In brief
In workplaces operating shifts, the legislation requires the assignment of the OHS specialist, workplace physician and DSP to match the shifts, emergency teams to be set up according to the shift pattern, and the physician to carry out health surveillance including night shifts. Sharing the monthly time according to headcount per shift, taking basic training to the night shift in sessions of at least one lesson hour each, and adding OHS items to the handover form stop the night team from being left out in a three-shift factory.
Why does an OHS plan for shift-based production in an OIZ need separate thought?
In Bursa's 17 active organised industrial zones (OIZs), shift and night-time production is common, especially among automotive suppliers, textile and machinery manufacturers. Bursa OSB, Nilüfer OSB, Hasanağa OSB and Kayapa OSB in Nilüfer; Demirtaş OSB in Osmangazi; Uludağ OSB in Gürsu and the Kestel and Barakfakih OSBs in Kestel are familiar examples. In a three-shift factory, the weak point of OHS is usually the night shift: management presence falls, maintenance teams are limited, and training and drills are generally planned around daytime hours. An OHS plan for shift-based production in an OIZ is built to correct this imbalance.
Such an OIZ factory OHS plan organises specialist and physician visits, training, emergency teams and handovers around the shifts. In this article we explain step by step what the legislation says about shifts and how to apply it on the ground.
What does the legislation say about shifts?
Shift-specific provisions are spread across several regulations:
| Topic | Provision | Legal basis |
|---|---|---|
| Specialist assignment | The calculated time cannot be split among several specialists; however, in shift-based workplaces the assignment is made to match the shifts | OHS Specialists Regulation Art. 7/4 |
| Physician and DSP assignment | In shift-based workplaces the assignment is made to match the shifts | Workplace Physicians and DSP Regulation Art. 7/3, 14/4 |
| Health surveillance | The physician carries out health surveillance of workers, including night shifts | Workplace Physicians and DSP Regulation Art. 9 |
| Emergency teams | The shift pattern is taken into account when designating support staff and their substitutes | Emergencies Regulation Art. 11/8 |
| Basic training | May be split into different time slots of no less than one lesson hour, taking the shift schedule into account | 2026 Training Regulation Art. 13/4 |
| Night work | Night is a period of at most 11 hours starting no later than 20:00 and lasting until no earlier than 06:00; night work cannot exceed 7.5 hours | Law No. 4857 Art. 69 |
| Shift rotation | A worker who works nights for one week moves to the day shift the following week; two-week rotation may also be applied; at least 11 hours of uninterrupted rest is given at shift change | Law No. 4857 Art. 69 |
| Young workers | Night work by workers under 18 is prohibited in industrial jobs | Law No. 4857 Art. 73 |
The common message is clear: monthly time, training and emergency arrangements cannot be built around the day shift alone.
OHS visits in a shift-based factory: an example of sharing the time
The minimum time is calculated on the workplace's total headcount; shifts do not reduce it, they only determine how it is distributed. As an example, take a factory in Bursa OSB with 360 workers manufacturing motor vehicle parts (29.32.20, hazardous). In the hazardous class, at least 20 minutes per worker per month is required for the specialist and 10 minutes for the physician:
- Specialist: 360 × 20 = 7,200 minutes (120 hours)
- Physician: 360 × 10 = 3,600 minutes (60 hours)
- DSP: not required in this factory, since it is mandatory only in very hazardous workplaces.
Sharing the time in proportion to the headcount of each shift is a good starting point:
| Shift | Workers | Specialist (min/month) | Physician (min/month) |
|---|---|---|---|
| A: 08:00–16:00 | 160 | 3,200 | 1,600 |
| B: 16:00–24:00 | 120 | 2,400 | 1,200 |
| C: 24:00–08:00 | 80 | 1,600 | 800 |
| Total | 360 | 7,200 | 3,600 |
This distribution is a starting point, not a rule. If the risk is higher on the night shift, for example because die changes and maintenance work pile up at those hours, a larger share of the specialist's time can be moved there. What matters is being able to show that each shift's needs for site tours, training and examinations are met over the year. You can calculate your own figures with the OHS obligation calculator, and find the details of the time rules in our article on physician and specialist working times.
Training and drills for the night shift
Shift-based training. Whatever shift a new worker starts on, they must receive at least 2 hours of face-to-face, practical induction training before starting work. For a worker starting directly on the night shift, this training is planned before their first night. Basic training is completed within 3 months of starting work at the latest and is at least 12 lesson hours in the hazardous class. Because the 2026 regulation allows this training to be split into sessions of at least one lesson hour each according to the shift schedule, it is possible to train the night team at night, in their own area. Job- and workplace-specific risk topics are delivered face to face in hazardous workplaces. For details, see our article on the 2026 training regulation.
Emergency teams. In the hazardous class, firefighting, rescue and protection teams are set up with at least one support person for every 40 workers or part thereof; there is one first aider for every 15 workers. These numbers should be distributed not according to the factory total but according to the people actually on site in each shift. Someone named on the night shift team list who does not work that shift is, in an emergency, absent.
Drills. An emergency drill is held at least once a year and a drill form is completed. Holding the drill at the same daytime hour every year means the night team never practises its evacuation route, assembly point or the step of alerting the OIZ fire brigade. Moving drills to different shifts over the years, or running a separate tabletop scenario exercise for the night shift, closes this gap. For scenario examples, see our article on emergency drills.
Adding OHS items to shift handovers
The handover is the only moment when what one shift knows is passed to the next. The legislation does not prescribe a form for it, but adding a few OHS items to the handover record prevents the night team from taking over a risky job started during the day without knowing it:
- Open permits to work: Is hot work, work at height or confined space work still in progress, and who will close the permit?
- Locked-out equipment: Is there a machine whose energy has been isolated and locked out for maintenance, and who owns the lock?
- Disabled guards: Is there a faulty light curtain, a non-working emergency stop or a removed guard, and has the machine been stopped because of it?
- Incidents: Was there a near miss, minor injury or chemical spill during the shift, and was it reported?
- Missing team members: Is a first aider or firefighting team member missing on this shift, and who is covering?
These five lines take a minute to fill in, on paper or in a digital system. Having the specialist review the handover records during visits is the shortest way to bring the night shift's problems to day management.
Health surveillance of night workers
The workplace physician carries out health surveillance of everyone, including those working night shifts. In the hazardous class, periodic examinations take place at least every 3 years; the physician may shorten this interval taking into account the effects of night work on fatigue, sleep patterns and nutrition. Scheduling examination days at the end or start of the night team's shift makes it easier for workers to attend without sacrificing sleep. The shift pattern and workload are also assessed among psychosocial risk factors; for the method, see our article on psychosocial risk factors.
From its centre in Nilüfer, Bursa Sistemer OSGB provides OHS specialist services and workplace physician services to factories in Bursa OSB, Nilüfer OSB, Demirtaş OSB and other zones, with visits planned around the shift pattern. For zone-specific notes, see our Bursa OSB and Nilüfer OSB pages, and for the sector's risks, our automotive suppliers page.
Frequently Asked Questions
Is specialist and physician time calculated per shift?
No. The minimum time is calculated on the workplace's total headcount and hazard class. Shifts do not increase or reduce this time; the legislation only requires the assignment to match the shifts.
Can we split basic training across night shifts?
Yes. Art. 13/4 of the 2026 Training Regulation states that basic training may be delivered in different time slots of no less than one lesson hour, taking the shift schedule into account. The total duration and the 3-month completion deadline do not change.
Do we need separate support staff on every shift?
The Emergencies Regulation requires the shift pattern to be taken into account when designating support staff and their substitutes. This means planning for trained people who can respond to an emergency to be actually on site on every shift.
Can a worker under 18 work the night shift?
No. Under Art. 73 of Law No. 4857, night work by child and young workers under 18 is prohibited in industrial jobs. When preparing the shift plan, these workers should be assigned to day shifts only.
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.