In brief
Free zones are subject to a special regime for customs, tax and foreign trade, but for occupational health and safety there is no difference between inside and outside the zone. Law No. 6331 applies to all public and private workplaces, and free zones are not among its exceptions; Law No. 3218 also states explicitly that Turkish social security legislation applies in free zones. Firms in the Bursa Free Zone in Gemlik meet their obligations on the OHS specialist, workplace physician, risk assessment, training and health surveillance like any workplace outside the zone.
Workplace safety in a free zone: the short answer
Managers of firms starting operations in the Bursa Free Zone in Gemlik often ask: "We are outside customs; does OHS legislation apply here in exactly the same way?" The answer is yes. Free zone status does not change a firm's occupational health and safety obligations.
The basis for this lies in two laws:
In other words, the free zone exception is for customs and foreign trade. For worker health, workplace safety and social security, the zone is like any industrial area in Türkiye. We explained in general terms which workplaces must obtain OHS services in our article on which workplaces OHS is mandatory for.
Free zones and Law 6331: inside versus outside the zone
| Obligation | In the free zone | Outside the zone |
|---|---|---|
| OHS specialist and workplace physician | Mandatory; time based on headcount and hazard class | Same |
| Other health personnel (DSP) | In very hazardous workplaces with 10 or more workers | Same |
| Risk assessment and emergency plan | Mandatory; renewed every 2 / 4 / 6 years and on changes | Same |
| Worker training | Under the 2026 training regulation | Same |
| Health surveillance | Pre-employment and periodic examinations | Same |
| Workplace accident notification | To SGK within 3 working days of the accident | Same |
| Periodic inspections of work equipment | According to Annex III intervals | Same |
| Inspection | Ministry labour inspectors | Same |
The only "difference" column in the table is empty, and that is a deliberate conclusion: there is no separate regime for free zones under Law 6331.
The main activity, not the licence type, determines the hazard class
Firms in the free zone operate under different operating licences: some manufacture, others carry out storage, trading or service activities. The extent of OHS obligations, however, is determined not by the name of the licence but by the hazard class set by the NACE code of the main activity actually carried out at the workplace. If there is more than one main activity, the higher class applies. For example, manufacturing parts for motor vehicles (29.32.20) is in the hazardous class, while outerwear garment manufacturing (14.21.01) is in the less hazardous class. Verify your code and class using the steps in our article on how to find your hazard class.
Once the class is known, the service time is calculated. Example: a parts manufacturer with 120 workers in the hazardous class.
- OHS specialist: 120 × 20 minutes = 2,400 minutes, i.e. 40 hours a month.
- Workplace physician: 120 × 10 minutes = 1,200 minutes, i.e. 20 hours a month.
- Other health personnel: not required in the hazardous class.
You can see the times for your own workplace with the OHS obligation calculator.
OSGB services and İSG-KATİP in the free zone
A firm in the free zone can obtain OHS services from professionals it employs directly or from an OSGB (joint health and safety unit). An OSGB's service area is its own province and the neighbouring provinces; since Gemlik is a district of Bursa, OSGBs in Bursa can serve firms in the zone.
Assignment is made through İSG-KATİP (the Ministry's online OHS registration system), just as outside the zone. Since the firm is subject to Turkish social security legislation, it is registered in the system with its SGK (Social Security Institution) workplace registration number. The contract is prepared in line with the template on İSG-KATİP and approved by both parties within 5 days at the latest; work cannot begin under an unapproved assignment. For the process, see our article on İSG-KATİP contract approval.
A common problem in firms with foreign partners is that OHS correspondence is conducted with the head office abroad and the responsible person on site remains unclear. The addressee of findings and recommendations is the employer or employer representative at the workplace; make this person clear at the contract stage.
For a firm starting operations in the zone, the order of OHS steps is the same as for a newly opened workplace outside it:
- Determine the main activity and hazard class. Check that the activity on the licence matches the work actually done on site.
- Assign the specialist and physician. Calculate the times according to headcount and approve the contract on İSG-KATİP.
- Train workers and have them examined before they start work. In hazardous and very hazardous work, a worker cannot start without a fitness-for-work report.
- Prepare the risk assessment and emergency plan. Add areas shared with neighbouring firms and common assembly points to the plan.
- Draw up an equipment inventory. Plan the first periodic inspections of equipment such as forklifts, compressors, racking and electrical installations.
- Set up the calendar. Bring training, examination, drill and inspection dates together in a single tracker.
For a detailed list of these steps, see our article on OHS when opening a new workplace.
OHS inspection in the free zone: who inspects?
In the free zone you deal with more than one authority, and this can cause confusion about inspections:
- OHS inspection: Carried out by Ministry labour inspectors under Art. 24 of Law No. 6331. Free zone status does not limit this power. For the documents requested in an inspection, see our article on preparing for a labour inspection.
- Ministry and zone directorate: The operating licence is issued by the Ministry of Trade; land use and construction permits are issued and inspected by the zone directorate (Law No. 3218 Art. 5). These permits do not replace OHS obligations.
- Operator rules: The zone's rules on common areas, access and construction also apply, but they do not remove the obligations in Law 6331.
- Customer audits: Export-oriented firms also undergo supplier audits by foreign customers; for preparation, see our article on preparing for a supplier OHS audit.
When a workplace accident or occupational disease occurs, notification is made to SGK as outside the zone: a workplace accident within 3 working days of the accident. For the notification steps, see our article on SGK workplace accident e-notification.
Site-specific notes for firms in the Gemlik free zone
Even though the legislation is the same, working conditions in the zone are distinctive. The points that stand out for firms in the Gemlik free zone are:
- Firms working side by side: Manufacturing, storage and trading firms use shared roads and yards. Where more than one employer shares the same work area, the employers cooperate on risks and inform each other (Law 6331 Art. 23). If you use a shared loading area or warehouse, set up traffic and emergency arrangements together with neighbouring firms.
- Logistics intensity: Because of the port and logistics links, forklift, lorry and container traffic is heavy. For forklifts working in open yards, see our article on the forklift operator's daily check.
- Foreign workers: Law 6331 applies to all workers regardless of nationality. Although the 2026 training regulation has no separate provision on the language of training, it requires training to change workers' knowledge, attitudes and behaviour. Training delivered in Turkish to a worker who does not speak Turkish does not achieve this; deliver it in a language the worker understands or with an interpreter, and record this in the training record.
- Subcontractors and service firms: Maintenance, cleaning and security firms work on the principal employer's site; for the sharing of responsibility in subcontracting relationships, see our article on subcontractor OHS responsibility.
For your firm in the free zone, assignment of the OHS specialist, risk assessment and site inspections fall under our OHS specialist services, and pre-employment and periodic examinations under our workplace physician services.
Frequently Asked Questions
Are firms in the free zone subject to Law No. 6331?
Yes. The Law applies to all public and private workplaces, and free zones are not among its exceptions. The free zone's special regime is for customs, tax and foreign trade.
Who carries out OHS inspections in the free zone?
Ministry labour inspectors. The Ministry of Trade, the zone directorate and the zone operator deal with licences, land use and common area rules; these permits and rules do not replace OHS obligations.
Can an OSGB in Bursa serve our firm in the free zone?
Yes. The Bursa Free Zone is in Gemlik, and OSGBs can provide services in their own province and in neighbouring provinces. Assignment is made through İSG-KATİP.
Is OHS training also required for our foreign workers?
Yes. Law No. 6331 makes no distinction by nationality; induction, basic and refresher training are mandatory for foreign workers too. For the training to achieve its purpose, it must be delivered in a language the worker understands.
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.