Mandatory OHS Appointments and Appointment Letters

Why is an OHS appointment letter needed?

Occupational health and safety legislation defines many duties with the words "the employer appoints". The only proof that the appointment has been made is the letter. In an inspection, the answer to "who are your emergency teams?" is given not with a list of names but with a dated and signed OHS appointment letter.

A good appointment letter has three functions: it shows to whom and on what basis the duty was assigned, it confirms with the appointee's signature that they know their duty, and it makes it easier to track the training the duty requires. Appointment letters are an integral part of the file we described in our article on the contents of the OHS file.

Mandatory appointments and headcount rules

The table below summarises the appointments that must be made in writing in the great majority of workplaces, and the headcount rules:

Duty	Basis	Headcount rule	Additional condition
Firefighting, rescue and protection team support staff	Emergencies Regulation, Art. 11	For each team, at least 1 person per up to every 30 employees in very hazardous, 40 in hazardous and 50 in less hazardous workplaces; 1 person for all three teams with fewer than 10 employees	Specific training; deputies according to shift pattern
First aid team (first aiders)	First Aid Regulation; Emergencies Regulation, Art. 11/5	1 per 20 employees in less hazardous, per 15 in hazardous and per 10 in very hazardous workplaces	Valid first aider certificate (3 years)
Employee representative	Law No. 6331, Art. 20	2–50 employees: 1; 51–100: 2; 101–500: 3; 501–1000: 4; 1001–2000: 5; 2001 and above: 6	Election; appointment if no one can be elected
Risk assessment team	Regulation on Risk Assessment, Art. 6	No number; members are listed in the Regulation	Employees representing all units
OHS committee members	Law No. 6331, Art. 22; Regulation on OHS Committees, Art. 6	50 or more employees and continuous work lasting more than six months	Chaired by the employer, OHS specialist as secretary
OHS specialist, workplace physician, other health personnel	Law No. 6331, Art. 6	Hours according to hazard class and number of employees	Approval on ISG-KATİP within 5 days at the latest

Threshold values are inclusive for support staff numbers: in the hazardous class, 1 person per team is required for up to 40 employees, 2 for 41–80 employees and 3 for 81–120 employees. In the first aider calculation, fractions are rounded up. You can see your own numbers with the OHS obligation calculator.

The support staff appointment letter

Art. 11 of the Regulation on Emergencies in Workplaces sets out the firefighting, rescue, protection and first aid teams and the numbers of support staff. The same article also lists the details to be taken into account in appointments:

Each team has a team leader (Art. 11/6).
For coordination between teams, a person or persons responsible for the protection team are appointed (Art. 11/7).
When support staff and their deputies are identified, the shift pattern is taken into account (Art. 11/8).
A list containing the support staff's names, surnames, titles, areas of responsibility and contact details is posted visibly at employees' eye level (Art. 11/9).
If someone leaves or changes location, a replacement is appointed (Art. 11/10).

If the building is a non-residential structure where more than 50 people are present, Art. 126 of the Regulation on the Protection of Buildings from Fire also applies: firefighting and rescue teams consist of at least three people each, and protection and first aid teams of at least two people each. Use whichever number is higher under the two regulations. Art. 125 of the same Regulation also requires a fire safety officer to be chosen from among staff for each floor or section of the building; you can add this appointment to the same letter.

For the training support staff will receive, see our article on support staff training, and for how to set up teams on the night shift, our article on night shift emergency teams.

The first aider appointment letter and the employee representative appointment letter

The first aider appointment letter must state the certificate number and expiry date. The first aider certificate is valid for 3 years, and refresher training is taken within the 3 months before expiry. A person whose certificate has expired is not considered a first aider; before renewing the letter, check that the certificate has been updated. For the process of obtaining the certificate, see our article on how to obtain a first aid certificate.

The employee representative, unlike the other duties, is determined first by election. Art. 20 of Law No. 6331 on Occupational Health and Safety requires the employer to appoint representatives with a balanced distribution, taking into account the risks and numbers of employees in different parts of the workplace. If no one can be elected, an appointment is made; if there is more than one representative, the chief representative is chosen by election among the representatives. If there is an authorised trade union at the workplace, the union representatives also act as employee representatives. The employee representative appointment letter should therefore be based on the election record and kept together with it. For the election procedure, see our article on electing an employee representative.

Risk assessment team appointment and the OHS committee

Art. 6 of the Regulation on Risk Assessment states that the risk assessment is carried out by a team set up by the employer. The team consists of the employer or their representative, OHS specialists and workplace physicians, employee representatives, support staff and knowledgeable employees chosen so as to represent all units. The work may be coordinated by the employer or by a person appointed from within the team.

The most common gap in the risk assessment team appointment letter is "employees representing all units". The letter should name at least one person from each of the production, maintenance, warehouse, dispatch and administrative units. The risk assessment document also contains the names and titles of those who carried it out, and the pages are initialled by these persons (Art. 11). For the process, see our article on how to carry out a risk assessment.

An OHS committee is established in workplaces with 50 or more employees where continuous work lasting more than six months is carried out. Under Art. 6 of the Regulation on OHS Committees, the committee consists of the employer or their representative (chair), the OHS specialist (secretary), the workplace physician, a person from HR or administration, a civil defence specialist if any, a foreman, charge hand or master craftsman if any, and the employee representative (the chief representative if there is more than one). The specialist, physician, HR member and civil defence specialist are appointed by the employer; the foreman or craftsman member is elected, and if no one can be elected, the employer appoints them. For the steps to set up the committee, see our article on how to establish an OHS committee.

What an appointment letter should contain

The legislation does not provide a template for appointment letters. A letter that works in inspections and in practice contains the following information:

The workplace's name, address and SGK workplace registration number.
The name of the duty and its basis (e.g. "Firefighting team leader under Art. 11 of the Emergencies Regulation").
The appointee's full name, department, title and shift.
The scope of the duty and area of responsibility (floor, department, shift).
The training or certificate the duty requires, with dates.
The start date of the duty; the name of the deputy, if any.
The signature of the employer or the employer's representative.
The appointee's statement "I have read and accept this duty", with the date and signature.

Common mistakes

The appointee is unaware: The letter is in the file, but the person does not know their duty. This is the first gap revealed in a drill.
A list without shifts: All support staff are on the day shift; no team remains on the night shift.
Expired certificate: A person whose first aider certificate has expired remains on the list.
Staff who have left: The name of someone who has left stays on the list for months.
Representative appointed without election: A direct appointment is made without holding an election.
Overlap of two regulations: The minimum team numbers required under the building fire regulation are overlooked.

Appointments are the foundation of the emergency plan and drills; we explained the general structure of the plan in our article on how to prepare an emergency plan. In its OHS specialist service, Bursa Sistemer prepares the appointment list according to the workplace's shift pattern and tracks training and certificate periods.

Frequently Asked Questions

Is a support staff appointment letter mandatory?

The Regulation requires support staff to be appointed and their lists to be posted in the workplace; it does not set the form of the letter. A dated, signed letter showing that the appointment was made and that the person knows their duty is the evidence of this obligation in an inspection.

How many support staff and first aiders are needed in a hazardous workplace with 85 employees?

3 people for each of the firefighting, rescue and protection teams (the 81–120 employee range) and 6 first aiders, from 85 ÷ 15 rounded up. The number of employee representatives in the 51–100 range is 2. In shift work, there must be enough people on each shift.

Can the employer appoint the employee representative directly?

The representative is first determined by an election among employees; an appointment is made only if no one can be elected. If there is an authorised trade union at the workplace, the union representatives also act as employee representatives.

When are appointment letters renewed?

There is no fixed period in the legislation. The letter is renewed when the appointee leaves, changes department or shift, when their certificate expires, or when the number of employees crosses a new threshold.