OHS in Workplaces with Fewer Than 50 Employees

What did the Constitutional Court decision change?

When Law No. 6331 on Occupational Health and Safety was enacted in 2012, the provisions on assigning a specialist and physician (Art. 6) and state support (Art. 7) were deferred to a later date for some workplaces. Under Art. 38 of the Law, these workplaces were public institutions and less hazardous workplaces with fewer than 50 employees. The date was postponed many times over the years:

The result is clear: there is no longer any postponement date in the Law for these workplaces. Less hazardous workplaces with fewer than 50 employees are also subject to the obligation to assign a specialist and physician. As of 5 November 2026, when this article was updated, there is no new postponement either.

The other group affected by the decision is public institutions, excluding employees covered by the repealed Art. 81 of Labour Law No. 4857. This article focuses on small private sector workplaces such as offices, workshops, shops and service businesses in Bursa.

For comparison: in hazardous and very hazardous workplaces with fewer than 50 employees, the same provisions have applied since 1 January 2014, and in workplaces with 50 or more employees, even earlier. In other words, the decision brought small, less hazardous workplaces into line with all other workplaces.

Who falls within this scope?

Two questions determine the scope: is your workplace's hazard class less hazardous, and do you have fewer than 50 employees? If the answer to both is yes, this article concerns you directly. Typical examples in Bursa are:

• Software offices (62.10.00), accounting firms (69.20.02) and business consultancy firms (70.20.01)
• Outerwear garment workshops (14.21.01)
• Bakeries (10.71.02)
• Many shops, offices and service businesses

Confirm your class not by assumption but with the 6-digit NACE code in your SGK (Social Security Institution) registration; in the list renewed in 2025, the class of some activities changed. For the steps, see our hazard class guide, and for risks specific to offices and shops, our office and retail page.

In the headcount, apprentices and interns with student status are not included in the calculation of assignment time. However, induction training and other measures apply to them too.

What should you do now? Checklist

In a small business, there is no need to complete all the steps in the same week, but the order matters. Make the assignment first, because the fine for not assigning a specialist and physician is applied again every month while the breach continues. Then come the risk assessment and emergency plan; the training and health surveillance calendar is built on these two documents. The list below is a sensible starting order for an office, workshop or shop in Bursa:

1. Confirm the hazard class and headcount. All calculations are based on these two pieces of information.
2. Choose the service model. An OSGB (joint health and safety unit), your own staff or the employer itself; the options are below.
3. Complete the ISG-KATİP registration. The OSGB contract or assignment in ISG-KATİP (the Ministry's online OHS registration system) is approved by both parties within 5 days at the latest; if the employer undertakes the service itself, a letter of undertaking is issued. Details: ISG-KATİP contract approval.
4. Have a risk assessment carried out. In less hazardous workplaces, it is renewed at least every 6 years and on changes. See: how to carry out a risk assessment.
5. Prepare the emergency plan. In a workplace with fewer than 10 employees, a single support person is sufficient for firefighting, rescue and protection; with 10–49 employees, at least one person is assigned to each team. A drill is held at least once a year.
6. Plan the training. Induction training is at least 2 hours, face to face and practical; basic training is completed as at least 8 hours within 3 months at the latest after starting work and repeated as at least 8 hours every 3 years. Details: new OHS training regulation.
7. Start health surveillance. A pre-employment examination is carried out; in less hazardous workplaces, the periodic examination is at least every 5 years. See: periodic examinations and tests.
8. Appoint a first aider. In less hazardous workplaces, 1 first aider is needed for every 20 employees; the certificate is valid for 3 years.
9. Have work equipment inspected. Periodic inspections of equipment such as compressor tanks, electrical installations and earthing, and fire extinguishers are carried out at least once a year.

To see all these values on a single screen according to your headcount, use the OHS obligations calculator tool.

Three routes: which suits you?

In small workplaces, the times are short. In an office with 12 employees, the physician's time is 60 minutes a month and the specialist's 120 minutes a month. The Regulation on OHS Services allows the employer and the service provider, in less hazardous workplaces with fewer than 50 employees, to agree to combine monthly times within the same contract year. In this way, the annual 720 minutes of physician time and 1,440 minutes of specialist time can be spread over less frequent but more productive visits.

If the employer carries out the service itself

Under Art. 6/1-a of Law No. 6331, employers or employer representatives of less hazardous workplaces with fewer than 50 employees may carry out occupational health and safety services themselves, provided they complete the training announced by the Ministry. The rules of this route are:

• Training: Delivered by institutions that have a protocol with the Ministry. Those who complete the training are issued a training completion certificate; with the amendment of 5 March 2025, the requirement to pass an exam was removed.
• Excluded: Pre-employment and periodic examinations and tests are not among the services the employer can carry out.
• Multiple workplaces: The employer may undertake the service for less hazardous workplaces within the same province, provided the total number of employees is fewer than 50.
• Employer representative: May undertake the service only for a single workplace where they work under a full-time contract of service.
• Registration: A letter of undertaking is issued in ISG-KATİP.

In this model, you take on the work the specialist and physician would do on site: carrying out or commissioning the risk assessment, preparing the emergency plan, planning and recording training, appointing first aiders and support staff, and tracking periodic inspection dates. For medical examinations, you need to work separately with a health service provider.

Health reports: the ÇASMER and family physician option

Under Art. 15/3 of the Law, health reports are obtained from the workplace physician; however, less hazardous workplaces with fewer than 50 employees may also obtain reports from ÇASMERs, family physicians or other public health service providers. A ÇASMER (employee health centre) is defined in the Law as a unit under the Ministry of Health authorised to provide OHS services to workplaces. Objections to reports are made to referee hospitals designated by the Ministry of Health, and their decisions are final.

This flexibility does not remove the examination obligation. Periodic examinations are carried out at the start of employment, on change of job and, in less hazardous workplaces, at least every 5 years; for child, young and pregnant employees, the interval is at least every 6 months. The cost of the examination cannot be passed on to the employee, and health information is kept confidential. If you carry out the service yourself, you need to plan the examination calendar separately; if you use a workplace physician service, this follow-up is among the physician's duties.

State support: what does the Law say?

Art. 7 of the Law provides that support may be given by the Ministry for OHS services. The article says the following:

• Workplaces in the very hazardous and hazardous classes with fewer than 10 employees, excluding public institutions, may benefit from the support.
• The President may decide that less hazardous workplaces with fewer than 10 employees may also benefit.
• The costs are financed by the SGK by transferring resources from occupational accident and occupational disease insurance premiums; in practice, SGK records are taken as the basis.
• An employer found to employ uninsured workers repays the payments received with statutory interest and cannot benefit from the support for three years.

As can be seen, less hazardous workplaces are not directly within the scope of the support; however, those with fewer than 10 employees can be brought within scope by Presidential decision. Confirm the current application of the support and the application conditions with the SGK; do not plan your budget on the assumption of support.

Frequently Asked Questions

I have an office with 5 employees; is an OHS specialist required?

Yes. Workplaces in the less hazardous class with fewer than 50 employees are also subject to the obligation to assign a specialist and physician. For 5 employees, the specialist's time is 50 minutes a month and the physician's 25 minutes a month, and these times can be combined within the contract year. Alternatively, you can complete the Ministry training and carry out the service yourself.

If I carry out the service myself, will I no longer need a physician?

You will still need one. Pre-employment and periodic examinations and tests fall outside the services the employer can carry out. You need to obtain health reports from the workplace physician or, for these workplaces, from a ÇASMER, family physician or other public health service provider.

What is the fine for non-compliance?

The 2026 basic fine for not assigning a specialist or physician is 111,263 TL for each person not assigned, and it is repeated every month while the breach continues. No increase is applied in less hazardous workplaces with fewer than 50 employees. The fine for not providing training is 8,980 TL per employee, and for not carrying out health surveillance 22,194 TL per employee. Details: OHS administrative fines.

I have two small branches; how is it calculated?

If you obtain services from an OSGB, the time is calculated separately for each workplace and a separate assignment is made for each. If you want to carry out the service yourself, the branches must be within the same province and in the less hazardous class, and the total number of employees must be fewer than 50.

Will there be a new postponement?

As of 5 November 2026, there is no new postponement. Rather than waiting for legislation, the safest course is to fulfil the obligations now; assignment fines are applied again every month while the breach continues.