In brief
The Annex 1 list of the Communiqué on Workplace Hazard Classes was completely renewed according to NACE Rev.2.1 on 13 March 2025; the class of some activities changed. For example, textile bleaching and dyeing (13.30.01) moved down from very hazardous to hazardous. A workplace whose class has changed must put in place the specialist, physician, training and examination arrangements required by the new class within 90 days. In this article we show the obligations that change by class with a table and a worked example.
NACE Rev.2.1 hazard class change: what changed in the list?
Your workplace's hazard class is the input to almost every calculation in OHS, from the specialist's certificate class to training hours, from the examination interval to the increase in fines. The NACE Rev.2.1 hazard class change altered this input for some workplaces. The list annexed to the Communiqué on Workplace Hazard Classes Relating to Occupational Health and Safety was completely renewed by the amendment published in the Official Gazette No. 32840 of 13 March 2025. The new 2025 hazard class list consists of 6-digit codes based on NACE Rev.2.1, the current version of the activity classification. The list was also amended on 21 May 2025 and 1 April 2026.
Under Art. 2 of the Communiqué, the class is determined by the main activity carried out at the workplace; if there is more than one main activity, the higher class applies. We explained how to find your code and the objection route in our article on how to find your hazard class. This article focuses on what a workplace whose class has changed needs to do.
Why are old NACE codes misleading?
Tables prepared according to the 2012 list, old quotes, the cover of an old risk assessment or "class lists" circulating on the internet may not show your current class. Old NACE codes lead to errors in three ways:
- Same code, different class. The activity code may have been kept but its class changed. The dye house example below is like this.
- The activity has been redefined. In Rev.2.1, some activities were split, merged or moved to another code. By looking at the old code, you may read the wrong row in the new list.
- Documents have not been updated. The OSGB contract, training plan and examination programme remain written for the old class; no one notices even though the class has changed.
The practical rule is: take the current 6-digit code shown in your workplace registration, find that row in the current version of Annex 1, and check that the activity description matches the main activity actually carried out at your workplace. If it does not match, the problem is with the code, and that is a separate correction matter.
An activity whose class changed: textile bleaching and dyeing
A verified example comes from textiles. 13.30.01 Textile bleaching and dyeing was in the very hazardous class in the 2012 list; in the 2025 list it is in the hazardous class. Since Bursa has a specialised zone dedicated to dye houses, the TOSAB Bursa Textile Dye Houses Specialised OIZ (organised industrial zone) in Nilüfer, this change directly concerns dye houses in the region. A lower class does not mean that the risks have fallen; chemicals, steam boilers and hot surfaces remain on site just as before. For risks specific to dye houses, see our article on textile dyeing and finishing.
Different classes sit side by side in the same sector: in the 2025 list, 13.20.16 cotton weaving is hazardous and 14.21.01 outerwear (garment manufacturing) is less hazardous. In a business doing both weaving and garment manufacturing under the same roof, if both are main activities, the higher class, i.e. hazardous, applies. A change of class does not only come from the list; the class can also rise when a new main activity is added to the workplace. For example, if laser cutting (25.53.03, very hazardous) is added as a main activity to a machining workshop in the hazardous class, the class rises to very hazardous.
Hazard class changed: what to do? Obligations that change by class
The answer to "the hazard class has changed, what should I do" is to compare the rows of the table below for the old and new class. The values are the minimum requirements in Law No. 6331 and the related regulations.
| Obligation | Less hazardous | Hazardous | Very hazardous |
|---|---|---|---|
| Specialist certificate class | At least C | At least B | A |
| Specialist hours (per worker, per month) | 10 min | 20 min | 40 min |
| Physician hours (per worker, per month) | 5 min | 10 min | 15 min |
| Other health personnel (per worker, per month) | Not required | Not required | 10 min for 10–49 workers, 15 min for 50–249, 20 min for 250 and above |
| Basic training (minimum) | 8 hours | 12 hours | 16 hours |
| Training refresher (at least 8 hours) | Every 3 years | Every 2 years | Every year |
| Periodic examination (at the latest) | Every 5 years | Every 3 years | Every year |
| Renewal of risk assessment and emergency plan | 6 years | 4 years | 2 years |
| First aider | 1 per 20 workers | 1 per 15 workers | 1 per 10 workers |
| Support staff (per team) | 1 for up to 50 workers | 1 for up to 40 workers | 1 for up to 30 workers |
| Starting work without a fitness-for-work report | Possible | Not permitted | Not permitted |
Two more items are added to this table. First, in a less hazardous workplace with fewer than 50 workers, the employer's option of running the service themselves after completing the Ministry's training disappears when the class rises. Second, the increase applied to administrative fines varies by class; for example, in a workplace with 50 or more workers the increase is 100 per cent in hazardous and 200 per cent in very hazardous workplaces. To see your own figures, you can use the OHS obligation calculator tool.
Worked example: two workplaces whose class went down and up
Class went down: a dye house with 120 workers (very hazardous → hazardous)
| Item | Before (very hazardous) | After (hazardous) |
|---|---|---|
| Specialist hours | 120 × 40 = 4,800 min (80 hours/month), class A | 120 × 20 = 2,400 min (40 hours/month), at least class B |
| Physician hours | 120 × 15 = 1,800 min (30 hours/month) | 120 × 10 = 1,200 min (20 hours/month) |
| Other health personnel | 120 × 15 = 1,800 min (30 hours/month) | Not mandatory |
| Periodic examination | Every year | Every 3 years at the latest |
| First aiders | 12 people | 8 people |
| Support staff (per team) | 4 people | 3 people |
When the class goes down, the minimum requirements fall, but reducing them is not mandatory. The workplace physician determines the frequency of tests carried out because of noise, chemical or dust exposure according to the risk, and this interval may be shorter than the general interval tied to the class. The vocational training certificate requirement also continues for work in the hazardous class.
Class went up: a workplace with 40 workers (less hazardous → hazardous)
- The specialist's certificate rises to at least class B; it is not possible to continue with a class C specialist.
- Specialist hours rise from 400 to 800 minutes, and physician hours from 200 to 400 minutes.
- Workers cannot start work without a fitness-for-work report, and reports are obtained from the workplace physician.
- The training refresher interval falls from 3 years to 2 years, and the periodic examination interval from 5 years to 3 years.
- The number of first aiders rises from 2 to 3.
- The renewal period for the risk assessment falls from 6 years to 4 years; the existing document is reviewed for the new class.
For the specialist's duties and powers, see our article on OHS specialist duties. For the logic behind specialist and physician hours, see our article on workplace physician and specialist working hours.
Hazard class within 90 days: an adaptation plan
Putting the hazard class 90 days rule on a calendar prevents everything piling up in the last week.
- First week: identification. Determine the current code and class in writing; check that the main activity description matches your workplace.
- First 2 weeks: contracts. Update the OSGB contract with the new hours and, if necessary, the new certificate class. Assignments in ISG-KATİP (the Ministry's online OHS registration system) are also re-approved for the new class; for contract approval deadlines, see our article on ISG-KATİP contract approval.
- First month: health surveillance. The workplace physician replans the periodic examination programme for the new interval; if the class has risen, a fitness-for-work report arrangement is put in place.
- First 2 months: training. The training plan is updated for the new refresher interval. If the class has risen, assess with the specialist how existing workers' training records meet the hour requirements of the new class; remember that the topic of job-specific risks is delivered face to face in hazardous and very hazardous workplaces.
- First 2 months: emergency teams. The numbers of first aiders and support staff are completed according to the new ratio.
- By day 90: documents and notification. The covers, renewal dates and content of the risk assessment and emergency plan are updated for the new class; what has been done is notified to the General Directorate.
Through our OHS specialist service, we carry out this plan together with you and add a record of each step to your file. To see renewal dates in one place, you can use the OHS calendar tool. For other topics specific to the textile sector, see our sector page.
Frequently Asked Questions
How much time do I have if my hazard class has changed?
Under Art. 3 of the Communiqué, the obligations required by the new class are fulfilled within 90 days and notified to the General Directorate of Occupational Health and Safety. A change of main activity, on the other hand, is notified to the Ministry within 1 month.
If my class has gone down, should I reduce specialist and physician hours immediately?
It is not mandatory. When the class goes down, minimum hours fall, but if the risks have not changed it is possible to keep the existing arrangement. Base the decision to reduce on the results of the risk assessment and health surveillance.
Are documents prepared according to the 2012 list invalid?
Documents do not become invalid automatically; however, if your class has changed, renewal dates, training hours and assignment hours must be updated for the new class. If your class has not changed, it is enough to check the equivalent of the code written in the documents in the current list.
Where do I check my old NACE code?
Take the current 6-digit code shown in your workplace registration and find its equivalent in the current Annex 1 list of the Communiqué. If the activity description does not match the main activity carried out at your workplace, correcting the code is a separate process.
A certified specialist matched to your hazard class: site inspections, approved logbook, training plan, annual plan and report follow-up.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.