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Updated on: 21 June, 2020
In Turkey, the first official announcement of a Covid-19 case was on 11 March and the first death took place on 18 March. As of 21 June, the number of cases reached 187,685 and the number of deaths reached 4,950.
Following the diagnosis of the first case, first measures were taken concerning schools. The Ministry of National Education announced that education was suspended from 16 March for one week in primary and secondary education schools, and for three weeks in universities. In the same announcement it was stated that from 23 March onwards, in primary and secondary education, distant education would be initiated on national channels. Distant education started on this date. Afterwards, considering the increased number of Covid-19 cases, the deadline for distant education was extended until 31 May. And finally, it was accounted on 18 May that the 2019-20 school year has ended, and the new school year will begin in September.
During the days following the diagnosis of the first case, the number of patients increased and measures such as the prevention of passenger transport to and from various countries, the payment of pensions at home, the termination of activities in places such as theatres, cinemas, cafeterias and restaurants, the prohibition of communion & praying in mosques and the termination of sports activities were taken. During this period, shops and shopping malls halted their activities one after the other.
As of 21 March, a curfew was announced for citizens aged over 65 and those who have chronic health problems such as asthma, COPD and cardiovascular diseases.
According to the announcement by the President of the Republic on 27 March, intercity travel is only possible with the permission of the governors. As of an announcement on 27 March, all flights abroad were totally terminated. A decision was taken to order people practice sparse sitting (social distancing) in urban public transport.
The Ministry of Interior circular of 3 April introduced a travel ban and, with some exceptions, banned the entrance and exit for 30 metropolitan provinces and Zonguldak province for a period of 15 days. Those whose residence and workplace are located in different cities were exempt from the travel ban. The same circular extended the curfew to those born after 1 January 2000. Nevertheless, youngsters between 18-20 years of age who are working were exempted. The circular also introduced the obligation to wear masks in shops, marketplaces and those workplaces where workers are working together. The travel ban was extended numerous times. As of 4 May, the ban has been removed for seven metropolitan provinces. For the remaining cities, the travel ban has been extended until 2 June.
A curfew was announced on 11-12 April, 18-19 April, 23-26 April, 1-3 May, 8-9 May and 16-19 May in the 30 metropolitan provinces and Zonguldak province. However, the majority of the factories have been exempted from the curfew. It was announced that a curfew in all 81 provinces of Turkey will be implemented on 23-26 May, which covers the feast following Ramadan.
Measures regarding the Ramadan month, which started on 24 April, were also publicised. According to the Ministry of Interior’s circular dated 22 April, events which bring together many people such as iftar and sahur will not be organised, and iftar tents will not be set up.
As of 11 May, some steps of ‘normalisation’ have started to be implemented. Shopping malls which meet the necessary criteria began re-opening from 11 May onward. The hygiene measures to be followed in these shopping malls were announced by the Ministry of Health. It was decided that barbers, hairdressers and beauty centres could re-start activities as of 11 May on the condition that they follow the rules announced by the relevant ministries. It was also announced that the football league shall start on the second weekend of June.
Daily life has ‘normalised’ to a great extent as of 1 June. Travel restrictions in 15 provinces were lifted on 31 May. Some of the other restrictions lifted as part of the normalisation are as follows:
The ban on quitting work (which applied for health personnel) was lifted as of 8 June.
Curfew covering those over age 65 and under 20 was first revised, and on 9 June President Tayyip Erdoğan announced that it was largely lifted. Accordingly, those over age 65 will be able to go out between 10.00-20.00, whereas there is no time restriction for children and young adults.
Together with normalisation, the number of cases rapidly increased in some provinces. Accordingly, governors are continuously monitoring and making decisions for their respective provinces. Going out without wearing a mask is forbidden in many provinces. It was announced that starting on 22 June those who are not wearing a mask will be charged a 900 TL fine in 54 provinces.
The textile and garment sector faced a contraction in their production capacities during this period. However, in some factories, working for stock is continuing. Regarding enterprises concentrating on exports, some international brands began cancelling their orders shortly before the pandemic came to Turkey. In the provision of intermediary input materials – such as raw materials and accessories from Europe – the problems that emerged as a result of the devastating influence of Covid-19 in the European continent increased in the past months.
Some textile factories / workshops, in line with increased demand, started the production of masks. However, there is no data showing how much is legal production and how much is fake.
While some of the factories working for exporters have resorted to short-work allowance, in some others, using paid annual leave or imposing unpaid leave practices have been on the agenda. In medium-sized enterprises where a smaller number of workers are employed, dismissals have been common. The enterprises in the sector producing for the domestic market are also facing problems since retail sales have stopped.
According to the decision of the Scientific Committee – which has taken the national lead in the struggle against Covid-19 – and of the President of the Republic, the distribution of the cases and deaths according to provinces is not shared with the public. Since the intensity of the cases according to provinces is not known by the public, there is no data to indicate the number of factories and workers who are directly at risk.
On the other hand, the proposal of professional associations, trade unions and of some scientists to the government is the immediate termination of production for a 15 day period, without any cuts to workers’ wages. In recent days, it is frequently stated that to prevent the further prolongation of the slowing down of production, and to prevent a further increase in the number of patients, the factories should be closed immediately. According to the ‘Covid-19 DISK Report’, prepared by the Research Institute of DISK (DISK-AR) and published on 27 April, the percentage of Covid-19 positive cases among DISK members is 3.2 times the percentage of cases in Turkey.
An important section of the measures taken by the government in favour of employers declared by Tayyip Erdogan, President of the Republic on 18 March, 2020, is within the Economic Stabilization Shield package. In this package, there are additional credits as well as the postponement of payments to support various sectors of the economy. Some of the outstanding headings of this package are as follows:
In addition to these, additional support will be provided to factories manufacturing products of urgent need such as masks, gloves, eyeglasses and protective garments.
President Tayyip Erdoğan, in a statement made on 27 April, expressed that the total amount of support within the Economic Stability Shield has reached 200 billion liras.
Another incentive package recently introduced concerns firms which will decrease imports and increase exports. It was announced that the Central Bank with the 18 billion TL ‘Advance Loans against Investment Commitment’ will provide the firms with investment support up to 400 million TL with a maximum length of 10 years.
Preparations for a new package called Employment Shield that will cause radical changes to working life is continuing. Although there is still no bill introduced by official channels, information regarding the content has filtered down through the press. Some elements of Employment Shield were also expressed in the President’s speech on 9 June. What we know so far can be summarised as follows:
Even though of the public sector employees in Turkey those considered within the risk group are granted the right to be considered on administrative leave, no such practice was on the agenda for the private sector. In jobs which do not require people to be at the factory, flexible working arrangements such as tele-working and work-on-call have become common. Work has been slowed down in major parts of the private sector and has almost come to a stop in various sectors such as tourism. Furthermore, a great majority of shops, cafes and restaurants have been closed for a temporary period from the first days of the pandemic onwards. The textile sector, due to the decline of orders, is one of the sectors influenced by the pandemic.
In case the weekly hours of work is considerably reduced for a temporary period at the workplace, or in case the activity in the workplace is terminated partially or totally for a temporary period because of force majeure, it is possible to apply for the payment of short-work allowance. For the payment of short-work allowance, the employer has to lodge a written application to the official labour placement office (İŞKUR) and should pledge not to dismiss workers. During the pandemic period, an amendment of the law softened the necessary conditions to benefit from the short-work allowance. Pursuant to this amendment, those workers who have been working at the workplace during the 60 day period prior to the initiation of short-work have the right to receive this allowance on the condition that during the last three year period, they have worked within the insurance system for at least 450 days and paid unemployment insurance contributions. During this period, the wages of the workers are financed from the Unemployment Insurance Fund. The daily short-work allowance is 60% of the daily average wage over the last 12 months’ gross income of the worker. However, the monthly payment can not exceed 150% of the monthly gross amount of the national minimum wage. Receiving applications for short work allowance started on 23 March, and on 27 April it was announced that within a one month period 291,594 firms have applied for short work allowance for nearly 3.2 million workers.
An important regulation within the scope of Covid-19 measures enacted on 16 April, which introduced restrictions regarding dismissals. In accordance with this regulation, the labour contracts of the workers cannot be terminated for reasons other than ‘cases contradicting rules of ethics and goodwill’ defined in Article 25/2 of the Labour Act (4857) for a period of three months. Within the context of this regulation, the obligation of getting workers’ approval for unpaid leave has been repealed. At the same time, during this period the worker will not be allowed to terminate his/her labour contract on just grounds, because of being sent on unpaid leave.
If the worker is sent on unpaid leave and cannot meet the conditions for receiving short work allowance, he/she may benefit from a daily cash payment of TL 39.24. Under the temporary arrangement made for a period of three months within Covid-19 measures, the application for this payment is made by the employer and the payment is made by the Unemployment Insurance Fund. The approval of the worker is not required, with the employer being the one to decide.
If the worker is Covid-19 positive, his/her labour contract will be suspended during the period of sick leave report, received from the medical institution. The employer is not under the obligation to pay wages for this period. The payment for this period will be made by the Social Security Institution (SGK).
During periods of reduced activity or total stoppage, the employer can also ask the workers to go on paid leave. This is not a legal obligation, but it is at the discretion of the employer. During the period of stoppage of work, it is possible for the worker to use his/her paid annual leave. Collective paid leave can be given by the employer between April and October.
Aside from these, in some sectors, including the textile and garment industries, it is necessary to ask for overtime work due to the pandemic. An increase in production might be on the agenda because of the extra demand in some sectors such as medical, pharmaceutical production, mask production, hygienic commodities production and above all in healthcare/hospitals. Under these conditions, daily hours of work with overtime not exceeding 11 hours a day may be imposed without a need for the approval of the worker. This situation may arise in the textile and garment industries for enterprises manufacturing required items such as protective clothing and masks.
During this period, another regulation arose concerning industrial relations concerned freedom of association. A circular issued by the Ministry of Family, Labour and Social Services on 23 March restricted trade union rights considerably during the pandemic period. In the circular, it was stated that various procedures undertaken by the ministry – such as the issuance of certificate of competence for negotiating with employers, mediation procedures and strike ballot – were suspended.
Apart from these, various new regulations concerning pensioners were on the agenda. It was stated that the religious feast (Ramadan) bonus payment due in May would be paid in April and the lowest pension increased to 1,500 TL per month.
According to data released by the Ministry of Family, Labour and Social Services, the total amount of funds provided to workers during the Covid-19 period is TL 11.5 billion as of 18 May 2020. If we look at how this amount is distributed, we see that TL 4.8 billion is paid for short work allowance, TL 441 million for wage support in cash, TL 730 million for unemployment allowance and TL 5.4 billion for the social support programme.
Labour statistics for March (when the influence of Covid-19 started to be felt in Turkey) were released by TUIK on 10 June. According to TUIK data, the rate of unemployment in March was 13.2% and the number of unemployed was nearly 4 million. However, labour organisations state that these figures do not cover a significant portion of the unemployed and that, actually, the number of unemployed is over 10 million and the rate of unemployment is over 30%.
Regulations within the scope of OHS
The employer has the obligation to inform the authorities in case Covid-19 is diagnosed at the workplace. Pursuant to the law, the employer is under the obligation to take all forms of measures to safeguard the health of the workers throughout the period they are in the workplace. It is the responsibility of the employer to take measures such as the provision of hygienic conditions in the workplace, the distribution of protective masks to the workers, regular fever measurement and provision of necessary material for hygiene in the lavatories during the period of the pandemic.
In the guide issued on the subject by the General Directorate of Work, Health and Safety affiliated with the Ministry of Family, Labour and Social Services, there is detailed information on subjects such as hygiene in commuting vehicles, quarantine practices, hygienic material to be used at the entrances and exits of workplaces, social distancing rules, temperature measurements and disinfecting of jointly used materials and areas. Pursuant to the law, in case the necessary preventive measures are ignored in spite of warnings of the workers, the workers have the right to refrain from work. In case these measures are still not taken, the workers have the right to terminate their labour contracts. Directorate General for Pension Services of the Social Security Institution issued a circular on 7 May 2020 which indicated that for workers who are infected with Covid-19, the sickness shall not be considered as work accident or occupational disease. The circular states that Covid-19 is a contagious disease and the treatment procedure for the insured person who is exposed to the virus should be the same the procedure followed for normal sickness. To be clearer, the circular of the Social Security Institution (SGK) considers Covid-19 not as a work accident or an occupational disease, but a normal sickness. Accordingly, even if the worker got infected at the workplace, the employers will not report the case to the SGK as a work accident or occupational disease. Various trade unions and NGOs drew attention to the fact that the content of this circular contradicts the Social Insurance and General Health Insurance Law no. 5510 and the Occupational Health and Safety Law no. 6331, and therefore cannot be implemented as it is. The Turkish Medical Association also states that this circular does not negate the obligation of employers to report Covid-19 positive cases as a work accident on just cause.
The ILO office in Turkey made a call on the trade unions and employers’ associations which are parties in industrial relations to increase social dialogue.
The ILO called for the meeting of an international working group coordinated by the International Trade Union Confederation (ITUC) with the participation of the International Organisation of Employers (IOE), brands and producers, workers’ and employers’ organisations and governments on 22 April. In this invitation, the objective of the joint activity thus established is stated as work on minimising the
damages caused by Covid-19 to the international garment sector and work on sustainable social protection systems for a just and durable garment industry. According to the information provided by the office in Turkey, the coordinated activity organised by the relevant agencies is continuing.
However, the trade unions were not invited to the nationwide meetings called by the government to discuss the urgent action plans. Therefore, the trade unions have stated that they are not in dialogue with the government on decisions to be taken at the national level, but have communicated their activities to the government through various channels.
DISK (Confederation of Progressive Trade Unions of Turkey), KESK (Confederation of Public Employees Trade Unions), TMMOB (Union of Chambers of Turkish Engineers and Architects), TTB (Turkish Medical Association) launched a signature campaign at the beginning of April to submit to the government their urgent demands, which comprises of seven articles. This text, opened for signatures, includes demands such as the temporary suspension of all economic activity except the essential and obligatory sectors, the nationalisation of private hospitals for the duration of the pandemic, the postponement of servicing consumers, housing and vehicle credits, the postponement of water, natural gas and electricity bills without the addition of interest.
DISK, one of the trade union confederations in Turkey, released a document on 14 May titled ‘The Road Map for Working Life During and After Covid-19’. The government had not included professional associations and trade unions in the committees assigned for crisis management. Therefore, the document released by DISK on 14 May called for the government’s approval approval that health associations and trade unions are involved in steps taken regarding working life.
An international e-panel on ‘How do workers of the world fight COVID-19?’ was organised on 16 May with the participation of DISK, IndustriAll, ITF (International Transport Workers’ Federation), ETUI (European Trade Union Institute), IUF (International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers’ Associations) and UNI Global Union. The Turkey side of the panel was coordinated by DISK. The participants shared their views on the socio-economic damage and effects of the pandemic at the international level.
The ILO office in Turkey has warned that in the struggle against Covid-19 the workers should abide by the protective regulations in order not to be victims of the pandemic, and discrimination against those who have been infected with the disease should be prevented. The Office made a statement to the attention of the employers concerning the training of the workers about hygiene, the protection of job security of infected workers, and advising that those employees who can work at home, should.
The worker’s trade union confederations made a statement on this issue and voiced their demands. The demands included measures such as payment to the unemployed workers for a period of three months of a sum equal to the minimum wage and the financing of this payment from the unemployment insurance fund. The stoppage of production for a period of 15 days in all sectors which are not considered strategic and, instead of dismissals, short-work allowance from unemployment insurance fund should be used without any time limit, until the effects of the pandemic are over. Some trade unions on the other hand, by negotiating with the employers, secured some measures concerning their members within the scope of the concluded collective agreements. Amongst these measures are the following: The prevention of the dismissal of the worker without his/her demand; balancing of the paid annual leave and additional paid leave apart from the paid annual leave.
The trade union confederations are regularly presenting observation records on the working and safety conditions of the factories in which their members work. In case there are workers with positive Covid-19 test results, they try to carry out a dialogue with the relevant parties to secure the obligatory suspension of activity. Professional associations and organisations active in the area of workers’ health and safety are publishing pamphlets including necessary technical measures for the prevention of the spread of the pandemic in working life.
In the ‘working conditions’ section within the document released on 14 May by DISK, ‘The Road Map for Working Life During and After Covid-19’, for protecting against Covid-19 and for increasing employment, shortening the working week to 37.5 hours was demanded. It is requested that enabling workers without facing any loss of wages and existing rights to work with a rotating system or working at home should be negotiated and resolved with the participation of trade unions. In the document, it is also demanded that workers who catch Covid-19 at work should be considered as having a work accident. Especially for health workers, workers in laboratories and similar places, that are directly involved in the fight against the pandemic, Covid-19 should be accepted as occupational illness. It was also emphasised that collective bargaining that had been postponed due to the pandemic should restart in July. Stating that violence against women both at work and at home has increased during Covid-19 pandemic, the document called for effective implementation of the Istanbul Agreement, the Law no. 6284 on the Protection of the Family and Prevention of Violence against Women and the ratification of ILO Convention 190.
Turkish Standards Institute (TSE) attached to the Ministry of Industry and Technology prepared a Covid-19 Hygiene, Infection Protection and Control Guide for the industrial and services sectors.
The guide also aims to meet the need of certifying firms’ compliance of safe and hygienic production standards after the pandemic is over. The inspection of those who wish to get a certificate and the issuing of a Covid-19 Safe Production Certificate in the form of an international quality certificate to those who pass the inspection is being planned. TSE has started to accept applications for certification inspections also on its website.
Turkish Industry and Business Association (TUSIAD) organised a webinar together with its members on 17 March entitled, ‘Coronavirus, Global Markets and the Economy of Turkey.’ TUSIAD participated in the Coordination Meeting on the Struggle Against Coronavirus held on 18 March, at which the President of the Republic, Ministers and relevant organisations took part. TUSIAD created a portal under the name ‘Covid-19’. They state that via their websites they receive proposals on various measures and support proposals to eradicate problems concerning supply and demand. They disclosed to the public on 27 March that they had presented a letter to the President of the Republic which included the information received through this channel. They state that it is necessary for the government to further expand measures to secure the integrity of the supply chain in sectors where production loss has occurred. They expressed that the 100 billion TL support package of the government should be increased. Aside from that, they also advised that in order for the economy to recovery rapidly, the implementation of an extensive curfew to slow down the contamination of the pandemic should be evaluated.
On 16 June, Simone Kaslowski, President of TUSIAD Board of Directors attended the inclusive sustainability platform, Leaders Summit of UN Global Compact, which is celebrating its 20th year. Kaslowski evaluated the sustainability agenda in the post-pandemic world and its possible risks and opportunities for Turkey. He spoke about the need to update the targets of the sustainable growth model to include Digital Single Market and Green Deal in EU-Turkey Customs Union. Emphasising EU-Turkey dialogue on carbon border adjustment and digital tax, Kaslowski also drew attention to the importance of expansionist policy for reaching sustainable development targets. On 4 April, 29 non-governmental organisations (the majority of which consisted of employers’ associations and organisations) issued a joint statement on Covid-19. The signatories of this statement called member employers to action. The context of this statement reminded employers to utilise the current practices of the government facilitating the conditions of receiving the short work allowance.
On 4 April, 29 Non-Governmental Organisations (the majority of which consisted of employers’ associations and organisations) issued a joint statement on Covid-19. The signatories of this statement called on member employers. The context of this statement reminded employers to utilise the current practices of the government facilitating the conditions of receiving the short work allowance.
Turkish Clothing Manufacturers’ Associations (TGSD) stated that it has established the TGSD Corona Liaison Desk, with which relevant institutions were in contact. It also formed a 24/7 accessible portal with which the affiliated enterprises could share the impact of Covid-19 on their activities.
The Chairperson of the Management Committee of the TGSD made a statement in line with the information supplied by the production companies to the Covid-19 portals which were active on 7 April 2020. In this statement there was mention of the damage inflicted on the supply chains by international brands that cancelled or postponed orders. It was also mentioned that some brands requested the postponement of the payment periods of the commodities which have been sent to the warehouses, which are being sold, or which have already been sold in the shops, and the international brands have been called to perpetuate healthy and sustainable supply chains on the basis of mutual understanding and respect. The TGSD which prepared a ‘Covid-19 Customer Situation Form’ accessible on the internet sites for the enterprises to fill, continues to monitor the activities of the local enterprises with the international brands and retailers. Read the letter from the TGSD board here.
İstanbul Textile and Raw Materials Exporters Association (ITHIB) evaluated the possible impacts of the pandemic on the sector at the management committee meeting that happened on 16 March. They stated that the capacity to produce medical masks and the supply of meltblown cloth – which is the raw material of the masks – were evaluated at this meeting. It was stated that Turkey has the raw material and production capacity for medical masks without a need for external sources. They also expressed that they will share the emergency action plans they have prepared with the ministries.
ITHIB stated on 24 March that they aim to produce protective clothing, gloves, one million masks a day and 40 million masks a month at the beginning, in line with the call of the ministry upon the decision taken at a joint meeting. It was also explained that a plan was drawn up in liaison with the ministries and in agreement with the enterprises to produce medical clothing, especially masks.
Following the call of ITHIB and TGSD, and as a result of the joint evaluations of the Ministry of Industry and Technology and the Ministry of Health, the enterprises for which medical mask production has been approved have started to produce one million masks daily.
Production standards for re-usable masks made of woven, knit, tricot and non-woven textiles was determined jointly by Ministry of Trade, Industry and Technology, TUBITAK, TSE, Istanbul Textile and Raw Materials Exporters’ Association (ITHIB). The Chairperson of ITHIB Management Board stated that Turkey is the third country after France and Spain which determined and implemented these standards. In a report prepared by ITHIB, besides medical masks, monthly production of cloth masks meeting these standards may reach 650 million.
The Ministry of Trade permitted the export of cloth masks for which production standards have been determined without getting the approval of the Medicine and Medical Device Institution of Turkey (TITCK). With this decision, the textile and apparel industrialists have freedom for mask exports.
ITHIB, in order to analyse the effects of the Covid-19 pandemic on the sector and to establish the necessary contact amongst the parties, started a survey open to the accession of the producers in the sector. Apart from this initiative, it prepared a very comprehensive guide concerning the measures taken in the country for the employers, including the following main areas: ‘Financial support’, ‘support concerning export procedures’ and ‘support concerning industrial relations’.
ITHIB made an announcement to its members that it has made an agreement with a law office for the settlement of disputes it faces with purchasing companies abroad. The law firm, with its own offices in seven countries and via contracted law offices in 56 countries, will provide assistance for commercial problems of the members.
Istanbul Textile and Apparel Exporters’ Association (ITKIB) published a ‘Back to Work Manual’ on 8 May 2020 under ‘Rules to be Observed During Back to Production Process within the Scope of Fight against the Covid-19 Pandemic’. The manual includes existing laws, decisions and regulations issued by the central government during the fight against the pandemic. In the manual, the measures that should be taken are explained in detail and working rules which should be observed both at the workplace as well as for employees working at home are stipulated.
Ahmet Öksüz, Chairperson of Istanbul Textile and Raw Materials Exporters’ Association (ITHIB), stated that together with the downward trend in the number of new Covid-19 cases, the business climate and exports have started to increase. During the first wave of the pandemic, the sector’s exports decreased by 50% and it started to increase again only recently. Öksüz said, ‘Short-term work allowances were of considerable support during this period. However we cannot stand a second wave. Therefore wearing a mask on the street should also be mandatory.’
Öksüz said that the textile and garments sector, following the global economic crises, a recovery period is expected and significant increases will be observed in export figures and added. He added, ‘As the textile and raw materials sector we shall be continuing our exports with new rules and new measures.’ He also stated that they are conducting projects for making improvements in many areas, from e-trade to alternative logistics channels, from virtual fairs to digitalisation.
The first response of a section of international brands was to postpone or cancel the existing orders. The suppliers are stating that they have endeavoured to persuade the brands by asking them to at least reduce the number of orders. In addition, there is also information testifying that they have tried to continue the dialogue with the brands to secure their honouring of the shipment plans. It is also known that some international brands have postponed the payment for the orders which have been already shipped.
In addition to this, some brands have agreed themselves stock the raw material that has already been purchased for now-postponed/cancelled orders. This is considered to be a positive step to reduce the damage incurred. Although it is a very rare case, there are also examples of brands which have provided support by agreeing to make earlier payments.
Provisions of relevant legal regulations – English
İlgili yasal düzenleme maddeleri – Turkish
Yıllık Ücretli İzin Yönetmeliği (Paid Annual Leave Regulation)
Kısa Çalışma Ödeneği’ne ilişkin yasal düzenlemeler (Regulations concerning short-work allowance)
İş Sağlığı ve Güvenliği’ne ilişkin yasal düzenlemeler (Regulations concerning OHS)