Must an employer in Uzbekistan appoint a safety professional or an occupational physician?

For safety, yes. Every organisation in production with 50 or more workers must set up an OSH service or create the post of an OSH specialist (Law ZRU-410, Art. 12), and Cabinet of Ministers (CM) Resolution No. 819 of 24 December 2025 sets the minimum size of that service by headcount and occupational risk class. Uzbek law does not generally require an in-house occupational physician; compulsory medical examinations are done by medical institutions.

Short answer

• Threshold in the law: production organisations with 50 or more workers must have an OSH service or OSH specialist; below 50 workers the employer decides, taking account of the nature of the work (Law ZRU-410, Art. 12).
• 2025 staffing norms: Annex 5 to the regulation approved by CM Resolution No. 819 combines headcount (under 50, 50 to 100, 100 to 500, 500 or more) with the occupational risk class (1 to 20) used for employer liability insurance.
• Reporting line: the OSH service is an independent unit reporting directly to the head of the organisation; its posts may not be cut or moved to other units, and failing to set it up is itself a breach of OSH law.
• Outsourcing: the service functions may be contracted to registered "professional participants of the OSH services market".
• Road safety: an organisation with 50 or more vehicles also needs a road safety service or specialist.
• Physician: no general duty to employ one; the medical commission that examines workers must be chaired by a doctor trained in occupational pathology.

The 2025 staffing grid

The class boundaries overlap in the official table (1 to 4, 4 to 10 and so on), and the low-risk cell for 50 to 100 workers gives the duty to a manager while the law speaks of a service or specialist from 50 production workers. Where the two point in different directions, plan for the stricter reading and confirm with the territorial State Labour Inspectorate. Budget organisations may organise the service within their existing staff. For a full OSH service (9 or more staff), the staffing norms add one more OSH specialist for every further 50 staff positions.

Who can be the OSH specialist

Under the regulation on organising OSH work (Annex 1 to Resolution No. 819), OSH service staff and single OSH specialists must have a higher engineering and technical education. The head of the service also needs at least three years' experience in the specialty and the OSH specialist qualification certificate, and is interviewed by the State Labour Inspectorate before appointment. New appointees must be retrained or upskilled within three months of appointment and upskilled at least every three years.

The 2025 training regulation (Annex 2 to Resolution No. 819) requires OSH service heads, specialists and engineers to complete upskilling of at least 72 academic hours every three years; after such a course they may sit the qualification examination for the OSH specialist certificate within one year. The training regulation allows six months for retraining after OSH specialist duties are assigned, while the service regulation speaks of three months, so plan for the shorter period; and managers without a technical higher education who are given OSH functions take retraining of at least 288 academic hours. Courses are run by the ministry's professional development centre or by registered professional participants.

What about the occupational physician?

The Labour Code (Art. 360) makes the employer organise pre-employment and periodic examinations, but the examinations themselves are carried out by the medical institution that serves the organisation or, if there is none, by the territorial institution where the organisation is located. The Ministry of Health regulation sets up a medical commission (therapist, neurologist, ophthalmologist, ENT specialist and others) chaired by a doctor trained in occupational pathology. Large plants often keep a medical and sanitary unit, and the 2026 accident regulation requires such a unit to report injuries to the employer and the union within one day, but no general headcount threshold for a workplace doctor was found.

There is one medical requirement inside the OSH service itself: Annex 1 to Resolution No. 819 says that one member of the organisation's OSH service must hold a higher medical degree in occupational hygiene. The regulation does not say how this applies where the service is a single specialist post, which must be filled by an engineer, so check with the territorial State Labour Inspectorate.

This differs from Türkiye, where Law No. 6331 (Art. 6) requires the employer to assign an OSH specialist and a workplace physician or use a joint health and safety unit, with narrow exceptions for small, less hazardous workplaces, and from many EU states where occupational health services are compulsory.

Common mistakes

• Counting only headcount. The risk class can push a small plant into needing a full OSH sector or department.
• Placing OSH under production. The service must report directly to the head of the organisation.
• Assuming a company clinic replaces the OSH service. Medical services and the OSH service are separate duties.

Related on excodex

• Occupational safety and health in Uzbekistan: law, authorities and employer duties
• Are pre-employment and periodic medical examinations required in Uzbekistan?
• What OSH training must employers provide in Uzbekistan?
• OSH law comparison: appointments and reporting deadlines

Standards and further reading

• Law No. ZRU-410 of 22 September 2016 "On Labour Protection", Arts. 12, 13 and 17: https://lex.uz/docs/3031427
• CM Resolution No. 819 of 24 December 2025 (in force 25 December 2025), Regulation on organising OSH work and the OSH service (paragraphs 56 to 79, Annexes 4 and 5) and Regulation on OSH training: https://lex.uz/docs/7942768
• Law No. 6331 on Occupational Health and Safety (İş Sağlığı ve Güvenliği Kanunu), Türkiye, Art. 6: https://www.mevzuat.gov.tr/mevzuat?MevzuatNo=6331&MevzuatTur=1&MevzuatTertip=5
• Labour Code of the Republic of Uzbekistan (2022), Arts. 359 and 360: https://lex.uz/docs/6257288
• Ministry of Health Regulation on medical examinations of workers, registration No. 2387 of 29 August 2012: https://lex.uz/docs/2046010

This article is general occupational safety and health information prepared by the excodex editorial team. It does not replace the applicable legislation, standards, manufacturers' instructions or the assessment of a competent OSH professional or occupational physician.