In brief
Risk assessment is the employer’s obligation and is carried out by a team made up of the employer, specialist, physician, employee representative and support staff. The legislation does not impose a specific method; it is enough to choose a method such as Fine-Kinney or an L-type matrix and state it in the document. The document is renewed every 2 years in very hazardous, 4 years in hazardous and 6 years in less hazardous workplaces, and immediately after an accident, a near miss or a significant change.
Whose job is risk assessment, and who should be on the team?
Risk assessment is the work of finding the hazards at the workplace, measuring how serious each one is and linking the measures to an owner and a date. Law No. 6331 on Occupational Health and Safety gives this job directly to the employer: the employer carries out or has carried out the risk assessment (Arts. 4 and 10). Obtaining the service from an OSGB (joint health and safety unit) does not remove this responsibility; the Law states this expressly (Art. 4/2). So as a factory manager or HR manager in Bursa, saying “the file is with the specialist” is not enough; the business itself owns the process.
Under Art. 6 of the Regulation on Occupational Health and Safety Risk Assessment, the team consists of:
- The employer or the employer’s representative,
- The OHS specialist and the workplace physician working at the workplace,
- The employee representative,
- Support staff,
- Workers who know the work carried out and the hazards, representing all units of the workplace.
The team may obtain outside support if necessary; coordination is taken on by the employer or a team member. The Regulation also requires workers’ views to be obtained at every stage where necessary (Art. 7/2). The most valuable information often comes from the person at the machine: the setter changing dies on the press line, the operator driving a forklift on the night shift or the worker preparing chemicals in the dyehouse knows hazards that cannot be seen from a desk.
Risk assessment in five steps
The Regulation starts the process at the design or establishment stage and moves through it in this order: identifying hazards, determining and analysing risks, deciding on control measures, documentation, updating and renewal where necessary (Art. 7). On site, it is practical to carry this out in five steps.
1. Identify the hazards
First, information is collected. Art. 8 of the Regulation lists the sources to look at: buildings and annexes, activities and work processes, work equipment, substances used, organisational structure, workers’ age, gender, education and health surveillance records, groups requiring special policies, inspection results, occupational accident and occupational disease records, near miss records, safety data sheets, workplace measurements, previous assessments and emergency plans. Accidents at similar workplaces may also be taken into account.
Hazards are identified by their physical, chemical, biological, psychosocial and ergonomic sources, also considering their interactions with each other. If measurements have not been taken before, the necessary measurements are carried out (Art. 8/4). We plan noise, dust or chemical measurements with authorised laboratories and enter the results in the assessment. On site, the most productive method is to walk through department by department with the team, see every shift at least once and ask workers: “What makes this job hardest for you?”
2. Analyse the risks
Each hazard is dealt with separately: how often harm could occur, and whom or what it would affect, how and with what severity, are determined, taking existing measures into account (Art. 9/1). Departments are assessed first separately, then as a whole, considering their interactions with each other. Finally, risks are ranked from highest to lowest and put in writing (Art. 9/5).
3. Decide on control measures
The choice of measures follows an order (Art. 10): first eliminate the hazard or its source; if that is not possible, replace the hazardous with the non-hazardous or less hazardous; if that is not possible either, combat the risk at source. Collective protection measures come before personal protection (Art. 10/2; Law, Art. 5/1-g). In other words, ear plugs are considered after enclosing the noisy compressor in a cabin. The measure chosen must not create a new risk.
4. Implement and assign owners
For each measure, an owner and a target date are set; implementation is tied to a plan (Art. 10/1-c). After the measure has been implemented, the risk is scored again; if it is still above the acceptable level, the steps are repeated (Art. 10/3).
5. Monitor and record
Whether the measures are actually implemented is monitored, and corrective action is opened for deviations (Art. 10/1-ç). The specialist’s findings and recommendations records, near miss reports and health surveillance findings are the main inputs to this monitoring.
Choosing a method: which method does the legislation require?
The short answer: none. The Regulation requires the analysis to be carried out with one or more methods chosen according to the nature of the work, the hazards, the constraints of the workplace or national and international standards (Art. 9/2). Fine-Kinney, the L-type matrix, FMEA and HAZOP are common in practice but are not named in the legislation. What matters is that you state the method chosen in the document and define its scales.
| Method | How does it work? | Where is it suitable? |
|---|---|---|
| L-type matrix (5×5) | Probability × severity; score from 1 to 25 | Workplaces with relatively limited hazards, such as offices, shops and small warehouses |
| Fine-Kinney | Probability × frequency × severity | Production facilities such as metal, automotive supply, furniture and plastics |
| FMEA | Scores failure modes in equipment or processes, their effects and detectability | Automated lines, suppliers working with a quality system |
| HAZOP | Questions process deviations with guide words (more, less, reverse…) | Chemicals, paint and coating lines, pressurised processes |
Fine-Kinney gives good results in most production facilities in Bursa because it takes the frequency of exposure into account as a separate multiplier: a die change done dozens of times a day and maintenance done once a year do not get the same score. You do not need to stick to a single method either; you can carry out the general assessment with Fine-Kinney and the process risks of the paint line with HAZOP.
Example scoring with Fine-Kinney
In Fine-Kinney, the risk score is calculated with the formula R = P × F × S. The scales below are values commonly used in practice in Türkiye; they come from the method itself, not from the legislation. Because labels may differ slightly between sources, attach the scale you use to the document.
- Probability (P): 0.2 not expected · 0.5 not expected but possible · 1 possible but unlikely · 3 quite possible · 6 very likely · 10 almost certain
- Frequency (F): 0.5 once a year or less · 1 a few times a year · 2 once a month · 3 once a week · 6 once a day · 10 continuous (once an hour or more often)
- Severity (S): 1 first aid level · 3 injury without lost working days · 7 injury causing lost working days · 15 loss of a limb, permanent damage or occupational disease · 40 fatality · 100 multiple fatalities
- Risk class: R < 20 acceptable · 20–70 possible risk, monitored · 70–200 significant risk, included in the action plan · 200–400 high risk, measures taken soon · R ≥ 400 intolerable, no work until measures are taken
Example: three hazards are scored at an automotive supplier workshop with 60 workers.
| Hazard | P | F | S | Before | Measure taken | After |
|---|---|---|---|---|---|---|
| Hand entering the die area on an eccentric press (two-hand control bridged) | 6 | 6 | 15 | 540 – intolerable | Bridge removed, light curtain fitted, lockout-tagout instruction and training for die changes | 0.5 × 6 × 15 = 45 – possible risk |
| Collision between a forklift and a pedestrian at the dispatch door | 3 | 6 | 40 | 720 – intolerable | Pedestrian walkway with barriers, mirror at the blind spot, speed limit, warning light on the forklift | 0.5 × 6 × 40 = 120 – significant risk |
| Slipping on an oily floor in machining | 3 | 6 | 7 | 126 – significant risk | Chip trays, drip trays, end-of-shift cleaning, non-slip flooring | 1 × 6 × 7 = 42 – possible risk |
The second row shows an important lesson: even after the measures, the forklift risk stays in the “significant” class because the severity of the possible outcome does not change. This risk stays in the action plan and is monitored regularly; if necessary, pedestrian crossing is closed completely during dispatch hours. In a real document, the owner of the measure and the target date are also written on each row.
How is the document prepared and signed?
In practice, pay attention to the following:
- Write the method at the beginning of the document and attach the scale tables. In an inspection, saying “Fine-Kinney was used” is not enough; it must be possible to read where the scores came from.
- Calculate the validity date according to your hazard class and enter it in the calendar.
- Do not forget subcontractors. The principal employer checks the subcontractor’s risk assessment; the subcontractor gives a copy of the document to the principal employer (Art. 15). In factories in OIZs (organised industrial zones), this point is often missed for maintenance, cleaning and canteen subcontractors.
- Know the fine. If no risk assessment has been carried out at all, the basic administrative fine for 2026 is 66,725 TL; 100,119 TL is applied every month the breach continues, and the amounts are increased according to the number of workers and the hazard class. For details, see the OHS administrative fines tool.
When is it renewed?
The risk assessment is renewed, according to the hazard class, at the latest at the following intervals (Art. 12/1):
| Hazard class | Renewal at the latest |
|---|---|
| Very hazardous | Every 2 years |
| Hazardous | Every 4 years |
| Less hazardous | Every 6 years |
If you are unsure of your class, see our hazard class guide. Even if the period has not expired, the assessment is renewed in full or for the relevant section in the following situations (Art. 12/2):
- Relocation of the workplace or changes to buildings
- Changes in technology, substances or equipment used
- Changes in the production method
- An occupational accident, occupational disease or near miss
- Changes in legislation setting limit values for the working environment
- When measurement or health surveillance results require it
- The emergence of a new hazard that may come from outside the workplace
The near miss item is the one most often missed. An event in which no one was injured (a load that toppled but hit no one, a sling that snapped but was unloaded) is also a reason to update the assessment. For the post-accident process, see our article on the first 72 hours after an occupational accident. To track renewal dates together with training, examination and drill dates, you can use the OHS renewal calendar.
The most common mistakes found in inspections
- Using a ready-made template. Another company’s hazard list does not describe your line. Two factories in the same OIZ with the same NACE code have different machinery and workflows.
- Not stating the method and scale. If it is not written which table the scores were given against, the results cannot be defended.
- Leaving measures without an owner and date. “The necessary measures will be taken” is not a measure.
- Writing PPE as the first solution. The order in the legislation is first elimination, substitution and collective protection.
- Setting up an incomplete team. A document prepared only by the specialist, without the participation of the employee representative and support staff, does not comply with the Regulation.
- Not entering measurement and health surveillance results. If a noise measurement exceeds 85 dB(A), this finding must go into the action plan.
- Leaving updates to the validity period. When a new line is installed, waiting for four years to pass would be wrong.
In our risk assessment service, we carry out these steps on site together with your business’s team; within our OHS specialist service, we also continue to follow up the measures.
Frequently Asked Questions
Can the employer carry out the risk assessment themselves?
The employer or their representative is a natural member of the team, but the assessment is not a one-person job; the team includes the OHS specialist and workplace physician, the employee representative, support staff and workers representing the units. In less hazardous workplaces with fewer than 50 workers, the employer or their representative can provide OHS services themselves (excluding pre-employment and periodic examinations) if they complete the training announced by the Ministry.
Which method is more valid: Fine-Kinney or the L-type matrix?
The legislation does not impose a method; it is enough to choose the method suitable for your work, state it in the document and attach its scale. In production facilities, Fine-Kinney, which also takes frequency into account, and in small and less hazardous workplaces, the L-type matrix gives practical results.
How many years is a risk assessment valid?
At most 2 years in very hazardous, 4 in hazardous and 6 in less hazardous workplaces. However, it is renewed before the period expires in situations such as an occupational accident, a near miss, new equipment, relocation or a change in production method. The validity date must be written in the document.
How do near misses affect the risk assessment?
Near miss records are one of the information sources listed in the Regulation, and a near miss that occurs is a reason for renewal. Art. 14 of Law No. 6331 also obliges the employer to investigate events with the potential to cause harm and to prepare reports. A simple reporting form and quick feedback strengthen workers’ reporting habits.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.