In brief
Part-time and on-call workers fall fully within the definition of employee in Law No. 6331; their training durations, pre-employment and periodic medical examinations are the same as for full-time employees. For thresholds such as specialist and physician time, DSP, the OHS committee and first aiders, a part-time employee counts as one person; no full-time-equivalent calculation is made. For on-call workers, training and the medical examination must be completed before the first call.
Are part-time employees covered by OHS?
A branch of a retail chain has 18 full-time and 12 part-time employees. The employer calculated the OHS service time by counting the part-timers as "half a person" and did not give basic training to the university students working the evening shift. At inspection, both issues turn up as deficiencies. Part-time employee OHS obligations are among the most frequently misunderstood topics, because people try to carry the "pro rata rights" logic of employment law over to OHS.
The legal framework is clear:
- Art. 13 of Labour Law No. 4857 treats a contract whose normal weekly working time is set considerably shorter than that of a comparable full-time worker as a part-time employment contract, and states that a part-time worker may not be treated differently solely for being part-time unless there is a justified reason. Pay and divisible rights are proportional to the time worked; OHS, however, is not a divisible right.
- Art. 14 of the same Law defines a contract based on the worker being called in when needed as a part-time contract based on on-call work.
- Under Art. 3 of Law No. 6331, an employee is any natural person employed at the workplace, regardless of status.
Conclusion: OHS obligations apply in full to part-time and on-call workers.
Part-time worker workplace safety: obligations in one table
For part-time worker workplace safety, how each obligation applies can be summarised as follows:
| Obligation | Rule for part-time employees | Common mistake |
|---|---|---|
| Induction training | Before starting work, at least 2 hours, face to face and practical | Leaving it until after the first shift |
| Basic training | Within 3 months at the latest; 8 teaching hours in less hazardous, 12 in hazardous, 16 in very hazardous | Shortening the duration in proportion to working hours |
| Refresher training | Every year in very hazardous, every 2 years in hazardous, every 3 years in less hazardous; at least 8 hours | Leaving part-timers off the refresher list |
| Pre-employment examination | In hazardous and very hazardous work, no one may start without a fitness-for-work report | Starting someone without a report as "temporary work" |
| Periodic examination | At the latest every 5 years in less hazardous, every 3 years in hazardous; every year in very hazardous | Not tracking the period separately from full-time staff |
| Risk assessment | Evening, night and weekend slots are assessed separately | Writing it only for the daytime pattern |
| Emergencies | Teams also cover the hours when part-time employees are present | No team member present at evening closing |
The induction and basic training rules come from Art. 7, 8, 13 and 14 of the Regulation on the Procedures and Principles of Employees' OHS Training, published on 2 April 2026; the regulation does not set separate durations for part-time employees.
Part-time worker training: hours and planning
When planning part-time worker training, the real challenge is fitting the training into the employee's short working hours. The duration cannot be shortened, but the arrangement is flexible:
- Split it into sessions. Basic training can be split into sessions of at least 1 hour. For someone working 20 hours a week, an 8-hour basic training can be spread over several weeks, as long as the 3-month limit is not exceeded.
- Use remote training in the right place. General, health and technical topics can be delivered remotely. The topic of job- and workplace-specific risks, however, is delivered face to face in hazardous and very hazardous workplaces.
- Training is working time. Under Art. 17 of Law No. 6331, time spent in training counts as working time and the cost of training cannot be passed on to the employee. Under Art. 5 of the 2026 regulation, if training exceeds weekly working time, those hours are treated as additional hours or overtime. Clarify with human resources in advance how training that exceeds the hours in a part-time employee's contract will be paid.
- Do not forget the exam. A pass requires at least 60 points out of 100; the same rule applies to part-time employees.
For the full regulation, see our article on the new OHS training regulation.
Part-time headcount calculation: specialist and physician time
OHS specialist and workplace physician times are defined in minutes per employee. Art. 12 of the Regulation on OHS Specialists and Art. 12 of the Regulation on Workplace Physicians and Other Health Personnel contain no provision allowing pro rata treatment of part-time employees. The only exception listed in Art. 6 of Law No. 6331 is that apprentices and interns under vocational education and higher education legislation are not included in the total headcount when determining assignment time. The part-time headcount calculation is therefore simple: every part-time employee is one person.
Back to the example in the introduction. A shop in the less hazardous class (confirm the class against the NACE code in the SGK registration) with 18 full-time and 12 part-time employees:
| Calculation | Correct: 30 employees | Wrong: "full-time equivalent" 24 | Difference |
|---|---|---|---|
| OHS specialist (10 min) | 300 min = 5 hours/month | 240 min = 4 hours/month | 60 min short |
| Workplace physician (5 min) | 150 min = 2.5 hours/month | 120 min = 2 hours/month | 30 min short |
At thresholds, the mistake is more costly:
- DSP: In the very hazardous class, workplaces with 10 or more employees require other health personnel. A very hazardous workshop with 6 full-time and 6 part-time employees has 12 employees; counting "we are 9" overlooks the DSP obligation.
- OHS committee: Under Art. 22 of Law No. 6331, a committee is set up in workplaces with fifty or more employees where permanent work lasting more than six months is carried out. 40 full-time and 14 part-time employees make 54 people.
- First aiders and support staff: There must be one first aider for every 20 employees in less hazardous, every 15 in hazardous and every 10 in very hazardous workplaces; the number of support staff is also determined by headcount. Part-time employees are included in these numbers.
In less hazardous workplaces with fewer than 50 employees, monthly times may be combined within the same contract year (Regulation on OHS Services Art. 11/7). This flexibility makes visit planning easier in small shops and cafés with many part-time employees, but it does not reduce the total time.
On-call work and OHS: special cases
Under Art. 14 of Law No. 4857, if the parties do not set the duration, the weekly working time is deemed to be 20 hours; unless otherwise agreed, the employer makes the call at least four days in advance and, if daily hours are not set, employs the worker for at least four consecutive hours per call. For on-call work and OHS, the following points matter:
- Training and examination before the first call: By the day an on-call worker first comes on site, they must have received induction training and, where required, a fitness-for-work report must have been issued. The four-day call period provides a sufficient window for this.
- Long periods without calls: Art. 17 of Law No. 6331 requires refresher information training on return to work for anyone away from work for more than six months for any reason. Treat an employee who has not been called for more than six months within this scope; for details, see our article on refresher and additional training.
- Employees missing from lists: Shift and emergency team lists must also show the people called in that day. In an evacuation, knowing who is inside matters more than knowing who is on which contract.
- PPE and issue records: PPE is issued to an on-call worker on the first call; size and fit checks must not be skipped.
Part-time employees working for more than one employer
A part-time employee may also be working for another employer in the same period. In that case each employer is separately responsible for its own workplace:
- Training: The topic of workplace-specific risks is delivered separately at each workplace. Decide together with the workplace physician and the specialist how to treat a general training certificate obtained from another employer.
- Examination: Fitness for work is assessed for the risks of the job itself; another workplace's report may have been based on different risks.
- Fatigue: The overall work and rest pattern of a person who works one job in the morning and for you in the evening must be considered in the risk assessment. We cover this in our article on shift systems and fatigue management.
The share of part-time employees is high in office and retail businesses; our article on OHS in supermarkets and shops is a useful complement for store operations. Setting up the headcount-based time calculation and the training calendar is one of the first steps of our OHS specialist service.
Frequently Asked Questions
Does a part-time employee count in full in the OHS time calculation?
Yes. Specialist and physician times are defined per employee, and the legislation contains no pro rata treatment for part-time employees. The only group excluded from the calculation is apprentices and interns with student status.
How many hours of basic training does a part-time employee receive?
The same as a full-time employee: 8 teaching hours in less hazardous, 12 in hazardous and 16 in very hazardous workplaces. The training can be split into sessions of at least 1 hour but must be completed within 3 months at the latest after starting work.
Must an on-call worker be trained before the first call?
Induction training is given before starting work, so it must be completed before the first call. In hazardous and very hazardous work, the fitness-for-work report is also obtained before the first working day.
Is the periodic examination frequency different for part-time employees?
No. Frequency depends on the hazard class: at the latest every 5 years in less hazardous, every 3 years in hazardous and every year in very hazardous workplaces. The workplace physician may shorten this interval if necessary.
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.