In brief
Under the 2026 training regulation, a worker who has been away from work for more than six months receives refresher training on topic 4 before being put back to work, and a worker who has had a workplace accident or contracted an occupational disease receives additional training before returning to work. When duties, equipment or technology change, training is given without waiting for the refresher period. Human resources can manage these three situations with a simple decision flow linked to return-to-work and job change records.
Refresher training and additional training: the difference
Periodic OHS training follows a calendar; refresher and additional training, on the other hand, are triggered by an event. In practice, both are sometimes called "return-to-work training", but the regulation ties them to different conditions. That is why they are missed not in the training plan but in human resources' day-to-day processes: a worker returning from long leave goes straight to their machine on Monday morning, and nobody looks for a training record for a worker returning after an accident. Yet both are training that must be given before work begins.
The basis is Art. 17 of Law No. 6331 on Occupational Health and Safety and the Regulation on OHS Training of Workers of 2 April 2026:
- Refresher training (Art. 18): given to a worker who has been away from work for more than six months for any reason, before they are put back to work. Its scope is topic 4 of Annex 1, i.e. risks specific to the job and the workplace.
- Additional training (Art. 19): given to a worker who has had a workplace accident or contracted an occupational disease, before they return to work; it covers the causes of the accident or disease, ways of protection and safe working methods.
- Training on change (Art. 14): for risks arising from situations such as a change of workplace or job, a change of work equipment or the introduction of new technology, training is given without waiting for the refresher periods.
- Worker changing workplace in the same job (Art. 25): basic training is not repeated in full; the worker is trained on topic 4 and also receives induction training.
We explain the regulation's general framework in our article on the new OHS training regulation. This article focuses on how human resources can catch event-triggered training.
Decision flow for human resources
When a return-to-work or job change record is opened, HR asks these five questions in order:
- Has the worker had a workplace accident or been diagnosed with an occupational disease? If yes, additional training is planned before they return to work and the workplace physician is informed.
- Have more than six months passed since the last day actually worked? If yes, refresher training on topic 4 is given before work begins.
- Is the worker's department, job, equipment used or working method changing? If yes, training on the risks of the new job is given before the new work begins; a job change examination is also planned.
- Does the new job require a vocational qualification certificate? If yes, the certificate is checked before the job begins.
- Is the refresher date for basic training approaching? If it falls in the same period as the event-triggered training, planning both together makes things easier; but one does not replace the other.
More than one question may be answered "yes". For example, for a worker who was on sick leave for seven months because of a workplace accident and is placed in a different department on return, all three types of training come into play; these can be given in a single session, provided the content of each is covered separately.
Which training for which situation?
| Situation | Training to give | When? | Basis |
|---|---|---|---|
| Return from leave, sick leave or military service of more than 6 months | Refresher (topic 4) | Before being put back to work | Regulation Art. 18 |
| Return after a workplace accident | Additional training: causes of the accident, ways of protection, safe working | Before returning to work | Regulation Art. 19; Law Art. 17 |
| Return after diagnosis of an occupational disease | Additional training | Before returning to work | Regulation Art. 19 |
| Change of department or job | Training on the risks of the new job | Before starting the new job | Regulation Art. 14; Law Art. 17 |
| New machinery, equipment or technology | Training on the changed risks | Before use begins | Regulation Art. 14; Law Art. 17 |
| Worker coming from another workplace in the same job | Topic 4 + induction training | On starting work | Regulation Art. 25 and Art. 7 |
| Leave of less than 6 months | No separate mandatory training in the regulation | Training on change if something has changed at the workplace | Regulation Art. 14 |
The last row is a frequent question. Refresher training is not mandatory for a worker who has been on leave for four months; however, if a new machine has been introduced in their department during that time, training on that machine's risks must still be given.
Returning from long leave: how are the six months calculated?
For refresher training, also referred to as "training after 6 months away", the regulation's criterion is being away from work for more than six months "for any reason"; the reason for the absence does not matter. Common situations in practice are:
- Long-term sick leave
- Maternity leave followed by unpaid leave; because maternity leave was extended to a total of 24 weeks by Law No. 7578, the total period with additional leave can easily exceed six months
- Military service
- Long unpaid leave or other periods during which the employment contract is suspended
Calculate from the worker's last day actually worked to the day they will return. The most practical method is to set a reminder in the HR system at the end of the fifth month for every worker going on long leave. That way, the training is ready when the return date is known. You will find the OHS side of pregnancy and maternity in our article on pregnant and breastfeeding workers.
Additional training after a workplace accident
The purpose of additional training is to help the worker understand what happened to them and to ensure they do not face the same conditions when they return to the same job. The training should therefore be based on the results of the accident investigation:
- Explain to the worker the root causes found in the accident investigation and the measures taken.
- Show the changed method, added guard or new instruction on site, at the machine.
- Ask for the worker's views; they are often the best witness to the event and can point out a cause that was missed.
- Document the training with a written record of its content.
An accident is one of the situations that require the risk assessment to be renewed; the content of the additional training should be consistent with the renewed assessment. We explain what to do immediately after an accident in our article on what to do after a workplace accident. After repeated absences for health reasons, the workplace physician carries out a return-to-work examination if the worker requests it; details are in our article on the return-to-work examination.
Job change training
A job change is the situation most easily overlooked, because the worker is already at the workplace and is assumed to be "trained". Yet for a worker moving from packing to the press line, topic 4 of their basic training now describes the risks of a different job. When a job changes:
- Training covering the hazards and measures in the risk assessment for the new job is given before the new work begins.
- Under Art. 15 of the Law, a health examination is carried out on a change of job; the workplace physician assesses fitness for the new job.
- The personal protective equipment required for the new job is issued and its use demonstrated.
- If the new job is one requiring vocational training, the certificate is checked; a worker without a certificate may not be employed in this job.
We discuss how to reflect machine or process changes in the risk assessment in our article on change management.
Who gives it, and how is it documented?
The regulation does not specify separately who gives refresher and additional training. Because the content is risks specific to the job and the workplace, this training is usually given by the OHS specialist and, where necessary, the workplace physician, with the department supervisor taking part. In basic training, topic 4 is delivered face to face in hazardous and very hazardous workplaces; delivering refresher training covering the same topic face to face and on site is also the safest practice.
Art. 24 applies to documentation: the employer documents all of this training and ensures it is kept in the worker's personnel file. The record should include the date, duration, topics, the name and title of the trainer and the worker's signature. Time spent in training counts as working time. For record-keeping, see our article on OHS training certificates and records.
As part of our OHS training service, Bursa Sistemer OSGB keeps the content of event-triggered training ready by department and monitors return and job change lists together with HR. You can track periodic training dates with the OHS calendar tool.
Frequently Asked Questions
How many hours should refresher training be?
The regulation does not set a separate duration for refresher training; it defines its scope as topic 4 of Annex 1. The duration is determined by the risks of the job the worker is returning to and the changes that have taken place at the workplace while they were away.
Does a worker returning from 5 months' leave need refresher training?
Refresher training is not mandatory for absences of less than six months. However, if equipment, methods or layout in their department have changed during this time, training on the change must still be given before work begins.
Is additional training given after a minor workplace accident too?
The regulation does not distinguish between workers who have had accidents; whether the accident was serious or minor, additional training on the causes of the accident and ways of protection is given before returning to work. For minor accidents, this training can be short and done on site, but it must be documented.
Does additional training count as the refresher for basic training?
No. Additional training and refresher training are triggered by events; the refresher period for basic training runs separately according to the hazard class.
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.