In brief
Law No. 6331 requires workers to be given the right to make proposals on occupational health and safety; a suggestion scheme is how that right works in the workplace. A good scheme collects suggestions easily, assesses them in a defined committee against measurable criteria, responds to the suggester on time and makes implemented suggestions visible. A suggestion box that goes unanswered loses more trust than having none at all.
Why should an OHS suggestion scheme be a separate process?
An operator on the press line knows better than anyone why they reach for a long lever every time the die is changed. A forklift driver learns in the first week on shift at which corner pedestrians suddenly appear. An OHS suggestion scheme is the structure that records this shop-floor knowledge and turns it into decisions.
This is not a matter of choice but the implementation of a legal obligation. Under Art. 18/1-a of Law No. 6331, the employer provides the means for workers or their representatives to be consulted on occupational health and safety matters, to be given the right to make proposals and to take part in discussions. Art. 20/3 gives the worker representative the right to make proposals to the employer and request measures to eliminate the source of a hazard or reduce the risk.
The suggestion scheme should not be confused with the near miss reporting system. A near miss report describes an incident that has happened; a suggestion brings an improvement idea before any incident occurs. Both can be collected on the same form, but their assessment and feedback flows should be tracked separately.
How are suggestions collected: from the box to the digital form
The classic safety suggestion box still works, but it is not enough as the only channel. The strengths and weaknesses of the different channels are as follows:
| Channel | Strength | Weakness | When is it suitable? |
|---|---|---|---|
| Locked suggestion box | Anonymity, no digital skills needed | Suggestions wait if the box is not opened regularly | Basic channel in every workplace |
| QR code digital form | Photos can be attached, automatic logging and numbering | Limited in areas where phone use is prohibited | Offices, warehouses, break areas |
| Kaizen OHS card | Describes the before and after situation in writing and visually | Takes time to fill in | Production cells, continuous improvement teams |
| Toolbox talk | Immediate discussion, team involvement | Lost if what is said is not recorded | Start of shifts |
| Via the worker representative | A voice for reticent workers | Depends on the representative's workload | Large and shift-based workplaces |
Whichever channel is chosen, every suggestion should end up on a single list and receive a number. The suggestion box should be opened at least once a week by a designated person and its contents entered on the same list. Verbal suggestions made during a toolbox talk should also be written down by the supervisor leading the talk.
What should a kaizen OHS card contain?
The kaizen OHS approach aims for small, continuous improvements. It is important that the suggestion form is simple but sufficient. A good form contains the following fields:
- Location and task: Which department, which machine or task?
- Current situation: What is the problem? A photo if possible.
- Suggestion: What should change? A rough sketch is acceptable.
- Expected effect: Which hazard is reduced, who is affected?
- Suggester: Giving a name is optional; however, the form states that if no name is given, feedback will be given via the noticeboard.
- Record details: Number, date received, assessment date and outcome. This section is filled in by the scheme coordinator, not the suggester.
Fields that the worker cannot know, such as a "cost estimate", should not be mandatory on the form. Such fields reduce the number of suggestions.
Assessing worker suggestions: committee and criteria
If assessing worker suggestions is left on one person's desk, suggestions either pile up or are rejected arbitrarily. Set up a small review team: the OHS specialist, the relevant department head, someone from maintenance or the technical unit and the worker representative. In workplaces with 50 or more workers, this team can work as a sub-group of the OHS committee. Art. 8/1-c of the Regulation on OHS Committees gives the committee the duty of assessing hazards and measures in the workplace, determining measures and reporting them to the employer. For setting up the committee, see our article on how to set up an OHS committee.
Apply the same criteria to every suggestion. A sample scoring:
| Criterion | 1 point | 3 points | 5 points |
|---|---|---|---|
| Level of risk reduction | Warning or instruction only | Engineering control | Eliminates the hazard |
| Number of workers affected | One person | One department | Several departments |
| Feasibility | Requires investment and a long time | Can be done in planned maintenance | Can be done immediately |
The level of risk reduction criterion is based on the logic of the hierarchy of controls. The score leads to one of four decisions: implement now, plan (with an owner and deadline), reject with reasons or escalate to the committee or management. Rejection without reasons should not be accepted.
Suggestion feedback: timescales and communication
Most suggestion schemes collapse not at the collection stage but at the suggestion feedback stage. The legislation does not set a response time; the company sets and announces timescales in its own procedure. A workable example arrangement is as follows:
- Acknowledgement: Within 2 working days at the latest, with the suggestion number.
- Decision: Within 10 working days at the latest, with one of the four decisions.
- Implementation update: For suggestions given a "plan" decision, the deadline and owner are notified to the suggester in writing or via the noticeboard; if the deadline slips, the new date is also notified.
- Close-out: When implementation is complete, the suggestion is closed with before and after photos.
For a rejected suggestion, the reason should be written in plain language: "The fixed guard you suggested prevents die changes; an interlocked cover is being considered instead." A reply like this turns even a rejection into a message that increases participation. To track the deadlines of planned measures, you can use the table structure in our article on tracking corrective and preventive actions.
Making implemented suggestions visible
If workers do not see that their suggestion has actually been implemented, they will not bring a second one. For visibility:
- A "suggestions implemented this month" corner on department noticeboards, with before and after photos,
- Mentioning the suggester's name in toolbox talks, if they have given permission,
- Including implemented and pending suggestions as a separate agenda item in the OHS committee meeting minutes. For the format of the minutes, see our article on OHS committee meeting minutes.
If a reward is used, it should be tied not to the number of suggestions but to the effect of the implemented suggestion. Rewards tied to the number of "accident-free days" should not be combined with the suggestion scheme, as they can discourage incident reporting.
Monitor the health of the scheme with three simple indicators: the annual number of suggestions per worker, the average decision time and the proportion of suggestions implemented. You can add these indicators to your set of OHS performance indicators. In automotive suppliers in Bursa and the surrounding provinces, customer audits frequently ask for evidence of worker participation; suggestion records are the most concrete form of that evidence. To prepare, see our article on supplier OHS audits and our automotive supplier industry page.
Five common mistakes that weaken the scheme
If the number of suggestions falls a few months after the scheme is set up, the cause is usually one of the following:
- The box not being opened for months: When the person holding the key to the suggestion box goes on leave, the process stops. Assign the key and the opening day to two people.
- The suggestion turning into a complaint about a person: A note such as "the shift supervisor makes us remove the guard" is not a suggestion but a non-conformity report. Reports like this should be examined through a separate, confidential flow by the OHS specialist and management.
- Treating every suggestion like an investment request: Most suggestions are a marking, a fixture or a change to an instruction. They should not wait for the budget cycle; give supervisors limited authority to make an "implement now" decision.
- Leaving implementation to the suggester: The approach "it's your idea, you do it" turns a suggestion into a punishment. The person responsible for implementation is decided in the committee.
- Not entering it in the risk assessment: An implemented measure changes the risk score of the related hazard. If this change is not written into the risk assessment, the measure remains invisible at the next revision.
At Bursa Sistemer, under our OHS specialist service we design the suggestion form together with the company, attend review meetings and enter implemented suggestions in the risk assessment. You can plan the dates of committee and review meetings with the OHS calendar tool.
Frequently Asked Questions
Is it mandatory to set up an OHS suggestion scheme?
The Law does not use the term "suggestion scheme"; however, Art. 18 of Law No. 6331 makes it an obligation of the employer to give workers the right to make proposals on OHS matters. Setting up a recorded route through which this right can be exercised is the most concrete way to meet this obligation.
Should the suggestion box be anonymous?
There should be an anonymous option, because some workers will only make suggestions this way. Workers who give their name receive individual feedback; those who do not receive feedback via the noticeboard.
How quickly should a suggestion be answered?
There is no time limit in the legislation. In practice, acknowledging receipt within a few working days and giving a decision within two weeks, and announcing these timescales in the procedure, builds trust.
Who should run the suggestion scheme?
The employer owns the scheme. Its day-to-day running is handled by the OHS specialist or a person designated by the company; assessment takes place in a small team made up of the specialist, the department head, the technical unit and the worker representative.
Can kaizen and OHS suggestions be collected on the same form?
They can. However, suggestions with an OHS impact should be marked on the form and the OHS specialist must take part in their assessment.
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.