
- Determine the company's hazard category (contact the relevant trade association)
- Calculate the required service hours (number of employees × hours per category)
- Enquire with an occupational health service or freelance occupational physician
- Issue and document the formal letter of appointment
- Establish and record the annual service schedule
Cost Overview
Costs for occupational health care vary depending on sector, region, and care model. As a general guide:
- Inter-company care: approx. €50–150 per employee per year
- Individual health surveillance examinations: approx. €80–200 per examination
- All costs are borne by the employer under Section 5 ASiG — they may not be passed on to employees
Medical Confidentiality and Data Protection
Medical confidentiality under Section 203 of the German Criminal Code (StGB) applies without restriction to occupational health physicians as well. The following principles are relevant for HR professionals:
- All medical data from health surveillance examinations is stored by the occupational health physician separately from the employer's records.
- The employer receives only the occupational health assessment (fit / conditionally fit / unfit), never the underlying diagnosis.
- Employees may request access to their occupational health records at any time.
- The GDPR applies to the processing of personal health data — including by external occupational health physicians.
Frequently Asked Questions about Occupational Health Physicians
When Is an Occupational Health Physician Required?
In principle, all employers in Germany are obliged under Section 2 ASiG to appoint an occupational health physician — regardless of company size. The specific scope of care is determined by the hazard category under DGUV Regulation 2. Simplified care models exist for very small businesses.
What Does an Occupational Health Physician Cost?
For inter-company care (the standard model for SMEs), costs typically range from €50–150 per employee per year. Individual health surveillance examinations cost between €80–200 depending on the type and provider. Under Section 5 ASiG, all costs are borne exclusively by the employer.
Can the Occupational Health Physician Share Information with the Employer?
The occupational health physician is bound by medical confidentiality. Without the explicit consent of the person concerned, no diagnoses or examination findings may be shared with the employer. Only the occupational health assessment regarding suitability for the relevant role is communicated.
How Many Hours Must an Occupational Health Physician Be on Site?
The minimum service time is derived from DGUV Regulation 2 (Annex 2) and the company's hazard category. For office workplaces (Category 1), this amounts to 0.5 hours per employee per year; for high-risk sectors such as construction or chemicals (Category 4), up to 2.5 hours.
What Is the Difference between an Occupational Health Physician and a Works Physician?
"Works physician" is a historical term for salaried physicians employed within large companies. "Occupational health physician" is the legally defined term under the ASiG and includes external, inter-company occupational health specialists. In practice, both terms are used interchangeably today.
Can I Appoint My General Practitioner as Occupational Health Physician?
Only if the GP holds the specialist recognition in "Occupational Medicine" or the additional designation "Occupational Health Medicine". A general medical licence alone is not sufficient — such an appointment would be legally invalid.
What Happens If I Do Not Appoint an Occupational Health Physician?
Failure to appoint constitutes an administrative offence under Section 20 ASiG and may result in a fine of up to €25,000. In addition, significant liability risks arise in the event of workplace accidents or occupational diseases. Compliance is monitored by the trade supervisory authority (Gewerbeaufsicht) and the relevant trade association (Berufsgenossenschaft).
Who Is Responsible for Appointing the Occupational Health Physician?
The obligation lies with the employer. In practice, HR departments typically manage the process: they determine the hazard category, calculate the required service hours, and commission a suitable occupational health service. The formal letter of appointment must be issued in writing.
Summary
An occupational health physician is not an optional addition to workplace safety — it is a legal obligation for all companies in Germany. Appointment protects employees from work-related illness, reduces sickness-related absences, and provides legal protection for HR professionals and managing directors. For SMEs, inter-company occupational health care is the pragmatic standard solution, with manageable costs and a clear legal basis in the ASiG and DGUV Regulation 2.
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Sources
- Act on Occupational Physicians, Safety Engineers and Other Occupational Safety Specialists (ASiG). Federal Ministry of Labour and Social Affairs, 2024. https://www.gesetze-im-internet.de/asig/
- DGUV Regulation 2: Occupational Physicians and Occupational Safety Specialists. Deutsche Gesetzliche Unfallversicherung (DGUV), 2011.
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