If employees of several employers work on a battery storage site, the client appoints a coordinator under § 3 of the German Construction Site Ordinance, already for the planning of execution. This concerns developers, clients and EPC contractors. The EPC contract should state who provides the SiGeKo and who runs permits. SAFETEE provides SiGeKo and HSE management through to handover.
Does building a battery storage system require a SiGeKo under the Construction Site Ordinance?
As a rule, yes. The German Construction Site Ordinance (BaustellV) ties the coordinator not to size but to one condition: if employees of several employers work on site, the client appoints suitable coordinators (§ 3 (1) BaustellV). On a storage site, civil works, crane company, container supplier and electrical installation are almost always separate companies.
Prior notice and a health and safety plan come on top. Prior notice goes to the authority at least two weeks before the site is set up if the work lasts more than 30 working days with more than 20 workers at the same time or exceeds 500 person-days (§ 2 (2) BaustellV). The health and safety plan (SiGe-Plan) is needed before set-up if prior notice is also required or particularly hazardous work under Annex II takes place (§ 2 (3)), such as work less than 5 m from high-voltage lines at the grid connection (Annex II No. 4). More on our page on safety coordination (SiGeKo).
When should HSE join the planning?
With the planning of execution, before the layout, delivery concept and commissioning sequence are fixed. In this phase the SiGeKo already coordinates planning, prepares the health and safety plan and starts the file for later work (§ 3 (2) BaustellV). What is decided now can only be changed on site by re-planning.
The project pipeline is large: according to the Federal Network Agency, the transmission system operators held about 650 connection requests for large-scale batteries totalling 226 GW at the end of 2024; about 2.4 GW were in operation on 15.10.2025 (BNetzA, energy storage topic page). Many projects are therefore in exactly the phase where HSE has the greatest effect. Above all, these can be set early:
- Distances and access between containers, fire water and fire brigade access in the fire safety concept.
- Crane pads with ground bearing capacity and exclusion zones.
- Logistics with delivery windows, routes and laydown.
- Commissioning sequence of battery strings, inverters and grid connection.
Under an EPC model, who provides the SiGeKo, who runs permits and who is responsible for the installation?
The duties under the ordinance lie with the client, who may commission a third party such as the EPC contractor to take them on its own responsibility (§ 4 BaustellV). Appointing coordinators does not release anyone from responsibility (§ 3 (1a)). SiGeKo, work permits and responsibility for the installation until handover therefore belong in the EPC contract by name.
In addition, employers coordinate under § 8 of the Occupational Safety and Health Act (ArbSchG) and, under § 6 DGUV Regulation 1, appoint a person who aligns work with mutual hazards, with authority to give instructions where hazards are particular. These questions are best settled before signing:
| Role | Basis | Question for the EPC contract |
|---|
| SiGeKo | §§ 3, 4 BaustellV | Does the client appoint the coordinator, or does the EPC contractor take on the client's duties as commissioned third party? |
| Alignment of mutual hazards | § 8 ArbSchG, § 6 DGUV Regulation 1 | Who aligns the subcontractors' work, and with what authority to give instructions? |
| Work permits | Project permit procedure (permit to work, LOTOTO) | Who issues permits, who keeps the permit and lock register? |
| Responsibility for the installation | DIN VDE 0105-100 | Who is the nominated person in control until handover, separately for battery field and grid connection? |
| Handover | § 3 (2) No. 3 BaustellV | When do the file, permit and emergency organisation pass to operations? |
More on coordinating subcontractors under contractor management. Please agree contract clauses with your legal advisers; we advise on occupational health and safety.
Which hazards shape the construction sequence?
Four hazards shape the order of work on a storage site: DC voltage from the first battery module, thermal runaway with fire and gases, crane lifts for containers and transformers, and work at the grid connection near high voltage. Each needs a decision before construction starts, and all come together in the health and safety plan.
- DC voltage and arc flash: battery strings supply energy even without the grid. Qualified electricians work on them under DGUV Regulation 3, with the five safety rules and a named person in control of the installation under DIN VDE 0105-100; DGUV Information 203-077 (09/2020) guides the choice of arc flash protective equipment.
- Thermal runaway and fire: a cell in thermal runaway releases flammable and toxic gases and can re-ignite. The vfdb information sheet TWB-02 (February 2025) and the BVES safety guideline (3rd edition, November 2025) describe distances, gas detection, fire water retention and coordination with the fire brigade.
- Heavy loads and cranes: a mobile crane sets containers and transformers; lifting gear, ground, wind limits and exclusion zones are checked before every lift.
- Grid connection: we agree switching authority and work near high voltage with the grid operator in advance.
In practice: a day on a storage site
A typical day during installation and commissioning, not tied to a specific project:
- Morning briefing: align trades, crane lifts and the day's permits.
- Lift permit: check lift plan and wind values, set up the exclusion zone.
- Container delivery: route clear, banksman in place.
- LOTOTO on the DC string: switch off, lock, tag, verify absence of voltage.
- LMRA before energising: a short last minute risk analysis with the team, for example with the SAFETEE LMRA app.
- Inspection and report: walk the cable route, record findings.
What is documented at handover to operations?
Handover includes the file for later work under § 3 (2) No. 3 BaustellV, which the SiGeKo starts during planning. It also covers the formal handover of responsibility for the installation, the permit and switching procedure and the response documents for the fire brigade. This lets operations plan maintenance and fault clearance on a secure basis.
- File: maintenance access, anchor points, hazards from DC voltage and fire.
- Responsibility for the installation: documented handover under DIN VDE 0105-100.
- Permit procedure: LOTOTO, lock management, switching authorities.
- Emergency organisation: fire brigade response documents and alarm routes.
How does SAFETEE support you?
As SiGeKo we coordinate on behalf of the client from planning to the file for later work. In HSE management on project our HSE managers work on site for the client, EPC contractor or subcontractors, with permits, LOTOTO and LMRA. If we hold several roles in one project, we staff them with different people. Hazards, rules and process are on our page HSE for battery storage; for your project, get in touch.
From what size does a storage site need a SiGeKo?
There is no size threshold. What matters is whether employees of several employers work on site; if so, a coordinator must be appointed under § 3 (1) BaustellV. When building a battery storage system this is almost always the case, because civil works, crane, container delivery and electrical installation come from different companies.
When is prior notice required for building a battery storage system?
Prior notice is required if the work lasts more than 30 working days with more than 20 workers at the same time, or if it exceeds 500 person-days (§ 2 (2) BaustellV). It goes to the competent authority at least two weeks before the site is set up and must be displayed visibly on site.
When must the health and safety plan for a storage site be ready?
Before the site is set up. It is mandatory when several employers are active and prior notice is required or particularly hazardous work under Annex II takes place, such as work less than 5 m from high-voltage lines (§ 2 (3) BaustellV). The SiGeKo prepares it during the planning of execution and updates it when things change.
Can the EPC contractor take on the client's duties?
Yes. Under § 4 BaustellV the client may commission a third party, such as the EPC contractor, to take the measures under §§ 2 and 3 on its own responsibility. A clear written arrangement should state who appoints the SiGeKo and who handles prior notice and the health and safety plan. Clarify the contract with your legal advisers.
How does the SiGeKo differ from the coordinator under DGUV Regulation 1?
The SiGeKo is appointed by the client under the Construction Site Ordinance and coordinates planning and execution of the whole project. The person under § 6 DGUV Regulation 1 is appointed by the companies involved to align work with mutual hazards, with authority to give instructions where there are particular hazards. Storage sites often need both roles, clearly separated.
Which guidance applies to fire safety at a battery storage site?
Two documents reflect the current state: the vfdb information sheet TWB-02 of February 2025 on thermal runaway, gases and firefighting tactics, and the BVES safety guideline for large lithium-ion batteries, 3rd edition of November 2025, developed with DGUV, BG ETEM and fire brigade associations, among others.
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