One of the most critical breaking points of occupational health and safety (OHS) practices in Türkiye is how OHS is positioned in businesses. In some organizations, OHS is treated as a management system; it's seen as a structure that reduces risks in the field, transforms behavior, and increases corporate control capacity. In some organizations, however, OHS is run with a "let the file be ready" approach. That is, the existence of OHS is measured not by the safety level in the field but by the documents to be presented at the audit.

This second approach is quite common in Türkiye. Because audit culture makes the document visible, while making the transformation in the field difficult to measure. Therefore, for many businesses, the answer to "is there OHS?" turns into "is there a file?" Risk assessment, training form, drill report, committee minutes, instructions... All of these documents are certainly necessary in terms of regulations. But the existence of documents alone doesn't mean the system is working. The real goal of OHS is not to produce paper; it's to manage risk. When risk management is not done, after a while the reality of "there are documents but there are accidents" is faced.

This article analyzes why the perception of OHS as "document" in Türkiye is so widespread, how this perception harms the business, and why organizations that complete the document with a system become stronger, with field reality.

Seeing OHS as a document often doesn't stem from bad intent. A large portion of businesses in Türkiye try to survive within intense competition and cost pressure. Within production targets, deadline pressure, staff turnover rate, subcontractor relations, maintenance delays, and daily operational rush, OHS is positioned as "an obligation that must be done." In everything seen as an obligation, a natural reflex also forms: doing the minimum.

Doing the minimum, at first glance in terms of regulations, is possible by producing documents. Because the document is a concrete and easily auditable output. Risk assessment is prepared, training signatures are collected, drills are done and reported. These processes look orderly in the file. Since the audit also often proceeds through documents, the business experiences this feeling: "There's no problem, so we must be fine." However, this is the most dangerous illusion of OHS.

We see the harm of this approach very clearly in the field. Because the purpose of OHS is not to complete paperwork but to reduce risk in the field. An OHS structure that doesn't reduce risks in the field weakens the business's "corporate control capacity" over time. The business knows the risks but can't manage them. Non-conformities enter the report but don't close. The same deficiencies recur. These repetitions become normalized after a while. Normalized risk also grows.

When an accident occurs, the existence of documents doesn't provide real protection to the business. Because evaluation mechanisms look at the actual situation: was the risk known, was precaution taken, was closure follow-up done, was it recurring? In Türkiye, this problem becomes more visible especially in outsource OHS services. Some businesses receiving OJHS service see OHS as "OJHS's job." The expert comes, writes the report, prepares the documents. The business also thinks the process is completed.

Another problem of document-oriented OHS is that it doesn't transform the behavior culture within the business. Training is given, signatures are collected. But behavior change is not followed. However, the heart of OHS is behavior. Personal protective equipment use, machine guard habit, lockout-tagout discipline, working at height reflex, subcontractor control... These change not with documents but with a system. When a system is not established, employee behavior fluctuates as "good on audit day, loose after audit."

One reason OHS gets stuck in documents in Türkiye is that "success criteria" is wrongly defined. In many organizations, the success of OHS is measured by "not getting fined at the audit." This criterion provides short-term comfort. But it doesn't produce long-term safety. The real success criterion is this: are recurring risks decreasing, are actions closing, are accidents decreasing?

"Document" is certainly necessary but not sufficient. The document is evidence of the system; it's not the system itself. Documents gain meaning with the system. Risk assessment is valuable if actions are closing. Training is valuable if it changes behavior in the field. Drills are valuable if they create crisis reflexes. Committee minutes are valuable if the implementation of decisions is followed.

Good businesses in Türkiye know this distinction clearly. They see the document as "what should be" and give their main focus to the control mechanism. Because the control mechanism transforms OHS into a management system for the business. When there's a management system, OHS becomes not a burden that hinders the business's growth but a tool that strengthens its sustainability.

EGEROBOT ISG-SIS® provides the infrastructure for this transformation. More important than automating documents, it builds the control system behind the documents. It transforms OJHS service into corporate memory, ensures actions are closed in the field, and forces management to make data-based decisions.