Role and future of Operations officers

Company representatives between reducing bureaucracy and ensuring compliance

1. classification: Operations officers are omnipresent in industrial facility management - from waste management officers to immission control and water protection officers to fire protection and safety officers. These specialists are required by law in certain companies or facilities and help to implement complex legal regulations in day-to-day operations. Their role cannot be overestimated: They provide _company self-inspection_ as a counterpart to government supervision. In sensitive industrial sectors in particular (chemicals, energy, logistics, etc.), they replace the permanent government inspector with internal expertise - a concept that has been tried and tested for decades and has become part of German regulatory law.

2. political pressure for reform: In view of increasing complaints about bureaucratic burdens, politicians have set their sights on the company representatives. In 2025, proposals were made in government documents and even opposition papers to partially abolish the statutory obligation to appoint a representative. For example, an immediate economic policy program aimed to abolish numerous officer positions (including immission control, waste and water protection officers and others) by the end of 2025. The argument: fewer formal requirements and reporting obligations should reduce the burden on companies. In fact, over the years, more and more areas have been added in which companies have to appoint specialist officers - in the view of some associations, a proliferation that causes costs and ties up staff.

3. critical view: Despite all the sympathy for reducing bureaucracy, compliance experts warn against throwing the baby out with the bathwater. The decisive factor is that the obligations do not disappear if the agents are abolished. The relevant laws - from the Federal Immission Control Act to the Federal Water Act, from the Industrial Emissions Directive to occupational health and safety regulations - remain in force. Companies would therefore still have to limit emissions, dispose of waste correctly, protect bodies of water, ensure occupational safety, etc. Someone in the company has to carry out these tasks. If an official representative is no longer appointed, the work is either spread across other shoulders or, in the worst case, it is left undone. Both scenarios harbor risks: either there is a lack of clear responsibility (if _everyone_ does a bit, no one feels fully responsible in the end), or dangerous gaps arise because complex requirements are not implemented due to a lack of expertise.

Compliance experts such as Dr. Manfred Rack also emphasize the _preventive effect_ of the officers: these internal specialists often identify problems before any damage occurs or an authority has to intervene. They advise management and employees, train staff in their area of expertise and continuously monitor compliance with regulations. Without such functional roles, the likelihood of breaches going unnoticed until it is too late increases - be it environmental damage, an accident at work or a fire incident. The result would be not less, but _more_ external intervention: authorities would have to carry out more checks, which in turn would increase bureaucracy and costs on the state side too. In short, abolishing company representatives would be a symbolic policy that misses the target - real relief - and instead weakens the company's protective mechanisms.

4. practice in industrial FM: In the operational reality of industrial sites, the statutory officers prove to be _indispensable team members_. Facility managers at large plants report that cooperation with environmental or safety officers, for example, is an integral part of day-to-day business. These experts provide valuable _practical insights_: for example, the immission control officer, who suggests optimizations to the exhaust air system based on emission measurements; or the water protection officer, who ensures in dialogue with facility management that wastewater from production is correctly pretreated before it enters the municipal network. Fire safety officers work closely with technical FM teams to keep fire exits, sprinkler systems and alarm plans up to date. Occupational safety specialists (and safety officers) train building services and maintenance in safe working practices and report unsafe conditions at an early stage. In industrial companies in particular, where facility management is responsible for the infrastructure for production, storage and logistics, a close network is created: _Operations officers and facility managers share the goal of ensuring safe, legally compliant and efficient operations._ Each has their own expertise - together they form a powerful unit.

Without a formal representative function, there is a risk that this network will break. Experience reports from companies show that if roles are unclear, important tasks are left undone. For example, many facility managers are familiar with the "caretaker effect": if there is a clearly designated person (such as the waste management officer), waste disposal issues are actively managed. If there is no one with this title, no one feels explicitly responsible in the end - which can lead to deficits (e.g. improper storage of hazardous substances, missed deadlines for verification obligations, etc.). The legal representatives therefore ensure transparency in the distribution of responsibilities, which ultimately also relieves the burden on management: by appointing qualified persons, they delegate certain monitoring duties and reduce their own liability risk. If these buffers are abolished, every compliance detail becomes the direct focus of the company management - which is neither practical nor in the interests of effective management structures.

5. digitalization as a way out: How can the justified desire to reduce bureaucracy be reconciled with the need for compliance officers? The key lies in the digitization and standardization of compliance processes. Dr. Rack cites the once-only principle: Information should be collected _only once_ and then used many times. Applied to our topic, this means that every piece of evidence, every report that a company officer creates - such as an emissions report, a waste balance sheet or a safety instruction protocol - should be available centrally in digital form and automatically reported to all responsible departments as required. Today, an environmental officer often has to prepare similar data in different formats for different authorities or internal reports. Tomorrow, a common platform could record this data and distribute it to the environmental agency, the district government, the statistics portal and internally to the compliance department at the click of a mouse. This will reduce the _operational effort_ while retaining the substance of the control.

Another lever is _filtering the flood of information_: companies are constantly confronted with changes to the law - which are almost impossible for laypeople to keep track of. Digital compliance systems can help here by maintaining customized legal registers. A medium-sized chemical company, for example, is only shown those legal changes that affect its facilities requiring approval, but not changes from other areas. This is exactly where FM-Connect.com comes in with its consulting approach: _industry and facility-specific catalogs of obligations_ that are constantly kept up to date and automatically tell those responsible - whether commissioner or facility manager - what needs to be done. Modern software can score points here with algorithm-supported updates: What used to be added manually in folders is now handled by an update service that efficiently supports the six central compliance tasks (determining obligations, delegating, updating, fulfilling, monitoring and documenting).

6 Conclusion: The following applies to industrial facility management in Germany: company officers are and will remain a cornerstone of the compliance culture. Maintaining and strengthening them is in the best interests of companies that want to operate safely and sustainably. Nevertheless, it is possible to reduce bureaucracy - through process optimization instead of structural cutbacks. The expertise and competence of the authorized representatives can be increased using digital tools: Routine tasks are automated, while the experts can devote their time to the really important things - analyzing risks, advising the workforce and implementing improvement measures.

FM-Connect.com Network GmbH recommends that companies take a proactive approach: Use the current discussions as an impetus to review your compliance organization. Where are digital interfaces missing? Where is data perhaps still being maintained twice? Investments in a digital compliance infrastructure pay off quickly - whether through avoided administrative costs or greater legal certainty. And despite all the debates about changes to the law: _Those who rely on well-qualified company officers today will give themselves a head start_. These experts protect your company - from environmental incidents, accidents, damage to your image and legal consequences. No entrepreneur who cares about the long-term development of his company will voluntarily do without such a valuable tool. Or as Dr. Rack puts it: "The statutory representatives in companies with their internal control, advisory and information functions are indispensable. Anyone who wants to abolish them fails to recognize their special position [...]."

Interview with Kay Meyer (Managing Director FM-Connect.com Network GmbH)

Question: Mr. Meyer, in the discussion about reducing bureaucracy, the _company representatives_ are coming under pressure. In your experience, why are these functionaries still indispensable?

Kay Meyer: From my practical point of view, operations officers are a central pillar of operational safety and compliance. We see their value every day in our projects: they know the plant inside out and have a trained eye for risks. Take an immission control officer in a chemical plant - they will immediately notice if an exhaust air purification system is not running optimally, for example, and can take countermeasures before emission limits are exceeded. Or the occupational safety specialist: they pay attention to the little things, e.g. whether traffic routes are clear, whether employees are using PPE correctly, and thus prevent accidents that outsiders might chalk up to "coincidence". These people are _picky_ in a positive sense - and that's exactly what you need to comply with regulations in the complex day-to-day running of industry.

If you were to abolish the representatives now, the dangers would not disappear. It would just become more chaotic because the tasks would be divided up. An engineer might then "also" take care of environmental protection, but still have ten other issues. The focus would be lost. In practice, I find that where responsibilities are clearly defined - "You are the water protection officer, this is _your_ topic" - things simply run more smoothly. Where this is not the case, there is a lot of reaction instead of action.

Question: Politicians hope that fewer officers will mean less bureaucracy. Do you share this hope from a facility management perspective?

Kay Meyer: Having to fill out fewer forms sounds good at first. However, this is _only half the truth_. Let me give you an example: If tomorrow the obligation to appoint a waste management officer were removed, I as a company would still have to manage my waste - keep records, coordinate waste disposal companies, report hazardous waste, etc. That doesn't happen by itself. On the contrary, without someone explicitly appointed, this work is either left to the FM department or is neglected. The bureaucracy itself does not become less, it is just redistributed. And it often even becomes more inefficient as a result. In my experience, officers are often professionals at streamlining this administrative work - they know the authorities' online portals, the right reporting deadlines and the right contacts. If someone has to do it without the routine, it takes longer and becomes more error-prone.

As FM-Connect, we often come to companies as consultants to help reduce the workload. Interestingly, one of our first pieces of advice is almost always: "Create clear responsibilities, use the expertise of your specialists!" Because if everyone does a bit, you often end up with _more_ bureaucracy due to duplication of work and correction loops. In short: without representatives, there is a risk of more chaos and bureaucracy in the company, not less.

Question: How do you experience the cooperation between facility management and the various company representatives in practice?

Kay Meyer: Very close and collegial, mostly. Facility Management is responsible for the technical and infrastructural operation of the site - there is a lot of overlap with the officers. A fire safety officer, for example, draws up the fire safety regulations and provides training, but when it comes to structural or technical measures (fire doors, extinguishing systems, escape route markings), the FM team implements them. Ideally, we sit together regularly - FM, safety engineers, environmental officers if necessary - and go through checklists: _What has changed? Where is there a need for action?" In an industrial park that we look after, we carry out quarterly tours together with the immission control officer and the incident officer. In doing so, we bring together the _operational_ aspects and the _legal_ requirements: For example, the immission control officer pays attention to emission sources, while we from FM manage the technical side (repair filter damage immediately, etc.). This dovetailing is extremely important.

I also see the officers as _multipliers_: they bring new legal requirements into the company. As an FM manager, you can't know all the details of the regulations, so it's worth its weight in gold if, for example, the water protection officer says: "From next year, stricter limits will apply for XY, we may have to adapt our wastewater system." Knowing something like this in good time saves costs and prevents stress with the authorities. In short: In practice, FMs and officers ideally pull together - for the benefit of the company.

Question: What _weak spots_ do you currently see? Where is there a need for improvement in companies when it comes to company representatives?

Kay Meyer: One point is often the integration of the representatives into the overall organization. Sometimes they are viewed somewhat in isolation - according to the motto: "The environmental officer does his thing, the rest of the company has little to do with it." This is dangerous because there is then a lack of support. Officers need the support of management and colleagues. If, for example, the waste officer wants to enforce a new rule (e.g. separate collection containers for special waste), this will only work if the management is behind it and the other departments go along with it. A lot can be achieved here through awareness training or by involving the officers in decision-making processes.

Another weak point: documentation and digitalization. Despite digital options, some companies still keep their reports very manually. Officers then have Excel lists and Word templates - which is prone to errors. I see a lot of potential to make work easier with suitable software. For example, there are tools that automatically generate reports or import legal changes. If such tools are not used, representatives spend too much time on paperwork and too little on substantive work.

Finally, there is the issue of emergency drills and up-to-dateness - especially in the area of safety and fire protection. We sometimes find that although evacuation assistants are appointed and plans exist, they are not regularly rehearsed (as Mr. Meyer noted in one of our earlier interviews on evacuation management). This is where the dovetailing between officers and FM is important again: regular drills, checks that signage is up to date, etc. There is often a problem with day-to-day business - you have to discipline yourself together not to postpone such important exercises.

Question: What specific role do _digital solutions_ play? You just mentioned tools - can you elaborate?

Kay Meyer: With pleasure. In my view, digital solutions are the lever that will both relieve the burden on the commissioners and meet the demands for a reduction in bureaucracy. At FM-Connect.com, for example, we rely on a platform in which all _requirements and measures_ are stored. Every operations officer - whether internal or external service provider - works through their tasks there. The system automatically reminds them of inspection dates (such as the annual training or emissions measurement), generates reports as required and feeds the data into a central dashboard. This gives the management or compliance officer an overview of whether all obligations are being fulfilled at all times. There are no redundant activities for the officer: He documents once and the system distributes the information to all those who need to know (management, QM department, authority via interface, etc.).

A practical example: The waste manager has to prepare an annual waste balance report. In the past, he used to collect data from various departments, then write a Word document and send it to countless places. With a digital solution, the relevant data - quantities, waste disposal certificates - is automatically taken from the company databases. The person responsible simply checks the data and presses "Send". The software sends the report to the authority's e-mail inbox and stores it internally in the archive. We implemented this process for one of our customers, resulting in fewer errors, enormous time savings and more satisfied employees. And in the end, the authority is also pleased with the standardized reports.

Or think of legal changes: A good compliance tool spits out, for example, that a new regulation affecting water protection will come into force in the coming quarter. The water protection officer is automatically informed and can make preparations. This is what is known as the once-only principle on the information side - "entered once, used many times". The data is stored in _one place_, and everyone uses it from there. I am convinced that this is where the future lies. We make bureaucracy _invisible_, done in the background, while the experts can devote themselves to the real challenges.

Question: Finally, what is your strategic advice to companies with regard to company representatives?

Kay Meyer: Firstly:_Keep_ your officers - no matter what the legislator decides. Even if the obligation no longer applies, it makes sense to have the expertise in-house. You can call the child something else - "environmental coordinator" instead of environmental officer - but the function should remain.

Secondly: _Use_ external support where appropriate. No company has to do everything on its own. There are specialized service providers (also in our network) who can take on the tasks of a pollution control or incident officer externally. For smaller companies, this can be more efficient than hiring someone internally. The only important thing is that responsibility remains within the company - you can't just let external people do it and tick them off, you have to involve them like internal colleagues.

Thirdly: _Invest_ in digital compliance tools. It pays off. A clear system that manages all deadlines, documents and obligations saves more money every year than it costs - not to mention the penalties and incidents avoided.

Fourthly: _Sensitize_ your managers and employees. Even the best officers are of no use if the rest of the organization is on hold. We recommend that company representatives regularly have their say at management meetings: Where does the shoe pinch? What resources do they need? This _backing from the top_ is important. And vice versa: training for employees on why, for example, environmental protection requirements are not just bureaucracy, but serve to protect everyone.

All in all, my advice is: see company representatives as an opportunity, not a burden. They are your allies when it comes to working safely, sustainably and in compliance with the law. With the right organizational setup and digital support, company representatives will not become a "bureaucracy monster", but an efficiency factor. We then achieve the goal of reducing bureaucracy - without compromising on security and compliance.

Background information

Statutory company representatives in industry and FM: In Germany, there are a number of officer roles that companies must appoint depending on their industry, facility type and size. Here is an overview of relevant roles in industrial facility management:

* Immission control officer: mandatory for operators of facilities subject to licensing with relevant emissions (regulated in ?? 53-58 BImSchG and 5th BImSchV). The immission control officer advises the operator on all matters relating to air pollution control and immission control and monitors compliance with emission limits. He enjoys special protection against dismissal, as he should be able to perform his duties without being subject to instructions and without fear of repression. In practice, immission control officers can be found in power plants, chemical factories, metal smelters - anywhere where exhaust fumes, dust or noise can be released into the environment.
* Major Accidents Officer: The 5th BImSchV also includes the Major Accidents Officer (for major accident facilities in accordance with the Major Accidents Ordinance, which implements the EU Directive _SEVESO III_ nationally). Operators of certain large-scale plants with hazardous substances must appoint a Major Accidents Officer. This officer draws up internal alarm and hazard prevention plans, coordinates drills and ensures that the company does everything possible to prevent serious accidents. He is the link between the company and the disaster control authorities.
* Water protection officer: Regulated in ?? 64-66 of the Water Resources Act (WHG). Companies that discharge large quantities of wastewater (more than 750 m3 per day) or handle substances hazardous to water must appoint a water protection officer. This officer monitors, for example, compliance with wastewater limits, the operation of wastewater treatment plants and advises on the protection of groundwater and surface water. Typical locations: Chemical and pharmaceutical plants, refineries, larger food producers or metal processors with their own wastewater treatment plants.
* Waste officer: According to the Closed Substance Cycle Waste Management Act (KrWG) in conjunction with the Waste Officer Ordinance, certain waste producers or disposers (e.g. operators of hazardous waste facilities, large producers of hazardous waste) must appoint a waste officer. This officer ensures proper disposal, record keeping and waste prevention in the company. This role is particularly important in industries with a high volume of waste (chemicals, hospitals, large companies) in order to avoid environmental offenses and liability cases.
* Pollution control and waste officer in one person: An employee often acts as an environmental officer who combines several of these functions - especially in medium-sized companies. A dual role is legally permissible as long as the person is competent in all areas. In large corporations, on the other hand, there are usually separate positions with correspondingly in-depth expertise.
* Occupational safety specialist (specialist for occupational safety): According to the Occupational Safety Act (ASiG), every employer must appoint company doctors and safety specialists. The occupational safety specialist (often part of the HSE department) provides support in occupational safety and accident prevention. They are not a "representative" in the traditional sense of the term to the authorities, but rather an internal advisor to the employer - but they are indispensable for implementing occupational health and safety regulations. In addition, the accident insurance institutions require the appointment of safety officers (voluntary helpers from the workforce, at least one from 20 employees) who look out for accident hazards on site.
* Fire safety officer: In many federal states or required by law in industrial companies, public places of assembly and special buildings. The fire safety officer draws up and updates fire safety regulations, organizes fire extinguishing drills, checks fire extinguishers and escape routes and trains employees on how to behave in the event of a fire. The obligation is laid down in law indirectly via technical regulations (workplace regulation ASR A2.2 requires a fire safety officer for certain companies) or official notices. This role is extremely important for safety - it works closely with the fire department and insurers.
* Evacuation and evacuation assistants: According to Section 10 of the Occupational Health and Safety Act and the Workplace Ordinance, employers must make provisions for emergencies and appoint employees as evacuation assistants. These persons (usually several per building/department) support the orderly evacuation in the event of an emergency. Although they are not "company officers" with a duty to report to the authorities, they are important players in facility management and occupational health and safety. Regular evacuation drills involving these helpers are part of operational emergency management.
* Hygiene officer: Particularly relevant in special environments - e.g. hygiene officers in hospitals or in the food industry. In normal industrial plants, there is no generally prescribed hygiene officer, but in certain situations (e.g. pandemic concepts, legionella prevention in large cooling towers or drinking water plants) internal hygiene officers can be appointed. These officers are responsible for cleaning and disinfection plans, employee health care (e.g. vaccination programs) and the implementation of hygiene standards. While hygiene in the production process tends to be monitored by quality management, _facility hygiene_ concerns issues such as indoor air quality, sanitary hygiene and canteen hygiene. The COVID-19 pandemic in particular has highlighted the importance of responsible persons for operational hygiene plans.

Current legislative developments: The discussion about reducing bureaucracy has resulted in several concrete initiatives:

* The German government passed the Bureaucracy Reduction Act IV, which has been in force since January 1, 2025. It contains various measures to reduce red tape, including for SMEs. For example, smaller companies will have to comply with less stringent documentation requirements. This law is not aimed directly at company representatives, but it is part of a general reduction in bureaucracy.
* The "one in, two out" principle was already enshrined in the coalition agreement between the governing parties (as of 2021-2025), according to which two old regulations are to be dropped for every new one. This principle underpins the political will to curb regulation and formed the basis for the discussion about the commissioners. It was also explicitly agreed to review or abolish the obligation to appoint certain company representatives.
* As part of the 2025 economic policy debate, the opposition (CDU/CSU) introduced an "immediate economic program", which, among other things, provided for a reduction in the number of statutory representatives. This goal also appeared in the exploratory paper for a possible grand coalition (CDU/CSU/SPD). This shows that the issue is on the agenda across all parties.
* In a 2025 report, the National Regulatory Control Council (NKR) - an advisory body for bureaucracy reduction - listed the abolition of the obligation to appoint an agent as one of several proposals to reduce the administrative burden on companies (named as "Goal 11" on a top 22 list). At the same time, however, the NKR also emphasizes the once-only principle as the key to simplification, which in turn goes in the direction of digitalization.
* Association positions: While the VCI supports the abolition of the obligation to appoint an agent, other industry experts and associations - for example in the environmental protection sector - warn against rushing into action. In June 2025, the _Institute for Economy and Environment (IWU)_, for example, published a highly regarded technical paper entitled _"Company representatives: bureaucracy reduction or symbolic policy?"_, which concludes that the benefits of the representatives clearly outweigh the disadvantages and that abolishing them would lead to uncertainty and additional costs. Such voices reflect the core arguments also put forward by Dr. Rack and FM-Connect.

Conclusion of the background: The legally prescribed company representatives are based on the principle of _regulated self-monitoring_ by the industry. This principle has developed since the 1970s (first enshrined in the Federal Immission Control Act in 1974 with the immission control officer) and is part of preventive, modern regulatory law. Current reform ideas do not fundamentally question this principle, but seek ways to reduce duplication of work and administrative effort. The most sensible approach seems to be the digitalization of compliance processes - in line with the once-only principle - instead of dispensing with the expertise of company officers. Companies would do well to follow the debate closely, but above all to set the course internally now: for an _efficient, digital and integrative compliance organization_ in which company officers play a key role. They guarantee that industrial facility management in Germany meets high standards of safety, environmental protection and legal compliance - and will continue to do so in the future

FM-Connect.com Network GmbH
Am Altenfeldsdeich 16
25371 Seesterm?he
Germany

https://fm-connect.com/

Herr Kay Meyer
01717044665

info@fm-connect.com

At FM-Connect.com, we see facility management as an integral part of sustainable corporate management. Since our foundation on January 1, 2003, we have lived the idea that complex requirements can only be mastered sustainably through cooperation and network competence. We are not a classic individual company, but a hybrid network of specialized consultants, engineers and authors that reconfigures itself every day - depending on the project, task and challenge. This structure gives us flexibility, depth and strength at the same time. As FM-Connect.com, we bring together the experience, expertise and innovative strength of many. Our website is a showcase, working platform and entry point all in one: https://fm-connect.com. If you would like to get to know our solutions in detail, you will find them structured at: https://fm-connect.com/a-z/index.html.

This release was published on openPR.