The role of standardisation in regulatory systems

The key purpose of rules, regulations and standards in occupational safety and health is to present the relevant duties and recommendations comprehensibly. It follows that the regulatory system must be structured consistently. One measure of this consistency is the policy paper on the role of standardisation in the safety and health of workers at work.

Parties seeking to keep track of occupational safety and health in its entirety must inevitably deal with relevant legislative acts, secondary legislation, accident prevention regulations, technical rules of the state and the accident insurance institutions (in Germany, those of the DGUV) and standards. Under the right circumstances, employers are quite able to cope with the various documents: not necessarily because they are experts in regulatory matters, but because the documents collectively form a logical structure, and any given issue is addressed only in one place. To ensure that this is the case, the German stakeholders in occupational safety and health have not only agreed on the precise relationship between statutory legislation and the rules and regulations of the German Social Accident Insurance Institutions; they have also agreed on the function of standardisation in this system in Germany, thus creating a further element for a consistent regulatory structure. This agreement, set out for the first time in 2014 in the “Policy paper on the role of standardisation in the health and safety of workers at work”, makes the use of standards in occupational safety and health dependent on whether the standards concerned are specifications for products or stipulations concerning workplace safety and health.

Where standards address products, their use as regulatory instruments in OSH is viewed positively. This is the case not only in Germany, but also at European level, where harmonised standards constitute an important means of achieving a harmonised European single market by laying down requirements for product properties. Since standardisation, whether at national, European or international level, also covers products used in a work context, OSH experts are active on standards committees to make the case for high levels of safety and health. In January 2026, experts delegated by the German Social Accident Insurance alone were contributing their OSH expertise in over 1,200 functions on German standards committees, and in almost 700 further functions at European and international level. Topics addressed include, for example, the product safety of machinery (such as meat processing, textile and forestry machinery) and of personal protective equipment (such as protective gloves, laser protective clothing and PPE against falls from a height). Standardisation benefits greatly from this involvement, as the standard of safety and health for users of these products is increased significantly when OSH expertise is taken into account alongside the interests of other stakeholders. Equally, the German authorities and the German Social Accident Insurance Institutions are able to make use of the expertise found in standards in their own bodies of regulations, and reduce the volume of the latter by referring to the relevant standards.

Safety and health of workers at work: other rules apply

The situation is different with regard to the safety and health of workers at work: in this area, standards are not considered suitable for use as a regulatory instrument. Where hazards at the workplace must be identified and decisions taken on the measures required for protection against them, the relevant legislation is supplemented primarily by secondary legislation, statutory regulations, and in Germany, also by the body of rules and regulations of the German Social Accident Insurance. This ensures an appropriate level of protection, since these regulatory structures provide the German Social Accident Insurance Institutions and the social partners with much greater scope for influence than in the general standardisation system. The reason for this is that during standards development processes, the occupational safety and health experts have to reconcile their interests in prevention with the interests of various other stakeholders. These particularly include manufacturers, but also consumers, retailers, research institutes, the authorities and test institutes.

However, standards addressing topics concerning the safety and health of workers at work do also exist. Standards primarily addressing terminology, definitions and symbols, for example, or describing testing, measurement, analysis and sampling procedures and statistical methods, are beneficial. OSH experts are therefore also active on standards committees addressing such topics as icons, the measurement of inorganic fibrous particles or the sampling of bioaerosols.

The wealth of standards impacting upon the safety and health of workers at work is, however, increasing beyond the standards of the kind referred to above for assurance of comparability or containing terminological provisions. Occupational safety and health representatives are working to counter this trend, particularly where the level of protection described is too low or where relevant provisions already exist elsewhere. For example, EN ISO 8804-1, Requirements for the training of scientific divers, is opposed by the OSH stakeholders in Germany, since the qualifications of scientific divers are already described in DGUV Rule 101-023, which concerns research diving and contains stricter requirements. DIN EN ISO 8804-1 therefore makes reference to the relevant DGUV rule in a national foreword. Another example is DIN EN 16194, a standard for mobile non-sewer-connected toilet cabins: the German national foreword of this standard draws attention to the primacy of a German national rule (ASR A4.1, concerning sanitary areas). However, a national foreword of this kind in a standard is not the ideal solution; content relating to the safety and health of workers at work should preferably be excluded from the standards development process altogether.

The policy paper provides clarity

The policy paper on the role of standardisation in the safety and health of workers at work does not exclude standards entirely from this area, provided development of a particular standard appears beneficial. The stakeholders in occupational safety and health discuss such cases and reach agreements on them in the Commission for Occupational Health and Safety and Standardization (KAN). Agreements are based on key criteria. Firstly, these criteria identify overlap with and duplication of state legislation or the body of rules and regulations of the German Social Accident Insurance Institutions; secondly, they examine whether the planned standard is beneficial for use in the field, and whether the development process is able to ensure the standard’s quality. KAN may decide to reject the work item of the standard, or to approve it, either in full or conditionally.