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Machinery risk assessment in Germany: procedure under the BetrSichV

Before a machine goes into operation, the employer must assess its hazards – from installation and set-up to cleaning and maintenance. How to proceed under the German Ordinance on Industrial Safety and Health and TRBS 1111, including for older machines.

Last updated on 7 min readAMS Go editorial team

Key points at a glance

  • Before a machine is used, the employer must assess the hazards and document the result before first use; CE marking does not release the employer from this duty (Section 3(1) and (8) BetrSichV).
  • All phases of use must be assessed – from assembly, operation, set-up and cleaning to maintenance – as well as hazards from the work environment and the workpieces processed (Section 2(2), Section 3(2) BetrSichV).
  • In the risk assessment, the employer defines the type, scope and intervals of inspections; only persons qualified to carry out inspections may inspect, and the result must be kept at least until the next inspection (Section 3(6), Section 14 BetrSichV).
  • Employees must be instructed on the basis of the risk assessment before first use and at least once a year thereafter; the date and names of those instructed must be recorded in writing (Section 12(1) BetrSichV).

What is a machinery risk assessment?

A machinery risk assessment (Gefährdungsbeurteilung für Maschinen) is the assessment of all hazards that arise when a machine is used in your own company, together with the protective measures derived from it. The legal basis is Section 3 of the Ordinance on Industrial Safety and Health (Betriebssicherheitsverordnung, BetrSichV); the procedure is specified in the technical rule TRBS 1111 “Risk assessment”. The assessment must be completed and documented before first use.

It is part of the risk assessment under Section 5 of the Occupational Safety and Health Act (ArbSchG) and should start before the machine is selected and purchased (Section 3(3) BetrSichV). Only competent persons may carry it out; if the employer lacks the knowledge, they must obtain competent advice, for example from the occupational safety specialist (Fachkraft für Arbeitssicherheit).

Machinery risk assessment in 7 steps

  1. 1

    Describe the machine and its use

    Record name, manufacturer, type, year of construction and location, plus the tasks, operating modes and the people who work on the machine.

  2. 2

    Gather information

    Evaluate the operating manual, declaration of conformity, technical rules, DGUV information and findings from accidents and malfunctions. You may assume manufacturer information is correct unless you have other findings (Section 3(4)).

  3. 3

    Identify hazards

    Go through each life cycle phase of the machine using the hazard factors – ideally on site and together with the operators.

  4. 4

    Evaluate hazards

    The benchmark is the state of the art under the BetrSichV and TRBS; where they are silent, DGUV rules and industry standards help (TRBS 1111 no. 5.4).

  5. 5

    Define protective measures

    Technical measures before organisational ones, and these before personal ones (Section 4(2)) – with owners and deadlines.

  6. 6

    Check effectiveness

    Before first use, check whether the measures work and do not create new hazards (Section 4(5)).

  7. 7

    Document and keep up to date

    Record the result, inspection intervals and review date, and update immediately after changes.

Where working conditions are similar, assessing one workplace or activity is sufficient (Section 5(2) ArbSchG). You can therefore assess several identical machines under the same conditions together.

Risk assessments in AMS GoCreate risk assessments by work area and activity, use AI suggestions for hazards, record the current state at the machine with photos and transfer actions with deadlines straight to the action plan.

Identifying hazards by life cycle phase

Many accidents do not happen in normal operation but during set-up, troubleshooting or maintenance. The ordinance therefore counts all activities as use – from assembly, operation and adjustment to maintenance, cleaning and conversion through to dismantling and transport (Section 2(2) BetrSichV).

  • Transport, installation, assembly

    Typical hazardsTipping over, falling parts, incorrect connections

    Typical measuresLifting points as per manual, anchoring, inspection after assembly

  • Commissioning, trial run

    Typical hazardsUnexpected movements, control system malfunction

    Typical measuresDefine danger zone, trial runs by competent persons only

  • Normal operation

    Typical hazardsEntanglement, drawing-in, crushing, ejected parts, noise

    Typical measuresInterlocked guards, extraction, hearing protection

  • Set-up, adjustment

    Typical hazardsWorking with guards open

    Typical measuresSpecial operating mode, jog mode, appointed employees only

  • Troubleshooting, cleaning

    Typical hazardsReaching into a running or starting machine

    Typical measuresStop, secure against restart, auxiliary tools

  • Maintenance

    Typical hazardsStored energy, electric shock, hot parts

    Typical measuresIsolation using lockout-tagout, dissipate residual energy, work permit

  • Dismantling, disposal

    Typical hazardsResidual energy, leaking operating fluids

    Typical measuresMake energy-free, drain and dispose of operating fluids

For each phase, check the ten hazard factors of TRBS 1111: mechanical hazards, falls of persons, loads or materials, electrical hazards, steam and pressure, fire and explosion, thermal hazards, special physical agents such as noise, the work environment, and physical and mental workload. Hazardous substances such as metalworking fluids are additionally assessed under the Hazardous Substances Ordinance (GefStoffV).

Manufacturer information, CE marking and older machines

The most important source is the operating manual with intended use, residual risks and maintenance requirements. You may adopt a risk assessment supplied by the manufacturer insofar as it matches the machine, working conditions and processes in your company (Section 3(5)). New machines placed on the market from 20 January 2027 must comply with the EU Machinery Regulation 2023/1230; this does not change your duties under the BetrSichV.

  • Older machines must comply with the rules that applied when they were made available on the market (Section 5(3)) and must be safe to use according to the state of the art (Section 4(1)).
  • The state of the art must be taken into account when the risk assessment is reviewed regularly – missing protective devices may require retrofitting (Section 3(7)).
  • If the operating manual is missing, request it from the manufacturer or dealer or determine the necessary information yourself, for example with the support of an expert.
  • Assess modifications as to whether they require inspection and whether manufacturer obligations arise (Section 10(5)).

Defining inspection intervals, checks and maintenance

Set the intervals for periodic inspections so that the machine can be used safely until the next inspection (Section 3(6)). They are based on manufacturer information, operating conditions and experience from previous inspections.

  • Check for obvious defects

    WhenBefore each use

    WhoUsually the operators (Section 4(5))

  • Function check of protective and safety devices

    WhenRegularly, interval from the risk assessment

    WhoDesignated, instructed employees (Section 4(5))

  • Inspection of machines whose safety depends on assembly

    WhenBefore first use and after each assembly

    WhoPerson qualified to carry out inspections (Section 14(1))

  • Periodic inspection where damaging influences apply

    WhenAt the defined interval

    WhoPerson qualified to carry out inspections (Section 14(2))

  • Inspection after a modification requiring inspection, an accident or a long period out of use

    WhenBefore next use

    WhoPerson qualified to carry out inspections (Section 14(3))

Maintenance must be carried out on the basis of a risk assessment and the operating manual, only by competent, appointed and instructed persons (Section 10(2)). This includes defined responsibilities, safe isolation of energy sources and permit systems for certain work (Section 10(3)).

Instruction, operating instructions and documentation

The risk assessment is the basis for operating instructions and instruction: before first use, written operating instructions (Betriebsanweisung) in an understandable form and language are required (Section 12(2)). Task-related instruction is given before work starts and at least once a year thereafter (Section 12(1)). Machines with particular hazards may only be used by appointed employees (Section 12(3)). The documentation contains at least (Section 3(8)):

  • the hazards that arise when using the machine
  • the protective measures to be taken
  • how the requirements are met where technical rules are not followed
  • type and scope of inspections and the intervals for periodic inspections
  • the result of the effectiveness check

If a regular review shows that nothing needs to change, record this with the date in the documentation (Section 3(7)). Electronic documentation is permitted.

Checklist: machinery risk assessment

  • Machine recorded with master data, location, tasks and operating modes
  • Operating manual and declaration of conformity available, state of the art assessed for older machines
  • All life cycle phases from installation to dismantling considered
  • Hazard factors including noise, hazardous substances and workload checked
  • Protective measures defined in order of priority with owners and deadlines
  • Effectiveness checked before first use
  • Type of inspection, intervals and qualified person defined
  • Operating instructions drawn up, employees instructed, instruction recorded
  • Date for the next review set

Free templates for this guide

As PDF and Excel, free – to use in your own company.

Frequently asked questions

Does every machine need its own risk assessment?

Every machine must be assessed before it is used (Section 3(1) BetrSichV). Where working conditions are similar, however, assessing one workplace or activity is sufficient (Section 5(2) ArbSchG) – you can assess identical machines under the same conditions together, provided the documentation shows which machines are covered.

Is CE marking sufficient proof of safety?

No. The presence of CE marking expressly does not release the employer from the risk assessment (Section 3(1) BetrSichV). It is an important indicator, though: with CE marking, a declaration of conformity and an operating manual, you can generally adopt the manufacturer's information.

How often does a machinery risk assessment have to be reviewed?

Regularly – the employer sets the interval. It must be updated without delay after safety-relevant changes, after accidents, when new findings emerge or if protective measures are not effective (Section 3(7) BetrSichV). Many companies review it annually, often together with the instruction.

Who may carry out a machinery risk assessment?

Only competent persons (Section 3(3) BetrSichV). Competence requires vocational training, professional experience or recent relevant work (Section 2(5)). In practice, supervisors or the maintenance manager prepare the assessment together with the operators; the occupational safety specialist advises.

Terms from the glossary

This guide gives a general overview of German occupational safety law and does not replace legal advice. The regulations in force and the rules of the statutory accident insurance institutions are authoritative.

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