In brief
Time spent in OHS training counts as working time; if training takes the employee beyond weekly working hours, the excess is overtime or extended hours (Law No. 6331, Art. 17/7; 2026 training regulation, Art. 5/6). Training outside working hours is not prohibited, but it creates pay or time off in lieu. In shift workplaces, training can be planned within shift hours by splitting it into sessions of at least one lesson hour.
Can OHS training be given outside working hours?
The short answer: it can, but it is not free. The legislation does not prohibit training at any particular time; it regulates how time spent in training is counted. The provision is equally clear in both the Law and the new training regulation published on 2 April 2026:
This article explains how these three provisions are reflected in payroll, timesheets and the shift roster. For the general changes in the Regulation, see our article on the new OHS training regulation 2026.
Training time counts as working time: what does this mean in practice?
The phrase "counts as working time" means that an employee in training is treated as if they were doing their job during those hours. The practical consequences on site are:
- It is entered on the timesheet. Training hours are recorded as working hours; a training day is not marked as leave, excused absence or "unpaid".
- Pay is not deducted. The employee attending training is paid for those hours; no training fee, travel or materials cost is taken from the employee.
- Remote training also counts. The Regulation does not distinguish by training method when counting time as working time. Remote training completed by the employee at home is also working time.
- Induction training is part of the first day. The induction training of at least two hours given before starting work is included in the employee's working time on their first working day; for its content, see our article on the induction training programme.
Overtime and OHS training: a worked calculation
When training takes place outside working hours, it is added to weekly working time. The decisive factor is the employee's contractual weekly hours. Under Art. 41 of Labour Law No. 4857, work exceeding 45 hours a week is overtime, and each hour is paid at the normal hourly rate plus 50%. If weekly hours are set below 45 hours by contract, work between the contractual hours and 45 hours is extended hours and is paid at plus 25%.
| Contractual weekly hours | Training added to the week | Total | Result |
|---|---|---|---|
| 45 hours | 4 hours on Saturday | 49 hours | 4 hours of overtime (plus 50%) |
| 40 hours | 4 hours on Friday evening | 44 hours | 4 hours of extended hours (plus 25%) |
| 42.5 hours | 4 hours | 46.5 hours | 2.5 hours of extended hours (25%) and 1 hour of overtime (50%) |
| 45 hours, training within working hours | Training replaces production hours | 45 hours | No additional payment arises |
If the employee wishes, they may take time off instead of pay: 1 hour 30 minutes for each hour of overtime, and 1 hour 15 minutes for each hour of extended hours. Time off is given within six months. Overtime requires the worker's consent, and total overtime may not exceed 270 hours a year (Art. 41). In workplaces using averaging, if the weekly average over a two-month period does not exceed 45 hours, time exceeding 45 hours in some weeks does not count as overtime (Art. 63); assess this detail with your payroll department.
Weekend OHS training
Saturday or Sunday training is the most common solution to avoid stopping production. Pay attention to three points:
- The weekly rest day is protected. The worker is given at least 24 hours of uninterrupted rest within each seven-day period (Labour Law, Art. 46). Do not schedule training in a way that removes this rest.
- Consent is obtained. If weekend training exceeds weekly hours, it is overtime and the employee's consent is required.
- Effectiveness drops. In long training squeezed into the weekend, attention falls. The aim of the Regulation is for training to change the employee's knowledge, attitudes and behaviour (training regulation, Art. 5/3); this aim is hard to achieve in a tired room.
Weekend training should remain an exception; setting the regular training calendar within shift hours is better in terms of both cost and effectiveness.
How is training planned in a shift workplace?
The Regulation gives shift workplaces clear flexibility: basic training can be split into different time slots, but each session must be at least one lesson hour. One lesson hour consists of at least 45 minutes of teaching and a 15-minute break (training regulation, Art. 4/1-b). In hazardous and very hazardous workplaces, the job- and workplace-specific risks topic (topic 4) is delivered face to face; the first three topics may also be delivered remotely.
Example: a metalworking plant in the hazardous class in an OIZ (organised industrial zone) in Bursa, working 08–16, 16–24 and 24–08 shifts. Basic training must be at least 12 lesson hours, and topic 4 at least 3 lesson hours.
| Sessions | Duration | Topic | Method | Timing by shift |
|---|---|---|---|---|
| 1–3 | 6 lesson hours | General, health and technical topics | Remote, recorded platform | Within the employee's own shift, two hours on each of three separate days |
| 4 | 2 lesson hours | Technical topics continued | Face to face | At the start of the shift, in the department meeting room |
| 5–6 | 4 lesson hours | Job- and workplace-specific risks | Face to face, on site | Within the shift, two sessions of two hours; the line is kept running with relief staff |
In this plan, no employee is called to training outside their shift, no additional payment arises, and topic 4 is taught on site at the employee's own machine. Pay particular attention to the night shift: as training time is working time, training added to the end of a night shift lengthens the shift. Under Art. 69 of the Labour Law, workers' night work may not exceed seven and a half hours; keeping an employee coming off the night shift for training both strains this limit and reduces the effectiveness of the training. For details, see our article on night shifts.
For a new employee who will work on the night shift, plan their induction training, if possible, during day hours when the trainer and the department supervisor are on site. These hours are also working time and count towards the weekly total together with that week's shifts; prepare the first week's roster so that it also shows the training hours.
For other issues specific to shift production in Bursa's OIZs, see our article on OHS in shift production in Bursa OIZs.
Common mistakes
- Training during the lunch break: The rest break does not count as working time and is given without interruption (Labour Law, Art. 68). Turning the break into training removes the employee's right to rest.
- Sessions shorter than one hour: 30-minute "start-of-shift training" sessions are useful briefings, but they do not count towards basic training hours.
- Not writing times on the record: The training attendance record contains the place, date, and the names and signatures of the participants and trainer (training regulation, Art. 17/1). The hours of training outside working hours must match the timesheet.
- Not entering training outside working hours on the timesheet: In an inspection, the date and time on the record may be compared with payroll.
- Putting an employee coming off the night shift into training: It both strains the legal limit and makes the training pointless.
The 2026 base administrative fine for not providing training is 8,980 TL per employee; you can see the amounts in the OHS administrative fines tool. For details of training topics, see our article on basic OHS training topics, and to set up a training calendar for your shift pattern, see our OHS training service.
Frequently Asked Questions
Is pay due if OHS training is given outside working hours?
Yes. Training time counts as working time; the part exceeding weekly working hours is paid as overtime (50%) or extended hours (25%), or, if the employee wishes, taken as time off.
Can we deduct the cost of training from the employee?
No. Both Law No. 6331 and the 2026 training regulation explicitly provide that the cost of training cannot be passed on to the employee.
If the employee completes remote training at home, is this working time?
Yes. The rule does not distinguish by training method. Completion records on the remote training platform also help document the time.
Into how many parts can basic training be split in a shift workplace?
The Regulation sets no limit on the number of parts; each session must be at least one lesson hour, and the total must meet 8, 12 or 16 lesson hours depending on hazard class. Basic training is completed within three months of starting work at the latest.
Induction, basic and refresher training in line with the 2026 regulation; on your premises, with examples from your own site and fully documented.
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.