In brief
A pharmacy working with a single assistant or technician is also covered by Law No. 6331; since the Constitutional Court decision there is no longer a deferral for small workplaces. In a pharmacy in the less hazardous class with fewer than 50 employees, specialist and physician services can be obtained from an OSGB (joint health and safety unit), or the pharmacist can complete the Ministry training and carry out the service personally; pre-employment and periodic examinations are excluded. The main risks in a pharmacy are prolonged standing, stockroom shelving, sharp and flammable materials, and violence and robbery on night duty.
Pharmacy safety: small workplaces are covered too
In a neighbourhood pharmacy there are usually one or more employees alongside the pharmacist: a pharmacy technician, an assistant, a cashier or a cleaner. The most frequently asked question about pharmacy safety is "Is OHS needed in such a small place?", and since 2025 the answer has been an unequivocal yes. The Constitutional Court annulled the provision that deferred the specialist and physician obligation for less hazardous workplaces with fewer than 50 employees; the decision was published in the Official Gazette of 9 December 2025 and no new deferral was made.
The scale of pharmacy OHS obligations depends on the workplace's hazard class. The class is determined by how the 6-digit activity code in the SGK workplace registration appears in the current list. The durations and frequencies in this article are given for the less hazardous class; check which class your code shows using the steps in our article on how to find out your hazard class. If your class is different, the durations change too.
Appointing a specialist and a pharmacy workplace physician: two routes
Under Art. 6 of Law No. 6331 on Occupational Health and Safety, the employer appoints an OHS specialist and a workplace physician. For a less hazardous pharmacy with fewer than 50 employees, there are two routes:
- Obtaining the service from an OSGB: The specialist and physician are appointed through a contract made via ISG-KATİP (the Ministry's online OHS registration system). In a less hazardous workplace, a class C specialist certificate is sufficient.
- The pharmacist carrying out the service personally: If the employer or their representative completes the training set by the Ministry, they can take on the service themselves; in this case an undertaking is filed on ISG-KATİP. Pre-employment and periodic examinations are outside this scope; they are still carried out by a physician.
In a less hazardous workplace, the minimum monthly time per employee is 5 minutes for the physician and 10 minutes for the specialist. In less hazardous workplaces with fewer than 50 employees, these monthly times can be combined within the same contract year.
Small workplaces also have an easier route for the pre-employment report: under Art. 15/3, less hazardous workplaces with fewer than 50 employees can obtain pre-employment and periodic examination reports not only from the workplace physician but also from occupational disease hospitals, family physicians or other public healthcare providers. For details, see our article on where to get a pre-employment health report. In a less hazardous workplace, periodic examinations are carried out at least every 5 years.
Pharmacy risk assessment: the main hazards
In less hazardous workplaces, the pharmacy risk assessment is renewed at least every 6 years and whenever significant changes occur. Its content, however, should reflect the real conditions of that pharmacy, not a template. In a typical pharmacy, the following hazards stand out:
| Hazard | Where is it seen? | Measure |
|---|---|---|
| Prolonged standing | Counter, till, in front of shelves | Anti-fatigue mat, high stool behind the counter, suitable footwear, changing posture during work |
| High shelves and heavy boxes | Stockroom, back room | Heavy boxes at or below waist height, light products on upper shelves; a step ladder with a handrail |
| Shelves toppling | Sales area and stockroom | Fixing shelves to the wall or to each other, light products instead of glass bottles on upper shelves |
| Sharp tools | Opening boxes, packaging, glass bottles | Safety box cutter, a separate sturdy container for broken glass |
| Flammable materials | Stock of alcohol, cologne, cosmetics | Storage away from heat sources, in small quantities and in a ventilated place |
| Chemicals | Compounding, disinfectants | Safety data sheet, gloves and goggles, a separate laboratory area |
| Slips and falls | Entrance on rainy days, floor after cleaning | Entrance mat, wet floor warning, cleaning moved to quiet hours |
| Violence and robbery | Till, night duty | See the section below |
| Display screen equipment | Prescription and stock systems | Screen height, glare, short breaks |
Bursa and its surroundings are an earthquake zone. Fixing shelves is therefore a simple, cheap measure that pharmacies should not overlook; we covered the topic from an emergency perspective in our article on the workplace earthquake emergency plan.
Standing work and stockroom shelving
In a pharmacy, employees move between the counter and the shelves all day; standing in the same spot for long periods is the main cause of leg and back fatigue. Placing a high stool behind the counter and setting up an arrangement that does not prevent sitting when there are no customers is the most effective measure. For more detail on the topic, see our article on risks of standing work.
On the stockroom side, the real risk is standing on a chair or cardboard box to get products from upper shelves. Buy a step ladder suitable for the pharmacy, with wide steps and a handrail, and do not put heavy boxes on upper shelves. Our article on portable ladder safety explains what to watch out for with portable ladders.
Robbery and violence risk: preparing for night duty
Pharmacies carry a risk of robbery and violence because they hold cash and medicines and stay open at night. This risk should be dealt with as a separate heading in the risk assessment and tied to concrete measures:
- Night duty arrangements: On night duty, serve through a service hatch if possible; keep the door locked.
- Cash management: Keep little cash in the till, and keep the cash box where customers cannot see it.
- Visibility and recording: Keep the entrance and till area well lit; make the presence of camera recording visible.
- Alarm and communication: Set up a silent alarm or emergency call arrangement; the employee should know whom to call in which situation.
- Instruction: Put the rule "Do not resist during a robbery, do not take risks for property" in writing and explain it to employees.
- After an incident: A record is kept for an employee who has been threatened or attacked; support from the physician and, if necessary, adjustments to their duties are planned.
For staff working at night, also observe the night work limits in Art. 69 of Labour Law No. 4857. For the general framework on violence against employees, see our article on violence against employees.
Pharmacy employee training and first aiders
Under the 2026 training regulation, every new employee receives at least 2 hours of face-to-face, hands-on induction training before starting work. Basic training is completed within 3 months of starting work at the latest; in a less hazardous workplace the minimum duration is 8 hours, and the training is repeated every 3 years for at least 8 hours.
In pharmacy employee training, in addition to the general topics, the following headings should be covered specifically: stockroom and shelf layout, sharps and broken glass, storing flammable products, chemical safety in compounding, behaviour during robbery and violence, using a fire extinguisher and the escape route.
In less hazardous workplaces, there must be 1 first aider for every 20 employees; in other words, even a small pharmacy needs at least one first aider. A first aid certificate is valid for 3 years. Having medicines in the pharmacy does not remove the need for a first aid cabinet; for its contents, see our article on first aid cabinet supplies.
Pharmacy emergency plan
A pharmacy emergency plan should be short but useful. The plan covers scenarios such as fire, earthquake, gas leak and robbery, the escape route, the assembly point and the people with duties. In a less hazardous workplace the plan is renewed at least every 6 years and a drill is held at least once a year.
Small workplaces have an easier rule on emergency team members: in workplaces with fewer than 10 employees, a single person can be appointed for the firefighting, rescue and protection teams. If the pharmacy is on the ground floor of an apartment block or business centre, joint emergency planning with the other users of the building is needed; for this see our article on the emergency plan in a shared building, and for the general steps, the emergency plan in a small workplace.
Summary of obligations for a pharmacy
| Obligation | Less hazardous, fewer than 50 employees | If missed |
|---|---|---|
| Specialist and physician | OSGB or the pharmacist personally (excluding examinations) | 111,263 TL a month for each person not appointed |
| Risk assessment | At least every 6 years and on change | 66,725 TL; 100,119 TL every month while it continues |
| Training | Induction 2 hours; basic 8 hours; repeated every 3 years | 8,980 TL per employee |
| Health surveillance | Pre-employment; periodic examination at least every 5 years | 22,194 TL per employee |
| Emergencies | Plan, emergency team members, annual drill | 22,194 TL a month for each obligation |
The amounts are the 2026 base amounts; no increase is applied in less hazardous workplaces with fewer than 10 employees. For calculations, see the OHS administrative fines page.
We provide OHS specialist and workplace physician services to pharmacies in Bursa and the surrounding provinces with visit plans suited to how busy a small workplace is. For other topics specific to the healthcare sector, see our healthcare facilities page.
Frequently Asked Questions
Does a pharmacy with only one employee have to appoint a workplace physician?
Yes. The obligation exists whatever the number of employees. In a less hazardous pharmacy with fewer than 50 employees, the service can be obtained from an OSGB, or the pharmacist can complete the Ministry training and carry out the service personally; however, pre-employment and periodic examinations are still carried out by a physician.
How is the number of employees in a pharmacy calculated?
The time calculation is based on the number of employees; apprentices and interns are not counted. When your number of employees changes, you also need to update the appointment time on ISG-KATİP.
Can pharmacy employee training be delivered remotely?
Induction training is delivered face to face and hands-on. The general, health and technical topic groups of basic training can be delivered remotely; the training must be completed with an exam and documented.
Is a first aider mandatory in a pharmacy?
Yes. Less hazardous workplaces need one first aider for every 20 employees; this means a pharmacy with fewer than 20 employees must have at least one certified first aider. The certificate is valid for 3 years.
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.