Matthias Surovcik
Your company has secured an important project in Germany. The engineering package is mature, the contract is signed, and mobilisation is approaching. From a commercial perspective, the project is ready to move. Yet one question remains: can the organisation demonstrate who is responsible for the electrical work, how that work will be controlled, and which evidence supports the decisions made on site?
A technically complete design does not answer this question. Neither does an accepted Electrical Safety Plan. German occupational safety requirements address the way work is organised as well as the condition of the equipment. If responsibilities, competence, procedures and records do not fit the actual project, an apparently minor gap can delay access, testing, energisation or handover.
Start with the Legal Entity, Employer and Electrical Scope
The first step is to identify the company that employs the people performing the work. International projects often use terms such as main contractor, package owner or commissioning partner. These descriptions are commercially useful, but they do not by themselves determine every legal and operational duty.
Each employer must organise the safety of its own employees and activities. The client may define project rules and coordinate shared hazards. A principal contractor may control access and common procedures. Neither arrangement automatically removes the duties that remain within each contractor organisation.
The electrical scope must then be made explicit. It should identify the installations, locations, voltage levels, activities and project phases involved. Installation, inspection, functional testing, energisation, fault finding and operation create different decisions and risks. A scope that merely states “electrical works” is rarely precise enough to assign responsibility.
The same clarity is needed at organisational boundaries. Who controls temporary supplies? When does a completed system move from construction to commissioning? Which company controls the installation while another company performs work on it? These questions are more useful than relying on job titles that may mean different things in different organisations.
Define Responsibility, Authority and Escalation
Once the scope is clear, the project needs people who can make the required decisions. Responsibility without authority is not a workable arrangement. A person expected to stop unsafe work, reject unsuitable personnel or withhold energisation must have the mandate, information and access needed to do so.
Management retains the duty to establish an appropriate organisation. Technical and organisational tasks can be assigned to suitably competent people, but the assignment must be clear and achievable. Depending on the company, the work and the available internal competence, a VEFK / CRES structure may form part of this organisation. It should not be treated as an automatic requirement based only on nationality, contract value or workforce size.
The practical test is simple. Can the organisation identify who decides, who approves, who verifies and who receives an escalation? The answer must cover normal work and exceptional situations. It must also connect management, electrical functions, HSE, commissioning and operations. If two departments each believe that the other holds the final authority, the project has not allocated responsibility.
Match Qualification and Work Controls to the Actual Tasks
Qualification must be assessed against the work that a person will actually perform. A degree, trade certificate or company authorisation is relevant evidence, but it does not prove competence for every installation, voltage level or procedure. The employer must consider training, knowledge, experience, familiarity with the relevant requirements, and the ability to recognise the hazards of the assigned task.
Instruction, appointment, supervision and authorisation are related, but they are not interchangeable. A person may have strong technical knowledge and still require project instruction, system familiarisation or a specific authorisation. Language also matters. Safety instructions, switching communication and emergency actions must be understood in practice, not merely available in a document.
Work controls should follow the real sequence of the project. Preparation, release, isolation, verification, supervision, testing, restoration and changes of operating state require defined interfaces. VDE 0105-100 together with VDE 1000-10 provides an important technical framework for operating and working on, with or near electrical installations. It supports the organisation of safe work, but the project must still translate this framework into its own responsibilities and procedures. Strongly recommended is the Maintenance of professional competence of all electricians and electrical engineers.
Establish the Evidence Required for Mobilisation and Release
An organisation becomes credible when its decisions can be demonstrated. Before work begins, the project should know which records are required and who maintains them. Typical evidence includes risk assessments, qualification records, instructions, appointments, authorisations, work procedures, inspection results and release documents.
This does not mean creating paperwork for its own sake. Each record should support a real decision. A qualification matrix should show which tasks a person may perform. An appointment should define scope and authority. A release should confirm that stated conditions have been checked. A gap record should name the issue, its consequence, the responsible owner, the required action and the acceptance criterion.
The result is a project that can mobilise with fewer surprises. Management can see where responsibility sits. Site teams understand the controls they must apply. Decisions about testing, energisation and handover have a traceable basis.
Electrical compliance is not created by just one certificate or one approved plan. It is created by an organisation that can make competent decisions and demonstrate how those decisions are implemented. A structured Electrical Compliance review provides the next level of detail for establishing that structure. It remains a continuous improving process.
Frequently Asked Questions
What must a foreign company establish before electrical work begins in Germany?
A foreign company must establish which legal entity employs the personnel, which electrical tasks they will perform, and who holds the authority to control those tasks. The organisation also needs suitable risk assessments, task based qualification decisions, instructions, authorisations and work procedures. The exact arrangement depends on the project scope and the employers involved. A certificate, contract clause or accepted safety plan cannot replace a functioning responsibility structure.
Does every foreign company need a VEFK / CRES in Germany?
No. German law does not impose a universal VEFK / CRES appointment simply because a company is foreign or performs electrical work in Germany. The employer must create an effective organisation and assign electrical duties only to people who are competent and have the necessary authority. A VEFK / CRES can be an appropriate part of that structure when management cannot provide the required electrical direction internally, but the need and scope must be assessed for the actual organisation and work.
Is an approved Electrical Safety Plan enough to start work?
No. An Electrical Safety Plan describes intended controls, but work can begin safely only when those controls exist in practice. Named responsibilities must be accepted, personnel must be assessed for their tasks, procedures must match the installation, and required inspections or releases must be available. Client acceptance of the plan does not transfer the employer duties of each contractor. The plan is valuable when it reflects the real organisation and remains current as the project changes.
Which documents are normally needed before mobilisation?
The required evidence depends on the work, but it commonly includes the electrical scope, risk assessments, responsibility and interface matrices, qualification records, instructions, appointments, authorisations, inspection evidence and release procedures. The project should also define how deviations and escalations are recorded. The purpose is not to create a large archive. Each document should support a specific decision about who may perform a task, under which conditions, and on whose authority.
Who remains responsible when an EPC contractor controls the project site?
Each employer remains responsible for the safety of its own employees and activities. An EPC contractor can coordinate interfaces, define site rules and control common access, but this does not automatically absorb every duty held by subcontractors or other employers. The project therefore needs clear boundaries between employer responsibility, installation control, work control and project coordination. These boundaries should be understood before work begins, especially where temporary power, testing or energisation affects several companies.
Discuss Your Project
Describe the planned electrical scope, responsible organisations and conditions required before work begins. Discuss your project with TCS.
