Who must prepare an HV risk assessment?

The employer is legally responsible for the risk assessment under §5 ArbSchG. In practice, it is typically prepared by the vEFK (Responsible Electrical Expert) or an FHV specialist in cooperation with the health and safety officer. The employer must review and approve it.

How often must the HV risk assessment be updated?

The risk assessment must be reviewed and updated whenever working conditions change – for example when new vehicle types are introduced, new tools or procedures are adopted, or after an accident or near-miss. A general review at least annually is recommended.

Is an HV risk assessment required for every single job?

Not necessarily for every individual job. A risk assessment can cover a category of work (e.g. HV de-energisation on series vehicles). However, it must be specific to the vehicle types and tasks performed. A general risk assessment covering all HV work in a workshop is acceptable if it covers all relevant hazards.

HV Risk Assessment – Legal Requirements under DGUV 209-093

Mandatory Content of an HV Risk Assessment

DGUV 209-093 and the underlying legal framework (ArbSchG, BetrSichV) define the minimum content. A complete HV risk assessment must cover:

Description of the work activity and vehicle types involved
Identification of all HV hazards (electric shock, arc flash, stored energy in capacitors)
Assessment of hazard severity and probability
Required qualification level for the activity (Level 1S to 3E)
Required PPE (insulating gloves, CAT III multimeter, VDE tools)
Applicable work procedures and manufacturer-specific instructions
Emergency and rescue procedures
Date, author's name and employer signature

Who Prepares the Risk Assessment?

The employer is legally responsible under §5 ArbSchG. In practice, the risk assessment is usually prepared by:

The vEFK (Responsible Electrical Expert) for the site
An FHV specialist with appropriate knowledge of the specific vehicles and activities
In cooperation with the company health and safety officer (Fachkraft für Arbeitssicherheit)

The employer must review and formally approve the document. An uninstructed employee or unqualified contractor may not prepare or approve an HV risk assessment.

When Must the Risk Assessment Be Updated?

When new vehicle types or HV systems are introduced
When work procedures or tools change
After an accident, near-miss or change in the legal framework
When personnel qualifications change (new staff, lapses in qualification)
At minimum: review annually and confirm it remains current

What are the consequences of missing or inadequate risk assessments?

Under §25 ArbSchG, failure to carry out a risk assessment is an administrative offence and can result in fines of up to €25,000. In the event of an accident, missing or inadequate documentation is treated as a breach of the employer's duty of care, which may affect liability under both civil and criminal law. Labour inspectorates (Arbeitsschutzbehörden) can also issue stop-work orders.

Does a risk assessment need to be written down?

Yes. Under §6 ArbSchG, employers with five or more employees must document the risk assessment in writing. In practice, documentation is advisable for all employers regardless of size, as it is the only way to demonstrate compliance in the event of an inspection or accident investigation.

HV Training Supports Compliant Risk Assessment

Properly qualified FHV personnel can prepare, approve and implement HV risk assessments. Nationwide in-house training.

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HV Risk Assessment

Mandatory Content of an HV Risk Assessment

Who Prepares the Risk Assessment?

When Must the Risk Assessment Be Updated?

Related Terms

HV Training Supports Compliant Risk Assessment