OHS Obligations for Private Schools and Course Centres

Private school workplace safety: who is an employee and who is not?

Most of the people in a private school or course centre during the day are not employees: pupils, parents and visitors. This is where the confusion in private school safety planning comes from. Some obligations arise only for employees, while emergency preparedness covers everyone in the building.

Under Art. 2 of Law No. 6331 on Occupational Health and Safety, the Law applies to all public and private sector work and workplaces regardless of their field of activity. Teachers, administrative staff, cleaning and security staff, school bus drivers and canteen workers fall within this scope; teachers paid by the lesson or working part-time are also employees. Pupils, however, are not employees as defined by the Law. Even so, Art. 10 of the Regulation on Emergencies in Workplaces requires other persons likely to be present at the workplace to be taken into account when establishing emergency response and evacuation methods.

On the building side, the Regulation on the Protection of Buildings from Fire (BYKHY) comes into play. Art. 11 of the regulation counts as educational facilities buildings used for educational purposes by six or more people for 4 hours or more a day or more than 12 hours a week. Nursery schools, special education institutions and private tutoring centres are explicitly included in this class.

Basic obligations for employees

Obligation	Summary	Legal basis
Specialist and physician	An OHS specialist and a workplace physician are assigned; times are calculated by hazard class and number of employees	Law No. 6331 Art. 6
Risk assessment	Carried out including classrooms, laboratories, workshops, the sports hall, the kitchen and school transport arrangements	Law No. 6331 Art. 10
Induction training	Before starting work, at least 2 hours, face to face and practical	2026 Training Regulation Art. 7
Basic training	Within 3 months of starting work at the latest; 8 class hours in less hazardous, 12 in hazardous and 16 in very hazardous workplaces	2026 Training Regulation Art. 8, 13
Health surveillance	Pre-employment and periodic examinations	Law No. 6331 Art. 15
First aider	1 for every 20 employees in less hazardous, every 15 in hazardous and every 10 in very hazardous workplaces	First aid legislation
OHS committee	For work lasting more than six months with 50 or more employees	Law No. 6331 Art. 22

In less hazardous workplaces with fewer than 50 employees, the employer or their representative can carry out the specialist and physician service personally after completing the Ministry’s training; pre-employment and periodic examinations are excluded from this. Since the Constitutional Court ruling published in December 2025 removed the postponement for these workplaces, small course centres are also within the scope of the obligation. Do not assume your business’s class; check it against the activity code in your SGK registration. We explained the method in our article on how to find out your hazard class.

What should OHS training for teachers cover?

The 2026 Regulation on OHS training divides basic training into four topic groups: general, health, technical, and job- and workplace-specific risks. In OHS training for teachers, the fourth group should be filled not with a template presentation but with the school’s own conditions:

Science laboratory and workshops: Chemical storage, supervising pupils during experiments, hand tools and machines.
Physical education and sport: Unsecured goals and basketball hoops, carrying equipment, first response to injuries.
Voice and communication: The strain of speaking loudly for long periods and reporting complaints to the workplace physician.
Psychosocial risks: Verbal and physical violence from parents or pupils, and the reporting route.
Duties in an emergency: How the teacher will evacuate their class, how they will carry the register, and who will accompany a disabled pupil.

Under the regulation, the first three topic groups may be delivered remotely; in hazardous and very hazardous workplaces, the fourth topic is delivered face to face. Refresher training is at least 8 hours and is repeated every 3 years in less hazardous, every 2 years in hazardous and every year in very hazardous workplaces. For details of the topic headings, see our article on basic OHS training topics.

The school emergency plan: how do you write pupils into the plan?

The school emergency plan must meet the team provisions of two different regulations together. Let us explain this with an example: consider a school with 24 employees and 300 pupils.

Regulation on Emergencies, Art. 11: The number of support staff for each of the firefighting, rescue and protection teams is calculated according to the number of employees. The thresholds are 30 employees in very hazardous, 40 in hazardous and 50 in less hazardous workplaces; in a school with 24 employees, at least one person for each team is sufficient whatever the class. The first aid team is set up under first aid legislation.
BYKHY Art. 126: In non-residential buildings with more than 50 people inside, firefighting, rescue, protection and first aid teams are set up. The firefighting and rescue teams consist of at least three people each, and the protection and first aid teams of at least two people each. This calculation is based on the number of people in the building; pupils are also counted.

As a result, in the example school it is not the minimum of the Regulation on Emergencies but the higher minimum of the BYKHY that is decisive. Team members are selected from among employees; pupils are not assigned team duties.

The parts of the plan specific to pupils are as follows:

Accompaniment: Art. 10 of the regulation requires elderly, disabled and pregnant employees and children in a crèche to be accompanied during evacuation. In a school, this principle is applied by name for young age groups and disabled pupils.
Class responsibility: In every lesson, the teacher in the classroom is responsible for evacuating the class and taking the register at the assembly area. Separate staff are assigned for break times, the lunch break and school bus times.
Register: The head count is done according to the daily register. The plan states where records are kept of pupils who leave early or arrive late during the day.
Lighting: Art. 72 of the BYKHY requires emergency lighting in buildings used for education.
Responsible person: Under Art. 124–125 of the BYKHY, the owners or managers of private institutions are responsible for fire safety; a fire safety officer is chosen from among staff for each floor or section.

For choosing the assembly area and the head count after evacuation, see our article on how to choose an assembly area, and for training team members, see support staff training.

The school drill: combining the employee drill with pupil evacuation

Art. 13 of the Regulation on Emergencies requires a drill to be carried out at least once a year and recorded on a drill form; Art. 129 of the BYKHY also provides for a firefighting and evacuation drill to be carried out in the building at least once a year. The two obligations can be met with a single, well-designed drill.

Steps for a school drill:

Scenario: A scenario such as a fire, earthquake or gas leak is chosen, and it is decided whether the scenario will coincide with a lesson or a break.
Preparation: Teachers are reminded of their duties, and escorts for young age groups and disabled pupils are checked.
Implementation: The alarm is raised, classes are evacuated and teams take up their positions.
Head count: Each teacher takes the class register, and the protection team collects the results.
Measurement: The evacuation time, the time taken to complete the head count and the problems observed are recorded.
Evaluation: The drill form is completed; shortcomings are entered into the plan and the next drill.

For the design of the drill and the drill form, see our article on how to carry out an emergency drill.

Course centres and shared buildings

Course centres often operate on one or two floors of a business centre and work with few staff in the evenings. Two issues therefore stand out in course centre OHS arrangements:

Joint plan: If there is more than one employer in the same building, the emergency plan is prepared jointly, and in business centres drills are carried out under the coordination of the management (Regulation on Emergencies Art. 13 and 17). Details are in our article on the emergency plan in a shared building.
Shifts: The shift pattern is taken into account when designating support staff (Art. 11). There should also be trained support staff among the employees present in the building during evening classes.

At Bursa Sistemer OSGB, we run occupational safety specialist and emergency plan services together for private schools and course centres in Bursa and the surrounding provinces, and we prepare the fourth-topic training for teachers according to the school’s laboratory, workshop and evacuation arrangements. For practical fire training, see our fire training page, and for the general framework for service businesses, see our office and retail sector page.

Frequently Asked Questions

Can pupils serve on emergency teams?

No. The Regulation on Emergencies requires support staff to be assigned from among employees. Pupils are taught the rules to follow during a drill, but they are not given firefighting, rescue or head count duties.

How many support staff should a school have?

Two calculations are made together. Under the Regulation on Emergencies, the number of employees and the hazard class are the basis; under the BYKHY, the total number of people in the building. If there are more than 50 people in the building, the BYKHY’s minimum team numbers apply; whichever is higher is met.

Are teachers paid by the lesson included in OHS training?

Yes. A teacher paid by the lesson or working part-time is also an employee. Induction training is delivered before they start teaching; basic and refresher training are subject to the same rules as for other employees.

How many times a year should a school drill be carried out?

Both the Regulation on Emergencies and the BYKHY require at least one drill a year. A short evacuation trial at the start of the school year is also recommended for new pupils and teachers.