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Legislation

Hazard Classes in the Automotive and Metal Sectors

Where does automotive supply sit in the 2025 hazard class list? Codes 29.32, laser cutting and plating, hazardous vs very hazardous and the specialist class.

  • Published:
  • 8 min read
  • Bursa SİSTEMER OSGB Technical Team

In brief

In the list that moved to NACE Rev.2.1 in 2025, automotive parts manufacturing (29.32.20), body parts (29.32.21) and machining and welding work (25.53.01) are hazardous; laser cutting of metals (25.53.03) and nickel plating of metals (25.51.01) are in the very hazardous class. Being in the same sector does not mean being in the same class; what is decisive is the main activity carried out at the workplace. The class changes the specialist’s certificate class, the specialist and physician times, the need for DSP, training hours and the increase in fines.

Hazard class in the automotive supply industry: same sector, different classes

In Bursa, the automotive and supply industry is spread over a wide area, from Bursa OIZ (organised industrial zone), Nilüfer OIZ and Hasanağa OIZ in Nilüfer to Demirtaş OIZ in Osmangazi and Uludağ OIZ in Gürsu. Most of these businesses describe themselves as “automotive suppliers”; however, the hazard class is determined not by the name of the sector but by the work actually done at the workplace. That is why the automotive supply industry hazard class is not a single class: of two suppliers delivering parts to the same customer, one may be in the hazardous class and the other in the very hazardous class.

The distinction became even more important in 2025. Annex 1 of the Communiqué on Workplace Hazard Classes was completely renewed on 13 March 2025 with 6-digit codes based on NACE Rev.2.1; further amendments were made on 21 May 2025 and 1 April 2026. Old codes prepared according to the 2012 list should no longer be used as a reference. For the general method, see our article on how to find out your hazard class; this article focuses on automotive and metal businesses.

Automotive and metal codes verified in the 2025 list

The codes below have been verified against the 2025 Annex 1 list:

NACE codeActivityHazard class
29.10.02Manufacture of carsHazardous
29.31.04Wiring harnesses for vehiclesHazardous
29.32.20Parts and accessories for motor vehicles (gearboxes, brakes, shock absorbers, etc.)Hazardous
29.32.21Body partsHazardous
25.53.01Machining and welding workHazardous
25.53.03Laser cutting of metalsVery hazardous
25.51.01Nickel plating of metalsVery hazardous

Two conclusions follow from the table. First, parts and body manufacturing under NACE code 29.32 and machining are in the hazardous class. Second, the metal sector hazard class depends not only on the product but on the process: a workshop machining a metal part is hazardous, while a business cutting the same part with a laser or plating it with nickel is in the very hazardous class. The fact that laser cutting and plating are very hazardous has direct consequences for subcontractors doing this work.

The main activity rule: a parts manufacturer with a laser cutting machine

Under Art. 2 of the Communiqué, the class of the main activity carried out at the workplace is the basis. If there is more than one main activity, the higher hazard class applies.

Example: a supplier manufactures brake parts under 29.32.20; it is in the hazardous class. For a new customer project, it decides to cut the sheet metal parts itself, buys a laser cutting machine and, after a while, also starts doing subcontract cutting for other companies. Laser cutting is no longer an intermediate process serving only its own production; it has reached the point where it can be considered one of the business’s main activities. In such a case there is more than one main activity, and the higher class, that is the very hazardous class, applies. In borderline cases, carry out the assessment with your specialist and record the reasoning.

The deadlines for such a change are clear: a change of main activity is reported to the Ministry within 1 month; if the hazard class changes, the obligations required by the new class are fulfilled within 90 days. That is why the OHS budget should be considered together with investments such as a plating line or laser cutting when they are being planned.

The effect on the specialist class: A or B?

Under Art. 8/5 of Law No. 6331, the OHS specialist must hold an A-class certificate in very hazardous workplaces and at least a B-class certificate in hazardous workplaces. In a business moving from the hazardous to the very hazardous class, the assignment of a B-class specialist cannot therefore continue; an A-class specialist is assigned and the contract on ISG-KATİP (the Ministry’s online OHS registration system) is redrawn.

ObligationHazardousVery hazardous
OHS specialist certificateAt least B classA class
Specialist time (per employee/month)20 min40 min
Workplace physician time (per employee/month)10 min15 min
Other health personnelNot requiredRequired with 10 or more employees
Basic training12 hours16 hours
Refresher trainingEvery 2 yearsEvery year
Periodic examinationAt least every 3 yearsEvery year
Risk assessment renewalAt least every 4 yearsAt least every 2 years
First aider1 for every 15 employees1 for every 10 employees

Example calculation: a supplier with 120 employees

Let us assume the supplier above has 120 employees.

  • In the hazardous class: Specialist 120 × 20 = 2,400 min/month (40 hours), physician 120 × 10 = 1,200 min/month (20 hours). No DSP required. 8 first aiders.
  • In the very hazardous class: Specialist 120 × 40 = 4,800 min/month (80 hours), physician 120 × 15 = 1,800 min/month (30 hours). In the 50–249 employee range, 15 min per employee for other health personnel (DSP): 120 × 15 = 1,800 min/month (30 hours). 12 first aiders.

The specialist time doubles, DSP is added as a new item, training rises from 12 to 16 hours and is repeated every year, and periodic examinations for all employees become annual.

Two details are often overlooked in the calculation. First, apprentices and interns are not included in the calculation of specialist, physician and DSP times; suppliers employing vocational education students calculate the time based only on the number of employees. However, these persons are not excluded from training, risk assessment and health surveillance. Second, if a full-time workplace physician is assigned at the workplace, DSP is not required.

The content of training also changes with the class. The fourth topic group of basic training, job- and workplace-specific risks, is allocated at least 3 hours in the hazardous class and at least 4 hours in the very hazardous class, and this section is delivered face to face in both classes. The risks of a laser cutting or plating line should be covered separately within these hours. You can see your own workplace’s times with the OHS obligation calculator tool.

The effect on fines: the Art. 26/3 increase

The hazard class also changes administrative fines. Under Art. 26/3 of Law No. 6331, in workplaces with 50 or more employees, the base amount is increased by 50% for less hazardous, 100% for hazardous and 200% for very hazardous workplaces. This increase is not applied to fines calculated per employee (Art. 26/5).

Example: the 2026 base amount for failing to carry out a risk assessment is 66,725 TL. For the supplier with 120 employees, this amount becomes 133,450 TL in the hazardous class and 200,175 TL in the very hazardous class; an additional fine is applied for every month the breach continues. You can calculate other items with the OHS administrative fines tool.

Steps to verify your class

  1. Check the NACE code in your SGK workplace registration and its counterpart in the 2025 list.
  2. Verify that the hazard class shown on ISG-KATİP matches this code.
  3. List the work done on site: laser cutting, plating, welding, machining, assembly. Determine which is the main activity.
  4. If there is more than one main activity, use the higher class.
  5. If a new line or subcontract work has been added, put the 1-month notification and 90-day compliance period in the calendar.
  6. Update the specialist certificate, DSP, training and examination plan according to the new class.

In its occupational safety specialist service, Bursa Sistemer OSGB reflects a change of class in the contract, training and examination plan together. For sector risks, see our automotive supply industry and metal and machinery pages, and for the area with a high concentration of OIZs, see our Nilüfer page. We have gathered the full set of obligations by class in our articles on the hazardous class and the very hazardous class.

Frequently Asked Questions

Which hazard class is the automotive supply industry in?

It depends on the activity. In the 2025 list, the manufacture of parts and accessories for motor vehicles (29.32.20) and body parts (29.32.21) are in the hazardous class. If laser cutting or nickel plating is carried out as a main activity in the same business, the class may be very hazardous.

Is a workplace doing laser cutting very hazardous?

Yes. Laser cutting of metals (25.53.03) is in the very hazardous class in the 2025 list. If laser cutting is one of the main activities, the workplace is subject to the obligations of the very hazardous class.

Which class is a plating business in?

Nickel plating of metals (25.51.01) is in the very hazardous class. For other types of plating, check your own code separately in the 2025 list.

If our hazard class changes, how long do we have to comply?

A change of main activity is reported to the Ministry within 1 month. If the class changes, the specialist, DSP, training and examination arrangements required by the new class are completed within 90 days.

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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.

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