Who conducts on-the-job OHS instruction in Poland? Requirements, stages and documents
When a State Labour Inspection inspector checks a company, they rarely ask outright whether initial OHS training took place - that is easy to document. Instead they dig deeper: who exactly conducted the job-specific instruction, what qualifications and experience that person had, and whether they were trained in instruction methods. If it turns out that a new employee was “shown the ropes” by someone picked at random, without the required credentials, then in the light of the regulations the initial training never took place at all - and allowing an employee to work without the required training is, under the amendment in force since 8 July 2026, an offence carrying a fine of PLN 2,000 to PLN 60,000 (art. 283 § 1 of the Labour Code).
Who conducts job-specific OHS instruction - the regulation answers directly
The answer comes from § 11 sec. 5 of the regulation on training in the field of occupational health and safety (consolidated text: Journal of Laws 2024 item 1327): job-specific instruction is conducted by a person managing employees, designated by the employer, or by the employer personally. In practice this will be a foreman, a shift leader, a department manager - someone who organises the work at a given station every day and knows it from the technical side.
The condition is single but triple in substance. The person conducting the instruction must jointly hold appropriate professional qualifications, have professional experience in the work the instruction concerns, and be trained in the methods of conducting job-specific instruction.
This third requirement is the one most often overlooked. Being a good tradesman is not enough - the designated instructor should know how to pass on knowledge step by step, how to demonstrate hazardous activities and how to correct the mistakes of the employee being trained. In companies where nobody has completed such training, the practical solution is training in job-specific instruction methods for designated persons, or support from an external OHS service at the stage of preparing the programme and the instructor.
Does the OHS service conduct job-specific instruction?
This is the most common misunderstanding in this area. The role of the occupational health and safety service begins and ends with general instruction - under § 10 sec. 2 of the regulation, it is the OHS service employee, a person performing the OHS service’s duties for the employer, or the employer who conducts the general instruction. Job-specific instruction is the domain of supervisors.
This does not mean the OHS service is redundant in the process. It can develop a detailed instruction programme for a specific work station, help the supervisor prepare for the instructor’s role and verify that the documentation is complete. But physically delivering the instruction at the machine, with a demonstration of the actual work activities, belongs to the person managing the employees - because only they can show the work as it looks every day, with the local conditions and the real hazards of the station.
Who must complete job-specific instruction
The scope of the obligation follows from § 11 sec. 1 of the regulation. Job-specific instruction must be completed, before being allowed to work, by employees hired for manual work stations and other stations where there is exposure to factors harmful to health, burdensome or dangerous, as well as employees transferred to such stations, and pupils undergoing practical vocational training and students on internships.
The regulation adds two specific situations. An employee employed at several work stations must complete the instruction at each of them (§ 11 sec. 2). And when the technical and organisational conditions at a station change - for example a new machine, a new hazardous substance or a new work organisation appears - the employee repeats the instruction, adjusted to the scope of the changes (§ 11 sec. 3).
The stages of job-specific instruction and how long it takes
The outline of the process is defined in annex no. 1 to the regulation. The instruction takes place at the actual work station, not in a training room, and covers five stages: an introductory conversation between the instructor and the employee, a demonstration and explanation of the entire work process, trial performance of the work under the instructor’s correction, independent work under supervision, and a check and evaluation of how the work is performed.
| Instruction stage | Outline time |
|---|---|
| Discussion of working conditions, hazards and the occupational risk assessment | 2 lesson hours |
| Demonstration by the instructor of how the work is performed | 0.5 lesson hour |
| Trial performance of the task under the instructor’s control | 0.5 lesson hour |
| Independent work under the instructor’s supervision | 4 lesson hours |
| Discussion and evaluation of the work performed | 1 lesson hour |
| Total | minimum 8 lesson hours |
A lesson hour is 45 minutes, so the outline minimum for manual and exposed stations is 6 clock hours of instruction. For employees of administrative and office stations exposed to burdensome factors, the outline minimum is 2 lesson hours, with the demonstration and trial-work stages omitted. The duration can be extended depending on the employee’s professional preparation, length of service and the level of hazards at the station (§ 11 sec. 4) - shortening it below the outline minimum is not allowed.
Job-specific instruction ends with a test of knowledge and skills, and a positive result is the basis for allowing the employee to work at the given station (§ 11 sec. 6). Until the test is passed, the employee is formally not ready for independent work.
How to document job-specific instruction - the card template
Confirmation of completed job-specific instruction is the initial OHS training card - its template is defined in annex no. 2 to the regulation. The job-specific instruction section of the card records the date, the subject matter and, finally, the permission to work at the given station. We describe the details of filling in and storing the card in a separate article on the initial OHS training card.
Since 12 December 2025 an amendment (Journal of Laws 2025 item 1640) has been in force here, which allowed confirmation of the completed training in electronic form alongside the previous paper form. In the electronic variant the employer places an annotation in the initial training card where the signature would go and attaches an electronic document, or a reproduction thereof, containing the confirmation of the completed training. The card - regardless of the variant - goes into the employee’s personal file.
How to designate an instructor and conduct instruction without mistakes
The whole process can be reduced to six steps worth ticking off with every new employee:
- Designate the instructor - the person managing employees at the given station, or conduct the instruction personally as the employer.
- Verify the three requirements of § 11 sec. 5: qualifications, professional experience and training in the methods of job-specific instruction.
- Develop a detailed instruction programme for the station - based on the occupational risk assessment and the outline programme from annex no. 1.
- Deliver the five stages of instruction at the work station, keeping to the minimum of 8 lesson hours (or 2 for office stations exposed to burdensome factors).
- Close with a test of knowledge and skills - only its positive result entitles you to allow the employee to work.
- Record the instruction in the initial OHS training card, obtain the signatures (or an electronic annotation) and place the card in the personal file.
Finally, remember the situations that require repeating the instruction: a transfer to another work station, a change of machine or technology, and employing one person at several stations.
Key takeaways
- Job-specific instruction is conducted by the person managing the employees, designated by the employer, or by the employer personally - provided they have the qualifications, experience and training in instruction methods.
- The OHS service conducts general instruction, not job-specific instruction - it can only provide substantive support.
- The outline minimum is 8 lesson hours (6 clock hours) for manual and exposed stations, closed with a test and an entry in the initial OHS training card.
If you are not sure whether job-specific instruction in your company is delivered and documented correctly, use our OHS outsourcing services or contact us - we will help you set up the process from designating instructors to complete documentation.
FAQ - the most common questions about job-specific OHS instruction
Who conducts job-specific OHS instruction? A person managing the employees, designated by the employer (e.g. a foreman, shift leader or manager), or the employer personally. The condition comes from § 11 sec. 5 of the OHS training regulation: appropriate qualifications, professional experience and training in the methods of job-specific instruction.
Can an OHS service employee conduct job-specific instruction? It is not their statutory role - the OHS service conducts general instruction (§ 10 sec. 2 of the regulation). For job-specific instruction the service can provide substantive support, e.g. by developing the station programme, but demonstrating the work at the station belongs to the supervisor or the employer.
How long does job-specific instruction take? The outline minimum is 8 lesson hours (a lesson hour = 45 minutes) for employees of manual stations and other stations exposed to factors harmful to health, burdensome or dangerous, and 2 lesson hours for administrative and office stations exposed to burdensome factors (annex no. 1 to the regulation).
Does job-specific instruction end with an exam? Not an exam, but a test of knowledge and skills concerning the performance of work in accordance with OHS regulations and rules (§ 11 sec. 6). A positive result of the test is the basis for allowing the employee to work at the given station.
How to document completed job-specific instruction? In writing, in the initial OHS training card (template in annex no. 2 to the regulation), which goes into the employee’s personal file. Since 12 December 2025 (Journal of Laws 2025 item 1640) confirmation in electronic form is also allowed: an annotation in the card plus an attached electronic confirmation document.
Sources
- Regulation of the Minister of Economy and Labour of 27 July 2004 on training in the field of occupational health and safety - consolidated text (Journal of Laws 2024 item 1327) - ELI
- Regulation of the Minister of Family, Labour and Social Policy of 24 November 2025 amending the regulation on training in the field of occupational health and safety (Journal of Laws 2025 item 1640) - ELI
- Act of 26 June 1974 - Labour Code - consolidated text (Journal of Laws 2025 item 277) - ELI
- State Labour Inspectorate - legal advice: OHS training
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.
