Is a workplace physician mandatory?

Question

Accepted Answer

Yes. Article 6 of Occupational Health and Safety Law No. 6331 places a duty on every employer within its scope to assign a workplace physician; hazard class and headcount change only the required time, not the duty itself. The service may be met in-house or bought from a joint health and safety unit. Where the duty comes from Article 6/1(a) of Occupational Health and Safety Law No. 6331 requires the employer to assign an occupational safety specialist, a workplace physician and, in highly hazardous workplaces with ten or more employees, other health personnel from among the employees. Where no qualified personnel is available, all or part of the service may be bought from joint health and safety units or from the training and research centres named in the law. Time follows the hazard class Hazard class Monthly time per employee Full-time threshold Low hazard 5 minutes 2,000 employees Hazardous 10 minutes 1,000 employees Highly hazardous 15 minutes 750 employees A full-time month equals 195 hours, that is 11,700 minutes. In a hazardous workplace with 200 employees, for example, the monthly physician time is 200 × 10 = 2,000 minutes, roughly 33 hours. The exception for small low hazard sites A sentence added to the same paragraph in 2014 provides that employers or employer representatives of workplaces with fewer than 50 employees in the low hazard class, who do not hold the required qualification and certificate, may carry out occupational health and safety services themselves provided they complete the training announced by the Ministry. Two items stay outside that permission: pre-employment and periodic medical examinations and tests . Health surveillance therefore remains a physician's work; failing to provide health surveillance carries a 2026 fine of TRY 22,194 per employee. As to entry into force, the wording that set the date for public institutions and for low hazard workplaces with fewer than 50 employees was annulled by the Constitutional Court decision of 22 July 2025, no. E: 2024/54, K: 2025/163. Outside that group the duty has been in force since 2013-2014. Other health personnel Other health personnel are required only in highly hazardous workplaces with ten or more employees, and are not mandatory where a full-time workplace physician is assigned. If no physician is assigned In the 2026 fine tables, failing to assign a workplace physician starts at TRY 111,263 and repeats every month while the breach continues. Failing to assign other health personnel starts at TRY 55,597, also repeating monthly. Work out your own physician time with the OHS duration calculator and read the amounts in the penalty tables .

Obligation	Legal basis	How the page covers it
The employer assigns an occupational physician from among the employees	Law no. 6331, art. 6(1)(a) — the employer shall assign, from among its employees, a safety expert, an occupational physician and, in very hazardous workplaces with ten or more employees, other health personnel; where no personnel with the required qualifications is available, all or part of the service may be obtained from joint health and safety units or from ÇASMERs.	The "Where the duty comes from" section.
The monthly working time is set by hazard class	Regulation on the Duties, Powers, Responsibilities and Training of Occupational Physicians and Other Health Personnel, art. 12(1) — occupational physicians work at least 5 minutes per employee per month in the less hazardous class, at least 10 minutes in the hazardous class and at least 15 minutes in the very hazardous class.	The first column of the "The time depends on the hazard class" table.
The full-time physician threshold is 2,000, 1,000 and 750 employees by class	Regulation on Occupational Physicians and Other Health Personnel, art. 12(2) — in the less hazardous class, at least one full-time occupational physician is assigned for every 2,000 employees in workplaces with 2,000 or more; art. 12(3) — for every 1,000 in the hazardous class; art. 12(4) — for every 750 in the very hazardous class.	The "Full-time threshold" column of the "The time depends on the hazard class" table.
There is an exception for small, less hazardous workplaces; entry and periodic examinations stay outside it	Law no. 6331, art. 6(1)(a) (added sentence) — employers or their representatives in workplaces with fewer than 50 employees in the less hazardous class who do not hold the required qualifications and certificate may carry out occupational health and safety services themselves, provided they complete the training announced by the Ministry, excluding entry and periodic examinations and tests.	The "Exception for small, less hazardous workplaces" section.
Where a full-time physician is assigned, other health personnel is not mandatory	Law no. 6331, art. 6(3) — in workplaces where a full-time occupational physician is assigned, it is not mandatory to assign other health personnel.	The "Other health personnel" section.
The cost of health surveillance cannot be passed on to the employee	Law no. 6331, art. 15(4) — the cost of health surveillance and any additional cost arising from it is borne by the employer and cannot be passed on to the employee; art. 15(3) — health reports required under this Act are obtained from the occupational physician.	The closing sentence of the "Exception for small, less hazardous workplaces" section: health surveillance is the physician's job in every case.

Obligation	Legal basis	How the page covers it
The employer designates a competent person for protective and preventive activities	Directive 89/391/EEC, art. 7(1) — the employer shall designate one or more workers to carry out activities related to the protection and prevention of occupational risks; art. 7(3) — if such measures cannot be organised for lack of competent personnel, the employer shall enlist competent external services or persons; art. 7(5) — the designated workers and external services must be sufficient in number, taking account of the size of the undertaking and the hazards involved.	The EU counterpart of the "Where the duty comes from" section.
National measures are introduced for health surveillance	Directive 89/391/EEC, art. 14(1) — measures shall be introduced in accordance with national law and/or practice to ensure workers receive health surveillance appropriate to the risks they incur at work; art. 14(3) — health surveillance may be provided as part of a national health system.	The EU counterpart of the "The time depends on the hazard class" section: the test is appropriateness to the risk, not a fixed time.
In a small undertaking a competent employer may take on the task himself	Directive 89/391/EEC, art. 7(7) — Member States may define, in the light of the nature of the activities and size of the undertakings, the categories of undertakings in which the employer, provided he is competent, may himself take responsibility for the measures referred to in paragraph 1.	The EU counterpart of the "Exception for small, less hazardous workplaces" section.

Obligation	Legal basis	How the page covers it
The employer appoints one or more competent persons to assist	Management of Health and Safety at Work Regulations 1999, reg. 7(1) — every employer shall appoint one or more competent persons to assist him in undertaking the measures he needs to take to comply with the requirements and prohibitions imposed on him by or under the relevant statutory provisions; reg. 7(3) — the number of persons appointed, the time available to them and the means at their disposal shall be adequate having regard to the size of the undertaking and the risks to which employees are exposed.	Matches the "Where the duty comes from" section.
Health surveillance appropriate to the risk is provided	Management of Health and Safety at Work Regulations 1999, reg. 6 — every employer shall ensure that his employees are provided with such health surveillance as is appropriate having regard to the risks identified by the assessment.	Matches the "The time depends on the hazard class" section: the test is the risk.

Is a workplace physician mandatory?

Where the duty comes from

Time follows the hazard class

The exception for small low hazard sites

Other health personnel

If no physician is assigned

Legal basis

Legal basis — Türkiye

Legal basis — European Union

Legal basis — United Kingdom

Manage this in Optifora

Hazard class	Monthly time per employee	Full-time threshold
Low hazard	5 minutes	2,000 employees
Hazardous	10 minutes	1,000 employees
Highly hazardous	15 minutes	750 employees

Is a workplace physician mandatory?

Where the duty comes from

Time follows the hazard class

The exception for small low hazard sites

Other health personnel

If no physician is assigned

Related answers

Legal basis

Legal basis — Türkiye

Legal basis — European Union

Legal basis — United Kingdom

Manage this in Optifora