OHS Documents to Request from Subcontractors

Why do you request documents?

We explained the division of responsibility between the principal employer and the subcontractor when working with subcontractors on a site or in a factory in our article on OHS when working with subcontractors. This article focuses on practice: what are the subcontractor OHS documents, what is each based on and how is each checked?

Requesting documents is not bureaucracy; it is evidence of the control duty the legislation gives the principal employer:

Art. 23 of Law No. 6331: Employers sharing the same work area work in cooperation and coordination and inform each other about risks.
Art. 15 of the Risk Assessment Regulation: Each subcontractor carries out a risk assessment for its own work and gives a copy to the principal employer. The principal employer integrates it with its own work, monitors and supervises the implementation of measures.
Art. 22 of the Regulation on the Procedures and Principles of Employees' OHS Training (Official Gazette 02.04.2026; the Training Regulation below): Each employer is responsible for its own employees' training; the principal employer is obliged to check the training certificates of subcontractor employees and provides information on workplace-specific risks before work begins.
Law No. 6331, Art. 17/5: In hazardous and very hazardous workplaces, employees coming from other workplaces to work cannot start work without a document showing they have received training on the risks of the work they will do.

Subcontractor OHS documents: checklist before work begins

The following contractor document checklist must be completed before the subcontractor enters the site:

Document	Basis	How is it checked?
Appointment of OHS specialist and workplace physician	Law No. 6331, Art. 6	Printout of the contract or appointment approved on ISG-KATİP; must be for the subcontractor's own workplace registration
Risk assessment	Risk Assessment Regulation, Art. 15	Does it cover the work to be done, does it include the risks of your site, is it signed and valid?
Emergency arrangements	Law No. 6331, Art. 11	People assigned to teams, first aider certificates; how they link into your emergency plan
Basic OHS training certificates	Training Regulation, Art. 22	Name match for each employee, training duration and date, suitability for the hazard class
Induction training record	Training Regulation, Art. 7	Before starting work, face to face and at least 2 hours
Pre-employment or periodic health report	Law No. 6331, Art. 15	Does it state fitness for the work to be done, has it expired?
Vocational training certificate	Law No. 6331, Art. 17/3	A suitable certificate for work requiring one, such as welders and scaffold erectors
Periodic inspection reports for work equipment	Work Equipment Regulation, Art. 7	The latest report for cranes, platforms, compressors and similar equipment brought on site, kept with the equipment
PPE issue records	Regulation on the Use of PPE	Signed issue record per employee; are the products suitable for the job and CE marked?
SGK employment start records	Law No. 5510	Employment start notification made for every person who will enter the site

A special case in equipment checks

If the subcontractor brings its own equipment, under Art. 7/3 of the Work Equipment Regulation, when portable equipment not subject to installation and assembly is used outside the business, the latest periodic inspection report is kept with the equipment. For equipment requiring installation, an inspection is carried out after installation and before first use. Check that the equipment serial number in the report matches the equipment on site. For intervals, see our article on periodic inspection intervals.

How should documents be checked?

It is not enough for a document to sit in the file; it must belong to the right person, the right job and the right date. Ask these questions when checking:

Person match: Is the list of names who will enter the site exactly the same as the training, health and vocational certificate lists?
Job match: Does the document cover the work the person will do on your site? For example, has fitness for this work been assessed in the report of a person who will work at height?
Date: Have the repeat period for basic training (every year in very hazardous, every 2 years in hazardous and every 3 years in less hazardous workplaces), the health report period and the validity of the equipment report expired?
Signature and stamp: Does the training certificate show the trainer's title, and the health report the physician's details?
ISG-KATİP: See from the system printout that appointments have been approved; duties cannot begin with an unapproved appointment. For the approval process, see our article on ISG-KATİP contract approval.

Example: a company servicing air conditioning on the roof

Suppose you have agreed with a three-person company to service the air conditioning units on the roof of a production plant. Even though the job is short, the list does not shrink; it is simply shaped by the work:

The company's specialist and physician appointments approved on ISG-KATİP.
A risk assessment covering roof work, electrical and pressurised refrigerant risks.
The three people's basic training certificates, health reports with fitness for work at height assessed, and the record of induction training given on your site.
The vocational training certificates the work requires.
The latest periodic inspection report for the mobile platform to be brought; the condition of the safety harnesses and lifeline to be used.
A work-at-height permit issued by you and a defined access route to the roof.

HVAC installation and maintenance is in the very hazardous class in the 2025 hazard class list; missing documents should therefore not be tolerated even for a short job.

Tracking while the work continues

If the document check is done once at entry and forgotten, the new craftsman who comes to the site in the third week may have no documents at all. For continuity:

New employees: The subcontractor must send the documents of every new person it sends to the site before entry; the list at the security gate must be updated accordingly.
Expiring documents: Keep health report and training dates in a table; notify the subcontractor in advance of those nearing expiry.
Work permits: For work such as hot work, work at height and confined spaces, the permit form must be signed jointly by the subcontractor's representative and your responsible person. See the permit-to-work system.
Committee coordination: In a principal employer–subcontractor relationship lasting more than six months, Art. 22/2 of Law No. 6331 regulates committee coordination; the party without a committee appoints an authorised representative for coordination.
Accidents and near misses: Incidents involving a subcontractor employee must also go into your records; the notification is made from the subcontractor's own registration.

Additional documents for construction work

On construction sites, in addition to the list above, the health and safety plan and coordination arrangement under the Regulation on OHS in Construction Work come into play. The subcontractor should share its work programme and method in advance so that the section relating to its work can be entered in the plan. For the plan and the coordinator's duties, see our article on OHS in construction work, and for daily checks on site, our construction site OHS checklist. Risks specific to the construction sector are on our construction sector page.

Common mistakes

Keeping a company list instead of a list of people. Documents belong to individuals; the sentence "the company's documents are complete" means nothing on its own.
Accepting a risk assessment for another site. If the subcontractor's general document does not include the risks of your site, it cannot be integrated.
Skipping the vocational training certificate. For work requiring a certificate, basic OHS training does not replace vocational training. Details are in our article on the vocational training certificate requirement.
Operating a crane or platform without seeing the equipment report. The report must be on site, next to the equipment.

In our OHS specialist services, we prepare the subcontractor document list for your site and plan checks at entry and while the work continues.

Frequently Asked Questions

In whose file are subcontractor OHS documents kept?

The originals stay in the subcontractor's own file. The principal employer should keep a copy of the documents it has checked or a record of the check; a copy of the risk assessment is given to the principal employer as required by the legislation.

Can we let an employee start work if the subcontractor has no training certificate?

In hazardous and very hazardous workplaces, an employee from another workplace who cannot document that they have received training on the risks of the work to be done cannot start work. In addition, every employee must be given induction training before starting work.

Where is a subcontractor's health report obtained?

Reports are obtained from the subcontractor's workplace physician; there are other options for less hazardous workplaces with fewer than 50 employees. The principal employer's workplace physician checks whether the report has expired.

Is a risk assessment required for jobs lasting a few days too?

Yes. Art. 15 of the Risk Assessment Regulation requires every subcontractor to carry out a risk assessment for the work it performs and to give a copy to the principal employer; it provides no exception based on job duration or headcount. For short jobs the assessment can be short, but it must include the risks of your site.

Should the subcontractor have its own OHS specialist?

The subcontractor is also an employer subject to the obligations in Art. 6 of Law No. 6331. It must show the appointment as approved on ISG-KATİP for its own workplace registration.