Using the Approved Register (Findings and Recommendations Book)

What is the approved register, and why is it so important?

The approved register is the official record in which the OHS specialist and the workplace physician write the deficiencies they see at the workplace and their recommendations to address them. In practice it is also referred to as the findings and recommendations book. Art. 4 of the Regulation on OHS Services defines the register as a serially numbered book whose pages consist of one original and two copies, kept as a single book for each workplace.

The register's importance comes from the legal consequence of every line written in it. Under Art. 7 of the regulation, findings and recommendations written in the approved register are deemed to have been served on the employer. This means the employer cannot say "I didn't know about this deficiency". Equally, it is difficult to prove that a warning not written in the register was ever given. Art. 8/2 of Law No. 6331 on Occupational Health and Safety also requires the specialist and physician to notify the employer in writing of the deficiencies and shortcomings they identify; the approved register is the standard tool for this notification.

After a workplace accident, the inspector, expert or court looks at this register first. Was the deficiency that caused the accident written down before, did the employer sign it, and when and how was it remedied? The register is the basic document showing both that the specialist did their job and that the employer took measures.

Who approves the approved register, and how is it prepared?

Under Art. 7/3 of the Regulation on OHS Services, the approved register is approved, with each page stamped, by the Provincial Directorate of Labour and Employment or a notary to which the workplace is attached. For a workplace in Bursa, this means the provincial directorate in Bursa or a notary.

In practice, the process works as follows:

1. A serially numbered book, each page consisting of one original and two copies, is obtained.
2. The book is taken to the provincial directorate or a notary on behalf of the workplace and its pages are stamped.
3. The original remains with the employer; the other two copies are kept by the specialist and the physician (Art. 7/5). If you receive services from an OSGB, these copies are kept in the OSGB's archive and shown on request during an inspection (Art. 13/2).

The phrase "a single book for each workplace" is important. A separate register is kept for a branch, warehouse or construction site with a separate SGK registration number. Writing the findings of two different workplaces in the same register makes it unclear on whom the entries were served.

Who writes what in the register?

The obligation to write in the register is set out for the two professions in separate regulations:

• OHS specialist: Under Art. 11/4 of the Regulation on the Duties, Powers, Responsibilities and Training of OHS Specialists, the specialist writes in the approved register their findings and recommendations, their activities relating to the duties listed in Art. 9, their joint work with the physician and other necessary matters.
• Workplace physician: Under Art. 11/4 of the Regulation on Workplace Physicians and Other Health Personnel, the physician also writes their findings and recommendations in the approved register.
• Other health personnel (DSP): The regulation does not give DSP the duty of writing in the register; DSP pass their findings and advice to the workplace physician (Art. 18/3).

The register is not just a list of deficiencies. Training given, site inspections carried out, accident investigations, work done together with the physician and the closing of previous findings are also written here. You can find the specialist's other duties on our OHS specialist page, and the physician's in our article on workplace physician duties.

What is written in the approved register? Example entries

For an entry in the register to be useful, everyone who reads it must understand the same thing. You can see the difference between a weak and a good entry in this table:

A good entry contains the following elements:

1. Date and time of the visit.
2. Location: department, machine number, line or room.
3. Concrete finding: what was seen, how many, in what condition. With a photo number where possible.
4. Recommendation: what needs to be done, and any interim measure.
5. Priority and recommended deadline: urgent, short term, planned.
6. Reference to previous entries: "Item 4 in the entry dated … has been remedied and was seen on site."

The employer's obligation to sign and follow up

Under Art. 7/4 of the Regulation on OHS Services, the approved register is signed by the specialist, the physician and the employer, together or separately. Art. 7/5 states that the employer is responsible for signing the register and keeping it in order, and that the register is shown when requested during an inspection.

The signature is not an approval but a record of having been informed. It is possible for the employer to disagree with a recommendation; however, in that case they need to put their reasoning and alternative measure in writing. Art. 5/5-ç of the regulation obliges the employer to implement the measures notified in writing by the persons they have appointed or by the OSGB.

When signing, the employer or their representative should do the following:

1. Read the entry and ask about anything you do not understand. A vague finding is later closed with the wrong measure.
2. Make the deadline realistic. If a job cannot be done within the recommended time, write the interim measure and the new date in the register together with the specialist.
3. Identify the person responsible. A name in the business must be assigned for each finding; "maintenance will do it" is not enough.
4. Reply in writing to recommendations you disagree with. Note your reasoning and alternative measure on the same page or notify them in writing.
5. Do not delay on an entry concerning a life-threatening danger. If the specialist recommends stopping a job, take the decision the same day.

In the case of a life-threatening danger, the process goes further. If written recommendations on matters involving a life-threatening danger, such as fire, explosion, collapse or a chemical leak, are not implemented within a reasonable time, the specialist and physician are obliged to notify the Provincial Directorate of Labour and Employment in writing (Regulation on OHS Specialists Art. 11/3; physician regulation Art. 11/3). The basis for this notification is also usually the entry in the approved register.

From the register to an action list: a follow-up system

The register alone is not a tracking system; as the pages go by, open findings are overlooked. We recommend the following arrangement:

1. At the end of each visit, new findings are written in the register and transferred to the action list the same day.
2. The action list holds the finding number, person responsible, deadline and closing date.
3. At the start of each visit, the specialist checks the open items from the previous visit on site and writes the result in the register.
4. Once a month, management reviews open and overdue items.
5. At the end of the year, open items are carried over to the annual work plan and the annual evaluation report.

This arrangement keeps the answer ready to the labour inspector's question, "When was this deficiency identified, and when was it remedied?" We explained the other steps in preparing for an inspection in our article on preparing for a labour inspection.

The register when changing OSGB and during inspections

The original of the approved register is kept by the employer and stays at the workplace. Because the register belongs to the workplace, no new register is opened when the OSGB or specialist changes; the new specialist continues in the same register and, as a first task, takes over the open findings. We listed what should be handed over during the transition in our article on the OSGB change process.

Common gaps seen in inspections are:

• The register is not at the workplace but at the OSGB or with the accountant.
• No entries for months; visits are said to have been made but are not documented.
• Findings are written in general terms, with no location or deadline.
• The employer's signature is missing or appears only on the first pages.
• There is no record of previous findings being closed.

Frequently Asked Questions

Who approves the approved register?

The Provincial Directorate of Labour and Employment to which the workplace is attached, or a notary. Approval is given by stamping every page (Regulation on OHS Services Art. 7/3).

What happens if the employer does not sign the approved register?

Findings and recommendations written in the register are still deemed to have been served on the employer. The employer is responsible for signing the register and keeping it in order; unsigned pages are treated as a deficiency in an inspection.

Can other health personnel write in the approved register?

The regulation does not give DSP the duty of writing in the register. DSP pass their findings and advice to the workplace physician; the physician writes what they consider necessary in the register.

Is a separate approved register needed for each branch?

Yes. The register is a single book for each workplace. A separate register is kept for a branch, warehouse or construction site operating under a separate SGK registration number.

How often should entries be made in the approved register?

The regulation does not set a specific frequency. However, since the specialist and physician are obliged to write their findings, recommendations and activities in the register, at least one entry is expected at each visit. A register left blank for a long time makes it difficult to show that the service hours in the contract were actually used.