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

Yes for organisations above 50 workers: under the Law "On Labour Protection" No. 82 of 2026 (Article 16) and the Labour Code (Article 207), an organisation with more than 50 workers must have a labour protection service (служба охраны труда) or at least a qualified labour protection specialist. Smaller employers decide for themselves and may use an external specialist. There is no general duty to employ an occupational physician: compulsory medical examinations are carried out by state health organisations under contract.

Short answer

• Threshold: more than 50 workers. Law No. 82, Article 16 requires a service in every organisation (and its branches) carrying out production activity; Labour Code Article 207 allows either a service or a post of labour protection specialist with suitable training or experience.
• 50 workers or fewer: the employer decides whether to create a service or a specialist post, taking the nature of the activity into account. Without one, the employer contracts specialists or organisations that provide labour protection services (Law No. 82, Article 16(3); Labour Code, Article 207(3)).
• Status: the service reports directly to the head of the organisation, ranks with the main production services and may be abolished only if the organisation ceases its activity (Article 16(4) and (7)).
• Powers: specialists issue binding instructions to unit managers, require removal of workers without a medical examination, training, instruction or knowledge test, and may stop machines, areas or in-plant vehicles that threaten life or health (Article 16(5) and (6)).
• Physician: no general duty to appoint an in-house occupational physician. The employer must organise first-aid points and conditions for primary medical care (a health post or medical unit) in the manner set by the Cabinet (Article 11), and medical examinations are done by state health organisations.

The labour protection service in practice

The labour protection service is the post-Soviet equivalent of an in-house safety department. The employer sets its structure and staffing by headcount, degree of hazard and the remoteness of sites, following norms of the state labour body (Labour Code, Article 207(4)). The model regulation on the service, approved by Government Resolution No. 225 of 5 April 2004 and still listed as in force, gives it tasks such as:

• organising training, instruction and knowledge testing;
• preparing or checking labour protection instructions;
• organising the workplace attestation (assessment of occupational risks by working conditions) and following up its measures;
• controlling the issue and use of PPE;
• taking part in accident investigations and keeping their records;
• inspecting workplaces and stopping dangerous work.

The accident regulation also expects a labour protection specialist, who may be engaged under contract, to sit on every accident investigation commission. A new model regulation is due from the Cabinet under the 2026 law (Article 16(8)); check whether it has been adopted.

Comparison with Türkiye and the EU

Worked example

A food processing company in Chuy region employs 45 workers and plans to expand to 60. At 45 workers it must still meet every labour protection duty, so the director either assigns a trained production engineer or signs a contract with an external labour protection specialist for instruction, PPE and the attestation. When headcount passes 50, a service or a full specialist post is required: the company appoints a labour protection specialist reporting directly to the director and documents the service's regulation, duties and powers. It also sends workers whose jobs require it for medical examinations at a state health organisation under contract; no in-house doctor is legally needed.

Common mistakes

• Placing the labour protection specialist under a production manager; the law requires direct reporting to the head of the organisation.
• Abolishing or merging the service during a restructuring; that is allowed only when the organisation ceases its activity.
• Importing Türkiye's workplace physician model as a legal requirement.

Related on excodex

• Occupational safety and health in Kyrgyzstan: law, authorities and employer duties
• Are pre-employment and periodic medical examinations required for workers in Kyrgyzstan?
• Is a safety committee or a worker safety representative required in Kyrgyzstan?
• OSH law comparison: appointments and reporting deadlines

Standards and further reading

• Law of the Kyrgyz Republic No. 82 "On Labour Protection", 5 June 2026 (Articles 11, 14, 16): official text.
• Labour Code of the Kyrgyz Republic No. 23, 23 January 2025 (Article 207): official text.
• Model Regulation on the service and organisation of labour protection work, Government Resolution No. 225 of 5 April 2004 (as amended 17 June 2005): official text.
• Türkiye: Occupational Health and Safety Law No. 6331 (İş Sağlığı ve Güvenliği Kanunu), Article 6: mevzuat.gov.tr.

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.