In brief
The hazard class is determined not for the company but for the workplace, based on the main activity carried out there. An administration building inside the factory campus and within the same registration and organisation as the factory is, as a rule, part of the factory; the class of a head office or sales office at a separate address with a separate SGK registration is determined by its own main activity. If the activity code on the registration does not reflect the actual work, it is corrected through the SGK record or an objection to the Ministry; if the class changes, the new obligations are fulfilled within 90 days.
What determines the hazard class of a head office?
A structure often found in Bursa is this: production is in an OIZ (organised industrial zone) in Nilufer, while the general management and sales team are in a business centre in the city centre. When requesting a quote or making assignments in ISG-KATIP (the Ministry's online OHS registration system), the question arises: "Our factory is in the hazardous class; is the head office hazardous too?" The hazard class of a head office is determined not by the company's name or main line of business but by the workplace.
The basis is two texts:
- Art. 9 of Law No. 6331 on Occupational Health and Safety states that workplace hazard classes are determined by a communiqué issued by the Ministry.
- Under Art. 2/1 of the Communiqué on Workplace Hazard Classes, the hazard class of the main activity carried out at a workplace is taken into account in determining the hazard class.
The key phrase here is "at a workplace". Different workplaces of the same company can be in different classes; so the right question is not "which class is our company in?" but what the hazard class is workplace by workplace. But it is necessary to establish correctly which structure is a separate workplace and which is part of the factory. The definition of workplace in Art. 3 of Law No. 6331 counts places attached to the workplace and annexes such as rest, dining, examination and training areas and yards as part of the workplace organisation.
Three scenarios: same campus, separate address, sales office
The situations met in practice can be summarised in this table:
| Scenario | SGK registration | How is the hazard class determined? |
|---|---|---|
| Administration building on the factory campus, in the same organisation as the factory | Same registration as the factory | There is one workplace; its class is set by the factory's main activity. Administrative staff are also employees of this workplace |
| Head office at a separate address, only management, accounting and purchasing work | Separate registration | The office's own main activity is considered; the code on the registration must describe this work correctly |
| Regional or sales office at a separate address | Separate registration | Its own code and class according to the sales and marketing activity |
| Head office building also housing a prototype workshop, laboratory or sample store | Separate registration | If there is more than one main activity, the higher hazard class applies (Communiqué Art. 2/3) |
The last row deserves particular attention. Art. 2/3 of the Communiqué states that, in case of doubt in determining the main activity, the purpose for which the workplace was established is considered, and that if activities fitting more than one main activity definition are carried out, the higher hazard class applies. If there is a workshop in the basement of the head office building where trial production is carried out, the class of that workplace can no longer be determined on the basis of "office" alone.
Separate SGK registration and hazard class: where does the code come from, and how is it corrected?
When a head office is opened at a separate address, a workplace notification is made to the Social Security Institution (SGK) and an activity code is assigned to the workplace. This is where the problem can start: the new registration may have been opened with the company's main activity code without looking at the work done in the office. In this case an office containing only desk-based workers appears on paper in the factory's class.
The consequences are concrete:
- The specialist must hold at least a class B certificate for the hazardous class (Art. 8/5).
- Specialist and physician times double.
- Basic training becomes 12 hours instead of 8 and is repeated every 2 years instead of every 3.
- Periodic medical examinations are done every 3 years instead of every 5.
The reverse can also happen: a production section belonging to the factory may remain registered under an administrative registration, and workers in this section are followed with less hazardous obligations. The route is the same in both cases. If the code does not reflect the actual main activity, it is corrected through the SGK workplace record together with your accountant. If the code is correct but the class is disputed, the Ministry assesses the objection under Art. 3 of the Communiqué; the assessment is made on the basis of the registration records and the main activity on which registration was based. If it emerges in an inspection that the main activity differs from the registration record, the class may be redetermined.
The time limits are clear: a change of main activity is notified to the Ministry within one month at the latest (Art. 2/2). If the decision leads to a change of hazard class, the work and procedures required by the new class are completed within 90 days and notified to the General Directorate of Occupational Health and Safety (Art. 3/4). For the general method, see our article on how to find out your hazard class, and for the changes in the 2025 list, our article on NACE Rev.2.1 hazard class changes.
OHS in the administration building: obligations continue even when the class is lower
If a head office with a separate registration is in the less hazardous class, the obligations become lighter but do not disappear. The table below shows the differences between a less hazardous head office and a factory in the hazardous class:
| Obligation | Head office (less hazardous) | Factory (hazardous) |
|---|---|---|
| Specialist certificate | At least class C | At least class B |
| Specialist time (per employee, monthly) | 10 minutes | 20 minutes |
| Physician time (per employee, monthly) | 5 minutes | 10 minutes |
| Basic training | 8 hours; repeated every 3 years | 12 hours; repeated every 2 years |
| Periodic medical examination | At least every 5 years | At least every 3 years |
| Risk assessment renewal | At least every 6 years | At least every 4 years |
| First aider | 1 per 20 employees | 1 per 15 employees |
At less hazardous workplaces with fewer than 50 employees, monthly times may be combined within the same contract year, and the employer or their representative may carry out the service themselves by completing the Ministry training; pre-employment and periodic medical examinations are excluded from this. For risks specific to office workplaces, see our article on an office risk assessment example.
Example calculation: an automotive supplier company in Bursa
Let us assume an automotive supply industry company has 220 employees at the factory where it makes brake parts and 30 employees at the head office in the city centre. The factory is in the hazardous class with code 29.32.20.
| Situation | Specialist (min/month) | Physician (min/month) | Specialist certificate |
|---|---|---|---|
| Office on a separate registration, with a less hazardous code suited to office activity | 30 × 10 = 300 | 30 × 5 = 150 | At least C |
| Office on a separate registration but opened with the factory's code | 30 × 20 = 600 | 30 × 10 = 300 | At least B |
| Factory (in both cases) | 220 × 20 = 4,400 | 220 × 10 = 2,200 | At least B |
The difference in the second row is not only time; office workers are unnecessarily scheduled for 12 hours of basic training and examinations every 3 years, while topics that are their real risks, such as display screen equipment, ergonomics and emergencies, may be pushed into the background. Remember that assignments are made separately for each registration; for the ISG-KATIP arrangement in multi-branch structures, see our article on OHS contracts for multi-branch businesses. To calculate with your own figures, you can use the OHS obligations calculator tool.
Office workers who go out on site
Working at the head office does not mean never entering the factory. Quality engineers, purchasing specialists, project managers and senior management regularly go down to the production floor; some visit customer and supplier facilities. Even if the office's class is less hazardous, the real exposure of these workers should be included in the risk assessment:
- The rules they will follow and the PPE they will use when going to the factory should be defined, and an entry briefing given on the factory side.
- The training content of office workers who regularly work on site should also cover the risks of these visits.
- The workplace physician should plan these workers' health surveillance according to the risks they are actually exposed to, not according to desk work.
- Traffic risks should be added to the assessment for workers who travel often in company vehicles.
Steps to check
- List all of the company's SGK workplace registrations with address, activity code and number of employees.
- Write the work actually done at each registration in one sentence and compare it with the code description.
- Verify the hazard class of each code from the current list; if there is more than one main activity, use the higher one.
- Check in ISG-KATIP that specialist and physician assignments for each registration are made correctly with certificate class and time.
- If there is a mismatch, start correcting the SGK record; if the class changes, enter the 90-day period into the calendar.
At businesses in Bursa and the surrounding provinces structured with different registrations, Bursa Sistemer OSGB carries out this check together with the client at the start of our OHS specialist services and plans the time and certificate class of each workplace correctly. For businesses whose factory is in the Nilufer OIZs and whose office is in the city centre, we also build the visit plan around this distinction.
Frequently Asked Questions
Does the company headquarters have to have the same hazard class as the factory?
No. If the headquarters is registered as a separate workplace on a separate registration, its class is determined by the main activity carried out there. If it is inside the factory campus, on the same registration and in the same organisation as the factory, it is as a rule part of the factory and subject to the factory's class.
What should we do if the code on the head office's registration is wrong?
If the code does not reflect the actual main activity, it is corrected through the SGK workplace record together with your accountant. If the code is correct but you object to the class, you apply to the Ministry under Art. 3 of the Communiqué.
Is a single OSGB contract enough for the head office and the factory?
You can work with the same OSGB (joint health and safety unit), but assignments in ISG-KATIP are made separately for each registration. Times and specialist certificate class are calculated according to each workplace's own number of employees and hazard class.
Does the class change if office workers go to the factory often?
The class of the office workplace does not change; the class is determined by the main activity carried out there. But these workers' risks at the factory should be taken into account in the risk assessment, training content and health surveillance.
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.