How to run a risk assessment in a hotel: team, method and renewal
A hotel risk assessment is a dated, signed document that lists hazards and sets control measures. This guide explains the legal requirements, team composition, scoring methods and renewal triggers for hotels in Türkiye.
Contents
Key takeaways
- The employer must have a risk assessment and cannot hand the duty away: outside help is allowed, but the employer still answers for health and safety (OHS Risk Assessment Regulation, Resmî Gazete 29 December 2012, No. 28512).
- Hotel-type accommodation sits in the less hazardous class, az tehlikeli, in the hazard class list replaced on 13 March 2025 (Resmî Gazete No. 32840); the risk assessment regulation sets renewal at least every six years for that class.
- The document must name who did it, the safety expert's and workplace doctor's Ministry certificate details, the method, the ranked risks and the measures with their dates; every page is initialled and the last page is signed.
- The calendar is not the only trigger: a new kitchen, a new pool, a reopened wing, a work accident or a near miss each require a full or partial renewal.
- A risk score is a sorting device, not a measurement; the useful output is a control measure with one owner and one date.
A hotel risk assessment is a dated, signed document: a team the employer forms lists the hazards of the building and the work, ranks the risks with a chosen method, and sets control measures with dates. Turkish rules require it, and hotel-type accommodation is classed less hazardous, so renewal is required at intervals of no more than six years.
The file sits in the general manager's cupboard: a hundred pages, a cover page carrying the logo of a firm nobody at the hotel can name, and a date from four seasons ago. Since then the hotel has rebuilt its kitchen and added a pool. This article is about how to do the work properly: what the regulation requires, who must sit on the team, how to walk the building, how to score risks without false precision, and when the document has to be renewed.
What does the regulation actually require a hotel to produce?
A signed, dated, page-numbered document that names the workplace and the people who made it, states the method, lists the hazards and ranked risks, and sets out the measures with their dates, kept at the workplace.
Under the OHS Risk Assessment Regulation (Resmî Gazete 29 December 2012, No. 28512) (opens in a new tab), the employer carries out the assessment or has it carried out, and doing so does not remove the employer's duty to ensure health and safety. Outside help is allowed; the responsibility stays where it was.
The stages start from the design or set-up stage of the workplace: identifying hazards, identifying and analysing risks, deciding control measures, documentation, updating and, where needed, renewal. A hotel that only documents is doing the fourth step and skipping three. Article 8 sets the minimum information to gather, including work accident and occupational disease records, near-miss records and emergency plans. Those records are the ones a hotel usually has and usually forgets to feed in.
Article 9 leaves the method open: one or more methods chosen for the business, or based on national or international standards, then the risks are ranked and written down. The document records the workplace's title and address and the employer's name; the names and titles of those who did the work, with the Ministry certificate details of the safety expert and workplace doctor; the date and the validity date; the hazards and risks; the method; the ranked results; and the corrective and preventive measures with their dates and the risk level after them.
Its pages are numbered, each page is initialled and the last page is signed, and it is kept at the workplace. It may be prepared and archived electronically, which is a filing choice, not a shortcut on signatures. Employees are consulted at every stage. A file presented for signature at the end has skipped the consultation the regulation describes.
ChecklistCheck your current file against these eight points
- Workplace title, address and employer named
- Everyone who took part named with title
- Ministry certificate details of the safety expert and workplace doctor written in
- Assessment date and validity date on the cover
- Method named
- Risks ranked, not just listed
- Every measure carries a date and a residual risk level
- Pages numbered, each initialled, last page signed, original kept at the workplace
Which hazard class is a hotel, and what does it change?
Hotel-type accommodation is classed az tehlikeli, less hazardous, which sets the renewal period at six years.
The Communiqué on Workplace Hazard Classes (Resmî Gazete 26 December 2012, No. 28509) sets the classes in its Ek-1 list. That list was replaced on 13 March 2025 (Resmî Gazete No. 32840) (opens in a new tab) with NACE Rev. 2.1 codes, so a file that quotes the old code numbers is quoting a list that no longer exists. There are two hotel-type codes, 55.10.02 and 55.10.05. They differ on whether the facility serves restaurant meals to its own guests, and timeshares are excluded from both.
| NACE code | Activity as listed | Class |
|---|---|---|
| 55.10.02 | Hotel-type accommodation (one of the two codes differing on serving restaurant meals to own guests) | az tehlikeli |
| 55.10.05 | Hotel-type accommodation (the other of the two, same distinction) | az tehlikeli |
| 55.20.01 | Holiday and other short-stay accommodation | az tehlikeli |
| 55.20.04 | Holiday pensions | az tehlikeli |
| 55.30.36 | Campsites and caravan parks | az tehlikeli |
| 55.40.00 | Accommodation intermediation | az tehlikeli |
Source: Mevzuat Bilgi Sistemi, Ek-1 list as replaced on 13 March 2025 (Resmî Gazete No. 32840).
A workplace's class follows its main activity, asıl iş. Where several activities qualify as main activities, the one with the higher class applies, which is the clause to check before a hotel adds a business line. The employer must notify the Ministry of Labour and Social Security of a change of main activity within one month at the latest. Rebranding a wing as a spa or a residence is worth a conversation with the safety expert before the paperwork moves. Later amendments of 21 May 2025 and 1 April 2026 did not change the accommodation rows, so the position above is the current one.
The class is not a judgment about danger. A hotel kitchen, a pool chemical store and a laundry press are as hazardous in a less hazardous workplace; the class only changes the renewal clock, not the hazards themselves. How much expert time your class requires is covered in safety expert and workplace doctor time by hazard class.
Who has to sit on the risk assessment team?
The employer or the employer's representative, the safety experts and workplace doctors providing the OHS service, employee representatives, support staff, and employees who know the work and its hazards, chosen to represent all units.
Each seat brings something the others cannot. The expert brings the method and the legal frame, the doctor brings health surveillance and exposure, the technician knows the boiler room, and the housekeeper knows the balcony rail on the top floor and where the chemicals are actually decanted.
The phrase that most hotel files fail is "chosen to represent all units". A team of department managers with nobody from housekeeping, laundry or the kitchen is a management meeting, not an assessment team. Outside help may be used. What outside help cannot do is replace the employees who know the work, because the regulation puts them on the team.
The document records the names and titles of those who did the work, together with the Ministry certificate details of the safety expert and workplace doctor. A file that cannot show those details cannot show that the team was properly formed. Consultation runs through every stage, from hazard identification to the choice of measures. The practical test: can the housekeeping supervisor describe a measure she helped choose, and say when it was done?
When the building or the work changes, the team is re-formed rather than the old page re-signed. New equipment usually means new people in the room.
Watch outThe contractor file
A file produced entirely by an outside firm, signed by a manager who never walked the building, with no employee from an operating department named, no method stated, and measures with no dates, looks complete and answers none of the questions a labour inspector, an insurer or a court would ask.
How do you walk a hotel?
Department by department and shift by shift, because most hotel hazards live in the work rather than in the floor plan: the laundry at 07:00 and the bar at 01:00 are two different buildings.
In rooms and housekeeping, look at decanting and mixing cleaning chemicals, bathroom cleaning in a small space, balcony rails, lifting mattresses and linen, and lone working along a corridor with no colleague in sight. In the kitchen: gas, hot oil, slicers and mixers, cold rooms, wet floors, the delivery yard, and late-night deep cleaning with caustic products after the chefs have gone home. In the laundry: wet floors, presses and rollers, chemical dosing, linen trolleys, and heat that builds through the afternoon.
Plant rooms hold the boiler, electrical panels, water treatment and pool chemicals, confined spaces, and locked rooms that nobody should enter alone. The pool and spa bring chlorine storage and dosing, depth marking, suction points, wet floors, sauna and steam rooms, and the chemical delivery that arrives through a public area. Staff housing and back of house carry their own questions: service corridors, stairs, waste areas and security at night. Staff housing should not be treated as an annex to the main building; see safety and house rules in a seasonal staff lojman.
Walk at the hour the work happens, talk to the person doing it, and write down what you see rather than what the procedure says. Then walk the seasonal state too: a closed winter wing, a drained pool and an idle kitchen still hold hazards, standing water in unused pipework being the common example. For a fuller inventory of what to look for in each department, use the department-by-department hazard checklist for hotels.
ChecklistUse a walk sheet, one line per area
- Guest rooms and floors, housekeeping store, kitchen and dishwash, cold stores
- Laundry, plant and boiler room, electrical rooms
- Pool and chemical store, spa and sauna, bar and terrace
- Waste yard, service corridors, staff housing, night entrance
For each area record: time of walk, who was with you, what you saw, who is exposed, existing control, gap.
How do you score a risk without false precision?
Pick one method, keep the scale small, and use the score only to sort risks so the largest ones get measures first.
The regulation does not name a method. It asks for one or more methods chosen for the business or based on national or international standards, applied and then ranked. Choosing a method and stating it in the document is part of the duty. A five by five matrix, likelihood against severity, is enough for a hotel. A three-level scale is often better, because it forces a decision instead of a debate about whether a hazard is a 12 or a 16.
Two assessors will score the same hazard differently. That is acceptable as long as the ranking holds and the biggest risks still come out on top; precision is not the product, order is. Write each measure so it can be checked later: what will be done, by whom, by when, and how anyone will know it is done. A measure that says "train the staff" is not a measure; a measure that says "brief the night shift on gas shut-off by 15 March, delivered by the technical manager" is.
Follow the usual order of control: remove the hazard, substitute something safer, guard or ventilate it, then procedure and training, then protective equipment last. A file whose measures are all training and gloves is telling you the real controls were never considered. Record the residual risk level after the measure; without it the document cannot show that anything improved. Do not re-score downward to make the file look tidy. A risk that stays high after the available measures is a capital decision for the owner, and the document is where that decision should be visible.
The following rows are illustrative, for example only:
| Hazard | Who is exposed | Likelihood x severity | Control measure, owner and date | Residual |
|---|---|---|---|---|
| Hot oil at the fryer | Chefs, waiting staff | 4 x 4 | Splash guard plus written filter change routine; technical manager, 30 days | Medium |
| Mixing two cleaning products in a bathroom | Room attendants | 3 x 4 | Pre-dosed dispensers, locked store; executive housekeeper, 60 days | Low |
| Chlorine storage next to plant room door | Pool staff, guests | 3 x 5 | Separate ventilated locked store with inventory sheet; technical manager, 90 days | Medium |
When must the assessment be renewed?
At least every six years in a less hazardous workplace such as a hotel, and fully or partly whenever one of the listed changes occurs.
The regulation sets the maximum interval by class: two years in very hazardous workplaces, four in hazardous and six in less hazardous. For hotel-type accommodation that is six years. The trigger list is the part managers forget: a move or building changes, new technology, substances or equipment, a change of production method, a work accident, an occupational disease or a near miss, a change in exposure-limit rules, the results of workplace measurements or health surveillance, or a new hazard arriving from outside.
Renewal may be full or partial. A new pool may only rewrite the pool and plant sections, but the change still has to be dated, initialled and signed, and the version it replaces has to be traceable. Hotel examples, and these are illustrative: reopening a winter wing that stood empty, converting a store into a second kitchen, adding a rooftop pool, switching laundry chemicals, or a near miss when a gas cylinder was left unsecured.
Six years is a ceiling, not a target. A hotel that rebuilds something every winter will renew far more often than the calendar suggests, and the file should show it. Keep the renewal date and the trigger list on the same calendar as the periodic inspections of boilers, lifts, electrics and fire systems, so that two compliance clocks do not drift apart and surprise the same manager in the same month.
Key pointThe two clocks
The six-year maximum is one clock; the trigger list is the other. Write both on one page: the renewal due date, and a short list of changes that require a partial renewal before that date, each with the person who must report it.
How do you turn the document into work that actually happens?
Every measure leaves the document with one owner, one date and a place in a routine that already exists, or it does not happen.
Move the measures into the plans that already run: maintenance schedules, the capital plan, the training calendar and the pre-season preparation list. A measure that lives only inside the assessment is a wish. Give each measure one named owner, not a department. Departments do not answer questions; people do.
Feed near misses back in. The regulation already treats near-miss records as an input, and a near miss is the cheapest renewal trigger a hotel will ever get, because it costs nothing and shows exactly where the control failed. Keep the signed original at the workplace and a working copy where the departments can read it. A file that only the general manager can open is a file the night shift cannot use.
Review at season handover. Incoming managers inherit hazards they did not assess and measures they did not choose, and the handover note is the natural place to close that gap. Check the file against the building once a year even when no renewal is due. Fifteen minutes of walking tells you whether the document still describes the hotel you are standing in.
TipOne page, four columns
Take the measures out of the document and onto a single sheet: measure, owner, date, and where it is tracked (maintenance plan, capital plan, training calendar). If a row has no entry in the last column, the measure has no home yet.
What to do next
Take the file you have, check it against the eight document checks above, and if the team, the method, the dates or the signatures are missing, that is the work for this month. Then put the renewal date and the trigger list on the same calendar as your periodic inspections, and walk one department before the week ends. The document is only as good as the last time someone stood in the room it describes.
Frequently asked questions
Does a small pension or apart hotel need a risk assessment too?
The duty attaches to the employer, and the team and document requirements described above are not written by size of building; confirm your own case with your safety expert. The hazard class comes from the communiqué's list, where holiday pensions and short-stay accommodation also sit in the less hazardous class. A small facility still has a kitchen, chemicals and guests, so confirm your own code and your own case with your safety expert.
Can we just download a risk assessment template and fill it in?
A template gives you the columns, not the assessment. The content has to come from a team that includes employees who know the work, from a walk of this building at the hours the work happens, and from a stated method applied to the hazards actually found. A filled template with no named team, no method and no dates on the measures fails the document requirements even if every box is ticked.
Is the risk assessment the same as our fire report or our periodic inspections?
No. Periodic inspections of boilers, lifts, electrics and fire systems are separate duties with their own documents and their own intervals, and a fire report covers one set of hazards. The risk assessment is broader and should take the inspection results as an input. Run them on one calendar so the dates support each other instead of colliding.
Does the risk assessment have to be on paper?
No. The regulation allows the document to be prepared and archived electronically. The formal requirements do not change: pages numbered, each page initialled, the last page signed, and the document kept at the workplace. Whatever the medium, the version in force must be identifiable and the superseded versions traceable.
Our safety expert changed firms. Do we need a new assessment?
The regulation's renewal triggers are about the workplace and the work, not about a change of service provider, so a change of expert is not itself listed. The document does record the Ministry certificate details of the expert and doctor who took part, so a new expert has to be able to work from the existing file and be recorded when the next update is made. Confirm how to handle the transition with your safety expert and your own adviser.
Sources
- İş Sağlığı ve Güvenliğine İlişkin İşyeri Tehlike Sınıfları Tebliği, Ek-1 İşyeri Tehlike Sınıfları Listesi (Değişik: RG-13/3/2025-32840) (opens in a new tab)T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi (mevzuat.gov.tr)mevzuat.gov.tr
- İş Sağlığı ve Güvenliği Risk Değerlendirmesi Yönetmeliği (consolidated text), Articles 5 to 12 and 18 (opens in a new tab)T.C. Cumhurbaşkanlığı Mevzuat Bilgi Sistemi (mevzuat.gov.tr)mevzuat.gov.tr