Medical checks when staff join or change jobs: a hotel employer’s checklist under the safety law
Article 15 of the safety law requires hotel employers to pay for medical checks when staff join or change jobs. Learn how to run this process for seasonal intake.
Contents
Key takeaways
- Article 15 of Law 6331 requires the employer to have workers examined on joining and on a change of job, among other cases.
- The same article puts the cost of health surveillance, and any additional cost arising from it, on the employer and forbids passing it to the worker.
- A change of job is a fresh trigger: the report written for the old post does not cover the new one.
- Keep the examination record in the occupational health and safety file, apart from the general personnel file, and limit access to the people whose job needs it.
- Article 15 does not say which examinations a hotel job requires; that comes from the regulation beneath the law and from the workplace physician.
Under Article 15 of the Occupational Health and Safety Law (Law 6331), the employer must have workers examined when they join and when they change jobs, among other cases, and the cost of this health surveillance stays with the employer: it cannot be passed on to the worker (Presidency Legislation Information System, Law 6331, Article 15 (opens in a new tab)).
The season starts on Monday, forty people arrive for induction, and someone asks whether the health reports can wait until after the first shifts. Under the safety law that question already has an answer, and it is written in one article. After reading this, you will know when the pre-employment medical check for hotel staff in Türkiye must happen, who pays for it, where the record lives and how to run it on a seasonal intake day without slowing the roster down.
What does Article 15 of the safety law require of a hotel employer?
It requires the employer to have workers examined at defined moments, joining and change of job among them, and to carry the cost. Health surveillance is the employer's ongoing duty to watch whether work is harming a person's health, not a single form collected at hiring.
Key pointThe two sentences this article rests on
Article 15 requires the employer to have workers examined on joining and on a change of job, among other cases. The cost of health surveillance, and any additional cost arising from it, is borne by the employer and cannot be passed on to the worker. Source: Presidency Legislation Information System, Occupational Health and Safety Law No. 6331, Article 15 (14 November 2026).
The duty sits on the employer, meaning the hotel's legal entity, not on the department head who fills the roster and not on the worker. The article names joining and change of job, then adds "among other cases", so the full list is longer than the two moments this article covers. Read the article itself rather than relying on any summary, including this one.
Health surveillance is wider than the joining examination. The examination is one moment inside a duty that continues for as long as the person works there. The hotel does not decide the medical content; the workplace physician does. The hotel owns the trigger, the appointment, the record and the access rule.
In standard compliance practice, each legal employer keeps its own file, so a group with three companies keeps three sets of records even when one HR team runs them all. If you are unsure how the safety expert and workplace doctor for hotels fit into your structure, that is the piece to settle first.
When does the examination duty apply?
The two moments this article can state from the text are joining and a change of job. The same article lists further cases that this article does not cover, so treat these two as the floor, not the ceiling.
| Moment | What Article 15 says | What the hotel does |
|---|---|---|
| Joining | named in the article | book the examination before the first shift, open the file |
| Change of job | named in the article | treat as a new trigger, do not reuse the old report |
| Return after an accident or illness | check the article text | read Article 15 in full and ask the workplace physician |
| Seasonal re-hire | apply your written rule | treat as joining again unless the physician advises otherwise |
For joining, the person is about to become a worker of the hotel, so the practical rule is that the examination happens before the first shift is worked, not after it. For a change of job, a move to a different post inside the hotel is a fresh trigger, even when the person has worked there for years and the old report is on file. If the question concerns a return after a work accident, read the article text and ask your workplace physician rather than assuming.
Write the trigger into the form that already exists. A rule that lives only in an HR memory disappears in the first busy week of the season.
Who pays for the health check?
The employer. Article 15 says the cost of health surveillance, and any additional cost arising from it, is borne by the employer and cannot be passed on to the worker (Presidency Legislation Information System, Article 15, 14 November 2026 (opens in a new tab)).
The phrase covers more than the appointment itself: a repeat test, a second visit, travel to the clinic. Budget it as a recruitment cost, not a staff cost. Put the line in the season's recruitment budget in advance, so no department head is tempted to skip the step to protect a cost target.
If a candidate is examined and then not placed, the hotel has still spent its own money. Plan the intake so examinations are booked for people you intend to place.
Watch outDo not turn the examination into a payroll deduction
Article 15 puts the cost on the employer and says it cannot be passed to the worker (Presidency Legislation Information System, Article 15, 14 November 2026). A deduction line is the one mistake in this process that leaves a written trail.
How should a hotel run the examination on a seasonal intake day?
As a numbered step in the intake sequence with one named owner, so that nobody works a shift before the record exists.
Fix the order: offer accepted, appointment booked with the workplace physician, report received, file opened, first shift rostered. The first shift comes last. Batch the season by sending the workplace physician the intake list and the job definitions a week ahead, so appointments are grouped instead of arranged one at a time.
The department head writes the job definition in plain words: what the person lifts, where they work, what they handle. The physician decides what that means for the examination. Keep one tracker for the season with name, post, appointment date, report received and file number, so anyone can see who is not yet cleared. The tracker carries dates and a yes or no on the file being complete; it never carries a diagnosis.
Where staff come through an agency, the contract decides who runs which step. Read it before the season, not during it.
Checklist
- Intake list sent to the workplace physician a week before the start date
- Job definition written by the department head for each post
- Appointment booked before the first shift is rostered
- Report received and placed in the occupational health and safety file, not the personnel file
- Tracker updated with the date the file was completed
- Department head told only what the roster needs to know
The job definitions come most easily out of your hotel risk assessment, which already describes what each post involves.
What changes when an employee moves to another job?
The trigger fires again. A change of job is one of the moments Article 15 names, so the hotel arranges a new examination instead of reusing the report written for the old post.
Write your own definition of a change of job, such as a department move, a materially different task set, or a move between outlets, and apply it identically in every property. How far the legal phrase reaches is a question for the workplace physician and the regulation, not for a summary article.
For example, a commis chef moves to housekeeping mid-season. The hotel books a new examination for the housekeeping post, files the new report beside the old one, and records the transfer date. Keep the old report: it is the evidence for the years the person spent in the previous post and for the post it was written for.
Transfers are usually decided in a hurry to cover a gap. Put the examination line inside the transfer form so it cannot be skipped under pressure. Temporary cover is the grey area: a week in the laundry is not obviously a change of job, a permanent reassignment is. Decide before the move, not after it.
What goes in the file, and who may read it?
Our practice is to keep the examination record in the occupational health and safety file, apart from the general personnel file, with access limited to the people whose job needs it.
The occupational file holds the report, the date, the post it was written for and the physician's fitness conclusion. The personnel file holds the contract, the identity copies and the payroll documents. Health information is personal data under KVKK, the personal data protection law. Treat this file as the most sensitive the hotel holds and keep the list of people who can open it short.
| Record | Where it lives | Who may read it |
|---|---|---|
| examination report | occupational health and safety file | the named owner and the workplace physician |
| fitness conclusion for the post | summary sheet in the same file | the department head, conclusion only |
| post definition and transfer dates | occupational file | owner and department head |
| appointment and cost records | recruitment budget file | finance and the named owner |
The department head needs the fitness conclusion for the roster, not the diagnosis. Say that in the procedure so nobody has to guess. No photographs of reports in messaging groups, no copies on a drive every manager can open, no reports left at the front desk. Decide now where the file lives when the person leaves and who can retrieve it later. If personnel records sit in software, the same access rule applies there.
Where the law's text stops
It stops before the medical content. Which examinations a given job needs, how often they repeat, and what applies to a kitchen, a pool or a night shift are not in Article 15.
This article lists no tests for any hotel job, deliberately. A list copied from another country or another sector is worse than no list at all. The technical detail comes from the regulation beneath the law and from the workplace physician's judgment about the post. The article's own wording matters: "among other cases" means a summary can miss a trigger that applies to your hotel.
Confirm the current text, the dates and your own case with your workplace physician, and the personnel side with your legal adviser. This is where the facts stop and advice begins. Training certificates are a separate duty with their own rules, covered in the article on hygiene training certificates for hotel staff.
What you can do without waiting: write the two triggers into your forms, name one owner, and book the physician's time for the season.
NoteScope of this article
This article states only what Article 15 says about when the employer arranges the examination and who pays for it. It does not state which examinations a hotel job requires, and it is not legal advice.
Two lines to add this week
Add two lines to your intake form and your transfer form: the date the examination was booked and the date the report reached the file. The cost rule, the access rule and the seasonal batch all hang off those two dates being visible to one named owner, and the file then answers for itself at the next inspection.
Frequently asked questions
Does a seasonal worker who comes back next year need a new examination?
Article 15 names joining and change of job. A returning worker is joining the hotel again in the ordinary sense, so the safe practice is to run the examination as a new joining. Whether a fresh examination is required every season is not settled by the text this article read, so decide with your workplace physician and record the decision in writing so every property applies it the same way.
Can the hotel ask the worker to pay for the examination and reimburse it later?
No. Article 15 puts the cost of health surveillance and any additional cost arising from it on the employer and says it cannot be passed on to the worker (Presidency Legislation Information System, Article 15, 14 November 2026). A payroll deduction, an invoice or a receipt collected for reclaim all break that rule.
What happens if the workplace physician's report says the person is not fit for the post?
The report speaks about fitness for that particular post, not about the person in general. The hotel's next step is to look at whether another post exists that the physician considers suitable. What happens to the employment if none does is a personnel question to take with advice, and the report itself stays in the occupational file.
Does the joining examination replace the hygiene training certificate?
No, they are separate duties with separate records. The examination is health surveillance under the safety law; the hygiene training certificate comes from the food safety rules and covers knowledge, not health. A hotel kitchen usually needs both, kept in different files.
Who inside the hotel should own this process?
One named person, usually in HR or the occupational safety role, with three inputs from others: the department head supplies the job definition, the workplace physician sets the medical content, and finance carries the cost line. The owner keeps the tracker, opens the file and is the only person who can say a new starter is cleared to work.
Sources
- 6331 sayılı İş Sağlığı ve Güvenliği Kanunu, madde 15 (opens in a new tab)Cumhurbaşkanlığı Mevzuat Bilgi Sistemimevzuat.gov.tr
- 6331 sayılı İş Sağlığı ve Güvenliği Kanunu, madde 15 (opens in a new tab)Cumhurbaşkanlığı Mevzuat Bilgi Sistemimevzuat.gov.tr