Who is covered by OHS obligations in Turkey?
The Occupational Health and Safety Law No. 6331 (İSG, İş Sağlığı ve Güvenliği) applies to all work and workplaces in the public and private sectors, to their employers and employer representatives, and to all employees including apprentices and interns. The core principle is that the employer is responsible for ensuring the health and safety of employees at work, and this responsibility does not end when the service is outsourced to a joint health and safety unit (OSGB, Ortak Sağlık ve Güvenlik Birimi).
OHS is not only a matter for factories or construction sites. A software company with office staff must also carry out a risk assessment, train employees and provide health surveillance. What differs is the frequency and intensity of obligations, and that is determined by the workplace hazard class.
This guide summarises the general rules for foreign companies operating in Turkey. Details and periods in the regulations can change, so confirm the current rules with the Directorate General of Occupational Health and Safety of the Ministry of Labour and Social Security before applying them.
How is my workplace hazard class determined?
The hazard class is set in the Communiqué on Workplace Hazard Classes based on the main activity code (NACE code) registered with SGK (Social Security Institution). There are three classes:
- Less hazardous (az tehlikeli): office services, software, consulting, some retail activities.
- Hazardous (tehlikeli): many types of manufacturing, warehousing, logistics, food production.
- Very hazardous (çok tehlikeli): construction, mining, metalworking, chemicals.
You can see your NACE code in your SGK workplace registration and on the e-Bildirge (online SGK filing) screen. If your actual activity differs from the registered code, correcting it matters for both premium rates and OHS obligations.
What are the key periods by hazard class?
The table below summarises the general rules most often applied in practice under the relevant regulations. Check the current values for your workplace in the regulation text.
| Obligation | Less hazardous | Hazardous | Very hazardous |
|---|---|---|---|
| Risk assessment renewal (at the latest) | Every 6 years | Every 4 years | Every 2 years |
| Emergency plan renewal (at the latest) | Every 6 years | Every 4 years | Every 2 years |
| Basic OHS training (minimum per employee) | 8 hours | 12 hours | 16 hours |
| Training repeat frequency (at least) | Every 3 years | Every 2 years | Every year |
| Periodic medical examination (at the latest) | Every 5 years | Every 3 years | Every year |
| Safety expert certificate class | C, B or A | B or A | A |
When there is a significant change at the workplace (new machinery, new production method, relocation, work accident or occupational disease), the risk assessment and emergency plan are renewed without waiting for these periods to expire.
Are a safety expert and a workplace physician mandatory?
As a general rule, every employer must appoint an occupational safety expert and a workplace physician, regardless of the number of employees. The service can be provided in three ways:
- Appointing qualified, certified people from among the employees
- Contracting a joint health and safety unit (OSGB)
- Under certain conditions and in small less hazardous workplaces, the employer or employer representative carrying out the service personally after completing the required training
Appointments and contracts are made and approved through İSG-KATİP (the OHS registration, monitoring and tracking system). The minimum monthly time per employee that the expert and physician must spend is set in the regulation by hazard class. Above certain employee numbers, full-time appointments or other health personnel may be required. Confirm these thresholds and minute values in the current regulation.
How is a risk assessment carried out?
Risk assessment is the process of identifying hazards at the workplace, analysing and rating the resulting risks and deciding on control measures. The employer carries it out with a team, which usually includes:
- The employer or employer representative
- The safety expert and workplace physician
- The employee representative
- Support staff (first aid, firefighting, evacuation)
- Employees who know the risks at the workplace
The method (for example, an L-type matrix or Fine-Kinney) is left to the employer. What matters is that all activities, equipment and employee groups are covered, including groups needing special policies such as pregnant, young and disabled employees, and that measures are followed up with an action plan.
How should employee training be planned?
Every employee must receive OHS training before starting work and at set intervals afterwards. Training covers general topics (legislation, rights and duties), health topics (occupational diseases, first aid) and technical topics (chemical, physical and ergonomic risks, fire, electricity). New starters also receive an orientation briefing before they start.
Training hours count as working time. Training delivered as overtime must be paid at the overtime rate. Plan the training calendar together with timesheets and shift plans.
Worked example: training hours required
Take a hazardous-class workplace with 40 employees. Under the general rule, each employee needs at least 12 hours of basic training, repeated at least every 2 years.
| Item | Value |
|---|---|
| Number of employees | 40 |
| Minimum training per employee | 12 hours |
| Total employee-hours per training cycle | 480 hours |
| If the workplace were less hazardous (8 hours) | 320 hours |
| If the workplace were very hazardous (16 hours) | 640 hours |
480 employee-hours means 1.5 working days for each of the 40 employees. To avoid disrupting operations, split training into groups and fit it into the shift plan. Where training runs into overtime, check the cost with the overtime calculator and see our guide to overtime rules in Turkey.
What does health surveillance involve?
Employees have a medical examination when they start and periodic examinations at intervals set by hazard class. Examinations are also carried out on job changes and on return to work after repeated absences due to a work accident or occupational disease. Medical reports are special category personal data, so only the workplace physician and authorised persons should have access; see our guide on KVKK compliance in HR.
For employees working nights, additional health checks and the rule that night work may not exceed 7.5 hours must also be observed. Shift planning is therefore directly linked to OHS; see our shift scheduling guide.
What about personal protective equipment and special groups?
Where risks cannot be eliminated at source or sufficiently reduced by collective measures, personal protective equipment (PPE) is used. PPE is provided to employees free of charge and its cost may not be deducted from wages. The employer is responsible for obtaining a delivery record, training employees in correct use and replacing worn equipment.
Some employee groups require special policies: pregnant and breastfeeding employees, employees under 18, disabled employees, older employees, and apprentices and interns. The risk assessment should look at these groups separately; for example, the risks of heavy lifting or chemical exposure for a pregnant employee are assessed and duties adjusted. Interns and apprentices are also covered by OHS training and health surveillance; see our guide to employing interns in Turkey.
In practice, HR runs the administrative side of OHS: training attendance records, examination dates, PPE delivery records and accident notifications are usually shared between HR and the safety expert. Keeping these records in order in the personnel file is decisive in inspections and as evidence in any dispute.
When are an OHS committee and an employee representative needed?
Workplaces with fifty or more employees where continuous work lasting more than six months is carried out must set up an occupational health and safety committee. The committee is chaired by the employer and includes the expert, physician, HR officer and employee representative, among others, and meets at intervals set in the regulation.
An employee representative is appointed even in small workplaces without a committee; the number increases with headcount. Support staff for first aid, firefighting and search, rescue and evacuation are designated and trained under the emergency plan. Check the current regulation for the required numbers.
What should the employer do after a work accident?
A work accident is an event occurring at the workplace or because of the conduct of work that causes physical or mental harm to the employee. The employer should:
- Provide first aid and access to medical care for the injured employee
- Preserve the scene so it can be investigated
- Report the accident to SGK within 3 working days after the accident
- Investigate the causes and update the risk assessment
- Record and analyse near misses as well
For the payroll treatment of an employee on sick leave after a work accident, see our guide to unpaid and sick leave in payroll.
What happens if obligations are not met?
Law No. 6331 provides administrative fines for failing to carry out a risk assessment, appoint an expert and physician, provide training, ensure health surveillance or report a work accident. For some violations the fine is applied again for each month the violation continues. Where there is a life-threatening danger, work may be stopped. In the event of a work accident, SGK may seek recourse against the employer, and civil or criminal liability may arise. Fine amounts are updated each year, so confirm them with the official source.