How to Prepare an Annual OHS Training Plan

The annual training plan: what does OHS legislation require?

In many businesses, the annual training plan is a one-page table prepared at the start of the year and filed away. Workers hired mid-year, refresher training falling due and the night shift do not appear in this table. Yet a good OHS training plan is a living calendar showing, person by person, who will receive which training and when.

The legal basis is the Regulation on the Procedures and Principles of OHS Training for Workers of 2 April 2026. We summarised what is new in the regulation in our article on the new OHS training regulation; here we focus on planning.

The annual training programme should not be confused with the annual work plan prepared jointly by the specialist and the physician. The work plan covers all OHS activities; the training programme is a detailed part of it.

Step 1: From the employee list to a training matrix

The plan starts with the current employee list registered with SGK. Collect the following information for each worker in a single table:

• Name and surname, start date, department and job,
• Shift,
• Date basic training was completed and date of the last refresher training,
• Special role: support person, first aider, employee representative,
• Whether they work in a job requiring a vocational training certificate,
• Special circumstances: absence from work for more than 6 months, having had a work accident, pregnant or breastfeeding worker, worker under 18.

This table is the raw data for the training matrix. The matrix lists jobs in the rows and training types in the columns, and shows which training each job requires:

Each job has different special training needs: see our articles on working at height training for those working at height, support staff training for team members, and the vocational training certificate for jobs requiring a certificate.

Step 2: Set out the training types and durations

The durations and periods of the 2026 regulation are as follows:

The topic of job- and workplace-specific risks is delivered face-to-face in hazardous and very hazardous workplaces; general, health and technical topics can be delivered remotely. The exam requires at least 60 out of 100; there are at most two resits. For the content of the topic groups see our article on basic OHS training topics, and for the induction programme see our article on induction training.

Step 3: Put refresher training on the calendar

Refresher training planning is the most frequently overlooked task of the year. Each worker's refresher date is calculated from the date their own basic training or last refresher was completed. In practice, the safest approach is to count the period from the date the last training was completed and finish before it falls due.

Example: An automotive supplier plant in Bursa with 140 workers in the hazardous class is preparing its 2027 plan. The refresher period is 2 years.

• 80 workers completed basic training in March 2025: their refresher training must be finished by March 2027 at the latest.
• 45 workers completed it in October 2025: their refreshers must be done by October 2027.
• The 15 workers who joined in 2026 took basic training within 3 months of starting: their refreshers fall in 2028.

The 2027 plan includes 8-hour refresher training for 125 people. If groups are limited to 20 people, 4 groups are needed for March and 3 for October; 56 lesson hours are planned on the trainer's side. For workers joining during the year, a basic training session is left open every month. You can work out these dates with the OHS calendar tool.

Step 4: An OHS training calendar by shift and hazard class

The calendar is built not on paper but on top of the shift roster. Points to watch:

• Shifts: In a three-shift plant, open a separate session for each shift. Basic training can be split into parts of at least one hour each; this makes it easier for the night shift to receive training during their shift.
• Overtime: Training scheduled after working hours counts as overtime if it exceeds the weekly hours. Allow for this in the budget and in timekeeping.
• Hazard class: In the very hazardous class, refresher training covers everyone every year; spread the workload over 12 months. In the hazardous class, balance it so that roughly half the workers take their refresher one year and the other half the next.
• Production calendar: Do not schedule training during busy order periods or before public holidays; maintenance shutdowns are a good opportunity for training.
• Linked dates: Schedule the emergency drill, held at least once a year, close to the support staff training. A first aid certificate is valid for 3 years, and the refresher training is taken within the 3 months before it expires.

You can build the skeleton of the year with a training plan example like this:

Step 5: Approval, records and updating

The employer approves the plan; seek the views of workers or their representatives during preparation and show this with a signed record. In workplaces with an OHS committee, also take the plan to the committee agenda.

A record is kept for each session. For face-to-face training, the record includes the venue, date, names, surnames and signatures of participants and the trainer, duration and topics. Those who successfully complete basic training are issued a certificate following the template in the annex to the regulation, which is kept in the personnel file.

Reopen the plan in the following situations: when legislation changes, when a new machine, chemical or process is introduced, when there is a work accident and when new workers are hired. The 2026 basic administrative fine for failing to provide training is 8,980 TL per worker, and no hazard class increase is applied to this per-worker fine; for the calculation, see the OHS administrative fines tool.

Common mistakes are: the plan shows only total hours, with no person-by-person tracking; the night shift has never received training; refresher dates have been calculated from the start of the year rather than from each person's own date; subcontractor workers' certificates have not been checked. For planning and delivering training, see our OHS training page.

Frequently Asked Questions

Who prepares the annual training plan?

Under the regulation, the employer has the annual training programme prepared and approves it. In practice, the OHS specialist prepares the programme together with the workplace physician and submits it for the employer's approval; the views of workers or their representatives are sought during preparation.

Can training be held outside working hours?

It can, but training time counts as working time. Training hours exceeding the weekly working time are treated as extra hours or overtime and paid accordingly. The cost of training cannot be passed on to the worker.

From which date is the refresher period counted?

The regulation gives the refresher period in years. The safest practice is to count the period from the date the worker's basic training or last refresher was completed, and to finish the training before that date is reached.

How are mid-year starters added to the plan?

Induction training is given before starting work; basic training is completed within 3 months at the latest. So put a basic training session on the calendar every month or every two months, and enrol new workers in the first suitable session.