In brief
There is no single document called an "OHS file" in the legislation; it is the sum of the contracts, plans, reports and records the employer is obliged to keep. This article places these documents in a 10-folder structure and shows the basis, author and renewal frequency of each. Health records are confidential and kept separately under the workplace physician's responsibility; when an OSGB contract ends, all records and files are handed over to the employer.
What is an OHS file, and is it a single folder?
"OHS file" is not a document name defined in the legislation; it is the everyday name given to the records of the occupational health and safety activities the employer carries out. Its basis, however, is clear. Under Art. 7 of the Regulation on OHS Services, subject to the periods in the relevant legislation, the employer keeps all records relating to OHS activities carried out in the workplace, and keeps employees' personal health files for at least 15 years from the date they leave.
A well-organised OHS file answers four questions for a labour inspector, a customer auditor or an expert witness investigating after an accident: Who provides the OHS service in this workplace? Have the risks been identified? Are the controls being applied? Are employees trained and fit for work?
The file may be on paper or electronic. The risk assessment document can be prepared and archived electronically (Regulation on Risk Assessment, Art. 11/3). The approved logbook, however, is a physical book whose pages are sealed and approved by the provincial directorate or a notary, and the original stays with the employer.
OHS documents list: a 10-folder structure
The OHS documents list below gathers the documents into a practical 10-folder structure. The same skeleton can be used in a small workshop or a large factory in Bursa and the surrounding provinces; what changes is the thickness of the folders. The basis and author of each folder are shown separately:
| No | Folder | Documents inside | Basis | Prepared / kept by |
|---|---|---|---|---|
| 1 | Appointments and contracts | ISG-KATİP contracts (OSGB or in-house specialist, physician, DSP), declarations, termination notices | Regulation on OHS Services, Art. 14 | Employer |
| 2 | Risk assessment | Signed and initialled document, team appointment letter, revision records | Regulation on Risk Assessment, Arts. 6, 11, 12 | Prepared by the team, kept by the employer |
| 3 | Emergencies | Emergency plan, evacuation plan drawing, support staff appointments and training, drill forms | Law No. 6331, Art. 11; Emergencies Regulation | Employer, guided by the specialist |
| 4 | Plans and reports | Annual work plan, annual evaluation report | Regulation on OHS Services, Art. 13 | Prepared by the specialist and physician, approved by the employer |
| 5 | Approved logbook | Original of the findings and recommendations logbook | Regulation on OHS Services, Art. 7 | Original with the employer, copies with the specialist and physician |
| 6 | Training | Induction training records, basic and refresher training attendance lists, exam papers, certificates | Law No. 6331, Art. 17; 2026 Training Regulation | Prepared by the trainer, kept by the employer |
| 7 | Health surveillance tracking | A list showing who was examined on which date and the fitness-for-work outcome | Law No. 6331, Art. 15 | Workplace physician; medical records kept separately and confidential |
| 8 | Equipment and environment | Periodic inspection reports, workplace exposure measurement reports, maintenance records | Work Equipment Regulation, Annex III; Law No. 6331, Art. 10/4 | Issued by the authorised person and laboratory, kept by the employer |
| 9 | PPE and instructions | PPE issue forms, machine and work instructions, records of notification | PPE Use Regulation; Work Equipment Regulation, Art. 10 | Prepared by the specialist, kept by the employer |
| 10 | Incidents | Work accident and occupational disease records, investigation reports, SGK notifications, near-miss records | Law No. 6331, Art. 14 | Employer |
Folders added depending on the workplace:
- OHS committee: Committee decisions and meeting minutes in workplaces with 50 or more employees where continuous work lasting more than six months is carried out (Law No. 6331, Art. 22). For setting up and running the committee, see our article on how to establish an OHS committee.
- Employee representative: Election or appointment record. The number of representatives starts at 1 for 2–50 employees and rises to 6 for 2,001 or more employees (Law No. 6331, Art. 20).
- Vocational training certificates: Certificates of employees doing jobs that require vocational training in hazardous and very hazardous workplaces.
- Subcontractor documents: Risk assessment, training, health and appointment documents obtained from the subcontractor. For the list, see our article on OHS documents to request from subcontractors.
- Chemicals and explosive atmospheres: Chemical inventory, safety data sheets and, if any, the explosion protection document.
OHS documents that go into the employee's personnel file
Some workplace OHS documents are kept per employee rather than per workplace and are placed in the personnel file:
- The induction training record, signed by the trainer, the employee and the employer or their representative.
- Basic and refresher training certificates.
- A copy of the vocational training certificate; the vocational training regulation requires the certificate to be kept in the personnel file.
- The report showing the fitness-for-work outcome; the examination form itself remains in the personal health file held by the physician.
- The PPE issue form.
- If any, the letter appointing them as support staff, first aider or employee representative, and a copy of the first aid certificate.
Who is responsible for the OHS folder structure?
Most documents are prepared by the OSGB (joint health and safety unit) or the in-house specialist and physician; but the obligation to keep them and keep them up to date lies with the employer (Regulation on OHS Services, Art. 7/1). The allocation of responsibility in the legislation is as follows:
- Approved logbook: The original is kept by the employer and copies by the specialist and physician. The employer is responsible for having the logbook signed and kept properly; it must be shown when the labour inspector requests it (Art. 7/5). For writing and signature rules, see our article on the approved logbook.
- OSGB archive: OSGBs keep copies of the approved logbook, copies of the annual work plan and evaluation report, and training records in their own archive. At the end of the contract, they hand over all records and files to the employer, even if not asked (Art. 13/2).
- File owner at the workplace: Designate someone from HR or administration as the file owner. This person receives new documents during OSGB visits, files them and tracks items whose deadlines are approaching.
Outsourcing the service does not change the allocation of responsibility; for details, see our article on OSGB and employer responsibility.
Calendar for keeping the OHS file up to date
The value of an OHS file lies in its being up to date. The main renewal intervals:
| Document | Renewal or update |
|---|---|
| Risk assessment | Every 2 years in very hazardous, 4 in hazardous and 6 in less hazardous workplaces; after changes, accidents and near misses |
| Emergency plan | Every 2 / 4 / 6 years and on relevant changes |
| Drill | At least once a year |
| Refresher of basic training | Every year in very hazardous, every 2 years in hazardous and every 3 years in less hazardous workplaces; at least 8 hours |
| Periodic examination | Every year in very hazardous, at least every 3 years in hazardous and at least every 5 years in less hazardous workplaces |
| First aid certificate | 3 years; refresher training within the 3 months before expiry |
| Periodic inspections of work equipment | At most 1 year for most equipment; 6 months for construction scaffolding |
| Annual work plan and evaluation report | Every year |
Instead of remembering these dates one by one, you can enter them into the OHS calendar tool. Our article on how to prepare an annual work plan explains how to distribute the annual plan across items.
Gaps commonly found in inspections
- Missing initials and signatures: The pages of the risk assessment are not initialled, and the last page is not signed.
- Findings not followed up: The findings in the approved logbook are signed, but there is no record that they were implemented.
- Induction training without a record: There is a basic training certificate, but no induction training record.
- Inspection report without correction: The periodic inspection report has an "unsuitable" result, with no record of correction.
- Destroyed health files: The personal health files of employees who left were thrown away before 15 years had passed.
- Documents not at the workplace: Documents are kept only at the OSGB, with no copy at the workplace.
- Forgotten subcontractors: The documents of the cleaning, catering or maintenance company working permanently on site were never requested.
We explained which documents the inspector looks at on inspection day in our article on preparing for a labour inspector visit. In our OHS specialist service, on the first visit we take an inventory of existing documents and set up the gap list and folder structure together with your business.
Frequently Asked Questions
Should the OHS file be kept at the workplace?
Yes. The obligation to keep records belongs to the employer, and documents such as the approved logbook must be shown when the inspector requests them. The OSGB keeps copies in its own archive, but this does not replace the file at the workplace.
Are medical reports placed in the OHS file?
Examination forms and test results are confidential and are kept in personal health files under the workplace physician's responsibility. The OHS file should contain only a tracking list showing examination dates and the fitness-for-work outcome.
What happens to old documents when the OSGB changes?
Under Art. 13/2 of the Regulation on OHS Services, the OSGB hands over all records and files to the employer at the end of the contract, even if not asked. Receive the handover with a signed record and give this file to the new OSGB on its first visit.
Can OHS documents be kept electronically?
Partly. The risk assessment can be prepared and archived electronically; records with a secure electronic signature are also accepted for the maintenance log. The approved logbook, however, is a physical book whose pages are sealed and approved; always keep the signed version of documents that require a signature.
A certified specialist matched to your hazard class: site inspections, approved logbook, training plan, annual plan and report follow-up.