A New Plant in TEKNOSAB: OHS from Set-up to Production

A new plant in TEKNOSAB: why a separate OHS plan?

Bursa Technology OIZ (TEKNOSAB) in the Taşpınar neighbourhood of Karacabey is an industrial area launched by BTSO (Bursa Chamber of Commerce and Industry) and promoted as Turkey's first high-technology organised industrial zone. The zone has factories already in production on one side and plots where investment is still under way on the other. This creates a unique situation in terms of new factory OHS: machines arrive at your facility before the shell construction is finished, the first employees start work while machines are being commissioned, and teams from several different employers work together under the same roof.

We described the general steps for opening a new workplace in our article on OHS when opening a new workplace. This article focuses on the period from construction to first production of a factory built from scratch, and how responsibility changes hands during that period. Our planning notes specific to Karacabey are on our Karacabey OSGB page.

New factory OHS: three stages, three different pictures

Stage	Who works on site?	OHS focus	Critical documents
1. Construction	Main contractor, subcontractors, the investor's design and supervision team	Working at height, excavation, cranes, scaffolding, coordination between contractors	Health and safety plan, coordinator assignment, prior notification
2. Machine installation and commissioning	The machine supplier's assembly teams, electrical and mechanical contractors, the investor's maintenance and production engineers	First energisation, test runs without guards, lockout, assembly of heavy loads	Machine conformity documents, initial inspection reports, work permits
3. First production	The investor's employees; contractors for remaining work	New employees, new machines, trial production, changing processes	ISG-KATİP assignments, risk assessment, emergency plan, examination and training records

On paper the stages are sequential; on site they overlap. The real risk is that the person responsible for one stage does not know who is working on site in another stage.

Stage 1: The investor's tasks during construction

When you award the entire construction to a contractor, the contractor largely runs the site's OHS arrangements. However, the Regulation on OHS in Construction Work assigns the following tasks to the employer or the project manager:

Health and safety plan: Prepared, or commissioned, during the preparation phase of the project, before construction work begins.
Coordinator: If there is more than one employer or subcontractor on the same construction site, a health and safety coordinator is assigned.
Prior notification: If the work will last more than 30 working days and more than 20 workers will be employed continuously, or if the work will require more than 500 person-days, notification is made to the provincial directorate before work begins.

For the investor, the most valuable opportunity in this period is design. While the factory is still on paper, safe roof access and anchor points for lifelines, separation of pedestrian and forklift routes, loading ramps, escape routes and the assembly area, maintenance platforms and safety distances in machine layout are determined. Every measure added after the building is finished is both more expensive and weaker. When your own design and supervision team enters the site, an obligation of cooperation and coordination also arises as employers sharing the same area; for details, see our article on more than one employer in the same work area.

At the end of construction, ask the contractor for the health and safety file. This file contains the information needed for future maintenance, cleaning, renovation and demolition work on the building to be carried out safely, and is a reference document for the factory's maintenance team. For details of the regulation, read our article on the regulation on OHS in construction work.

Stage 2: Machine installation and commissioning OHS

With the arrival of the machines, the site begins to turn from a construction site into a factory, and commissioning OHS risks come to the fore: panels energised for the first time, test runs carried out before guards are fitted, several teams doing different jobs on the same machine, and the assembly of heavy parts.

Before accepting delivery of the machine:

Ask for conformity documents. The machine's CE marking, declaration of conformity and user manual in Turkish are part of the delivery. Most provisions of the new Machinery Safety Regulation (EU 2023/1230) will enter into force on 20 January 2027; after that date the 2009 regime based on Directive 2006/42/EC will be referred to as a transitional rule. Check which legislation the declaration of conformity was issued under. For details, read our article on the machinery safety regulation and CE.
Assess suitability for the work. The Regulation on Work Equipment requires the employer to take the necessary measures to ensure that the equipment used is suitable for the work to be done and does not harm employees (Art. 5). CE marking alone does not show that the machine will be safe on your line.

After installation, before first use:

Work equipment whose safety depends on installation and assembly conditions is inspected by authorised persons after installation and before first use; non-mobile equipment is inspected again after every relocation (Art. 7/2-a). The inspection contract is made through ISG-KATİP, the Ministry's online OHS registration system, at least one day before the inspection. For details, see our article on the initial inspection of work equipment.
Pressure vessels, lifting equipment, internal electrical installations and earthing, and fire installations are on the inspection list in Annex III. From 1 January 2027, the inspection of some equipment such as steam boilers will be carried out by accredited inspection bodies; set up your calendar accordingly.

During commissioning:

Define an energisation permit for each machine: first energisation is given with the approval of the electrical supervisor and the assembly team.
The lockout and tagout rule applies during assembly and testing; each team fits its own lock. For details, see our article on LOTO lockout and tagout.
Hot work, working at height and confined space entry are subject to work permits.
For the supplier's foreign assembly teams, the site rules, emergency arrangements and assembly point are explained in understandable language, with an interpreter if necessary. Law No. 6331 requires that employees coming from other workplaces to work receive information on the risks and measures at the workplace (Art. 16/2). In hazardous and very hazardous workplaces, these people cannot start work without a document showing that they have been trained on the risks of the work they will do (training regulation Art. 5/4).

Transition from construction to production: how is an area handed over?

The transition from construction to production is usually not a date but a process that progresses area by area. When the production hall is completed, the administrative building may still be under construction and solar panels may still be being installed on the roof. Manage this transition with written area handovers:

Define the area. Which area is being handed over to production, and where are its boundaries? Mark it on the layout plan.
Separate physically. Put a fence or barrier, a separate entrance and a separate vehicle route between areas still under construction and the production area. Contractor vehicles should not pass through the production area.
Collect the handover documents. The electrical installation design and initial inspection reports, earthing and lightning protection measurements, fire installation tests, checks of emergency lighting and escape routes, machine files.
Make remaining work subject to work permits. Any work the contractor does in the handed-over area is now construction work carried out inside an operating factory; assembly, renovation and maintenance also fall within the definition of construction work.
Sign the handover record. It is signed by the investor's production manager, the contractor, the coordinator and the OHS specialist.

Stage 3: OHS checklist before first production

From the day your first employee enters the facility, even for trial production, all your obligations as an employer begin. Complete the following list before first production:

Hazard class: Determine your class according to the NACE code of your main activity; the specialist's certificate class and monthly times depend on it.
Assignment: An OHS specialist and a workplace physician, and other health personnel if required, are assigned. The contract is approved by both parties on ISG-KATİP within 5 days at the latest; work cannot begin under an unapproved assignment. For the process, see our article on ISG-KATİP contract approval.
Risk assessment: Prepared before production starts, based on observations from design and commissioning.
Emergency plan: Fire, chemical spill and earthquake scenarios; support staff; coordination with the OIZ fire brigade. For details, read our article on emergency coordination with the OIZ fire brigade.
Pre-employment examinations: In hazardous and very hazardous work, an employee cannot start work without a fitness-for-work report. We plan tests with authorised health institutions.
Training: Every employee receives at least 2 hours of induction training before starting work; basic training is completed within 3 months at the latest. For jobs requiring vocational training, certificates are checked before hiring.
PPE: A PPE matrix is prepared by department and task, and PPE is issued against signature.
Periodic inspection calendar: An annual calendar is set up starting from the initial inspection reports.
Workplace measurements: Noise, dust and chemical measurements are planned with authorised laboratories once production reaches its normal pace; a measurement taken in an empty hall does not reflect reality.
OHS committee: A committee is set up in workplaces with fifty or more employees where continuous work lasting more than six months is carried out; start preparing as your headcount approaches this threshold.

You can see your numbers of specialists, physicians, support staff and first aiders with the OHS obligation calculator.

New facility risk assessment: be prepared to write it twice

The new facility risk assessment is written before first production, but it must be revisited in the first months. During trial production, processes, line speeds and the division of work change frequently; new employees are unfamiliar with the machines, and habits not foreseen in the design emerge. The Regulation on Risk Assessment requires the assessment to be renewed regardless of its period in the event of building changes, changes in technology, substances and equipment, and changes in production methods (Art. 12).

A practical approach is as follows:

Initial assessment: Prepared using design documents, machine manuals, problems seen during commissioning and lessons learned from similar facilities.
Intensive site follow-up: Site walks are made more frequent in the first months; near miss reporting is encouraged.
First revision: Once production reaches a stable pace, the assessment is reviewed using measurement results and what has been observed on site.

For assessing the construction stage, see our article with a construction site risk assessment example. At Bursa Sistemer, for new facilities in Karacabey and TEKNOSAB, we start our OHS specialist service during the commissioning period, and we prepare the risk assessment before first production and revise it in the first months.

Frequently Asked Questions

Can we start production at the facility while construction is ongoing?

You can, but the production area must be physically separated from areas still under construction, the area handover must be made in writing and every job the contractor does in the handed-over area must be subject to a work permit. Coordination between employers sharing the same area is also ensured.

When should we start OHS services at a new facility?

Before your first employee starts work. Trial production and the commissioning period are also covered by the obligations. Since the assignment does not begin until it is approved on ISG-KATİP, start the process before the hiring date.

Who is responsible for the OHS of the machine supplier's assembly team?

The assembly team's own employer is responsible for its employees' training and health surveillance. As the facility owner, you also ensure that these teams are informed about the risks, rules and emergency arrangements at your workplace, and coordinate the work with work permit and lockout rules.

Who carries out the risk assessment in a new factory?

A team made up of the employer, the OHS specialist, the workplace physician, the employee representative and employees who know the processes. In a new facility, the commissioning engineers and the maintenance manager should also join this team.