OHS in Construction Works: Safety Plan and Coordinator

Who does the Regulation on Occupational Health and Safety in Construction Works cover?

The Regulation on Occupational Health and Safety in Construction Works was published in the Official Gazette of 5 October 2013 and applies to all workplaces where construction works are carried out within the scope of Law No. 6331; in practice it is often simply called the construction works regulation. Mining workplaces are subject to a separate regulation. The amendment of 31 December 2018 renewed the provisions on working at height and scaffolding and added a new Annex 5 on work equipment; the plan, coordinator and notice provisions discussed in this article were not affected by that amendment.

The regulation's definition of "construction work" is broader than most employers assume. Alongside excavation, earthworks and building construction, the list in Annex 1 includes:

• Assembly, alteration and fitting-out works,
• Alteration, renovation, repair, dismantling and demolition,
• Maintenance, painting and cleaning,
• Plastering, whitewashing and painting; electrical, plumbing and heating installations,
• Erection and dismantling of prefabricated elements.

So a factory in Bursa having its roof renewed, a steel platform installed in its production area or its facade painted is also construction work. The factory may be less hazardous or hazardous in its own main activity, but the regulation applies directly to the contractor working on the roof. It is also worth remembering that activities such as site preparation are very hazardous in the 2025 hazard class list.

Who is who? Employer, project manager, coordinator, subcontractor

The regulation has four main roles. Neither the plan nor coordination will work unless you define in writing who wears which hat on a site.

Self-employed persons, i.e. people who contribute to the work without employing workers, also comply with the coordinator's warnings and instructions; the employer is responsible for monitoring this (Art. 7).

The health and safety plan: when, who prepares it, what goes in it?

The employer or project manager prepares, or has prepared, the health and safety plan before construction work starts, during the project preparation stage (Art. 8/2). The article makes no exception based on the size of the site.

According to the regulation's definition, the plan sets out:

• The assessment of likely risks,
• The health and safety measures to be taken throughout the construction work,
• The organisational structure and working methods,
• When and by whom these tasks are to be carried out,
• Coordination between the different employers, subcontractors and crews in the same area.

If any of the high-risk works listed in Annex 2 are present on site, specific measures for them are also included in the plan (Art. 10/1-b). This list includes work with a high risk of burial or falls from height, work near high-voltage lines, well, underground excavation and tunnelling work, the use of explosives, and the assembly and dismantling of heavy prefabricated elements.

The plan is not written once and filed away. The coordinator updates the plan and the health and safety file as work progresses and as things change (Art. 11/1-c). These two documents are often confused:

1. The health and safety plan is the OHS roadmap for the construction process.
2. The health and safety file contains the information needed so that work such as cleaning, maintenance, alteration and demolition can be done safely during the project and after the building is completed (Art. 10/1-c).
3. The risk assessment is the assessment each employer carries out for its own workers under Law No. 6331, and it feeds into the plan.

The anchorage points needed for lifelines used when working at height must also be identified at the project preparation stage and written into the plan and the file (Annex 4). For the steps of a risk assessment, see our risk assessment guide.

When is an OHS coordinator mandatory?

If there is more than one employer or subcontractor on the same construction site, the employer or project manager appoints one or more health and safety coordinators (Art. 8/1). The exception is narrow: a coordinator need not be appointed if the work does not require notice and does not involve work with the risks listed in Annex 2 (Art. 8/3).

The coordinator's duties are split into two stages:

• Preparation stage (Art. 10): Coordinates the application of the principles of prevention in design decisions, prepares or has prepared the plan, and creates the health and safety file.
• Execution stage (Art. 11): Coordinates the application of the principles of prevention in the work schedule and time planning, monitors implementation of the plan, ensures organisation and exchange of information between employers, including those who join later, coordinates the necessary checks and makes arrangements to prevent unauthorised persons from entering the site.

The regulation does not require any particular profession or certificate for the coordinator; the coordinator may be a natural or legal person. The employer needs to choose a person or organisation with competence suited to the size and risks of the work. The coordinator's role does not replace each employer's obligation to appoint its own OHS specialist and workplace physician.

Site prior notice: which works must be notified?

In any of the following cases, the employer or project manager notifies the relevant provincial directorate of the Ministry before construction work starts (Art. 8/4):

1. The construction work will last more than 30 working days and more than 20 workers will be employed continuously,
2. The size of the work will require more than 500 person-days of work.

Example: if a 12-person crew will work for 45 working days, the first condition is not met, because the number of workers employed continuously does not exceed 20. But since 12 × 45 = 540 person-days, the second condition is met and notice is required.

The content of the notice is listed in Annex 3: the full address of the site, the name and address of the employer, the type of project, the project manager if any, the coordinators for the preparation and execution stages, the planned start date and duration, the maximum number of workers on site, the number of contractors and details of the contractors already selected. A sign board containing this information is posted where it is clearly visible on the construction site and updated as necessary (Art. 8/5).

Sharing duties on a multi-contractor site

On a site where the main contractor and the structural works, electrical, mechanical installation, facade and scaffolding firms work at the same time, put the division of duties in writing. Art. 23 of Law No. 6331 on Occupational Health and Safety requires employers sharing the same work area to implement measures in cooperation and coordination and to inform each other and employee representatives about the risks. In a principal employer and subcontractor relationship lasting longer than six months, coordination of the committees is governed by Art. 22 of the Law.

A practical division of duties can be set up as follows:

• Principal employer or project manager: Approves the plan, appoints the coordinator, submits the prior notice, and manages site access control and shared areas (scaffolding, temporary electrics, cranes).
• Coordinator: Runs the weekly coordination meeting, reviews contractors' work schedules for clashes, and updates the plan and the file.
• Each contractor: Provides its own risk assessment, training, health surveillance and PPE; complies with the rules for shared areas and the coordinator's instructions.
• OHS specialists: Each employer's own specialist makes findings concerning its own workers and shares information with the coordinator.

Working one above another, excavation and crane operations at the same time, or one crew removing a guardrail installed by another crew are the most typical points of conflict. At the weekly meeting, read the following week's work schedule with this in mind. Our articles on the PPE use regulation for PPE selection and working at height, and on OHS culture for shared behaviour on site, can help.

For plan preparation, risk assessment and site follow-up on construction sites and in-factory construction works in Bursa and the surrounding provinces, see our OHS specialist and risk assessment services, and for other topics in the sector, our construction page. You can see the obligations for your site according to its number of workers with the OHS obligation calculator.

Frequently Asked Questions

Is a health and safety plan mandatory on every site?

Art. 8 of the regulation requires the employer or project manager to prepare, or have prepared, the health and safety plan before construction work starts, and makes no exception based on the size of the site. For small jobs the plan can be short, but it must exist.

Does the OHS coordinator have to be an OHS specialist?

The regulation does not require any particular profession or certificate for the coordinator; it may be a natural or legal person. However, since the duties require technical knowledge, the employer is expected to choose a competent person or organisation. The coordinator does not remove employers' obligation to appoint their own OHS specialist.

Where is the site prior notice submitted?

The regulation requires the notice to be submitted to the relevant provincial directorate of the Ministry before construction work starts. A sign board showing the information in the notice is also posted in a visible place on site.

We are having roof repairs done at our factory. Does this regulation apply?

Yes. The list of construction works in Annex 1 also includes repair, alteration, maintenance, painting and dismantling work. If more than one firm will work on the roof, a coordinator is required, and if the duration and headcount threshold is exceeded, prior notice is required.