Health services
Health Surveillance and Periodic Examinations in Bursa
From the pre-employment health report to annual tests, we plan health surveillance around your employees’ actual exposures and feed the results back into the risk assessment.
- Legal basis
- Law No. 6331, Art. 15
- Periodic examination
- At least every 5 / 3 / 1 years (less hazardous / hazardous / very hazardous)
- Hearing test
- Mandatory for noise above 85 dB(A)
- Confidentiality
- Health data is special-category data (KVKK, Art. 6)
What is health surveillance and which examinations does it cover?
Health surveillance means regularly monitoring how employees’ work affects their health. Under Article 15 of Law No. 6331, the employer must ensure that employees are placed under health surveillance with regard to the risks they are exposed to, and must have examinations carried out in four situations: on hiring, on a change of job, on return to work at the employee’s request after repeated absences due to a work accident, occupational disease or ill health, and at regular intervals while the work continues.
The question we hear most often about periodic examinations and pre-employment health reports in Bursa is “which tests?”. The legislation does not prescribe the same test package for everyone. The maximum examination intervals are fixed: at least every 5 years in less hazardous work, at least every 3 years in hazardous work and every year in very hazardous work; at least every 6 months for children, young workers and pregnant employees. The workplace physician shortens these intervals where necessary.
The choice of tests depends on exposure: hearing tests for noise, chest X-rays for dust, blood tests or biological monitoring for chemical exposure, and so on. Tests such as pulmonary function testing (PFT) and complete blood counts have no fixed frequency in the legislation; the physician decides based on the risk assessment and workplace measurement results. A good plan therefore starts with an up-to-date risk assessment and measurements carried out by an authorised laboratory.
The cost of health surveillance and any additional costs arising from it are borne by the employer and cannot be passed on to employees. Examination results are confidential. Under the Personal Data Protection Law No. 6698 (KVKK), health data is a special category of personal data; processing it is prohibited as a rule and permitted only in cases listed in the law, such as legal obligations in the field of occupational health and safety, with the necessary safeguards in place.
Bursa Sistemer OSGB runs health surveillance as part of its workplace physician service. We schedule tests with authorised laboratories and healthcare providers and, with our physician’s evaluation, record the results in each employee’s file. We also feed aggregated, anonymised results back into the risk assessment: rising hearing loss in one department shows that its noise controls are not enough.
What we do as part of health surveillance
The outcome depends less on examination day than on the planning beforehand and the evaluation afterwards.
Exposure map
Using the risk assessment, workplace measurements and safety data sheets, we match each employee to an exposure group.
Test matrix
Our physician determines which tests each group needs and how often; the plan prevents both unnecessary tests and overlooked risks.
Pre-employment examination
We assess new employees together with the exposures of the job they will do and record the result on the EK-2 form and in the fitness-for-work report.
Per-person examination schedule
We track each employee’s last and next examination dates individually and group upcoming examinations around your shift plan.
Hearing conservation programme
In areas above 85 dB(A) we schedule hearing tests and compare the results with noise measurements and the use of hearing protection.
Return to work and change of job
After long sick leave or a move to a new job we reassess fitness and, where necessary, submit a suitable job recommendation for the employer’s approval.
Confidentiality and archiving
We keep personal health files separate from personnel files, accessible only to health personnel, and ensure they are retained for at least 15 years.
Types and timing of examinations
A summary of which examination takes place when. Periodic intervals are maximum intervals; the workplace physician may shorten them according to risk.
| Examination | When? | Legal basis and note |
|---|---|---|
| Pre-employment | Before starting work | In hazardous and very hazardous work, no one may start without the report (Law No. 6331, Art. 15/2) |
| Change of job | When the employee’s job changes | Fitness is reassessed for the risks of the new job |
| Return to work | After repeated absences due to an accident, occupational disease or ill health, at the employee’s request | If returning to the previous job is inadvisable, the physician recommends a suitable role |
| Periodic: less hazardous | At least every 5 years | The physician may shorten the interval |
| Periodic: hazardous | At least every 3 years | The physician may shorten the interval |
| Periodic: very hazardous | Every year | The physician may shorten the interval |
| Children, young workers and pregnant employees | At least every 6 months | Group requiring special policies |
| After a diagnosis or suspected diagnosis of occupational disease | When the diagnosis is made | Examinations of employees working in the same environment are repeated |
| Noise above 85 dB(A) | At regular intervals set by the physician | Hearing test mandatory (Regulation on Noise, Art. 13) |
You can see your own examination, training and renewal dates in one calendar with the OHS calendar.
How we plan health surveillance
Employee and job list
We obtain the employee list with job descriptions, shift details, hiring dates and last examination dates.
Defining exposure groups
Using the risk assessment, workplace measurement reports and safety data sheets, we group employees with similar exposures: welders, paint shop, shipping, administrative office and so on.
Test matrix and approval
Our physician sets the examination content and test frequency for each group. The plan is submitted for the employer’s approval, and tests are scheduled with authorised laboratories and healthcare providers.
Information and examination
We explain the purpose of examinations and tests to employees and obtain their consent. We group examinations by shift so that production is not disrupted.
Evaluation and report
Results are recorded on the EK-2 form; the physician states the fitness-for-work opinion and any restrictions. Each employee is informed about their own results.
Feedback and schedule
Aggregated results are transferred anonymously to the risk assessment and the annual evaluation report; each employee’s next examination date is entered in the schedule.
Documents and records we deliver to you
- Examination and test matrix by exposure group
- EK-2 Pre-employment/Periodic Examination Forms
- Fitness-for-work reports and restriction notes
- Physician’s evaluation of test results
- Personal health files kept under the confidentiality principle
- Periodic examination schedule per employee
- Evaluation of hearing tests compared with noise measurements
- Anonymised summary of aggregated results for the annual evaluation report
Expert notes: choosing tests, managing results and confidentiality
From exposure to test: the selection logic
A good health surveillance plan does not start with “which package?” but with “what is this employee exposed to?”. The table below separates exposures with explicit provisions in the legislation from those left to the physician’s judgement.
| Exposure | Test | Position in the legislation |
|---|---|---|
| Noise above the 85 dB(A) upper action value | Hearing test (audiometry) | Mandatory; interval set by the physician |
| Noise between 80 and 85 dB(A) | Hearing test | May be carried out if the risk assessment and measurements indicate a health risk |
| Dust (including dust that may contain quartz or asbestos) | Chest X-ray in line with the ILO classification | Frequency set by the physician |
| Dusts, fumes and vapours affecting the respiratory tract | Pulmonary function test (PFT) | No fixed frequency; physician’s decision |
| Solvents, paints and metals | Blood tests, biological monitoring | No fixed frequency; physician’s decision |
| Work at height, forklift and vehicle operation | Vision, hearing and balance assessment | No fixed frequency; physician’s decision |
What happens when a result comes back?
The Regulation on Noise sets out the steps to take when work-related hearing loss is detected. This sequence is a good model for other exposures too:
- The workplace physician informs the employee about the results concerning them.
- The employer reviews the risk assessment and the measures taken.
- Where necessary, the employee is assigned to other work without exposure.
- The health of other employees with similar exposure is reviewed and they are placed under regular surveillance.
There is a similar power for dust exposure: the physician may recommend any protective and preventive measure, including not assigning the employee to work involving dust exposure, and may decide how long surveillance continues after exposure ends. The employee or the employer may request that examinations and tests be repeated.
Confidentiality, KVKK and the personal health file
In practice this means:
- The personal health file is kept separate from the personnel file and accessible only to health personnel.
- Only the fitness-for-work opinion and any work restrictions are passed on to human resources.
- Files are kept for at least 15 years after the employee leaves.
- If the employee moves to another workplace, the new employer requests the file in writing; the previous employer sends a certified copy within one month.
The most common gaps found during inspections
The same test package for everyone
Periodic examinations are carried out in line with the results of the risk assessment. A bulk package chosen without regard to exposure both creates unnecessary cost and misses the real risk.
Noise measurements and hearing tests never meet
The measurement report sits in one folder and the hearing tests in another. If areas above 85 dB(A) are not matched against the employee list, mandatory hearing tests are skipped.
Scheduling by a single bulk examination day
Each employee’s periodic examination runs from their own date. The 2026 base fine for failing to provide health surveillance is TRY 22,194 per employee and is calculated separately for each employee affected.
Passing test costs on to employees
The cost of health surveillance and any resulting additional costs are borne by the employer. Deducting the fee from payroll or having employees pay out of pocket is unlawful.
Filing health forms in the personnel file
The EK-2 form and test results are confidential. Health data kept in personnel files, shared folders or circulated by email creates risk under both Law No. 6331 and KVKK.
What determines the service fee?
- Examination frequency based on headcount and hazard class
- Number of exposure groups and variety of tests
- Missing examinations to be completed in the first year
- Shift pattern and splitting of examination days
- Transport plan to the healthcare provider where tests are carried out
- Tracking employees at more than one location
Legal basis
- Law No. 6331 on Occupational Health and Safety, Art. 15 Situations requiring examination, the fitness-for-work report, costs borne by the employer and confidentiality of health information.
- Regulation on Workplace Physicians and Other Health Personnel, Art. 9 Periodic examination intervals, the EK-2 form, groups requiring special policies and repeat examinations after an occupational disease.
- Regulation on Noise, Art. 13 (Official Gazette 28.07.2013) Mandatory hearing tests where noise exceeds the upper action value and the steps to take when hearing loss is detected.
- Regulation on Dust Control, Art. 10 and 11 (Official Gazette 05.11.2013) Health surveillance in dusty work and chest X-rays in line with the ILO classification.
- Personal Data Protection Law No. 6698 (KVKK), Art. 6 Health data as a special category of personal data and the conditions for processing it.
- Regulation on Occupational Health and Safety Services, Art. 7 and 9 Retention of personal health files for at least 15 years, sending them to a new employer, and services imposing no financial burden on employees.
Legislative information is provided for general guidance only; consult our specialists for an assessment specific to your business.
Health Surveillance for your industry
Metalworking and Machinery Manufacturing
Hazardous; laser cutting and plating very hazardous Limb injuries, lifting operations and equipment inspections on CNC, machining, welding, laser cutting and plating lines.Textiles and Apparel
Apparel less hazardous; weaving and dyeing hazardous Managing noise, cotton dust, dyestuffs, steam boilers and sewing-line ergonomics in weaving, dyehouses and apparel production.Furniture and Wood Products
Furniture manufacturing (31.00.01) is hazardous An OHS plan for wood dust, cutting machinery, paints and varnishes and a high fire load at furniture makers in İnegöl and Bursa.Chemicals, Plastics and Rubber
Class is determined by the NACE code Compliance management for chemical exposure, explosive atmospheres, injection and extrusion machines, mold changes and storage.Construction and Building Sites
Site preparation (43.12.00) is very hazardous A site-focused OHS and health plan for construction sites with work at height, scaffolding, excavation, tower cranes and earthmoving machinery.Health Surveillance: frequently asked questions
How often are periodic examinations carried out?
At least every 5 years in less hazardous work, at least every 3 years in hazardous work and every year in very hazardous work. For children, young workers and pregnant employees the interval is at least every 6 months. These are maximum intervals; the workplace physician shortens them if the employee’s condition or exposure requires it. For example, even if you are in the hazardous class, we may schedule hearing tests more often for someone working in a noisy area.
Who decides which tests are carried out?
The workplace physician. The legislation sets explicit rules only for some exposures: hearing tests are mandatory for noise above 85 dB(A), and chest X-rays in dusty work are taken in line with the ILO classification. Tests such as PFT, complete blood count or biochemistry have no fixed frequency; the physician decides based on the risk assessment and workplace measurement results. Sharing your up-to-date measurement reports is important for a sound plan.
Is a hearing test (audiometry) mandatory for every employee?
No. A hearing test is mandatory for employees whose noise exposure exceeds the upper exposure action value of 85 dB(A). For employees exceeding the lower action value of 80 dB(A), it may be carried out if the risk assessment and measurements indicate a health risk. Someone working in an office does not need routine hearing tests. Personal exposure measurements by an authorised laboratory show who belongs in which group.
How often should chest X-rays be taken?
The legislation sets no fixed number of years. The Regulation on Dust Control requires X-rays to be taken in line with the ILO International Classification of Radiographs of Pneumoconioses and the frequency to be set by the workplace physician. The physician considers the type of dust, measurement results, length of exposure and the employee’s health. This assessment is particularly important for dust that may contain quartz or asbestos. The physician may also decide how long surveillance continues after exposure ends.
Can we deduct examination and test fees from employees?
No. Under Article 15 of Law No. 6331, the cost of health surveillance and any related additional costs are borne by the employer and cannot be passed on to employees. The Regulation on Occupational Health and Safety Services also requires services to be provided without imposing a financial burden on employees. If employees need to leave the workplace for examinations, we recommend including transport in this planning. The rule applies to all pre-employment, periodic and return-to-work examinations.
What should we do if an employee refuses to attend an examination?
Employees are obliged to attend health examinations (Regulation on Occupational Health and Safety Services, Art. 8). The physician obtains the employee’s consent by explaining the purpose of the examinations and tests, and explains that the results will be used only to assess health and fitness for work and will be kept confidential. Most objections stem from a lack of information. If the refusal continues, we recommend recording it in a signed report. Remember that in hazardous and very hazardous work an employee cannot start without a fitness-for-work report.
Can we request the health file from a previous workplace?
Yes. When an employee leaves a previous workplace and starts with you, you request the file from the previous employer in writing; the previous employer sends a certified copy within one month. This file does not replace the new pre-employment examination, but it lets the physician see past exposures and earlier findings. The file received is kept under the same confidentiality rules. Waiting for the file to arrive is not a reason to postpone the pre-employment examination.
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