Occupational Health and Safety (OHS) Requirements in Turkey: A Complete Guide for Foreign Employers

Introduction

Occupational Health and Safety (OHS) - known as İş Sağlığı ve Güvenliği (İSG) in Turkish - is a critical compliance area for all employers operating in Turkey, including foreign companies. Turkey’s OHS framework is comprehensive and strictly enforced, with significant penalties for non-compliance.

This guide covers everything foreign employers need to know about OHS obligations in Turkey.

Legal Framework

Primary Legislation

Occupational Health and Safety Law (No. 6331)

Enacted: June 20, 2012
Comprehensive OHS framework
Applies to all workplaces
Aligned with EU directives

Supporting Regulations

Workplace Safety Services Regulation
Occupational Diseases Regulation
Heavy and Dangerous Work Regulation
Risk Assessment Regulation
Personal Protective Equipment Regulation

Mandatory OHS Requirements

1. Workplace Risk Assessment

Legal Obligation Every employer must conduct workplace risk assessment before starting operations and update regularly.

Risk Assessment Must Include:

Identification of hazards (physical, chemical, biological, ergonomic)
Analysis of risks for each job position
Protective measures and controls
Emergency procedures
Regular review and updates

Frequency:

Initial assessment before operations begin
After any workplace accident/occupational disease
When workplace layout/processes change
At least annually

2. Occupational Health and Safety Professionals

Workplace Physician (İşyeri Hekimi)

Required for: All workplaces with employees
Duties: Health surveillance, periodic examinations, first aid, occupational disease prevention
Qualification: Licensed physician with OHS certificate

Safety Specialist (İş Güvenliği Uzmanı)

Required for: All workplaces with employees
Duties: Risk assessment, safety inspections, training, accident investigation
Qualification: Engineer/architect/technical expert with OHS certificate

Required Service Hours (per month):

Number of Employees	Safety Specialist Hours	Workplace Physician Hours
1-10 (low risk)	10-20 hours	10-20 hours
11-50 (low risk)	20-40 hours	20-30 hours
50+ (medium risk)	Full-time	Part-time+
Any (high risk)	Full-time+	Part-time+

Risk Classification:

Low risk: Offices, retail, education
Medium risk: Light manufacturing, food processing
High/Very high risk: Construction, mining, chemicals, heavy industry

3. Employee Health Surveillance

Mandatory Medical Examinations:

Initial Examination (İşe Giriş Muayenesi)

Required before employee starts work
Confirms fitness for specific job
Job-specific health screenings

Periodic Examinations (Periyodik Muayene)

Frequency depends on risk level and age:
- High risk workplaces: Annually
- Medium risk: Every 2 years
- Low risk: Every 3-5 years
- Employees under 18: Annually
- Employees over 50: Annually

Special Examinations

After work accidents
After sick leave >6 weeks
When changing to hazardous job
When employee/doctor requests

Record Keeping: All medical records must be kept for 15 years after employment ends.

4. OHS Training

Mandatory Training for All Employees:

Initial OHS training before starting work (minimum 8 hours)
Job-specific safety training
Periodic refresher training (at least annually)
Training after workplace changes
Emergency and evacuation drills

Special Training Requirements:

New hires: Within first week
Transferred employees: Before starting new role
High-risk jobs: Extended training required
Young workers (<18): Enhanced safety training

Documentation:

Training records with signatures
Training content and duration
Trainer qualifications
Keep records for 5 years

5. Personal Protective Equipment (PPE)

Employer Obligations:

Provide appropriate PPE free of charge
Ensure PPE meets Turkish/EU standards (CE marking)
Replace damaged/worn PPE
Train employees on proper use
Monitor and enforce PPE usage

Common PPE Requirements:

Safety helmets (construction, manufacturing)
Safety shoes/boots
Gloves (task-specific)
Eye protection (goggles, face shields)
Hearing protection (earplugs, earmuffs)
Respiratory protection (masks, respirators)
High-visibility clothing
Fall protection equipment

Workplace Safety Committees

OHS Committee (İSG Kurulu)

Required for: Workplaces with 50+ employees

Committee Composition:

Employer representative (chair)
Workplace physician
Safety specialist
Employee representatives (elected)
Union representative (if unionized)
Civil defense expert (if required)

Meetings: At least monthly, with minutes documented

Responsibilities:

Review risk assessments
Investigate accidents
Monitor safety measures
Recommend improvements
Follow up on action items

Employee Representatives

Required for: Workplaces with 2-49 employees

One employee representative for OHS matters
Elected by employees
Participates in risk assessment
Reports hazards to employer

Work Accidents and Occupational Diseases

Work Accident Reporting

Immediate Actions (within 24 hours):

Provide first aid/medical treatment
Notify Social Security Institution (SGK)
Report to Ministry of Labor (for serious accidents)
Preserve accident scene (if investigation needed)

Online Reporting: Via SGK’s electronic system (e-SGK portal)

Investigation:

Internal investigation by employer
Official investigation by Ministry of Labor (serious accidents)
Root cause analysis
Corrective action plan

Serious Accidents (Ministry Notification Required):

Death
Multiple injuries (3+ workers)
Permanent disability
Dangerous substance release
Structural collapse

Occupational Disease Reporting

Reporting Obligation:

Employer must report to SGK within 3 business days of learning about occupational disease
Workplace physician assists with reporting
SGK determines if disease is work-related

Common Occupational Diseases:

Respiratory diseases (dust, chemicals)
Hearing loss (noise exposure)
Musculoskeletal disorders
Skin diseases (chemical exposure)
Vibration-related conditions

Industry-Specific Requirements

Construction Sites

Additional Obligations:

Construction site safety plan
Coordination between contractors
Temporary facilities (first aid room, changing rooms)
Scaffolding and fall protection inspections
Excavation safety measures
Crane and heavy equipment certifications

Site Safety Coordinator: Required for projects with multiple contractors

Manufacturing

Machine Safety:

CE certification for machinery
Machine guarding and emergency stops
Lockout/tagout procedures
Regular maintenance and inspections

Chemical Safety:

Safety Data Sheets (SDS) in Turkish
Chemical inventory and labeling
Hazardous substance risk assessments
Spill containment and emergency procedures

Hazardous Substances

Additional Requirements:

Explosive atmospheres assessment (ATEX)
Confined space entry procedures
Hot work permits
Specialized PPE
Enhanced monitoring and controls

Penalties for Non-Compliance

Administrative Fines (2026)

Per Violation:

Failure to conduct risk assessment: ₺50,000-₺75,000
No workplace physician/safety specialist: ₺30,000-₺50,000 per month
No medical examinations: ₺5,000-₺10,000 per employee
Insufficient OHS training: ₺3,000-₺8,000 per employee
No PPE provided: ₺5,000-₺15,000 per employee
No OHS committee (50+ employees): ₺20,000-₺40,000

Fines are adjusted annually for inflation.

Criminal Liability

Serious Violations:

Work accidents causing death/injury: Criminal investigation
Employer/manager can face imprisonment
Company may be barred from public tenders

Work Stoppage Orders

Ministry of Labor can:

Stop work immediately for imminent danger
Prohibit use of unsafe equipment
Close part or all of workplace
Work cannot resume until violations corrected

SGK Premiums

Accident Rate Impact:

High accident rate → Higher SGK premiums
“Risk discount” for excellent safety record (up to 20% reduction)
“Risk increase” for poor safety record (up to 100% increase)

Inspection and Enforcement

Ministry of Labor Inspections

Labor Inspectors Have Authority To:

Enter any workplace without notice
Review OHS documents
Interview employees
Take samples/measurements
Issue immediate stop-work orders
Impose administrative fines

Common Inspection Focus Areas:

Risk assessment documentation
Workplace physician/safety specialist contracts
Medical examination records
Training records
PPE provision and usage
Machine safety and guarding
Emergency exits and fire safety

Inspection Frequency:

High-risk workplaces: More frequent inspections
Random inspections at any time
Complaint-triggered inspections
Post-accident investigations

Best Practices for Foreign Employers

1. Early Compliance

Before Starting Operations:

Appoint workplace physician and safety specialist
Conduct comprehensive risk assessment
Arrange employee medical examinations
Prepare OHS training program
Set up document management system

2. Service Providers

Common Outsourcing (Shared Services): Many companies outsource OHS professionals to specialized service providers:

Shared Workplace Physician & Safety Specialist: Cost-effective for small/medium businesses
Service provider handles compliance, documentation, visits
Typical cost: ₺1,000-₺5,000/month (depending on employee count and risk level)

In-House vs. Outsourced:

Small companies (<50): Almost always outsource
Medium companies (50-200): Usually outsource
Large companies (200+): Often hire in-house + outsource specialized services

3. Documentation System

Essential Records:

Risk assessment reports (updated)
Medical examination records (15-year retention)
Training records (5-year retention)
Accident investigation reports
Inspection checklists
PPE distribution records
OHS committee meeting minutes

Digital Solutions:

Cloud-based OHS management systems
E-SGK integration for reporting
Mobile apps for inspections
Training tracking software

4. Culture of Safety

Leadership Commitment:

Visible management support for OHS
Adequate budget allocation
Regular management reviews
Recognition of safe behavior

Employee Engagement:

Encourage hazard reporting
Near-miss reporting system
Safety suggestion program
Regular safety talks

5. Emergency Preparedness

Required Plans:

Emergency evacuation plan
Fire safety plan
First aid procedures
Natural disaster response
Chemical spill response (if applicable)

Drills:

Fire/evacuation drills: At least twice per year
First aid training: Regular updates
Emergency contact lists: Keep current

Integration with Other Compliance

OHS Impacts SGK:

Work accident reports affect premium rates
Medical examinations recorded in SGK system
Employer compliance affects SGK inspections

Employment Law

Coordination with Labor Contracts:

Job descriptions must include OHS responsibilities
Employment contracts reference OHS training
Disciplinary procedures for safety violations

Environmental Permits

Environmental & OHS Overlap:

Chemical handling requirements
Waste management safety
Emissions monitoring (employee exposure)

Remote Work and OHS

Emerging Guidance (2024-2026): Turkey’s Ministry of Labor has begun addressing OHS for remote workers:

Employer Obligations:

Risk assessment for home office
Ergonomic guidance and equipment
Training on home workspace safety
Electrical safety checks (if employer provides equipment)

Practical Approach:

Written OHS policy for remote work
Self-assessment checklists for employees
Periodic virtual safety meetings
Equipment provision records

Costs and Budgeting

Typical Annual OHS Costs

Small Office (10 employees, low risk):

Workplace physician/safety specialist: ₺15,000-₺25,000
Medical examinations: ₺5,000-₺10,000
Training: ₺3,000-₺5,000
PPE (minimal): ₺2,000-₺5,000
Total: ₺25,000-₺45,000/year

Manufacturing Facility (100 employees, medium risk):

Workplace physician/safety specialist: ₺60,000-₺120,000
Medical examinations: ₺40,000-₺70,000
Training: ₺20,000-₺40,000
PPE: ₺50,000-₺100,000
Equipment/signage: ₺30,000-₺60,000
Total: ₺200,000-₺390,000/year

Construction Site (200 workers, high risk):

Full-time OHS team: ₺300,000-₺600,000
Medical examinations: ₺100,000-₺150,000
Training: ₺50,000-₺100,000
PPE: ₺200,000-₺400,000
Safety equipment: ₺100,000-₺300,000
Total: ₺750,000-₺1,550,000/year

Common Mistakes to Avoid

1. Delayed Compliance

❌ Wrong: “We’ll set up OHS after we hire employees” ✅ Right: OHS professionals appointed before first employee starts

2. Paper Compliance Only

❌ Wrong: Documents exist but no actual implementation ✅ Right: Active safety culture with real risk mitigation

3. Skipping Medical Exams

❌ Wrong: “We’ll catch up on medical exams later” ✅ Right: No employee works without initial medical clearance

4. Inadequate Training

❌ Wrong: One-time generic safety presentation ✅ Right: Regular, job-specific, documented training

5. Ignoring Near Misses

❌ Wrong: “No accident happened, so no problem” ✅ Right: Investigate and learn from near misses

How FDI Consultancy Can Help

OHS Compliance Setup

We assist foreign employers with:

Initial compliance audit and gap analysis
Risk assessment coordination
Workplace physician and safety specialist sourcing
Medical examination arrangements
Training program development
Documentation system setup
Ongoing compliance monitoring

Outsourced OHS Services

Turnkey Solution:

Shared workplace physician and safety specialist
Monthly site visits and inspections
SGK reporting and accident management
Training coordination
Document management
Ministry of Labor liaison

Industry-Specific Guidance

We provide tailored OHS solutions for:

Manufacturing facilities
Construction projects
Warehousing and logistics
Offices and service companies
Chemical and hazardous materials operations

Key Takeaways

OHS compliance is mandatory from day one of operations
Workplace physician and safety specialist required for all workplaces
Medical examinations must be completed before employees start work
Risk assessment is the foundation of all OHS activities
Training and PPE are legal obligations, not optional
Penalties are significant and strictly enforced
Culture matters - go beyond paper compliance
Outsourcing is common and cost-effective for most businesses

Conclusion

Occupational health and safety in Turkey is a serious compliance matter with strict enforcement and meaningful penalties. Foreign employers must prioritize OHS from the beginning of operations, not as an afterthought.

While the requirements may seem extensive, most can be efficiently managed through professional OHS service providers, allowing you to focus on your core business while maintaining full compliance.

The investment in workplace safety protects your employees, your business reputation, and your bottom line.

Need help with OHS compliance in Turkey?

FDI Consultancy provides comprehensive support for foreign companies navigating Turkey’s occupational health and safety requirements.

📧 Email: info@fdiconsultancy.com
📞 Phone: +90 (212) XXX-XXXX
🌐 Website: fdiconsultancy.com

This guide is for informational purposes only and does not constitute legal advice. OHS regulations are subject to change; consult with qualified professionals for your specific situation.