In brief
Law No. 6331 applies to all public and private workplaces with at least one employee, regardless of their line of business; apprentices and interns are also covered. Those outside the scope are limited to five narrow exceptions: domestic services, people producing on their own account without employing anyone, and certain military, disaster response and penal enforcement activities. Every employer within scope must obtain specialist and physician services; in less hazardous workplaces with fewer than 50 employees, the employer may provide this service themselves, excluding examinations, after completing the Ministry's training.
In which workplaces is OHS mandatory? The short answer
The answer to the question "in which workplaces is occupational safety mandatory?" is broader than most employers expect. Under Art. 2/1 of Law No. 6331 on Occupational Health and Safety, the Law applies to all work and workplaces in the public and private sectors, to the employers and employer's representatives of these workplaces, and to all their employees, including apprentices and interns, regardless of their line of business.
The decisive factor is whether anyone is employed. The Law defines an employer as a natural or legal person, or an institution or organisation without legal personality, that employs workers (Art. 3/1-ğ). In terms of scope, there is no difference between a café, an accountancy office, a car repair shop and a factory with hundreds of employees operating in an OIZ (organised industrial zone) in Bursa. The difference lies in how and how often the obligations are fulfilled.
The provision postponing specialist and physician appointment for public institutions and less hazardous workplaces with fewer than 50 employees no longer exists either: it was annulled by the Constitutional Court decision published in the Official Gazette on 09.12.2025, and no new postponement has been introduced. For details, see our article on OHS in workplaces with fewer than 50 employees.
The scope of Law No. 6331: what do "employee", "workplace" and "employer" mean?
The scope of Law No. 6331 is drawn by its definitions. Knowing four definitions answers most of the frequently asked questions:
- Employee: A natural person employed in a public or private workplace, regardless of their status under their own special laws (Art. 3/1-b). No distinction is made between workers, civil servants, contract staff, part-time or seasonal employees.
- Workplace: A structure organised to produce goods or services; it includes associated places and annexes such as rest, eating, washing and training areas and the yard, as well as vehicles (Art. 3/1-h). The staff shuttle, the field team's van and the site container are part of the workplace.
- Employer's representative: Persons acting on behalf of the employer and involved in managing the work are considered the employer for the purposes of the Law (Art. 3/2). The factory manager or site manager is therefore not outside the scope of responsibility.
- Apprentices and interns: They are within the scope of the Law; training, risk assessment and health surveillance also apply to them. Only in calculating the appointment hours of the specialist, physician and DSP are apprentices and interns with student status under Laws No. 3308 and No. 2547 not included in the number of employees (Art. 6/4).
Work outside OHS scope: five narrow exceptions
Work outside the scope of OHS is listed item by item in Art. 2/2. The list is narrow, and each exception has a limit:
| Exception (Art. 2/2) | What is outside the scope | Limit to watch |
|---|---|---|
| a) Turkish Armed Forces, general law enforcement and National Intelligence Organisation activities | Military, law enforcement and intelligence activities | Factories, maintenance centres, tailoring workshops and similar workplaces are not excepted; the Law applies there |
| b) Disaster and emergency units | The response activities of these units | The exception is limited to response activities |
| c) Domestic services | Domestic services performed in the home | The exception covers only domestic services |
| ç) Production on one's own account | Those producing goods and services without employing workers | You come within scope the moment you employ your first worker |
| d) Penal enforcement services | Workshop, training, security and vocational training activities within the rehabilitation of convicts and detainees | The exception is limited to these activities |
Apart from these five headings, there is no activity of which it can be said "our sector is not covered by OHS". Offices, shops, cafés, schools, hotels, municipal units; all are within the scope of the Law.
OHS for a workplace with one employee: what is mandatory?
A workplace with one employee has the same headings of obligation as one with thousands; what changes are the hours and frequencies. For OHS in a workplace with one employee, the following headings apply:
- OHS specialist and workplace physician services (Art. 6); in the very hazardous class with 10 or more employees, other health personnel as well.
- Carrying out or commissioning a risk assessment (Art. 10).
- Emergency plan, support staff appointment and drills (Art. 11). In a workplace with fewer than 10 employees, one person is sufficient for the firefighting, rescue and protection teams.
- Pre-employment and periodic medical examinations (Art. 15). In hazardous and very hazardous jobs, an employee may not start work without a fitness-for-work report.
- Induction training of at least 2 hours before starting work and basic training within 3 months of starting work at the latest (Art. 17; the 2026 training regulation).
- Notifying a work accident to the SGK within 3 working days of the accident (Art. 14/2).
The hours are short in a small workplace: in a less hazardous office, at least 10 minutes per employee per month for the specialist and 5 for the physician. In less hazardous workplaces with fewer than 50 employees, these hours can be combined within the same contract year by agreement between the employer and the service provider (Regulation on OHS Services, Art. 11/7). Art. 7 of the Law provides that support may be given for OHS services to hazardous and very hazardous workplaces with fewer than 10 employees, excluding the public sector; confirm the current practice separately before basing your budget on this support.
Is an OHS specialist mandatory? Who can provide the service?
The answer to the question is an OHS specialist mandatory is yes for every workplace within scope. What changes is who can provide the service and which certificate class the specialist must hold:
| Workplace | Who can provide the service? | Specialist certificate | DSP |
|---|---|---|---|
| Less hazardous, fewer than 50 employees | OSGB or ÇASMER; certified in-house staff; the employer or their representative after completing the Ministry's training (excluding examinations) | At least C | Not required |
| Less hazardous, 50 or more employees | OSGB or ÇASMER; certified in-house staff | At least C | Not required |
| Hazardous | OSGB or ÇASMER; certified in-house staff | At least B | Not required |
| Very hazardous, fewer than 10 employees | OSGB or ÇASMER; certified in-house staff | A | Not required |
| Very hazardous, 10 or more employees | OSGB or ÇASMER; certified in-house staff | A | Required; not required if there is a full-time physician |
An employer with the required qualifications and certificate may also take on the service themselves, taking into account the hazard class and number of employees (Art. 6/1-a). If you do not know your hazard class, see our hazard class guide; you can calculate monthly hours by number of employees with the OHS obligation calculator. For a detailed calculation of hours, see our article on workplace physician and specialist working hours.
Commonly confused situations
- Part-time and seasonal employees: They fall within the Law's definition of employee; training, examinations and risk assessment are carried out for them as well.
- Subcontractor employees: The subcontractor is the employer of its own employees; the principal employer also has coordination and supervision obligations. For details, see our article on subcontractor OHS responsibility.
- Public institutions: The Law does not distinguish between public and private. After the Constitutional Court decision, there is no longer any postponement of specialist and physician appointments in public institutions either.
- "We have an agreement with an OSGB, the rest is their job": Outsourcing the service does not remove the employer's responsibility (Art. 4/2). To understand what an OSGB (joint health and safety unit) does, see our article on what an OSGB is.
What awaits a workplace within scope that does not obtain the service?
The 2026 base administrative fine for not appointing a specialist or physician is 111,263 TL for each person not appointed, and the same amount is applied every month the breach continues. Under Art. 26/3, this fine is increased according to the number of employees and hazard class.
Example: Suppose a workshop with 12 employees in the hazardous class has not appointed a specialist or physician. The base amount is 2 × 111,263 = 222,526 TL. As the increase is 50 per cent for a hazardous workplace with 10–49 employees, the fine becomes 333,789 TL and is repeated every month the breach continues. Gaps in health surveillance (22,194 TL per employee) and training (8,980 TL per employee) may be added to this. You can use the OHS administrative fines tool for your own situation.
We plan our OHS specialist service for workplaces in Bursa and the surrounding provinces, from a one-person office to large production plants, with hours and certificate classes appropriate to their hazard class and number of employees.
Frequently Asked Questions
Is an OHS specialist mandatory in a workplace with one employee?
Yes. The Law applies to all workplaces with at least one employee and does not make specialist and physician appointment dependent on workplace size. In less hazardous workplaces with fewer than 50 employees, the employer or their representative may provide the service themselves, excluding pre-employment and periodic examinations, after completing the Ministry's training.
If I have no employees, am I within scope?
A person producing goods or services on their own account without employing anyone is outside the scope of the Law (Art. 2/2-ç). You come within scope the moment you employ your first worker and must complete the contract, examination and training steps before they start work.
Is OHS service also needed for interns and apprentices?
Yes. Apprentices and interns are among the employees the Law protects; training, risk assessment and health surveillance also apply to them. Only apprentices and interns with student status are not included in the number of employees when calculating specialist and physician appointment hours.
Does Law No. 6331 apply to domestic workers?
No. Domestic services are outside the scope of the Law under Art. 2/2-c. The exception is limited to domestic services only; if the same person works in a business, the Law applies to that workplace.
Are public institutions also within the scope of OHS?
Yes. The Law applies to all workplaces in the public and private sectors. The provision postponing specialist and physician appointment for public institutions was annulled by the Constitutional Court decision.
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.