Does an Employer Need OHS Training in Poland?

When we plan occupational health and safety (OHS) training, we usually think about employees. That instinct is right — an employer is obliged to prepare their staff for safe work, primarily through mandatory OHS training. But there is a question that is easy to forget: what about the employer themselves? In Poland, is an OHS course for the employer mandatory, or merely good practice?

This article explains — under Polish law — who counts as an employer, which regulations require them to be trained, by when the employer’s OHS course must be completed, and exactly what its programme should cover.

Is the employer also subject to mandatory OHS training?

Let’s start with the basics: who is an employer? The term is defined in Article 3 of the Polish Labour Code (Kodeks pracy): “An employer is an organisational unit, even one without legal personality, as well as a natural person, if they employ workers.”

Article 207 § 3 of the Labour Code states that the employer must know the provisions on labour protection, including OHS rules and principles, to the extent necessary to perform their duties. This obligation is reinforced by Article 237³ § 2¹ of the Labour Code, which requires the employer to complete periodic OHS training. The answer is therefore unambiguous — yes, OHS training for the employer is mandatory in Poland.

When and how often must an employer complete OHS training?

The first OHS course for the employer must be completed within 6 months of taking up the role. The training should take the form of a course, seminar or guided self-study, and be repeated as periodic training at least once every 5 years.

In Poland, employer training is delivered by organisations authorised to provide OHS training under the Act of 7 September 1991 on the education system. In other words, the employer’s OHS course cannot be done “the quick way” — it must be carried out by an authorised provider, following an approved programme.

An employer who wants to perform OHS service tasks themselves

If an employer wishes to perform the tasks of the OHS service in their own company, additional conditions apply. This is possible when they employ up to 10 workers, or up to 20 workers and are at the same time classified in an activity group assigned no higher than the third risk category within the meaning of the Polish regulations on social insurance for accidents at work and occupational diseases. In that case the employer must hold completed OHS-service training — a course broader in scope than the standard employer OHS training.

What does the employer’s OHS training programme cover?

The periodic OHS training programme — regardless of the target group — should set out the detailed topics, the form of delivery and the duration. It is prepared by the training provider on the basis of the framework programme contained in the annex to the Regulation of the Minister of Economy and Labour on training in occupational health and safety. Importantly, the programme should be tailored to the needs, scope of tasks and duties of the employer in the given organisation.

A detailed employer OHS training programme should include the following:

1. Sources of law, including the basic principles of labour law and international law (ILO conventions, EU directives).
2. Rights and obligations of employees regarding occupational health and safety.
3. Rights and obligations of employers regarding occupational health and safety.
4. Duties of persons who manage employees.
5. Liability for breaching OHS regulations and rules.
6. Protection of the work of women and young workers.
7. The employer’s duties in the preventive health care of employees.
8. OHS training — a discussion of the Regulation of the Minister of Economy and Labour of 27 July 2004 on training in occupational health and safety.
9. Supervision and inspection of working conditions by the competent bodies: state authorities (in Poland, the State Labour Inspectorate — PIP), trade-union and administrative supervisory bodies.
10. Hazard identification and assessment — occupational risk assessment and the identification of dangerous and harmful factors present in the work process.
11. Classification of dangerous and harmful factors present in the work process according to the nature of their action: chemical, physical, biological and psychophysical factors.
12. Occupational risk assessment associated with those hazards.
13. Organisation and methodology of OHS training (including on-the-job instruction methods) and the shaping of safe employee behaviour in work processes.
14. Issues of fire protection and protection of the natural environment.

As you can see, the knowledge delivered during an employer’s OHS course is genuinely broad. It underlines how important it is for everyone in the organisation — from employees to top management — to understand occupational health and safety.

Have questions about the timing, format or programme of an employer’s OHS course in Poland? Contact us — we will match the training to your company’s specifics and help you keep on top of the mandatory deadlines.