In brief
Safety culture is how work gets done when nobody is watching, and it is not built by writing procedures. Three levers are decisive: management's visible involvement on the shop floor, not punishing people who report near misses and errors, and genuine worker participation in decisions. Law No. 6331 already provides the legal basis for all three; what is missing is making them part of everyday practice.
What is safety culture, and why can't it be built with procedures?
Safety culture is how work gets done in a workplace when nobody is watching. The instruction is on the noticeboard, the training record is signed, the risk assessment is in the file; yet the light curtain is bypassed to finish before the end of the shift, and someone climbs the rack without a harness because it is "a one-minute job". The gap between the system on paper and behaviour on the shop floor is the measure of the culture.
Law No. 6331 actually lists the tools to close this gap. Among the principles of protection from risks is "developing a coherent and overall prevention policy covering the effects of factors related to technology, work organisation, working conditions, social relationships and the working environment" (Art. 5). Consulting workers and their participation (Art. 18), the worker representative (Art. 20) and the right to refuse to work in serious danger (Art. 13) are also the legal foundation of culture. In this article we explain step by step how to put that foundation to work on site.
Which stage is your safety culture at?
Before starting to build a safety culture, take an honest look at where you are. A five-stage model widely used in practice classifies organisations by their attitude to accidents:
| Stage | What is said after an accident? | Typical picture |
|---|---|---|
| Pathological | "It wouldn't have happened if he'd been careful." | Panic before inspections, PPE only when the inspector comes |
| Reactive | "Never again, write everyone up." | A new rule after an accident, then forgotten |
| Rule-focused | "There was a procedure, it wasn't followed." | Plenty of forms, little site presence; figures are tracked, nothing is learned |
| Proactive | "We should have seen this from the near misses." | Reporting is encouraged, managers are on site |
| Generative | "The team had already stopped that." | Workers stop risky work themselves, nobody questions it |
In places under heavy audit pressure, such as companies in Bursa and the surrounding provinces that make parts for vehicle manufacturers, it is easy to get stuck at the "rule-focused" stage: the files are tidy but information does not flow up from the shop floor. Moving to the next stage takes not more forms but the steps below.
Step 1: Management commitment to OHS must be visible on site
Workers look not at what managers say but at what they spend time on. Show management commitment not with a signature on the OHS policy but with these behaviours:
- Regular site walks. The general manager or plant manager walks the line at set intervals together with the OHS specialist, and on the walk asks "what makes this job hardest for you?" instead of "why aren't you wearing PPE?".
- Authority to stop production. Back the worker who stops work when they see serious danger. Art. 13 of the Law already recognises the right to refuse to work in serious and imminent danger; the manager's first reaction to this sets the direction of the culture.
- Assign a deadline and an owner to each reported shortcoming. Carrying out the measures that the workplace physician and the OHS specialist write in the approved logbook or report in writing is the employer's obligation (Law Art. 6 and Art. 8). Items left open send the message "even if you speak up here, nothing changes".
- Outsourcing the service does not transfer responsibility. Working with an OSGB (joint health and safety unit) does not remove the employer's responsibility (Art. 4/2). Culture is built with the company's own managers; the specialist makes this easier.
Step 2: A system that does not punish people who report
The most sensitive point of culture is reporting. A worker who reports a near miss and finds themselves in front of a disciplinary committee the next day will not report again, and the company loses the chance to see the next accident coming. The Law requires the employer to investigate and report incidents that have the potential to cause harm even if they do not result in injury or death (Art. 14/1-b). The raw material of that investigation is the worker's report.
For a fair approach, set out three distinctions clearly in writing:
- Honest error: Pressing the wrong button, skipping a step. The system question is asked: was the instruction clear, are the buttons easily confused?
- At-risk behaviour: Shortcuts, habits. Coaching is needed, along with a review of the incentives in the system.
- Deliberate violation: Intentionally disabling safety equipment. Sanctions may apply here, but first ask what encouraged it.
Keep the reporting system simple: a QR code, a short paper card or a verbal report to the foreman. Respond to every report within a set time and share the outcome on the noticeboard. A report that gets no response is the end of the reporting system. We covered how to carry out a root cause analysis after an accident in our article on the first 72 hours after a workplace accident.
Step 3: How do you achieve worker participation in safety?
The Law requires the employer to consult workers or their representatives and ensure their participation. In particular, support staff and worker representatives are consulted in advance on the risk assessment, the selection of protective equipment, the training plan and assignments (Art. 18/2). The number of worker representatives depends on the size of the workplace:
| Number of workers | Worker representatives |
|---|---|
| 2–50 | 1 |
| 51–100 | 2 |
| 101–500 | 3 |
| 501–1,000 | 4 |
| 1,001–2,000 | 5 |
| 2,001 and above | 6 |
In workplaces with 50 or more workers where continuous work lasting longer than six months is carried out, an occupational health and safety committee must also be set up (Art. 22). Stop the committee being a body that only produces meeting minutes: make the first agenda item every month the previous month's reports.
Effective ways to make participation concrete:
- Include a worker who does the job in the risk assessment team.
- Have workers try out new gloves, masks or safety shoes before they are purchased.
- Have workers take turns giving the five-minute talk at the start of the shift, rather than the foreman.
- Announce clearly that workers or their representatives cannot have their rights restricted because they applied to the competent authority (Art. 18/3).
Step 4: Link OHS awareness to behaviour
OHS awareness is formed at the machine, not in the training room. The training regulation that came into force in 2026 supports this approach: induction training lasts at least two hours and is face-to-face and practical; job- and workplace-specific risks are covered face-to-face in hazardous and very hazardous workplaces. Details are in our article on the new training regulation.
To link training to culture:
- Explain the reason for the rules; not "wear a harness", but "what nearly happened on this rack last month".
- Prepare foremen as trainers; workers do what their own supervisor does.
- Teach PPE use through hands-on practice; the regulation on the use of PPE explicitly requires this.
Step 5: Measure the right thing
A company that tracks only the number of accidents believes it is doing well as long as there are no accidents. "Accident-free days" boards can even suppress reporting: a worker who does not want to be the one who resets the counter hides a minor injury. Add leading indicators alongside the lagging ones:
- Near miss reports per month and the time taken to close them,
- The number of site walks carried out by managers,
- The age of open items in the approved logbook,
- The proportion of workers whose training has been verified by observation on site.
An increase in the number of reports in the first months is a good sign: it shows trust is forming. If you set up an incentive scheme, reward reporting and preventive suggestions, not the absence of accidents.
Common mistakes in culture work
The same traps appear again and again in companies that apply these steps. Discuss them with your team before you start:
- Campaign thinking. Organising an "OHS week" and putting up posters ends with a return to the old ways the following week. Culture needs continuity, not campaigns.
- Multiplying rules. Adding a new rule after every incident lowers the value of rules in workers' eyes. First ask why the existing rule is not being followed.
- Bypassing the foreman. The bridge between management and workers is the foreman and the shift supervisor. They feel production pressure most; if they are not supported, the message does not reach the shop floor.
- Turning reporting into a number. A target of "every worker reports two near misses a month" produces made-up reports. The target is not a number but the quality with which reports are closed.
- Leaving subcontractors out. Subcontractor workers working in the same area must also be included in the reporting system and the shift talks. The Law requires employers sharing the same work area to work in cooperation and coordination (Art. 23).
- Not sharing the outcome. A worker who does not see how a reported risk was dealt with will not believe the system works.
You can see the number of representatives, committee members and first aiders for your company's size with the OHS obligation calculator. Planning site walks, setting up the reporting system and foreman training can be carried out together with our OHS specialist services and OHS training. Companies that make parts for vehicle manufacturers should also see our automotive supplier industry page.
Frequently Asked Questions
How long does it take to change a safety culture?
It would be wrong to give a single figure. Behaviour change can begin within weeks; but for workers to trust the reporting system, they need to see consistent management behaviour for months. That is why you should track leading indicators regularly.
Can culture work be done in a small business too?
Yes, it is even easier. In a ten-person workshop, the employer being on the shop floor every day, collecting near misses verbally and holding a five-minute talk once a week is often a sufficient start. Appointing one worker representative in a workplace with 2–50 workers is also required by the Law.
Do accident-free bonuses work?
A bonus tied to the number of accidents carries the risk of suppressing reporting. The behaviour to reward is not the absence of accidents but reporting risks, suggesting measures and stopping unsafe work.
Can near miss reports be anonymous?
Yes. Opening an anonymous reporting channel while trust has not yet formed can increase the number of reports. As trust grows, moving to named reports and direct feedback speeds up learning.
A certified specialist matched to your hazard class: site inspections, approved logbook, training plan, annual plan and report follow-up.