In brief
Businesses involved in the carriage of dangerous goods by road first obtain a Dangerous Goods Activity Certificate (TMFB); for most activities the threshold is 20 tonnes in the last calendar year. TMFB holders must receive at least 18 hours a month of dangerous goods safety adviser services for each TMFB, except for exemptions such as businesses that are only carriers (vehicle capacity below 50 tonnes) or only consignees. The TMGD falls under Ministry of Transport and Infrastructure legislation and does not replace the OHS specialist.
Which legislation creates the TMGD requirement?
Businesses that dispatch or receive products such as paint, solvents, fuel, gas cylinders, acids or bases by road come up against a second body of legislation alongside occupational health and safety rules: ADR transport rules. The ADR agreement, to which Turkey is a party, is implemented at national level through two regulations of the Ministry of Transport and Infrastructure:
- The Regulation on the Carriage of Dangerous Goods by Road (Official Gazette 18.06.2022, No. 31870). It was most recently updated by the amendments of 06.02.2025 and 17.10.2026.
- The Regulation on Dangerous Goods Safety Adviser Services (Official Gazette 18.06.2022, No. 31870).
The requirement for a TMGD (dangerous goods safety adviser) arises from these two regulations. The subject lies outside the scope of OHS Law No. 6331 and ISG-KATİP, the Ministry of Labour's online OHS registration system; so your OSGB's OHS specialist cannot take on this role unless they also hold a TMGD certificate. Even so, the two fields are intertwined on site: at the loading dock, in the warehouse and at the tank filling point, the same risks are subject to two different bodies of legislation.
First the TMFB: who needs an activity certificate?
The TMGD obligation depends on the obligation to hold a Dangerous Goods Activity Certificate (TMFB). Under Art. 7 of the road regulation, the businesses that must obtain a TMFB are:
| Role of the business | TMFB threshold | Basis |
|---|---|---|
| Carrier, tank-container or portable tank operator | No quantity requirement | Art. 7/1-a |
| Consignee of dangerous goods | Receipt of 20 tonnes or more in the last calendar year | Art. 7/1-b |
| Consignor of dangerous goods | Dispatch of 20 tonnes or more in the last calendar year | Art. 7/1-c |
| Packer, loader, filler or unloader without receiving or dispatching | Handling of 20 tonnes or more in the relevant activity in the last calendar year | Art. 7/1-ç |
| Businesses dealing in Class 1 (except 1.4S) and certain Class 7 goods | No quantity requirement | Art. 7/1-d |
| Businesses dealing in Class 6.2 and listed in Annex 4 of the regulation | Depending on the field of activity | Art. 7/1-e |
When reading this table, note three details:
- Exempted carriage does not count: For consignees and unloaders, activities covered by the exemptions in ADR Chapters 3.3, 3.4 and 3.5 are not taken into account when calculating quantities (Art. 7/2).
- A separate certificate for each address: A separate TMFB is obtained for each branch, factory, warehouse, construction site and workshop under the same trade name (Art. 7/4).
- Exceeding the threshold during the year: A business that exceeds 20 tonnes before the end of the year in which it started operating must also obtain a TMFB appropriate to its activity (Art. 7/5).
Does everyone with a TMFB need a TMGD?
No. Art. 8 of the road regulation excludes three groups of TMFB holders from the obligation to receive dangerous goods safety adviser services:
- Businesses whose TMFB covers only "Carrier" as a field of activity and whose vehicles registered on the transport authorisation certificate have a total minimum capacity of less than 50 tonnes,
- Businesses whose TMFB covers only "Consignee" and/or "Tank-container/portable tank operator" as fields of activity,
- Businesses holding a combination of the fields of activity of these two groups.
Other TMFB holders must receive TMGD services and comply with the following time rules:
- A business obtaining a TMFB for the first time starts receiving TMGD services within 30 days of the date it obtained the certificate (Art. 8/4).
- The service is received for at least 18 hours a month for each TMFB (Art. 8/7).
- If the TMGD appointment is terminated by the business, the TMGD or the consultancy firm, a new appointment is made within 15 days; if it is terminated by the Ministry, within 30 days (Art. 8/6).
- The service is obtained by employing a TMGD full-time or part-time at the business or from an authorised consultancy firm (TMGDK); the appointment is made via e-Devlet (the government's online services portal), and the service is not deemed to have been received unless it is approved by the business's authorised representative (TMGD Services Regulation Arts. 5, 7).
TMFB holders without a TMGD obligation still have duties: they ensure that personnel assigned to the carriage of dangerous goods receive training under ADR Chapter 1.3 before starting their duties and every two years, and they keep training records (Art. 7/9, 2025 amendment).
TMGD duties: what does the adviser do at the business?
The TMGD carries out the duties listed in ADR 1.8.3 and in national legislation and is independent in these duties; they may not be placed under influence by the business (TMGD Services Regulation Art. 8). Art. 27 of the road regulation lists the main TMGD duties that the business receiving TMGD services carries out together with the adviser:
- Notifying the Ministry via e-Devlet of accident reports prepared in accordance with ADR within 30 days of the accident
- Providing ADR Chapter 1.3 training to personnel to be assigned to transport processes before they start and every two years, and keeping records
- Preparing a security plan in accordance with ADR 1.10.3.2
- Preparing an annual activity report on dangerous goods activities and notifying it via e-Devlet within the first four months of the following year
- Drawing up instructions for the documents and safety equipment that must be carried in the vehicle
- Preparing and keeping up to date written procedures, plans, instructions and checklists relating to the fields of activity
The TMGD visits the business at least once a month; the visit is approved via e-Devlet and notified to the Ministry by the fifteenth of the following month (Art. 27/3). Findings and recommendations reported by the TMGD via e-Devlet are deemed to have been notified to the business (TMGD Services Regulation Art. 8/3); so reading and following up the reports is the business's responsibility.
The difference between the TMGD and OHS services
Although both services look like "consultancy", their basis, scope and registration system are different:
| Topic | Dangerous goods safety adviser | OHS specialist |
|---|---|---|
| Responsible ministry | Ministry of Transport and Infrastructure | Ministry of Labour and Social Security |
| Basis | ADR and the road and TMGD regulations | Law No. 6331 and the OHS Specialists Regulation |
| Focus | Packing, loading, carriage and unloading of dangerous goods | Employee health and safety; all risks at the workplace |
| Certificate | TMGD certificate issued by the Ministry | Class A, B or C OHS specialist certificate |
| Service time | At least 18 hours a month for each TMFB | Minutes calculated according to number of employees and hazard class |
| Registration system | Ministry system via e-Devlet | ISG-KATİP |
| Typical outputs | Security plan, annual activity report, accident report | Risk assessment, emergency plan, training and the approved logbook |
One person may hold both certificates; however, the time and registration obligations of the two roles are fulfilled separately. One does not count in place of the other.
How do the TMGD and OHS work together in warehousing and logistics?
In the warehouse of a dangerous goods consignor, the same pallet passes under the eye of two different bodies of legislation. The TMGD checks that the packaging, labelling and transport documents comply with ADR and that the load is correctly secured in the vehicle. The OHS specialist looks at the forklift traffic, manual handling load and chemical exposure of the employee doing the same job, and at what they will do in the event of a spill.
These two perspectives feed into each other on the following topics:
- Risk assessment: Loading and unloading areas, filling points and temporary holding areas should be separate lines in the risk assessment. The transport information section of safety data sheets is a shared source for both services; for a reading guide, see our article on the safety data sheet.
- Emergency plan: Spill and leak scenarios should be consistent between the TMGD's security plan and the workplace's emergency plan. For response steps, see our article on responding to chemical spills.
- Forklifts and docks: In areas where dangerous goods pallets are moved, separating pedestrians and forklifts becomes particularly important; forklift and pedestrian traffic plans in warehouses is a starting point for these arrangements.
- Training: ADR Chapter 1.3 training and basic OHS training are documented separately; they can be given on the same day, but one does not replace the other.
For industrial facilities and logistics warehouses in Bursa and the surrounding provinces, planning this shared area together makes it easier to give consistent answers to the questions of two different ministries during inspections. Bursa Sistemer does not provide TMGD services; as part of our OHS specialist service, we prepare the risk assessment and emergency plan in coordination with your business's TMGD. For risks specific to warehousing and logistics, see our logistics and warehousing sector page, and to calculate your OHS obligations, our OHS obligation calculator.
Frequently Asked Questions
Does a business dispatching less than 20 tonnes of dangerous goods a year need a TMGD?
The TMFB threshold for the consignor activity is 20 tonnes in the last calendar year; a business below this threshold does not obtain a TMFB, except in quantity-independent cases such as Class 1, Class 7 or Class 6.2, and therefore does not come under the TMGD obligation. Even so, as a consignor it must comply with the obligations in Part Four of the regulation (Art. 7/8). If you are close to the threshold, clarify your situation with an activity determination report.
Should a factory that only buys dangerous goods appoint a TMGD?
A business receiving 20 tonnes or more in the last calendar year obtains a TMFB. Businesses whose TMFB covers only "Consignee" as a field of activity are exempt from the obligation to receive TMGD services; however, the situation changes if they have other fields of activity such as unloading, filling or dispatching.
Can our OHS specialist also act as the TMGD?
Only if they hold a valid TMGD certificate issued by the Ministry and the employment, appointment and time requirements of TMGD legislation are also met. The two roles fall under different legislation; one does not count in place of the other.
How many hours a month does a TMGD provide?
Businesses obliged to receive the service do so for at least 18 hours a month for each TMFB, and the TMGD visits the business at least once a month.
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.