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

Yes for safety staff, no for a company doctor. Under Article 202 of the Labour Code, an organisation with production activity and more than 50 workers must create an occupational safety and health (OSH) service, and an employer with up to 50 workers must appoint an OSH specialist or give OSH duties to another specialist. Kazakh law does not require an in-house occupational physician: medical examinations are carried out by licensed medical organisations.

Short answer

• More than 50 workers, production activity: an OSH service (служба безопасности и охраны труда) reporting directly to the first head of the organisation or a person the head authorises, working to a model regulation issued by the Ministry of Labour.
• Up to 50 workers: a post of OSH specialist (специалист по безопасности и охране труда), or OSH duties assigned to another specialist who reports directly to the head.
• Small businesses: may organise OSH under a contract with an individual or a company (Article 202, paragraph 6).
• Training: heads of OSH services and specialists responsible for OSH must be trained and tested every 3 years in a listed training organisation (40 academic hours or more per programme).
• Physician: no statutory in-house occupational physician; periodic examinations are done by licensed medical organisations whose commission is chaired by an occupational pathologist.
• Penalty for no OSH service or specialist: 20, 30 or 120 monthly calculation indices (MCI) for small, medium and large businesses (Code of Administrative Offences, Article 93).

What the OSH service or specialist must do

Article 202 gives the OSH service, or the specialist in a smaller firm, the right to enter and inspect production and welfare premises, to check preventive measures, and to issue binding instructions to departments to correct breaches. It also sets three duties:

1. analyse every month the state and causes of work injuries and occupational diseases, plan prevention and keep the analysis in the organisation's electronic records;
2. organise training, briefing and knowledge testing of workers, managers and persons responsible for OSH;
3. make sure the procedure for investigating work accidents is followed.

The head of the OSH service also sits on the employer's accident investigation commission (Article 188) and on the attestation commission for working conditions (Article 183).

The Code does not set a number of OSH staff per worker. The size of the service is the employer's decision, made in line with the model regulation and the risks of the activity.

Qualifications and training

The Labour Code does not create a certified profession like the Turkish occupational safety expert (iş güvenliği uzmanı), whose A, B and C certificate classes are set by Law No. 6331 (Article 8). The practical qualification is set by the training rules (Order No. 1019 of 25 December 2015, as revised from 12 July 2026): heads of OSH services and persons performing OSH service functions complete at least 40 academic hours of general training, and OSH service specialists and appointed responsible persons at least 40 academic hours of special, sector-related training, every 3 years in an organisation on the ministry's list. The knowledge test result is recorded as an electronic certificate. First managers and persons authorised for OSH need at least 16 academic hours every 3 years.

The Ministry of Labour has also approved a professional standard "Safety and labour protection" (Order No. 490 of 25 December 2024), which is used, for example, to certify the experts of the specialised organisations that carry out occupational risk assessments.

What about an occupational physician?

Employers must pay for and organise mandatory pre-employment, periodic and pre-shift medical examinations (Labour Code Articles 182 and 185). Under the Ministry of Health order ҚР ДСМ-131/2020 these are performed by licensed medical organisations; the medical commission for periodic examinations includes several specialists and is chaired by an occupational pathologist (профпатолог). The employer cooperates with that organisation, for example by drawing up the list of workers to be examined by 1 December each year.

Pre-shift checks of workers in high-hazard jobs and pre-trip checks of drivers need a medical worker and a dedicated room, provided by the organisation or the medical organisation. This differs from Türkiye, where Law No. 6331 (Article 6) requires every employer to have a workplace physician (işyeri hekimi), employed in-house or provided by an external OSH service.

Related on excodex

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

Standards and further reading

• Labour Code of the Republic of Kazakhstan No. 414-V of 23 November 2015, Articles 182, 185 and 202: adilet.zan.kz
• Rules and terms of OSH training, briefing and knowledge testing, Order No. 1019 of 25 December 2015 as revised by Order No. 223 of 30 May 2026: adilet.zan.kz
• Order of the acting Minister of Health No. ҚР ДСМ-131/2020 of 15 October 2020 on mandatory medical examinations: adilet.zan.kz
• Code of Administrative Offences No. 235-V of 5 July 2014, Article 93.

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.