Initial OHS training in Poland: what it covers, how long it takes and who conducts it
How many employers let a new hire start work “right away”, with the thought “we’ll do the training later”? The Polish Labour Code answers unambiguously: the employer must ensure the employee is trained in occupational health and safety before being allowed to start work (art. 237³ § 2 of the Labour Code). And since 8 July 2026 the cost of neglecting this duty has doubled - the fine for OHS violations now reaches PLN 60,000. In this article we explain exactly what initial OHS training covers, how long it takes, who may conduct it and how to document it.
The two parts of initial OHS training
Initial OHS training in Poland always consists of two parts (§ 8 of the regulation on training in the field of occupational health and safety): general instruction (instruktaż ogólny) and job-specific instruction (instruktaż stanowiskowy). These are not two names for the same thing - they are different training courses, with different content, delivered by different people, in different places.
General instruction familiarises the employee with the basic OHS provisions of the Labour Code, collective agreements and work regulations, with the rules applicable in the given workplace and with first-aid principles (§ 9 sec. 1). It must be completed before starting work by all newly hired employees, students on internships and pupils in practical vocational training (§ 10 sec. 1).
Job-specific instruction concerns the specific work station: the work-environment factors present there, the related occupational risk, ways of protecting against hazards and methods of performing the work safely (§ 9 sec. 2). It applies primarily to employees at manual work stations and to everyone else exposed to harmful, arduous or hazardous factors (§ 11 sec. 1).
How long does initial OHS training take?
The regulation does not give a single figure, but the framework training programme (annex no. 1) sets minimums in lesson hours (45 minutes):
| Part | Minimum duration |
|---|---|
| General instruction | 3 lesson hours |
| Job-specific instruction | 8 lesson hours (2 hours for administrative and office employees exposed to arduous factors) |
For a typical manual work station this adds up to a minimum of 11 lesson hours. Importantly, this time covers more than theory - the framework programme of job-specific instruction includes, among other things, a demonstration of the work by the instructor, a trial performance of the task by the employee and independent work under the instructor’s supervision (4 hours). The duration of job-specific instruction should additionally be adjusted to the employee’s vocational preparation, length of service and the type of hazards at the station (§ 11 sec. 4) - the less experience and the more hazardous the station, the longer it takes.
Who conducts each part?
The people delivering the training differ between the two parts. General instruction is conducted by the OHS service employee, a person performing the OHS service’s duties for the employer, the employer personally (if they perform these duties themselves) or an employee designated by the employer - provided they have the knowledge and skills to properly deliver the programme and a valid certificate of completing the required OHS training (§ 10 sec. 2).
Job-specific instruction is conducted by a person managing the employees, designated by the employer, or by the employer personally - but only if they have the relevant qualifications and professional experience and have been trained in the methods of conducting job-specific instruction (§ 11 sec. 5). This is a requirement that is often overlooked: a foreman who knows the job “inside out” is not enough if they have never completed training in instruction methods.
Special situations: transfers and changed conditions
Job-specific instruction is not a one-off formality. It is repeated in three situations (§ 11): when the employee is transferred to another manual work station or one exposed to harmful factors, when technical and organisational conditions change (a change of the technological process, work-station layout, or the introduction of new machines or harmful substances), and when the employee works at several stations - in that case the employee must receive instruction at each of them.
Documentation: the initial training card
Completion of both parts is confirmed by the employee in writing in the initial training card (§ 12 sec. 1), the template of which is set out in annex no. 2 to the regulation. The card goes into the employee’s personal file. An additional quality requirement is a knowledge test: job-specific instruction ends with a test of knowledge and skills, which is the basis for allowing the employee to work at the station (§ 11 sec. 6).
Key takeaways
- Without initial OHS training the employer may not allow an employee to start work - the fine now reaches PLN 60,000, and an on-the-spot fine imposed by the labour inspectorate PLN 10,000.
- Initial OHS training consists of general instruction (min. 3 lesson hours) plus job-specific instruction (min. 8 lesson hours) before the employee starts at the work station.
- Instructors need not only knowledge but also a valid OHS training certificate (general instruction) and training in instruction methods (job-specific instruction) - the most frequently overlooked condition.
FAQ - the most common questions about initial OHS training in Poland
Can initial OHS training be done as e-learning? The regulation defines instruction as a form of training delivered at the work station and in the workplace (an introductory talk, a demonstration, a trial performance, work under supervision). For the general part other delivery forms are acceptable, but job-specific instruction by definition requires the instructor to be present at the work.
Does an office employee have to complete job-specific instruction? If harmful, arduous or hazardous factors are present at their work station - yes (§ 11 sec. 1). For office employees exposed to arduous factors, the framework programme provides a shorter version (min. 2 lesson hours).
Who may conduct general instruction? The OHS service employee, a person performing the OHS service’s duties, the employer personally, or a designated employee holding a valid certificate of completing the required OHS training (§ 10 sec. 2).
Does a re-hired employee have to complete initial training from scratch? Not always. Training before starting work is not required when the employee takes up work at the same work station with the same employer that they held immediately before concluding the next contract (art. 237³ § 2 of the Labour Code).
Does the initial training card expire? The card does not expire - it is a record of completed initial training, kept in the employee’s personal file. Deadlines concern periodic training, which comes later.
Sources
- Regulation of the Minister of Economy and Labour on training in the field of occupational health and safety - consolidated text (Journal of Laws 2024 item 1327) - ELI
- Labour Code - consolidated text (ELI)
- Act of 11 March 2026 amending the Act on the State Labour Inspectorate and certain other acts (Journal of Laws 2026 item 473) - ELI
Legal status: September 2026. This article is for information only and does not constitute legal advice. For individual cases consult a lawyer or an OHS specialist.
