In brief
An internal OHS audit is a planned self-assessment that tests the workplace's compliance with legislation at least once a year, using a checklist and looking at documents, the site and employees. It is not named in the legislation, but it is the most systematic evidence of the employer's duty to monitor and check whether measures are being followed. If you grade findings by severity and close them with an owner and a deadline, a labour inspection becomes an external repeat of the same list.
What is an internal OHS audit, and how does it differ from a site walk?
An internal OHS audit means testing your workplace's compliance with OHS legislation with your own team, in a planned and documented way, before an external auditor arrives. There is no requirement named "internal audit" in the legislation. However, Art. 4/1-b of Law No. 6331 on Occupational Health and Safety requires the employer to monitor and check whether the measures taken are being followed and to ensure that nonconformities are eliminated. Under Art. 4/2, obtaining services from experts and organisations outside the workplace does not remove the employer's responsibilities. An annual internal audit is the most systematic and most easily proven form of this obligation.
An internal audit needs to be distinguished from two practices it is often confused with:
| Site walk | Internal OHS audit | Labour inspection | |
|---|---|---|---|
| Frequency | Weekly or monthly | At least once a year | Programmed, or following a complaint or accident |
| Who carries it out? | Manager, specialist | Internal team independent of the audited department | Ministry labour inspectors |
| Focus | Observation on site | Documents, site and interviews; linked to articles of legislation | Compliance with legislation |
| Output | Observation form, quick action | Graded findings report, action plan | Findings, administrative sanctions, stopping work if necessary |
For how to organise a site walk see our article on the OHS site walk checklist. In ISO 45001 certified workplaces an internal audit is a requirement of the standard; for workplaces without certification it is good practice. The general structure of the standard is covered in our article what is ISO 45001.
OHS internal audit form: scope and checklist headings
An OHS internal audit form is a checklist in which every line is tied to a legal obligation. A line does not just ask "does it exist?"; it also asks "is it up to date and is it applied?". The main headings:
| Heading | Legal basis | Evidence required | Sample audit question |
|---|---|---|---|
| Appointment of specialist, physician, DSP | Law 6331 Art. 6 | Approved contracts on ISG-KATİP (the Ministry's online OHS registration system) | Headcount has increased; have service times been updated? |
| Risk assessment | Law 6331 Art. 10 | Signed document, team, renewal date | Has it been updated since the last machine change? |
| Emergency plan and drill | Law 6331 Art. 11 | Plan, team list, drill form | Has more than a year passed since the last drill? |
| Training | Law 6331 Art. 17; 2026 training regulation | Induction records, basic and refresher training records | Did new starters complete basic training within 3 months? |
| Health surveillance | Law 6331 Art. 15 | Pre-employment and periodic examination records | Is anyone working in a hazardous job without a medical report? |
| Periodic inspection of work equipment | Work Equipment Regulation Annex III | Inspection reports | Is there any lifting equipment with an overdue inspection? |
| Workplace environment measurements | Law 6331 Art. 10 | Reports from an authorised laboratory | Were measurements repeated after a process change? |
| Accident and near miss records | Law 6331 Art. 14 | Incident records, SGK (Social Security Institution) notifications | Were notifications made within three working days? |
| Approved logbook | Regulation on OHS Services Art. 7 | Findings and recommendations, employer's signature | Is the closure of recommendations tracked? |
| Employee representative and committee | Law 6331 Art. 20, 22 | Election minutes, committee minutes | Does the committee meet regularly? |
| Subcontractor coordination | Law 6331 Art. 23 | Subcontractor documents, coordination records | Have the training certificates of the maintenance company's employees been checked? |
| Vocational training certificates | Law 6331 Art. 17/3 | Copies of certificates | Is anyone working without a certificate in a job that requires one? |
Our article on OHS file contents guides you in preparing the documentary side of the list. Update the form every year in line with changes to the legislation. For example, the 2026 training regulation changed the content of training records, and the renewed Annex III of 23 December 2025 changed the periodic inspection lines; the Machinery Safety Regulation, most of whose provisions will enter into force on 20 January 2027, also affects the documents to be checked when buying new machinery.
OHS compliance audit step by step
- Plan. Set the date, the scope (the whole workplace or certain departments), the audit team and last year's open findings. The team must be independent of the department it audits; the maintenance supervisor should not audit their own department.
- Review the documents. See the evidence for every line on the checklist. Tick "exists" only after opening the document and seeing its date and signature.
- Go on site. Compare what is written in the documents with what happens on site: is the guard listed in the risk assessment fitted to the machine, and is the assembly point in the emergency plan marked and clear?
- Talk to employees. Ask a few employees from each department three simple questions: "Where do you assemble in an emergency?", "What is the biggest risk in your job?", "Who do you tell when you see a hazard?" The answers show the real effect of training.
- Hold a closing meeting. Share the findings with department managers; correct misunderstandings before reporting.
- Report. For each finding, write down the evidence, the legal basis and its grade.
- Track and verify actions. Check every closed action on site; do not close it on paper.
Grading findings
Presenting all findings in the same list with the same weight causes the critical ones to get lost. A four-level scale is sufficient for most workplaces. Target closure times are the workplace's own decision; those below are examples.
| Grade | Definition | Example | Sample target |
|---|---|---|---|
| Critical | A situation that may pose a danger to life or lead to work being stopped | Press with its guard removed, locked emergency exit | Same day; work is stopped |
| Major | A legal obligation has not been fulfilled | Overdue risk assessment, employee who has not received basic training | 30 days |
| Minor | The obligation is met but the document or practice is partly incomplete | Missing signature on a training record, no evaluation on a drill form | 90 days |
| Opportunity for improvement | Good-practice suggestion beyond the legislation | Making near miss reporting easier | In the annual plan |
Tracking audit findings
If audit findings are not followed up, the internal audit amounts to nothing more than an annual report. For effective follow-up:
- Action list: For each finding, the root cause, the work to be done, the responsible person and the deadline.
- Root cause: The root cause of a "training record missing" finding is often the lack of a process for new starters; simply completing the missing record does not solve the problem. For methods see our article on root cause analysis methods.
- Repeat findings: Flag separately any finding that also appeared in the previous audit; repetition shows that the system is not working.
- Indicators: The number of open findings and the percentage of actions closed on time are two simple indicators to present to management. Our article on OHS performance indicators guides the choice of indicators.
- Transfer to the plan: Findings that take time to close go into the annual work plan. For the structure of the plan see our article on how to prepare an annual work plan.
A new hazard or an inadequate measure found in the audit should also be entered in the risk assessment. In this way the internal audit becomes an input that keeps the risk assessment alive.
Link to labour inspection readiness
The lines of the internal audit form and the documents a labour inspector requests during an inspection are largely the same. A workplace that carries out its internal audit with this list does not need fresh preparation when the inspector arrives; the latest internal audit report, closed actions and an up-to-date document index are already on the table. We explained how an inspection proceeds and what the inspector looks at on site in our article on preparing for a labour inspection. To see which shortcoming meets which administrative sanction, you can use our OHS administrative fines tool.
Many manufacturers in Bursa and the surrounding provinces, especially in the automotive supply industry, also go through customer audits during the year. The same internal audit form is the basis for preparing for those audits as well; for customer expectations see our article on preparing for OEM supplier OHS audits.
As part of our OHS specialist service, we plan the annual internal audit with a legislation checklist, grade findings and link them to an action list, and verify closures on site during subsequent visits. You can track audit and document renewal dates with our OHS calendar tool.
Frequently Asked Questions
Is an internal OHS audit a legal requirement?
There is no requirement under the name "internal audit". However, Art. 4 of Law No. 6331 requires the employer to monitor and check whether measures are being followed. An annual internal audit is the most systematic evidence that you fulfil this obligation. In ISO 45001 certified workplaces, an internal audit is a requirement of the standard.
Who should carry out the internal audit?
A team that knows the legislation and the work processes but is independent of the audited department. The OHS specialist can lead the team; one person each from production, maintenance and human resources, plus the employee representative, strengthen it.
How often should an internal audit be carried out?
Once a year is a good starting point for a comprehensive compliance audit. In very hazardous workplaces, after major changes or when many critical findings arise, the interval can be shortened. Weekly site walks do not replace this audit; they complement it.
Is an OHS self-assessment the same as an internal audit?
They serve a similar purpose. A self-assessment is usually a department manager checking their own area against a list; an internal audit is a more comprehensive review by an independent team looking at documents, the site and employees. The two can be used together.
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.