In brief
Candidate apprentices, apprentices and students receiving vocational training in businesses under Law No. 3308 are students, not workers; but Law No. 6331 protects them too. These students are covered by work accident and occupational disease insurance and sickness insurance, with premiums paid from the public budget; where the workplace is at fault, the employer is liable for the accident. In hazardous and very hazardous work a fitness-for-work report, and for everyone induction training, is required; those under 18 are examined at least every 6 months. The student's first safeguard on site is the master instructor.
Vocational school intern safety: student or not, the protection is the same
The question employers most often ask about vocational school intern safety is: "The student is not our employee; do OHS rules apply to them too?" The answer is yes. Art. 2 of Law No. 6331 on Occupational Health and Safety states explicitly that the Law applies to all workers, including apprentices and interns. Student status makes a difference at only one point: under Art. 6/4, apprentices and interns with student status under Laws No. 3308 and 2547 are not included in the number of employees when calculating the assignment time of the specialist and physician. Training, risk assessment, PPE and health surveillance apply to them as well.
This article addresses the topic through vocational education centre (MESEM) students and vocational high school interns, who are common in metal and machinery workshops. First let us separate the concepts. The definitions in Art. 3 of Vocational Training Law No. 3308 are as follows:
| Concept | Meaning in Law 3308 | Equivalent in the business |
|---|---|---|
| Candidate apprentice | A person who has not reached apprenticeship age and is given an introduction to the workplace environment and the occupation | Most restricted assignment |
| Apprentice | A person learning the occupation on the job under an apprenticeship contract | Student in a vocational education centre programme |
| Vocational training in the business | Practice in which a vocational school student receives skills training in the business and theoretical training at school | Vocational high school student |
| Internship | Work done by a higher education student in a real production environment in a business | University intern |
| Master instructor | A person with master craftsman competence, responsible for students' training at the workplace and familiar with vocational training techniques | The student's supervisor on site |
Status and the 3308 student insurance rule
The student is not a worker; they are at the business not under an employment contract but under an apprenticeship or in-business vocational training contract. The insurance and liability side is set up as follows:
- Insurance branches. Under Art. 5/b of Law No. 5510, work accident and occupational disease insurance and sickness insurance apply to candidate apprentices, apprentices and students receiving vocational training in businesses. Students doing an internship during vocational and technical education or higher education are covered only by work accident and occupational disease insurance.
- Premiums. Under Art. 25 of Law 3308, these students' insurance premiums are calculated on half the minimum wage and are met from appropriations in the relevant public budgets.
- Liability. The same article states that the employer is liable for work accidents and occupational diseases occurring through the fault of the workplace. The state paying the premium does not remove the obligation to take measures at the workplace from the employer.
- Accident notification. Art. 13 of Law 5510 also requires accidents involving insured persons under Art. 5 to be notified to the Social Security Institution (SGK) within 3 working days of the accident. For a student, notify the school of the accident immediately, and clarify in writing with the school at the contract stage who will take which step in the SGK notification. For the notification screens, see our article on SGK work accident e-notification.
The minimum payment is also regulated in Art. 25 of Law 3308 and varies with the number of personnel in the business; ask your school's coordinator teacher for current information on the amounts.
Skills training in the business and the master instructor
Law No. 3308 gives a business that takes students the duty of having a person responsible for training:
- To take apprentices (Art. 15): To take candidate apprentices and apprentices, a master instructor must be present at the workplace.
- Number of students (Art. 18): Businesses employing ten or more personnel provide skills training to vocational school students in a number not less than five per cent of their personnel. Businesses training ten or more students set up a training unit and assign a master instructor or training personnel to it.
The master instructor's duty in Law 3308 is vocational training; they have no separate title in OHS legislation. But on site, they are the person who most affects the student's safety. Set up the following arrangement with the master instructor:
- Task list. The jobs the student can do, can do under supervision and may not do at all should be in writing. Machines such as presses, guillotine shears, lathes and CNC machines should be assessed separately on this list.
- Never alone. The student does not work on a machine carrying high risk in the risk assessment without the master instructor or an experienced worker beside them.
- Work instructions. The instructions for every machine the student uses should be at the machine, short and illustrated.
- PPE. The student should be given PPE that fits them; oversized gloves and shoes cause accidents.
- Reporting. The master instructor passes on near misses involving the student to the specialist.
For the general rules of machine safety, our article on CNC operator safety is a good starting point for topics to explain to students at the machine.
Intern health report and health surveillance
The health requirement comes from two sources. Art. 10/b of Law 3308 requires that, to start an apprenticeship, the person's constitution and state of health be suitable for doing the work the occupation they are entering requires. Art. 15 of Law 6331 provides that, in hazardous and very hazardous work, no one may start work without a fitness-for-work report, and that these reports are obtained from the workplace physician.
In practice, follow this order:
- Before the student starts at the business, the workplace physician carries out the pre-employment examination; the examination takes into account the department in which the student will work and the risks to which they will be exposed (noise, dust, chemicals, lifting).
- If the student is under 18, their periodic examination is carried out at least every 6 months.
- Any restriction the physician writes on the report is entered into the master instructor's task list.
We plan the necessary tests with authorised laboratories and healthcare institutions. For where to obtain the report and its cost, see our article on the pre-employment health report.
For students under 18, working hours, the ban on night work and the jobs they may do are also subject to the Regulation on the Procedures and Principles for the Employment of Children and Young Workers. The jobs and places where students in in-business vocational training and internships will practise are determined by MEB (the Ministry of National Education). For details, see our article on child and young workers.
Training: induction and basic training
The training regulation of 2 April 2026 sets two rules for students:
- Induction training (Art. 7): Given to everyone, including apprentices and interns, before they start work, for at least 2 hours, face to face and in practice, and documented with a record.
- Responsibility and school lessons (Art. 21): The employer of the workplace where practical training is received is responsible for the training and informing of apprentices and interns. OHS lessons or courses the student has completed at school replace basic training if the employer accepts them.
Look at the content before accepting a school lesson. A general OHS lesson given at school does not cover the presses, chemicals and emergency arrangements at your workplace. Even if you accept it as basic training, explain the job- and workplace-specific risks separately on site. For a sample programme, see our article on induction training.
First-week checklist for a student in a metal workshop
| Step | Who does it? | When? |
|---|---|---|
| Confirming the contract and insurance registration with the school | Human resources | Before starting |
| Pre-employment examination and fitness-for-work report | Workplace physician | Before starting |
| Induction training and record | Specialist, physician or experienced worker | First day, before starting work |
| Task list and prohibited machines | Master instructor and specialist | First day |
| Issuing PPE and recording it | Department supervisor | First day |
| Introduction to emergency teams and the assembly point | Specialist | First week |
| Basic training or acceptance of the school lesson | Employer, with the specialist's opinion | First week |
| Periodic examination date (under 18) | Workplace physician | Within 6 months |
Although students are not counted in the time calculation, a large group of students increases the specialist's and physician's workload; we explained how this exception is applied in our article on working times. You can see the minimum times for your number of employees with the OHS obligations calculator tool.
At metal and machinery businesses in Bursa and the surrounding provinces, preparing student task lists and induction training are part of Bursa Sistemer OSGB's OHS specialist services, and pre-employment and 6-monthly examinations are part of our workplace physician services.
Frequently Asked Questions
Who is liable if a MESEM student has a work accident?
The student's insurance premiums are paid from the public budget, but under Art. 25 of Law 3308 the employer is liable for work accidents and occupational diseases occurring through the fault of the workplace. The obligation to take measures does not change.
Is a health report needed for an intern?
In hazardous and very hazardous work, yes; under Art. 15 of Law 6331, no one may start work without a fitness-for-work report, and the report is obtained from the workplace physician. Students under 18 undergo a periodic examination at least every 6 months.
Does an OHS lesson the student took at school replace basic training?
It does if the employer accepts it (2026 training regulation Art. 21). However, induction training is given separately, and workplace-specific risks must always be explained on site.
Are interns counted when calculating specialist and physician time?
Apprentices and interns with student status under Laws No. 3308 and 2547 are not counted in the time calculation. This exception applies only to the time calculation; all other OHS obligations apply.
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.