OHS for Outsourced Cleaning, Security and Catering

OHS in outsourced services: external teams working inside permanently

The cleaner working every day in a factory or office building, the private security guard at the gate and the cook in the canteen are often not on that workplace's payroll. These teams are different from contractors who come in for a few days' maintenance work: they work for years in the same workplace, on the same shifts and with the same risks. This is why OHS in outsourced services should be handled not with "external team" rules but as if they were a permanent part of the workplace.

The legal framework is in Art. 2 of Labour Law No. 4857. The relationship between an employer and another employer that takes on ancillary work relating to the production of goods or services carried out at its workplace, and employs the workers it assigns to this work only at that workplace, is a principal employer-subcontractor relationship. Cleaning, security and on-site catering are typical ancillary work. In this relationship, the principal employer is jointly responsible with the subcontractor for obligations towards the subcontractor's workers relating to that workplace.

Note one distinction in catering: if meals are cooked in a central kitchen and transported to the workplace, the cooks in the central kitchen do not work at your workplace; if only serving and dishwashing staff are at your workplace, the relationship is established through those staff. If meals are cooked on site, the whole kitchen team is at your workplace. For the general rules of the subcontractor relationship, see our article on subcontractor OHS responsibility.

Who is responsible for what? The basic split

The table below summarises how OHS obligations are split in permanent outsourced services.

Subject	Service firm (subcontractor)	Principal employer
OHS services (specialist, physician)	Assigns them for its own employees	Assigns them for its own employees; sets up coordination
Risk assessment	Carries it out for the work it does and gives a copy to the principal employer	Provides information and documents, integrates the subcontractor's work with its own and supervises
Training	Gives basic and refresher training	Provides information on workplace-specific risks; in hazardous and very hazardous workplaces, does not let anyone start work without seeing their training certificate
PPE	Provides suitable PPE to its employees and monitors its use	Communicates workplace-specific PPE needs and checks use on site
Health surveillance	Arranges pre-employment and periodic examinations	Communicates exposures at the workplace
Emergency plan	Limited to its own work area and activities	Prepares it for the workplace as a whole
OHS committee	Joins the committee or appoints a representative where the relationship lasts more than six months	Ensures coordination

The legal bases for this split are:

Risk Assessment Regulation Art. 15: Each subcontractor carries out, or has carried out, a risk assessment for the work it does and gives a copy to the principal employer; the principal employer integrates it with its own work, monitors implementation and supervises.
Law No. 6331 Art. 16/2-b: To ensure that employees coming from other workplaces to work receive the necessary information, the employer gives the necessary information to their employers.
Law 6331 Art. 17/5: In hazardous and very hazardous workplaces, employees coming from other workplaces may not start work without a certificate showing that they have received training on the risks of the work to be done. The 2026 training regulation also requires the principal employer to check the subcontractor's training certificates.
Law 6331 Art. 22/2: In a principal employer-subcontractor relationship lasting more than six months, coordination of the OHS committee is ensured by the principal employer; a party that is not required to form a committee appoints an authorised representative. For details see our article on the OHS committee where there is a subcontractor.

Cleaning company safety: chemical and area risks

A cleaner's risks are the risks of the area they clean. In an office, wet floors and manual handling come to the fore, while in a factory the areas around machines, oily floors, chemical stores and electrical rooms come into play. For cleaning company safety, the principal employer needs to provide the following:

Area information: Which departments may be entered, which only with an escort and which not at all (electrical room, chemical store, robot cell) is communicated in writing.
Rule for cleaning around machines: Underneath, inside or close to the moving parts of a running machine are not left to the cleaner; if machine cleaning is needed, it is done with the energy isolated and locked out, under the workplace's own procedure.
Chemical list: The cleaning firm gives the principal employer a list of the products it uses and their safety data sheets. The principal employer in turn communicates the production chemicals that may be encountered during cleaning.
Shift alignment: A communication arrangement is set up for a cleaner working alone at night or outside production hours.

For risks specific to cleaning staff's own work, such as mixing chemicals, slips and sharp waste, see our article on cleaning staff risks.

OHS for security company staff: nights, working alone and the emergency role

In most workplaces, the private security guard is the only person inside during the night. This makes OHS for security company staff important in two respects: the guard's own risks and the role they take on in an emergency.

The guard's own risks are night shifts and fatigue, working alone, tension with visitors or suspects, and guard posts exposed to the weather. These are included in the security company's risk assessment; however, measures such as heating the guard hut, lighting dark spots on the patrol route or an alarm arrangement for a guard working alone depend on the principal employer's facility. For details see our article on private security guard risks.

The emergency role is an even more critical issue. In a fire that starts at night, the person who first hears the alarm, calls the fire brigade and opens the gate is often the security guard. This guard needs to know the workplace's emergency plan, recognise the energy and gas shut-off points and take part in drills.

Catering company OHS: kitchen, hygiene and health

The canteen kitchen is like a separate workplace within the workplace: hot oil, steam, knives, slicing machines, gas hobs and slippery floors. Points to watch in catering company OHS:

The burn, cut and slip risks of kitchen staff are addressed in the catering company's risk assessment; responsibility for risks tied to building installations, such as the kitchen gas installation and extractor hood, is clarified in the contract.
Kitchen staff's hygiene training certificates and the monitoring of conditions preventing work under Art. 9 of the Hygiene Training Regulation are the catering company's responsibility. The principal employer's workplace physician monitors and inspects the canteen's general hygiene conditions.
Catering company staff are included in the workplace's fire and evacuation arrangements; a kitchen fire scenario is practised separately in drills.

For the points the physician looks at when inspecting the canteen see our article on canteen and kitchen hygiene, and for kitchen accidents our article on cooks and kitchen staff.

Including them in the emergency plan

The Regulation on Emergencies in Workplaces is clear on this: where there is a subcontractor at a workplace, the principal employer is responsible for preparing the emergency plan for the workplace as a whole, and subcontractors are responsible limited to their own work areas and the work they do (Art. 18). The employer also ensures that any subcontractor's employees are informed about emergencies, the evacuation plan, escape routes, assembly points and emergency teams (Art. 5/1-g).

In practice this means:

Cleaning, security and catering teams are added, with their shifts, to the evacuation and assembly point head count lists.
What each person will do in an emergency is written down for hours when the principal employer's employees are not present, such as nights and weekends; the external team inside at these hours is at the centre of the plan.
External team employees take part in drills; their participation is shown on the drill form.
If external team employees are to be put on emergency teams, their training and job description are clarified in writing between the two employers.

OHS clauses in the service contract

Whether the split works on site depends on it being written into the service contract. The OHS clauses of the service contract should include:

The service firm's assignment of a specialist and physician for its own employees on ISG-KATİP (the Ministry's online OHS registration system), with documentary evidence,
A copy of the risk assessment provided before work starts and updated when things change,
Employees' training certificates, pre-employment examination records and, where necessary, hygiene training certificates submitted before work starts,
Notification to the principal employer of staff starting or leaving,
Who will provide PPE, and the rules for its use on site,
A list of the chemicals to be used and their safety data sheets,
Immediate notification to the principal employer of work accidents and near misses,
Participation in the emergency plan, drills and, where necessary, the OHS committee,
The principal employer's right of inspection, the time allowed to correct non-conformities and stopping work in case of serious danger.

For details of document checks, see our article on OHS documents to request from subcontractors. In offices, shopping centres and production facilities in Bursa and the surrounding provinces, we set up coordination with service firms, document checks and joint emergency arrangements as part of our OHS specialist service. For other risks in office and retail workplaces, see our office and retail page.

Frequently Asked Questions

Who is responsible for the OHS training of a cleaning company's employees?

The cleaning company is responsible for basic and refresher training. The principal employer provides information on workplace-specific risks and, in a hazardous or very hazardous workplace, does not let the employee start work without seeing their training certificate.

Are security guards included in the emergency plan?

Yes. The principal employer is responsible for the emergency plan for the workplace as a whole, and subcontractors' employees must be informed about emergencies, evacuation and assembly points. The duty of a security guard who stays inside at night should be written clearly in the plan.

Who tracks the medical reports of catering company staff?

Pre-employment and periodic examinations and the monitoring of conditions preventing work under hygiene legislation are the catering company's responsibility. The principal employer's workplace physician monitors the canteen's general hygiene conditions and asks to see the documents when necessary.

Is the service firm's risk assessment given to the principal employer?

Yes. Under Art. 15 of the Risk Assessment Regulation, the subcontractor gives a copy of the risk assessment it has prepared to the principal employer; the principal employer integrates it with its own work and supervises implementation.