Who can prepare an Explosion Protection Document in Turkey?
Abstract
The employer must have it prepared before work starts. Turkish law names no licence or profession: the employer's risk assessment team writes it, outside experts may help, and explosion safety must be verified by people trained or experienced in explosion protection.
The employer is responsible and must have the Explosion Protection Document (patlamadan korunma dokümanı, PKD) prepared before work starts. Turkish law does not reserve the task for a particular profession, licence or certificate: the document is produced as part of the risk assessment by a team the employer forms, outside experts may be hired, and the proof that the workplace is safe against explosions must come from people trained and/or experienced in explosion protection.
Short answer
- Responsible: the employer (işveren). Hiring a consultant does not transfer that responsibility (Law No. 6331, Article 4(2)).
- Who writes it: the risk assessment team defined in the 2012 risk assessment regulation: employer or representative, occupational safety specialist, workplace physician, employee representatives, support staff and knowledgeable employees, supported where needed by outside people or organisations.
- Competence condition: Annex 2 of the 2013 explosive atmospheres regulation requires that the explosion safety of the whole workplace is verified before operation starts by competent persons trained and/or experienced in explosion protection.
- No named certificate: neither the regulation nor the risk assessment regulation requires a specific engineering title, an occupational safety specialist class (A, B or C) or an Ex personnel certificate for the author.
- Status of the text: the consolidated text published by the Ministry of Justice (December 2025) and the mevzuat.gov.tr text show no amendment to the 2013 regulation; claims of a new "authorised preparer" rule should be checked against the Official Gazette before being relied on.
What the Turkish rules actually say
The duty sits in the Regulation on the Protection of Workers from the Hazards of Explosive Atmospheres (Çalışanların Patlayıcı Ortamların Tehlikelerinden Korunması Hakkında Yönetmelik), Resmî Gazete 30 April 2013, No. 28633, which follows Directive 1999/92/EC.
| Source | Provision, paraphrased |
|---|---|
| Law No. 6331, Article 10(1) | the employer must carry out the risk assessment or have it carried out |
| Law No. 6331, Article 4(2) | using outside experts or organisations does not remove the employer's responsibilities |
| 2013 regulation, Article 10(1) | the employer prepares the PKD while meeting the risk assessment duty of Article 6 |
| 2013 regulation, Article 10(3) | prepared before work starts; reviewed and updated after significant changes, extensions or modifications |
| 2013 regulation, Article 10(4) | the PKD may be combined with the general risk assessment and other reports |
| 2013 regulation, Annex 2, item 2.8 | explosion safety of the whole workplace is proven before operation, by competent persons trained and/or experienced in explosion protection |
| Risk assessment regulation (29.12.2012, No. 28512), Article 6 | the risk assessment is carried out by a team formed by the employer; outside people and organisations may support it; the employer or a team member may coordinate |
The Ministry of Labour and Social Security implementation guide (revised 2024) adds practical points: the document should set out the organisation and responsibilities, and all responsible persons should take part in preparing it; hazardous zones should be classified using the relevant standards and published scientific calculations rather than assumptions; and the team that prepares the document may set a period for checking its validity. It also says the PKD has no prescribed format. The guide is advice, not binding law.
Can the occupational safety specialist prepare it alone?
Legally, the occupational safety specialist (iş güvenliği uzmanı) is a member of the team, not the sole author, and the regulation gives no preference to any certificate class. In practice the specialist often coordinates the work and the general risk assessment, while the technical core needs explosion-protection knowledge:
- Zone classification for gases and vapours (IEC 60079-10-1) and for combustible dusts (IEC 60079-10-2): sources and grades of release, ventilation, zone extents and drawings.
- Ignition source assessment, including non-electrical equipment and static electricity (EN 1127-1 gives the method).
- Equipment check: whether each device in a zone has a suitable category or EPL, gas group and temperature class, and whether the installation follows IEC 60079-14.
- Process knowledge: substances, flash points, dust properties and operating states that only plant staff know.
A specialist with this knowledge can lead the whole document. Where the team lacks it, the risk assessment regulation allows outside support, and Annex 2 effectively requires it for the verification step.
Using an outside consultant
Many employers commission the PKD from an engineering or OHS service provider. This is lawful, but:
- the employer still owns the document and must sign off the measures and their implementation;
- the consultant needs plant data, process staff and site access; a PKD written from a desk visit is rarely correct;
- the employer should ask for evidence of explosion-protection competence. Turkish law names none, so evidence is usually training records, documented project experience, or an international personnel certificate such as the IECEx Certificate of Personnel Competence (CoPC), whose unit Ex 002 covers performing hazardous area classification.
Turkish engineering chambers and private bodies run PKD preparation courses. Such a course certificate can support a competence claim, but no course is a legal precondition for preparing the document.
Common mistakes
- "Only an A-class specialist may sign it." The 2013 regulation contains no such rule; competence in explosion protection is what it asks for.
- Outsourcing the responsibility. The consultant prepares; the employer remains responsible under Law No. 6331.
- A document without plant input. Process staff and maintenance must contribute; the guide expects all responsible persons to take part.
- Zoning by habit. The Ministry guide asks for classification based on standards and calculation, not on assumptions or copied drawings.
Related on excodex
- The Explosion Protection Document (EPD) and area classification drawings under ATEX 1999/92/EC
- ATEX explained: the two EU directives 2014/34/EU and 1999/92/EC in plain language
- Which workplaces in Turkey must prepare an explosion protection document?
- What competence does a person need to carry out a hazardous area classification?
- Standards space: Turkish explosive atmosphere regulations
Standards and further reading
- Regulation on the Protection of Workers from the Hazards of Explosive Atmospheres, consolidated text (Ministry of Justice, December 2025): adalet.gov.tr
- Occupational Health and Safety Risk Assessment Regulation (İş Sağlığı ve Güvenliği Risk Değerlendirmesi Yönetmeliği), consolidated text: mevzuat.gov.tr
- Occupational Health and Safety Law No. 6331 (İş Sağlığı ve Güvenliği Kanunu), consolidated text: csgb.gov.tr
- Ministry of Labour and Social Security, implementation guide on explosive atmospheres (revised 2024, in Turkish): csgb.gov.tr
- IECEx Certification of Personnel Competencies scheme, units of competence: iecex.com
- IEC 60079-10-1 and IEC 60079-10-2, classification of areas for gas and dust atmospheres; EN 1127-1, explosion prevention and protection, basic concepts.
This article is general technical information prepared by the excodex editorial team. It does not replace the applicable standards, the equipment certificates and instructions, national regulations or the assessment of a competent person.