Why Doesn't Responsibility Disappear When You Outsource OHS?

An examination of how outsourcing OHS services doesn't transfer legal responsibility, and why real control in the field and employer ownership are indispensable.

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EGEROBOT Team
March 17, 2020
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Why Doesn't Responsibility Disappear When You Outsource OHS?

Why Doesn't Responsibility Disappear When You Outsource OHS?
Why Doesn't Responsibility Disappear When You Outsource OHS?

The External Service Illusion and the Reality of Responsibility

A large portion of occupational health and safety services in Türkiye are carried out through the OJHS model. This situation appears to be a practical solution especially for small and medium-sized enterprises: you get the expert from outside, you get the physician from outside, trainings and risk assessments are done, documents are prepared, documents that may be asked during audits are arranged. For this reason, when many businesses outsource OHS service, they can get the feeling that "this job is no longer ours." Phrases frequently heard in the field clearly show this: "OJHS takes care of it," "we have an expert," "our paperwork is complete."
However, the most critical reality in terms of both regulations and field reality in Türkiye is this: You can outsource OHS, but you cannot outsource responsibility. Purchasing service does not mean transferring risk. The employer, regardless of which model they receive the service through, is ultimately responsible for occupational health and safety. This responsibility is not just a provision on paper. When an occupational accident, occupational disease, or a serious audit process occurs, all evaluations that confront the business center on this responsibility.
This article analyzes why the outsource OHS model in Türkiye is often misunderstood, why responsibility remains with the business, and what kind of results this reality produces in the field. At the same time, it reveals how the outsource model can empower the business when operated correctly and what control mechanisms need to be established for this.

Why Does Responsibility Remain with the Business?

Outsourcing OHS is essentially obtaining an expertise service from outside. In cases where the business does not employ a full-time expert within its own structure or does not consider the competency sufficient, external service may be the best method. Especially processes such as the technical burden of regulations, training and documentation needs, and field observations can be carried out more systematically with external service. The only problem here is not the outsource model itself; it's the wrong perception that the outsource model "removes responsibility."
In terms of regulations, the picture is clear. The basic approach of Law No. 6331 places the employer at the center. The employer is obligated to ensure the health and safety of employees. Applying the principles of protection from risks, making necessary organization, providing tools and equipment, informing employees, providing training, conducting supervision, auditing, and eliminating non-conformities... These duties do not disappear with outsourcing.
This wrong perception in Türkiye is fed by several reasons. First, the business sees OHS not as an operational area but as an externally obtained obligation. Second, the audit culture is document-focused. Third, the OJHS model in practice cannot produce "full ownership" within the business. External service only supports the technical execution of this process. Because the source of risk is not in the OJHS but in the business's field. The machine works at the business, the chemical is used at the business, the subcontractor works at the business, the production tempo is determined by the business's decision. Therefore, responsibility is naturally also at the business.

Legal Traceability and Evidence Chain

One of the harshest collisions seen after occupational accidents in the field is this. The business tries to step back by saying "OJHS was taking care of it." But the evaluation mechanisms don't stop with this sentence. It's examined whether the employer knew the risks, was warned, and took action. If risks were written in OJHS reports, and if they were written repeatedly, these reports show that the business was aware of the risks. In this case, the outsource service doesn't protect the business; on the contrary, it can strengthen the perception that the business "didn't provide sufficient control despite being aware."
At the root of this fragility is "action ownership." OJHS can detect risks, bring recommendations, and provide training. But the closure of actions depends on the business's internal order. If a machine guard is to be installed, the maintenance unit will step in, budget approval will be given, production will be stopped, a new standard will be published. These decisions are within the business. OJHS only recommends these decisions. That's why for the outsource model to be successful, a control backbone must be established within the business. The OJHS's report must be connected to the business's action mechanism.

Internal Ownership and Sustainability

In many examples where the outsource model is not properly established in Türkiye, what the business experiences is this: There are documents but real control in the field is weak. The business has obtained the expert from outside but the execution of the work has not been owned internally. As a result, OHS is seen as a job "that the expert does." This approach is not sustainable. Because the expert leaves, the OJHS changes, personnel changes; but the risk continues to live in the same field. This is why corporate memory doesn't form at the OJHS, responsibility doesn't stay at the OJHS, and even when OHS is outsourced, the employer's obligation doesn't end.
The correct approach here is: OJHS provides expertise to the business, and the business establishes the system. When these two work together, the outsource model produces real value. The business transforms the OJHS's findings into actions, tracks actions, makes delays visible, and reduces recurring risks. Thus, the OJHS report stops being a "record" and transforms into a "change tool."

Conclusion and EGEROBOT ISG-SIS® Perspective

Outsourcing OHS makes the service easier; but it doesn't remove responsibility. This is the most critical reality seen in the field in Türkiye. Since the source of risk is at the business, responsibility is also at the business. The OJHS model provides technical support and expertise to the business; but the system working, actions closing, and the control mechanism being established depends on the employer's ownership.
For this reason, for the outsource model to work truly efficiently, a follow-up and control infrastructure must be established within the business. Connecting risk findings to actions, matching actions with responsible parties, closure verification, monitoring recurring non-conformities, and management regularly seeing these processes; reveals the real value of outsource service.
EGEROBOT ISG-SIS® offers a backbone to the business at this point. It provides a system that transforms OJHS reports into the business's corporate memory; establishes action tracking discipline; makes delays visible; analyzes repetitions; and clarifies the responsibility chain. Thus, outsource service becomes not just document production but a structure that produces real control in the field. Permanent success in OHS in Türkiye is possible not by saying "we have an expert" but by being able to say "the system is working."

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