Safety expert and workplace doctor for hotels: hazard class, required time and training hours

Hotel-type accommodation is classed "az tehlikeli" (less hazardous) in Türkiye's hazard class communiqué, so a hotel needs at least 10 minutes of safety expert and 5 minutes of workplace doctor time per employee per month, 8 lesson hours of basic occupational health and safety training repeated every three years, and 2 hours of practical onboarding before work starts.

An inspector asks for the safety expert's contract. The general manager finds a number that was right in February and is half of what July needed, because nobody recalculated the minutes when the season hired far more people than the winter contract assumed. This is the most common way hotels fall short on occupational safety requirements for hotels in Türkiye: not by ignoring the rules, but by calculating them once. After reading this article you will be able to work out your hotel's hazard class, its minimum expert and doctor minutes, its training hours, and the records that connect them all.

What hazard class is a hotel in Türkiye?#

Hotel-type accommodation sits in "az tehlikeli", the less hazardous class, and the class follows the workplace's main activity rather than its size, star rating or guest profile. The Communiqué on Workplace Hazard Classes (Resmî Gazete 26 December 2012, No. 28509) sets the classes in its Ek-1 list, which was replaced on 13 March 2025 (Resmî Gazete No. 32840) with NACE Rev. 2.1 codes. Later amendments of 21 May 2025 and 1 April 2026 did not change the accommodation rows.

Two codes cover hotel-type accommodation, 55.10.02 and 55.10.05, and they differ on whether the facility serves restaurant meals to its own guests; timeshares are excluded from both. The same list puts most other lodging activities in the same less hazardous class.

Source: the communiqué's Ek-1 list as replaced on 13 March 2025, per the hazard class communiqué on mevzuat.gov.tr (opens in a new tab).

The governing rule is "asıl iş", the main activity. If several activities qualify as main activities, the one with the higher class applies, so a hotel that also runs a genuinely separate higher-class operation does not get the hotel class for that part. A change of main activity must be notified to the Ministry of Labour and Social Security within one month at the latest.

One practical point: read the NACE code on your own Ministry registration rather than inferring it from the sign outside. That code is what the class and the inspector's file follow.

How much safety expert and workplace doctor time does a hotel need?#

In a less hazardous workplace the minimum is 10 minutes of safety expert and 5 minutes of workplace doctor per employee per month, set by Article 12 of each regulation. The safety expert regulation (Resmî Gazete 29 December 2012, No. 28512, Article 12 as amended 30 April 2015) sets 10, 20 and 40 minutes for the three classes; the workplace doctor regulation (Resmî Gazete 20 July 2013, No. 28713, Article 12, with the current times in force from 1 January 2016) sets 5, 10 and 15.

Source: Article 12 of both regulations, per the regulations on mevzuat.gov.tr (opens in a new tab).

A C-class safety expert certificate is enough for a less hazardous workplace (Article 7 of the expert regulation), which is the class a hotel needs. Very large workplaces change shape: at 1,000 or more employees a less hazardous workplace assigns at least one full-time safety expert per 1,000 employees, plus extra time for the remainder, and at 2,000 or more at least one full-time workplace doctor per 2,000.

The expert or doctor serves the time written in the contract. Part-time contracts across several workplaces are allowed, but travel time between them does not count toward weekly statutory working time. For example, a hypothetical hotel with 80 employees on the payroll in a month owes 800 minutes of expert time, about 13 hours 20 minutes, and 400 minutes of doctor time, about 6 hours 40 minutes, for that month.

The contract is the evidence, and the employer stays responsible. Buying the service does not transfer the duty.

How does seasonal headcount change the calculation?#

The minimum is per employee per month, so the peak month sets the contract, not the annual average. A hotel running 30 people in February and 120 in July owes four times the monthly minutes in July. Size the contract for the peak and keep the monthly headcount record that shows why the number moves.

The training clock runs from each person's start date: basic training must be completed as soon as possible and in any case within three months, so hiring week is the deadline, not the end of the season. The two hours of practical face-to-face onboarding must happen before the person actually starts work, which puts it inside the recruitment week, not the first quiet Monday afterwards.

Anyone away for more than six months gets refresher training before returning, which is exactly the seasonal gap for staff who work one summer and come back the next. Sharing an expert or doctor across several workplaces is allowed and common in a seasonal destination, but the minutes still have to add up per workplace, and travel between sites is not counted as their working time.

Keep the payroll count for each month next to the contract. It is the cheapest way to show an inspector that the February number was correct in February and the July number was raised in July. If you are building the recruitment week itself, see our seasonal staff onboarding checklist and our guide to hotel shift planning across the desk, floors and nights.

How many hours of OHS training do hotel staff need, and how often is it repeated?#

At least 8 lesson hours of basic training in a less hazardous workplace, repeated at least every three years, plus 2 hours of practical face-to-face onboarding before the first shift. The current regulation was published on 2 April 2026 (Resmî Gazete No. 33212) and repealed the 2013 text. A lesson hour means at least 45 minutes of teaching plus a 15-minute break, so 8 lesson hours is about a full working day, of which six hours are teaching and the rest breaks.

Every repeat is at least 8 lesson hours, and the 2-hour practical onboarding sits outside these hours. Source: the training regulation in the Resmî Gazete of 2 April 2026 (opens in a new tab).

Within those hours, topic 4 of Annex 1 gets at least 2 lesson hours in a less hazardous workplace and covers the general hazards of the activity: work at height, falls from height, work in confined spaces, fire and work with special-risk equipment. In a hotel that reads as window and facade cleaning, ladder work, shafts and boiler rooms, kitchen fire and laundry machinery.

In a less hazardous workplace all basic-training topics may be given remotely, face to face or both, which is what makes a multi-department hotel schedule workable. Training given under the old regulation remains valid, and basic-training certificates issued before 2 April 2026 stay valid for the new repeat intervals, so the first job is to date what you already hold.

The cost may not be passed to employees and training time counts as working time. Employees who had a work accident or occupational disease get extra training. Hygiene certificates are a separate duty with their own rules; do not file them as OHS training.

What else must a hotel set up besides the expert and the doctor?#

The risk assessment, the emergency plan, enough trained people for evacuation, firefighting and first aid, and drills that actually happen. Law No. 6331 (Resmî Gazete 30 June 2012, No. 28339) puts the duty on the employer: carry out a risk assessment or have one carried out, then decide the measures and protective equipment that follow from it (Articles 4 and 10).

The employer identifies possible emergencies in advance, takes measures to prevent and limit them, prepares emergency plans, and appoints enough trained and equipped people for prevention, protection, evacuation, firefighting and first aid, with training and drills (Article 11). Training is required before work starts, on a change of workplace or job, when work equipment changes or new technology is introduced, and at regular intervals (Article 17). Using outside experts does not remove the employer's responsibility, and the cost of measures and training may not be passed on to workers.

The department-by-department version of this, covering kitchens, pools, plant rooms and housekeeping floors, belongs in a separate checklist rather than in the hazard class calculation; see our department-by-department OHS checklist.

Which records does an inspector ask to see?#

The contract and time records for the expert and the doctor, training records with dates and hours, the risk assessment, the emergency plan and the drill records. The contract must state the monthly time, and a record should show the time was actually served; a contract with no trace of the visits answers only half the question.

Training records need the date, the topics, the lesson hours and who attended, with the 2-hour practical onboarding kept as its own record rather than folded into the 8 hours. The risk assessment should be dated and show review, and the emergency plan should match the building as it stands today, not as it stood before the last renovation.

Headcount by month, taken from payroll, is what connects the contract to the season and explains why the minutes changed. Keep the expert's C-class certificate and the doctor's registration with the contract rather than in someone's email. Note that hygiene certificates are a separate duty; see our guide to hygiene training certificates for hotel staff.

What to do next#

Take last July's payroll headcount, multiply it by 10 minutes for the safety expert and 5 for the workplace doctor, and compare the result with the time written in your contracts. Then check that every person hired for the season has a dated 2-hour practical session and a basic-training date inside three months. The class is fixed by your main activity, the minutes follow the headcount, and the records are what prove both.