In brief
Because the minimum monthly time for the specialist, physician and DSP changes directly with the number of employees, the minutes in the contract and on ISG-KATİP must be recalculated when the number increases. Thresholds such as 10, 50 and 250 change not only the time but also other obligations such as DSP, the OHS committee and the employee representative. The updated appointment is approved by the parties within 5 days at the latest.
Why is the OHS contract updated when headcount rises?
The minimum time in the legislation for the OHS specialist, the workplace physician and, where required, other health personnel (DSP) is defined in minutes per employee. So when the number of employees rises, the OHS contract must also be updated: an appointment made for 38 people no longer meets the minimum time when 55 people are working at the workplace. In practice this situation is called an under-hours appointment.
The problem usually arises not from bad faith but from a gap in tracking. The contract is renewed once a year, while hiring continues all year. A new line opens, a shift is added for a seasonal order, and nobody looks at the minutes in the OHS contract. This article explains how to recalculate the time when the number changes, which thresholds trigger other obligations and how the update is completed on ISG-KATİP (the Ministry's online OHS registration system).
Which number of employees is used?
The Regulation on OHS Services does not define a general method for determining from which month's, or which record's, average the number of employees for the time calculation is taken. The place where the Regulation explicitly relies on SGK records is where the employer takes on the service in less hazardous workplaces with fewer than 50 employees (Art. 14/6). The only known exception in the time calculation is that apprentices and interns with student status are not included in the total number of employees (Art. 5/9).
In practice, the link between the SGK headcount and OHS time is established as follows:
- The time is required for those actually working at the workplace. The Law's definition of "employee" does not look at status; permanent, temporary and part-time staff all count.
- The most concrete document for this number is the monthly declarations submitted to the SGK. This is also the record that may be compared in an inspection.
- If the number fluctuates within the month, using the highest number eliminates the risk of under-hours.
It is best to resolve this uncertainty in the contract: write which record will be used, at what interval the check will be made and by how much the number must change for the time to be revised. For other clauses to add to the contract, see our article on OSGB contract clauses.
Recalculating specialist and physician minutes
The minimum times are set in Art. 12 of the Regulation on Workplace Physicians and DSP and of the Regulation on OHS Specialists:
| Appointee | Less hazardous | Hazardous | Very hazardous |
|---|---|---|---|
| OHS specialist (per employee/month) | 10 min | 20 min | 40 min |
| Workplace physician (per employee/month) | 5 min | 10 min | 15 min |
| DSP (very hazardous only) | — | — | 10–49 employees: 10 min; 50–249: 15 min; 250+: 20 min |
| 1 full-time specialist | per 1000 employees | per 500 employees | per 250 employees |
| 1 full-time physician | per 2000 employees | per 1000 employees | per 750 employees |
Example 1: hazardous class, from 38 to 55 employees. Consider an automotive supplier workshop in Bursa:
- Specialist: 38 × 20 = 760 min (12 h 40 min) → 55 × 20 = 1,100 min (18 h 20 min). Difference: +340 min.
- Physician: 38 × 10 = 380 min (6 h 20 min) → 55 × 10 = 550 min (9 h 10 min). Difference: +170 min.
Example 2: very hazardous class, from 48 to 52 employees. The specialist's time rises from 1,920 minutes to 2,080 minutes and the physician's from 720 minutes to 780 minutes. For DSP, however, the band changes: from 48 × 10 = 480 min to 52 × 15 = 780 min. An increase of just 4 people creates a difference of 300 minutes in DSP time.
You can do the calculation with your own numbers using the OHS obligation calculator. We gave examples of how minutes are calculated for additional employees once the full-time appointment threshold is exceeded in our article on workplace physician and specialist working hours.
What else changes at which threshold?
The number of employees does not change only the minutes. The following thresholds also trigger obligations outside the contract:
| Threshold | What changes? | Basis |
|---|---|---|
| 10 employees in very hazardous | DSP appointment becomes mandatory (not required if there is a full-time physician) | Law No. 6331, Art. 6 |
| 10 and 50 employees | The increase rate for administrative fines changes | Law No. 6331, Art. 26/3 |
| 50 employees in less hazardous | The options of the employer providing the service themselves, combining monthly hours and obtaining medical reports from a ÇASMER or family doctor end | Law No. 6331, Arts. 6, 15; Regulation on OHS Services, Art. 11/7 |
| 50 employees and continuous work over 6 months | An OHS committee is established | Law No. 6331, Art. 22 |
| 51, 101, 501 employees | The number of employee representatives rises to 2, 3 and 4 | Law No. 6331, Art. 20 |
| 50 and 250 employees in very hazardous | DSP time rises to 15 and 20 minutes | Physician and DSP Regulation, Art. 12 |
| 30, 40, 50 and multiples, by hazard class | Additional support staff for the firefighting, rescue and protection teams | Emergencies Regulation, Art. 11 |
When the workshop in Example 1 reaches 55 employees, the obligation to establish a committee arises, the number of employee representatives rises to two and a second support staff member is needed for each emergency team. The number of first aiders also depends on the number of employees; in the hazardous class, one first aider is required for every 15 employees. For the committee, see our article on how to establish an OHS committee, and for the representative, our article on electing an employee representative.
Steps to update the number of employees on ISG-KATİP
Menu names in the system may change over time; the logic, however, stays the same: one party edits the record and the other checks and approves it.
- Document the number. Take the latest SGK declaration and the staff list; show apprentices and interns with student status separately.
- Calculate the new time. Calculate separately for the specialist, physician and, if required, DSP; if a full-time threshold is exceeded, show this as well.
- Make a written revision. Clarify the new minutes, visit plan and scope of service in writing with the OSGB (joint health and safety unit).
- The record is updated. The OSGB edits the contract and appointment record on ISG-KATİP according to the new time. If you employ in-house staff, you update the appointment yourself.
- Approve. The contract and appointment are approved by the parties through the system within 5 days at the latest (Regulation on OHS Services, Art. 14/3).
- Check the new appointees. If DSP is required for the first time, they are appointed separately; the specialist's certificate class must match the hazard class.
- Reflect it on site. Rearrange the visit calendar according to the new time.
What happens if the number of employees falls?
When the number falls, it is possible to reduce the time; however, the new time cannot go below the minimum calculated for the new number. A reduction is also made in writing as a contract revision and approved in the system. Some thresholds also work in reverse: if the number of employees in a very hazardous workplace falls below 10, DSP is no longer required; if a less hazardous workplace falls below 50, the option of the employer providing the service themselves becomes available again.
Ending the contract entirely, however, is not a revision but a termination. Termination is notified through ISG-KATİP within 5 working days (Art. 14/9). For businesses with seasonal fluctuations, writing a headcount range and a revision rule into the contract is more orderly than terminating and signing a new contract every month.
Common mistakes
- Reviewing the contract only at the annual renewal and missing increases during the year.
- Updating the specialist's time but forgetting the physician's or DSP's time.
- Overlooking DSP at the 10 and 50 thresholds in the very hazardous class.
- Counting apprentices and interns with student status, or leaving out intern-like employees who do not have student status.
- Making the revision in writing but not following up the approval in the system.
The 2026 base administrative fine for not appointing a specialist or physician is 111,263 TL for each person not appointed and is applied every month the breach continues; for DSP this amount is 55,597 TL per month. For other items, see the OHS administrative fines tool. In OHS specialist and workplace physician contracts in Bursa and neighbouring provinces, Bursa Sistemer checks the number of employees periodically and notifies you in writing when a revision is needed.
Frequently Asked Questions
If the SGK headcount and the number on site differ, which is used?
The minimum time is required for those actually working at the workplace; the SGK declaration is the document for this. If the difference arises from start and leaving dates, using the higher number eliminates the risk of under-hours.
When headcount rises, is a new contract or an update needed?
If the service continues with the same OSGB, a revision showing the new time is sufficient; however, this revision must also be recorded on ISG-KATİP and approved by the parties within 5 days. The transaction in the system may be called an update or a new appointment.
Do I need to change the time every month when hiring seasonal workers?
The time must cover the number of employees working in that period. Rather than making a new transaction every month, setting a separate time and revision rule for the season in the contract makes tracking easier.
Are interns counted in the time calculation?
Apprentices and interns with student status under vocational training and higher education legislation are not included in the total number of employees. Persons without student status who work for pay, however, are counted.
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.