In brief
The legislation defines working at height not in metres but as any work where there is a difference in level and where injury could result from a fall. There is no separate "working at height regulation"; the rules are in the Construction Works OHS Regulation, the Work Equipment Regulation and the Regulation on Workplace Buildings and Annexes. The order of measures is: bring the work down to ground level, collective protection, suitable equipment, and lastly a personal fall protection system.
What is working at height?
A maintenance technician climbs onto a 1.5-metre-high conveyor frame to replace a faulty sensor. A warehouse worker stacks boxes at the edge of a lorry bed. A construction worker strips formwork next to a floor opening. All three are working at height; yet on site, the first two are often not seen that way.
Part (A) of Annex 4 of the Construction Works OHS Regulation gives this definition: work carried out in any area where there is a difference in level and where injury could result from a fall is considered working at height. The definition has two elements: a difference in level and the possibility of injury from a fall across that difference. The difference in level does not have to be upwards; working at the edge of an open excavation, a well or a platform opening carries the same risk.
In factories and warehouses, working at height is often done under the name of "maintenance", "cleaning" or "a quick job" and is therefore not planned. Make sure your risk assessment specifically looks for the following jobs:
- Maintenance and troubleshooting on top of machines, conveyors or silos,
- Cleaning roof gutters, replacing rooflight panels, maintaining solar panels,
- Placing goods on or changing labels on the upper levels of racking,
- Loading in lorry and truck beds, opening and closing tarpaulins,
- Passing materials at the edge of mezzanines and platforms,
- Work on ceiling lighting, ventilation ducts and fire installations.
Is there a working at height regulation? Which legislation applies?
There is no separate regulation under the frequently searched name "working at height regulation". The rules are spread across several regulations, and which one applies depends on the type of work:
| Legislation | Scope | Key provision |
|---|---|---|
| Law No. 6331 Art. 5 | All workplaces | Collective protective measures take priority over personal protective measures |
| Construction Works OHS Regulation, Annexes 4 and 5 | Construction works such as building, alteration, assembly and dismantling | Definition of working at height, safety nets, harness use, supervision by a competent person (Annex 4); temporary edge protection and guardrail dimensions (Annex 5 B) |
| Work Equipment Regulation, Annex II Art. 4 | Choice of equipment for temporary work at height | The most suitable equipment is chosen, collective protection is given priority, ladders are used only where the risk is low |
| Regulation on Workplace Buildings and Annexes, Annex I | Permanent workplaces such as factories, warehouses and offices | Guardrails on raised walkways and platforms, no access to roofs that are not sound without safe equipment, preventing unauthorised access to areas with a fall risk |
| PPE Use Regulation | Personal protective equipment | Selection, training and maintenance of PPE for risks that cannot be prevented by collective measures |
So a formwork carpenter on a construction site is protected under the Construction Works Regulation, while a maintenance worker cleaning a roof gutter at a factory is protected under the Work Equipment and Workplace Buildings and Annexes regulations. For the health and safety plan and coordinator obligations specific to construction works, see our article on OHS in construction works.
How many metres is working at height? Fall risk instead of metres
Rules often heard on site, such as "below 2 metres doesn't count as working at height", have no basis in Turkish legislation. The definition is based not on metres but on the possibility of injury from a fall. The practical reason is clear: falling from a one-metre platform onto a concrete floor, onto exposed reinforcing bars or onto a running machine can cause serious injury.
So instead of asking "how many metres?", the risk assessment should ask these questions:
- What surface could someone fall onto: concrete, reinforcing bars, a machine, water, a chemical pool?
- Is there an edge, opening, floor gap or fragile surface (rooflight panel, old roof covering)?
- How does the worker reach this point, and how long do they stay there?
- Do wind, rain, icing or poor lighting make the work harder?
- If a fall occurs, how will the person be rescued?
The numerical values in the legislation set the dimensions of protection, not the threshold at which working at height begins. Guardrail dimensions used to be in Annex 4; since the 2018 amendment, temporary edge protection systems have been regulated in part (B) of Annex 5 of the Construction Works Regulation. On flat surfaces (Class A), the minimum requirements are:
- A main guardrail at least 1 metre above the working surface,
- A toe board at least 15 cm high, adjacent to the platform,
- Gaps between the main guardrail, intermediate guardrail and toe board of no more than 47 cm,
- The system to be checked after installation and at least once a week.
The installation and inspection of edge protection should be planned as part of the health and safety plan in construction works.
Measures for working at height: the right order
When choosing measures, the order comes from the legislation itself. Annex 4 of the Construction Works Regulation requires assembly and similar work that does not have to be done at height to be done at ground level as far as possible, and collective protection measures to be used, or, where they cannot be, full body harness systems. Annex II of the Work Equipment Regulation repeats the same principle: collective protection measures take priority over personal protection measures.
| Order | Measure | Example |
|---|---|---|
| 1 | Eliminate working at height | Assembling the part at ground level and lifting it into place by crane, long-handled cleaning equipment, putting lighting on lowerable hangers |
| 2 | Collective protection | Guardrails, edge protection, floor opening covers, safe working platforms, safety nets (TS EN 1263-1 and 1263-2) |
| 3 | Suitable work equipment | Scaffolding with guardrails, scissor or boom-type elevating work platforms, platform steps with guardrails |
| 4 | Personal fall protection system | A full body harness attached to a suitable anchorage; where possible, work restraint that prevents reaching the fall point rather than arresting a fall |
| 5 | Administrative measures | Supervision by a competent person, permit to work, training, weather checks, rescue plan |
The rule for ladders should be read carefully: under the Work Equipment Regulation, ladders may be used as a workplace at height only where, because of the low risk, a safer piece of work equipment is not required and the conditions listed in the regulation are met. For ceiling work lasting all day, a platform or scaffold, not a ladder, should be chosen.
Periodic inspection of the equipment you use is also part of the measure: construction scaffolding is inspected at least every 6 months, and elevating work platforms at least once a year. Details are in our guide to periodic inspection intervals; you can track the dates with the OHS calendar. The Construction Works Regulation also requires regular inspection and maintenance of equipment for safe work at height, and inspection of scaffolds before use and weekly.
Who works in places with a fall risk, and how?
Alongside the measures, you also need the right person and the right organisation:
- Supervision: The Construction Works Regulation requires work at height to be carried out under the supervision and control of a competent person appointed by the employer.
- Weather conditions: In places exposed to strong winds, work is not carried out without the necessary safety measures; icing and rain should also be on the decision list.
- Fragile surfaces: On roofs and surfaces that are not sound and are made of fragile materials, measures are taken to prevent inadvertent walking or falling. In factories, transparent rooflight panels are the riskiest points in this respect.
- Training: The person who will work at height is shown how to use the equipment in hands-on induction training; you can find the programme in our article on an induction training example. For selecting harnesses, lanyards and anchorages, our article on the PPE Use Regulation offers guidance.
- Health: The fitness for work of the person who will work at height is assessed by the workplace physician; restrictions in the report are reflected in the task plan.
- Permit to work: For non-routine work at height such as maintenance and repair, a written permit to work guarantees that checks are made before the work starts.
Checklist for the site
When assessing fall risk on construction sites and at production facilities in Bursa and the surrounding provinces, we use these questions:
- Are floor openings, lift shafts and service shafts covered or guarded?
- Do the open edges of platforms, walkways and landings have a main guardrail, intermediate guardrail and toe board?
- Have the roof access route, roof edge protection and fragile panels been identified?
- Are scaffolds tagged and their inspections up to date?
- In jobs where harnesses are used, is the anchorage point defined and its strength known?
- Are a rescue plan and equipment ready for a worker left suspended in a harness?
- Has the area below been closed off or protected against falling objects?
The fact that activities such as site preparation (43.12.00) are in the very hazardous class requires a class A specialist to be appointed to these sites. Identifying fall risks on site and setting up the order of measures in the construction sector and at production facilities is the subject of our OHS specialist service, and recording the findings in documentation is the subject of our risk assessment service.
Frequently Asked Questions
From how many metres does working at height start?
There is no threshold in metres in Turkish legislation. Any work where there is a difference in level and where injury could result from a fall is working at height. The nature of the surface one could fall onto is as decisive as the height.
Is there a separate regulation called the working at height regulation?
No. The rules are in Annex 4 of the Construction Works OHS Regulation, Annex II of the Work Equipment Regulation and the Regulation on Workplace Buildings and Annexes. Depending on the type of work, one or several of them apply together.
Is wearing a safety harness enough?
No. The legislation gives priority to collective protection; a harness is used where collective measures cannot be, together with a suitable anchorage and a rescue plan.
Does climbing onto a roof or on top of a machine in a factory count as working at height?
Yes. Any difference in level where injury could result from a fall is working at height. Not accessing roofs that are not sound without equipment ensuring safe work is also a requirement of the Regulation on Workplace Buildings and Annexes.
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.